A request has to be by a "person", not necessarily a national or citizen of the
U.S., as far as I see in the statute. This came up as an issue during the
Reagan Presidency because the Cold War-era U.S.S.R. reportedly made FOIA
requests and I think they resolved it by the U.S. Attorney General
https://torrentfreak.com/tor-and-bitcoin-hinder-anti-piracy-efforts-160715/
https://euipo.europa.eu/tunnel-web/secure/webdav/guest/document_library/observatory/resources/Research_on_Online_Business_Models_IBM/Research_on_Online_Business_Models_IBM_en.pdf