Top 10 International Anti-Corruption Developments for November 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: How did a Foreign Corrupt Practices Act (FCPA) resolution involving an alleged Guatemalan bribery scheme reflect the new U.S. foreign bribery enforcement priorities? What updates did the United Kingdom (UK) Serious Fraud Office (SFO) make to its corporate compliance guidance? What steps did France, Kuwait, the United Arab Emirates (UAE), and Morocco take toward enhancing their anti‑corruption efforts? The answers to these questions and more are here in our November 2025 Top 10.

1. Telecommunications Company Resolves FCPA Charges Arising from Guatemala Bribery Scheme

On November 10, 2025, Luxembourg-based Millicom International Cellular S.A. (Millicom) disclosed that its subsidiary in Guatemala, Comunicaciones Celulares S.A., d/b/a TIGO Guatemala, had entered into a two-year deferred prosecution agreement (DPA) with the U.S. Department of Justice (DOJ) and agreed to pay more than $118 million to resolve Foreign Corrupt Practices Act (FCPA) charges arising from improper payments to Guatemalan officials.[1] According to DOJ, from 2012 to 2018, TIGO Guatemala made corrupt payments to Guatemalan officials in order to secure improper advantages and to obtain and retain telecommunications business in Guatemala. These advantages allegedly included the passage of legislation in 2012 and 2014 that allowed the company to renew its right to use, possess, and benefit from radiofrequency usufruct titles for a 20-year term and to obtain all authorizations for the installment of telecommunications infrastructure from the federal rather than local government, which “disproportionately benefited” the company. DOJ alleged that the bribery scheme “featured monthly bribe payments, usually paid in cash, to numerous Guatemalan members of congress or members of their security teams.” DOJ stated that it originally closed the investigation in 2018, but in 2020 it obtained new evidence that led to the re-opening of the investigation. According to DOJ, “The new evidence revealed the scope of TIGO Guatemala’s conduct, including that the criminal conduct continued during and after the department’s closure of the first phase of the investigation and involved narcotrafficking proceeds that were used to generate cash for some of the bribe payments.” This latter fact appears to have satisfied at least the first factor under DOJ’s new “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA),” which requires prosecutors to consider whether the alleged bribery utilizes money launderers that also engage in money laundering for cartels or transnational criminal organizations (TCOs), seemingly even when the company is unaware of such a connection. Under the DPA, which was filed in the Southern District of Florida, the company will pay a $60 million criminal monetary penalty, which reflects a reduction of 50 percent from the bottom of the applicable range of the United States Sentencing Guidelines, and more than $58 million in forfeiture. The DPA does not require a corporate monitor. The company received credit for its and Millicom’s cooperation with DOJ’s investigation and timely remediation under the Criminal Division’s Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) but did not receive self-disclosure credit.

2. Tuna Bonds Defendant Ordered to Forfeit $5.7 Million

On November 6, 2025, former bank executive Surjan Singh was ordered to forfeit $5.7 million related to his role in an alleged scheme to steal approximately $200 million from a total of $2 billion in loans issued to state-controlled companies in Mozambique between 2012 and 2016 for three maritime projects, including one related to tuna fishing.[2] Former Mozambique Finance Minister Manuel Chang, who was convicted by a jury in August 2024 and sentenced to 102 months’ imprisonment in January 2025, allegedly received $7 million in bribes in exchange for signing guarantees for the loans. Singh pleaded guilty in September 2019 to one count of conspiracy to commit money laundering. (For more on the “Tuna Bonds” case, see our January 2019, March 2019, July 2023, May 2024, August 2024, January 2025, and May 2025 Top 10s.)

3. Six Former Employees of Swiss Commodities Trader Face UK Trial for Alleged Foreign Bribery Schemes in West Africa

On November 10, 2025, four former Glencore employees appeared in London’s Southwark Crown Court and entered not-guilty pleas to SFO charges alleging conspiracies to bribe officials in Cameroon, Nigeria, and Côte d’Ivoire between 2007 and 2014. The defendants include former executive David Perez and former traders Paul Hopkirk, Ramon Labiaga, and Martin Wakefield. Two former senior executives, Alex Beard and Andrew Gibson, previously confirmed their intent to plead not guilty. The SFO alleges that the defendants routed corrupt payments through an agent and used falsified invoices linked to the company’s West Africa oil-trading operations. The SFO charged the conduct under the Prevention of Corruption Act 1906, which governs pre-UK Bribery Act (UKBA) activity. The court scheduled a six-month trial to begin on October 4, 2027. The case forms part of the broader enforcement actions that followed Glencore’s 2022 corporate resolutions and illustrates SFO’s continued emphasis on individual accountability in foreign bribery matters. (For more coverage of Glencore-related matters, see our July 2021, May 2022, June 2022, September 2022, November 2022, February 2023, August 2024, and March 2025 Top 10s.)

4. UK SFO Updates Corporate Compliance Guidance

On November 26, 2025, the UK SFO published updated corporate compliance guidance that explains when, how, and why SFO prosecutors may evaluate a company’s compliance program. The guidance identifies six scenarios in which the SFO may conduct such evaluations, including when assessing whether prosecution serves the public interest, determining eligibility for a DPA, deciding whether DPA terms should include compliance enhancements or a monitorship, and evaluating the availability of the “adequate procedures” defense under the UKBA or the “reasonable procedures” defense under the Economic Crime and Corporate Transparency Act. The SFO emphasized that policies on paper do not establish effectiveness and stated that prosecutors will examine how compliance measures operate in practice across the organization. The SFO also outlined criteria that prosecutors may use to assess whether a company had reasonable procedures to prevent fraud, reflecting the new “failure to prevent fraud” offense that took effect in September 2025. (See our October 2023, November 2024, and August 2025 Top 10s for more on the failure to prevent fraud offense.) The guidance also explains that the SFO intends to draw on compelled disclosures, internal investigation records, and witness interviews when reviewing a company’s compliance environment. The SFO noted that organizations may reference external standards, including guidance issued by DOJ and the French Anti-Corruption Agency, when designing and assessing compliance programs. This update follows the SFO’s earlier 2025 revisions to its corporate cooperation and corporate prosecution guidance, and signals increasing convergence between UK and international expectations regarding proactive, effective compliance.

5. Former UK Politician Is Sentenced for Russia-Related Bribery

On November 21, 2025, the Central Criminal Court of the UK sentenced Nathan Gill, the former leader of Reform UK in Wales, to 10 years and six months of imprisonment after Gill pleaded guilty to eight counts of bribery in September 2025. According to court filings and investigative records, between December 2018 and July 2019, Gill accepted a series of cash payments from Ukrainian politician Oleg Voloshyn in exchange for making pro-Russian statements in the European Parliament and in Ukrainian media outlets. The conduct included speeches, parliamentary questions, and coordinated media commentary that advanced narratives favorable to Viktor Medvedchuk, a sanctioned Ukrainian politician and close associate of Vladimir Putin. UK counterterrorism investigators seized Gill’s devices at Manchester Airport in 2021 and matched WhatsApp communications with public statements that he delivered on Voloshyn’s behalf. This matter first drew public attention in September 2025, when investigators disclosed Gill’s exchanges with Voloshyn, including messages that detailed scripts, media appearances, and parliamentary interventions financed through cash payments. UK authorities viewed these actions as part of a coordinated influence effort that leveraged Gill’s elected position to advance pro-Russian narratives. The sentencing remarks referred to at least $45,000 cash that Gill received under the scheme but noted that the aggregate financial gain that Gill received from Russia‑related bribes was “difficult to quantify precisely due to the piecemeal and cash nature of payments.” The court described the financial gain as “substantial.” At sentencing, the judge described Gill’s conduct as a profound breach of public trust that undermined democratic integrity and damaged confidence in parliamentary processes.

6. Dutch Prosecutors Pursue Corruption and Sanctions-Evasion Cases Against Dutch Shipyard and Its Senior Executives

On November 24, 2025, prosecutors in the Netherlands opened preliminary hearings in Zwolle in the corruption and sanctions-evasion proceedings involving Damen Shipyards, a major Dutch defense shipbuilder. Prosecutors charged the company, several subsidiaries, and multiple executives with allegedly bribing officials in Brazil, the Caribbean, and African countries, including Sierra Leone, Ghana, and Togo. Prosecutors also charged the company with concealing irregular commissions, falsifying documents, and manipulating accounts. In a parallel sanctions case, prosecutors alleged that the company exported ship components to Russia in violation of EU sanctions and submitted false customs declarations for at least 14 shipments in 2022. Two directors, including former regional director Sander van Oord, settled their cases after accepting sanctions for concealing improper commissions. Prosecutors also settled with a former Curaçao Ports Authority director linked to promised payments tied to Damen contracts. Prosecutors noted that many alleged offenses ended after authorities raided Damen headquarters in 2017. A conviction could bar Damen Shipyards Gorinchem and Damen Schelde Naval Shipbuilding from public contracts in the Netherlands and the European Union and could expose both companies to fines of up to 10 percent of annual turnover. The company stated that it intends to contest the allegations.

7. France Adopts Multi-Year National Anti-Corruption Plan for 2025–2029

On November 14, 2025, the French government adopted a four-year national anti-corruption plan that introduces 36 measures aimed at strengthening prevention and detection of integrity breaches across public administrations, local authorities, and the private sector. France stated that it intends to respond to increased corruption risks linked to organized crime and to reinforce public confidence in government institutions. The plan establishes an interministerial committee to steer implementation and directs all sovereign-function administrations to adopt stronger internal controls, alert systems, and procurement safeguards. France also committed to strengthen training for civil servants and expand guidance for local authorities, small and medium enterprises, and mid-cap companies. The plan includes a significant European and international dimension, and positions France to advocate for a more coordinated EU strategy on corruption risk. The French Anti-Corruption Agency will lead implementation and will coordinate with government bodies and economic actors.

8. Ukraine Launches Major Operation Targeting Corruption in State-Owned Enterprises

On November 10, 2025, the National Anti-Corruption Bureau of Ukraine (NABU) and the Specialized Anti-Corruption Prosecutor’s Office (SAPO) announced that they had uncovered a large‑scale corruption scheme in the energy sector involving Ukraine’s state-owned nuclear electricity producer, Energoatom. According to NABU, several members of the Ukrainian government accepted bribes from Energoatom contractors, amounting to 10-15 percent of each contract’s value, from which around $100 million in funds was laundered. On November 11, 2025, NABU charged eight people with bribery, embezzlement, and illicit enrichment, including Ihor Myroniuk, once advisor to former Justice Minister Herman Halushchenko, who previously served as deputy head of the State Property Fund. NABU alleged that the leader behind the corruption scheme is Timur Mindich, a past business partner of Ukraine’s President Volodymyr Zelenskyy. On November 13, 2025, in addition to the investigation into Energoatom, Ukraine launched an anti‑corruption audit of all state-owned enterprises (SOEs). On November 19, 2025, Justice Minister Halushchenko and Energy Minister Svitlana Hrynchuk were terminated. On November 28, 2025, the residence of Andriy Yermak, President Zelenskyy’s chief of staff and Kyiv’s lead negotiator in peace talks with the United States, was searched by anti-corruption investigators; Yermak resigned later that same day. Reportedly, the anti-corruption efforts were being welcomed domestically but may potentially risk undermining Ukraine’s leverage in international peace negotiations. Nevertheless, the anti-corruption efforts show that, despite the Russia war, Ukrainian anti-corruption authorities are still functioning effectively and are not being stifled by other Ukrainian authorities.

9. Kuwait Affirms Its Anti-Corruption Efforts

In November 2025, Kuwait advanced its anti-corruption agenda through coordinated domestic and international initiatives. On November 11, 2025, the Kuwait Anti-Corruption Authority (Nazaha), the country’s central agency responsible for promoting integrity and preventing corruption across the public and private sectors, reaffirmed Kuwait’s commitment to global cooperation at the International Criminal Police Organization (INTERPOL) Global Anti-Corruption and Asset Recovery Conference in Abu Dhabi. Nazaha’s chairman outlined Kuwait’s efforts to strengthen integrity systems, expand asset recovery tools, improve information sharing, and deepen collaboration with foreign law enforcement, oversight bodies, and financial intelligence units. On November 17, 2025, Nazaha, working with the United Nations Development Program and the General Secretariat of the Supreme Council for Planning and Development, launched nationwide consultations to shape Kuwait’s next anti-corruption and integrity strategy. The consultations will draw on progress made under the 2019–2025 strategy and help shape Kuwait’s forthcoming anti-corruption and integrity framework, aligning it with the United Nations Convention Against Corruption (UNCAC). Kuwait cited recent improvements in international governance indicators and plans to finalize the new strategy in 2026.

10. UAE and Morocco Sign Anti-Corruption Cooperation Agreement

On November 12, 2025, the UAE Accountability Authority (UAEAA) and the Morocco National Authority for Integrity, Prevention, and Combating of Bribery signed a Memorandum of Understanding (MOU) committing the countries to enhance institutional collaboration and exchange expertise and best practices in combating corruption and safeguarding public funds. Regional agreements like the UAE-Morocco MOU can play an important role in combating foreign bribery.

[1] Deferred Prosecution Agreement, United States v. TIGO Guatemala, Case No. 1:25-cr-20476-JB, ECF No. 17 (S.D. Fla. Nov. 12, 2025).

[2] Order of Forfeiture, United States v. Surjan Singh, Case No. 1:18-cr-00681-NCG, ECF No. 839 (E.D.N.Y. Nov. 7, 2025).