Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption developments from the past month, with links to primary resources. This month, we ask: Which enforcement agency entered into its first foreign-bribery-related deferred prosecution agreement (DPA) in nearly five years? Will the Organization of Economic Cooperation and Development (OECD) continue to vigorously monitor its member states’ enforcement of the OECD Anti-Bribery Convention? What does a new report tell us about foreign bribery and money laundering risks in the United Kingdom (UK)? The answers to these questions and more are here in our May 2026 Top 10.
On May 1, 2026, the UK Serious Fraud Office (SFO) announced that a UK court had approved a DPA with Ultra Electronics Holdings Limited, alleging that the company had failed to prevent bribery in connection with a public sector contract in Oman worth more than £200 million and two public sector contracts in Algeria potentially worth £1.4 million. The bribery schemes allegedly involved the use of third-party agents. As part of the agreement, the company agreed to pay a £10 million penalty and £4.8 million toward the SFO’s costs and to report annually on the effectiveness of its anti-corruption compliance program. The SFO stated that its investigation began in 2018 after the company reported suspected corruption involving its Algeria business and was expanded in 2024 to cover all jurisdictions in which the company operated. The SFO also stated that DPA negotiations, which had previously been withdrawn, resumed after significant changes in the company’s ownership, structure, and leadership. The Ultra DPA is the first DPA, and the first foreign-bribery-related DPA, from the SFO in nearly five years. (For the most recent foreign bribery-related DPA from the SFO, see our July 2021 Top 10.)
In November 2024, the U.S. Department of Justice (DOJ) and U.S. Securities and Exchange Commission (SEC) announced enforcement actions related to an alleged $250 million bribery scheme involving a large solar energy project in India pursued by companies associated with, among others, Gautam and Sagar Adani. On May 14, 2026, SEC announced that it had moved for final judgments by consent in its case, filed in the Eastern District of New York, against the Adanis. According to SEC, while the alleged bribery scheme was ongoing, the defendants made false or misleading statements in connection with a 2021 bond offering by Adani Green Energy Ltd., including statements concerning anti-bribery compliance. The offering allegedly raised more than $175 million from U.S. investors alone. Without admitting or denying SEC’s allegations, the defendants consented to proposed final judgments that would impose permanent injunctions and civil monetary penalties of $6 million and $12 million. (For more on the SEC case, see our January 2026 Top 10.)
On May 18, 2026, DOJ moved to dismiss related criminal charges that had been filed in the Eastern District of New York. The motion does not state whether the SEC resolution or any reported promises by the Adanis to invest in the U.S. economy factored into DOJ’s decision, stating only that DOJ “has reviewed the case and has decided, in its prosecutorial discretion, not to devote further resources to these criminal charges against individual defendants.” The motion also noted that none of the defendants had appeared in the criminal matter.
On May 14, 2026, Methode Electronics, Inc. disclosed in a Form 8-K that SEC staff had notified the company that the agency’s investigation had concluded and that the staff did not intend to recommend an enforcement action. The company had previously disclosed that it had received SEC subpoenas in November 2024 and 2025 relating to, among other things, the company’s compliance with the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws and its operations in “certain foreign countries[.]” The company stated at that time that it was cooperating with SEC but did not identify a parallel DOJ investigation.
On May 21, 2026, Abraham Cigarroa Cervantes, a Mexican citizen and former CFO of Illinois-based international waste management company Stericycle, Inc.’s Latin America division and former financial director of Stericycle Mexico, pleaded guilty in the Southern District of Florida to one count of conspiring to violate the FCPA.[1] In his factual proffer, Cigarroa admitted to conspiring to pay, with the assistance of third party vendors, approximately $3.5 million in bribes to Mexican government officials to help secure government contracts for medical waste collection, obtain priority release of payments, overbill government customers, and avoid fines.[2] Cigarroa also admitted to knowing about additional bribery schemes in Argentina and Brazil. DOJ announced charges against Cigarroa in March 2024, and he was extradited to Miami from Argentina in April 2026. Cigarroa’s supervisor, Mauricio Gomez Baez, pleaded guilty in February 2024 to one count of conspiracy to violate the FCPA’s anti-bribery provisions. Stericycle resolved related allegations with DOJ and SEC in April 2022, agreeing to pay $84 million in penalties. Sentencing for Cigarroa is scheduled for July 10, 2026.
On May 18, 2026, DOJ announced that Alex Nain Saab Moran, Venezuela’s former Minister of Industry and National Production, had been charged “for his alleged role in a sprawling international money laundering conspiracy involving the corruption and exploitation of a Venezuelan public welfare program intended to provide food to vulnerable Venezuelans.” More specifically, DOJ alleged that Saab conspired to bribe Venezuelan public officials to secure contracts from the Comité Local de Abastecimiento y Producción (CLAP) to import food into Venezuela and then “siphon[ed] off” hundreds of millions of dollars, including through transfers to and through U.S. bank accounts. DOJ further alleged that Saab and his co-conspirators exploited their corrupt relationships with government officials to gain access to, and then sell, billions of dollars’ worth of oil owned by Venezuela’s national oil company, Petróleos de Venezuela, S.A. (PDVSA). Saab has had an interesting relationship with U.S. law enforcement. In July 2019, DOJ announced charges against Saab and another defendant in connection with a scheme to bribe Venezuelan officials to obtain U.S. dollars at a favorable exchange rate in connection with a government contract to build low-income housing. In October 2021, Saab was extradited from Cabo Verde to the United States to face those charges. In December 2023, however, the Biden administration announced that it was releasing Saab in exchange for the Venezuelan government’s agreement to return to the United States Leonard Glenn Francis, who had fled to Venezuela after pleading guilty to bribing U.S. naval officials. Soon after the U.S. government’s January 2026 capture of Venezuelan President Nicolas Maduro, Saab was arrested in Venezuela and later extradited to the United States. CLAP was also at the center of an FCPA enforcement action announced in October 2021.
On May 27, 2026, DOJ announced that it had obtained a forfeiture order for a luxury New York apartment—as well as related rental income—allegedly purchased with funds that had been misappropriated from Malaysian sovereign wealth fund 1Malaysia Development Berhad (1MDB). DOJ stated that the apartment had been purchased for the benefit of May Ling Catherine Tan, a personal assistant of Low Taek Jho, also known as Jho Low, one of several alleged conspirators who misappropriated more than $4.5 billion from 1MDB between 2009 and 2015. DOJ has alleged that the misappropriation was facilitated by bribes paid to 1MDB officials and other Malaysian government officials. DOJ has recovered and returned to Malaysia over $1.4 billion of funds misappropriated from 1MDB. (For more on the 1MDB investigation, see our July 2016, August 2016, June 2017, December 2017, May 2018, June 2018, August 2018, October 2018, February 2019, May 2019, April 2020, August 2021, September 2021, December 2021, February 2022, April 2022, March 2023, April 2023, December 2023, June 2024, January 2025, February 2025, May 2025, October 2025, and December 2025 Top 10s.)
On May 27, 2026, the World Bank announced an 18-month debarment with conditional release of China National Technical Import & Export Corporation (CNTIC), a Beijing-based Chinese state-owned enterprise. According to the World Bank, the sanction related to fraudulent practices in World Bank-financed projects in Pakistan, Bangladesh, and the Maldives designed to strengthen power transmission systems and energy capacity. The World Bank stated that CNTIC failed to disclose current contract commitments and pending or historical litigation in bids, failed to disclose commissions and fees to third parties, and misrepresented key personnel in connection with a Pakistan project. The World Bank characterized the conduct as fraudulent under its Anti-Corruption Framework. Under the settlement, CNTIC and controlled affiliates are ineligible to participate in World Bank Group-financed projects during the debarment period, and release from debarment is conditioned on implementing an integrity compliance program consistent with World Bank Group Integrity Compliance Guidelines and cooperating fully with the World Bank Group Integrity Vice Presidency. The World Bank also stated that the debarment qualifies for cross-debarment by other multilateral development banks under the 2010 Agreement for Mutual Enforcement of Debarment Decisions.
All parties to the OECD Anti-Bribery Convention are subject to a rigorous peer-review process, which has historically proceeded through four phases: Phase 1 assesses whether a member country’s legal and legislative texts meet the standards set by the Convention; Phase 2 assesses the structures in place to enforce the laws and the countries’ application of the Convention; Phase 3 assesses progress made on recommendations from Phase 2 and the evaluated country’s enforcement efforts; and Phase 4 focuses on the evaluated country’s enforcement efforts and considers the country’s particular challenges and positive achievements. Many countries have already progressed through Phase 4. From April 22 to May 25, 2026, the Working Group sought stakeholder input as it begins to design Phase 5 of its peer-review monitoring process. The Working Group invited input from the private sector, civil society, academia, non-governmental organizations, companies operating abroad, small and medium-sized enterprises, and the media. The consultation is significant because OECD Working Group monitoring has long been one of the principal mechanisms for evaluating whether countries are enforcing foreign bribery laws in practice, not merely adopting them on paper, and has been credited with driving foreign bribery enforcement efforts and legal reforms in many member countries. Through the consultation, the Working Group has signaled that it intends to continue to hold member countries to account for their commitments to fighting foreign bribery.
On May 8, 2026, the SFO announced that it had hosted an International Economic Crime Conference in London with France’s Parquet National Financier (PNF) and Switzerland’s Office of the Attorney General (OAG). According to the SFO, the two-day event brought together more than 100 prosecutors and investigators from multiple jurisdictions to address challenges in tackling international economic crime. Among other things, the conference covered case detection, corporate prosecutions, asset recovery, the growing role of cryptocurrency in financial crime, and the importance of international collaboration in addressing complex cross-border financial crime. The SFO, PNF, and Swiss OAG are founding members of the International Anti-Corruption Prosecutorial Taskforce, which was launched in March 2025, and the conference underscores their commitment to working together to combat foreign bribery and other cross-border crimes.
On May 25, 2026, the Finance Innovation Lab announced the results of a report analyzing the annual flow of “dirty money” through the UK. According to the report, at least £325 billion in “dirty money” flows through the UK each year, and the amount could rise to more than £788 billion if UK Crown Dependencies and Overseas Territories were included. The report described the estimate as covering money linked to financial crime, money laundering, corruption, illegal trade, and tax dodging, and stated that the UK-linked estimate amounts to more than 10% of UK GDP. The report acknowledged certain assumptions and limitations in data but concluded that it likely understated the true scale of the problem. The report also identified public concern over economic crime, with nearly nine in ten UK voters wanting the government to take economic crime seriously. The report’s recommendations included strengthening crypto regulation, increasing transparency in UK-linked tax havens and shell-company structures, and providing more resources to enforcement agencies, including the National Crime Agency and SFO.
[1] Minute Entry, United States v. Abraham Cigarroa Cervantes, Case No. 24-CR-20109-KMW, ECF No. 24 (S.D. Fla. May 21, 2026).
[2] Factual Proffer, United States v. Abraham Cigarroa Cervantes, Case No. 24-CR-20109-KMW, ECF No. 26 (S.D. Fla. May 21, 2026).