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: What is the latest turn in the Adani case? Why did French authorities decide for the first time to sanction a company and its president for compliance failures? Why did the OECD Working Group on Bribery take the “exceptional step” of warning that Turkish companies might need to undergo enhanced anti-corruption due diligence? The answers to these questions and more are here in our July 2026 Top 10.
In June 2026, Eastern District of New York Judge Nicholas G. Garaufis ordered DOJ to provide reasons and factual support for its May 2026 motion to dismiss with prejudice criminal charges against Gautam Adani, Sagar Adani, and others related to an alleged $250 million bribery scheme involving a large solar energy project in India. The Adanis were charged with securities- and wire fraud-related violations, while other defendants were charged with FCPA anti-bribery violations and obstruction of justice, in an indictment unsealed in November 2024. On July 4, 2026, DOJ responded to Judge Garaufis’s order, arguing that the case should not have been charged, that the securities charges were not viable, and that the FCPA charges no longer aligned with DOJ enforcement priorities reflected in the June 2025 FCPA enforcement guidelines. DOJ also denied that the dismissal request was tied to any commitment by the Adanis to invest in the United States. Notably, the DOJ submission was signed by the Principal Associate Deputy Attorney General, not by attorneys from either of the DOJ offices that had brought the charges. Following the DOJ filing, Judge Garaufis ordered Gautam Adani to file an affidavit regarding the investment issue. On July 15, 2026, Gautam Adani filed an affidavit denying any promise, agreement, or deal connected to DOJ’s motion to dismiss, while stating that his counsel had suggested that the Adani Group’s previously announced $10 billion U.S. investment plan could potentially form part of a resolution with DOJ and the Securities and Exchange Commission (SEC), which had brought related charges, and that DOJ later informed counsel that the investment would not be considered in deciding whether to seek a dismissal.
On July 10, 2026, Abraham Cigarroa Cervantes, a Mexican citizen, former CFO of Illinois-based international waste management company Stericycle, Inc.’s Latin America division, and former financial director of Stericycle Mexico, was sentenced in the Southern District of Florida to time served, three years’ supervised release, and a $225,000 fine. Cigarroa pleaded guilty in May 2026, admitting that he conspired with third-party vendors to bribe Mexican officials to secure government contracts for medical waste collection and other benefits and that he knew 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.
On July 17, 2026, DOJ announced that The Scoular Company had agreed to enter into a three-year deferred prosecution agreement (DPA) in the Western District of Texas and to pay a penalty of approximately $9.8 million and forfeiture of approximately $414,000 to resolve allegations that it conspired with customs brokers, in violation of the FCPA, to make payments to Mexican officials to ensure successful shipment of certain commodities into Mexico between 2013 and 2019. One of the customs brokers involved in the alleged scheme, Carlos Leopoldo Alvelais Alarcón, pleaded guilty in the Western District of Texas in October 2025 to related charges and was sentenced on July 20, 2026 to 18 months’ imprisonment, three years of supervised release, and a $250,000 fine.
On July 23, 2026, a federal judge in the Eastern District of New York granted DOJ’s motion to dismiss charges against Credit Suisse Group AG[1] related to an alleged conspiracy to steal approximately $200 million from a total of $2 billion in loans issued to state-controlled companies in Mozambique between 2012 and 2016 for three maritime projects, including one related to tuna fishing. According to DOJ’s motion, the bank had met its obligations under the DPA. In February 2025, UBS Group, which acquired Credit Suisse Group AG in 2023, disclosed in a securities filing that the original three-year term of the DPA had been extended for one year. In December 2025, a federal judge vacated or reduced restitution orders for three former bank executives in a related case.
On July 23, 2026, the U.S. Congressional Research Service published an update on sanctions imposed under the Global Magnitsky Human Rights Accountability Act. Enacted in December 2016 and permanently reauthorized in April 2022, the Act, named after the late Russian anti-corruption advocate Sergei Magnitsky, authorizes the President to impose economic sanctions and deny entry into the United States to foreign persons identified as engaging in human rights violations or corruption. Covered corruption includes expropriation, corruption in government contracts or natural resource extraction, bribery, and offshore sheltering of corruption proceeds. As of the date of the report, 257 individuals and 326 entities from more than 50 countries were publicly designated for sanction under a related Executive Order. However, only seven individuals and entities were newly designated in 2025, down from 70 individuals and entities in 2024.
On July 9, 2026, the Sanctions Commission of the Agence Française Anticorruption (AFA) announced that it had, for the first time, imposed monetary sanctions on a company and its legal representative for breaches of Article 17 of the Sapin II law. Article 17 requires companies with at least 500 employees and a turnover exceeding €100 million to implement a robust, risk-based anti-corruption compliance program. This mandate also applies to corporate leadership. In its decision imposing a €350,000 sanction on “company V.” and a €60,000 sanction on its legal representative, “M.S.,” the Commission found seven of eight Article 17 obligations unmet, including risk mapping, code of conduct, disciplinary regime, third-party evaluation, accounting controls, training, and internal control/evaluation. The Commission held that AFA could seek monetary sanctions directly without first seeking an injunction, rejected the argument that subsequent remediation eliminated the basis for sanctions, and ordered anonymized publication due to the company’s sector sensitivity.
On July 7, 2026, the OECD Working Group on Bribery announced the results of its Phase 4 evaluation of Latvia’s implementation of the OECD Anti-Bribery Convention. 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. According to the Working Group, Latvia has made substantial progress in strengthening its foreign bribery framework and enforcement, including by sanctioning two companies for foreign bribery and starting trial proceedings against two other companies, enhancing prosecutorial and judicial specialization in economic and corruption crimes, strengthening the foreign bribery offense, increasing monetary sanctions, broadening whistleblower protections, and improving its anti-money laundering system. The Working Group nevertheless recommended additional measures, including strengthening Latvia’s detection strategy, encouraging companies to detect and report foreign bribery, applying whistleblower protections effectively, ensuring that the foreign bribery offense is not interpreted too narrowly, confiscating foreign bribery proceeds where appropriate, and ensuring sufficient resources for enforcement. Latvia must report to the Working Group on its progress in June 2028.
On July 7, 2026, the OECD Working Group on Bribery announced the results of its Phase 4 evaluation of the Slovak Republic’s implementation of the OECD Anti-Bribery Convention. The Working Group acknowledged the Slovak Republic’s adoption of a whistleblower protection framework but expressed concern at the country’s recent attempt to dismantle the Whistleblower Protection Office (WPO) and found that recent institutional reorganizations and legislative amendments have created challenges to the country’s ability to investigate and prosecute foreign bribery. The Working Group recommended that the Slovak Republic clarify key elements of the foreign bribery offense, provide training and guidance on proceeds, seizure, and confiscation, ensure immediate notification to prosecutors when credible foreign bribery allegations arise, and remove exemptions in whistleblower protections. The Slovak Republic must report back to the Working Group orally in June 2027 on seven high-priority recommendations and in writing in June 2028 regarding its implementation of all recommendations.
On July 7, 2026, the OECD Working Group on Bribery published the results of its evaluation of Luxembourg’s implementation of the recommendations set out in its March 2024 Phase 4 evaluation of Luxembourg’s implementation of the OECD Anti-Bribery Convention. The Working Group concluded that Luxembourg had fully implemented 10 recommendations, partially implemented 22, and not implemented 14 recommendations. The Working Group recognized positive developments, including a revised circular calling on prosecutors to prioritize foreign bribery, new investigative powers, additional resources, and awareness efforts linked to whistleblower protection. At the same time, the Working Group found that implementation remained insufficient in several areas, including whistleblower protection, successor liability, jurisdiction over legal persons, and access to financial information. The Working Group noted that Luxembourg cited the adoption of the European Union (EU) Anti-Corruption Directive as a reason for some of the delays in implementation. (See our April 2026 Top 10 and client alert for more on the EU Directive.) The Working Group also noted that foreign bribery enforcement remains limited, with no new convictions since the Phase 4 report. Luxembourg must report back to the Working Group in 2028 on implementation of its recommendations.
On July 9, 2026, the OECD Working Group on Bribery announced the results of its evaluation of Türkiye’s implementation of the recommendations set out in its June 2024 Phase 4 evaluation of Türkiye’s implementation of the OECD Anti-Bribery Convention. The Working Group identified major concerns regarding deficiencies in corporate liability, the inability to fine individuals for foreign bribery, ineffective detection of foreign bribery allegations, a lack of whistleblower protections, and the absence of meaningful efforts to investigate or prosecute foreign bribery allegations. As a result of this negative evaluation, the Working Group took the “exceptional step” of warning that Türkiye’s failure to implement key aspects of the OECD Anti-Bribery Convention may necessitate increased due diligence over Turkish companies by their commercial partners, multilateral development banks, Working Group member countries, and other jurisdictions. The warning will remain in effect until the Working Group determines that Türkiye has adequately addressed the identified issues.
[1] Motion to Dismiss, United States v. Credit Suisse Group AG, Case No. 1:21-cr-00521-DG, ECF No. 20 (E.D.N.Y. July 17, 2026).