Not according to the Foreign Corrupt Practices Act (FCPA).

The FCPA basically says that as a representative of a US corporation (in my case, anyone at a Staff Engineer level or above), it's illegal to bribe an official of a foreign government.

It does try to make a distinction (sort of) between the kinds of bribe you're talking about but in my FCPA training, that "distinction" boils down to "go ask your lawyer." The lawyer will just tell you how to do it in a way that doesn't look like a bribe, even though it still is.