With the Venezuelan bonds purchase, has Goldman Sachs committed an act punishable under Foreign Corrupt Practices Act?

Sir I refer to Robin Wigglesworth’s and Gideon Long’s “Goldman hit by ‘hunger bond’ storm after Venezuela deal” June 2.

There are plenty of persons currently in jail in the US because of acts committed against the Foreign Corrupt Practices Act (FCPA). You can read about many cases in http://www.fcpablog.com

Goldman Sachs, has just handed over about US$865 million cash to the notoriously corrupt and human rights violating government of Venezuela, in order to obtain $2.8billion Venezuelan bonds, which according to some calculations seen, if repaid, would provide GS with about a 48% internal rate of return.

So, has Goldman Sachs, de facto, unwittingly, committed the mother of all corruptions acts punishable under the FCPA? 

http://perkurowski.blogspot.ca/2017/05/goldman-sachs-lloyd-blankfein-should.html

@PerKurowski