This post provides a summary of Foreign Corrupt Practices Act enforcement activity and related developments from the second quarter of 2026. See here for the first quarter of 2026.
DOJ Enforcement (Corporate)
The DOJ did not bring an FCPA enforcement action in the second quarter.
DOJ Enforcement (Individual)
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 a bribery scheme in Mexico involving Pemex. 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.”
SEC Enforcement (Corporate)
The SEC did not bring an FCPA enforcement action in the second quarter.
SEC Enforcement (Individual)
The SEC did not bring an FCPA enforcement action in the second quarter.
Other Developments or Items of Interest
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.
