Top 10 International Anti-Corruption Developments for October 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: What company was charged in a relatively rare corporate Foreign Corrupt Practices Act (FCPA) indictment? How did the European Union (EU) prosecutor bring corruption charges in Italy against Bosnian public officials? How did a company use social media to spur Indian authorities to investigate alleged corruption by Indian customs agents? The answers to these questions and more are here in our October 2025 Top 10.

1. Voting Technology Firm Charged in Connection with Philippines Bribery Scheme

On October 16, 2025, a grand jury sitting in the Southern District of Florida returned a superseding indictment adding SGO Corporation Limited, a/k/a Smartmatic, as a defendant to a case alleging that the company and its executives conspired to pay at least $1 million in bribes to the former chairman of the Republic of the Philippines’ Commission on Elections (COMELEC) to secure contracts to provide voting machines and election services in connection with the 2016 Philippines elections. The payments allegedly came from a slush fund created by over-invoicing the cost for each voting machine sold to the Philippines for the elections and were allegedly concealed by routing transactions through bank accounts in the United States, Asia, and Europe, among other methods. The company was charged with one count of conspiracy to violate the FCPA, one count of conspiracy to commit money laundering, and three substantive counts of money laundering. DOJ initially announced charges against three of the company’s executives—Roger Alejandro Pinate Martinez, Jorge Miguel Vasquez, and Elie Moreno—and COMELEC’s former chairman, Juan Andres Donato Bautista, in August 2024. FCPA indictments against companies are relatively rare, especially in recent years, as most companies prefer to resolve matters pre-indictment. Notably, DOJ did not publicly decline prosecution of the company when the individual charges were announced. Smartmatic denies the allegations, stating that it cooperated extensively with prosecutors and calling the indictment “targeted, political, and unjust.” The company is a plaintiff in a defamation lawsuit related to the negative press it received in connection with voter fraud allegations during the 2020 presidential election.

2. Intermediary Sentenced in Honduran Bribery Scheme

On October 28, 2025, Aldo Nestor Marchena was sentenced in the Southern District of Florida to seven years’ imprisonment following his June 2025 guilty plea to conspiracy to launder the proceeds of a scheme to bribe Honduran officials in connection with the procurement of police uniforms and tear gas worth more than $10 million.[1] Charges against Marchena and two co-defendants, Carl Alan Zaglin (the owner of Atlanco LLC, a Georgia-based manufacturer of law enforcement uniforms and accessories) and Francisco Roberto Consenza Centeno (the former Executive Director of the Comité Técnico del Fideicomiso para la Administración del Fondo de Protección y Seguridad Poblacional (TASA)), were announced in December 2023. Zaglin was convicted at trial in September 2025, while Consenza and former TASA Titular Director Juan Ramón Molina pleaded guilty to related charges in August 2025 and December 2024, respectively. Marchena’s sentencing underscores DOJ’s continued focus on third-party facilitators in foreign procurement bribery cases.

3. U.S. Judge Denies Motions to Dismiss Charges in PEMEX Bribery Case

On October 21, 2025, a U.S. federal judge in the Southern District of Texas denied Ramón Alexandro Rovirosa Martínez’s third motion to dismiss the indictment against him, or in the alternative to exclude evidence against him, because of DOJ’s alleged delay in turning over his co-defendant’s cell phone and its contents and foreign translations.[2] According to an indictment announced in August 2025, Rovirosa and a co‑defendant, Mario Alberto Ávila Lizárraga, conspired to offer at least $150,000 in bribes to officials at Mexico’s state-owned oil company, Petróleos Mexicanos (PEMEX), and its subsidiary, Pemex Exploración y Producción (PEP), to assist Rovirosa’s companies in securing contracts from the companies worth more than $2.5 million. Rovirosa’s motion argues that the contents of Ávila’s cell phone are the primary evidence against him, were translated incorrectly, were produced in violation of the deadlines set forth in the court’s discovery order, and, if admitted, would violate his rights under the constitution’s confrontation clause.[3] In denying the motion, the court held that the proper remedy for the late discovery was a continuance of trial, that admitting the contents of the cell phone would not violate the confrontation clause because they are not testimonial in nature, and that Rovirosa may offer his own translations to refute the government’s translations.

Although the court’s Memorandum and Opinion only expressly addresses Rovirosa’s third motion to dismiss, the docket states that the order also denies two motions to dismiss filed by Rovirosa in September 2025. Those motions alleged that DOJ had violated Rovirosa’s constitutional rights by publicly asserting that he had ties to cartels and that the charges were time barred. An earlier order by the court appears to more explicitly address the cartel motion, stating that any “language and inferences” regarding the defendant’s association with a drug cartel “will not be tolerated in this trial from either party” and that the “defendant’s motion to dismiss is Denied.”[4]

4. Customs Broker Pleads Guilty to FCPA Conspiracy

On October 24, 2025, a U.S. federal judge in the Western District of Texas accepted the guilty plea of a U.S.- and Mexico-based customs broker, Carlos Leopoldo Alvelais Alarcón, to one count of conspiracy to violate the FCPA. The plea agreement and indictment remain under seal. Alvelais is scheduled to be sentenced in early 2026.

5. Court Orders Extradition of Former UN Official to Face U.S. Bribery Charges

On October 21, 2025, a Madrid court approved the extradition of Vitaly Vanshelboim, former deputy executive director of the United Nations Office for Project Services (UNOPS), to the United States to face three of the six charges against him: soliciting and receiving bribes, wire fraud, and money laundering. The court refused extradition on certain conspiracy counts that are not recognized under Spanish law and dismissed defenses based on UN immunity and alleged political motivation. U.S. prosecutors allege that Vanshelboim accepted more than $2 million in bribes between 2015 and 2023 from a British businessman, in exchange for steering over $60 million in UNOPS‑related grants and loans to companies under that businessman’s control. The alleged bribes include home repairs, a new Mercedes, and a $1.2 million sponsorship for his teenage son, who was a tennis player. The extradition order follows the UN Dispute Tribunal’s finding in October 2024 that Vanshelboim committed fraud and “blatant misconduct” in connection with financial losses at UNOPS.

6. Rapper Ordered to Forfeit Proceeds Linked to Malaysia’s 1MDB Corruption Scandal

On October 30, 2025, a U.S. federal court ordered Prakazrel “Pras” Michel, a member of the U.S. hip-hop group the Fugees, to forfeit nearly $65 million in proceeds derived from assets linked to Malaysia’s 1MDB scandal.[5] The forfeiture order follows findings that Michel used funds connected to the bribery and misappropriation of 1MDB assets to finance luxury purchases and entertainment projects. Michel was convicted by a jury in the District of Columbia in April 2023 for conspiracy, concealing material facts, making false entries in records, witness tampering, and serving as an unregistered agent of a foreign power. The case arose in part from Michel’s unregistered backchannel efforts to persuade DOJ to drop its investigation into Malaysian businessman Low Taek Jho. The forfeiture order represents continued U.S. efforts to recover assets tied to the 1MDB embezzlement scheme. (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, June 2024, January 2025, February 2025, and May 2025 Top 10s, as well as entry 7 below.) 

7. Malaysian Anti-Corruption Agency Freezes $115 Million in Swiss Accounts Linked to 1MDB Corruption Scandal

In a further development related to 1MDB, on October 10, 2025, the Malaysian Anti‑Corruption Commission (MACC) obtained court orders restraining transactions totaling $115.3 million held in three Swiss accounts allegedly tied to the money laundering and bribery scheme. Cooperation between Malaysian, Swiss, and Singaporean authorities revealed that the Swiss accounts belong to Prince Turki Abdullah Abdulaziz Al-Saud, a Saudi Arabian national. MACC’s application was based on information it had received in 2011 that indicated the prince had received, transferred, and utilized funds derived from the misappropriation of 1MDB’s assets. The action underscores Malaysia’s renewed efforts to recover overseas assets, including through cooperation with national authorities.

8. European Public Prosecutor’s Office Brings Charges in Bosnian Corruption Scheme 

On October 13, 2025, the European Public Prosecutor’s Office (EPPO) in Venice, Italy, announced that it had filed charges against six individuals, including three Italian business executives and three Bosnian public officials, accused of accepting bribes tied to a €4 million consultancy project. The consultancy project linked to the alleged bribes is part of a wider €340 million construction project for the Pan-European Motorway Corridor, which connects Hungary and eastern Croatia to Bosnia and Herzegovina and the Adriatic Sea. The European Investment Bank (EIB), which has financed 87% of the overall project, reported its suspicions that there had been manipulation in the procurement process for the consultancy services to EPPO. The subsequent investigation, conducted by Italy’s Carabinieri, found that the Bosnian officials allegedly took coordinated actions to secure the contract for the Italian business executives’ company in return for financial and other benefits. The exact amount of the alleged benefits has not been publicly disclosed. EPPO cooperated closely with judicial and enforcement authorities in Bosnia and Herzegovina, highlighting the ever-increasing cross-border collaboration between enforcement agencies and prosecutors.

9. India Investigates Bribery Allegations Against Customs Officials

On October 2, 2025, India’s Ministry of Finance announced over social media that it has directed India’s Department of Revenue to investigate customs officials in Chennai for demanding bribes from a logistics company, Wintrack Inc., in exchange for clearing shipments. The announcement came after Wintrack alleged through social media that the customs officials had relentlessly harassed the company and retaliated against it for exposing their bribery practices. Wintrack’s post then went viral. In response to the allegations, Chennai Customs issued an official social media statement, asserting that Wintrack had misclassified goods, carried undeclared USB charging cables, and failed to provide a mandatory Extended Producer Responsibility certificate. The investigation emphasizes the potential risks associated with customs officials and provides an interesting example of how social media can be leveraged by companies in their interactions with enforcement authorities.

10. Former Executives Make First UK Court Appearance in Connection with Turkish Bribery Probe

On October 6, 2025, former executives of affiliated entities involved in the provision of gambling services in Turkey appeared in a London court to face charges announced by the UK Crown Prosecution Service (CPS) in August 2025, including bribery and conspiracy to defraud. Prosecutors allege that, between 2011 and 2018, the company’s Turkish-facing arm made improper payments and concealed revenue to secure favorable business conditions. Among those charged were the company’s former chairman, former chief executive, and former directors. The CPS has highlighted that many of the alleged criminal activities occurred in northern England, and the trials may be moved to Leeds Crown Court.

[1] United States v. Aldo Nestor Marchena, Case No. 1:23-cr-20454 (S.D. Fla. Oct. 28, 2025).

[2] Memorandum and Order, United States v. Ramon Alexandro Rovirosa Martinez, Case No. 4:25-cr-00415, ECF No. 75 (S.D. Tex. Oct. 21, 2025).

[3] Defendant’s Third Motion to Dismiss, United States v. Ramon Alexandro Rovirosa Martinez, Case No. 4:25-cr-00415, ECF No. 60 (S.D. Tex. Oct. 6, 2025).

[4] Orders, United States v. Ramon Alexandro Rovirosa Martinez, Case No. 4:25-cr-00415, ECF No. 57 (S.D. Tex. Sept. 30, 2025).

[5] Preliminary Order of Forfeiture Imposing Money Judgment and Memorandum Opinion, United States v. Prakazrel Michel, Case No. 1:19-cr-00148, ECF Nos. 400-401 (D.D.C, Oct. 30, 2025).