There are places in the world where if you do not bribe an official, you could suffer for your morals. So, yeah, a private citizen only representing themselves

There are places in the world where if you do not bribe an official, you could suffer for your morals. So, yeah, a private citizen only representing themselves is not covered by the foreign corrupt practices act. That said, many US Gov't Officials do bribe foreign actors, though they may not call them bribes.