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: Why are Congress and a federal judge questioning the decision by the U.S. Department of Justice (DOJ) to dismiss a foreign bribery-related case? What are the enforcement priorities of the UK Serious Fraud Office (SFO)? How does Norway intend to reward cooperation in foreign bribery cases? The answers to these questions and more are here in our June 2026 Top 10.
In May 2026, DOJ moved to dismiss criminal charges, announced in November 2024, against several individuals, including Gautam and Sagar Adani, related to an alleged bribery scheme involving a large solar energy project in India. On June 26, 2026, Eastern District of New York Judge Nicholas G. Garaufis ordered DOJ to provide, by July 13, 2026, each reason why the government sought dismissal with prejudice of the charges, as well as sufficient factual support for those reasons.[1] The court stated that DOJ’s motion to dismiss was “terse, bland, and conclusory.” Given the low standard for dismissal, DOJ’s motion will likely be granted, but the judicial pushback is notable. The motion to dismiss also garnered congressional scrutiny. In a letter to the Acting Attorney General dated June 11, 2026, Senator Elizabeth Warren and other Senators requested information by June 25, 2026, about how the dismissal decision was made, including whether Gautam Adani, the Adani Group, or their representatives had made or discussed any offer to invest $10 billion in the United States if DOJ dropped the prosecution.
On June 5, 2026, Francisco Roberto Cosenza Centeno, the former executive director of the Comité Técnico del Fideicomiso para la Administración del Fondo de Protección y Seguridad Poblacional, a Honduran governmental entity that procured goods for the Honduran National Police, was sentenced in the Southern District of Florida to five years’ probation with home confinement and ordered to forfeit two luxury watches following his August 2025 guilty plea to one count of money laundering in violation of 18 U.S.C. § 1957. Cosenza admitted that he agreed to share approximately $248,000 in bribes tied to contracts worth approximately $10 million and that the proceeds of the bribery scheme were wired through bank accounts in the United States and elsewhere. Carl Alan Zaglin, former CEO of a Georgia-based manufacturer of law enforcement uniforms and accessories, Atlanco LLC, was convicted by a jury on related charges in September 2025 and sentenced to eight years’ imprisonment in December 2025. Another defendant, Aldo Nestor Marchena, who pleaded guilty in June 2025, was sentenced to seven years’ imprisonment in November 2025, while another alleged bribe recipient, Juan Ramon Molina pleaded guilty in December 2024 and is awaiting sentencing.
On June 23, 2026, DOJ posted a hiring notice seeking trial attorneys for the Criminal Division’s Fraud Section, including for the Foreign Corrupt Practices Act (FCPA) Unit. The posting listed a July 17, 2026, application deadline. In addition to several enforcement actions covered in the Top 10, the hiring notice is further evidence that the FCPA Unit is open for business following the February 2025 FCPA pause order and the June 2025 release of new FCPA enforcement guidance.
On June 15, 2026, the U.S. Court of Appeals for the Seventh Circuit vacated the May 2023 conspiracy and FCPA books-and-records convictions of former Commonwealth Edison (“ComEd”) CEO Anne Pramaggiore and former ComEd lobbyist Michael McClain, while allowing DOJ to retry them. DOJ alleged that the defendants falsified books, records, and accounts related to a contract between ComEd and a third-party consultant used to pay bribes to the former Speaker of the Illinois House of Representatives. Because both ComEd and its parent company were issuers, the indictment alleged that these acts violated the FCPA’s books-and-records provision, which prohibits the knowing falsification of any book, record, or account required to be maintained by an issuer. The court vacated the FCPA convictions because the jury could have relied on a theory that was no longer valid under the U.S. Supreme Court’s June 2024 decision in Snyder v. United States, which held that a significant federal bribery statute, 18 U.S.C. § 666, applies only to quid pro quo bribery schemes and not to gratuities. But the court rejected defendants’ argument that the allegedly falsified records related to the alleged scheme were merely misleading rather than false, holding that the government may retry the conspiracy and FCPA counts without the invalid theories. As we have previously observed, the ComEd case is an important reminder that the FCPA’s accounting provisions apply outside of the foreign bribery context, and this opinion will be important for interpreting those provisions. (For more on the ComEd/Madigan matter, see our May 2023, September 2023, February 2025, May 2025, and April 2026 Top 10s and our article on the application of FCPA accounting provisions outside of the foreign bribery context.)
On June 4, 2026, a unanimous U.S. Supreme Court held in Sripetch v. SEC that a showing of pecuniary loss to investors is not required before the U.S. Securities and Exchange Commission (SEC) may obtain disgorgement. The defendant in Sripetch consented to an entry of judgment against him on six counts of securities fraud and one count of selling unregistered securities in connection with several penny-stock schemes but objected to SEC’s request for over $4.1 million in disgorgement, arguing the absence of evidence of investor loss. The Supreme Court rejected the argument that its June 2020 decision in Liu v. SEC required SEC to prove that victims suffered pecuniary loss before disgorgement could be awarded. According to the Court, even if a defendant does not leave a plaintiff worse off financially, traditional equitable principles prefer that the defendant be restored to his prior position by stripping him of his unjust gains, rather than allowing him to benefit from his misconduct. Although Sripetch is not an FCPA case, it is relevant because SEC frequently seeks disgorgement in FCPA cases. But given that FCPA cases typically involve harm to society at large rather than identifiable victims, Sripetch’s potential application to a contested FCPA case is unclear.
On June 17, 2026, a London jury acquitted former Nigerian petroleum minister and former OPEC president Diezani Alison-Madueke of bribery charges following a trial at Southwark Crown Court that began in January 2026. The UK National Crime Agency (NCA) announced in August 2023 that Alison-Madueke had been charged with five counts of accepting bribes and one count of conspiracy to commit bribery. According to the NCA, Alison-Madueke received at least £100,000 in cash, along with “financial or other advantages,” including private jet flights, chauffeur-driven cars, the use and refurbishment of London properties, luxury goods, and school fees for her son, in exchange for the awarding of multimillion-pound oil and gas contracts during her time in office. During the trial, Alison-Madueke denied soliciting or receiving bribes, characterizing herself as a strict enforcer of rules who was nicknamed “Madam Due Process.” She also testified that Nigerian ministers were barred from holding foreign bank accounts while serving overseas, forcing her to rely on wealthy associates to cover her living expenses, which were paid back in Nigeria. The jury also acquitted Alison-Madueke’s co-defendants.
In a June 3, 2026 speech, Serious Fraud Office (SFO) Director Graham McNulty identified three priorities for the SFO: working with responsible corporates, becoming a more active enforcer, and serving as a leading player in the international justice system. The speech highlighted the SFO’s April 2025 revised corporate-cooperation guidance, the May 2026 Ultra Electronics deferred prosecution agreement (DPA), and plans to strengthen intelligence capabilities, increase the use of surveillance, and incentivize whistleblowers. McNulty expressly warned that “not self-reporting is a gamble and the odds are getting worse,” while describing the SFO’s effort to build a proactive pipeline of work less dependent on corporate referrals. McNulty also highlighted the new failure to prevent fraud offense and the new “senior manager” attribution test under the Economic Crime and Corporate Transparency Act 2023 (ECCTA) and the Crime and Policing Act 2026 (CPA) as tools that expand the SFO’s ability to pursue corporate misconduct with a UK nexus.
On June 24, 2026, the UK Cabinet Office updated its Procurement Act 2023 Guidance: Debarment and published a June 2026 National Security Debarment Protocol Summary. The new materials provide further details on how debarment investigations are triaged and conducted, and how the Debarment Review Service and National Security Unit for Procurement assess whether suppliers should be added to the public debarment list. The debarment regime, which took effect on February 24, 2025, allows a Minister of the Crown to place suppliers on a published debarment list following an investigation. Suppliers can be listed as “must” or “may” exclude depending on whether the relevant exclusion ground is mandatory or discretionary. Contracting authorities must check the list in covered procurements. The regime has significant anti-corruption implications because bribery- and corruption-related exclusion grounds can affect access to UK public contracts. A conviction for core bribery offenses under the UK Bribery Act 2010 (UKBA), including bribing another person, being bribed, and bribing a foreign public official, falls within the mandatory exclusion grounds, meaning an affected supplier is generally an “excluded supplier” if the circumstances giving rise to the exclusion ground are continuing or likely to recur. By contrast, a conviction for the corporate failure to prevent bribery offense is not listed as a mandatory exclusion ground but may be captured under the discretionary professional misconduct ground, which covers serious misconduct calling into question the supplier’s integrity or honesty. Where a supplier is listed for a discretionary ground, contracting authorities retain discretion and may still allow the supplier to bid or be awarded a contract following appropriate review and due diligence.
On June 12, 2026, Økokrim, Norway’s National Authority for Investigation and Prosecution of Economic and Environmental Crime, announced that new guidelines for determining corporate penalties in international corruption cases had entered into force. According to Økokrim, the guidelines are intended to increase self-reporting from the business sector and to provide predictability on the size of corporate fines in international corruption cases covered by the OECD Anti-Bribery Convention. Økokrim stated that the guidelines address factors that may lead to reduction of a corporate penalty, including self-reporting, documented preventive work, and contributions to clarify the case. Økokrim also stated that the guidelines were developed after a process involving the business sector and are aimed primarily at the largest Norwegian companies with international operations. The guidelines are significant because they appear designed to make Norway’s corporate foreign-bribery enforcement framework more predictable and to encourage voluntary disclosures and cooperation.
On June 24, 2026, Transparency International published Connecting the Dots: How Financial Intelligence Units Expose Corrupt Money Flows and How They Could Do More, along with an accompanying feature article. The report examines how financial intelligence units (FIUs) function in practice in relation to corruption and corruption-related money laundering across 20 countries. Transparency International stated that FIUs can help expose major corruption schemes, trigger investigations, and recover stolen public funds, but that their effectiveness depends on access to information, institutional independence, resources, and follow-through by law enforcement and prosecutors. The feature article identified several gaps. Transparency International stated that many FIUs lack direct access to key information, including beneficial ownership, tax, and law-enforcement data; that reporting gaps can leave FIUs without important warning signs when corrupt money moves through companies, property transactions, or professional services; and that financial intelligence proactively shared by FIUs is too often not acted on. The report recommends strengthening FIU access to information and preventive powers, making financial intelligence more operational and actionable, improving cooperation and accountability, and protecting FIUs from political and institutional pressure.
[1] Memorandum & Order, United States v. Gautam Adani, et al., Case No. 1:24-cr-00433-NGG, ECF No. 36 (E.D.N.Y. June 26, 2026).