Global Anti-Corruption Insights: Winter 2026

Although President Trump temporarily paused enforcement of the U.S. Foreign Corrupt Practices Act (FCPA) in the first half of 2025, U.S. Department of Justice (DOJ) officials recently have declared that enforcement of the FCPA — and other criminal laws that apply to international business conduct — remains alive and well.

In the second half of 2025, two companies negotiated agreements with DOJ to resolve FCPA investigations, and a third came under indictment. DOJ also took to trial two FCPA cases against individuals, winning both. Other individual prosecutions moved forward as well. Criminal FCPA enforcement was therefore down but not out in 2025.

All has been quieter on the civil front, however. The U.S. Securities and Exchange Commission (SEC) did not bring any new FCPA cases this past year, and the future of its specialized “FCPA Unit” hangs in the balance.

Below, we discuss how the FCPA and global anti-corruption landscape has changed over the past year and where enforcement priorities may lie in the year ahead.

DOJ’s New Guidelines for FCPA Enforcement

In February 2025, shortly after entering office, President Trump signed an executive order that paused most FCPA enforcement for 180 days and directed the Attorney General to issue updated guidelines or policies that “prioritize American interests, American economic competitiveness with respect to other nations, and the efficient use of Federal law enforcement resources.” DOJ effectively lifted the pause on June 9, 2025, when Deputy Attorney General Todd Blanche issued new Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act. The Guidelines articulated specific focus areas for prosecutors, including eliminating cartels and transnational criminal organizations; safeguarding U.S. companies’ competitiveness; guarding against threats to U.S. national security; and punishing misconduct that bears strong indicia of corrupt intent tied to particular individuals.¹

In December, during a keynote speech at the American Conference Institute’s 42nd Annual Conference on the FCPA and Global Anti-Corruption, Mr. Blanche emphasized that, while DOJ had closed certain investigations and announced new priorities, it is committed to combating foreign corruption that harms U.S. interests — regardless of the nationality of the perpetrator. At the same time, he noted that DOJ will not seek to stretch the bounds of the FCPA by making a federal crime out of routine business courtesies, especially when only very low-dollar amounts are involved. He did not, however, specify what qualifies as “routine” or “low-dollar.”

Other senior DOJ officials at the conference similarly stressed that the FCPA will continue to be enforced. David Fuhr, who has headed the DOJ Criminal Fraud Section’s FCPA Unit since 2023, suggested that DOJ will announce new FCPA cases against both individuals and organizations in 2026. Mr. Blanche, for his part, also signaled that an updated, department-wide corporate enforcement policy will be released soon.²

DOJ’s Resolution of FCPA Cases With Two Companies, Indictment of a Third in 2025

The three corporate FCPA enforcement actions in 2025 demonstrate that DOJ is still holding companies accountable for FCPA violations, even if they do not squarely fit within the department’s new stated enforcement priorities.

In August 2025, DOJ issued a declination letter to Liberty Mutual Insurance Company pursuant to the department’s Corporate Enforcement and Voluntary Self-Disclosure Policy. According to DOJ, “[t]he Government’s investigation found evidence that, from in or around 2017 until in or around 2022, Liberty Mutual, through its subsidiary in India, Liberty General Insurance (LGI), paid bribes totaling approximately $1.47 million to officials at six state-owned banks in India, in order to obtain or retain business with those state-owned banks…. Certain LGI employees took steps to conceal the true nature of the payments, including by classifying the payments as marketing expenses and using third-party intermediaries to make the payments to the officials.” In declining to bring criminal charges, DOJ acknowledged Liberty Mutual’s voluntary self-disclosure, cooperation, and remediation, as well as its agreement to disgorge $4.7 million in profits from its commercial relationships with the six state-owned banks. Liberty Mutual, a U.S.-based company, did not get off scot-free.

In October 2025, a federal grand jury returned a rare indictment of a corporation for conspiracy to violate the FCPA. SGO Corporation Limited (commonly known as Smartmatic), a voting machine and election services company, is accused of “participating in a scheme to pay and launder more than $1 million in bribes to a Philippine government official in connection with contracts related to the 2016 Philippine national elections.” Three former executives and a former Philippine government official originally were indicted in August 2024.

In November 2025, Comunicaciones Celulares S.A. (d/b/a TIGO Guatemala) — a telecommunications service provider in Guatemala and subsidiary of Millicom International Cellular — paid over $118 million to resolve an FCPA enforcement action through a two-year Deferred Prosecution Agreement. The company had engaged in a scheme that “featured monthly bribe payments, usually paid in cash, to numerous Guatemalan members of Congress or members of their security teams, in exchange for, among other things, their support for legislation that benefited TIGO Guatemala. Some of the cash that TIGO Guatemala used to pay bribes were the laundered proceeds of narcotrafficking.” Although the settlement papers do not refer to cartels or transnational criminal organizations, the repeated references to narcotrafficking suggest that any corporate ties to such activity, even if indirect, are of interest to DOJ.

The DOJ’s enforcement action against TIGO Guatemala also illustrates the FCPA risks associated with joint ventures and corporate acquisitions. Millicom initially self-disclosed certain misconduct to DOJ in 2015, prior to having full ownership and control of TIGO Guatemala. DOJ closed its initial investigation in 2018 but re-opened the investigation years later after obtaining additional evidence from other sources that revealed the scope of TIGO Guatemala’s misconduct. According to settlement papers, Millicom’s former joint venture partner in Guatemala had prevented Millicom from accessing critical information and from requiring TIGO Guatemala personnel to take remedial actions. Therefore, despite Millicom’s early self-reporting and cooperation, its subsidiary was not able to avoid criminal charges altogether.

Individuals Convicted, Sentenced in FCPA Cases Involving Bribery in Latin America

In September 2025, a federal jury convicted Carl Alan Zaglin, a Georgia businessman, of FCPA and money laundering conspiracy offenses for his role in a scheme to bribe Honduran officials in exchange for contracts with a governmental entity that procures goods for the Honduran National Police. According to DOJ, hundreds of thousands of dollars in bribes were paid through a third-party intermediary residing in Florida, who received payments pursuant to sham invoices authorized by Mr. Zaglin. On December 2, 2025, the court sentenced Mr. Zaglin to eight years in prison and ordered him to forfeit over $2 million. Other individuals involved in the scheme have pleaded guilty to money laundering conspiracy charges.

In October 2025, Carlos Leopoldo Alvelais Alarcón, a Mexican customs broker working in the United States and Mexico, pleaded guilty in federal court in Texas to conspiring to violate the FCPA. Publicly available details are limited, as most case documents remain under seal.

In December 2025, a federal jury convicted Alexandro Rovirosa, a Mexican citizen and U.S. lawful permanent resident residing in Texas, on FCPA charges relating to his role in a scheme to bribe officials at the Mexican state-owned oil company PEMEX and one of its subsidiaries. Mr. Rovirosa was alleged to have paid more than $150,000 in bribes through cash payments, luxury goods, and other valuable items, in exchange for obtaining and retaining contracts with the Mexican companies. His alleged co-conspirator, Mario Avila, remains a fugitive.

Also in December, a federal judge sentenced Glenn Oztemel, a Connecticut-based oil trader, to 15 months in prison for FCPA violations, money laundering violations, and conspiracy. Oztemel was convicted by a jury in September 2024 for his role in a multi-year scheme to bribe officials at Petrobras, the Brazilian state-owned oil and gas company. DOJ showed that the bribes were paid in exchange for inside information — including competitor bids and confidential pricing information — that helped two companies where Oztemel worked secure lucrative fuel oil contracts with Petrobras.

These prosecutions against individuals all involved corruption in Latin America, an apparent region of focus for FCPA enforcement. But DOJ also has been pursuing cases concerning corruption in other parts of the world through use of the FCPA and other federal statutes. For example, DOJ last year obtained convictions and forfeiture orders in money laundering cases relating to drilling rights in Nigeria and loan agreements in Mozambique.³ DOJ is expected to go to trial in the coming months on FCPA charges against a former U.S.-based coal company executive accused of bribing Egyptian officials.

The SEC’s Silence

The SEC did not bring any new FCPA charges against companies or individuals in 2025. Nor did the SEC make any policy announcements regarding the FCPA last year. Practitioners have been left to speculate about the fate of the SEC Enforcement Division’s specialized FCPA unit following the recent retirement of its longtime head and reassignment of personnel within the division. Still, the FCPA’s accounting provisions remain on the books, and current or future SEC leadership could bring civil FCPA charges against companies that issue stock in the United States, as well as against their officers, directors, employees, and agents.

International Developments

The anti-corruption landscape has been evolving in other countries, too, over the past year. By way of example:

• On October 15, 2025, amendments to China’s Anti-Unfair Competition Law went into effect. As Arnold & Porter has previously discussed in a July 2025 Advisory, the amendments make clear that both the payment and acceptance of bribes can be punished; raise the upper limit for fines for commercial bribery; increase liability for individuals involved in commercial bribery; and introduce potential “long-arm jurisdiction.”
• Authorities in the United Kingdom, France, and Switzerland announced a new task force in March of last year to strengthen collaboration on efforts to tackle international bribery and corruption. To date, they have not publicly disclosed any coordinated enforcement actions. Nevertheless, authorities in all three countries have been prosecuting cases involving international corruption.⁴
• In November 2025, the U.K. Serious Fraud Office (SFO) published new Guidance on Evaluating a Corporate Compliance Programme. And in December 2025, the SFO — together with law enforcement partners in Australia, Canada, New Zealand, and the United States — published “Indicators of Foreign Bribery” to help businesses and professionals detect corruption.
• Brazilian authorities, which over the past decade have become major players on the global anti-corruption stage, released new guidelines and statements in recent months that are intended to create greater consistency and transparency in their enforcement of anti-corruption laws. For instance, in September 2025, the Brazilian Office of the Comptroller General (Controladoria-Geral da União or CGU) approved non-binding administrative statements with interpretive guidance on the Anti-Corruption Law (also known as Clean Company Act) of 2013.

© Arnold & Porter Kaye Scholer LLP 2026 All Rights Reserved. This Newsletter 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.