of what real exposure can be here. vladimir putin may have been gifted an apartment in this development deal maybe give him a cut of the action, it matters to you, why? >> the foreign corrupt practices act is serious. you don't have to fully transact the deal, you just have to offer it, if you're offering something of value, to get something of value, you are in violation of the foreign corrupt practices act it would be hard for anyone to argue you didn't give something of value to the president of russia to get approved a building to have some value there. that's against the law. >> what's the difference between a corrupt practice and a business deal? >>. >> when you're dealing overseas, you cannot offer something of value. the aren't u.s. does this is to promote u.s. values over seas.