An Uninformed, False Narrative

June 5, 2026

Imagine being so uniformed and/or so committed to spinning false narratives that you publish an article today asserting that the Justice Department has “essentially shut[…] down the pursuit of cases under the Foreign Corrupt Practices Act.”

That is was David Corn (the Washington Bureau Chief of Mother Jones and an on-air analyst for MSNBC) did.

However, informed individuals (including FCPA Professor readers) will recognize the following DOJ FCPA developments over the past approximate ten months.

An appeal was filed in the Second Circuit by an FCPA defendant after being found guilty at trial. (See here). No doubt the DOJ will be responding to this brief and the issues presented … in other words the DOJ will continue to pursue this case.

The DOJ filed a Fifth Circuit notice of appeal in an individual FCPA matter in which the defendant was previously found guilty at trial, but the conviction was overturned and the case dismissed by the judge as a result of post-trial briefing. (See here). In other words, by filing the notice of appeal the DOJ is continuing to pursue this case.

An FCPA defendant was arrested in a foreign country and brought to the U.S. to face the charges and subsequently pleaded guilty. (See here).

An FCPA enforcement action against Smartmatic and individuals associated with the company remains in active litigation mode. (See here).

An FCPA defendant was found guilty at trial and sentenced to 8 years. (See here and here).

Comcel resolved a $118 million DOJ FCPA enforcement action concerning alleged bribery schemes in Guatemala. (See here).

An individual pleaded guilty to FCPA offenses. (See here).

An FCPA defendant was sentenced. (See here).

The DOJ filed a criminal indictment and unsealed another alleging that two individuals violated the FCPA in connection with an alleged bribery scheme in Mexico. (See here).

The DOJ criminally charged two individuals with FCPA and related offenses in connection with an alleged bribery scheme involving an employee of an alleged French state-owned and state-controlled public university hospital. (See here).

Balt resolved a $1.2 million DOJ FCPA enforcement concerning an alleged bribery scheme in France. (See here).

An FCPA defendant was found guilty at trial in connection with an alleged bribery scheme in Egpyt and post-trial briefs, as well as sentencing, are pending. (See here).

Another FCPA case against an individual defendant is proceeding to trial. (See here).

Liberty Mutual resolved a $4.7 million DOJ FCPA enforcement action concerning an alleged bribery scheme in India. (See here).