I imagine it depends on which country makes that request, its legal basis, and how their gag order is written.

I find it hard to imagine a federal US order wouldn’t proscribe this cute “wink” payment. (Although who knows? If a state or locality takes it upon themselves to raid a bit barn, can their local courts bind transnational payments or is that federal jurisdiction?)

But from the way it’s structured—around a specific amount of currency corresponding to a dialing code of the requesting nation—it sure sounds like they’re thinking more broadly.

I could more easily imagine an opportunistic order—say, from a small neighboring state compelling a local contractor to tap an international cable as it crosses their territory—to accommodate the “winking” disclosure: by being either so loosely drafted or so far removed from the parent company’s jurisdiction as to make the $billions contract worth preserving this way.