As explained the text, the FCPA's anti-bribery provisions are extraterritorial only as to U.S. actors. As to foreign actors, the FCPA's anti-bribery provisions remain "territorial" in that a U.S. nexus is generally required. Like other FCPA issues, this territorial nexus is broadly interpreted. Some times one might mention this because expansive jurisdictional theories as to foreign actors is different than saying that the FCPA's anti-bribery provisions are extraterritorial as to foreign actors (a false statement).