opinion/2004/0401.pdf; US. DEPT. OF JUSTICE, FCPA Op. RELEASE them as “payments which merely movea particular matter toward an 96-01 (Noy. 25, 1996) (travel, lodging, and meal expenses of regional eventual act or decision or which do not involve any discretionary action,” government representatives to attend training courses in United giving the examples of “a gratuity paid to a customs official to speed the States), available at http: //wwwjustice.gov/ criminal/fraud/ fepa/ processing ofa customs document” or “payments made to secure permits, opinion/ 1996/9601 .pdf; US. DEPT. OF JUSTICE, FCPA Op. RELEASE licenses, or the expeditious performance of similar duties of an essentially 92-01 (Feb. 1992) (training expenses so that foreign officials could ministerial or clerical nature which must of necessity be performed in any effectively perform duties related to execution and performance of joint- event.” H.R. Rep. No. 95-640, at 8. venture agreement, including seminar fees, airfare, lodging, meals, and '6l Section 30A(f)(3)(B) of the Exchange Act, 15 US.C. § 78dd-1(f)(3) ground transportation), available at http://www,justice.gov/criminal/ (B); 15 US.C. §§ 78dd-2(h) (4)(B), 78dd-3(£)(4)(B). fraud/fcpa/review/ 1992/1920 1.pdf. 182 Tn a 2004 decision, the Fifth Circuit emphasized this precise point, 47 US, DEPT. OF JUSTICE, FCPA Op, RELEASE 11-01 (June 30, 2011); commenting on the limited nature of the facilitating payments exception: US. DEPT. OF JUSTICE, FCPA Op, RELEASE 07-02 (Sept. 11, 2007); A brief review of the types of routine governmental US. Dept. oF JusTICE, FCPA Op, RELEASE 07-01 (July 24, 2007); actions enumerated by Congress shows how limited US. DepT. oF JusTICE, FCPA Op. RELEASE 04-04 (Sept. 3, 2004); US. Congress wanted to make the grease exceptions. Dept. oF JUSTICE, FCPA Op. RELEASE 04-03 (June 14, 2004); US. Routine governmental action, for instance, includes Dept. oF JusTICE, FCPA Op. RELEASE 04-01 (Jan. 6, 2004). “obtaining permits, licenses, or o