This post highlights twenty-four FCPA enforcement actions concerning conduct (in whole or in part) in India.
The enforcement action concerned conduct in India and the allegations were: “The Government’s investigation found evidence that, from in or around 2017 until in or around 2022, Liberty Mutual, through its subsidiary in India, Liberty General Insurance (“LGI”), paid bribes totaling approximately $1.47 million to officials at six state-owned banks in India, in order to obtain or retain business with those state-owned banks. Specifically, in exchange for the bribes, the officials caused the state-owned banks to refer bank customers to LGI’s insurance products. Certain LGI employees took steps to conceal the true nature of the payments, including by classifying the payments as marketing expenses and using third-party intermediaries to make the payments to the officials. In total, the bribe scheme resulted in revenue of approximately $9.2 million and profits of approximately $4.7 million.”
This post highlights FCPA enforcement actions concerning conduct (in whole or in part) in Pakistan and Nepal.
The enforcement action concerned conduct in Russia, Azerbaijani, China, Kuwait, South Korea, Pakistan, Thailand, and Indonesia.
As to Pakistan, the allegations were: “In addition to the purely leisure trips arranged by Otis to influence foreign officials, at times UTC businesses provided excessive leisure travel and entertainment in conjunction with legitimate business travel. For example, from 2012 to 2014, the Pratt Belgium Engine Center paid for excessive, leisure hotel stays in Belgium and Amsterdam for Air Force officials from Pakistan …”.
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.
This post shifts the focus a bit west and highlights seven FCPA enforcement actions concerning conduct (in whole or in part) in Bangladesh.
The enforcement action concerned conduct in Angola, Bangladesh, Indonesia, Thailand, China, and Egypt.
As to Bangladesh, the allegations stated that an indirect subsidiary paid “$43,700 to an agent in Bangladesh with the understanding that the agent would use the money, in part, for corrupt purposes.”
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 separate motion for a judgement of acquittal pending, recently Hobson filed a motion to dismiss based on the court’s supervisory powers.
The motion began:
“When confronted with coercive prosecutorial tactics . . . , the [Supreme] Court has often condoned those practices or let them pass in silence.” Hunter v. United States, 146 S. Ct. 1702, 1715 (2026) (Gorsuch, J., concurring). This Term, it “begins to correct course.” Id.
This case is directly in Hunter’s cross hairs. The government improperly used a five-year-old proffer to deprive a United States citizen of his constitutional right to a fair trial. Its threats disabled the adversarial process throughout the trial. The government then cashed in on this unlawful effort, calling its proof “overwhelming and uncontradicted.” The government never sought a ruling that the proffer waiver was knowing, voluntary, triggered, or enforceable. Even if it had, Hunter confirms that a valid waiver does not compel enforcement. On a lesser record, where the court did rule and no proffer statement was ever admitted, the Second Circuit vacated and ordered a new trial. United States v. Oluwanisola, 605 F.3d 124 (2d Cir. 2010).
At a minimum, Hobson is entitled to a new, fair trial—one in which he can confront the government’s witnesses, test its evidence, and present a defense without one hand tied behind his back. But the government’s deliberate actions warrant more. Hobson asks this Court to dismiss the indictment with prejudice under its supervisory power, protect the integrity of the federal courts, and prevent them from “making . . . themselves accomplices in willful disobedience of law.”
Earlier this month, Asante Berko (a former Executive Director of Goldman Sachs International) was convicted by a jury of FCPA and related offenses in connection with a Ghana bribery scheme after a trial in the E.D. of New York.
Recently, Berko filed a motion for acquittal and a new trial.
In summary fashion the motion states:
“Defendant Asante Kwaku Berko moves pursuant to Rule 29 of the Federal Rules of Criminal Procedure for a judgment of acquittal on all counts because the evidence admitted at trial was insufficient for any rational trier of fact to find that the Government had proven Mr. Berko’s guilt with respect to any of the charged offenses. Specifically, the evidence at trial was insufficient for any reasonable jury to conclude, beyond a reasonable doubt, (1) that Mr. Berko agreed with the alleged co-conspirators to violate the FCPA by paying bribes to Ghanaian government officials, as necessary to sustain a conviction as to Count One, (2) that any of the elements of Count Two were established, including that Mr. Berko offered or paid anything of value, with corrupt intent for an improper purpose, and (3) that the transfers of funds that served as the basis of conviction as to Count Three were the result of a separate agreement among the alleged coconspirators with the specific intent to promote the alleged bribery scheme or substantive FCPA violation. In addition, the evidence was insufficient for the jury to conclude by a preponderance of the evidence that venue in the Eastern District of New York was proven as to all Counts. In the alternative, Mr. Berko moves pursuant to Federal Rule of Criminal Procedure 33 for a new trial on all counts.”
Democratic Congressman Jamie Raskin is investigating Trump Son-In-Law Jared Kushner for potential FCPA violations in connection with a land purchase in Albania.
Raskin’s sophomoric letter to Kushner begins:
“You may have been too busy causing a new foreign policy fiasco in Albania after your yachting foray in the Adriatic to get back to us on some questions we have about your stark conflicts of interest taking place right here in America. So, in case you had forgotten about the existence of a congressional investigation into your conflicts of interest and corrupt business practices, I write to remind you of your obligation to respond to congressional investigative inquiries and also to notify you that we have expanded our investigation to include your suspect real estate practices.”
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.
This post highlights five FCPA enforcement actions (ranging from the largest FCPA settlement of all-time to one of the first FCPA enforcement actions in 1978) concerning conduct (in whole or in part) in Malaysia.
The enforcement action (the largest FCPA settlement in history) concerned bribes to various Malaysian and Abu Dhabi officials in connection with 1Malaysia Development Berhad (1MDB), Malaysia’s state-owned and state-controlled investment development company.
The same core conduct was also at issue in the 2018 FCPA enforcement action against Low Taek Jho (Jho Low), Ng Chong Hwa (Roger Ng – a former managing director at Goldman Sachs), and Tim Leissner (the former Southeast Asia Chairman at Goldman Sachs and Participating Manager Director). Leissner pleaded guilty and was sentenced in 2025 to 2 years in prison . In 2022, Ng was found guilty at trial of FCPA and related offenses and was sentenced to 10 years in prison. Jho Low remains a fugitive.