18 USC 3292 can play a meaningful role in certain FCPA enforcement actions in terms of the statute of limitations.
The statutory provision states in pertinent part:
(a) (1) Upon application of the United States, filed before return of an indictment, indicating that evidence of an offense is in a foreign country, the district court before which a grand jury is impaneled to investigate the offense shall suspend the running of the statute of limitations for the offense if the court finds by a preponderance of the evidence that an official request has been made for such evidence and that it reasonably appears, or reasonably appeared at the time the request was made, that such evidence is, or was, in such foreign country.
As highlighted in this prior post, in 2021 Frederick Cushmore Jr. (a former executive of Pennsylvania-based coal mining company Corsa Coal Corp.) was criminally charged and pleaded guilty to a conspiracy charge to violate the FCPA’s anti-bribery provisions in connection with a bribery scheme in Egypt involving Al Nasr Company for Coke and Chemicals (an alleged Egyptian state-owned and state-controlled entity).
In 2022, in connection with the same core allegations, the DOJ also criminally charged Charles Hunter Hobson (another former executive of Corsa Coal). The charges against Hobson went to trial, at trial Cushmore testified for the DOJ, and Hobson was found guilty in February 2026.
With post-trial mentions pending, Hobson’s counsel recently filed a motion to continue sentencing revealing “new sentencing-related information disclosed by the government.”
This post highlights nine FCPA enforcement actions concerning conduct (in whole or in part) in Egypt.
The enforcement action concerned conduct in Egypt and alleged that from “2016 until early 2020, certain of Corsa’s employees and agents engaged in a scheme to bribe Egyptian government officials in order to obtain and retain lucrative contracts to supply coal to Al Nasr Company for Coke and Chemicals (“Al Nasr”), an Egyptian state-owned and -controlled coke company. To effectuate the scheme, Corsa paid approximately $4.8 million to an Egypt-based third-party intermediary that Corsa’s employees knew would be used, at least in part, to pay bribes to Egyptian government officials, including the Chairman of Al Nasr. In exchange for the bribe payments, Corsa secured approximately $143 million in coal contracts from Al Nasr and earned approximately $32.7 million in profits.” Individual enforcement actions were also based on the same core conduct.
This post highlights seven FCPA enforcement actions concerning conduct (in whole or in part) in Egypt.
The enforcement action against Cyrus Ahsani and Saman Ahsani (the former CEO and Chief Operations Officer of Monaco-based Unaoil) concerned conduct in Iraq, Kazakhstan, Libya, Algeria, Iran, Azerbaijan, Angola, Syria, the Democratic Republic of the Congo, and elsewhere.
As to Libya, the enforcement action concerned various schemes involving foreign government officials including at a state-owned oil and gas company to obtain and retain business for Unaoil and its client companies. The information refers to Libya Official 1, but states that S. Ahsani and others “understood that Libya Official 1 was not an appointed Libyan government official at the time they promised to pay Libya Official 1” but that “Libya Official 1 could exert influence over senior Libyan government officials, including one official who was a close relative of the then head of the Libyan government, and that this senior Libya official’s support or lack of support could determine whether” a company won an award for a project. Based on the same core conduct, Steven Hunter (a former business development manager at Unaoil) resolved an enforcement action.
This post highlights approximately 20 FCPA enforcement actions concerning conduct (in whole or in part) in Russia.
The enforcement action concerned conduct in Russia.
The allegations were: “Between May 26, 2015 and May 15, 2020, the Company paid approximately $8.9 million to consultants in Russia in support of the Company’s operations and its efforts to have poker legalized in that country.”