There are some things written about the Foreign Corrupt Practices that are so lacking in FCPA knowledge, so lacking in attention to detail, and so lacking in relevant FCPA context – as to be complete rubbish.
This dealbreaker.com piece (which describes itself as providing original commentary about the financial industry) by Jon Shazar is complete rubbish.
The article is titled “Feel Free To Filter Your Bribes Through Foreign-Government Owned Investment Banks” with the teaser “Bill Barr sees absolutely nothing wrong with that kind of thing” and states: