In 2019, Alvaro Pulido Vargas was criminally charged with laundering the proceeds of violations of the FCPA in connection with a scheme to pay bribes to take advantage of Venezuela’s government controlled-exchange rate. (See here).
In 2021, the DOJ also announced the unsealing of an indictment charging various individuals including Alvaro Pulido Vargas for their alleged roles in laundering the proceeds of contracts to provide food and medicine to Venezuela that were obtained through bribes. (See here for the prior post).
Yesterday, the DOJ announced that Pulido Vargas was arrested and will be making an initial appearance on October 13th in the Southern District of Florida to face federal prosecution.
This post highlights seven FCPA enforcement actions concerning conduct (in whole or in part) in South Africa.
The enforcement action concerned conduct in South Africa and Nepal.
As to South Africa, the allegations were: “between January 2016 and at least January 2020, AAR, through its agents, knowingly and willfully conspired and agreed with others to corruptly offer and pay bribes to, and for the benefit of, government officials in South Africa […] to secure improper advantages in order to assist AAR in obtaining and retaining business from SAAT [South African Airways Technical – a wholly owned subsidiary of South African Airways – that provided technical services for SAA and other airlines], namely the award of a five-year aircraft component support contract (“SAAT Contract”) and disbursement of payments by SAAT pursuant to that contract.”
In February 2026 Charles Hunter Hobson (who served in a variety of roles at Corsa Coal from 2013 to 2018) was found guilty by a jury for various Foreign Corrupt Practices Act and related offenses in connection with an Egyptian bribery scheme.
With a motion for a judgement of acquittal pending, in September 2026 (through new counsel) Hobson filed a motion to dismiss based on the court’s supervisory powers.
In a rather cavalier response, the DOJ sort of responded to the motion, but also stated that if “the Court wishes to resolve the substance of Defendant’s claims, the government respectfully requests 60 days to respond more fully.” (See here).
The Foreign Corrupt Practices Act has always been a law much broader than its name suggests.
Sure, the FCPA contains anti-bribery provisions which concern foreign bribery.
Sure, the FCPA’s books and records and internal controls provisions can be implicated in foreign bribery schemes.
However, the fact remains that most FCPA enforcement actions (that is enforcement actions that charge or find violations of the FCPA’s books and records and internal controls provisions) have nothing to do with foreign bribery. For lack of a better term, these enforcement actions have longed been called non-FCPA, FCPA enforcement actions by this site.
The latest example concerns an SEC enforcement action against Latch, Inc. (a Missouri based company that develops and manufactures smart access hardware and software products for multi-family residential properties).
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.