A Jurisdictional Stretch?
An interesting DOJ criminal action alleging foreign bribery to highlight.
As highlighted in this recent press release an indictment was unsealed charging a Turkish national (Bahadir Hatipoglu) and a German national (Ralf Grywnow) for an alleged bribery scheme involving contracts with the U.S. military and the North Atlantic Treaty Organization (NATO).
As alleged in the indictment, Hatipoglu was the owner and General Manager of a Turkish construction company and Grywnow worked for the NATO Support and Procurement Agency (NSPA – an organization within NATO that served as a logistics and procurement agency supporting NATO’s mission).
According to the indictment, Hatipoglu and Grywnow engaged in a fraud scheme in which Hatipoglu bribed Grywnow “with money and other forms remuneration” and “in exchange [Grywnow] gave the construction company favorable treatment on NATO construction contracts and signed fraudulent evaluations of the company’s prior performance that favorably recommended the company for future projects with the United States military.” The indictment alleges that Hatipoglu “then used these evaluations to defraud and attempt to defraud the U.S. military.
A Focus On DOJ Individual FCPA Enforcement Actions
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).
FCPA Institute – Zoom (Feb. 23-25)
Since 2014, the FCPA Institute has elevated the Foreign Corrupt Practices Act knowledge and practical skills of professionals from around the world. The FCPA Institute began as an in-person event, but shifted to Zoom in 2020. The Zoom event is time and cost efficient and has resulted in greater participation from professionals around the world.
The next FCPA Institute – Zoom will be offered on February 23-25 and consists of 9 hours of integrated and cohesive instruction (each day from 7:00 a.m. -10:00 a.m. U.S. central) led by Professor Koehler, an FCPA expert with FCPA practice and teaching experience.
The Gray Cloud Of FCPA Scrutiny
This recent post highlighted the origins of corporate Foreign Corrupt Practices Act enforcement actions in 2025.
Continuing with the 2025 FCPA statistical feast, this post follows the chronology of scrutiny to enforcement and highlights one of the most troubling policy issues when it comes to FCPA enforcement.
That is – FCPA scrutiny simply lasts too long. In the FCPA’s modern era, FCPA scrutiny has tended to last approximately 4 years.
In 2025, there were three corporate FCPA enforcement actions making a median analysis less relevant than certain previous years.
In these three enforcement actions, the length of FCPA scrutiny was approximately 1.5 years, 5 years, and 5 years.
First, some general background.
Thank You For Reading FCPA Professor In 2025
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I look forward to your readership in 2026.