FCPA Summer Review 2026
International Alert
Introduction
Foreign Corrupt Practices Act (FCPA) enforcement continued its slow pace in the second quarter of 2026, reflecting the current administration's focus of enforcement assets on other areas and issues. The Department of Justice (DOJ) primarily focused on individual actions whereas the Securities and Exchange Commission (SEC) resolved one non-FCPA action related to foreign bribery and continued to close FCPA investigations started in prior years without action. The quarter also included an important Supreme Court decision addressing the SEC's disgorgement authority and international developments in the U.K. and Europe.
The third quarter opened with the DOJ announcing a three-year deferred prosecution agreement (DPA) with the Scoular Company, a Nebraska-based agricultural supply chain company, for FCPA anti-bribery violations. The Scoular Company disposition is covered here in a separate alert.
DOJ Updates
During the second quarter of 2026, the DOJ secured guilty pleas for a former Stericycle finance director and for an Austrian banker involved in the long-running Odebrecht bribe laundering case. The DOJ prosecution of individuals hit a roadblock in April, when a district court judge issued a decision acquitting Texas-based businessman (and Mexican national) Ramón Alexandro Rovirosa Martínez based on the DOJ's failure to call the translators of key Spanish-language communications as witnesses, which the judge held denied the defendant his Sixth Amendment rights to challenge the evidence. The DOJ has appealed the decision.
The DOJ has also faced scrutiny from another district court judge (as well as two U.S. senators) related to their May 19, 2026, request that the judge dismiss criminal charges (including conspiracy to violate the FCPA) against Gautam Adani (a prominent Indian billionaire) and several co-defendants. The judge presiding over the case ordered the DOJ to justify its decision and requested that Mr. Adani submit an affidavit addressing whether he promised the U.S. government anything in exchange for dropping the charges. The DOJ recently filed its justification claiming that the case is a foreign matter better addressed by the Indian government, while Mr. Adani's July 15, 2026, affidavit stated that he was not aware of any promises or offerings made in exchange for the dismissal.
On May 27, 2026, a district court judge granted the DOJ's motion to dismiss the indictments against Full Play Group and former Fox executive Hernán López, which were prosecutions relating to the long-running Fédération Internationale de Football Association (FIFA) corruption probe. López and Full Play were convicted in 2023 after prosecutors alleged they participated in a scheme to pay bribes to soccer officials in exchange for commercial rights to tournaments. The dismissals followed the Supreme Court's January 2026 order vacating lower court rulings against the two defendants after the U.S. Solicitor General informed the Court of the administration's view that dismissal of the case was "in the interests of justice."
In other news, the DOJ FCPA Unit has continued to lose experienced prosecutors, with three attorneys announcing their departure in June 2026. In an effort to restaff the FCPA and Market, Government, and Consumer Fraud Units, the DOJ issued a hiring notice on June 23, 2026, suggesting that the DOJ intends to continue to prosecute FCPA matters and other fraud issues going forward.
SEC Updates
In parallel with the DOJ's effort to dismiss charges against Gautam Adani, the SEC moved to resolve charges that he and Executive Director Sagar Adani of Adani Green Energy Ltd.'s Board of Directors violated section 17(a) and section 10(b) of the Securities Act by falsely stating that the company was in compliance with anti-bribery principles and laws in connection with a $750 million bond offering while actively engaged in a bribery scheme in India. Gautam and Sagar Adani executed consent agreements with the SEC without admitting or denying the allegations and agreed to pay civil monetary penalties of $6 million and $12 million, respectively.
The SEC continued to close FCPA investigations this quarter. On May 14, 2026, the agency informed Methode Electronics, Inc., that it had concluded its FCPA investigation, according to the company's Form 8-K filing. The company had received subpoenas from the SEC in November 2024 and March 2025 requesting documents and information relating to compliance with the FCPA, among other requests.
Other U.S. Developments
On June 1, 2026, the U.S. Trade Representative (USTR) determined that certain Brazilian acts, policies, and practices are unreasonable, discriminatory, or burden U.S. commerce and are thus actionable under section 301(b) of the Trade Act. As one of the grounds for the determination, the USTR cited Brazil's anti-corruption enforcement, claiming that Brazil "fails to take sufficient enforcement action to combat bribery and corruption." The USTR proposed a 25 percent tariff on imports from Brazil as a result of the 301 investigation. USTR held a hearing on July 6 and 7 regarding the proposed tariffs and announced its final decision imposing the 25 percent tariff on July 15, 2026.
On June 4, 2026, in Sripetch v SEC, the Supreme Court unanimously held that the SEC does not need to prove that investors suffered pecuniary harm to obtain a disgorgement order. This decision reinforces the SEC's ability to seek disgorgement, such as in FCPA resolutions, where quantifying investor losses may be difficult.
International Developments
The second quarter of 2026 featured several international developments, particularly in the U.K. and Europe, including the hiring of a new vice president of Integrity at the World Bank.
In the U.K., prosecutors successfully resolved a corporate action but lost a jury trial involving individuals. On May 1, 2026, the U.K.'s Serious Fraud Office (SFO) entered into a DPA with Ultra Electronics, its first DPA since 2021, to resolve allegations of bribery in Oman and Algeria. The DPA resolved charges that Ultra Electronics failed to prevent bribery, in violation of section 7 of the U.K. Bribery Act 2010 (UKBA). The DPA will last for three years and requires that Ultra Electronics cooperate with the SFO in all investigations and prosecutions. The DPA also requires Ultra to pay £10 million in fines and an additional £4.8 million in SFO investigation costs.
On June 17, 2026, a London jury acquitted former Nigerian Oil Minister Diezani Alison-Madueke and two co-defendants in a U.K. bribery case. The Crown Prosecution Service had alleged that oil executives provided improper benefits to Alison-Madueke in exchange for assistance obtaining lucrative Nigerian oil and gas contracts during her tenure overseeing Nigeria's petroleum sector from 2010 to 2015.
In April 2026, the EU Council adopted an anti-corruption directive to create a universal definition of financial crimes across the EU. The new directive will introduce common definitions of corruption offenses such as bribery, ensure that all member states provide for common minimum levels of penalties for corruption offenses to ensure maximum penalties are not too low, and require that all states adopt a national anti-corruption strategy and create specialized anti-corruption units. Also in April, Germany introduced a new bill that would expand corporate liability and quadruple corporate penalties. The bill would increase the maximum fine for a company in the case of an intentional offense committed by a manager from €10 million to €40 million and from €5 million to €20 million in the case of a negligent offense committed by a manager. The bill also includes new sentencing guidelines for the imposition of these fines. Circumstances impacting the fine amount include the size of a company, the company's compliance measures both before and after the offense, and whether the company voluntarily disclosed the offense.
On April 29, 2026, the World Bank announced the hiring of Maria Thestrup, formerly the compliance chief of a global non-profit, to be the vice president of Integrity (INT). INT is an independent unit in the Bank that investigates allegations of fraud and corruption in Bank-financed projects and regularly pursues sanctions against companies and individuals, including debarment.
DOJ Updates
Former Stericycle Finance Director Pleads Guilty to FCPA Conspiracy Charges and Is Sentenced to Time Served
On May 22, 2026, Abraham Cigarroa Cervantes (Cigarroa), former finance director at waste management company Stericycle, entered into a plea agreement with the DOJ following a change-of-plea hearing in Miami federal court on May 21, giving the DOJ another individual conviction in its FCPA case over the company's Latin America operations. Under the plea agreement, Cigarroa pleaded guilty to one count of conspiracy to commit an offense in violation of the FCPA's anti-bribery and accounting provisions. He faces a prison term of up to five years, followed by supervised release for up to three years, and a fine of up to $250,000.
The agreement marks a turn in the case against Cigarroa, who had previously pleaded not guilty after being arrested in Argentina and extradited to the U.S. Prosecutors charged Cigarroa in early 2024 with conspiracy to violate the FCPA anti-bribery provisions and conspiracy to violate the FCPA books and records provisions. According to the indictment, he participated in a years-long scheme to pay roughly $10.5 million in bribes to government officials in Brazil, Mexico, and Argentina in exchange for medical waste collection contracts for Stericycle between 2011 and 2016. The indictment alleges that Cigarroa and his co-conspirators concealed the scheme by falsifying entries in Stericycle's books and using coded terms in spreadsheets, including "IP" and "advanced payments."
As reported in our FCPA Summer Review 2022, Stericycle resolved related criminal and civil charges in 2022. As part of a three-year DPA, the company agreed to pay more than $84 million in penalties and disgorgement to the DOJ and SEC, and to engage an Independent Compliance Monitor for two years. The company also agreed to continue cooperating with the DOJ's investigation and any ongoing or future prosecutions. As reported in our FCPA Summer Review 2025, the DOJ ended the DPA ahead of schedule in April 2025.
At a sentencing hearing held on July 10, 2026, in district court, the judge sentenced Cigarroa to time already served, three years of supervised release, and a fine of $225,000.
Austrian Banker Pleads Guilty in Odebrecht Bribe Laundering Case
On June 12, 2026, Austrian banker Peter Weinzierl pled guilty in a U.S. money laundering case tied to Odebrecht's long-running bribery scandal. Weinzierl is the former chief executive of the now-defunct Austrian Meinl Bank. The case is one of the remaining individual prosecutions stemming from the sprawling Odebrecht investigation.
In September 2020, U.S. prosecutors charged Weinzierl with helping Odebrecht move hundreds of millions of dollars through offshore accounts and sham transactions to conceal funds used in a broader bribery scheme. The charges against Weinzierl include conspiracy to commit money laundering, two substantive "international promotional" money laundering counts (tied to promoting alleged wire fraud), and one money laundering spending count. Weinzierl was extradited from the U.K. in May 2025 to face the charges in U.S. federal court and initially pleaded not guilty, but changed his plea during the pre-trial process.
The prosecution is tied to Odebrecht's 2016 settlement with authorities in the U.S., Brazil, and Switzerland. In the U.S. resolution, discussed in our FCPA Winter Review 2017, Odebrecht and its affiliate Braskem each pleaded guilty to one count of conspiracy to violate the anti-bribery provisions of the FCPA. Braskem also entered into a settlement with the SEC over claims that the company falsified its books and records. In settling with the U.S., Brazil, and Switzerland, the companies agreed to pay at least $3.5 billion in combined global penalties.
A sentencing hearing for Weinzierl is scheduled for October 1, 2026.
District Court Issues Acquittal Order in Rovirosa FCPA Case; DOJ Appeals
The DOJ has taken the next step in a closely watched FCPA case, filing a notice of appeal on May 8, 2026, in the U.S. Court of Appeals for the Fifth Circuit. The appeal challenges an April 14, 2026, decision by the U.S. District Court for the Southern District of Texas acquitting defendant Ramón Alexandro Rovirosa Martínez (Rovirosa).
The case against Rovirosa was the first FCPA-related indictment by the DOJ since the administration's pause of FCPA enforcement in February 2025. The DOJ indicted Rovirosa with co-defendant Mario Alberto Avila Lizarraga in August 2025 for alleged participation in a bribery scheme spanning June 2019 through October 2021. According to the indictment, the scheme involved providing cash, luxury items, and other benefits to officials at Petróleos Mexicanos (PEMEX) and its subsidiary, PEMEX Exploración y Producción (PEP). In exchange, the defendants allegedly secured favorable treatment related to audits, payment approvals, and contract awards, including contracts valued at least $2.5 million.
After a trial, the jury initially returned a mixed verdict in December 2025, finding Rovirosa guilty of conspiracy to violate the FCPA and substantive FCPA violations, and not guilty on one FCPA-related charge. However, Judge Kenneth M. Hoyt, who is overseeing the case, overturned the jury's conviction based on evidentiary issues, focusing on the DOJ's reliance on English-language translations of Spanish electronic messages as key pieces of evidence. The court found these translations to be testimonial in nature, triggering Sixth Amendment confrontation rights, but noted that the DOJ never entered the original Spanish-language messages into the evidentiary record. The court's order criticized the DOJ's litigation strategy, noting that prosecutors "intentionally did not call as witnesses the Translators" (meaning the defense could not test the accuracy or interpretation of the translated messages). The order also noted that "the government failed to produce forensic copies of the Spanish messages taken from both defendants' electronic devices" (emphasis added). The court held that Rovirosa was denied the opportunity to challenge critical evidence in violation of the Sixth Amendment.
As a result, the court granted Rovirosa's motion for judgment of acquittal, dismissed the indictment in full, and ordered his release. The DOJ's appeal raises potentially significant legal questions about the extent to which the government must present and authenticate translated electronic evidence in FCPA prosecutions to satisfy Sixth Amendment requirements. The outcome of an appellate ruling could have broader implications for cases involving multilingual evidence, particularly in cross-border investigations where translations are frequently central to the case.
DOJ Drops Bribery Case Against Adani After SEC Settlement
On May 19, 2026, DOJ prosecutors in the Eastern District of New York (EDNY) formally requested that a federal judge dismiss the criminal charges against Gautam Adani and several co-defendants, stating that they would "not devote further resources" to the prosecution. This request marked a notable shift from the November 2024 indictment, which alleged that Adani and others orchestrated a roughly $265 million bribery scheme to secure solar energy contracts and misled U.S. investors in connection with those activities. Gautam Adani founded the Adani Group in 1988, which is currently one of India's largest business conglomerates, and is currently valued at $191 billion across six companies (including Adani Green Energy Ltd.) and sectors ranging from green energy to infrastructure.
The request for dismissal came days after reporting indicated that the DOJ was preparing to drop the case following a meeting between Adani's counsel and senior DOJ officials in Washington. According to those media reports, during that meeting, Adani's legal team presented arguments challenging both the sufficiency of the evidence and the DOJ's assertion of U.S. jurisdiction over activities that occurred in India. Further reports state that as part of those discussions, Adani's counsel referenced an offer under which Adani would invest approximately $10 billion in the U.S. and create up to 15,000 jobs if the charges were dropped. Prosecutors later indicated that this proposal did not factor into their decision to request a dismissal.
Judge Nicholas Garaufis, who presided over the case, ordered the DOJ to justify its decision to drop the charges, requesting the department submit more information. In the order, Judge Garaufis said that "the Government has failed to meet its obligation to supply adequate reasoning and sufficient facts to support dismissal of the Indictment." In response, the DOJ defended its decision in a letter to the court by stating that the case is a foreign matter, and that "India can better manage its internal systems than can prosecutors in Brooklyn and Washington." The DOJ letter further argued that "not a single penny has ever been lost on the securities at issue" and strongly denied that the charges were dropped in exchange for promises of investment in the U.S.
Upon receiving the letter from the DOJ, Judge Garaufis ordered Adani to file an affidavit about whether he was aware of any agreements with the government in exchange for dropping the charges. Adani filed his response on July 15, 2026, stating that he was not aware of any promises or offerings made in exchange for the dismissal, and that the reference to $10 billion in investment originates from a social media post from November 2024, predating the indictment and SEC complaint being unsealed. Adani further claims that during settlement discussions, his counsel suggested that this previous publicly stated intent to invest might be part of a resolution, but that the DOJ later informed Adani's counsel that it would not consider potential investment as part of its decision to dismiss charges. It is unclear as of the time of publication whether the court will require further actions in the case.
In parallel with the DOJ's actions, the SEC moved to resolve a related case in which the agency charged Gautam Adani and Executive Director Sagar Adani of Adani Green Energy Ltd.'s Board of Directors with violations of section 17(a), section 10(b), and associated Rule 10b-5 of the Securities Act of 1933. The SEC alleged that the Adanis participated in a bribery scheme in India stemming from a solar energy project that Adani Green secured in India in 2019. Under the purported bribery scheme, the Adanis offered payments to Indian government officials to secure commitments to purchase energy at above-market rates. The SEC further alleged that, while the bribery scheme was ongoing, the Adanis falsely stated that Adani Green was in compliance with anti-bribery principles and laws in connection with a $750 million bond offering, making the offering materials false and misleading. The Adanis executed consent agreements with the SEC, without admitting or denying the allegations, agreeing to the entry of a final judgment imposing permanent injunctions under the federal securities laws. The agreements required Gautam Adani and Sagar Adani to pay civil monetary penalties of $6 million and $12 million, respectively.
In May 2026, the Department of the Treasury also reached a settlement of $275 million with Adani Enterprises Limited to address "potential civil liability for 32 apparent violations of [the Office of Foreign Assets Control's (OFAC)] Iran sanctions" allegedly occurring between November 2023 and June 2025. The violations arise from purchased shipments of liquefied petroleum gas (LPG) from a Dubai-based trader that claimed to be sourcing supplies from Oman and Iraq. In the settlement documentation, OFAC identified several red flags that should have alerted Adani Enterprises to the fact that the LPG actually originated from Iran, including learning of third-party concerns that the cargo may have originated in Iran. The OFAC case documents note that, during the time period, Adani Enterprises caused U.S. financial institutions to process more than $192 million across 32 transactions related to the shipments.
Judge Dismisses Bribery Case in Long-Running FIFA Corruption Scandal
On May 27, 2026, EDNY Judge Pamela K. Chen granted the DOJ's motion to dismiss the indictments against Full Play Group and former Fox Executive Hernán López, ending a significant chapter of the long-running FIFA corruption prosecutions. López and Full Play were convicted in 2023 after prosecutors alleged that they participated in a scheme to pay bribes to soccer officials in exchange for commercial rights to tournaments. Prosecutors also alleged that López's conduct helped Fox obtain lucrative U.S. broadcast rights to the 2018, 2022, and 2026 World Cups. The dismissals followed the Supreme Court's January 2026 order vacating lower court rulings against the two defendants after the Solicitor General informed the Court that dismissal of the case was "in the interests of justice."
This latest development does not end the broader FIFA matter. The case has produced more than 30 convictions and hundreds of millions of dollars in fines and restitution since the investigation began, and the government argued that the remaining convictions should stand. Four other defendants, however, already asked Judge Chen to drop their convictions as well, contending that the DOJ's position in the López and Full Play matters shows that no crimes were committed. FIFA and the Confederation of North, Central America and Caribbean Association Football (CONCACAF) have supported the government's efforts to preserve those convictions.
According to media reports, at the dismissal hearing U.S. Attorney Joseph Nocella, Jr., stated that the case no longer fit the administration's priorities, which he described as focused on terrorism, violent gangs, and illegal drugs. The government has nevertheless maintained that the López and Full Play dismissals should not disturb the remaining convictions. The four remaining defendants (Eduardo Li, Reynaldo Vasquez, Juan Angel Napout, and Alfredo Hawit), have all submitted petitions to vacate their convictions. Proceedings remain ongoing.
Other U.S. Developments
Supreme Court Upholds SEC's Disgorgement Power in Absence of Specific Pecuniary Harm
On June 4, 2026, the Supreme Court unanimously held in Sripetch v. SEC that the SEC does not need to prove that investors suffered pecuniary harm to obtain a disgorgement order against defendants in certain federal securities laws cases. This decision resolves a previous circuit split between the First and Ninth Circuits on one side and the Second Circuit on the other following the Supreme Court's decision in Liu v. SEC, which held that disgorgement was an equitable remedy available to the SEC when it was awarded for victims.
In the case underlying the Sripetch decision, the SEC brought a civil enforcement action against Sripetch for six counts of securities fraud and one count of selling unregistered securities in connection with numerous fraudulent schemes involving penny stocks. Sripetch consented to a judgment against him and agreed that the relevant federal district court could order disgorgement. Once the SEC sought $4.1 million in disgorgement, however, Sripetch objected, arguing that the SEC's request violated Liu because the agency could not show the investors suffered any financial losses.
Relying on equitable principles and building on the analysis in Liu, the Supreme Court held that, as to the question presented, the existence of pecuniary harm to an investor is not necessary for the SEC to obtain a disgorgement remedy. As it did in Liu, the Court noted that disgorgement is an equitable remedy, subject to "traditional equitable rules, including the rule that disgorgement must be awarded for victims." Discussing the history of equitable remedies, the Court stated that "only one common feature [of those various remedies] matters: [g]enerally, the final award to the plaintiff is not measured by his loss but by the defendant's gain attributable to his wrongdoing against the plaintiff." Discussing various cases that it deemed applicable, the Court then concluded that "[a]pplying traditional equitable principles, [the courts involved] ordered the defendant to disgorge the value of the gain attributable to his invasion of the plaintiff's legally protected interests without requiring a showing of pecuniary loss."
The Court determined that Sripetch's arguments that Liu forbade such an outcome were incorrect under the traditional equity principles the Court was applying in both cases. The appropriate focus, according to the Court, is on whether the defendant was unjustly enriched by a violation of the federal securities laws enforced by the SEC. The relevant equity cases support this outcome, according to the Court, because in such matters a court
can either restore the defendant to his prior position by stripping him of his unjust gains, or it can allow the defendant to benefit from his misconduct because the plaintiff's financial position has not changed. And as the [relevant] cases [discussed in the opinion] illustrate, equity traditionally prefers the first outcome, not the second.
In the wake of Liu, in 2021 Congress amended the Exchange Act to expressly allow the SEC to seek disgorgement of "unjust enrichment" from defendants in enforcement cases. The Court in Sripetch sidestepped the parties' arguments as to the effect of this statutory amendment, stating that "[t]he question we face is not whether Congress's recent amendments free the SEC from the traditional equitable rule that disgorgement must be "awarded for victims." Instead, its holding resolved the question at issue as to pecuniary loss. Thus, some of the questions raised as to the extent of the SEC's authority under the amendment will require resolution in future cases.
International Developments
U.K. SFO Enters into First DPA in Five Years
On May 1, 2026, the U.K.'s Serious Fraud Office (SFO) entered into a DPA with Ultra Electronics, its first DPA since 2021, to resolve allegations of bribery in Oman and Algeria.
The DPA resolved charges that Ultra Electronics failed to prevent bribery, in violation of section 7 of the UKBA, in connection with three projects. The first project related to an IT and systems contract for airports in Oman. According to the statement of facts, Ultra Electronics formed a joint venture (JV) in Oman, and the JV hired a "fixer" to influence the award of the contract. The remaining two projects involved two contracts in Algeria between 2016 and 2017, where persons associated with Ultra Electronics allegedly bribed Algerian officials to try to secure contracts for IT systems in airports and other public infrastructure, but were ultimately unsuccessful.
The DPA lasts for three years and requires that Ultra Electronics cooperate with the SFO in all investigations and prosecutions. The DPA also requires Ultra to pay £10 million in fines and an additional £4.8 million in SFO investigation costs. Due to Ultra Electronics not profiting from any of the contracts, there is no disgorgement provision. The company must also submit reports to the SFO regarding the effectiveness of the company's anti-bribery and compliance program during the term of the DPA.
The SFO previously withdrew from DPA negotiations with Ultra after determining that "the conditions for a meaningful agreement" were not met. Negotiations only resumed after significant changes in the company's ownership and subsequent negotiations leading to the implementations of new compliance programs led to the SFO believing that Ultra Electronics had both "the willingness and the capacity to engage in good faith." In support of the DPA, which had to be approved by the Crown Court at Southwark, the SFO also noted that the misconduct was not recent, none of the employees or directors associated with the misconduct were still employed, Ultra Electronics was proactive about cooperating with SFO, Ultra Electronics took extensive steps to overhaul its compliance program after the incident, and the fact that a conviction would likely have collateral effects on the public due to Ultra Electronics' status as a large defense contractor.
Ultra Electronics previously settled corruption charges in Canada for bribery and fraud in the Philippines, as we reported in our FCPA Winter Review 2023.
Former Nigerian Oil Minister Found Not Guilty of Bribery and Conspiracy Charges After London Trial
On June 17, 2026, a London jury acquitted former Nigerian Oil Minister Diezani Alison-Madueke and two co-defendants on bribery and related charges brought by U.K. criminal authorities. The Crown Prosecution Service alleged that oil executives provided improper benefits to Alison-Madueke in relation to her official duties during her tenure overseeing Nigeria's petroleum sector from 2010 to 2015. After a lengthy trial, the jury at Southwark Crown Court cleared Alison-Madueke of four counts of accepting a bribe and one count of conspiracy to commit bribery. Her brother, Doyé Agama, was acquitted of one count of conspiracy to commit bribery, and Nigerian oil executive Olatimbo Ayinde was acquitted of one count of bribery and one count of bribing a foreign public official. Alison-Madueke, who became the first woman to lead the Organization of the Petroleum Exporting Countries (OPEC) in 2014, denied the allegations, and her defense maintained that she did not receive improper financial benefits and had accounted for gifts she received. According to media reports, the trial was marked by significant challenges related to evidence collected (or not) from Nigeria, Switzerland, and elsewhere, and by claims by Ayinde that she was actually a "whistleblower" who was working on behalf of a subsequent Nigerian presidential administration.
The DOJ previously recovered over $53 million in profits and entered into agreements to transfer forfeited assets for the benefit of Nigeria in cases tied to alleged corruption proceeds associated with Alison-Madueke. Those U.S. matters are separate from the U.K. proceedings and involved assets allegedly traceable to bribery and money laundering schemes connected to the award of Nigerian oil and gas contracts. The U.K. acquittal does not automatically resolve related money laundering and corruption charges that Alison-Madueke faces in Nigeria.
EU Adopts New Anti-Corruption Directive
On April 21, 2026, the EU Council adopted an anti-corruption directive to create a universal definition of financial crimes across the EU. The directive has been in the works since 2023 and was adopted by the EU Parliament in March 2026. Its purpose is to address enforcement gaps across the EU and increase cooperation between national authorities and EU bodies. The directive states that previous EU instruments for addressing corruption are "not sufficiently comprehensive," and that "[e]nforcement gaps and obstacles in cooperation between the competent authorities of different Member States have also emerged." This directive would replace those instruments (a Council framework decision and a convention) in their entirety.
Specifically, the new directive will:
- Introduce common definitions of corruption offenses like bribery, misappropriation, trading in influence, obstruction of justice, and enrichment from corruption offenses.
- Ensure all member states provide for common minimum levels of penalties for corruption offenses to ensure maximum penalties are not too low. Offenders may face prison time ranging from three to five years, and companies may face penalties ranging from three to five percent of their total worldwide turnover or from €24 to €40 million.
- Require that all states adopt a national anti-corruption strategy and have anti-corruption units.
The directive was published in the Official Journal of the EU on May 11, 2026, and entered into force May 31, 2026. All 27 EU member states will have 24 months to amend relevant national laws to implement the directive's provisions.
Germany Introduces Draft Law to Quadruple Corporate Penalties, Introduce Sentencing Guidelines
On April 20, 2026, Germany introduced a new bill geared towards expanding corporate liability that would quadruple corporate penalties while also introducing new sentencing guidelines. The draft bill is mostly focused on hitting United Nations sustainable development goals and aligning with the 2024 EU directive on environmental crimes, but also includes provisions aimed at "promoting the rule of law at the national level and building effective, accountable, and transparent institutions at all levels."
The bill would increase the maximum fine for a company in the case of an intentional offense committed by a manager from €10 million to €40 million and from €5 million to €20 million in the case of a negligent offense committed by a manager. This change applies for any offense where the company could be held liable. The bill also includes new sentencing guidelines for the imposition of these fines with the goal of increasing "certainty for legal practitioners." For example, the size of a company will be considered in assessing the amount of a fine. Other circumstances impacting the amount of a fine include the company's compliance measures both before and after the offense, as well as whether the company voluntarily disclosed the offense.
To take effect, the bill must still be approved by the two German legislative bodies. Although the timeline for adopting the bill is unclear, there may be some urgency, as the EU's May 21, 2026, deadline for members to implement the EU's environmental crimes directive has passed.
World Bank Taps Healthcare Compliance Veteran to Run Integrity Unit
On April 29, 2026, the World Bank announced that it had hired Maria Thestrup, formerly the compliance chief of a global non-profit, to be the vice president of INT, an independent unit within the World Bank that investigates allegations of fraud and corruption in World Bank-financed projects and pursues sanctions against companies and individuals, including debarment from bidding on projects. Thestrup will succeed Lisa Rosen, who has been acting vice president since previous INT head, Mouhamadou Diagne, retired in December 2025, as reported in our Spring 2026 FCPA Review.
According to the World Bank's announcement, Thestrup, who is a Danish national, has "more than 25 years of global experience in integrity, ethics, compliance, and investigations across international organizations and the private sector," the majority of which was spent in the healthcare space. She has been the head of compliance most recently at Gavi, a vaccine non-profit, and "held senior leadership roles at LEO Pharma and the International Committee of the Red Cross."
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