Since I was dealing with compliance, FCPA and such for the last 15 years, here are my two cents:
- in case people involved in the unethical behavior are either employees of Visa OR employees of Visa subsidiaries, joint ventures or partnerships, such behavior does constitute a violation of at least Visa's internal Code of Business Conduct and Ethics [1], not sure about FCPA due to lack of details;
- compliance matters are a serious business for most all multinational companies, especially public/US based;
- this Code is an internal Visa document, that implies that Reporting any Illegal or Unethical Behavior [2] shall/can be done by Visa's employees, but you are not an employee;
I would recommend to write an e-mail, describing your facts, and send it to 4-5 Visa employees, including US HQ. Having multiple recipients, including HQ people, will ensure that one of those will report this case internally. Your e-mail will trigger internal investigation of this matter, and hopefully favorable resolution [i.e. discontinuation of such practices].
Of course, speak with lawyer before doing anything. Also, I would advise against talking to press, at least for now.
1 [http://investor.visa.com/phoenix.zhtml?c=215693&p=irol-g...]
2 [http://investor.visa.com/phoenix.zhtml?c=215693&p=irol-g...]