Analysis

The United States concluded 2025 with the sparsest FCPA enforcement in years—just two corporate dispositions, a remarkable contraction reflecting the administration's recalibration of enforcement priorities. The first Trump administration's February 2025 enforcement pause, followed by Deputy Attorney General Todd Blanche's June memorandum, narrowed DOJ's focus to matters "directly undermining U.S. national interests," deprioritized routine foreign business practices, and centralized approval authority in the Criminal Division. That policy shift did not halt enforcement altogether: DOJ secured a $118 million deferred prosecution agreement with Millicom subsidiary TIGO Guatemala (the sole corporate DPA of 2025) and negotiated a declination with disgorgement for Liberty Mutual. The department simultaneously brought individual prosecutions to trial, convicted Carl Zaglin and Ramón Rovirosa on Pemex bribery-related charges, and pursued forfeiture against Pras Michel in the 1MDB matter.

Programmatically, the revised Corporate Enforcement Policy now guarantees declinations to qualifying self-reporters and shortens DPA terms to two years (down from the customary three); early terminations for Stericycle, Albemarle, ABB, and Honeywell underscored DOJ's intent to reduce compliance-monitor burdens for cooperating companies.

TIGO Guatemala (Millicom subsidiary) — DOJ reached a $118 million deferred prosecution agreement (DPA) on November 10, 2025 (filed Southern District of Florida October 22), resolving a Guatemala bribery conspiracy in which TIGO executives delivered monthly cash payments (including duffel bags flown by helicopter) to legislators to secure favorable telecommunications laws and exclusive government contracts; the scheme generated $58 million in illicit profits, involved narcotrafficking proceeds laundered through U.S. bank accounts, and continued after Millicom's 2015 voluntary self-disclosure (which DOJ reopened in 2020 upon discovering the ongoing conduct and cartel nexus). TIGO received a 50% penalty reduction and two-year DPA term (rather than the historic three years) for voluntary disclosure, cooperation, and remediation, though it did not qualify for a declination. The resolution is notable as the first criminal FCPA corporate action after the enforcement pause lifted and as the clearest signal that cartel-linked corruption will receive enhanced scrutiny even where the primary offense is bribery of foreign officials rather than material support to an FTO.

Liberty Mutual — DOJ issued a declination with disgorgement in 2025 (the only other corporate FCPA disposition of the year), reflecting the revised Corporate Enforcement Policy's more predictable incentives for voluntary disclosure and full cooperation. The declination confirms that qualifying self-reporters can secure non-prosecution outcomes even in the narrowed enforcement environment, provided they meet cooperation and remediation thresholds.

• Pras Michel (1MDB forfeiture) — A federal court ordered forfeiture of $65 million from defendant Pras Michel in the 1MDB matter, continuing the department's decade-long pursuit of individuals and assets tied to the Malaysian sovereign-wealth-fund theft; the forfeiture underscores DOJ's sustained commitment to asset recovery in grand-corruption cases with a U.S. nexus, even where the primary enforcement activity occurred years earlier.

• Carl Zaglin and Ramón Rovirosa (Pemex bribery) — DOJ secured trial convictions of two individuals on conspiracy to commit money laundering charges tied to Pemex-related bribery in 2025; cooperating witnesses proved critical in establishing the context of vague communications and transaction records in what the department characterized as a complex international bribery case; the convictions demonstrate that individual prosecutions remain a priority even as corporate enforcement contracts, consistent with Blanche's directive to target corrupt executives and bribery middlemen over companies.

• Pras Michel (1MDB forfeiture) — A federal court ordered forfeiture of $65 million from defendant Pras Michel in the 1MDB matter, continuing the department's decade-long pursuit of individuals and assets tied to the Malaysian sovereign-wealth-fund theft; the forfeiture underscores DOJ's sustained commitment to asset recovery in grand-corruption cases with a U.S. nexus, even where the primary enforcement activity occurred years earlier.

• Stryker, Toyota Thailand subsidiary, and Inotiv — DOJ closed investigations into Stryker, Toyota's Thai subsidiary, and Inotiv without action, consistent with the policy shift toward cases with clear indicia of corrupt intent, substantial payments, sophisticated concealment, or national-interest impact; companies should interpret these closures as confirmation that marginal or compliance-failure cases are deprioritized absent aggravating factors.

Australia delivered the lowest penalty on record in a foreign-bribery case when former Leighton Holdings CEO David Savage received an AUD 1,000 (USD 700) fine after pleading guilty to covering up $45 million in bribes paid to Iraqi politicians to secure a $1 billion oil-pipeline project. Savage's sentence—issued in January 2026 following a decade-long investigation that began with a 2011 self-report to the Australian Federal Police—prompted immediate outcry from Transparency International and compliance practitioners, particularly because intermediaries in the same scheme received multi-year prison sentences in the UK and the United States. The Australian Commonwealth Director of Public Prosecutions successfully obtained a conviction on a charge of providing misleading information to directors (Savage misallocated costs and removed references to "agency support" from cost summaries in 2010), but the AUD 1,000 fine raises serious questions whether Australia's sentencing framework satisfies the OECD Anti-Bribery Convention's requirement that penalties be "effective, proportionate and dissuasive."

The Savage case is not isolated evidence of weak enforcement: Australia's National Anti-Corruption Commission (established July 2023) has secured eleven convictions since inception, primarily in domestic public-sector corruption matters, but foreign-bribery enforcement remains anemic and conviction rates low. Separately, the NACC published its Operation Myrtleford report in March 2026, finding that two of six individuals referred by the Royal Commission into the Robodebt Scheme engaged in serious corrupt conduct, and its Operation Pelican report, which led to the July 2025 conviction of a Western Sydney Airport staff member for soliciting a bribe during a tender process (sentenced to two years served via Intensive Correction Order with 500 hours of community service).

• AUSTRAC audit of Airwallex and MHITS — AUSTRAC ordered external audits of payment platforms Airwallex (January 2026) and MHITS Limited (April 2026) under Section 162 of the AML/CTF Act for suspected failures in transaction monitoring, customer due diligence, and suspicious-matter reporting; the regulator cited concerns that compliance programs were not attuned to multi-jurisdiction payment-platform risks, particularly MHITS's failure to identify high-risk payments linked to child-sexual-exploitation material sent offshore; the audits follow a 264% increase in suspicious-matter reports in the payment-platforms sector related to suspected child exploitation, signaling heightened regulatory focus on fintechs and remittance channels.

The United Kingdom charged six former Glencore employees with West Africa corruption offenses, arraigning them before the Serious Fraud Office in early 2026 following the company's 2022 global settlement. The charges represent the SFO's continued emphasis on holding individuals accountable after corporate resolutions, a policy that mirrors DOJ's approach but operates within a compressed time horizon given the UK's absence of statute-of-limitations bars on bribery prosecutions. Separately, former Entain executives face charges in the UK, demonstrating enforcement activity beyond the extractives sector. The SFO's institutional trajectory remains one of cautious investment: the office has announced plans to expand its crime-prevention capability—offering companies proactive advisory services to strengthen anti-bribery controls—and has committed to accelerate investigations through artificial intelligence and machine-learning tools, with an explicit mandate to share lessons learned across the UK enforcement system.

Recent matters:

• Glencore (West Africa corruption) — The SFO arraigned six former Glencore employees on corruption charges related to West Africa bribery schemes in early 2026, following Glencore's June 2022 global settlement with UK, U.S., and Brazilian authorities totaling over $1.5 billion; the individual prosecutions signal the SFO's commitment to pursuing executives and employees after corporate resolutions, a practice that places senior management at continuing personal risk even where the company has resolved liability.

• Entain executives — The SFO brought charges against former Entain executives in 2025, expanding enforcement beyond the extractives and infrastructure sectors into gaming and hospitality; the matter reinforces that SFO enforcement spans industries and that UK companies with international operations face persistent scrutiny where business practices deviate from UK Bribery Act standards.

• EU Directive on Combatting Corruption (implementation considerations) — The new EU Directive, requiring member-state implementation, introduces "trading in influence" as a standalone criminal offense (absent in UK law), applies corporate liability where a leader's "lack of supervision" enables bribery (a narrower trigger than the UK Bribery Act's section 7 "failure to prevent" strict liability), and treats compliance programs as mitigating factors rather than complete defenses; UK businesses operating in the EU must revise due diligence to scrutinize intermediary compensation for access-based fees, map supervisory chains for "leading position" accountability, and prepare data-driven evidence that compliance programs are effective (not merely adequate on paper), because post-Brexit the UK is under no obligation to harmonize and the regimes will diverge materially.

The OECD Anti-Corruption and Integrity Outlook 2026 documented a persistent implementation gap across sixty-two surveyed countries: while 63% of OECD members report strong anti-corruption regulation, only 44% demonstrate effective implementation—a nineteen-percentage-point delta that grows wider in judicial integrity, where fewer than one-third of OECD countries require judges and prosecutors to submit routine conflict-of-interest declarations. Only one in four OECD members tracks anti-corruption-strategy implementation with measurable indicators. The report recommends governments deploy artificial intelligence and data analytics to detect procurement fraud and strengthen enforcement in high-risk areas including state-owned enterprises and public-private partnerships.

For compliance officers, the OECD's findings confirm what the U.S. enforcement pause and Australia's Savage sentence illustrate: that the global anti-corruption architecture suffers not from a lack of rules but from weak or inconsistent enforcement, particularly outside the United States. The formation of the International Anti-Corruption Prosecutorial Taskforce by the UK, France, and Switzerland in March 2025 reflects European recognition that collective action is necessary to fill enforcement voids, but the Taskforce lacks the jurisdictional reach and resource depth (320 U.S. FCPA actions versus 71 combined for UK, France, and Switzerland) to replicate U.S.-led enforcement at scale. Commentators have proposed that the Taskforce adopt cooperative enforcement models in which investigation proceeds are shared with victim countries—citing the $1.78 billion Petrobras settlement, in which Brazil received $680 million—as a mechanism to incentivize cross-border collaboration and asset return. The broader strategic question is whether a multipolar enforcement environment, in which the U.S. enforces selectively and Europe enforces modestly, will prove sufficient to sustain deterrence, or whether the reduced enforcement tempo will embolden risk-taking by companies and individuals who calculate that the probability of detection and sanction has fallen materially.

This briefing synthesizes enforcement actions, policy shifts, and institutional developments from ten monitoring sources covering approximately twenty-four months through May 2026. Jurisdiction assignment reflects the enforcing authority's home country; conduct locus and foreign-official nationality are noted as context within the enforcing jurisdiction's discussion. Nothing in this briefing constitutes legal advice. For questions on specific matters or jurisdictional interpretation, contact your usual anti-corruption partner.