This recent post compared corporate FCPA enforcement actions in 2025 to prior years.
However, before a Foreign Corrupt Practices Act enforcement action is announced, scrutiny must first arise.
This post highlights the origins of the three corporate enforcement actions in 2025. (See here for a similar post for 2024; here for 2023; here for 2022; here for 2021; here for 2020; here for 2019, here for 2018, here for 2017, and here for 2016).
Liberty Mutual
Voluntary disclosure.
Smartmatic
The corporate enforcement action is based on the same core allegations of a 2024 enforcement action against individuals associated with Smartmatic.
Millicom / Comcel
As stated by the DOJ:
“[I]n 2015, Millicom voluntarily and timely disclosed to the Criminal Division misconduct at the Company (Millicom’s then-joint venture) that, in part, forms the basis for this Agreement. However, despite Millicom’s 55% ownership share, Millicom lacked operational control over the Company. The Company’s Guatemalan shareholder used its operational control to prevent Millicom from accessing critical information, and to prevent Millicom from requiring Company personnel to cooperate with the Fraud Section’s investigation and take remedial actions. The Fraud Section closed its initial investigation in 2018. Two years later, in 2020, the Offices obtained and proactively developed new evidence from sources other than the Company and Millicom regarding the Company’s conduct and reopened their investigation on that basis. During the second phase of the investigation, the Offices obtained new and additional evidence about the scope of the Company’s conduct, including that the criminal conduct continued during and after the Offices’ closure of the first phase of the investigation and involved narcotrafficking proceeds that were used to generate cash for some of the bribe payments. For those reasons, while the Company received credit for Millicom’s self-report, the Company did not meet the requirements of the Criminal Division’s Corporate Enforcement and Voluntary Self-Disclosure Policy, to qualify for either a Part I or Part II resolution. Nonetheless, the Offices gave significant weight to the voluntary disclosure of the misconduct in 2015 in determining the appropriate disposition of this matter-including the form and term of the resolution and the maximum reduction for cooperation and remediation under Part III of the CEP.”
