Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past month, with links to primary resources. This month we ask: Which company was the subject of a coordinated foreign bribery resolution between the United States and France? Which companies were the subject of Dutch foreign bribery enforcement actions? How much does the Organization for Economic Cooperation and Development (OECD) estimate is lost each year to corruption, fraud, and organized crime? The answers to these questions and more are here in our March 2026 Top 10.
On March 19, 2026, the U.S. Department of Justice (DOJ) announced that it had entered into a declination with disgorgement with Balt SAS and its subsidiary Balt USA LLC and that two individuals, David Ferrera of California and Marc Tilman of Belgium, had been indicted in the Central District of California in connection with an alleged scheme to pay bribes to a physician who served in a senior role at a state-owned public hospital in France, in exchange for causing the hospital to purchase the company’s medical devices. According to DOJ, Ferrera worked as an executive at the company’s U.S. subsidiary, while Tilman was retained as a consultant, with the understanding that Tilman would pay a portion of his consulting fees and bonuses to the physician. The bribes were allegedly paid between 2017 and 2023, totaled over $600,000, and resulted in profits of approximately $1.2 million, which the company agreed to forfeit. To conceal the scheme, the co-conspirators allegedly used sham consulting agreements, fake invoices, and personal email accounts. Ferrera and Tilman were charged with one count of conspiring to violate the FCPA (based on both domestic concern (15 U.S.C. § 78dd-2) and territorial jurisdiction (15 U.S.C. § 78dd-3)), two substantive FCPA counts (domestic concern), one count of conspiring to commit money laundering, and two substantive money laundering counts. DOJ stated that this was the first declination with disgorgement under the new Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP), discussed below at number 4. Among other things, DOJ stated that it chose to decline prosecution of the company because the company had agreed to enter into a parallel resolution with France. That resolution was announced the same day by France’s Parquet National Financier (PNF). According to the PNF, Balt USA entered into a convention judiciaire d’intérêt public (CJIP) under which it would pay a fine of €1,765,493 (an amount which reflects a deduction of the forfeiture amount paid pursuant to the U.S. declination with disgorgement) and implement a three-year compliance program. The PNF stated that this was the 31st CJIP signed by the PNF, reflecting France’s continuing status as an important white collar and foreign bribery enforcement authority. This is DOJ’s third coordinated resolution with France since June 2018.
On March 16, 2026, DOJ filed an FCPA conspiracy charge in the Southern District of Texas against Alfonso Wilson, a dual U.S.-Mexican citizen, alleging that he used his Texas-based intermediary company to pay bribes to an official at PEMEX Exploración y Producción (PEP), a subsidiary of Mexico’s national oil company, Petróleos Mexicanos (PEMEX), to help an unnamed “Equipment Company” win a $540 million contract from PEMEX in December 2021. The charging document lists another unnamed intermediary company and several unnamed individuals who were also allegedly involved in the conspiracy. The conspirators allegedly coordinated aspects of the bribe scheme over third-party messaging applications. On or about March 31, 2026 (the docket is unclear), Wilson pleaded guilty to the charge. This is the second time since the end of the FCPA pause in June 2025 that DOJ has brought charges against individuals in connection with PEMEX-related bribery allegations, suggesting that Mexican bribery schemes are on DOJ’s radar. (See our August 2025, September 2025, October 2025, and December 2025 Top 10s for coverage of the first case.) Wilson’s guilty plea and the allegations about additional co-conspirators in his charging document suggest that we can expect charges against additional entities and individuals in the future.
In a March 6, 2026 securities filing, Dr. Reddy’s Laboratories Ltd. disclosed that DOJ had informed the company that it had closed its investigation and did not intend to pursue an enforcement action. The company disclosed in February 2026 that the U.S. Securities and Exchange Commission (SEC) had similarly concluded its investigation without an enforcement action. According to the company, the investigation related to allegations of improper payments to healthcare professionals in Ukraine and potentially in other countries.
On March 10, 2026, DOJ announced “the first-ever Department-wide corporate enforcement policy for criminal matters.” Under the new CEP, DOJ will decline to prosecute companies that voluntarily disclose discovered misconduct to DOJ, cooperate with DOJ investigations, and timely and appropriately remediate the wrongdoing, absent certain aggravating circumstances. Companies not eligible for a declination could receive a reduction of up to 75% off the low end of the U.S. Sentencing Guidelines fine range, depending on the circumstances. The new Department-wide policy is substantially similar to the Criminal Division’s CEP, which has been in place in some capacity since 2016 and was last revised in May 2025; people familiar with the Criminal Division CEP thus will already be familiar with the new policy. Importantly, however, the new Department-wide CEP policy supersedes and replaces the Criminal Division’s CEP, as well as similar programs implemented by various U.S. Attorney’s Offices, such as the Southern District of New York’s policy, which was announced just last month. (As we discuss, some aspects of the old policies could theoretically survive to the extent that they do not conflict with the new CEP, but such aspects are likely few and far between. Also of note, the new CEP does not apply to criminal violations of the Sherman Antitrust Act.) As noted in number 1 above, the Balt SAS declination with disgorgement is the first declination officially released under the new CEP.
On March 9, 2026, 14 Democratic senators introduced the FCPA Reinforcement Act, in response to what they described as the Trump administration’s narrowed enforcement of the FCPA. “To address th[e] perception [of reduced FCPA enforcement] and signal that bribery could well be prosecuted later even if it is presently outside of DOJ’s narrowed focus, the FCPA Reinforcement Act would extend from five to 10 years the statute of limitations for criminal violations of the three anti-bribery provisions of the FCPA.” As evidence of the narrowing of FCPA enforcement, the senators cited the February 2025 Executive Order pausing FCPA enforcement and the June 2025 FCPA Enforcement Guidelines. The senators acknowledged that FCPA enforcement and trials have resumed since the pause but noted that enforcement activity dropped in 2025. Senator Elizabeth Warren, one of the act’s co-sponsors, argued that the FCPA acts as a “shield for U.S. companies that compete the right way” and that the legislation would “encourage[] continued private sector vigilance.” The legislation is unlikely to pass in either chamber, and even if it did, it would likely be vetoed by President Trump. Nevertheless, the legislation does signal that a change in presidential administrations could lead to an uptick in FCPA enforcement, which was basically Senator Warren’s point. In our experience, despite the pause and potential for narrowed enforcement in the short term, companies have wisely continued to invest in FCPA compliance and internal investigations, recognizing not only the long tail of potential government investigation but also the benefits that flow from good internal governance.
On March 10, 2026, the Dutch Public Prosecution Service (OM) announced that it had imposed a penal order, which included a €25.8 million fine, on Fleurette Properties Ltd. for official bribery in the Democratic Republic of Congo (DRC). According to the announcement, the investigation, which began in 2018, focused on foreign official bribery in the DRC to obtain lucrative licenses for cobalt and copper mines and revealed that, from 2010 to 2017, the company served as the top holding company for a group of enterprises active in mining and oil and gold extraction, and was established in the Netherlands due to the business and tax climate. The announcement also stated that the investigation was related to the Swiss Public Prosecution Service investigation that resulted in the August 2024 enforcement action against Glencore International AG. In that case, the Swiss prosecutors determined that Glencore failed to take adequate measures to prevent bribery of a Congolese public official by a business partner in connection with its 2011 acquisition of minority stakes in two mining companies from the DRC’s state mining company and ordered the company to pay over $152 million. Dutch authorities declined to pursue an enforcement action against Glencore, given the Swiss resolution.
On March 30, 2026, OM announced that construction company Strukton had agreed to pay €10 million to resolve allegations of foreign official bribery and forgery in connection with the construction of a metro line in Saudi Arabia. According to the announcement, the investigation, which began in July 2018, revealed that, between February 2013 and June 2021, the company paid a total of approximately $31 million to a third-party agent, a portion of which was intended as a bribe for “a high-ranking member of the ruling family.” OM credited the company for cooperating with the government’s investigation and for implementing remedial and compliance measures. OM stated that it intends to prosecute “a number of individuals” in connection with the alleged bribery scheme.
On March 19, 2026, French billionaire Vincent Bolloré was ordered by investigating judges to stand trial in Paris for bribery of a foreign public official in Togo and complicity in breach of trust in Togo and Guinea. Bolloré, whose family businesses once included logistics assets in Africa, allegedly bribed officials during the presidential campaigns in the two countries between 2009 and 2011 in exchange for port contracts. Two other executives from Bolloré’s group of companies were also ordered to stand trial. The PNF had requested the charges against Bolloré in June 2024. His trial is currently scheduled to take place in December 2026.
On March 24, 2026, the OECD released its Anti-Corruption and Integrity Outlook 2026, which assesses the strengths and gaps in 37 OECD Member and 25 partner countries’ integrity systems. The OECD found that, despite recent progress, implementation of integrity measures remains uneven; the OECD noted that the number of countries that have adopted their first-ever anti-corruption strategy or lobbying law has risen but that countries fail to translate regulations into practice at a concerning rate, particularly with respect to conflict-of-interest management, political financing, and disciplinary systems. The OECD found that high-performing countries are moving away from overly rules-based, compliance-focused, and process-heavy approaches and are adopting digital, risk-based, and results-oriented approaches. According to the report, organizations globally are estimated to lose 5% of funds to fraud each year; between 8–25% of global public investment may be lost to mismanagement and corruption each year; and organized crime is estimated to cost as much as 5% of annual global GDP. The OECD recommends that countries build “strategic, evidence-based, preventative approaches which use resources more effectively and protect public funds and institutions” instead of “relying on enforcement alone.”
On March 31, 2026, the OECD Working Group on bribery released its Phase 4 report on Argentina and its Phase 4 Follow-Up reports on Brazil and Canada. All parties to the OECD Anti-Bribery Convention are subject to a rigorous peer-review process, Phase 4 of which focuses on the evaluated country’s enforcement of the Convention and considers the country’s particular challenges and positive achievements.