Introduction

As was the case throughout 2025, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) continued to pursue Foreign Corrupt Practices Act (FCPA) enforcement actions at a relatively slow pace during the first quarter of 2026. Both the DOJ and SEC were busy during Q1 with other developments impacting FCPA-related enforcement. Namely, the SEC updated its Enforcement Manual for the first time since 2017 (discussed in detail here) and the DOJ issued a department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) and created a new fraud-focused enforcement division.

DOJ Updates

On March 10, 2026, the DOJ announced a department-wide CEP for all criminal matters, with the exception of antitrust violations. The new policy would apply to FCPA cases. The DOJ noted that the new CEP is intended to "promot[e] uniformity, predictability, and fairness." The new department-wide CEP replaces but is largely similar to the Criminal Division's most recent iteration of the CEP (previously discussed here), which rolled out in May 2025. As with the Criminal Division's latest CEP, the department-wide policy provides for a declination when a company has voluntarily self-disclosed misconduct, fully cooperated, timely and appropriately remediated the causes of the issues involved, and otherwise presents no aggravating circumstances. There are only a few key changes in the department-wide policy:

• Under the new CEP, in order to receive voluntary self-disclosure credit, companies must make the disclosure to the "appropriate component of [DOJ]." Similar to the preexisting Criminal Division CEP, the DOJ will credit instances where a "good faith disclosure" was made to one DOJ component and the DOJ's investigation is later carried out by "another appropriate component." The new CEP now also clarifies that generally, "[d]isclosures made only to federal regulatory agencies, state and local governments, or civil enforcement agencies" will not qualify as disclosures to the DOJ, but the DOJ notes that such disclosures "may qualify if appropriate under the circumstances." Even when such disclosures do not qualify, the DOJ recognizes that these actions may still be considered when evaluating the company's cooperation and remediation – and thus these disclosures are still valuable when aiming to obtain a favorable settlement.
• While the CEP does not provide specific timelines, the new policy also directs prosecutors to inform companies of whether they meet the voluntary self-disclosure requirements "as soon as practicable." The DOJ notes that this requirement is intended "[t]o minimize uncertainty for companies that self-report."
• In the event of a "near miss" voluntary self-disclosure or aggravating circumstances, though not in the case of "particularly egregious or multiple aggravating circumstances," the new CEP indicates that companies will still be eligible for a non-prosecution agreement (NPA) with a term length of less than three years and no Independent Compliance Monitor. This concept was in the preexisting Criminal Division CEP.  The new CEP also retained the language that companies with a "near miss" voluntary self-disclosure or aggravating circumstances that cooperate and remediate will receive a reduction in the criminal fine. However, the proposed reduction has changed, increasing the DOJ's discretion and potentially minimizing the discount companies will receive. Under the new CEP, companies will receive "a reduction of at least 50% but not more than 75% off the low end of the U.S. Sentencing Guidelines... fine range." The Criminal Division's CEP previously provided for a standard 75 percent reduction. 
• In these same cases – when companies "nearly miss" satisfying the declination requirements – the DOJ now offers the NPA package discussed above not only to companies that do not quite qualify for voluntary self-disclosure credit or had aggravating circumstances, but also to companies that nearly missed the voluntarily self-disclosure and had aggravating circumstances. This change may make it possible for more companies to receive the NPA settlement option. Companies will still be expected to fully cooperate and timely and appropriately remediate in order to be eligible for the "near miss" option.
• As before, DOJ prosecutors will consider whether a company is a recidivist when determining the appropriate form of a corporate resolution. The DOJ continues to indicate that it will consider criminal adjudications and resolutions within the prior five years. The new CEP slightly expands the scope of the DOJ's review by also directing prosecutors to consider corporate criminal matters involving misconduct similar to that under investigation, seemingly outside of the five-year period. Such an expansion would move back towards the broader conception of recidivism incorporated into the CEP during the Biden administration. 
• The new CEP also provides some additional guidance on receiving cooperation credit. As before, the policy explains that if a company generally meets the requirements for cooperation credit, the DOJ will assess "the scope, quantity, quality, impact, and timing of cooperation." Now, the new policy explicitly notes that as part of that analysis, the DOJ will also consider "the size, sophistication, and financial condition of the cooperating company." Under prior CEP guidance, the Criminal Division considered whether a company's financial condition functioned as an impediment to more fulsome cooperation. Consistent with that prior approach, the DOJ is now explicitly expected to also consider the impact of a company's size and sophistication, potentially allowing for increased cooperation credit in more instances. Prosecutors are also required to explain the reasoning behind their cooperation credit determinations in corporate resolution agreements. 

The new CEP was announced two weeks after the U.S. Attorney's Office for the Southern District of New York (SDNY) announced its own Corporate Enforcement and Voluntary Self-Disclosure Program. In rolling out the department-wide CEP, the DOJ noted that the CEP "supersed[ed] all component-specific or U.S. Attorney's Office-specific corporate enforcement policies currently in effect." As a result, the SDNY policy appears to be no longer operational. 

During the first quarter of 2026, the DOJ also created the National Fraud Enforcement Division (NFED). On January 8, 2026, the White House initially announced the new division during a press conference and publicized it in a Fact Sheet, which notes that the NFED would "enforce the Federal criminal and civil laws against fraud targeting Federal government programs, Federally funded benefits, businesses, nonprofits, and private citizens nationwide." Additionally, the NFED was expected to establish national enforcement priorities and potentially propose legislative and regulatory reforms. Subsequently, on January 16, 2026, the DOJ issued a letter to U.S. Congressman Hal Rogers (R-KY), Chairman of the Subcommittee on Commerce, Justice, Science, and Related Agencies, regarding the new division. Consistent with the White House's announcement, the letter indicated NFED would be led by an Assistant Attorney General (AAG), appointed by the president and confirmed by the U.S. Senate. Proposed organizational charts attached to the letter indicated that the new AAG would report to the Deputy Attorney General (DAG). This contradicted an earlier statement by Vice President Vance, who had indicated the NFED would be "run out of the White House." The White House later nominated Colin McDonald to lead the NFED as Assistant Attorney General, and on March 24, 2026, he was confirmed.

On April 7, 2026, Acting Attorney General (AG) Todd Blanche issued a memorandum formalizing the creation of the NFED. At this time, it is unclear how the creation of the NFED will impact the DOJ's FCPA Unit, which is currently housed within the preexisting Fraud Section within the Criminal Division. One possibility is that FCPA Unit attorneys will be assigned to the NFED, further reducing the number of prosecutors dedicated to FCPA enforcement. 

FCPA Enforcement Actions and Related Developments

In the first quarter of 2026, there was only one corporate resolution: the DOJ issued a declination to Balt SAS and its subsidiary Balt USA LLC for engaging in an alleged bribery scheme in France. This declination is discussed in detail further below. 

The voting machine company Smartmatic continued litigating corruption charges in court. In October 2025, the DOJ filed a superseding indictment that added Smartmatic to an ongoing case against former Smartmatic executives. On March 10, 2026, Smartmatic filed a motion to dismiss, arguing that the DOJ's indictment of the company was "vindictive" and "selective." Smartmatic claimed that it had been cooperating with the DOJ's investigation since 2021 and was only later indicted after the current Trump administration assumed office because President Trump blames the company for his 2020 election loss and Smartmatic had been pursuing defamation suits against President Trump's allies for those claims. In a response filed on March 24, 2026, the DOJ denied that the indictment was politically motivated, and explained that it had never concluded its investigation into Smartmatic and there had been ongoing discussions regarding a potential corporate resolution. The DOJ claimed that in the months prior to the filing of the superseding indictment, Smartmatic rejected a July 2025 resolution offer that would have required a Smartmatic subsidiary to plead guilty. At time of publication, the motion to dismiss remains pending before the court.

On the SEC side, one potentially noteworthy development is evidence that the SEC is continuing its investigation of certain personnel connected to India's Adani Group, announced in November 2024. The SEC's complaint alleged in part that these individuals "engaged in a bribery scheme to obtain contracts that benefitted [certain companies], while, at the same time, falsely touting the company's compliance with antibribery principles and laws in connection with a $750 million bond offering." According to a status update filed with the court in October 2025, the case had been stalled due to lack of response from relevant Indian authorities to requests for treaty-based assistance to formally serve the complaints on the defendants in India. 

In light of these issues, on January 21, 2026, the SEC petitioned the court to allow for alternative service methods. Following subsequent discussions with the defendants' U.S. counsel, on January 30, 2026, the parties filed a proposed joint motion establishing the manner under which the case can move forward. On April 7, 2026, defendants' counsel filed a letter with the court summarizing legal arguments for an "upcoming motion to dismiss" the case. The trial judge has scheduled a pre-motion conference for May 29, 2026. 

In contrast to the relative standstill in the corporate enforcement space, Q1 2026 continued to see indictments and other developments in several cases against individuals, discussed below. In one noteworthy development in early Q2 2026, the federal trial judge presiding over the prosecution of Ramón Alexandro Rovirosa Martínez (who was convicted by a jury in December 2025 on two counts of violating the FCPA and one related conspiracy count) granted Rovirosa an acquittal based on the defendant's motion to dismiss. The judge held that the DOJ's failure to call the prosecution's Spanish translators at trial violated Rovirosa's Sixth Amendment "confrontation clause" rights, and thus the charges were not supported by sufficient evidence. The DOJ filed a notice of appeal on May 8, 2026. We will discuss this case in more detail in the next Review.

Further below, we also discuss various World Bank debarments and international developments. 

Other Indicia of Enforcement Trends, Including Investigation-Related Announcements

The DOJ and SEC continued to close FCPA investigations without further action throughout the beginning of 2026. In some cases, 2026 securities filings also identified additional investigation closures from the second half of 2025. 

• On February 11, 2026, medical device manufacturer Stryker Corporation (Stryker) disclosed that the SEC closed its investigation into potential FCPA violations. The SEC informed the company of its decision to close its investigation on December 16, 2025, approximately eight months after the DOJ informed Stryker that it had closed its inquiry. In its disclosure, Stryker also indicated that it is still responding to related inquiries "by certain foreign authorities arising in the normal course of business."
• On February 24, 2026, another medical device manufacturer, Merit Medical Systems, Inc. (Merit), disclosed that the SEC had previously closed an investigation into a subsidiary's conduct in China during the third quarter of 2025. The investigation focused on the subsidiary's "interactions with hospitals and health care officials" but was ultimately concluded with the SEC recommending no further action.
• Dr. Reddy's Laboratories Limited (Dr. Reddy's), an India-based pharmaceutical company, reported that both the SEC and DOJ closed their investigations into possible corrupt activities in Ukraine and potentially other countries. The SEC closed its probe on February 23, 2026. Several days later, on March 5, 2026, the DOJ also notified Dr. Reddy's that it was similarly closing its investigation without any further action.

Separately, in a February 25, 2026, securities filing, Cemex, S.A.B. de C.V. (Cemex) disclosed that it "believes" both the DOJ and SEC have closed years-long FCPA investigations into the company's conduct. Cemex reported originally receiving subpoenas from the SEC in December 2016 and later receiving a grand jury subpoena from the DOJ in March 2018. Cemex reportedly provided all requested information to the agencies in 2020 and has not received any additional requests since. Based on the six-year lapse, Cemex suspects the investigations were closed, though it has not received a formal notification from either the DOJ or SEC.

Another indicator of the decline in FCPA enforcement and SEC enforcement more generally is a recent SEC report confirming the dearth of recent whistleblower awards. The SEC, which is responsible for administering awards under the Dodd-Frank Act's Whistleblower Program, recorded a near halt in award activity during the first half of federal fiscal year (FY) 2026, covering the period from October 1, 2025, through March 31, 2026. After not issuing any awards over 24 claims during the first quarter, the SEC concluded the second quarter by granting a single award order of approximately $570,000. 

This represents a 91 percent decline in the number of awards compared to the same period in FY 2025, when the SEC issued 11 awards during the first half of FY 2025. In February of this year, the SEC released its Annual Whistleblower Report to Congress, which reflected that the program awarded just over $60 million in FY 2025. By contrast, based on data previously reported by the SEC, total awards under the program reached roughly $600 million in FY 2023 and $255 million in FY 2024, highlighting the sharp decrease in recent award activity.

While FCPA enforcement has slowed and investigations continue to close, members of the U.S. Congress and the Helsinki Commission are advocating for heightened anti-corruption enforcement. Below, we discuss congressional efforts to extend the statute of limitations for FCPA violations and the Helsinki Commission's push for increased enforcement of the Foreign Extortion Prevention Act (FEPA). These efforts demonstrate that although anti-corruption enforcement is currently down, parts of the U.S. federal government still have an appetite for prioritizing these issues. 

DOJ Corporate Resolutions

DOJ Issues First Declination with Disgorgement Under Revised CEP

On March 17, 2026, the DOJ issued its first corporate declination related to FCPA violations since announcing its department-wide CEP just one week earlier; we discuss the updated CEP in the Introduction.  
 
Pursuant to the CEP, the DOJ formally declined to prosecute Balt SAS and its subsidiary, Balt USA LLC (together, Balt), for FCPA violations arising from an alleged bribery scheme involving a physician working at a state-owned public hospital in France. The declination came on the heels of an indictment issued by the U.S. District Court for the Central District of California against two individuals who were allegedly involved in the bribery scheme, reinforcing the DOJ's stated priority of prosecuting individual misconduct. 
 
According to the declination letter, from approximately 2017 to 2023, Balt engaged in a scheme to pay $602,000 in bribes to a physician working at Maison Blanche (CHU Reims), a French state-owned and state-controlled public university hospital affiliated with Centre Hospitalier Universitaire de Reims. The physician held a senior position at CHU Reims and qualified as a "foreign official" under the FCPA (15 U.S.C. § 78dd-2(h)(2)(A)). According to the DOJ, Balt made the payments to induce the foreign official to cause CHU Reims to purchase endovascular embolization coils and other ancillary medical devices from Balt. To facilitate and conceal the payments, Balt routed the funds through a Belgian-based consulting company, using "fake invoices" and "bonus payments" to disguise the true nature of the payments to the consulting group. The bribery scheme resulted in approximately $1.7 million in revenue and $1.2 million in profit for Balt. 
 
To support its declination decision, the DOJ cited:

• Balt's voluntary self-disclosure of the misconduct (discovered through an internal investigation launched after the company received anonymous allegations)
• Balt's full cooperation, including the "provision of all known relevant facts of the misconduct and information regarding the individuals involved"
• "[T]he nature and seriousness of the offense"
• Balt's timely and thorough remediation efforts, including disciplining responsible individuals, terminating "business relationships that gave rise to the misconduct," enhancing the corporate compliance program and internal controls, and providing "tailored compliance training for Balt senior management"
• The absence of aggravating circumstances
• Balt's acceptance of responsibility and acquiescence to a parallel resolution with French authorities (which the letter noted would also include "compliance requirements imposed under the French system")
• Balt's agreement to disgorge $1.2 million in ill-gained profits

Balt also agreed to fully cooperate with the U.S. government's ongoing investigation. 
 
Consistent with the declination letter's statement that Balt entered into a resolution with French authorities, the Parquet National Financier (PNF) in France announced on March 19, 2026, that a Paris court had approved a €1.8 million ($2 million) judicial public interest agreement (CJIP) with Balt to resolve alleged violations of French law related to the same underlying activity. Pursuant to the CJIP, Balt also agreed to go through a three-year compliance program review led by French authorities. This settlement was coordinated with the DOJ's declination: French prosecutors subtracted the $1.2 million paid to the DOJ from the French penalty, which would have otherwise been €3 million. Notably, the French investigation began in 2023, the same year Balt voluntarily self-reported to the DOJ, indicating that U.S.-French enforcement coordination occurred throughout the case.  
 
As noted, while the company avoided prosecution, the DOJ is pursuing cases against individuals for their role in Balt's bribery scheme. On March 4, 2026, a federal grand jury in the Central District of California indicted two individuals: David Ferrera, a former senior executive of Balt USA, and Marc Tilman, the owner and operator of the Belgian consulting company. According to the indictment, between approximately 2017 and 2023, Ferrera caused Balt to make corrupt payments to Tilman, knowing that Tilman would pay a portion of the funds to a French "official" as bribes. The indictment alleges that Ferrera and Tilman, together and with others, took steps to conceal the bribery scheme by communicating on personal e-mail accounts and encrypted messaging services, using coded language like "training" and "bonuses" to justify the bribes, referring to the physician official as "our friend," and creating fake consulting agreements and invoices to conceal the true nature of the bribe payments. The individuals are charged with conspiracy to violate the FCPA, substantive FCPA anti-bribery violations, conspiracy to commit money laundering, money laundering, aiding and abetting the commission of a federal crime, and civil and criminal forfeiture. 
 
Taken altogether, the DOJ's decision to decline prosecution of Balt, the government's indictment of individuals allegedly involved in the bribery scheme, and its coordination with French prosecutors demonstrate the continued application of the DOJ's policy to prosecute individual misconduct while rewarding companies that disclose misconduct, fully cooperate in investigations, and effectively remediate the underlying issues, as explicitly stated in the CEP. While coordination between the DOJ and foreign authorities has continued in some cases, the Balt disposition also comports with the administration's view that "[c]onduct that does not implicate[core] U.S. interests should be left to our foreign counterparts or appropriate regulators." 

Cases Involving Individuals

Indictment Against Former NATO Official and Turkish Defense Contractor for Bribery Scheme Unsealed

On January 26, 2025, the DOJ announced the unsealing of an indictment against Ralf Grywnow, a German national and former official of the North Atlantic Treaty Organization (NATO) Support and Procurement Agency, and Bahadir Hatipoglu, a Turkish national, in federal court in the District of Columbia. The indictment charges Grywnow and Hatipoglu with one count of conspiracy to commit wire fraud and four counts of wire fraud each.

The indictment alleges that the two men engaged in a bribery scheme in which Hatipoglu provided Grywnow with cash, a romantic encounter with a woman, and assistance constructing and furnishing a house in Poland to be used by Grywnow and one of his romantic partners. In exchange, Grywnow gave Hatipoglu preferential treatment in overseeing NATO contracts, provided Hatipoglu with confidential information related to bids for NATO contracts, and helped companies owned by Hatipoglu secure contracts with the U.S. military by providing falsified positive reviews of the companies' work with NATO. 

Grywnow and Hatipoglu were both arrested abroad (in Poland and Lithuania, respectively), and the DOJ is collaborating with authorities in each country to secure their extradition to the U.S. Both men face up to 20 years imprisonment if convicted.

Senior U.S. African Development Foundation Official Agrees to Plead Guilty to Accepting Bribes

On January 30, 2026, the DOJ announced that Mathieu Zahui, Director of Financial Management of the U.S. African Development Foundation (USADF), agreed to plead guilty to one count of accepting gratuities as a public official and one count of making a false statement to federal law enforcement officers. 

According to the indictment, Zahui arranged for a Kenya-based company (Company-1) owned by a government contractor Zahui had known for over 20 years (CC-1) to act as a pass-through entity for USADF payments to certain vendors. The indictment alleges that Zahui approved USADF payments on invoices from Company-1 that contained markups of up to 66 percent (amounting to an additional $134,000) compared to what USADF would have paid directly to vendors, despite knowing that Company-1 had done "little-to-no actual work" justifying the markups. 

Zahui also accepted $12,000 in cash payments from CC-1. However, when interviewed by special agents from the U.S. Agency for International Development (USAID) regarding his relationship with CC-1, Zahui falsely claimed that he had never received any benefits from CC-1.

According to the DOJ press release, Zahui faces maximum penalties of two years in prison for the charge of accepting gratuities and five years in prison for the charge of making a false statement to federal law enforcement officers.

U.S. District Court Rejects Leissner's Request to Delay Commencement of Prison Sentence

On February 4, 2026, former Goldman Sachs banker Tim Leissner filed a motion in the U.S. District Court for the Eastern District of New York to delay by one month the date upon which he must report to prison. The judge denied the motion and Leissner reported to a federal correctional center as required on February 6, 2026, to begin serving his sentence.

Leissner pled guilty to conspiracy to violate the FCPA and conspiracy to launder money for his role in a multi-billion dollar scheme involving the state-owned Malaysian development fund 1Malaysia Development Berhad (1MDB) and bribes to government officials in Malaysia and Abu Dhabi back in 2018; however, due to repeated delays, Leissner's sentence of two years in prison was not handed down until May 2025.

Leissner's recent motion represented his fourth request to delay the start of his imprisonment. His counsel claimed that reporting to prison on February 6, 2026, as scheduled would cause Leissner, a German national, to be unable to appear virtually in ongoing immigration proceedings related to his lawful permanent resident status. 

Court Declines to Dismiss FCPA Case Against Senegalese Businessman Due to Alleged Violations of Rights to Speedy Trial and Effective Assistance of Counsel

On February 13, 2026, a federal judge denied Amadou Diallo's motion to dismiss his case due to violations of the Sixth Amendment and his right to a speedy trial. The DOJ charged Diallo, a Senegalese businessman, with violating the FCPA in 2023 for providing lavish gifts to various Senegalese officials and Diallo has since been detained despite multiple unsuccessful attempts to obtain bail.

Diallo's motion argued that a lack of funding for court-appointed defense lawyers impeded his counsel's ability to provide him with effective assistance of counsel in a timely manner, therefore violating his constitutional rights and justifying dismissal of the case. The DOJ responded that dismissal was not an appropriate remedy, pointing to Diallo's repeated firing of his legal representation and requests for continuances. The judge denied Diallo's motion and ordered a new trial date of August 18, 2026.

Former Corsa Coal Corporation Executive Convicted for Money Laundering, Wire Fraud, and Bribery of Egyptian Officials

On February 19, 2026, a federal jury convicted Charles Hunter Hobson, former vice president of Corsa Coal Corporation (Corsa), of one count of conspiracy to violate the FCPA, two counts of violating the FCPA, one count of conspiracy to commit money laundering, two counts of money laundering, and one count of conspiracy to commit wire fraud.

According to the court documents, between 2016 and 2020, Hobson paid $4.8 million in bribes to Egyptian government officials in order to secure lucrative contracts for Corsa with the then-state-owned Egyptian chemical manufacturing company Al Nasr Company for Coke and Chemicals. Hobson allegedly paid the bribes through sales commissions passed through an intermediary in Egypt. The DOJ alleged that Hobson himself received over $200,000 in kickbacks from the bribe payments.

Hobson faces up to five years in prison on each of the FCPA-related counts and up to 20 years in prison on each of the money laundering- and wire fraud-related counts. He is scheduled to be sentenced on June 25, 2026.

California Lawyer Sentenced to Over Seven Years in Prison for Accepting $2.1 Million Bribe as an Official of Nigerian Oil Company

On February 23, 2026, a court sentenced Paulinus Iheanacho Okoronkwo, a Los Angeles-based lawyer, to 87 months in prison for receiving a $2.1 million bribe while serving in his former role as a foreign official of the state-owned Nigerian National Petroleum Corporation (NNPC). On August 28, 2025, a federal jury in California convicted Okoronkwo of "three counts of transactional money laundering, one count of tax evasion, and one count of obstruction of justice."

According to the DOJ's August 2025 press release, Addax Petroleum wired the bribe to Okoronkwo's Interest on Lawyers' Trust Account (IOLTA), disguised as payment for purported legal and consulting services that Okoronkwo provided in relation to a settlement between Addax Petroleum and NNPC. In reality, per the DOJ, the sum was payment for Okoronkwo using his influence as an official of NNPC to secure favorable financial terms for Addax Petroleum to exercise oil drilling rights in Nigeria. Okoronkwo routed the funds from his IOLTA to a company called IPO Capital LLC before using them to purchase a house and car and to pay family expenses.

In addition to his prison sentence, the court ordered Okoronkwo to pay $923,824 in restitution to the Internal Revenue Service (IRS) due to his failure to disclose the payment on his tax returns and to forfeit the proceeds (over $1,000,000) from the sale of the house he purchased with the bribe money. The State Bar of California suspended Okoronkwo's license to practice law in January 2026.

Oil Consultant Pleads Guilty to Facilitating Bribes to Pemex Officials

On March 31, 2026, Alfonso Wilson, a Houston-based oil industry consultant, pleaded guilty to one count of conspiring to violate the FCPA. According to the Information filed in the Southern District of Texas, Wilson conspired with five individuals to pay millions of dollars in bribes to a Petróleos Mexicanos (Pemex) official to facilitate the award of a $540 million contract to a Texas-based equipment supplier. The DOJ alleged that Wilson worked as a liaison between the Pemex official and the Texas-based company. As part of the deal with DOJ, Wilson agreed to pay $383,896 in forfeiture. Wilson is scheduled to be sentenced on June 26, 2026. He faces a maximum penalty of five years in prison and a fine of up to $250,000.

Congressional Developments

Helsinki Commission Urges Robust FEPA Enforcement

On February 6, 2026, bipartisan leadership of the U.S. Helsinki Commission wrote to then-AG Pam Bondi, with copies to Secretary of the Treasury Scott Bessent and Secretary of Commerce Howard Lutnick, urging the relevant government departments to "robustly enforce" the FEPA. Per the Commission's accompanying press release, the Helsinki Commission, established in 1976, is a U.S. government commission made up of 21 Commissioners from the Senate, House of Representatives, and executive branch. Its express goal is promoting human rights, economic cooperation, and military security in 57 countries. Thirteen Commissioners (seven Republicans and six Democrats) signed the letter, representing a bipartisan effort.

The letter outlined the DOJ's ability under FEPA to prosecute foreign officials who demand bribes from U.S. actors, opining that FEPA enforcement is key to Trump administration priorities. In particular, the letter flagged policy documents like the February 2025 Presidential Memorandum "Defending American Companies and Innovators from Overseas Extortion and Unfair Fines and Penalties" and the DOJ's May 2025 white collar crime enforcement plan as illustrative of the administration's focus on these issues. The letter urged the government to "urgently and fully realize its commitment to prioritize FEPA cases with national security implications, including those involving foreign adversaries, sanctions evasion, and corruption that undermines U.S. firms abroad." 

No FEPA enforcement actions have been publicly brought since the law was enacted in 2023. To date, the government has not responded publicly to the letter.

Senators Propose Temporary Extension of FCPA Statute of Limitations

On March 9, 2026, several U.S. senators (all Democrats) introduced the FCPA Reinforcement Act, which would extend the FCPA's statute of limitations from five to 10 years. As written, the bill would sunset eight years after its enactment. The Senate Committee on Foreign Relations press release accompanying the bill criticized a perceived weakening of FCPA enforcement by the Trump administration, explaining that the bill was designed to "signal that bribery could well be prosecuted later even if it is presently outside of DOJ's narrowed focus." Sponsors of the bill emphasized its importance not only to promote global accountability for anti-corruption – and U.S. credibility – but specifically to empower future presidential administrations to prosecute FCPA violations that the Trump administration has not pursued.

Given Republican control of Congress and likely hostility from the current administration to extending the limitations period, this bill is unlikely to become law. However, the "signal" that future Congresses and administrations likely will bring renewed interest to FCPA enforcement is one that companies should account for in their compliance planning and execution. 

Actions by Multilateral Development Banks

World Bank Debars Turkish Company Aktif Elektroteknik

On March 9, 2026, the World Bank Group Sanctions Board issued a one-year-and-three-month debarment with conditional release to the Turkish engineering firm Aktif Elektroteknik San ve Tic A.S. (Aktif) for "corrupt and fraudulent practices" involving a Bank-financed energy project in Iraq dating back to 2016. The World Bank Integrity Vice Presidency (INT) found that the company, with the involvement of its CEO, approved improper payments to Iraqi officials during the contract award process. According to INT, Atkif's joint venture (JV) partner made the payments in exchange for the JV obtaining a contract for which it had initially been considered ineligible. INT obtained evidence including emails and contractual documentation showing that the improper payments were built into project cost calculations as "envisaged expenses." The Sanctions Board noted aggravating factors including the company's concealment of the payments, senior level involvement, and limited cooperation during the investigation, while it declined to accept other arguments raised by the company, such as its full performance of the contract and the direct involvement of its JV partner in the payments. Per the Sanctions Board decision, after the debarment period ends, the company will be required to undergo an evaluation by the Bank's Integrity Compliance Office before it can regain eligibility to participate in Bank-financed projects.

World Bank Debars PwC entities in Mauritius, Kenya, and Rwanda

On March 18, 2026, the World Bank Group announced a one-year-and-nine-month debarment with conditional release for PricewaterhouseCoopers Associates Africa Ltd. (Mauritius), PricewaterhouseCoopers Ltd., Kenya, and PricewaterhouseCoopers Rwanda Ltd. for their involvement in "collusive and fraudulent practices" in connection with an energy-related investment project spanning Kenya and Ethiopia. The debarment stems from a Negotiated Resolution Agreement (settlement) between the firms and INT. Under the settlement, the entities admitted to improperly obtaining confidential information from project officials to influence the award of a 2019 consultancy contract, and to influencing the award of an additional accounting services contract through misrepresentations regarding the qualifications of key experts and by failing to disclose the involvement of subcontractors. The sanction was reduced in recognition of the companies' admission of misconduct and cooperation, though the settlement included the commitment of the entities to enhance their integrity compliance programs and controls. According to the decision, these enhancements must align with the World Bank's recently updated Integrity Compliance Guidelines and will serve as a condition for their release from debarment.

International Developments

Transparency International Releases 2025 Corruption Perceptions Index 

On February 10, 2026, Transparency International (TI) issued its 2025 Corruption Perceptions Index, a ranking list that compares the perceived levels of governmental corruption in 182 countries. The index scores countries on the level of perceived corruption on a scale of zero to 100, with zero representing the highest level of perceived corruption and 100 representing a hypothetical corruption-free country. The top-scoring country (with the lowest perceived corruption) in 2025 was Denmark, with a score of 89; the countries perceived as most corrupt were Somalia and South Sudan, with a score of 9, and Venezuela, with a score of 11. The U.S. hit its lowest mark on record with a 64, down from 65 in 2024.

In its press release, TI noted that "the temporary freeze and weakening of enforcement of the Foreign Corrupt Practices Act signal tolerance for corrupt business practices, while cuts to US aid for overseas civil society have weakened global anti-corruption efforts." TI discussed these developments as evidence of a broader erosion of global leadership by the U.S. and Europe, which has undermined anti-corruption efforts. TI also noted that some high-scoring countries (namely Switzerland and Singapore) "enable corruption in other countries by facilitating the laundering and transfer of proceeds of corruption across borders," and flagged an increase in "politicised interference with the operations of [non-governmental organizations]" that "scrutinise and criticise" government activities in certain countries.

U.K. High Court Permits SFO to Enforce Breach of Guralp Systems DPA After Stated Expiration Date

On January 13, 2026, the High Court of England and Wales upheld a lower court's decision that the U.K. Serious Fraud Office (SFO) may pursue legal proceedings against Guralp Systems (Guralp) for breach of the company's deferred prosecution agreement (DPA) after it expired.

The SFO first investigated Guralp Systems in 2018 for allegedly conspiring to bribe a South Korean official to purchase earthquake detection technology from the company. In October 2019, Guralp entered into a DPA that required the company to disgorge £2 million in ill-gotten gains within five years of the date of the agreement. The DPA expired on October 22, 2024, without Guralp paying disgorgement, and the following month the SFO requested a hearing at the Southwark Crown Court to address the alleged breach.

According to the lower court's original decision, Guralp argued that the court lacked jurisdiction because the SFO waited until after the specified expiration date of the DPA to bring the proceedings, and therefore the DPA was no longer "in force" as required by applicable law. The SFO counterargued that it could not have brought proceedings at any time before the DPA expired on October 22, 2024, as Guralp had until that date to pay the disgorgement and therefore there was no breach of the DPA up until that point.

Looking to language of the DPA and the intent of the parties at the time they entered it, the court determined that the DPA was intended to remain "in force" beyond October 22, 2024, if Guralp had not paid the required disgorgement by that time. As such, the court stated that the SFO was permitted to pursue action against Guralp for breach of the DPA despite the fact that the action was not initiated until after the stated expiration date in the DPA.

According to the SFO's case summary, on February 10, 2026, "[t]he High Court refused Guralp Systems Ltd permission to appeal a previous ruling to the Supreme Court." 

Bribery Trial of Former Nigerian Oil Minister Commences in London

On January 27, 2026, the trial of former Nigerian oil minister Diezani Alison-Madueke began in the Southwark Crown Court. 

Alison-Madueke served as Nigeria's Minister of Petroleum Resources from 2010 to 2015 and was elected president of the Organisation of Petroleum Exporting Countries (OPEC) in 2014. She was the first woman to hold both positions. Investigation into Alison-Madueke by British authorities began in 2015 and in 2023, Britain's National Crime Agency (NCA) charged her with five counts of accepting bribes and one count of conspiracy to commit bribery. Alison-Madueke is alleged to have accepted several forms of bribes from Nigerian oil tycoons Olajide Omokore and Kolawole Aluko, including £100,000 in cash, the use and renovation of several expensive London properties, luxury goods from Louis Vuitton and Harrods, chauffeur-driven cars, and flights on private jets. In March 2023, the DOJ announced the completion of two forfeiture cases related to these allegations, resulting in the DOJ's recovery of "roughly $53.1 million in cash – constituting the net liquidated value of the defendant's assets – plus a promissory note with a principal value of $16 million."

Alison-Madueke has denied all charges. If convicted, Alison-Madueke could face up to ten years in prison and an unlimited fine. According to media reports, the trial was delayed for several weeks due to undisclosed reasons, and continued in mid-April. 

U.K. SFO Drops London Mining Sierra Leone Bribery Case

On February 12, 2026, the SFO announced it was discontinuing its prosecution of London Mining, which was scheduled to proceed to trial in April 2026. The SFO's investigation into London Mining had spanned nearly a decade and concerned company executives' alleged payments of bribes in Sierra Leone between 2009 and 2014. 

Explaining the rationale for its decision to discontinue the case, the SFO reported that due to "significant delays to trial, difficulties obtaining and reviewing material and challenges with witness evidence," there was now "no realistic prospect of conviction." 

The announcement came the same day that the SFO released an update on its ongoing review of its legacy e-discovery system, Autonomy, which has been plagued by technical issues affecting the availability of certain documents. The issues with Autonomy have led to delays in SFO document reviews and may have affected as many as 23 cases, including, potentially, London Mining.

New Interim Director of SFO Appointed

On February 26, 2026, the SFO announced the appointment of Graham McNulty as Interim Director following the resignation of Nick Ephgrave. Ephgrave, who began his five-year term as Director in 2023, announced in January 2026 his intention to retire early after a 38-year career in public service.

McNulty has been serving as chief operating officer (COO) of the SFO since September 2024. He has extensive experience in law enforcement, including a 31-year policing career in the Metropolitan and Hampshire forces, where he led teams responsible for investigating economic crime, kidnapping, homicides, and drug trafficking. 

McNulty began his new role at the SFO on April 6, 2026. On April 16, 2026, the SFO released its 2026-2027 Business Plan as one of McNulty's first official actions. In remarks tied to the plan's release, McNulty said that "[w]hile the complex nature of our cases means investigations can be lengthy, [the SFO] are determined to increase the pace and efficiency of our work." The Business Plan highlights continued cooperation with French and Swiss economics crime authorities, announced in March 2025, as well as hosting the inaugural International Anti-Corruption Prosecutorial Taskforce Economic Crime Conference in London in May 2026. 

Brazil's Updated Leniency Agreement Rules Broadens Incentives for Early Self-Disclosure

On December 19, 2025, Brazil's Comptroller General of the Union (CGU) and Attorney General of the Union (AGU) published an interagency directive (Portaria Interministerial) establishing new rules for negotiating and executing leniency agreements with companies accused of violating anticorruption laws. The directive allows for a penalty reduction of up to two-thirds for companies that voluntarily disclose irregularities within 12 months of discovery. The agencies are also now authorized to enter into a single leniency agreement with the Federal Prosecution Service (MPF).

Other key changes include specifically allowing companies to credit penalties imposed in third countries against the final monetary fine in Brazil, as well as establishing a limited safe harbor that allows companies to report misconduct before completing their internal investigation. This lets a company benefit from the 12-month voluntary disclosure deadline while still having time to finish the investigation. If the leniency agreement is not later signed, the CGU and AGU cannot use the facts previously shared against the company.

Brazil's Comptroller General Sanctions Nine Companies for Corruption and Procurement Fraud

On January 20, 2026, the CGU announced the imposition of sanctions against nine companies, totaling more than 211 million real (approximately $40 million) in fines. The enforcement actions targeted alleged misconduct in four separate schemes, including bribery involving Brazil's state-owned nuclear power company, Eletronuclear, procurement fraud in school transportation contracts and at the national pension agency (INSS), and bid rigging tied to Transpetro, a subsidiary of the country's state-owned oil and gas company, Petrobras, responsible for oil transportation. 

Peru Disbands Lava Jato Prosecutorial Team

On January 5, 2026, Peru's Prosecution Service (Ministerio Público Fiscalía de la Nación) announced the closure of the special Lava Jato prosecutorial team tasked with investigating the Operation Car Wash scandal. The team was created in 2016 following allegations that Brazilian construction company Odebrecht had paid bribes to secure contracts in Peru. According to media sources, the decision to close the team was based on a new institutional policy to strengthen permanent specialist offices focused on specific offenses, such as corruption and money laundering, rather than teams focusing on specific cases. Those media sources reported that enforcement actions targeting white collar crime are generally expected to continue. Brazil shut down its special Lava Jato squad in February 2021. 

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