Gift, by definition, is something voluntarily transferred, without compensation.
Bribe, on the other hand, is to provide something of value to persuade or influence a judgement or the conduct of a person in the position of trust.
How is a required gift, voluntary? How, also, is it without compensation, if one receives a golden ticket?
Under the FCPA, one is permitted to "expedite or secure the performance of a routine governmental action which is routinely and commonly performed by a foreign official" which includes processing of paperwork to obtain visas and/or paperwork to allow a person to do business in a foreign country - that's covered by the $15k application fee, but the million dollar "gift" cannot influence the decision to issue or guarantee a visa.
It states on the Trump Gold Card website that a successful applicant will be vetted by DHS and will be subject to available EB-1 and EB-2 visas. USCIS falls under DHS, but DoS is a separate agency that works with DHS. Can you imagine? Pay $15k, get an I-140 approval, pay your $1mil and the DoS says "nah bruh, sorry, we're not issuing your visa". 👀
As others have said, at least an EB-5 requires some sort of capital investment as well as a business plan to prove economic benefit to the US, which seems less sketchy and probably a lot easier.
I'd wager dollars to donuts the "platinum card" is a no go thus far because of the "gifting" as well as the benefit of 270 tax free days per year on foreign income while living in the US. Any non-resident alien for tax purposes, PR or citizen's foreign income has always been subject to US taxes, period. Getting past those sketchy benefits is instrumentally more challenging as it's multiple laws to challenge with those bad boy promises.