Top 10 International Anti-Corruption Developments for August 2025

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter highlights some of the most significant international anti-corruption law and enforcement developments from the past month, with links to primary resources. This month we ask: What were the first two Foreign Corrupt Practices Act (FCPA) enforcement actions under the second Trump administration? What foreign bribery enforcement action was brought in the United Kingdom (UK)? In what ways was Switzerland a focus of foreign bribery developments in August? The answers to these questions and more are here in our August 2025 Top 10.

1. DOJ Announces First FCPA Declination with Disgorgement of Trump’s Second Term

On August 7, 2025, the U.S. Department of Justice (DOJ) issued a declination letter stating that it would not prosecute U.S.-based Liberty Mutual Insurance Company for violating the FCPA, despite evidence that employees of its Indian subsidiary, Liberty General Insurance, paid $1.47 million in bribes to officials at six state-owned banks in India between 2017 and 2022. According to the letter, in exchange for the bribes, the officials caused the state-owned banks to refer customers to the Indian subsidiary’s insurance products, resulting in approximately $4.7 million in profits, which the company agreed to disgorge as part of the declination. The letter stated that DOJ’s decision reflected the company’s timely and voluntary self‑disclosure, full and proactive cooperation, the nature and seriousness of the offense, the company’s timely and appropriate remediation efforts, which included removing personnel involved, the company’s significant improvements to its compliance program and internal controls, including enhancing oversight of third-party payments and use of messaging applications for business purposes, the absence of aggravating factors, and the company’s agreement to disgorge profits. As we noted in August 2024, declinations with disgorgement have been relatively rare over the last several years, which amplifies the significance of this declination as the first corporate FCPA resolution of the second Trump administration. The factors cited in the letter as warranting declination are consistent with the factors set out in the DOJ Criminal Division’s Corporate Enforcement Policy, which was revised in May 2025, and appear to be consistent with some of the factors set out in DOJ’s June 2025 FCPA Enforcement Guidelines.

2. DOJ Announces First FCPA Case Against Individuals of Trump’s Second Term

On August 11, 2025, DOJ announced that two Mexican citizens and U.S. lawful permanent residents, Ramon Alexandro Rovirosa Martinez and Mario Alberto Avila Lizarraga, had been indicted in the Southern District of Texas for allegedly bribing officials of Mexico’s national oil company, Petróleos Mexicanos (PEMEX), and its wholly owned exploration and production subsidiary, PEMEX Exploración y Producción (PEP). According to DOJ, from 2019 to 2021, Rovirosa and Avila paid at least $150,000 in cash and luxury goods to PEMEX and PEP officials in exchange for the officials taking actions to help companies associated with Rovirosa win contracts with PEMEX and PEP worth at least $2.5 million. The indictment charges both defendants with one count of conspiring to violate the FCPA and three counts of violating the FCPA.[1] Each of the three substantive FCPA counts is based on a message sent by one of the defendants using a third‑party messaging application regarding the delivery of a cash payment to a foreign official. Rovirosa was arrested in Texas on August 10 and is currently scheduled for trial on October 6, 2025, in front of District Judge Kenneth Hoyt (who has been covered in previous Top 10s, e.g., this one from February 2023), while Avila remains a fugitive. Although not expressly stated in the press release, the decision to bring an enforcement action against Rovirosa and Avila appear to be consistent with some of the factors set out in DOJ’s June 2025 FCPA Enforcement Guidelines. The indictment calls the Rovirosa-related companies “Mexico-Energy Companies,” which could imply that DOJ believes that U.S. companies were disadvantaged by the bribery scheme. According to reporting (and according to the original version of the DOJ press release), DOJ alleged that Rovirosa has ties to Mexican cartel members. The Rovirosa case is the first FCPA enforcement action against individual defendants announced during Trump’s second term.

3. Federal Judge Upholds Conviction of Former Connecticut Oil Trader in Petrobras Bribery Case

On August 12, 2025, the U.S. District Court for the District of Connecticut denied former Freepoint Commodities trader Glenn Oztemel’s motion for a judgment of acquittal or a new trial,[2] leaving intact his September 2024 jury conviction on FCPA and money laundering charges. DOJ alleged that Oztemel funneled bribe payments to Rodrigo Garcia Berkowitz, an official at Brazil’s national oil company, Petróleo Brasileiro S.A. (Petrobras), through “commissions” paid to intermediary Eduardo Innecco in exchange for confidential information and business advantages. The court rejected Oztemel’s argument that the FCPA charges were time-barred, finding sufficient evidence—particularly testimony from Berkowitz—that the bribery scheme and related exchanges of confidential Petrobras information continued past the statute of limitations date. The court held that Berkowitz’s testimony, corroborated by emails, coded language, and payment records, sufficiently established Oztemel’s knowing participation in the bribery and money laundering conspiracy. The court also held that it was proper to instruct the jury that Oztemel could be convicted either for making payments directly to a foreign official (§ 78dd-2(a)(1)) or indirectly through a third party (§ 78dd-2(a)(3)), rejecting his argument that the government had to choose between the two theories. (This holding echoed the Second Circuit’s December 2020 opinion rejecting a defendant’s theory that the FCPA’s domestic concern (15 U.S.C. § 78dd-2) and territorial jurisdiction (15 U.S.C. § 78dd-3) provisions were mutually exclusive.) Oztemel’s sentencing is scheduled for November 4, 2025. In December 2023, Freepoint entered into a deferred prosecution agreement (DPA) on related charges.

4. Honduran Official Pleads Guilty to Laundering Proceeds of Bribery Scheme

On August 13, 2025, 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, pleaded guilty in the Southern District of Florida to one count of money laundering in violation of 18 U.S.C. § 1957.[3]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.[4]Aldo Nestor Marchena pleaded guilty to related charges in June 2025, while a third defendant, Carl Zaglin, was scheduled for trial in September 2025. As discussed in our April 2025 Top 10, DOJ decided to pursue this case following a detailed review of the factors set out in President Trump’s February 2025 Executive Order pausing FCPA enforcement.

5. UK Charges Former Executives in Connection with Turkish Bribery Probe

On August 28, 2025, the UK Crown Prosecution Service (CPS) announced that it had authorized charges against 11 individuals related to the provision of gambling services in Turkey between 2011 and 2018. Among those charged for, among other things, bribery and conspiracy to defraud, were the company’s former chairman, former chief executive, and former directors of affiliated entities involved in the Turkish operations. The company previously entered into a DPA with the CPS in December 2023 for failing to prevent bribery by its Turkish business unit in violation of Section 7 of the UK Bribery Act of 2010 (UKBA). The first hearing in the case against the individuals is scheduled for October 6, 2025, at Westminster Magistrates’ Court.

6. United Kingdom Updates Corporate Prosecutions Guidance

On August 18, 2025, the UK CPS and the Serious Fraud Office (SFO) published joint updated Corporate Prosecutions guidance ahead of the new “failure to prevent fraud” offence, which takes effect on September 1, 2025. The offence makes large organizations—defined as those meeting at least two of the following three thresholds: more than 250 employees, turnover over £36 million, or a balance sheet total exceeding £18 million—criminally liable if they fail to prevent fraud committed by employees or other “associated persons” for the organization’s benefit. The updated guidance to prosecutors also covers changes to the common law “identification doctrine” already in force under the Economic Crime and Corporate Transparency Act 2023 (ECCTA), enacted in October 2023. Under the ECCTA, corporations can be held liable for economic crimes, including bribery, committed by “senior managers,” defined as those with significant decision-making or management authority, within their actual or apparent authority, even if the senior managers are not the “directing minds and wills” of the company. According to the CPS and SFO, these reforms “remove barriers that have made it harder to hold companies to account” and are intended to make it easier for prosecutors to pursue corporate wrongdoing. Under the ECCTA, organizations may defend themselves by demonstrating that they had “reasonable prevention procedures” in place or that such procedures were not reasonably expected in the circumstances. Both CPS and SFO urged companies, charities, and other large organizations to put systems, training, and controls in place now to mitigate risk. In November 2024, the UK government published a 44-page guidance document setting out six principles that companies should follow to ensure their fraud prevention procedures are “reasonable,” which could help them avoid liability under the new offense. As we noted then, the guidance is substantially similar to the guidance that the UK government had previously published in connection with the UK Bribery Act 2010’s failure to prevent bribery offense.

7.  United States to Return Former National Oil Company Executive to Mexico to Face Corruption Charges

On August 14, 2025, Mexico’s President Claudia Sheinbaum stated that Carlos Treviño, PEMEX’s CEO from 2017–2018, had been arrested in the United States on August 13 and would be deported to Mexico to face corruption charges. Mexico had been seeking Treviño’s arrest and extradition since September 2021, when he failed to appear in a Mexican court. According to Sheinbaum, the arrest stems from a complaint filed by former PEMEX director Emilio Lozoya, who alleged that Treviño had received approximately 4 million pesos in bribes in exchange for authorizing a contract for an ethylene plant with the chemical-industry subsidiary of a Brazilian construction company. Lozoya was extradited from Spain to Mexico in July 2020 on allegations that he himself had accepted $10 million in bribes from the Brazilian construction company. Shortly after his extradition, Lozoya reportedly began providing evidence to Mexican authorities regarding other Mexican officials who were involved in corruption.

8. Former International Soccer Executives Score Significant Victories in Switzerland

Since 2015, we have been covering allegations related to international soccer, including allegations against former officials of the Fédération Internationale de Football Association (FIFA) and several of its continental confederations. In August 2025, FIFA’s former President, Sepp Blatter, and former Acting Secretary General, Markus Kattner, as well as the former president of the Union of European Football Associations (UEFA), Michel Platini, enjoyed significant victories in this long-running drama.  On August 28, 2025, Switzerland’s Office of the Attorney General (OAG) confirmed it would not appeal a March 2025 appeals court ruling acquitting Blatter and Platini of fraud and related charges stemming from a CHF 2 million payment made in 2011. Prosecutors argued the payment lacked any legal basis and unlawfully enriched Platini, while Blatter testified it honored a verbal agreement for advisory work Platini performed from 1998–2002. Blatter and Platini were acquitted at trial in 2022. On August 29, 2025, the Zurich Industrial Tribunal rejected FIFA’s attempt to claw back bonuses paid to Blatter and Kattner between 2010 and 2013, including a bonus totaling CHF 23 million. FIFA had argued that senior FIFA executives had improperly approved each other’s bonuses, but the tribunal found the defendants could reasonably rely “in good faith” on FIFA’s authorization of the payments. The judgment, while not yet final, denied FIFA’s claims in full.

9. Swiss Bank Fined in Brazil Corruption Case

On August 22, 2025, Switzerland’s attorney general fined Swiss private bank J. Safra Sarasin SA CHF 3.5 million for failures tied to corruption and money laundering involving Brazil’s national oil company, Petrobras. The bank also reached a CHF 16 million settlement with Petrobras, resolving its civil claims. In a statement, the bank emphasized that the prosecutors’ order did not constitute an admission of guilt or liability by the bank or its representatives. Prosecutors alleged that between 2011 and 2014, accounts at the bank were used to launder approximately $71 million in bribes paid to Petrobras executives to secure contracts for about 10 companies in the oil and construction sectors. A former bank employee was separately sentenced to a six-month suspended custodial sentence for aggravated money laundering related to his conduct while working at another Swiss bank. The investigation, opened in 2019, was related to Brazil’s Operation Car Wash (Lava Jato).

10.  U.S.-Based Bank Settles with Malaysia and Fined in Switzerland Over 1MDB Scandal

On August 22, 2025, a U.S.-based bank announced that it had reached a $330 million settlement with the Malaysian government to resolve all existing and potential claims related to its alleged role related to alleged wrongdoing involving the Malaysian sovereign wealth fund 1Malaysia Development Berhad (1MDB). According to a joint statement, the bank will contribute the payment to Malaysia’s 1MDB Assets Recovery Trust Account without any admission of liability. The agreement binds both parties from pursuing future claims and requires withdrawal of all pending appeals tied to 1MDB’s 2021 lawsuit against the bank’s Swiss unit in the Kuala Lumpur High Court. That lawsuit had sought $800 million in damages for alleged negligence, breach of contract, conspiracy to defraud, and dishonest assistance. On the same day, the Switzerland’s OAG announced that the bank’s Swiss subsidiary was found guilty of failing to implement adequate organizational measures to prevent aggravated money laundering in connection with its 1MDB dealings. The bank was ordered to pay a fine of CHF 3 million. (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, and June 2024, January 2025, February 2025, and May 2025 Top 10s.)

[1] Indictment, United States v. Ramon Alexandro Rovirosa Martinez, et al., Case No. 4:25-cr-00415, ECF No. 1 (S.D. Tex. Aug. 6, 2025).

[2] Memorandum of Decision, United States v. Glenn Oztemel, Case No. 3:23-cr-000026-KAD, ECF No. 403 (D. Conn. Aug. 11, 2025).

[3] Plea Agreement, United States v. Francisco Roberto Cosenza Centeno, Case No. 1:23-cr-20454-JB, ECF No. 165 (S.D. Fla. Aug. 13, 2025).

[4]Factual Proffer, United States v. Francisco Roberto Cosenza Centeno, Case No. 1:23-cr-20454-JB, ECF No. 166 (S.D. Fla. Aug. 13, 2025).