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.
As stated by the DOJ, the bribery scheme involved “Al Nasr Company for Coke and Chemicals (Al Nasr), which was then a state-owned and state-controlled chemical manufacturing company in Egypt.”
The issue of whether Al Nasr was an “instrumentality” of the Egyptian government, such that employees of Al Nasr could be “foreign officials” under the FCPA, was the focus of a specific jury instruction and this prior post discussed how it was flawed.
In December 2023, Freepoint Commodities resolved a Foreign Corrupt Practices Act enforcement action in connection with a bribery scheme in Brazil.
The criminal charge of conspiracy to violate the FCPA’s anti-bribery provisions was resolved through a deferred prosecution agreement in which Freepoint agreed to pay approximately $98 million as well as a host of compliance and reporting obligations for the duration of the DPA.
Section 3 of the DPA titled “Term of the Agreement” stated:
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 judgment of acquittal pending, Hobson switched counsel and is now represented by R. McConnell Group attorneys Ryan McConnell, Matthew Boyden, and Larry Finder. This same group of attorneys recently represented FCPA defendant Ramon Alexandro Rovirosa Martinez (in April 2026, Judge Kenneth Hoyt (S.D. Texas) granted post-trial motions to dismiss and acquittal by Ramon Alexandro Rovirosa Martinez and ordered that he be released from prison).
New counsel drew the court’s attention to a June Supreme Court decision – Hunter v. U.S. – and how it “bears directly on how this case was litigated.”
Yesterday, and separate from the pending motion for a judgment of acquittal, Hobson filed a motion to dismiss based on the court’s supervisory powers.
Previous posts have focused on Foreign Corrupt Practices Act enforcement actions concerning conduct (in whole or in part) in Thailand, Vietnam, Indonesia, Malaysia and other Southeast Asian countries.
In total, 66 enforcement actions were highlighted (in some instances one enforcement action concerned conduct in multiple Southeast Asian countries and was counted separately for each country at issue).
Drawing conclusions from Foreign Corrupt Practices Act enforcement actions is relevant, but only to a certain extent.
For instance, the enforcement actions spanned nearly 50 years and specific business conditions in a country (which may give rise to FCPA issues) change over time.
Resolution documents in an FCPA enforcement action obviously tell a “story,” but that “story” is often the subject of negotiation between the DOJ/SEC and the company as to what conduct is included or left out.
With these qualifications in mind, set forth below are some take-away points from FCPA enforcement actions concerning conduct (in whole or in part) in Southeast Asian countries.
Previous posts have focused on Foreign Corrupt Practices Act enforcement actions concerning conduct (in whole or in part) in Thailand, Vietnam, Indonesia, and Malaysia.
This post takes a look at FCPA enforcement actions involving conduct (in whole or in part) in other Southeast Asian countries: the Philippines, Laos, and Myanmar.
Philippines
In 2024, the DOJ criminal charges against various individuals (including Smartmatic executives) concerning an alleged bribery and money laundering scheme “to retain and obtain business related to the 2016 Philippine elections. […] These bribes were allegedly paid to obtain and retain business related to providing voting machines and election services for the 2016 Philippine elections and to secure payments on the contracts, including the release of value added tax payments.” In 2025, Smartmatic was also criminally charged in connection with the same core conduct. Smartmatic, as well as the executives, are contesting the charges and the enforcement action remains pending.