If you believe that Foreign Corrupt Practices Act enforcement has stopped, you are either highly misinformed or perhaps informed but more interested in advancing false narratives.
This post provides a summary of Foreign Corrupt Practices Act enforcement activity and related developments from the first quarter of 2026.
DOJ Enforcement (Corporate)
The DOJ announced one corporate enforcement action in the first quarter.
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
DOJ Enforcement (Individual)
In the first quarter, the DOJ announced FCPA charges against three individuals in two core actions.
As highlighted here, a few weeks prior to the 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.
SEC Enforcement (Corporate)
The SEC did not bring an FCPA enforcement action in the first quarter.
Other Developments or Items of Interest
During the first quarter, there were several developments in FCPA enforcement actions filed prior to 2026.
As discussed here, 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.
In the on-going FCPA enforcement action against Smartmatic, 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 highlighted in this prior post, in September 2025 a jury found Carl Zaglin guilty of FCPA and related offenses for his role in bribery schemes involving Honduran government officials to secure contracts to provide uniforms and other goods to the Honduran National Police. As discussed in this post, a judge recently granted Zaglin’s request for a federal prisoner to appear as a witness during a hearing on a new trial.
In December 2025, Ramon Alexandro Rovirosa Martinez was found guilty after a bizarre trial of various charges in connection with an alleged Mexican bribery scheme. (See here for the prior post). Post-trial, Rovirosa filed a motion for a judgement of acquittal as well as a “Motion to Dismiss Case with Prejudice Based on the Court’s Supervisory Powers.” Among the reasons stated were the following: “the Government attorneys in this case (1) made misrepresentations to the Court and/or to the jury that willfully mispresented both the record and the legal standards; (2) failed to provide evidence to defense counsel, and (3) failed to present any witnesses at trial with actual knowledge of the facts. Even more alarming, the case was under the legal supervision of a Department of Justice supervisory attorney, who apparently allowed such conduct to occur.”
In September 2024, Glenn Oztemel (previously employed by Arcadia Fuels Ltd. and Freepoint Commodities LLC) was found guilty at trial of FCPA and related offenses in connection with a Brazil bribery scheme. (See here for the prior post). Recently, a judge allowed Oztemel to remain free on bond pending appeal stating that the “case presents several novel issues of law which, frankly, should be addressed by [the appellate court].”
As discussed here, 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, the DOJ released yet another non-binding policy document titled “Corporate Enforcement and Voluntary Self-Disclosure Policy.”
