After reading the linked Wikipedia page, if it's accurate then you seem to be correct. The act prohibits influencing foreign officials by giving them things of

After reading the linked Wikipedia page, if it's accurate then you seem to be correct. The act prohibits influencing foreign officials by giving them things of value, and doesn't mention whether that would be illegal in the foreign country. So it would seem that a U.S. corporation would be in violation of this law for doing in a foreign land what they routinely do within the U.S. (essentially all large U.S. businesses make, or aggregate, "campaign contributions" with the intent to influence lawmakers and other elected officials).