21 May 2026
· Volkov Law — Corruption, Crime & Compliance
OFAC settled with Adani Enterprises Limited for $275 million over sanctions compliance failures involving LPG purchases from a Dubai supplier that allegedly masked Iranian origin; the case emphasizes that compliance programs must conduct risk-based due diligence beyond paperwork, investigate red flags like below-market pricing and suspicious vessel activity (AIS manipulation, dark periods, illogical routing), and establish robust escalation procedures when warnings arise about sanction violations.
21 May 2026
· Volkov Law — Corruption, Crime & Compliance
Michael Volkov argues that most corporate scandals are discovered by employees before management acts, but fear prevents reporting. He emphasizes that DOJ and regulators now evaluate whether employees trust reporting systems beyond just hotline existence, noting that strong speak-up cultures detect misconduct earlier and reduce enforcement risk.
20 May 2026
· Volkov Law — Corruption, Crime & Compliance
OFAC settled with Adani Enterprises Limited for $275 million over alleged imports of Iranian-origin LPG disguised as Omani and Iraqi product between November 2023 and June 2025, involving 35 shipments and $192 million in U.S. dollar payments through U.S. banks. OFAC deemed the conduct 'egregious' and reckless, citing AEL's failure to investigate numerous red flags including suspicious vessel activity, AIS manipulation, and implausible pricing, though the penalty was reduced from $384 million due to post-discovery cooperation and compliance enhancements including maritime intelligence technology deployment.
19 May 2026
· Volkov Law — Corruption, Crime & Compliance
Michael Volkov outlines how companies can avoid corporate fines after discovering criminal conduct by conducting thorough internal investigations, identifying responsible individuals, and cooperating with DOJ prosecutors to hold those individuals accountable rather than the company itself.
18 May 2026
· Volkov Law — Corruption, Crime & Compliance
DOJ secured a $549.5 million settlement with Perfectus Aluminum for customs fraud spanning 2011-2014, illustrating DOJ's expanding use of the False Claims Act for trade enforcement alongside criminal prosecution and whistleblower incentives. The settlement demonstrates increased long-tail liability for tariff evasion, transshipment schemes, and product misclassification, with enforcement overlapping UFLPA compliance and requiring companies to modernize trade compliance programs beyond basic customs processes.
17 May 2026
· Volkov Law — Corruption, Crime & Compliance
DOJ secured a $549.5 million False Claims Act settlement with California-based Perfectus Aluminum for allegedly evading antidumping and countervailing duties on over $880 million worth of Chinese-origin aluminum extrusions imported between 2011-2014 by disguising them as finished pallets. The settlement, one of the largest trade-related FCA recoveries, was driven by whistleblowers who will receive 17.5% of the recovery and signals DOJ's escalating prioritization of tariff circumvention enforcement under "America First" trade policy framing, with Acting AG Todd Blanche linking customs fraud to national security concerns.
14 May 2026
· Volkov Law — Corruption, Crime & Compliance
Attorney Michael Volkov explains DOJ's revised corporate enforcement policy, emphasizing that companies can avoid fines by voluntarily disclosing criminal conduct, cooperating with investigations, and remediating compliance programs—resulting in declinations with only disgorgement of ill-gotten gains required.
12 May 2026
· Volkov Law — Corruption, Crime & Compliance
China has expanded its countersanctions framework through new Regulations on Countering Improper Extraterritorial Jurisdiction and State Council Provisions on Industrial and Supply Chain Security, authorizing Beijing to prohibit compliance with foreign sanctions/export controls and impose countermeasures against entities assisting such restrictions. Multinational companies now face direct conflicts of law, where complying with U.S. sanctions or export controls (particularly on semiconductors, AI, and advanced technology) may violate Chinese law, while non-compliance risks U.S. civil or criminal liability—creating incompatible legal obligations across both jurisdictions.
12 May 2026
· Volkov Law — Corruption, Crime & Compliance
Michael Volkov outlines AI third-party risk mitigation strategies for compliance officers, estimating 10-20% of third parties present serious AI risks and recommending six contractual provisions: data use restrictions aligned with privacy laws, confidentiality terms, audit rights, representations and warranties, security obligations, and indemnification with violation disclosure requirements.
11 May 2026
· Miller & Chevalier — FCPA practice
DOJ issued its first declination with disgorgement under the revised Corporate Enforcement Policy in Q1 2026, while enforcement remained slow. Key updates include: the March 2026 department-wide CEP now requires disclosures to "appropriate DOJ component," reduces guaranteed fine reductions from 75% to 50-75%, expands recidivism review beyond five years for similar misconduct, and explicitly considers company size/sophistication in cooperation credit. International developments include World Bank debarring Turkish company Aktif Elektroteknik and PwC entities in Mauritius/Kenya/Rwanda, UK SFO enforcing Guralp Systems DPA breach after expiration, Brazil updating leniency rules, and Peru disbanding its Lava Jato prosecution team.
08 May 2026
· Miller & Chevalier — FCPA practice
Miller Chevalier attorneys examine how the Trump administration's designation of drug cartels as Foreign Terrorist Organizations (FTOs) expands enforcement authorities under the Anti-Terrorism Act, enabling DOJ, OFAC, and FinCEN to pursue criminal and civil liability against companies providing material support to cartels, with coordinated enforcement targeting cartel-related activity throughout Latin America.
07 May 2026
· Miller & Chevalier — FCPA practice
Mexico's Supreme Court ruled in Leonardo Poblete v. UBS that corporate compliance programs must be effective and actively implemented, not merely paper policies, significantly expanding corporate criminal liability in a jurisdiction that previously lacked robust corporate liability concepts. This landmark decision strengthens the Mexican government's ability to prosecute corporations and reflects broader trends of intensified compliance expectations and cartel enforcement across Latin America.
27 April 2026
· Global Anticorruption Blog (Harvard)
U.K. District Judge Sam Goozée ruled April 22 that civil forfeiture statute of limitations under the Proceeds of Crime Act begins only when the National Crime Agency discovers hidden assets, ordering forfeiture of $260,000 from Marinette Soumery's London account linked to former Seychelles official Mukesh Valabhji (charged with 11 corruption counts). The precedent-setting decision allows prosecutors to pursue concealed assets beyond traditional limitation periods when defendants actively hide accounts and origins, rejecting Soumery's defense that the six-year clock started in 2007 when deposits were made rather than 2023 when NCA discovered the account during assistance to Seychelles investigators.
23 April 2026
· Global Anticorruption Blog (Harvard)
Moldova's Parliament lowered the threshold for appointing members to judicial vetting commissions from a supermajority to a simple majority, potentially compromising the independence of bodies tasked with reviewing judges and prosecutors for corruption; the move echoes Poland's contested justice reforms and may violate Article 6 ECHR standards.
20 April 2026
· Global Anticorruption Blog (Harvard)
House and Senate Democrats introduced the Ban Presidential Plunder of Taxpayer Funds Act on April 15, prohibiting sitting presidents and vice presidents (and their families/entities) from collecting settlement payments or damages from the U.S. government, pausing administrative claims processing while in office, and requiring independent counsel and public proceedings for any federal court damages awards. The bill also imposes a cooling-off period restricting former presidents when their VP succeeds them and establishes guardrails on claims by former presidents/VPs.
14 April 2026
· Global Anticorruption Blog (Harvard)
Sri Lanka launched a beneficial ownership register on March 31, 2026, following IMF Governance Diagnostic recommendations and amendments to the Companies Act, with civil society group Transparency International Sri Lanka successfully challenging the legislative approach to extend disclosure requirements and enable public access. The country also enacted a Proceeds of Crime Act, amended its National Audit Act, and rolled out a digital asset declaration system, though firm-level bribery incidence increased from 10% in 2011 to 26% in 2025 even as the country's Corruption Perceptions Index score rose three points to 35 in 2025.
16 March 2026
· Miller & Chevalier — FCPA practice
Miller Chevalier attorneys Matteson Ellis and Collmann Griffin published guidance on compliance risks for companies considering investments in Venezuela's energy sector amid evolving U.S. sanctions, outlining a three-step roadmap that includes OFAC general license compliance, security protocols, and operational planning to address heightened bribery, money laundering, cartel, and sanctions risks.
04 March 2026
· DOJ FCPA Enforcement Actions
DOJ Criminal Division filed an indictment against David Ferrera and co-defendants on March 4, 2026 in the Central District of California, though specific charges and details are not provided in this case listing.
03 March 2026
· Global Anticorruption Blog (Harvard)
John Chevis and the University of New South Wales team have developed "Neon," an AI-powered tool using a captive Large Language Model (Ollama) to automate National Anti-Money Laundering Risk Assessments by analyzing suspicious transaction reports, company registrations, and other data sources to identify ML/TF vulnerabilities and corruption risks. Built for Papua New Guinea's FIU with Australian Department of Foreign Affairs funding, Neon quantifies money laundering significance using monetary values, identifies unreported suspicious matters, and tracks temporal changes in AML effectiveness—offering a digital alternative to manual NRA processes required by FATF.
19 February 2026
· Miller & Chevalier — FCPA practice
DOJ and SEC showed minimal FCPA enforcement in 2025 with only two corporate resolutions: Millicom's Guatemalan subsidiary TIGO Guatemala agreed to a $118 million DPA for bribery conspiracy, and Liberty Mutual received a declination with disgorgement. DOJ secured trial convictions against Carl Zaglin and Ramón Rovirosa, while internationally the UK SFO arraigned six ex-Glencore employees for West African bribery conspiracy and a Brazilian court nullified J&F Investimentos' R$10 billion Lava Jato fine.
11 February 2026
· Global Anticorruption Blog (Harvard)
Following the Trump administration's February 2025 FCPA enforcement pause and narrowed policy, the UK, France, and Switzerland formed the International Anti-Corruption Prosecutorial Taskforce in March 2025. Israeli legal scholar Noam Kozlov argues Europe cannot replace US enforcement due to resource gaps (US: 320 FCPA actions vs. Europe's 71) and jurisdictional limitations, but should instead pursue cooperative enforcement through global settlements and proceeds-sharing with countries where bribes occurred, citing the Petrobras $1.78 billion resolution that shared $680 million with Brazil as a model.
11 February 2026
· Miller & Chevalier — FCPA practice
Miller & Chevalier and Sainz Abogados published a practical glossary to help companies navigate compliance risks following Trump's January 20, 2025 Executive Order 14157, which designated cartels and other organizations as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs), creating new enforcement priorities for companies operating in Latin America around terrorism designations, sanctions, and cartel-related risks.
11 February 2026
· Miller & Chevalier — FCPA practice
Matteson Ellis notes FCPA cases were down in 2025 due to an FCPA enforcement pause, DOJ FCPA Unit downsizing, and the SEC disbanding its FCPA enforcement unit under the Trump administration, but anticipates Latin America cases will comprise a significant portion of 2026 FCPA enforcement.
09 February 2026
· Global Anticorruption Blog (Harvard)
NDI, OGP, and Transparency International published a brief debunking justifications for confidentiality clauses in sovereign debt contracts, which have enabled hidden debt scandals like Mozambique's $2bn undisclosed loans and Senegal's 2024 audit revealing billions in hidden debt. The brief recommends borrower countries enact laws mandating full debt transparency and proactive disclosure, creditor countries require transaction-level reporting to public databases, and establishment of a single global debt registry to combat corruption-driven hidden debt that forces LMICs to slash public services.
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 officials for a billion-dollar oil pipeline project but received only a AUD $1,000 fine (about $700 USD), drawing criticism from Transparency International as embarrassingly low and potentially violating Australia's OECD Anti-Bribery Convention commitments requiring 'effective, proportionate and dissuasive' penalties including imprisonment for executives involved in foreign bribery.
03 February 2026
· Miller & Chevalier — FCPA practice
Matteson Ellis warns companies considering reentry into Venezuela's energy sector that state oil company PDVSA is 'perhaps the most corrupt state-owned entity in Latin America,' noting that firms will face constant extortion and bribery requests from local officials alongside the need to interact with PDVSA, creating significant FCPA compliance risks in what is now an 'unknown landscape' after years without major international company presence.
14 January 2026
· Miller & Chevalier — FCPA practice
Matteson Ellis outlines elevated corruption and sanctions compliance risks for U.S. companies re-entering the Venezuelan market, drawing parallels to challenges in Nigeria and Iraq, and emphasizing the need for careful legal compliance and ethics planning in this unstable environment.
12 November 2025
· Miller & Chevalier — FCPA practice
Miller Chevalier's Q3 2025 FCPA review covers multiple developments: DOJ issued its first Trump-era corporate resolution (a declination with disgorgement to Liberty Mutual), charged Mexican nationals Ramon Rovirosa and Mario Avila with bribing Pemex officials in a case controversially linking FCPA violations to cartel activity, won conviction of a Georgia CEO for Honduras bribery, convicted Nigerian-American lawyer for oil company bribery, and added Smartmatic to a superseding indictment of its former executives Roger Pinate Martinez and Jorge Vasquez. International actions include Singapore shipbuilder paying nearly $190 million for Lava Jato-related misconduct and UK prosecutors charging former Entain executives with bribery violations.
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 handled by the Criminal Division's Fraud Section, though specific allegations and financial terms are not detailed in this docket entry.
22 October 2025
· Miller & Chevalier — FCPA practice
FinCEN orders under the Fentanyl Sanctions Act took effect October 20, 2025, designating three Mexican financial institutions (CIBanco, Intercam Banco, and Vector Casa de Bolsa) as primary money laundering concerns for facilitating cartel fentanyl trafficking and requiring U.S. covered financial institutions to block fund transmittals involving these entities. The Trump administration has also designated 13 Latin American cartels as Foreign Terrorist Organizations, creating potential Anti-Terrorism Act liability for companies providing material support, prompting recommendations for financial institutions to enhance CDD, transaction monitoring, and AI-powered compliance programs to address TCO-related risks.
22 October 2025
· Miller & Chevalier — FCPA practice
James Tillen analyzes the Carl Zaglin conviction for conspiracy to commit money laundering, noting that despite narrowed anti-corruption enforcement focus under the Trump administration, DOJ maintains appetite for FCPA prosecutions targeting individuals—particularly corrupt executives and bribery middlemen—over companies, with cooperating witnesses playing a strategic role in establishing context beyond vague emails and transaction records.
14 October 2025
· Miller & Chevalier — FCPA practice
DOJ's Criminal Division is aggressively pursuing companies and individuals with ties to Latin American cartels designated as Foreign Terrorist Organizations, including filing FCPA charges against Texas residents for bribing Pemex officials allegedly linked to cartels, seizing 300,000 kg of methamphetamine precursors under new FTO civil forfeiture authority, and reporting 313 whistleblower tips (120 under investigation) in four months since expanding its May 2025 whistleblower program to cover cartel-related corporate violations. Acting AAG Galeotti announced DOJ has taken custody of 50 cartel bosses and charged 30 individuals for money laundering since February 2025, signaling coordinated multi-agency enforcement against the 13 designated Latin American FTOs under the administration's 'total elimination' strategy.
06 October 2025
· Miller & Chevalier — FCPA practice
The Trump administration 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 create significant FCPA-adjacent compliance risks for companies operating in the region, as providing 'material support' (broadly defined to include payments, services, or resources) to these organizations can result in criminal and civil liability even for transactions occurring entirely outside the U.S.
10 September 2025
· Miller & Chevalier — FCPA practice
Cadence Design Systems reached a $140M parallel settlement with DOJ and Commerce's BIS for unlawfully exporting semiconductor design tools to a restricted Chinese military university. DOJ required a parent-level guilty plea for an indirectly owned foreign subsidiary under agency liability theory, while BIS imposed penalties approaching the statutory maximum of twice the transaction value for violations involving EDA hardware/software and EAR99 items.
09 September 2025
· Miller & Chevalier — FCPA practice
Miller & Chevalier authors contributed to the fourth edition of Global Investigations Review's Guide to Compliance, with their U.S. chapter examining DOJ and SEC compliance guidance under the second Trump administration, emphasizing heightened expectations for proactive compliance program development and providing a blueprint for companies to enhance their programs.
31 July 2025
· Miller & Chevalier — FCPA practice
Miller Chevalier's Q2 2025 FCPA review details DOJ's June 9 Guidelines that restart FCPA enforcement after Trump's February 10 executive order pause, prioritizing cases affecting U.S. national interests while deprioritizing routine foreign business practices. Notable developments include updated Corporate Enforcement Policy with guaranteed declinations in certain circumstances, early dismissals of DPAs/NPAs for Stericycle, Albemarle, ABB, and Honeywell, closure of investigations into Stryker and Toyota's Thai subsidiary, sentencing of Tim Leissner to two years for 1MDB role, and $352 million restitution order in Mozambique 'Tuna Bonds' scandal.
17 July 2025
· Miller & Chevalier — FCPA practice
DOJ is linking FCPA enforcement to interactions with cartels, transnational criminal organizations, and Foreign Terrorist Organizations, creating overlapping liability exposure where companies operating in high-FTO-activity jurisdictions face both Anti-Terrorism Act and FCPA risks when payments to foreign officials potentially support or aid designated terrorist organizations.
09 July 2025
· Miller & Chevalier — FCPA practice
FinCEN sanctioned three Mexican financial institutions, prohibiting U.S. banks from transmitting funds to or from them, signaling heightened enforcement under the Trump administration. Companies doing business in Mexico should reassess compliance controls beyond traditional anti-corruption measures to address these new sanctions risks.
09 July 2025
· Miller & Chevalier — FCPA practice
Matteson Ellis of Miller Chevalier analyzes DOJ's June 2025 resumption of FCPA enforcement under Trump administration, noting new guidelines will intensify scrutiny in Latin America—historically the focus of 40% of corporate FCPA cases (2018-early 2025)—especially in matters involving cartels, national security, and foreign companies disadvantaging U.S. competitors.
03 July 2025
· Miller & Chevalier — FCPA practice
FinCEN issued unprecedented orders on June 25, 2025, under the FEND Off Fentanyl Act prohibiting U.S. financial institutions from transmitting funds to or from three Mexican banks—CIBanco, Intercam, and Vector—finding they facilitated money laundering for cartels including CJNG and Cártel de Sinaloa in connection with illicit opioid trafficking. The prohibition took effect July 21, 2025, with no end date; willful violations may result in BSA civil or criminal penalties, and the orders mark the first use of the sixth special measure authorizing fund transmittal prohibitions.
02 July 2025
· Miller & Chevalier — FCPA practice
Miller Chevalier attorneys advise that the Trump administration's heightened focus on combating Mexican cartels and transnational criminal organizations requires multinationals operating in Mexico to strengthen compliance programs and develop crisis response protocols for extortion attempts, drug contamination in supply chains, and timely risk reporting to avoid inadvertently supporting cartel operations.
12 June 2025
· Miller & Chevalier — FCPA practice
On June 9, 2025, Deputy Attorney General Todd Blanche issued new DOJ guidelines ending the 180-day FCPA enforcement pause from President Trump's February 10 executive order, directing prosecutors to focus on individual misconduct rather than corporate liability, prioritize cases affecting U.S. national interests, and centralize case authorization through the Assistant Attorney General for the Criminal Division. The memo signals potential shifts away from prosecuting U.S. companies for bribes that don't harm specific U.S. entities, increased scrutiny of Chinese companies, and enhanced focus on cartel/TCO-related corruption in Latin America, while leaving key implementation questions unanswered and not addressing SEC enforcement policy.
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· DOJ FCPA Enforcement Actions
DOJ indicted Rovirosa and Avila in the Southern District of Texas (case filed August 6, 2025) on charges handled by the Criminal Division's Fraud Section, suggesting potential FCPA or related corruption violations, though specific allegations are not detailed in the docket entry.
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· DOJ FCPA Enforcement Actions
Nazar Mohamed and Azruddin Mohamed were indicted in the Southern District of Florida on October 2, 2025, in a criminal FCPA case brought by DOJ's Criminal Fraud Section, though specific allegations regarding bribery amounts, foreign officials involved, or industry are not disclosed in this docket entry.
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· DOJ FCPA Enforcement Actions
DOJ charged Smartmatic (SGO Corporation Limited) and four individuals—Juan Andres Donato Bautista, Rojer Alejandro Pinate Martinez, Jorge Miguel Vasquez, and Elie Moreno—in the Southern District of Florida with criminal fraud offenses; indictment filed August 2024, superseding indictment October 2025, case involves the election technology company.