As highlighted in this post, recently the Second Circuit concluded in U.S. v. Ng Lap Seng that just because 18 U.S.C. 201 (the so-called domestic bribery statute) and the FCPA (as well as other statutes) all concern bribery does not therefore mean that all bribery statutes have the same elements or interpretations.
Recently, the Ninth Circuit concluded the same thing in U.S. v. Heon-Cheol Chi. (See here for the decision).
The decision sets forth the following relevant background:
