candidate to use his or its influence with a foreign government or present enforcement policy regarding the preceding provisions of this instrumentality thereof to affect or influence any act or decision of section. The Attorney General shall issue the guidelines and procedures such government or instrumentality, in order to assist such issuer in referred to in the preceding sentence in accordance with the provisions obtaining or retaining business for or with, or directing business to, of subchapter H of chapter 5 of Title 5 and those guidelines and proce- any person. dures shall be subject to the provisions of chapter 7 of that title. (b) Exception for routine governmental action (e) Opinions of Attorney General Subsections (a) and (g) of this section shall not apply to any facilitat- (1) The Attorney General, after consultation with appropriate depart- ing or expediting payment to a foreign official, political party, or party ments and agencies of the United States and after obtaining the views official the purpose of which is to expedite or to secure the perfor- of all interested persons through public notice and comment pro- mance of a routine governmental action by a foreign official, political cedures, shall establish a procedure to provide responses to specific party, or party official. inquiries by issuers concerning conformance of their conduct with the Department of Justice’s present enforcement policy regarding the pre- (c) Affirmative defenses ceding provisions of this section. The Attorney General shall, within 30 days after receiving such a request, issue an opinion in response It shall be an affirmative defense to actions under subsection (a) or (g) to that request. The opinion shall state whether or not certain speci- of this section that— fied prospective conduct would, for purposes of the Department of Justice’s present enforcement policy, violate the preceding provisions (1) the payment, gift, offer, or promise of anything of value that was of th