The narrative continues, there is no Foreign Corrupt Practices Act enforcement.
A recent example, in the aftermath of last week’s elections, was the hope that the “next administration can announce the immediate reinforcement of tools like … the FCPA.” (See here).
Set forth below is an update to a post previously published approximately six weeks ago which provided a brief overview of FCPA enforcement during the second Trump administration.
It is true, that on February 10, 2025 President Trump signed an Executive Order Titled “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security.” As highlighted in this post, several of the substantive issues discussed in the Executive Order had been festering in the FCPA space (and openly discussed by politicians in both parties) for approximately 15-20 years prior.
The “pause” lasted a brief 118 days, during which certain aspects of FCPA or related enforcement actually continued (see here, here, here, here, here).
Since the “pause” ended in mid-June 2025, there have been several FCPA enforcement actions against business organizations or individuals and other FCPA or related developments.
In July 2025, the DOJ “defended” its positions in responding to a motion to dismiss filed by Carl Zaglin in a pending FCPA (and related) enforcement action concerning an alleged bribery scheme in Honduras. (See here). In September 2025, Zaglin was found guilty at trial. In December 2025, Zaglin was sentenced
In August 2025, Liberty Mutual resolved a $4.7 million FCPA enforcement action concerning conduct in India.
In August 2025, the DOJ criminally charged Ramon Alexandro Rovirosa Martinez and Mario Alberto Avila Lizarraga in connection with an alleged bribery scheme in Mexico. In December 2025, Roviorsa was found guilty at trial, post trial briefs were filed, and in April 2026 a federal court judge dismissed the case. In May 2026, the DOJ filed a notice of appeal and in September 2026 the DOJ filed its appellate brief.
In September 2025, a Nigerian “foreign official” was found guilty at trial in the U.S. of various criminal offenses in connection with bribery schemes.
In September 2025, Vikas Sagar was sentenced in connection with a pending FCPA enforcement action.
In September 2025, Smartmatic was criminally charged with FCPA and related offenses in connection with alleged bribery scheme in the Philippines and since then the DOJ has continued to actively prosecute the case.
In October 2025, Carlos Leopoldo Alvelais Alarcon pleaded guilty to FCPA offenses in connection with a bribery scheme in Mexico and he was sentenced in July 2026. Also in July 2026, and in connection with the same core conduct, Scoular resolved a $10.2 million FCPA enforcement action.
In November 2025, Millicom International Cellular S.A. and its subsidiary Comcel resolved a $118 million FCPA enforcement action in connection with a bribery scheme in Guatemala.
In December 2025, Glen Oztemel was sentenced in connection with an FCPA enforcement action involving conduct in Brazil. Oztemel has appealed to an appellate court and the DOJ has responded.
In February 2026, Charles Hunter Hobson was found guilty at trial in an FCPA enforcement action concerning an alleged bribery Scheme in Egypt. Post trial motions remain pending and the DOJ has objected to the motions.
In March 2026, the DOJ announced an FCPA enforcement action against David Ferrera and Marc Tilman in connection with an alleged bribery scheme in France and the DOJ continues to actively prosecute the case. Also in March 2026, and in connection with the same core action, Balt resolved a $1.2 million FCPA enforcement action.
In March 2026, the DOJ criminally charged Alfonso Wilson in connection with an bribery scheme in Mexico and he later pleaded guilty. In April 2026, in connection with the same core action, the DOJ unsealed a related FCPA enforcement action against Diego Bergonzi.
In April 2026 the DOJ filed a civil forfeiture action alleging that a U.S. defense contractor bribed a Kurdish official in connection with jet fuel contracts.
In June 2026, Abraham Cigarroa Cervantes pleaded guilty to FCPA offenses in connection with a bribery scheme in Brazil.
In August 2026, 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 New York. In October 2026, the judge denied Berko’s motion for aquittal and a new trial.
In September 2026, U.S. Marshals took custody of Jald Jensen (a former BizJet executive who was criminally charged with FCPA offenses in 2013) after evading law enforcement in Panama. In October 2026, Jensen pleaded pleaded guilty in the N.D. of Oklahoma to conspiracy to violate the FCPA’s anti-bribery provisions.
In September 2026, U.S. District Judge Eric Vitaliano (E.D. N.Y) sentenced Javier Aguilar (a former employee of Vitol Inc.) to four years in prison and also ordered him to pay approximately $7.13 million in criminal forfeiture and a $100,000 fine after Aguilar was previously found guilty at trial in 2024 and plead guilty to other FCPA charges.
In October 2026, in connection with the SEC’s FCPA enforcement action against Cyril Sebastien Dominique Cabanes (a former member of the board of directors of Azure Power Global Limited) the SEC stated in a status report filed with the court that it has “been engaging in discussions with representatives of the Defendant regarding a possible resolution of the matter.”
In October 2026, Charles Finkel (a former executive of Sicpa – a Swiss technology company which provides governments with banknote security inks and secured identification, traceability and authentication solutions) was charged in a criminal information with conspiracy to violate the FCPA’s anti-bribery provisions in connection with an alleged bribery scheme in Brazil (original charges were filed in 2022). In November 2026, Finkel was ordered to pay a $5 million judgment in advance of his sentencing.
In October 2026, the DOJ announced the arrest of Alvaro Pulido Vargas who was previously charged with, among other things, laundering the proceeds of violations of the FCPA in connection with a scheme to pay bribes to take advantage of Venezuela’s government controlled-exchange rate.
