Iit's specifically minor bribes required to get anything done even if you comply with the law. Bribing a building inspector to overlook safety problems, that's an FCPA violation. Tipping him $20 to thank him for his hard work on verifying your construction's code compliance, not a problem. The text is so:

> Subsections (a) and (g) of this section shall not apply to any facilitating or expediting payment to a foreign official, political party, or party official the purpose of which is to expedite or to secure the performance of a routine governmental action by a foreign official, political party, or party official.