This post provides a summary of Foreign Corrupt Practices Act enforcement activity and related developments from the second quarter of 2025. (See here for a similar post for Q1 and here for Q2).
DOJ Enforcement (Corporate)
There was one corporate enforcement action brought by the DOJ in the third quarter.
As discussed here, Liberty Mutual Insurance resolved a $4.7 million enforcement action concerning “bribery committed by certain employees of the Company’s subsidiary in India who were acting as agents of the Company.” This post highlights additional issues to consider from the enforcement action.
DOJ Enforcement (Individual)
In the third quarter, the DOJ announced one core enforcement action involving two individuals. As highlighted here, the DOJ announced criminal charges against Ramon Alexandro Rovirosa Martinez (a citizen of Mexico and a lawful permanent resident of Texas) and Mario Alberto Avila Lizarraga (a citizen of Mexico and lawful permanent resident of Texas) for their roles in an alleged bribery scheme to retain and obtain business related to Petróleos Mexicanos (PEMEX), the state-owned oil company of Mexico, and PEMEX Exploración y Producción (PEP), PEMEX’s wholly owned exploration and production subsidiary.
SEC Enforcement (Corporate)
There were no corporate FCPA enforcement actions brought by the SEC in the third quarter.
SEC Enforcement (Individual)
There were no individual FCPA enforcement actions brought by the SEC in the third quarter.
Other Developments or Items of Interest
As discussed here, following the DOJ’s April dismissal of criminal charges against former Cognizant executives Gordan Coburn and Steven Schwartz in connection with an alleged Indian bribery scheme, the SEC also dismissed its civil enforcement action against the individuals.
As highlighted here, a Nigerian “foreign official” was convicted at trial of various offenses related to a bribery scheme.
As highlighted here, Carl Zaglin (the owner of a Georgia-based manufacturer of law enforcement uniforms and accessories) was found guilty at trial for his participation in a scheme to pay and conceal bribes to Honduran government officials to secure contracts to provide uniforms and other goods to the Honduran National Police.
In a speech, Acting Assistant Attorney General Matthew Galeotti stated that “white-collar enforcement remains a priority for the Criminal Division” and that foreign corruption is a “key priority area” for the DOJ. (See here).
As highlighted here, Vikas Sagar (a citizen of India who was a partner and senior partner of McKinsey working in McKinsey’s office in Johannesburg, South Africa) was sentenced to time served and ordered to return to India after pleading guilty to bribery schemes in South Africa.
