Based on those trainings I also have to take yearly, the US has a weird carve out for "facilitation payments" that are basically just bribes to cut through red

Based on those trainings I also have to take yearly, the US has a weird carve out for "facilitation payments" that are basically just bribes to cut through red tape and delays that probably exist just to extract bribes in the first place. But I do remember the training calling out using a third party intermediary to launder your bribes isn't a defense and you're suppose to be responsible for how your money is used. I suspect the later isn't well enforced though but I couldn't say.