19 February 2026
· Miller & Chevalier — FCPA practice
Miller Chevalier's Q4 2025/early 2026 FCPA review reports minimal DOJ enforcement activity: only one corporate DPA (Millicom subsidiary TIGO Guatemala paid $118M for Guatemala bribery conspiracy) and one declination with disgorgement (Liberty Mutual) in 2025, the lowest corporate disposition count in years. DOJ confirmed Andrew Tysen Duva as Criminal Division AAG and named Lorinda Laryea as Fraud Section Chief. Individual prosecutions included trial convictions of Carl Zaglin and Ramón Rovirosa for Pemex-related bribery, and Pras Michel was ordered to forfeit $65M in the 1MDB case. Internationally, the SFO arraigned six ex-Glencore employees for West Africa corruption, World Bank debarred Indian company Transformers and Rectifiers, and Brazilian courts nullified J&F Investimentos' R$10B Lava Jato fine.
11 February 2026
· Global Anticorruption Blog (Harvard)
Noam Kozlov argues that following the Trump administration's February 2025 FCPA enforcement pause and subsequent policy narrowing, the UK, France, and Switzerland formed the International Anti-Corruption Prosecutorial Taskforce in March 2025, but Europe lacks the resources and jurisdictional reach to replace US enforcement (US has 320 FCPA actions vs. 71 combined for UK/France/Switzerland); instead, the Taskforce should adopt cooperative enforcement models that share investigation proceeds with victim countries where bribes occurred, citing examples like the $1.78 billion Petrobras global settlement where Brazil received $680 million.
11 February 2026
· Miller & Chevalier — FCPA practice
Miller & Chevalier and Mexico-based Sainz Abogados published a glossary guide following President Trump's January 20, 2025 Executive Order 14157 designating cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs), helping companies operating in Latin America navigate new compliance risks around terrorism designations, sanctions, and cartel-related enforcement priorities.
06 February 2026
· Global Anticorruption Blog (Harvard)
David Savage, former CEO of Leighton Holdings, pled guilty to covering up $45 million in bribes to Iraqi politicians to secure a $1 billion oil pipeline project but received only a AUD $1,000 (USD $700) fine, prompting outcry from Transparency International and raising questions about Australia's compliance with OECD Antibribery Convention requirements for "effective, proportionate and dissuasive" penalties, especially since intermediaries in the scheme received multi-year prison sentences in the UK and US.
18 November 2025
· Cleary Gottlieb
Comunicaciones Celulares S.A. (TIGO Guatemala), a Millicom subsidiary, entered a two-year DPA with DOJ on November 10, 2025—the first criminal FCPA corporate resolution since the enforcement pause ended in June 2025. TIGO admitted bribing Guatemalan legislators with monthly cash payments (including duffel bags delivered by helicopter) to secure telecommunications legislation and exclusive government contracts, earning $58 million in illicit profits; the scheme involved narcotrafficking proceeds and U.S. bank accounts. Despite Millicom's 2015 voluntary self-disclosure, DOJ reopened the investigation in 2020 after discovering the misconduct continued and involved narcotrafficker cash; TIGO will pay $118 million ($60 million penalty plus $58 million forfeiture), receiving a 50% penalty reduction for VSD, cooperation, and remediation but avoiding a compliance monitor.
12 November 2025
· Miller & Chevalier — FCPA practice
Miller Chevalier's Q3 2025 FCPA review details DOJ's first Trump-era corporate resolution (Liberty Mutual declination with disgorgement), charges against two Mexican nationals with alleged cartel ties for bribing Pemex officials, convictions of a Georgia CEO for Honduras bribery and a Nigerian-American lawyer for oil company bribes, and international enforcement actions including Singapore's Sembcorp paying $190 million for Lava Jato-related violations and UK charges against former Entain executives.
22 October 2025
· DOJ FCPA Enforcement Actions
DOJ filed criminal charges against TIGO Guatemala in the Southern District of Florida on October 22, 2025, resulting in a deferred prosecution agreement. The case was handled by the Criminal Division's Fraud Section, indicating potential FCPA or foreign bribery violations by the telecommunications company.
14 October 2025
· Miller & Chevalier — FCPA practice
The Trump DOJ is aggressively targeting Latin American cartels designated as Foreign Terrorist Organizations under the Anti-Terrorism Act, coordinating multi-agency enforcement across DOJ, OFAC, FinCEN, SEC, ICE, and DHS. Key developments include 50 cartel bosses extradited since February, the August 2025 Pemex FCPA indictment alleging cartel ties, 313 whistleblower tips received in four months (120 warranting investigation), and Latin America's first FTO-related civil forfeiture seizing 300,000 kg of methamphetamine precursors from Sinaloa cartel operations.
06 October 2025
· Miller & Chevalier — FCPA practice
Secretary of State Marco Rubio has designated 13 Latin American cartels and TCOs as Foreign Terrorist Organizations since February 2025, including MS-13, Tren de Aragua, Sinaloa Cartel, CJNG, and others operating across Mexico, Central America, and South America. These FTO designations expose U.S. companies to criminal and civil liability for providing "material support" (broadly defined to include payments, services, transportation, or resources) to these organizations, even for transactions occurring entirely outside the U.S., significantly increasing compliance risks for businesses operating in Latin America.
31 July 2025
· Miller & Chevalier — FCPA practice
Miller Chevalier's Q2 2025 FCPA review details major DOJ policy shifts following President Trump's February 10 executive order pausing FCPA enforcement, including DAG Todd Blanche's June 9 memorandum establishing new guidelines that restart enforcement focused on conduct "directly undermining U.S. national interests" while deprioritizing routine foreign business practices. Key developments include updated Corporate Enforcement Policy guaranteeing declinations in certain circumstances, early terminations of DPAs/NPAs for Stericycle, Albemarle, ABB, and Honeywell, Tim Leissner's two-year sentence in the 1MDB scandal, and closure of investigations into Stryker, Toyota's Thai subsidiary, and Inotiv, alongside ongoing individual prosecutions and international enforcement actions by SFO, Dutch, French, and Brazilian authorities.
17 July 2025
· Miller & Chevalier — FCPA practice
DOJ is now linking FCPA enforcement to interactions with cartels, transnational criminal organizations (TCOs), and Foreign Terrorist Organizations (FTOs), creating overlapping liability exposure under both the FCPA (bribery of foreign officials) and the Anti-Terrorism Act (material support to FTOs), particularly in jurisdictions with high FTO activity.
09 July 2025
· Miller & Chevalier — FCPA practice
Matteson Ellis analyzed DOJ's June 2025 resumption of FCPA enforcement under Trump, noting new guidelines will intensify scrutiny in Latin America—historically the source of 40% of corporate enforcement actions (2018-early 2025)—particularly in cases involving cartels, national security, and foreign companies disadvantaging U.S. competitors.
12 June 2025
· Miller & Chevalier — FCPA practice
Deputy Attorney General Todd Blanche issued new FCPA enforcement guidelines on June 9, 2025, ending the 180-day enforcement pause ordered by President Trump's February 10 executive order. The memorandum directs DOJ prosecutors to focus on individual criminal misconduct rather than corporate liability, prioritize cases affecting U.S. national interests, minimize business disruption, and expedite investigations—with all new cases requiring authorization from the Assistant Attorney General for the Criminal Division or higher, though this centralized approach conflicts with Attorney General Bondi's directive that U.S. Attorneys' Offices lead cartel/TCO-related corruption cases.