This recent post focused on SEC individual FCPA actions in 2025 and historically.
Today’s post highlights various facts and figures regarding the DOJ’s prosecution of individuals for Foreign Corrupt Practices Act offenses in 2025 and historically.
The key word above is FCPA offenses.
Some in the FCPA space include enforcement actions containing non-FCPA charges (often money laundering charges against alleged “foreign officials” or with increasing frequency money laundering charges against alleged bribe payors – see here) related to an FCPA enforcement action as an individual FCPA enforcement action. While it is fine to track such enforcement actions, calling these FCPA enforcement actions is not accurate. (In fact, as highlighted in this prior post, a high percentage of enforcement actions in recent years on the DOJ’s FCPA website are not actual FCPA enforcement actions).
Compared to corporate FCPA enforcement actions, tracking individual FCPA enforcement actions can be difficult because the DOJ does not publicly announce every individual enforcement action and/or certain matters are filed under seal and announced at a later date (sometimes in a different year).
Since 2000, the DOJ has charged 254 individuals with FCPA criminal offenses. The breakdown is as follows.
- 2000 – 0 individuals
- 2001 – 8 individuals
- 2002 – 4 individuals
- 2003 – 4 individuals
- 2004 – 2 individuals
- 2005 – 3 individuals
- 2006 – 6 individuals
- 2007 – 7 individuals
- 2008 – 14 individuals
- 2009 – 18 individuals
- 2010 – 33 individuals (including 22 in the Africa Sting case)
- 2011 – 10 individuals
- 2012 – 2 individuals
- 2013 – 12 individuals
- 2014 – 10 individuals
- 2015 – 8 individuals
- 2016 – 8 individuals
- 2017 – 18 individuals
- 2018 – 13 individuals
- 2019 – 26 individuals
- 2020 – 15 individuals
- 2021 – 10 individuals
- 2022 – 9 individuals
- 2023 – 8 individuals
- 2024 – 13 individuals
- 2025 – 3 individuals
The following 3 individuals (in connection with 2 core actions) were charged with FCPA offenses that were filed and/or publicly announced in 2025.
- As highlighted here, in August 2025 the DOJ announced an enforcement action charging Ramon Alexandro Rovirosa Martinez (a citizen of Mexico and a lawful permanent resident of Texas) and Mario Alberto Avila Lizarraga (a citizen of Mexico and lawful permanent resident of Texas) with FCPA (and related offenses) for their roles in an alleged bribery scheme to retain and obtain business related to Petróleos Mexicanos (PEMEX), the state-owned oil company of Mexico, and PEMEX Exploración y Producción (PEP), PEMEX’s wholly owned exploration and production subsidiary. In December 2025, Roviorsa was found guilty at trial. (See here).
- As highlighted here, in October Carlos Leopoldo Alvelais Alarcon appeared before a Magistrate Judge (W.D. District of Texas – El Paso Division) and pled guilty to Count One of a Felony Information charging him with Conspiracy to Violate the Foreign Corrupt Practices Act pursuant to a Plea Agreement. The criminal information and plea agreement are still under seal. Sentencing was to occur on January 8, 2026 but has been reset to March 9, 2026.
