This post highlights Foreign Corrupt Practices Act enforcement and related developments at the mid-point of 2026.
DOJ Enforcement (Individual)
Thus far in 2026, the DOJ has brought / unsealed FCPA charges against four individuals in three core actions.
As highlighted here, a few weeks prior to the March 2026, Balt enforcement action and based on the same alleged core conduct, the DOJ charged David Ferrera and Marc Tilman with FCPA and related offenses. Ferrera has pleaded not guilty – see here. As highlighted in the prior post, this matter is believed to be the first time the DOJ has ever charged individuals with FCPA offenses based on the theory that employees of certain foreign health care systems are “foreign officials” under the FCPA and thus occupy a status akin to a President or Prime Minister. This enforcement theory has been used approximately 35 times in corporate enforcement actions but has never been subjected to judicial scrutiny.
As highlighted here, the DOJ filed a criminal information against Alfonso Wilson (CEO of Oil Technologies Consortium) alleging that he and others obtained and retained a December 2021 Contract with PEMEX for an Equipment Company through corrupt and fraudulent means, including by offering and paying bribes to a Foreign Official. As highlighted here, in April a January 2025 criminal information was unsealed charging Diego Bergonzi (a dual U.S. – Italian citizen who was a Vice President of Sales at Drillmec) with FCPA and related offenses in connection with the same core action. Bergonzi pleaded guilty and in April Judge David Hittner (S.D. Tex) ordered Bergonzi to forfeit $1,019,757 (the amount he obtained from the criminal offense). Judge Hittner noted that this “will be made part of the Defendant’s sentence and included in the judgement against him.”
DOJ Enforcement (Corporate)
Thus far in 2026, the DOJ has brought one corporate enforcement action.
Balt (March 19)
See here for the prior post.
Charges: None (reference made to violations of the FCPA’s anti-bribery provisions).
Resolution Vehicle: Declination with disgorgement.
Guidelines Range: Not mentioned in the resolution document.
Settlement: $1.2 million.
Origin: Voluntary disclosure.
Monitor: No
Individuals Charged: Yes
SEC Enforcement (Corporate)
Thus far in 2026, the SEC has not brought an enforcement action.
SEC Enforcement (Individual)
Thus far in 2026, the SEC has not brought an enforcement action.
Other Developments or Items of Interest
As discussed here, in February 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 highlighted here, the “foreign official” jury instruction in the Hobson case was flawed and Hobson’s motion for acquittal (filed on April 6th) remains outstanding.
In the on-going FCPA enforcement action against Smartmatic, in March the company filed a motion to dismiss on the basis of “vindictive and selective prosecution.” (See here and here). As highlighted in this post, Smartmatic separately filed a motion for a bill of particulars asserting that the “the Constitution protects defendants … from having to defend against such opaque charges.”
As discussed here, in March various Democratic Senators introduced a short bill titled “The FCPA Reinforcement Act” seeking to temporarily extend the statute of limitations for criminal FCPA anti-bribery offenses. For additional reading, see prior posts here and here.
As discussed here, in March the DOJ released yet another non-binding policy document titled “Corporate Enforcement and Voluntary Self-Disclosure Policy.”
In April, Judge Kenneth Hoyt (S.D. Texas) granted post-trial motions by Ramon Alexandro Rovirosa Martinez and ordered that he be released from prison. In terms of background, in December 2025 Rovirosa was found guilty after a bizarre trial of various charges in connection with an alleged Mexican bribery scheme. (See here for the prior post). As reported here, the trial featured no fact witnesses which led the judge to block the government from introducing most of its evidence until their closing argument. Soon after the verdict, Rovirosa was taken into custody and remained in custody as a motion for a judgement of acquittal and a motion to dismiss were filed based on various constitutional and evidentiary issues. The DOJ has filed a notice of appeal in the Fifth Circuit (see here).
This post highlights the Second Circuit appeal of Glenn Oztemel (previously employed by Arcadia Fuels Ltd. and Freepoint Commodities LLC) who was found guilty at trial in September 2024 of FCPA and related offenses in connection with a Brazil bribery scheme. Statute of limitations issues are among the issues on appeal.
As highlighted here, Abraham Cigarroa Cervantes (a Mexican citizen and a former finance director of the Latin America division of Stericycle) pleaded guilty to conspiracy to violate the FCPA’s anti-bribery provisions in connection with bribery schemes in Mexico, Brazil, and Argentina. Cigarroa was charged in March 2024 arrested in December 2025 in Argentina while hiking with his family in Patagonia.
