Has a violation of the FCPA occurred in this situation?

Following are some hypothetical situations that involve payments while doing international business. Do these represent bribes, which are illegal under the Foreign Corrupt Practices Act (FCPA) or are they “grease payments” intended to facilitate work getting done?

Situation 1

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Healthy Forever, an infant formula manufacturer, has a subsidiary in Korea. The subsidiary makes payments to health-care professionals to get them to recommend Healthy Forever’s products to new and expectant mothers.

Has a violation of the FCPA occurred in this situation

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