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 individuals are facing Foreign Corrupt Practices Act (FCPA) charges in the United States? How did Australian and Brazilian authorities resolve long-running foreign-bribery investigations? What new incentives for reporting suspected bribery are being considered in the UK? The answers to these questions and more are here in our October 2026 Top 10.
On October 30, 2026, the U.S. Department of Justice (DOJ) announced that former BizJet International Sales and Support sales manager Jald Jensen had pleaded guilty in the Northern District of Oklahoma to conspiring to violate the FCPA by bribing foreign officials to obtain aircraft-maintenance, repair, and overhaul business in Latin America. At the time of the press release, the sentencing hearing had not yet been scheduled. In March 2012, BizJet entered into a three-year deferred prosecution agreement (DPA) under which it agreed to pay an $11.8 million criminal penalty. In April 2013, DOJ announced charges against four former BizJet executives—two pleaded guilty in January 2012, one was arrested in Amsterdam and pleaded guilty in July 2014, and Jensen, the last to resolve his case, was located and arrested by Interpol and Panama’s National Border Service in May 2026 and transferred to U.S. custody in September 2026.
On October 11, 2026, DOJ announced that Colombian national Alvaro Pulido Vargas (also known as German Enrique Rubio Salas) had been brought to the United States to face charges arising from alleged Venezuelan public-contract bribery and money-laundering schemes. Pulido Vargas was the subject of two indictments in the Southern District of Florida—one in July 2019 related to allegations that he conspired to launder the proceeds of a bribery scheme involving a contract with the Venezuelan government to build low-income housing, and the other in October 2021 related to allegations that he conspired to launder the proceeds of a bribery scheme involving contracts with a Venezuelan state‑owned and state-controlled food and medicine program. Pulido Vargas had been detained in Venezuela since April 2023 in connection with a domestic corruption investigation and was transferred to U.S. custody by October 2026. In September 2026, alleged co-conspirator Alex Saab pleaded guilty to money-laundering charges arising from the Venezuelan food-and-medicine scheme.
On October 13, 2026, Eastern District of New York Judge Diane Gujarati denied Asante Kwaku Berko’s post-trial motions for a judgment of acquittal or for a new trial,[1] following his August 2026 conviction 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. Berko challenged the sufficiency of the evidence of an agreement to pay bribes, corrupt intent, a money-laundering conspiracy, and venue in the Eastern District of New York. The court held that the trial evidence, including Berko’s recorded statements, emails with alleged co-conspirators and bank colleagues, witness testimony, and bank records, permitted a rational jury to find each element of the three offenses beyond a reasonable doubt and established venue. The court also concluded that allowing the verdict to stand would not constitute a manifest injustice warranting a new trial.
On October 21, 2026, Charles Finkel, a former executive of a Brazilian subsidiary of a Swiss security‑printing company, pleaded guilty in the Southern District of New York to a one-count criminal information charging him with conspiracy to violate the FCPA in connection with an alleged scheme to bribe Brazilian officials to obtain and retain government contracts for the company’s Brazilian subsidiary.[2] According to the information and a previously sealed October 2022 criminal complaint,[3] Finkel participated in a scheme to pay more than $14 million in bribes to a senior official of Brazil’s Federal Revenue Service (RFB), through more than 70 payments routed through a Finkel-owned consulting company to a consulting company owned by the RFB official’s wife. The RFB official allegedly assisted the subsidiary in obtaining and retaining contracts with Casa da Moeda do Brasil (CMB), Brazil’s state-owned mint, including a five-year contract worth approximately $1.4 billion, awarded without competitive bidding in 2008, to implement a beverage-tracking system for tax collection. CMB extended the subsidiary’s services through 2016 without competitive bidding. During a separate procurement in 2014–15, the RFB official allegedly provided confidential information concerning a competing bidder and helped manipulate technical testing requirements to favor the subsidiary. Finkel, the RFB official, and the RFB official’s wife were convicted of bribery‑related offenses in Brazil in May 2019, but those convictions were overturned on appeal in June 2022. Sentencing in this matter is scheduled for February 2027.
On October 26, 2026, Brazil’s Office of the Comptroller General (CGU) announced that it and the Office of the Attorney General (AGU) had signed a leniency agreement with Koenig & Bauer Banknote Solutions SA (KBBS), a Swiss security-printing technology company, resolving allegations that the company obtained contracts with CMB through improper payments to public officials between 2008 and 2011. Under the agreement, the company agreed to pay approximately R$69.2 million, implement compliance enhancements, and continue to cooperate with related investigations. The CGU credited the company’s cooperation and said the company had previously disclosed and resolved related conduct with Swiss authorities in 2017. The company stated that it intends to seek a partial refund of payments made under the Swiss resolution, as the payment made to Brazil should be credited against the disgorgement payments in Switzerland.
On October 2, 2026, the Australian Federal Police (AFP) announced that SMEC International Pty Ltd had agreed to resolve foreign-bribery allegations involving Sri Lanka, Vietnam, and other jurisdictions. Under the agreement, the company agreed to pay A$9 million but was not required to admit liability, and the AFP did not refer the matter to the Commonwealth Director of Public Prosecutions. In explaining the outcome, the AFP cited the company’s cooperation, voluntary production of evidence, self-reporting of additional conduct uncovered through internal investigations, waiver of privilege over certain materials, enhanced compliance procedures, departure of individuals allegedly involved, and the age of the conduct. The AFP said the outcome was consistent with its guidance on optimal investigation outcomes for self-reporting and cooperating corporations. SMEC and several subsidiaries were separately sanctioned by the World Bank in September 2017 related to projects in India and Sri Lanka.
On October 12, 2026, the UK government opened a public consultation on reforms to its whistleblower protection framework and the creation of a financial-reward program for individuals who report economic crime to the Serious Fraud Office (SFO), including bribery and corruption. The proposed program would represent a significant departure from the UK’s traditional approach, which has generally emphasized protection against retaliation rather than financial incentives for whistleblowers. The consultation seeks views on the structure of the program, eligibility requirements, award calculations, and potential penalties for false whistleblower reports. The proposal follows the development of financial whistleblower incentives in other jurisdictions, particularly the United States, where the Securities and Exchange Commission (SEC) has operated a whistleblower reward program since 2011 and DOJ launched its Corporate Whistleblower Awards Pilot Program in August 2024. The SFO has been considering financial incentives for whistleblowers since at least February 2024.
On October 13, 2026, the SFO announced revisions to its corporate cooperation guidance, introducing a new mechanism for companies considering voluntary disclosure of suspected fraud, bribery, or corruption to communicate directly with the SFO’s Director of Legal Services and General Counsel before making a formal self-report. Under the revised guidance, companies’ legal representatives may request a preliminary meeting, potentially without initially identifying the company, to discuss a possible disclosure and whether the SFO is the appropriate enforcement authority to receive it. According to the SFO, this new option is intended to facilitate “a swifter, clearer path to enter negotiations for a deferred prosecution agreement[.]” The SFO first issued its corporate cooperation guidance in April 2025.
On October 21, 2026, the World Bank announced sanctions arising from misconduct in Tanzanian urban transport projects. Aqgola Engineering & Management Services Limited (AQGOLA) and its managing director, Aquiline Joseph Massawe, received 52-month conditional debarments after admitting corrupt and fraudulent practices, including offers of improper payments to project officials, connected to the Southern Africa Trade and Transport Facilitation Project (SATTFP) and the Dar es Salaam Urban Transport Improvement Project (DUTP). In a related action, AQGOLA’s co-owner, Godfrey William Mashauri, received a 28-month conditional debarment for fraudulent and corrupt practices involving undisclosed conflicts of interest and acceptance of gifts from a consulting firm that he supervised. Mashauri allegedly served as a DUTP and SATTFP procurement specialist under a Bank‑financed consulting contract without disclosing his ownership interest in AQGOLA. The settlements provide for cooperation credit and integrity compliance requirements, and the sanctions are eligible for cross-debarment by other multilateral development banks.
On October 27, 2026, the Organization for Economic Co-operation and Development (OECD) published its report, “The Next Decade of Action for Public Integrity in Latin America and the Caribbean,” assessing progress in public integrity and anti-corruption reforms across the region over the past decade. The report finds that, although countries have established increasingly robust legal and institutional frameworks, significant gaps remain between regulatory requirements and implementation. According to the OECD’s Public Integrity Indicators, those gaps were larger in Latin American and Caribbean countries than in OECD countries outside the region. The OECD identified six priority areas where stronger implementation, institutional capacity, and sustained political commitment are needed to translate reforms into tangible results, strengthen public trust, and deliver greater impact for citizens. These areas include addressing undue influence in public decision-making, identifying and managing integrity risks, and combating impunity through more transparent and effective enforcement mechanisms.
[1]Memorandum & Order, United States v. Asante Kwaku Berko, Case No. 1:20-cr-00328-DG, ECF No. 135 (E.D.N.Y. Oct. 13, 2026).
[2]Information, United States v. Finkel, Case No. 26-cr-00493-JMF, ECF No. 92 (S.D.N.Y. Oct. 21, 2026).
[3]Complaint, United States v. Finkel, Case No. 22-mj-08103, ECF No. 2 (S.D.N.Y. Oct. 6, 2022).