What do you mean by "minefield"? To me, it sounds pretty easy to comply with - just don't offer (or accept) bribes.
Anyone who hasn't chosen to spend years in jail when they were a victim of the airport mall shoplifter scam is an example of someone who has violated the FCPA.
https://www.tripadvisor.com/ShowTopic-g293916-i3687-k6457766...
TL;DR -
Get accused of shoplifting and police give you the option of paying a $5k - $10k fine to avoid waiting in Thai jail for months awaiting trial.
Some accounts say it wasn't a scam and the people were actually caught on CCTV and that they were given the option of a paying a bribe to avoid waiting months in jail.
If you can claim duress in this case, then can you not bribe authorities in every case of being arrested and awaiting trial? Do you need to file paperwork to claim this duress, might another country acquire this paperwork before you flee? AFAIK, it is all a minefield as the higher post claims.
I don't think the DOJ will necessarily honor that unless you have some kind of health condition and evidence the foreign court is refusing to hear about it.. I don't think anyone in the cases I referenced made medical arguments before bribing officials.