Charles Is Working as a Representative on Behalf of His

Charles is working as a representative on behalf of his company to close a deal with a company based on China. He knows that gifts are welcome when doing business in China and he wants to respect the customs as well as make good impression to help build a relationship. The company in China is connected to the Chinese government, and Charles knows that he could sway the company in his favor if he reaches out to his connection in the government and offers an incentive. If Charles did this, he would be in violation of the Foreign Corrupt Practices Act because

A) it could be viewed as a bribe even though it is acceptable in Chinese culture
B) Charles works for an American company
C) a foreign official would be involved
D) all of the above