Top 10 International Anti-Corruption Developments for September 2025

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: Did the U.S. Department of Justice (DOJ) continue its record of success in Foreign Corrupt Practices Act (FCPA) trials? What are the latest foreign bribery enforcement developments in the United Kingdom, France, and Germany? How is Albania using artificial intelligence (AI) to combat corruption in its public procurement process? The answers to these questions and more are here in our September 2025 Top 10.

1. Miami Jury Convicts CEO of Georgia-Based Manufacturer of Law Enforcement Uniforms in Honduran Bribery and Money Laundering Scheme

On September 15, 2025, DOJ announced that Carl Alan Zaglin, Chief Executive Officer of Atlanco LLC—a Georgia-based manufacturer of law enforcement uniforms and accessories—was convicted following a trial in the Southern District of Florida of one count of conspiracy to violate the FCPA, one count of violating the FCPA, and one count of conspiracy to commit money laundering. According to DOJ, Zaglin engaged in a five-year scheme that involved the payment of hundreds of thousands of dollars in bribes to Honduran officials in exchange for business worth over $10 million with a Honduran governmental entity, Comité Técnico del Fideicomiso para la Administración del Fondo de Protección y Seguridad Poblacional (TASA), that procured goods for the Honduran National Police and other Honduran security agencies. In furtherance of the scheme, Zaglin and his co-conspirators allegedly used coded language, sham brokerage agreements, and personal email accounts and encrypted messaging applications and laundered proceeds through the United States. Zaglin’s co-defendants, Aldo Nestor Marchena, who ran a front-company involved in the scheme, and former TASA Executive Director Francisco Roberto Consenza, who was one of the bribe recipients, pleaded guilty to related charges in June 2025 and August 2025, respectively. A fourth defendant, former TASA Titular Director Juan Ramon Molina, pleaded guilty to related charges in December 2024. Charges in this case were first announced in December 2023. Zaglin’s trial was postponed in March 2025, following President Trump’s February 2025 executive order pausing FCPA enforcement. In April 2025, DOJ informed the court that it had reviewed the case against Zaglin pursuant to that order and intended to proceed to trial. Zaglin faces a maximum of 25 years in prison. The Zaglin trial is the most recent in a string of DOJ victories in FCPA-related trials, including three trial victories in 2024. (For an analysis of themes DOJ successfully used in the 2024 trials, see our article.)

2. Defendants in Recently Charged Mexico Bribery Scheme File Motions to Dismiss

Last month, DOJ announced the first individual FCPA charges of the second Trump administration. Ramon Alexandro Rovirosa Martinez and Mario Alberto Avila Lizarraga were indicted in the Southern District of Texas for violating and conspiring to violate the FCPA in connection with an alleged scheme to bribe officials of Mexico’s national oil company, Petróleos Mexicanos (PEMEX), and its wholly owned exploration and production subsidiary, PEMEX Exploración y Producción (PEP), in exchange for contracts worth at least $2.5 million. As we noted in our August 2025 Top 10, DOJ’s initial press release alleged that Rovirosa has ties to Mexican cartel members. On September 8, 2025, Rovirosa moved to dismiss the indictment on the grounds that the cartel allegations amounted to “shocking and egregious” prosecutorial misconduct in violation of the Fifth and Sixth Amendments.[1] On September 11, 2025, Rovirosa filed a second motion to dismiss on the grounds that the alleged conspiracy ended in April 2020 and, therefore, the charges against him were time barred under the FCPA’s five-year statute of limitations.[2] DOJ filed its oppositions to the motions on September 24 and 27, 2025.[3] With respect to the first motion, DOJ argued that the cartel allegations were supported by evidence gathered during its investigation and were properly raised in the context of a detention hearing, that the press release permissibly reported an allegation raised in a public filing and was unlikely to taint the jury pool, and that Rovirosa had adduced no evidence that he was charged or targeted for improper motives. With respect to the second motion, DOJ argued that the charges were not time barred because it had obtained an order from the district court under 18 U.S.C. § 3292, which provides for tolling the statute of limitations for a criminal offense for up to three years when the government officially requests evidence from a foreign country in furtherance of a grand jury investigation, and because the defendants engaged in acts in furtherance of the alleged conspiracy in October 2021. These motions will be important to watch for at least two reasons: first, they involve a direct challenge to DOJ’s focus on cartels under the second Trump administration (see the February 2025 Attorney General Memo on the Total Elimination of Cartels and Transnational Criminal Organizations and the June 2025 Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)) and second, because they highlight that the statute of limitations in FCPA cases can be up to eight years (meaning that FCPA violations that occur during the second Trump administration could potentially be prosecuted well into the next administration).  

3. DOJ Reportedly Declines FCPA Charges Against California-Based Avocado Distributor

On September 9, 2025, Calavo Growers, Inc. disclosed in its Form 10-Q filing that DOJ had notified the company that the agency had closed its FCPA inquiry related to the company’s operations in Mexico. It is not apparent from the filing why DOJ declined to pursue the matter. In January 2024, the company disclosed it had self-reported to DOJ and the U.S. Securities and Exchange Commission (SEC) and intended to cooperate with both agencies. In a March 2025 securities filing, the company disclosed that SEC had informed it in February 2025 that the agency’s investigation had been “postponed,” but the latest securities filing does not mention the status of the SEC investigation.

4. Wife of Former U.S. Senator Sentenced for Involvement in Egypt-Related Corruption Scheme

On September 11, 2025, DOJ announced that Nadine Menendez, wife of convicted former Senator Robert Menendez, was sentenced to 54 months’ imprisonment following her April 2025 conviction on bribery and other counts for her role in the corruption and foreign influence scheme that also led to her husband’s conviction in July 2024. According to DOJ, Ms. Menendez introduced Senator Menendez to Wael Hana, a New Jersey businessman with close connections to Egyptian officials, and two of Hana’s business associates in early 2018. Between 2018 and 2002, the Menendezes allegedly accepted bribes, including gold, cash, a luxury convertible, and payments toward a home mortgage, from the three men in exchange for Senator Menendez’s promise to use his influence to protect their interests and to engage in official acts to benefit the government of Egypt.  The Menendezes, along with the three New Jersey businessmen, were first charged in September 2023, with additional charges added against Senator Menendez in October 2023 and January 2024. Senator Menendez was sentenced to 11 years’ imprisonment in January 2025. In addition to Nadine Menendez’s term of imprisonment, she was ordered to pay a forfeiture of over $922,000.

5. Former UK Politician Pleads Guilty to Russia-Related Bribery Charges

On September 26, 2025, Nathan Gill, the former leader of Reform UK in Wales, pleaded guilty to eight counts of bribery between December 2018 and July 2019 in connection with his receiving money in exchange for, among other things, making statements in the European Parliament and in news outlets designed to benefit Russia in its war efforts in Ukraine. Gill reportedly received the money from Oleg Voloshyn, a Ukrainian politician suspected to have ties with Russian secret services. Gill’s activities were first uncovered after authorities discovered communications between Gill and Voloshyn regarding the scheme on Gill’s phone pursuant to a stop at the Manchester airport in September 2021. A later search of Gill’s home revealed additional communications corroborating the scheme. Gill’s sentencing is scheduled for November 2025. 

6. French Company Agrees to Resolve Ukraine Bribery Allegations

On September 3, 2025, the Paris Court of Justice approved a Judicial Public Interest Agreement (CJIP) between security technology company SAS Surys (formerly Hologram Industries, a subsidiary of French company Imprimerie Nationale, the official printing office of the French government) and France’s National Financial Prosecutor’s Office (PNF). According to the order, Ukraine’s state-owned printing house, Polygraph, agreed to purchase raw materials used in making secure documents from an Estonian company, Ou Feature, which sourced the materials from Surys. Ou Feature was allegedly inserted into the deal to facilitate the payment of bribes to a Polygraph official and his relatives. Ou Feature allegedly received approximately €7 million from this arrangement between 2018 and 2021. The CJIP requires Surys to pay a fine of over €18 million to France and compensation of over €3.7 million to Ukraine. The CJIP also requires the Imprimerie Nationale group to agree to a three-year compliance program aimed at combatting future corruption under the supervision of the French Anti-Corruption Agency (AFA). This resolution demonstrates France’s continued status as a significant foreign bribery enforcer. (For other foreign bribery enforcement actions in France, see, for example, our November 2017, January 2020, July 2022, November 2022, and July 2024 Top 10s.)

7. Former French President Nicolas Sarkozy Convicted and Sentenced in Libya-Related Corruption Case

On September 25, 2025, a Paris court convicted and sentenced former French President Nicolas Sarkozy to five years in prison for his role in a conspiracy to finance his 2007 presidential campaign with funds from Libya. Sarkozy allegedly allowed his associates to contact Libyan officials for the purpose of obtaining financial support for his campaign in exchange for political favors, which the court described as a “corruption pact.” The scheme involved discussions with Libyan officials regarding financing for nuclear power, improving Libya’s image on the world stage, and the fate of former dictator Moammar Gadhafi’s brother-in-law, who is understood to have played a key role in attacks on a French airliner in 1999. Sarkozy continues to deny the allegations and was acquitted of charges of passive corruption, illegal campaign financing, and concealing the embezzlement of public funds. Sarkozy was initially placed under formal investigation for the conduct in March 2018 and his trial began in January 2025.  Sarkozy is the first former president of postwar France to be formally sentenced to a term of incarceration.

8. German Investigators Search Offices of MP in Connection with China and Russia Bribery Allegations

On September 12, 2025, German investigators searched the offices of MP Maximilian Krah after the Bundestag—the lower house of the German federal parliament—stripped Krah of his parliamentary immunity. Krah is being investigated on allegations of money laundering and bribery during his time as a Member of European Parliament (MEP). Prosecutors allege that Krah took payments from Russia (including from Oleg Voloshyn, see No. 5 above) and China while he served as an MEP. Krah has denied the charges as false and “politically motivated.” On September 30, 2025, a member of Krah’s former staff, Jian Guo, was sentenced to four years and nine months for his involvement in passing information to Chinese intelligence services.

9. Organization for Economic Cooperation and Development (OECD) Working Group on Bribery Publishes Anti-Corruption Reports for Several Former Soviet Republics. 

• Istanbul Anti-Corruption Action Plan (IAP) Issues Monitoring Reports for Four Countries. On September 18, 2025, the IAP announced results of the fifth round of peer-review anti-corruption monitoring for Ukraine, Armenia, Azerbaijan, and Moldova. Launched in 2003, the IAP is a sub-regional peer review program of the OECD Anti-Corruption Network for Eastern Europe and Central Asia. IAP conducts regular and comprehensive peer reviews of countries’ anti-corruption reforms against a set of indicators under nine performance areas. The IAP’s fifth round of monitoring was launched in 2022 and introduced a more normative peer-review framework than previous monitoring efforts.  The process measures country performance against a set of uniform benchmarks, with the goal of achieving higher objectivity, consistency, and transparency. While the reports commend the countries for their progress in developing anti-corruption policies and reforms, they also identify areas for improvement to further strengthen anti-corruption efforts, including advancing the independence of the judiciary, prosecution offices, and specialized anti-corruption institutions.
• OECD Encourages “Systemic” Approach to Anti-Corruption in an Integrity Review of Kazakhstan. On September 18, 2025, the OECD published its review of Kazakhstan’s integrity system, with the goal of “ensuring the sustained impact of anti-corruption reforms” in the country. In its report, the OECD praised Kazakhstan for its “significant strides in anti-corruption efforts” but stated that anti-corruption institutions nonetheless “remain vulnerable” to corruption. The OECD recommended greater cooperation and coordination between integrity bodies to work towards a systemic approach to anti-corruption across the whole of Kazakhstan, including through targeted capacity-building and information-sharing as well as greater transparency and accountability.

10. Albania Appoints AI Bot as Anti-Corruption Minister for Public Procurement

On September 11, 2025, Albanian Prime Minister Edi Rama announced that a new AI-generated bot will be appointed as “minister” in the Albanian government to “manage and award all public tenders in which the government contracts private companies for various projects.” The appointment of the AI bot, known as “Diella” (which means “sun” in Albanian) is aimed to reduce corruption in the public tender process in a country where the awarding of public contracts has been mired with corruption scandals. According to Rama, giving Diella responsibility for public tenders will make the government’s contracts “100 percent corruption free” and will ensure that “every public fund submitted to the tender procedure will be perfectly transparent.” AI is clearly a hot topic in compliance circles, and Albania’s experience in putting Diella in charge of public tenders is something to monitor.

[1] Defendant’s Motion to Dismiss, United States v. Ramon Alexandro Rovirosa Martinez, et al., Case No. 4:25-cr-00415, ECF No. 33 (S.D. Tex. Sept. 8, 2025).

[2] Defendant’s Motion to Dismiss, United States v. Ramon Alexandro Rovirosa Martinez, et al., Case No. 4:25-cr-00415, ECF No. 35 (S.D. Tex. Sept. 11, 2025).

[3] Government’s Opposition to Rovirosa’s Motion to Dismiss Based on Statute of Limitations, United States v. Ramon Alexandro Rovirosa Martinez, et al., Case No. 4:25-cr-00415, ECF No. 47 (S.D. Tex. Sept. 24, 2025); Government’s Opposition to Rovirosa’s Motion to Dismiss Based on Constitutional Grounds, United States v. Ramon Alexandro Rovirosa Martinez, et al., Case No. 4:25-cr-00415, ECF No. 52 (S.D. Tex. Sept. 26, 2025).