Work for a big enough company and you will be told that at least once a year in “training.”
Observe big American companies doing business all over the world and you will conclude the law is... selectively applied.
I’m not sure, but I would guess this is advantageous to the US government in that US companies are allowed to compete globally but there is a wink-wink nudge-nudge acknowledgement they could be prosecuted at any time if they don’t play nice with Washington on other issues.
http://s3.documentcloud.org/documents/515229/a-resource-guid...
The FCPA’s bribery prohibition contains a narrow exception for “facilitating or expediting payments” made in furtherance of routine governmental action.159 The facilitating payments exception applies only when a payment is made to further “routine governmental action” that involves non-discretionary acts.160 Examples of “routine governmental action” include processing visas, providing police protection or mail service, and supplying utilities like phone service, power, and water. Routine government action does not include a decision to award new business or to continue business with a particular party.161 Nor does it include acts that are within an official’s discretion or that would constitute misuse of an official’s office