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 development in the effort by the U.S. Department of Justice (DOJ) to dismiss Foreign Corrupt Practices Act (FCPA) and other charges related to an alleged India bribery scheme? Why is Australia opening a public consultation regarding its foreign bribery law? What could China’s proposed cross-border anti‑corruption law mean for companies operating internationally? The answers to these questions and more are here in our August 2026 Top 10.
As discussed in our June 2026 and July 2026 Top 10s, DOJ moved in May 2026 to dismiss charges against Gautam Adani, Sagar Adani, and others arising from an alleged bribery scheme involving a solar energy project in India, prompting the district court to require additional explanation. On August 10, 2026, Eastern District of New York Judge Nicholas G. Garaufis dismissed with prejudice the fraud-related charges against the Adani defendants who had appeared in the case but ordered further briefing on DOJ’s request to dismiss FCPA and obstruction charges against other defendants who had not appeared. Among other things, the court rejected DOJ’s contention that the FCPA charges do not satisfy any of the four factors for prosecution set out in the June 2025 FCPA Guidelines; the court concluded that, although the indictment’s allegations do not implicate cartels or Transnational Criminal Organizations (TCOs) (factor 1), the allegations suggest an impact on U.S. companies and U.S. national security interests (factors 2 and 3) and describe conduct that bears strong indicia of corrupt intent tied to particular individuals, such as substantial bribe payments and sophisticated efforts to conceal them (factor 4). The court also noted that DOJ had waited to file its motion to dismiss until after the 180-day period for reviewing existing FCPA cases set out in the February 2025 Executive Order pausing FCPA enforcement. The court directed DOJ to provide each reason, supported by facts, for dismissing the remaining counts and directed defense counsel for the non-appearing defendants to confirm their clients’ consent to dismissal.
On August 6, 2026, DOJ announced that a federal jury in the Eastern District of New York had convicted Asante Kwaku Berko on FCPA and money laundering charges arising from an alleged scheme to bribe Ghanaian officials to help his client, a Turkish energy company, win a bid to build and operate a power plant. According to DOJ, Berko paid more than $1 million in bribes to Ghanaian government officials and concealed the payments from his employer’s compliance personnel through lies, personal email accounts, shell companies, sham invoices, nominee bank accounts, and cash withdrawals. Payments in furtherance of the bribery scheme were allegedly laundered through U.S. and foreign bank accounts. DOJ stated that Berko’s employer, an investment bank, ultimately withdrew from the transaction because of corruption concerns. Berko was convicted of one count of conspiracy to violate the FCPA, substantive FCPA violations, and one count of conspiracy to commit money laundering and faces up to 30 years’ imprisonment. Sentencing is scheduled for November 2026. Berko was arrested in London in November 2022 on charges that had been brought in a sealed indictment filed in the Eastern District of New York in August 2020. In July 2024, DOJ announced that Berko had been extradited from the UK to the United States to stand trial. In December 2025, the court rejected Berko’s attempt to dismiss the charges against him on speedy trial grounds. In June 2021, Berko resolved related allegations with the U.S. Securities and Exchange Commission (SEC), agreeing to pay approximately $329,000 without admitting or denying the SEC’s charges.
On August 24, 2026, the U.S. District Court for the District of Connecticut granted[1] DOJ’s unopposed motion to dismiss with prejudice[2] the criminal information against Freepoint Commodities LLC, terminating its three-year deferred prosecution agreement (DPA) approximately four months before its scheduled expiration. Freepoint entered into the DPA in December 2023 to resolve allegations that it conspired to pay bribes to officials at Brazil’s state-owned oil company, Petrobras, in violation of the FCPA. The Commodity Futures Trading Commission (CFTC) announced a parallel resolution the same day. In seeking early dismissal, DOJ stated that Freepoint had fully met its obligations under the DPA, including cooperation, self-reporting, enhanced compliance measures, payment of a $68 million criminal penalty, and forfeiture of approximately $30.6 million. DOJ also stated that Freepoint would continue to cooperate in investigations and prosecutions arising from the conduct.
On August 27, 2026, Hugo Jinkis and Mariano Jinkis, the father-and-son owners of Argentine sports marketing company Full Play Group S.A., entered into one-year DPAs, filed in the Eastern District of New York, resolving charges arising from the long-running corruption investigation involving Fédération Internationale de Football Association (FIFA) and affiliated continental and regional soccer confederations. The Jinkises admitted paying tens of millions of dollars in commercial bribes to soccer executives in exchange for support in obtaining media and marketing rights to soccer tournaments, including World Cup qualifiers and Copa América. They agreed to forfeit $50 million. In December 2025, DOJ moved to dismiss with prejudice charges against Full Play, which had been convicted in March 2023 by a federal jury on related wire fraud and money laundering charges.
In August 2026, DOJ renamed the Criminal Division’s Fraud Section the White Collar and Corporate Enforcement Section following the creation of a separate National Fraud Enforcement Division focused primarily on fraud involving federal programs and the public fisc. The original Fraud Section, established in 1955 following DOJ’s efforts to combat large-scale housing and procurement fraud in the wake of World War II and designed to bring focused expertise to the most complex and consequential frauds threatening the United States, held that name for 71 years. Importantly for international anti-corruption enforcement, the FCPA Unit remained in the legacy Fraud Section rather than moving to the new National Fraud Enforcement Division. DOJ’s updated FCPA Unit webpage continues to identify the FCPA Unit as responsible for FCPA matters and for receiving reports of potential violations of the Foreign Extortion Prevention Act (FEPA). The FCPA section of the Justice Manual has not, as of the release date of this Top 10, been updated to reflect the name change. (On August 13, 2026, the Assistant Attorney General (AAG) for the National Fraud Enforcement Division announced the release of a memo regarding the new Division’s enforcement priorities, which include, among other things, bribery in connection with domestic government procurement.)
On August 11, 2026, the U.S. Department of the Treasury announced a final rule that permanently removes Corporate Transparency Act beneficial ownership information (BOI) reporting requirements for U.S. companies and U.S. persons. The rule, effective August 14, 2026, makes permanent exemptions first introduced through an interim final rule in March 2025. The Treasury Department stated that FinCEN will delete BOI previously reported by U.S. persons. Under FinCEN’s updated guidance, only certain foreign entities registered to do business in the United States remain subject to BOI reporting, and those entities generally are not required to report BOI for U.S. beneficial owners. The Corporate Transparency Act was included in the National Defense Authorization Act for Fiscal Year 2021, passed in December 2020 under the first Trump administration, in response to the “sense of Congress” that “malign actors seek to conceal their ownership” of certain corporations, limited liability companies, and similar entities formed under state law to facilitate foreign corruption, money laundering, and other illicit activities.
On August 7, 2026, Australia’s Attorney-General’s Department opened consultation on the statutory review of the Combatting Foreign Bribery Act 2024. The February 2024 legislation amended Australia’s foreign bribery offense and introduced a corporate offense for failing to prevent foreign bribery, subject to an adequate procedures defense, which went into effect in September 2024. The review will consider, among other things, whether the reforms are deterring foreign bribery, improving enforcement outcomes, and influencing corporate compliance practices. The public consultation closes September 10, 2026. During an August 19, 2026, speech, Organization for Economic Cooperation and Development (OECD) Secretary-General Mathias Cormann stated that Australia historically struggled with foreign bribery enforcement but that seven individuals and three companies have now been criminally sanctioned for foreign bribery, with three additional companies sanctioned through administrative or civil proceedings.
On August 3, 2026, the African Development Bank’s Office of Integrity and Anti-Corruption (PIAC) published its 2025 annual report describing its work to prevent, detect, and investigate fraud, corruption, and staff misconduct in Bank-financed activities and within the Bank. The report highlights PIAC’s increasing focus on preventive integrity measures, including integrity due diligence on Bank counterparties, proactive integrity reviews designed to identify vulnerabilities in Bank-financed projects, and compliance monitoring of sanctioned entities. In 2025, PIAC also entered into three negotiated settlements involving three companies and two individuals; each company was required to implement an integrity compliance program as a condition of the settlement.
On August 2, 2026, Hungary officially became the 25th European Unition (EU) Member State participating in the European Public Prosecutor’s Office (EPPO). EPPO is the independent EU prosecution office responsible for investigating and prosecuting crimes affecting the EU’s financial interests, including fraud, corruption, and related money laundering. According to EPPO, operations in Hungary will begin after the appointment of the European Prosecutor for Hungary and the required European Delegated Prosecutors. Hungary’s participation will expand EPPO’s geographic reach and give the office authority to pursue qualifying corruption and fraud matters affecting EU funds in Hungary. EPPO has played a role in foreign bribery enforcement (see, for example, our October 2025 Top 10).
On August 25, 2026, a draft Anti-Cross-Border Corruption Law was submitted for first reading to the Standing Committee of China’s National People’s Congress. According to official descriptions, the draft contains six chapters and 47 articles addressing the law’s scope and principles, mechanisms for handling cross-border corruption cases, international cooperation, and institutional responsibilities and would clarify the obligations of enterprises concerning integrity and compliance and establish legal liability for violations. The legislation is reportedly intended in part to strengthen the regulation of cross-border business activity and encourage Chinese companies operating overseas to conduct business lawfully and compliantly. Public consultation on the new law will run through September 26, 2026.
[1] Order, United States v. Freepoint Commodities LLC, Case No. 3:23-cr-00224-KAD-1, ECF No. 19 (D. Conn. Aug. 24, 2026).
[2] Unopposed Motion to Dismiss Information, United States v. Freepoint Commodities LLC, Case No. 3:23-cr-00224-KAD-1, ECF No. 18 (D. Conn. Aug. 24, 2026).