In this study, we analyze the main interpretative difficulties associated with the crime “private-to-private corruption” in Chile. These challenge are related to the actus reus requirements of the criminal offense, that restrict the behavior to the bribery of employees or agents so that in their work they favor the contracting of one bidder over another. To achieve the goals of this study, we analyze this crime from the perspective of the regulatory model “of competition”. We identify several contradictions based on prior studies describing what constitutes a bribe in a “competitive situation” that could satisfy the requirement of actus reus. We conclude by proposing solutions relying on the regulatory model adopted by the Chilean legislator and its further legitimate consequences.