As a consultant, I have to take FCPA training an average of 3 times a year. So although I’m not a lawyer, my take is that it’s only allowed if you can point to official documentation that lays out an expedited action fee schedule.

Paying a third party is just as illegal. However, unless you’re expecting to run for Congress, nobody is going to care that you bribed some low level foreign customs agent to get your ink cartridges released.