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 Dada Nexus Limited.
This post highlights FCPA enforcement actions concerning conduct (in whole or in part) in Azerbaijan.
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.
Although the criminal information makes general reference to a corrupt scheme in Azerbaijan, there were no specific substantive allegations in the information concerning Azerbaijan.
This post highlights thirteen FCPA enforcement actions concerning conduct (in whole or in part) in Kazakhstan.
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 Kazakhstan, the allegations concerned various schemes involving officials at state-owned oil and gas companies to obtain and retain business for Unaoil and its client companies. In one instance, the information alleged that although the promise to pay bribes occurred while Kazakh Official worked for an SOE, Unaoil “did not make payments to Kazakh Official 1 until [the official] stopped working” for the SOE. The information does allege however that C. Ahsani did “arrange for the purchase of an automobile and furniture for Kazakh Official 1 while Kazakh Official 1 was still employed” by SOE. The information further alleged that C. Ahsani and others caused Unaoil “to make payments to a company they knew was beneficially owned and controlled by Kazakh Official 1.”
Foreign Corrupt Practices Act enforcement has existed for approximately 50 years.
From time to time, criminal charges that are brought are dismissed.
In some instances, a judge dismisses the charges against the DOJ’s wishes. (See here, here, here, here, here, here, here, here, here, here, here, and here).
In other instances, criminal charges are dropped at some point during the litigation process (or even after) per the DOJ’s request.
In early December 2025, Ramon Alexandro Rovirosa Martinez was found guilty at trial of FCPA and related offenses in connection with an alleged Mexican bribery scheme.
In mid-April 2026, Judge Kenneth Hoyt (S.D. Texas) granted post-trial motions by Rovirosa and ordered that he be released from prison. (See here).
Shortly thereafter, on May 8th, the DOJ filed a notice of appeal in the Fifth Circuit. (See here) and twice requested extensions to file its opening brief given that the “Solicitor General has not yet determined whether or on what grounds to allow a government appeal to proceed in this case.”
Recently the DOJ filed its opening brief in the Fifth Circuit.