SRU sells degrees to USSS agent posing as highschool dropout

galanga · Aug 28, 2005

More material from the affidavit:

Secret Service’s First Undercover Purchase of a “Degree” via the Internet

34. On 2/28/05, SA Ross, acting in an undercover (U/C) capacity and using a U/C computer, made contact with "James Monroe University High School" via their website at www.jamesmonroeuniversity.ac/jmu_admissions.html. At this internet site, SA Ross, using a U/C alias of 18 year old Jeffrey Rowley, was solicited/prompted to complete an "assessment of competency." Shortly after completing the "James Monroe University High School" online form, SA Ross received an e-mail on his U/C e-mail account at [email protected]. This e-mail was from forward1@university services.net. The e-mail SA Ross received invited him to take a free online exam to test for SA Ross' qualifications to receive a High School Diploma and/or Associate of Arts Degree. The e-mail requested SA Ross to go to www.university-services.net/james_sre/high_school/test.html to take the test.

35. On 2/28/05, SA Ross clicked on the link that had been forwarded to the Rowley U/C e-mail account and took a test consisting of approximately 125 questions. Out of the approximately 125 questions, SA Ross was confident of the correct answers for the majority of the 125 questions. However, SA Ross purposefully answered approximately 75% of the questions incorrectly in order to judge the integrity of the test's scoring system. After completing the questions, the web site indicated that SA Ross had tested to the equivalency of a 3.1 Grade Point Average for High School, and a 3.2 Grade Point Average for an AA college degree. The site then solicited SA Ross (as Jeffery Rowley) to purchase any number of potential diploma packages including false transcripts, degrees, and supporting documents. Utilizing a U/C credit card account for alias Jeffery Rowley, SA Ross purchased "transcripts" for both High School and an AA degree, a High School "diploma", an AA degree, and supporting documents of accreditation verification. SA Ross' U/C credit account was subsequently charged $399.00 via a PayPal online charging service.

Interview of DHL Employees – Rowley “Degree” Shipped from Suite 8B

36. On 3/1/05, SA Ross met with Thomas Hall, Mike Carpine and Nate Reed, managers from DHL Shipping Corporation at their main office for the Eastern Washington/Northern Idaho region. District Manager Nate Reed conducted numerous computerized record searches pertaining to the DHL account registered to "A + Institute", and to the shipping records assigned to “A + Institute's" DHL account. DHL records indicated that "A + Institute" shipped approximately 60 packages per month for the months of January and February 2005. Records indicated that approximately 40% of those shipments were international shipments and 60% were domestic U.S. shipments. Each of the three managers that SA Ross met with were quite familiar with the "A + Institute" account because they are a "high volume daily shipper." According to the DHL supervisory team, the "A + Institute" account largely ships "document" packages as opposed to larger box oriented shipments. The DHL team further informed SA Ross that this account has shipped at approximately the same volume from the Post Falls address since September of 2004. The DHL supervisory team stated that prior to September 2004, the "A + Institute" account had a different primary address of 14525 N. Newport Hwy, Mead, Washington. DHL agreed to begin to make copies of the shipping information for all packages being shipped out of "A + Institute" at 601 E. Seltice, Post Falls. Finally, during this same meeting SA Ross informed the DHL supervisory team that SA Ross is expecting a specific package to be shipped from "A + Institute", sent to the undercover alias of Jeffery Rowley. DHL agreed to intercept this shipment and notify SA Ross immediately upon receipt.

37. On 3/4/05, SA Ross received a telephone message from Thomas Hall, DHL Supervisor, informing him that they had received a shipped package sent from "A + Institute" in Post Falls to SA Ross' undercover alias Jeffery Rowley.

38. On 3/5/05, SA Ross responded to DHL's shipping office on Airport Way, Spokane, WA. SA Ross took possession of a package that had been shipped from "A + Institute", 601, E. Seltice 8B, Post Falls Idaho, which was intended to be shipped to SA Ross’s U/C alias, Jeffery Rowley, in Minneapolis, MN. SA Ross reviewed the contents of the shipment and found that it contained two folders. The first folder contained a "diploma" and "transcript" from "James Monroe University High School" awarded to Jeffery Rowley showing that Rowley had successfully achieved his high school diploma. SA Ross noted that the false "transcript" represented that Rowley had attended four years of schooling at "James Monroe University High School" despite the fact that SA Ross (as U/C Rowley) had informed the "school" that SA Ross had not completed four years of high school. The second folder contained both a "transcript" and an "AA degree" from "James Monroe University" awarded to Jeffery Rowley indicating that Rowley had fulfilled an Associate College degree. All of the documents appeared official and bore various "seals", signatures of "school officials", etc. All of these diploma, degree, and transcript documents were shipped to SA Ross by "James Monroe University", from "A + Institute" after SA Ross (acting as Jeffery Rowley) had simply taken a single 20 minute test, scoring approximately 25% correct on the test, attended no classes, and paid $399.00 with a credit card.
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...continued next post...

galanga · Aug 28, 2005

Rowley, part 2...

...continued from previous post...

Secret Service’s Third Undercover Purchase of a “Degree” via the Internet

43. On 3/15/05, SA Ross, acting under his other U/C alias Jeffrey Rowley, e-mailed his "advisory contact" at “James Monroe University.” SA Ross, using the e-mail account of U/C alias Jeffrey Rowley, electronically requested to be considered for a Bachelor's degree, in addition to the High School and Associates degrees that Rowley had already received via "James Monroe University." SA Ross submitted via e-mail a short synopsis including two years of work experience working at a movie theater as well as multiple years as a newspaper boy. SA Ross also stated via e-mail that U/C alias Rowley had completed almost one year of home study after SA Ross had dropped out of high school.

44. On 3/16/05, SA Ross, acting under the U/C alias Jeffery Rowley, received an e-mail communication at [email protected] from the "James Monroe University" "advisor" confirming that he was eligible to receive a Bachelor's degree from "James Monroe University." The context of the e-mail was exactly the same as had been sent to U/C alias Anthony Gwynn. The e mail from forward1@university services.net stated that Rowley qualified for a Bachelor of Arts degree based solely on the fact that he was purportedly an eighteen year old high school dropout who had paid recently for a bogus High School and AA degree through "James Monroe University."

45. On 3/17/05, SA Ross was telephonically contacted by DHL Field Supervisor Mike Carpine who informed him that he had successfully intercepted a package shipped from "A + Institute," A. Hensley, 601 E. Seltice Way, Post Falls, ID to the U/C alias Anthony Gwynn in San Diego, California. SA Ross informed Carpine that USSS Resident Agent In Charge (RAIC) Kevin Miller would pick up the package on 3/18/05.

46. On 3/18/05, RAIC Miller responded to the DHL Field Office on Airport Way in Spokane, Washington and took possession of the aforementioned intercepted package which had been shipped by "A + Institute" to Anthony Gwynn, 7411 Gowen Place, San Diego, California. The package, for which U/C alias Anthony Gwynn had paid $2,454 included:
A "degree" indicating U/C alias Anthony Gwynn had obtained a BA in Business Administration from "James Monroe University;"
"Official transcripts" from “James Monroe University” falsely representing that Anthony Gwynn had taken four full years worth of college classes;
-A document entitled “Degree Authentication Attestation” representing that “Richard Novak, Director of the University Services, Inc., and the Registrar of the James Monroe University, hereby solemnly declare and certify that the Degree of Bachelor of Arts in Major(s): Business Administration and the Transcript with all other documents for: Anthony Aaron Gwynn are fully earned, accredited and granted;”
-A document entitled “Dean’s List Certificate of Achievement” and awarded by “James Monroe University” to Anthony Gwynn.
A “James Monroe University” academic records summary for Anthony Gwynn certifying a 3.36 grade point average.

-A laminated “Alumni ID Card” in the name of Anthony Aaron Gwynn from “James Monroe University.”

47. On 4/1/05, SA Ross, working in a U/C capacity as Jeffery Rowley, completed the aforementioned transaction offered by “James Monroe University” to complete a Bachelor’s degree. SA Ross linked to the following internet link as provided by his “advisors” from “James Monroe”: www.university-services.net/jamesmonroe/rev/worldpay_ja.html. At the listed internet site, SA Ross purchased a “Bachelors of Pre-Law” using Confidential Funds, as well as various associated documents including associated “transcripts” and “letters from University Staff”. The entire purchase cost $1,173.00 from the U/C Rowley Account. It should be noted that this purchase completed a transaction for U/C identity “Jeffery Rowley” in which Rowley was allowed by “James Monroe University” to purchase a High School Diploma, followed immediately by an “AA degree” and then a “Bachelor’s Degree in Pre-Law” despite his being an 18 year old high school dropout with limited work history. [my emphasis]

48. On 4/8/05, SA Ross received a telephone call from Mike Carpine, DHL Supervisor, who informed SA Ross that the expected document package from A + Institute sent to the U/C alias “Jeffery Rowley” had been intercepted and would be held for pickup by the Secret Service at the DHL Field Office. The fraudulent documents were subsequently picked up by SA Ross at the DHL Field Office.

49. On 4/11/05, SA Ross reviewed and inventoried the newest aforementioned package sent to the U/C alias of Jeffery Rowley. The shipment of documents, for which “Jeffery Rowley” had paid $1173.00 included:
- Two official copies of “degrees”, BA in Pre-Law from “James Monroe University”
- “Official transcripts” for four full years worth of college classes which never occurred.
- Numerous supporting letters and documents from the “administration” at “James Monroe University”.

Verification of Rowley Degree through OTAC (Official Transcript Archive Center)

50. On 5/3/05, SA Ross placed a recorded telephone call to (208) 777-9704. The phone was answered by an individual identifying herself initially as “OTAC”. SA Ross, acting in an undercover capacity identified himself as “Bob Winthrop” from the Transportation Security Administration (TSA). SA Ross indicated that he had received a job application from a person named Jeffery Rowley who was applying to be a baggage screener for TSA (Note: Jeffery Rowley is the identity of SA Ross’ previously established U/C role to obtain multiple fraudulent degrees/diplomas from James Monroe University). SA Ross stated that he was calling “OTAC” to verify the academic credentials as listed on Jeffery Rowley’s application. The woman at “OTAC” identified herself as “Jennifer Greene” (verified spelling). When questioned, she stated that she is located in Delaware. However, Detective Bryan Tafoya, Spokane Police Department, subsequently listened to the recorded conversation and determined that the voice of “Jennifer Greene” was remarkably similar to the voice of Robert Markishtum, who Detective Tafoya interviewed at Suite 8B in Post Falls, Idaho. Ms. “Greene” indicated that she was looking into her computer database to query for Jeffery Rowley. “Greene” then confirmed that Rowley was indeed a student and had achieved both an AA degree as well as a BA in Pre Law from “James Monroe University.” When questioned by SA Ross about speaking to professors or to an advisor, Ms. “Greene” stated that she would locate an appropriate individual to speak with and would have that person call “Bob Winthrop”. SA Ross provided a telephone number for a return phone call to “Bob Winthrop”.

51. On 5/9/05, in response to a subpoena, Verizon Legal Compliance, San Angelo, TX, indicated that number (208) 777-9704 rolls over to a main number of (208) 777-9707, and is billed to AEIT at 601 E. Seltice Way, B-8, Post Falls, ID.

52. On 5/19/05, acting in an undercover capacity, SA Ross placed a recorded telephone call to (208) 777-9704. The phone was answered by an individual identifying herself initially as “OTAC”, and later identified as “Jennifer Greene.” SA Ross, again identified himself as “Bob Winthrop” from the Transportation Security Administration. “Greene” again stated that she was located in Delaware, despite the fact that SA Ross knowingly called a phone number registered in Post Falls, Idaho. SA Ross asked “Greene” if “James Monroe University” is fully accredited, to which “Greene” responded that it is. SA Ross further inquired as to whether or not “James Monroe University” is the same, or equivalent to, the well known on-line University of Phoenix. “Greene” responded that “James Monroe University” is equivalent in accreditation to the University of Phoenix. SA Ross also questioned “Greene” about the course work and degree program at “James Monroe University.” He asked “Greene” if students who receive a degree from “James Monroe University” are required to take individual classes/courses, and take tests and complete study programs for each class. “Greene” answered affirmatively, that the on-line “James Monroe University” program does require full course work for each class and degree program.
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Guest · Aug 28, 2005

Galanga:

to Anthony Gwynn,
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A baseball fan no doubt!

BillDayson · Aug 28, 2005

You know Galanga, this is extraordinary.

I don't know that there has ever been anything quite like this.

The exotic assortment of schools. The weird offshore accreditation and the almost-successful attempt to scam 'GAAP'. Abdullah K. ("nah, I'm a diplomat") Dunbar. Factions struggling for control of the Liberian embassy. Visits to war-torn African capitals with bags full of cash. The all-star supporting cast (one that's a veritable who's-who of mill operators). Credential evaluators. Apostiles. UNESCO listings. Pakistan. Bangalore. Seborga (whatever that is). Head transplants. Fast track one-paragraph 'theses'. Pecking pigeons. NBOE. Accreditation resellers. Affiliate schools. 'Marketing entities'. Greedy Georgia teachers. Subpoenas. Grim faced Secret Service agents in their suits and shades. Even multiple homeland security angles.

Degreeinfo's more exciting than television!

Considering all the very shady people who seem to have been at least tangentially associated with the SRU empire, and the extensive contacts with others in the degree-mill business that SRU's operators appear to have, my guess is that lots of disreputable people are very concerned right about now, wondering what damaging information about them might have fallen into the Feds' hands.

Things have definitely moved into phase two. What will be interesting now is to see how far it all unravels. The Feds certainly seem to be taking it seriously and are devoting resources to it.

Jake_A · Aug 28, 2005

posted by BillDayson
Degreeinfo's more exciting than television!
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Yes, oh, yes!

Finally, reality TV that is worth watching!

galanga · Aug 28, 2005

the thing that is an adult female canine

Originally posted by BillDayson
You know Galanga, this is extraordinary...
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Think of it from the pespective of the guy whose 16-year-old daughter is sent messages like these:

Your daddy is a stupid bald f--k
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and

Talk about smelling like manure...P.U. bitch, wash that thing now and then. I'd rather stick my tongue in a toilet.
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Now recall that the first court documents that were released concerned the intended seizure of a particular house and surrounding property in Colbert, Washington. Further, it is likely that the obscene messages bear some connection to the activities of the occupants-for-now of the Colbert house.

And it goes on from there.

uncle janko · Aug 28, 2005

Bill said what I felt better than I could have done.
This is splendid, simply grand, and like a sea of glory.

DaveHayden · Aug 28, 2005

Re: the thing that is an adult female canine

Originally posted by galanga
Think of it from the pespective of the guy whose 16-year-old daughter is sent messages like these:andNow recall that the first court documents that were released concerned the intended seizure of a particular house and surrounding property in Colbert, Washington. Further, it is likely that the obscene messages bear some connection to the activities of the occupants-for-now of the Colbert house.

And it goes on from there.
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George

I am sorry anyone has to go through the harassment these frauds have (and continue to) put you and your family through. No one should have to deal with the kinds of things they have said. Like others I value and appreciate the important work you have done to close down these mills.

Bill Huffman · Aug 28, 2005

George I'm very sorry that you and your family were put through this kind of nonsense. Their intended purpose was obviously to get you to decide that it wasn't worth the personal pain and to stop putting the pressure on them. You took the course of self sacrifice and helped teach the wicked bully a lesson for the far greater good. You have my deepest respect. When one knows that the academic frauds are part of the lowest class of despicable humans walking the planet, it makes their capture and punishment even more satisfying.

uncle janko · Aug 28, 2005

Yes, this too.

This is the sort of contemptible stuff that turned me from a ridiculer of mills and shills into an utter enemy of them. Now, the consternation over at the salon des refuses is general, as is the rejoicing here. But nobody should ever forget for one damn moment the kind of sheer hell these weasels and their (even yet!) defenders tried to inflict on a young girl and an honourable lady and the dignified paterfamilias.

When I explained to my ecclesiastical superiors the Spokane Raid and its significance, what stunned them was not the venality of the millists and shills but their sheer viciousness. What this board is, is a triumph of civil society. What people like galanga and his family are, are heroes of civil society.

Die Familie Galanga: Hoch! Dreimal hoch!

Jack Tracey · Aug 28, 2005

Thanks George. I admire your perseverance in the face of adversity. I am sorry that your daughter had to learn, at such a young age, the depths to which humanity can sink. Hopefully, she will be smarter and stronger as a result. Thanks again.
Jack

bullet · Aug 28, 2005

SWORD

Dr. G,

You are beyond a doubt a BIG MAN.

If some trash wrote something like that to my daughter I would beat the ^^^^ outta them and drink their sangre with whiskey.

G-D speed to you.

Originally posted by galanga
Think of it from the pespective of the guy whose 16-year-old daughter is sent messages like these:andNow recall that the first court documents that were released concerned the intended seizure of a particular house and surrounding property in Colbert, Washington. Further, it is likely that the obscene messages bear some connection to the activities of the occupants-for-now of the Colbert house.

And it goes on from there.
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galanga · Aug 28, 2005

Re: SWORD

Originally posted by bullet
Dr. G...
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Why thank you! But tell me... would you rather punch them out yourself or watch federal, state, and local enforcement agencies do the things that they seem to be planning to do? In particular, matters relating to this (taken from the affidavit):

Overview of Scheme

3. Fraudulent high school and college “degrees” are being sold over the internet to people throughout the United States and the world by various entities, including “Saint Regis University”, “James Monroe University”, “Robertstown University”, “Trinity Christian School” and others. As shown below, Dixie Ellen Randock, Steven Karl Randock (also known as Steven Randock, Sr., Steven Randock, and Steve Randock), Heidi Kae Lorhan, Amy Leann Hensley, Richard John Novak (also known as Rick Novak), Blake Alan Carlson, Roberta Lynn Markishtum and others are involved in manufacturing and selling fraudulent “degrees” to consumers over the internet using various entities. Depending on the type of “degree” a consumer wants to obtain, the suspects, through one or more of the websites registered either in their name or in the name of a nominee, charge fees from $399.00 to in excess of $2,454.00 per “degree” and accompanying documents. The “degrees” are then shipped or mailed via interstate carrier or the United States Postal Service to the purchasers. As shown below, the fees generated by the sale of fraudulent degrees and academic credentials are being laundered through one or more domestic and offshore bank accounts. Some of the foreign bank accounts which are being used to launder the proceeds of their wire fraud activity are/or were located offshore, in the islands of Dominica and St. Vincent, West Indies.
To further the scheme and to create the appearance that the “degrees” they have sold to consumers over the internet are legitimate, Dixie and Steven Randock and others have set up “accreditation” and “transcript verification” fronts.

Statutes Involved

4. Title 18, United States Code, section 1341, (Frauds and swindles) provides:

Whoever, having devised or intending to devise any scheme or artifice to defraud, or for obtaining money or property by means of false or fraudulent pretenses, representations, or promises, or to sell, dispose of, loan, exchange, alter, give away, distribute, supply, or furnish or procure for unlawful use any counterfeit or spurious coin, obligation, security, or other article, or anything represented to be or intimated or held out to be such counterfeit or spurious article, for the purpose of executing such scheme or artifice or attempting so to do, places in any post office or authorized depository for mail matter, any matter or thing whatever to be sent or delivered by the Postal Service, or deposits or causes to be deposited any matter or thing whatever to be sent or delivered by any private or commercial interstate carrier, or takes or receives therefrom, any such matter or thing, or knowingly causes to be delivered by mail or such carrier according to the direction thereon, or at the place at which it is directed to be delivered by the person to whom it is addressed, any such matter or thing, shall be fined under this title or imprisoned not more than 20 years, or both. If the violation affects a financial institution, such person shall be fined not more than $1,000,000 or imprisoned not more than 30 years, or both.

5. Title 18, United States Code, section 1343, (Fraud by wire, radio, or television) provides:

Whoever, having devised or intending to devise any scheme or artifice to defraud, or for obtaining money or property by means of false or fraudulent pretenses, representations, or promises, transmits or causes to be transmitted by means of wire, radio, or television communication in interstate or foreign commerce, any writings, signs, signals, pictures, or sounds for the purpose of executing such scheme or artifice, shall be fined under this title or imprisoned not more than 20 years, or both. If the violation affects a financial institution, such person shall be fined not more than $1,000,000 or imprisoned not more than 30 years, or both.

6. Title 18, United States Code, section 1956, (Laundering of monetary instruments) provides, in part:

(a)(1) Whoever, knowing that the property involved in a financial transaction represents the proceeds of some form of unlawful activity, conducts or attempts to conduct such a financial transaction which in fact involves the proceeds of specified unlawful activity—
(A)(i) with the intent to promote the carrying on of specified unlawful activity; or

(ii) with intent to engage in conduct constituting a violation of section 7201 or 7206 of the Internal Revenue Code of 1986; or
(B) knowing that the transaction is designed in whole or in part—
(i) to conceal or disguise the nature, the location, the source, the ownership, or the control of the proceeds of specified unlawful activity; or
* * *
shall be sentenced to a fine of not more than $500,000 or twice the value of the property involved in the transaction, whichever is greater, or imprisonment for not more than twenty years, or both.

(2) Whoever transports, transmits, or transfers, or attempts to transport, transmit, or transfer a monetary instrument or funds from a place in the United States to or through a place outside the United States or to a place in the United States from or through a place outside the United States—
(A) with the intent to promote the carrying on of specified unlawful activity; or
(B) knowing that the monetary instrument or funds involved in the transportation, transmission, or transfer represent the proceeds of some form of unlawful activity and knowing that such transportation, transmission, or transfer is designed in whole or in part—
(i) to conceal or disguise the nature, the location, the source, the ownership, or the control of the proceeds of specified unlawful activity; or
(ii) to avoid a transaction reporting requirement under State or Federal law,
shall be sentenced to a fine of not more than $500,000 or twice the value of the monetary instrument or funds involved in the transportation, transmission, or transfer, whichever is greater, or imprisonment for not more than twenty years, or both.
* * *

(c)(7) the term “specified unlawful activity means—
(A) any act or activity constituting an offense listed in section 1961 (1) of this title. . .

(18 U.S.C. § 1961(1) lists both § 1341 mail fraud and § 1343 wire fraud.)

7. Title 18, United States Code, section 1957, (Engaging in monetary transactions in property derived from specified unlawful activity) provides:

(a) Whoever, in any of the circumstances set forth in subsection (d), knowingly engages or attempts to engage in a monetary transaction in criminally derived property of a value greater than $10,000 and is derived from specified unlawful activity, shall be punished as provided in subsection (b).
(b) (1) Except as provided in paragraph (2), the punishment for an offense under this section is a fine under title 18, United States Code, or imprisonment for not more than ten years or both.
(2) The court may impose an alternate fine to that imposable under paragraph (1) of not more than twice the amount of the criminally derived property involved in the transaction.
(c) In a prosecution for an offense under this section, the Government is not required to prove the defendant knew that the offense from which the criminally derived property was derived was specified unlawful activity.
(d) The circumstances referred to in subsection (a) are—
(1) that the offense under this section takes place in the United States or in the special maritime and territorial jurisdiction of the United States; or
(2) that the offense under this section takes place outside the United States and such special jurisdiction, but the defendant is a United States person (as defined in section 3077 of this title, but excluding the class described in paragraph (2)(D) of such section).

(e) Violations of this section may be investigated by such components of the Department of Justice as the Attorney General may direct, and by such components of the Department of the Treasury as the Secretary of the Treasury may direct, as appropriate and, with respect to offenses over which the United States Postal Service has jurisdiction, by the Postal Service. Such authority of the Secretary of the Treasury and the Postal Service shall be exercised in accordance with an agreement which shall be entered into by the Secretary of the Treasury, the Postal Service, and the Attorney General.
(f) As used in this section—
(1) the term “monetary transaction” means the deposit, withdrawal, transfer, or exchange, in or affecting interstate or foreign commerce, of funds or a monetary instrument (as defined in section 1956 (c)(5) of this title) by, through, or to a financial institution (as defined in section 1956 of this title), including any transaction that would be a financial transaction under section 1956 (c)(4)(B) of this title, but such term does not include any transaction necessary to preserve a person’s right to representation as guaranteed by the sixth amendment to the Constitution;
(2) the term “criminally derived property” means any property constituting, or derived from, proceeds obtained from a criminal offense; and
(3) the term “specified unlawful activity” has the meaning given that term in section 1956 of this title.
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(continued next post)

galanga · Aug 28, 2005

...continued

...continued from last post

8. Title 15 United States Code, § 78dd-2 (Prohibited Foreign Trade Practices) provides:

(a) Prohibition

It shall be unlawful for any domestic concern, other than an issuer which is subject to section 78dd 1 of this title, or for any officer, director, employee, or agent of such domestic concern or any stockholder thereof acting on behalf of such domestic concern, to make use of the mails or any means or instrumentality of interstate commerce corruptly in furtherance of an offer, payment, promise to pay, or authorization of the payment of any money, or offer, gift, promise to give, or authorization of the giving of anything of value to
(1) any foreign official for purposes of

(A)(i) influencing any act or decision of such foreign official in his official capacity, (ii) inducing such foreign official to do or omit to do any act in violation of the lawful duty of such official, or (iii) securing any improper advantage; or

(B) inducing such foreign official to use his influence with a foreign government or instrumentality thereof to affect or influence any act or decision of such government or instrumentality, in order to assist such domestic concern in obtaining or retaining business for or with, or directing business to, any person;

(2) any foreign political party or official thereof or any candidate for
foreign political office for purposes of–

(A)(i) influencing any act or decision of such party, official, or candidate in its or his official capacity, (ii) inducing such party, official, or candidate to do or omit to do an act in violation of the lawful duty of such party, official, or candidate, or (iii) securing any improper advantage; or

(B) inducing such party, official, or candidate to use its or his influence with a foreign government or instrumentality thereof to affect or influence any act or decision of such government or instrumentality, in order to assist such domestic concern in obtaining or retaining business for or with, or directing business to, any person; or

(3) any person, while knowing that all or a portion of such money or thing of value will be offered, given, or promised, directly or indirectly, to any foreign official, to any foreign political party or official thereof, or to any candidate for foreign political office, for purposes of

(A)(i) influencing any act or decision of such foreign official, political party, party official, or candidate in his or its official capacity, (ii) inducing such foreign official, political party, party official, or candidate to do or omit to do any act in violation of the lawful duty of such foreign official, political party, party official, or candidate, or (iii) securing any improper advantage; or

(B) inducing such foreign official, political party, party official, or candidate to use his or its influence with a foreign government or instrumentality thereof to affect or influence any act or decision of such government or instrumentality,
in order to assist such domestic concern in obtaining or retaining business for or with, or directing business to, any person.
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So that's what may land on their heads.

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