Big Mining Corp. (BMC), a major company listed on the New York Stock Exchange, recently discovered a quartz deposit in Kuwait. To get access to the deposit, BMC needs to construct a road from the deposit site to the nearest port. BMC hires an agent to help it get this job done, especially the securing of the required permits and documents from government officials. The agent informed BMC that he will need to make a small cash payment to an administrative clerk in Kuwait so that he will process the permit application speedily. In their previous experiences, BMC learned that permit approvals such as this could take months to get approved. BMC's director of projects is anxious to get the road permit approved, so she gives the agent permission to make the payment to the clerk. Is this payment a violation of the FCPA?