Have violations of the FCPA occurred in this situation?

While at the trade show in Beijing, Dynamic Products Co. decides it wants to invite some executives from one of China’s state-owned utilities to the United States to engage in talks about a lucrative contract with the utility on which it plans to make a bid. DP desperately wants the contract and offers to fly the officials and their wives first class to the United States and put them up at Augusta, Georgia’s nicest hotel for a week and offers them tickets to The Master’s, one of the premier golf events in the world. On the final day of their visit, DP organizes a meeting at which they discuss the possible contract.

Have violations of the FCPA occurred in this situation?

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