The DOJ recently released its Fraud Section Year in Review.
Among the Fraud Section’s four “litigating units” is the FCPA Unit described as follows.
“The Foreign Corrupt Practices Act (FCPA) Unit is responsible for investigating and prosecuting violations of the FCPA and the Foreign Extortion Prevention Act (FEPA). The FCPA Unit brings criminal enforcement against individuals and companies and focuses its enforcement efforts on both the supply and demand side of corrupt transactions. The FCPA Unit works closely with domestic and foreign partners to advance common efforts in curbing foreign bribery and corruption.”
The portion of the report on the FCPA Unit states:
“The FCPA Unit, currently composed of 22 prosecutors, investigates and prosecutes individuals and companies for their roles in foreign bribery schemes. In accordance with the Presidential Executive Order pausing the FCPA in February 2025, the FCPA Unit conducted a thorough review of its cases and carried out fair and firm enforcement during the second half of the year under the Deputy Attorney General’s Guidelines for Investigations and Enforcement of the FCPA, issued in June 2025. The FCPA Guidelines are part of a broader effort to identify and focus on key enforcement objectives in the most mission-critical areas. The FCPA Guidelines highlight four non-exhaustive priority areas: the investigation and prosecution of foreign bribery conduct that (1) facilitates the operations of cartels and transnational criminal organizations; (2) deprives U.S. companies of fair opportunities to compete; (3) undermines U.S. national security interests; and (4) involves substantial bribe payments and efforts to conceal criminal schemes.
In 2025, the FCPA Unit had three corporate enforcement actions, including the Section’s first corporate indictment in fifteen years. Specifically, in October 2025, the FCPA Unit indicted SGO Corp., a/k/a Smartmatic Group, for alleged FCPA and money laundering offenses arising from a scheme to pay and launder more than $1 million in bribes to a Philippine government official in connection with contracts related to the 2016 Philippine national elections. Additionally, the FCPA Unit entered into a DPA with Comunicaciones Celulares S.A., a/k/a TIGO Guatemala and declined to prosecute Liberty Mutual under Part I of the CEP.
The FCPA Unit also prevailed in two criminal trials against individuals accused of FCPA violations, including trying one of the cases four months after the indictment.
The throughline from this record of enforcement is clear. The Criminal Division is prosecuting FCPA violations, consistent with the Deputy Attorney General’s Guidelines, in a way that vindicates U.S. interests by ensuring that criminal actors in this space are held to account. We are enforcing this law firmly, fairly, and efficiently—regardless of the identity of the offender, in a way that promotes the rule of law and ensures an equal playing field so that companies win business based on merits.”
