Calavo Growers
As highlighted in this prior post, in early 2024 Calavo Growers, Inc. “a global leader in quality produce, including avocados, tomatoes and papayas, and a pioneer of healthy fresh-cut fruit, vegetables and prepared foods” disclosed:
“On January 16, 2024, the Company announced that its internal audit process had identified to the Audit Committee of the Board of Directors certain matters that the Board of Directors determined after fiscal year end merited enhanced evaluation. A Special Committee of the Board of Directors (the “Special Committee”) was established to commence an investigation, with the assistance of external legal counsel and external forensic accountants. The Special Committee determined that certain of those matters related to the Company’s operations in Mexico raised potential issues under the Foreign Corrupt Practices Act (“FCPA”). The Company voluntarily disclosed this ongoing investigation to the SEC and the DOJ, and the Company intends to fully cooperate with the SEC and the DOJ in connection with these matters.”
In September 2025, the company disclosed:
“On September 2, 2025, the U.S. Department of Justice officially notified us that it has closed its Foreign Corrupt Practices Act (“FCPA”) inquiry related to our operations in Mexico.”
Recently, the company disclosed:
“On December 22, 2025, Calavo Growers, Inc. (the “Company”) received a letter from the staff of the U.S. Securities and Exchange Commission (the “Commission”) advising the Company that the Commission’s staff (the “Staff”) has concluded its investigation relating to the Company (the “Investigation”) and, based on the information available as of that date, does not intend to recommend an enforcement action by the Commission against the Company.”
Congressional Inquiry
Recently, various members of the U.S. House Committee on Oversight and Democratic Reform sent this letter to executives of Chevron, ExxonMobil, ConocoPhillips, and Continental Resources.
The letter seeks to “determine who stands to privately or personally benefit from President Trump’s actions [in Venezeula] and whether corrupt motives were a driving force in U.S. foreign policy decisions …”.
Among the categories of documents sought are:
“The measures your company has taken to ensure that its dealings with the Trump Administration, any member of the Trump Administration, and the Venezuelan regime comply with U.S. anticorruption laws, including the Foreign Corrupt Practices Act.”
Oztemel Forfeiture
As highlighted in this recent post, Glenn Oztemel was recently sentenced to 15 months in prison and ordered to pay a $300,000 fine after being found guilty at trial of FCPA and related offenses in connection with a Brazil bribery scheme.
Recently, the DOJ filed a notice with the court indicating that it and the defense agreed that an appropriate “forfeiture amount is $1,709,138, which is equal to the amount of U.S. dollar bribes paid to Rodrigo Berkowitz in connection with the charged scheme.” As stated in the filing: The parties have agreed that the Defendant will pay the forfeiture amount to United States on the following schedule: (a) $100,000 on or before February 9, 2026; (b) $464,013 by June 10, 2026; and (c) the balance of the forfeiture amount within one calendar year of the entry of the proposed forfeiture order.”
