Why does Larry Kurlander say U. S. firms are at a disadvantage versus European firms in the international competition for government contracts and concessions

This question refers to a litigation between Newmont (US firm) and BRGM (a French firm). They disputed rights over a gold mine in Peru, the largest in the world at that time (mid 1990s). Both sides accused each other of bribing Peruvian officials and judges. Finally, the French company won and everyone assumed that they had paid a higher bribe.

Since bribing by US firms is illegal due to the Foreign Corrupt Practices Act, Newmont has repeatedly denied bribing anyone and so has the other party. But in reality no one believes them since Mr. Kurlander was taped when he was negotiating with former Peru's former chief of intelligence Vladimiro Montesinos who is now in prison for committing every single crime that you can imagine.

When interviewed by the New York Times, Kurlander stated that European corporations were not forbidden by law to bribe, so American companies were at a disadvantage. I'm not sure, but I believe that this has changed since the 1990s.