A publicly-traded U.S. company is not permitted, either directly or through its agents, to try to bribe foreign officials to do any actions or to fail to do any actions. U.S. companies cannot try to use any items or value, nor any promises of items of value, to try to secure or retain business in foreign locations.
FCPA broadly prohibits paying money, authorizing the payment of money, the giving of gifts, or the promise of gifts or items of value to foreign officials if the purpose of the gift is to influence acts in official capacity. Giving items of any value to secure an improper advantage of any type is against the law.
A U.S. company also cannot bribe foreign officials to use their influence with their governments to influence official actions