This could be a violation of the FCPA provisions. The XYZ company should do their due diligence to establish a FCPA compliance before entering a potential business relationship with the Chinese officials. The form of payment in terms of flying the Chinese officials to the US on a corporate jet for tours and meetings in the US facilities may be construed as payments to retain and obtain business of a foreign official. In any event, XYZ can record the trip in its books as long as information are accurately recorded in a reasonable detail mean as it “would satisfy prudent officials in the conduct of their own affairs” (Compliance Issues in the Life Sciences: Fraud and Corruption
