Global Anti-Corruption Insights: Summer 2026

The U.S. Department of Justice (DOJ) has continued to enforce the Foreign Corrupt Practices Act (FCPA) in 2026, while also seeking to dismiss certain high-profile FCPA prosecutions that began before the second Trump administration.

Civil enforcement has remained comparatively quiet, with no new FCPA enforcement actions by the U.S. Securities and Exchange Commission (SEC) so far this year. Although the SEC has not made any official policy pronouncements regarding the FCPA, top enforcement officials there have discussed new approaches to the enforcement of securities laws more generally.

Across the pond, the UK Serious Fraud Office (SFO) entered into its first deferred prosecution agreement in several years, and the EU adopted a new Anti-Corruption Directive.

Meanwhile, Chinese authorities have updated a regulatory framework for criminal bribery and issued new guidance on the enforcement of a commercial bribery law, while continuing to focus on anti-corruption investigations and prosecutions.

We cover these stories and more below.

DOJ Resolves FCPA Case in Medical Device Industry Under New Corporate Enforcement Policy

In March, DOJ issued a formal declination letter to French medical device company Balt SAS and its U.S. subsidiary pursuant to the department’s revised Corporate Enforcement and Voluntary Self-Disclosure Policy. According to DOJ, Balt paid bribes to a physician who served in a senior role at a state-owned French public hospital in order for the physician to cause the hospital to purchase medical devices from Balt. DOJ considered this physician to be a “foreign official” for purposes of the FCPA. In granting a declination, DOJ credited Balt’s timely self-disclosure, full cooperation, appropriate remediation, disgorgement of $1.2 million in ill-gotten gains, and parallel resolution with authorities in France. Two individuals — David Ferrera, a former Balt executive in the United States, and Marc Tilman, a former consultant to Balt — have been indicted on related FCPA and money laundering charges for their roles in the alleged bribery scheme.

The Balt declination was DOJ’s first under the new department-wide corporate enforcement policy released on March 10, 2026. The policy, which builds on a prior framework used by the DOJ Criminal Fraud Section, sets up three tiers of outcomes:

1. Declinations for companies that voluntarily self-disclose to an appropriate DOJ criminal component, fully cooperate, timely and appropriately remediate, and face no aggravating circumstances, such as serious or pervasive misconduct, significant harm, or a recent prior resolution for similar conduct. Companies that earn declinations must still disgorge ill-gotten gains and pay restitution or other compensation to victims.
2. Reduced-penalty resolutions for “near miss” situations where companies cooperate and timely remediate but otherwise fall short of a full declination, including because of delayed disclosures or the presence of aggravating factors. To encourage even imperfect cooperation, the policy offers benefits such as a non-prosecution agreement (absent particularly egregious or multiple aggravating circumstances) with a term of less than three years, no independent compliance monitor, and a fine reduction of 50% to 75% off the low end of the Sentencing Guidelines range.
3. Discretionary credit for companies that do not voluntarily self-disclose but still cooperate or remediate to some degree. In considering monetary penalties for these companies, DOJ will weigh the effectiveness of the company’s compliance program, the quality and timing of cooperation, and the steps taken to fix the underlying problem.¹

DOJ Litigates Rare Corporate Indictment Under FCPA

In March 2026, SGO Corporation Limited (SGO) — the parent of the voting machine and election services company known as Smartmatic — filed a motion to dismiss FCPA charges on grounds of vindictive and selective prosecution. SGO argues that last year’s indictment was based, at least in part, on the company’s “limited role in the 2020 election and on its proper exercise of its First Amendment rights both to publicly and vehemently defend its integrity and to bring defamation lawsuits against the President’s political allies and Fox News.” SGO further contends that the government has declined to pursue charges against similarly situated companies and individuals, pointing out that it has been 15 years since a company was last indicted under the FCPA.² In response, the government counters that the investigation into SGO’s role in an alleged $1 million bribery scheme tied to the 2016 Philippine elections began in 2018 under career prosecutors and that the corporate entity was indicted only after pre-trial settlement negotiations broke down.³ The case is being closely watched because corporate FCPA indictments are rare, and the litigation may provide insight into DOJ’s current charging priorities.

Individuals Go to Trial, Plead Guilty in FCPA Prosecutions

DOJ has gone to trial and secured guilty pleas in FCPA cases this year.

In February, a federal jury in Pennsylvania found Charles Hunter Hobson, former vice president of Corsa Coal Corporation, guilty of violating the FCPA and other federal criminal laws. 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, DOJ greenlit the case to proceed. According to DOJ, Hobson used his position to pay bribes to Egyptian government officials, via an Egyptian intermediary, to win future contracts for Corsa to sell coal products to Al Nasr Company for Coke and Chemicals, a state-owned and state-controlled manufacturing company in Egypt. In addition to the almost $140 million in coal supply contracts for Corsa, Hobson received over $200,000 in kickbacks from the Egyptian intermediary. Hobson has not yet been sentenced.

In April, U.S. District Judge Kenneth M. Hoyt granted a post-trial motion to acquit Ramón Alexandro Rovirosa Martínez of all charges, after a jury had found the defendant guilty of FCPA violations related to a bribery scheme involving the Mexican state-owned oil company PEMEX. Judge Hoyt cited a lack of evidence to support the conviction in violation of the defendant’s Sixth Amendment Confrontation Clause rights. The judge agreed with the defendant that the government improperly introduced WhatsApp messages translated from Spanish, without calling the translators to the witness stand during trial.⁴ On May 8, 2026, DOJ appealed to the U.S. Court of Appeals for the Fifth Circuit.⁵ The appeal may clarify when translated messages can be introduced at trial and whether translators must be available for cross-examination.

In May, Alfonso Wilson, a resident of Texas and CEO of Oil Technologies Consortium, pleaded guilty to conspiracy to violate the FCPA in connection with a corruption scheme involving a $540 million contract to supply PEMEX with drilling equipment.⁶

Also in May, just 11 days before his trial was set to begin, Abraham Cigarroa Cervantes — a Mexican citizen and the former finance director of Stericycle’s Latin America division — pleaded guilty to conspiracy to violate the FCPA. According to his proffer statement, Cigarroa authorized the distribution of funds to Mexican vendors that ostensibly provided services for Stericycle; in reality, these vendors would create fake invoices and use the funds to bribe officials at Mexican state-owned entities in exchange for business opportunities and other advantages for Stericycle.⁷ Stericycle resolved corporate FCPA charges with the government back in 2022.

In May, the DOJ filed a motion to voluntarily dismiss FCPA and other criminal charges it initially brought in 2024 against prominent Indian businessmen associated with the Adani Group for their alleged roles in a bribery and securities fraud scheme. The alleged scheme involved $250 million in bribes to Indian government officials to secure solar energy contracts, as well as efforts to conceal bribery from U.S. investors. When asked to explain its decision to drop the charges, DOJ told a U.S. District Court Judge for the Eastern District of New York that, in addition to the challenges of prosecuting foreign individuals for foreign conduct: “[T]he alleged conduct did not involve criminal organizations, did not have any effect on U.S. companies, did not in any way implicate national security, was not egregious, and has been the subject of investigations in India…. The FCPA charges here therefore do not plausibly satisfy any of the bases given in the Blanche Memorandum for FCPA charges worthy of proceeding.”⁸ (The “Blanche Memorandum” set forth guidelines for the investigation and enforcement of the FCPA following Executive Orders by President Trump last year.)

Certain defendants who also faced civil charges have entered into a related settlement with the SEC.⁹ Around the same time, an Adani Group company entered into a civil settlement with the U.S. Department of the Treasury’s Office of Foreign Assets Control to resolve an investigation into potential sanctions violations.

DOJ Pursues Non-FCPA Foreign Corruption Cases

In 2026, DOJ also used federal laws beyond the FCPA to target international corruption. For example, DOJ secured a guilty plea under the Travel Act from Peter Weinzierl, an Austrian citizen and former CEO of the Austrian lender Meinl Bank AG, related to his alleged role in helping Odebrecht SA hide $170 million used to bribe government officials and defraud the Brazilian government.¹⁰

DOJ also has pursued corruption cases involving U.S. military contracts. An indictment unsealed in January charged Bahadir Hatipoglu, who resides in Lithuania and is the owner of companies that received contracts from the North Atlantic Treaty Organization (NATO) and the U.S. military, and Ralf Grywnow, who resides in Poland and is a former NATO procurement official, with one count of conspiracy to commit wire fraud and four counts of wire fraud. According to the indictment, Hatipoglu bribed Grywnow with cash, a romantic encounter, and assistance with the construction and furnishing of a house, in exchange for help securing contracts with the U.S. military. DOJ is seeking to extradite the individuals to the United States.

Moreover, in April, DOJ filed a civil forfeiture complaint in the U.S. District Court for Central California, seeking the forfeiture of a Beverly Hills mansion that was allegedly purchased and renovated with proceeds from a scheme, perpetrated by a Virginia defense contractor, to defraud the U.S. Department of Defense’s Defense Logistics Agency, bribe Iraqi officials, and violate U.S. money laundering laws.

SEC Signals Enforcement Shift

While the SEC has not brought any new FCPA cases or announced any new FCPA enforcement policies in 2026, SEC officials have spoken about their current approach to enforcement of securities laws (which include the FCPA). In April 2026, when releasing enforcement results for the 2025 fiscal year, SEC Chairman Paul S. Atkins stated that the Commission has “recentered its enforcement program … by prioritizing cases that provide meaningful investor protection and strengthen market integrity.” The same press release criticized the prior administration’s “aggressive pursuit of novel legal theories” and cases “not sufficiently grounded in the federal securities laws.”

In May 2026, the SEC rescinded its 54-year-old policy that prohibited settling defendants from publicly denying the agency’s allegations. The SEC will no longer require parties to agree to “no-deny” provisions as a condition of settling civil enforcement actions. According to the SEC, the policy had a minimal “effect on the public interest” and “created an incorrect impression that the Commission is trying to shield itself from criticism.” Since 1972, this policy has allowed companies and individuals to accept “neither admit nor deny” resolutions.

Moreover, as Arnold & Porter previously reported, February saw the first major update to the SEC Enforcement Manual since 2017. The revisions incorporate and reflect the structural change to the formal order process resulting from the Commission’s March 2025 revocation of authority delegated to Enforcement Division staff. Now, when seeking a formal order, staff must “succinctly describe the relevant conduct and potential violations, obtain approval from the Office of the Director, and then submit both the memorandum and the proposed formal order to the full Commission for a vote.” The new manual also includes a more predictable and structured Wells process, concrete guidance on how cooperation credit is evaluated for companies, and the restoration of the practice of simultaneously considering settlement offers and statutory disqualification waiver requests.

Senator Introduces Bill to Extend FCPA’s Statute of Limitations

On March 9, 2026, U.S. Senator Elizabeth Warren introduced a bill to extend the FCPA’s statute of limitations period to 10 years. The current draft of the bill states it would expire eight years after the date of enactment, which would give future presidential administrations an opportunity to prosecute recent violations of the FCPA. The bill was referred to the Senate Judiciary Committee.

International News

In May 2026, the SFO entered into a Deferred Prosecution Agreement with Ultra Electronics Holdings Ltd., which agreed to pay approximately £15 million and accept responsibility for the failure to prevent bribery in relation to public-sector contracts in Algeria and Oman. The SFO’s investigation reportedly lasted approximately eight years. This was the SFO’s 13th DPA and its first since 2022.

In April 2026, the European Council adopted a new Anti-Corruption Directive in an effort to harmonize definitions of corruption and penalties across EU member states. This directive covers both public-sector and private-sector (i.e., commercial) bribery. EU member states now have two years to ensure their national laws conform to the new directive.

In April 2026, China’s Supreme People’s Court (SPC) and Supreme People’s Procuratorate (SPP) jointly issued their Interpretation on Several Issues Concerning the Application of Law in Handling Criminal Cases of Corruption and Bribery (II).¹¹ Interpretation II took effect on May 1, 2026, and is the first major update to the interpretation of the criminal law of bribery released by the SPC and SPP in a decade. It focuses on private-sector crimes and “entity crimes,” meaning crimes that carry liability for companies, public institutions, government agencies, and other organizations. Notably, Interpretation (II) lowers the monetary thresholds for bribery and corruption crimes in the private sector and revises the standards for entity crimes and key industries.

In March 2026, China’s State Administration for Market Regulation (SAMR), a main anti-corruption enforcement agency, issued a Notice on Further Implementing the Anti-Unfair Competition Law of the People’s Republic of China (AUCL).¹² The notice directed lower-level SAMRs to focus equally on investigation and punishment of paying bribes and accepting bribes when enforcing the AUCL, one of China’s primary laws against corruption.

Enforcement statistics released by Chinese regulators show that anti-corruption remains a high priority, with the volume of anti-corruption investigations and prosecutions continuing to rise year on year.

Julian Karam contributed to this Newsletter. Julian is a summer associate in Arnold & Porter’s San Francisco office.

© 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.