definiens: ( as such term is defined in the FCPA ) or any foreign po litical party or official thereof or any candidate for foreign political office, in contravention of the FCPA or o ther anti - bribery law, ( ii ) using any corporate fun ds for any illegal contributions, gifts, entertainment or othe r unlawful expenses relating to political activity, ( iii ) maintaining any fund of corporate monies or o ther properties for the purpose of supplying funds for any of the unlawful purposes described in the foregoing cl auses, or ( iv ) making any bribe, unlawful rebate, p ayoff, influence payment, kickback or other similar unlawf ul payment of any nature . Neither the Seller nor an y Affiliate of the Seller, nor, to the Knowledge of t he Seller, any of their respective officers, direct ors, or employees ( i ) is currently the subject of, nor has it been since January 1, 2014, the subject of, any Action alleging a violation, or possible violation, of any Anti - Corruption Laws, or since January 1, 2014, th e recipient of a subpoena, letter of investigation or other doc ument alleging a violation, or possible violation, of any Anti - Corruption Law, or ( ii ) has, since January 1, 2014, improperly or inaccurately recorded in any Busines s Books and Records ( A ) any payments, cash, contributions, gifts, hospitalities or entertainment to a foreign or domestic government official, employee of an enterprise owne d or controlled in whole or in part by any foreign government, official of a foreign or domestic polit ical party or campaign, or a foreign or domestic ca ndidate for political office ; or ( B ) other expenses related to political activity or lobbying, in each case, in vi olation of applicable Law