The FCPA Still at Work: Jury Finds U.S. Executive Guilty For Role in International Bribery Scheme

On February 18, 2026, a federal jury in Pennsylvania found Charles Hunter Hobson — a former U.S.-based coal company executive — guilty of violating the U.S. Foreign Corrupt Practices Act (FCPA) and other federal criminal laws.¹ In many ways, this was a typical FCPA case, with a common fact pattern: alleged bribes paid by a businessperson, through a third party, to secure lucrative contracts with a state-run company overseas. Several aspects of the prosecution, however, stand out.

We provide our key takeaways below:

• The case was briefly put on hold last year following President Trump’s February 2025 Executive Order that paused most enforcement of the FCPA in light of stated concerns about harm to “American economic competitiveness.” But in April 2025, the U.S. Department of Justice (DOJ) greenlit the case to proceed, and the court set a February 2026 trial date, over Hobson’s objections. DOJ’s victory, after a weeklong trial, demonstrates that the FCPA is still being enforced — including against U.S. citizens employed by U.S. companies trying to win business abroad. 
• Consistent with recent DOJ guidelines on FCPA enforcement, prosecutors focused on individual, not corporate, criminal liability. While Hobson was convicted at trial and a former colleague (who testified against him) pleaded guilty to an FCPA conspiracy charge, the company they had worked for — Corsa Coal Corporation — did not face criminal charges. Corsa Coal received a formal “declination” from DOJ, crediting the company’s voluntary self-disclosure of misconduct, full and proactive cooperation with the Government’s investigation, timely remediation, and disgorgement of the amount of ill-gotten gains that the company was able to pay.
• The Government’s case against Hobson relied heavily on electronic communications, including text messages, WhatsApp messages, and emails that he exchanged with a third-party agent who allegedly helped him land business for Corsa Coal in Egypt through alleged bribes. Neither Hobson nor the agent testified at trial, however. The electronic messages were introduced into evidence by an FBI agent, who provided insight into their coded language, such as the use of initials to refer to individual recipients of illicit payments and the term “Mr. Yen” to refer to the money being distributed.
• Hobson was convicted not only of violating the FCPA’s anti-bribery provisions, but also of conspiracy to violate the FCPA, money laundering, money laundering conspiracy, and conspiracy to commit wire fraud. The case thus illustrates how international corruption schemes can implicate a variety of U.S. criminal laws, with potentially severe consequences for sentencing.

Hobson is scheduled to be sentenced on June 25, 2026, and, according to DOJ, “faces a maximum penalty of five years in prison on each of the FCPA and FCPA conspiracy counts, and a maximum penalty of 20 years in prison on the money laundering conspiracy, money laundering and wire fraud conspiracy counts, respectively.”

Stay tuned as we continue to monitor developments in FCPA enforcement trends here on Enforcement Edge. For questions about this topic, contact the authors or any of their colleagues in Arnold & Porter’s White Collar Defense & Investigations practice group.

© Arnold & Porter Kaye Scholer LLP 2026 All Rights Reserved. This Blog post is intended to be a general summary of the law and does not constitute legal advice. You should consult with counsel to determine applicable legal requirements in a specific fact situation.