Top 10 International Anti-Corruption Developments for December 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 winning streak in Foreign Corrupt Practices Act (FCPA) related trials? Did a U.S. appellate court uphold an earlier DOJ FCPA trial victory? What advice did the UK Serious Fraud Office (SFO) and its partner agencies provide to businesses on how to spot indicators of foreign bribery? The answers to these questions and more are here in our December 2025 Top 10.

1. Houston Jury Convicts Texas Businessman of Violating FCPA in Mexican Bribery Case

On December 5, 2025, DOJ announced that a federal jury in the Southern District of Texas had convicted Ramon Alexandro Rovirosa Martinez for his role in a bribery scheme involving government officials at Mexico’s state-owned oil company, Petróleos Mexicanos (PEMEX), and its subsidiary, Pemex Exploración y Producción (PEP). Rovirosa—who was one of the first individuals to be charged with FCPA violations under the second Trump administration—was convicted of one count of conspiracy to violate the FCPA and two counts of violating the FCPA and acquitted of one additional count of violating the FCPA. An indictment unsealed in August 2025 alleged that Rovirosa and a co‑defendant, Mario Alberto Ávila Lizárraga, conspired to offer at least $150,000 in bribes to PEMEX and PEP officials to help Rovirosa’s companies secure more than $2.5 million in contracts. Despite substantial pretrial motion practice involving the propriety of cartel-related allegations in DOJ’s initial press release, the timeliness of the FCPA charges, and the timeliness of discovery (see our September 2025 and October 2025 Top 10s for more on those motions), this case went to trial extremely quickly for an FCPA case. The trial victory also continues DOJ’s run of success in FCPA-related trials over the last two years, including four trial victories in 2024 and one other in 2025. (For an analysis of themes DOJ successfully used in the 2024 trials, see our article. For more on one of the cases that went to trial in 2024, see #4 below. For more on the other case that went to trial in 2025, see #3 below.)

2. Former Banker Fails in Bid to Overturn 1MDB-Related Conviction and Sentence on Appeal

On December 5, 2025, the U.S. Second Circuit Court of Appeals affirmed the conviction and sentence of former Goldman Sachs banker Ng Chong Hwa, also known as Roger Ng. Ng was convicted by a jury in the Eastern District of New York on foreign bribery-related charges in April 2022 and, in March 2023, was sentenced to 10 years’ imprisonment and ordered to forfeit $35.1 million. Ng allegedly conspired to launder billions of dollars embezzled from Malaysia’s sovereign wealth fund 1Malaysia Development Berhad (1MDB), conspired to violate the FCPA’s anti-bribery provisions by paying more than $1 billion in bribes to a dozen government officials in Malaysia and Abu Dhabi, and conspired to violate the FCPA’s accounting provisions by circumventing the internal accounting controls of his employers’ parent company, an investment bank whose shares trade on a U.S. stock exchange. Ng argued on appeal that (1) the district court excluded from evidence a recording that was material to his defense, (2) the government breached an agreement pursuant to which he had waived extradition from Malaysia, (3) venue in the Eastern District of New York was improper, and (4) the forfeiture order was an unconstitutionally excessive fine. The Second Circuit held that (1) the district court properly excluded the recording because it contained inadmissible hearsay and was not needed to provide context or completeness, (2) the government did not breach any agreement not to change the offenses following extradition because, although the superseding indictments added overt acts, they charged the same three offenses as the original indictment, (3) Ng failed to object to venue following the return of the second superseding indictment, and (4) the $35.1 million forfeiture order correctly reflected the amount Ng received from the offenses and was not grossly disproportional to the gravity of Ng’s offense. (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, May 2025, and October 2025 Top 10s.)

3. CEO of Georgia-Based Manufacturer of Law Enforcement Uniforms Sentenced for Role in Honduran Bribery and Money Laundering Scheme

On December 3, 2025, DOJ announced that Carl Alan Zaglin, former CEO of Georgia-based manufacturer of law enforcement uniforms and accessories Atlanco LLC, was sentenced in the Southern District of Florida to eight years’ imprisonment following his September 2025 trial conviction on FCPA and money laundering charges. Those charges stemmed from Zaglin’s role in an alleged 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 that procured goods for Honduran security agencies. In furtherance of the scheme, Zaglin and his co-conspirators allegedly used coded language, sham brokerage agreements, personal email accounts, and encrypted messaging applications and laundered proceeds through the United States. One of Zaglin’s co-defendants, Aldo Nestor Marchena, who pleaded guilty in June 2025, was sentenced to seven years’ imprisonment in November 2025, while two of the alleged bribe recipients, Juan Ramon Molin and Francisco Roberto Cosenza Centeno, who pleaded guilty in December 2024 and August 2025, respectively, await sentencing. (For more on the cases of Zaglin and his co-defendants, see our December 2023, March 2025, April 2025, June 2025, August 2025, and September 2025 Top 10s.)

4. U.S. Oil Trader Sentenced for Role in Brazilian Bribery Scheme

On December 9, 2025, DOJ announced that former senior oil and gas trader Glenn Oztemel had been sentenced to 15 months in prison for his role in an alleged eight-year bribery scheme involving Brazil’s national oil company, Petroleo Brasileiro S.A. (Petrobras). In September 2024, a federal jury in the District of Connecticut convicted Oztemel of one count of conspiracy to violate the FCPA, one count of conspiracy to commit money laundering, three counts of violating the FCPA, and two counts of money laundering. According to an August 2023 superseding indictment, Oztemel and his co-conspirators paid over $1 million in bribes to Petrobras officials over the course of the alleged scheme in order to win lucrative contracts for two Connecticut-based commodities trading companies. At sentencing, Oztemel, citing President Trump’s February 2025 Executive Order pausing all FCPA investigations and prosecutions, sought a sentence of probation, plus home detention and community service. He argued that a sentence of any prison time would constitute a disparate sentence because “individuals engaging in similar conduct are almost certain not to be charged in the future” in light of the Executive Order. The government, which sought a sentence of seven to 10 years’ imprisonment, countered that DOJ reviewed Oztemel’s case under the Executive Order and specifically authorized it to proceed.[1] The government also pointed out that the Executive Order Oztemel cited explicitly stated that it “is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or in equity by any party against” DOJ. (For more on Oztemel’s case, see our February 2023, August 2023, September 2024, and August 2025 Top 10s.)

5. Judge Vacates or Reduces Restitution Orders for Three “Tuna Bonds” Defendants

On December 12, 2025, a federal judge in the Eastern District of New York vacated in part a May 2025 decision ordering three former bank executives in the high-profile “Tuna Bonds” case to pay nearly $310 million in restitution.[2] The alleged scheme involved a conspiracy 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. The court vacated the portion of the decision ordering two of the executives, Surjan Singh and Detelina Subeva, to pay restitution of $35.2 million and $10.5 million, respectively. Singh argued, and the court and DOJ agreed, that he was not liable for any losses incurred by the victim bank because he was not involved in the loans between the victim bank and the relevant Mozambican state-owned entities. Subeva argued, and the court and DOJ agreed, that the May 2025 order contravened a 2022 sentencing order, which was issued by a judge who subsequently recused himself and which held that restitution was “not applicable” in Subeva’s case. The court thus found that ordering any restitution would prejudice Subeva. The third executive, Andrew Pearse, was previously ordered to pay more than $264 million in restitution. DOJ opposed, and the court rejected, Pearse’s various substantive arguments against restitution. The court, however, “sympath[ized]” with Pearse’s alternate arguments that he was “essentially destitute” and—given that the government did not dispute that point—ordered that Pearse pay only 5% of his post-tax income as restitution, following a three-year grace period. For all three defendants, the court’s decision comported with arguments the government affirmatively made or appeared to tacitly accept. The portion of the order requiring a fourth defendant, former Mozambique Finance Minister Manuel Chang, to pay over $42 million in restitution was not at issue. (For more on the “Tuna Bonds” case, see our January 2019, March 2019, July 2023, May 2024, August 2024, January 2025, May 2025, and November 2025 Top 10s.)

6. Former Banker Loses Bid to Dismiss Charges in Connection with Ghana Bribery Scheme

On December 17, 2025, a judge in the Eastern District of New York rejected former Goldman Sachs banker Asante Kwaku Berko’s attempt to dismiss criminal bribery and money laundering charges against him related to an alleged scheme to bribe Ghanaian government officials in exchange for assisting a Turkish client in winning approval for a power plant project in the Republic of Ghana. Berko was arrested in London in November 2022 on charges that had been brought in a sealed indictment filed in the Eastern District of New York in August 2020. In July 2024, DOJ announced the extradition of Berko, a dual citizen of the United States and Ghana, from the UK to the United States to stand trial. Berko argued in his motion that the indictment was improperly sealed, and his arrest wrongly delayed, resulting in untimely allegations and violations of his Sixth Amendment right to a speedy trial. The court found that prosecutors had acted reasonably in locating and arresting him. The judge also rejected Berko’s request to suppress all evidence obtained pursuant to a search warrant for his personal email account, finding that the magistrate judge had enough reason to determine the existence of probable cause when issuing the warrant. In June 2021, Berko resolved related allegations with the SEC, agreeing to pay approximately $329,000 without admitting or denying the SEC’s charges.

7. U.S. Government Terminates Two Foreign Bribery Cases

• Texas Congressman Facing Dozens of Corruption Charges Is Pardoned
  
  On December 3, 2025, President Trump announced the pardon of U.S. Congressman Enrique Roberto “Henry” Cuellar and his wife in a federal bribery and conspiracy case. In May 2024, DOJ unsealed an indictment in the Southern District of Texas charging Congressman Cuellar and his wife for participating in two schemes involving bribery, unlawful foreign influence, and money laundering. Over seven years, Congressman Cuellar and his wife allegedly accepted approximately $600,000 in bribes from two foreign entities, an oil and gas company owned and controlled by the government of Azerbaijan and a bank headquartered in Mexico City. In return for these bribes, Congressman Cuellar allegedly agreed to influence U.S. foreign policy to benefit Azerbaijan and to manipulate legislative activities to favor the Mexican bank. The couple’s criminal trial had been set to begin in April 2026.
• DOJ Moves to Dismiss Foreign Bribery Charges in International Soccer Corruption Case
  
  On December 9, 2025, DOJ moved to dismiss, with prejudice, charges against two defendants prosecuted as part of the global bribery scandal involving the Fédération Internationale de Football Association (FIFA) and affiliated continental and regional soccer confederations. In March 2023, a jury in the Eastern District of New York convicted Full Play Group, S.A. (Full Play), an Argentine sports marketing company, and Hernan Lopez, the former CEO of Fox International Channels, on wire fraud and money laundering charges stemming from an alleged scheme to bribe South American soccer officials to obtain soccer broadcasting rights. In September 2023, the district court overturned the convictions, finding that the intangible right to honest services under 18 U.S.C. § 1346 did “not extend to foreign commercial bribery.” DOJ appealed, and the U.S. Second Circuit Court of Appeals reinstated the convictions in July 2025, holding that 18 U.S.C. § 1346 did extend to foreign bribery cases.
  
  In September 2025, however, Full Play and Lopez petitioned the U.S. Supreme Court to again review the convictions. They urged the Court to reject DOJ’s reading of the honest services wire fraud statute and hold that a private code of conduct applying to foreign employees—in this case, FIFA’s code of ethics—is insufficient to establish a fiduciary duty subject to the honest services wire fraud statute. Because the statute should not be read to govern breaches of foreign fiduciary duties, they argued, it should not be extended to foreign commercial bribery. After requesting and receiving two extensions from the Supreme Court to file a reply brief, DOJ on December 9 submitted its motion in the Eastern District of New York to dismiss the case with prejudice. In the one-page motion, DOJ explained that it “has determined in its prosecutorial discretion that dismissal of this criminal case is in the interests of justice.” The same day, DOJ filed a reply brief in the Supreme Court requesting that the Court grant Full Play’s and Lopez’s certiorari petitions, vacate the Second Circuit’s decision, and remand the cases to allow the district court to grant DOJ’s motion to dismiss. The district court noted in a December 16, 2025 scheduling order that it intends to defer ruling on DOJ’s motion until the Supreme Court resolves the pending petitions[3]
  
  (For more on this prosecution, see our April 2020, January 2022, March 2023, September 2023, and July 2025 Top 10s. For more on an earlier trial involving allegations of bribery in international soccer, see our November 2017, December 2017, and June 2020 Top 10s. For more on the potential impact of recent Supreme Court decisions on foreign bribery cases, see our article Applying High Court’s Domestic Corruption Rulings to FCPA.)

8. Mistrial Declared in Case Against New York State Official Charged for Allegedly Laundering Benefits from Chinese Government

On December 22, 2025, a judge in the Eastern District of New York declared a mistrial in the corruption case against Linda Sun, a former senior New York state official who served in multiple roles, including as deputy chief of staff for the sitting governor, Kathy Hochul, and as an aid to the administration of Hochul’s predecessor, Andrew Cuomo. After a nearly monthlong trial, the jury deadlocked on all 19 counts. Prosecutors told the court that the government intends to retry the case “as soon as possible.” Sun was initially charged in September 2024 in connection with allegations that she acted on behalf of the People’s Republic of China (PRC) to influence the policies and practices of the state of New York and laundered millions of dollars in the process. In June 2025, the government announced a second superseding indictment, charging Sun with committing and conspiring to commit honest services wire fraud and bribery, as well as conspiring to defraud the United States, alleging that Sun used her position of influence with the New York state government during the COVID-19 pandemic to procure contracts for personal protective equipment (PPE) from vendors located in the PRC. Two of these vendors allegedly had direct ties to Sun and her family, which she concealed by falsifying documents and claiming the referrals were from the PRC government. With Sun’s alleged assistance, these vendors were awarded millions of dollars in contracts with the New York state government, which also allegedly resulted in the payment of approximately $2.3 million in kickbacks to Sun and her co-defendant—Sun’s husband, Chris Hu—who faced similar charges.

9. Senate Confirms New Head of DOJ’s Criminal Division

On December 18, 2025, the Senate confirmed President Trump’s pick to lead the Justice Department’s Criminal Division, Tysen Duva. Duva specialized in public corruption cases as an Assistant U.S. Attorney in Jacksonville, Florida. Because FCPA prosecutions originate from the Criminal Division’s Fraud Section, Duva was questioned about his FCPA enforcement agenda at his October 2025 nomination hearing. Duva testified that, if confirmed, he planned to follow the Deputy Attorney General’s June 2025 FCPA memo, stating that he “would dedicate Fraud Section resources to investigating and prosecuting violations of the FCPA firmly but fairly and consistent with Department policies and priorities.”

10. UK Publishes Anti-Corruption Strategy and Foreign Bribery Guidance

• UK Launches Anti-Corruption Strategy 2025
  
  On December 8, 2025, the UK government released its Anti-Corruption Strategy 2025, outlining wide-ranging commitments to disrupt corruption, illicit finance, and professional enablers while strengthening national security and economic growth. The UK’s plans include using artificial intelligence to accelerate investigations, simplifying the country’s complex regulatory system by consolidating the anti-money laundering and counterterrorist financing supervisory functions, and increasing efforts to dismantle kleptocratic networks by scaling up investigation capacity. The strategy includes a £15 million expansion of the Domestic Corruption Unit within the City of London Police, allowing special officers to take on more investigations and support local forces to detect and disrupt bribery and money laundering networks nationwide. The funding follows an additional £110 million annually from the Economic Crime Levy to tackle economic crime. Deputy Prime Minister David Lammy wrote, “[w]e will now go further to grow the economy, support British businesses, secure our borders, tackle the instability overseas that drives organised crime in the UK, and restore trust in the UK and its institutions.”
• UK SFO Publishes Foreign Bribery Indicator Guidance
  
  On December 22, 2025, the UK SFO and law enforcement partners from across the Five Eyes alliance jointly released guidance titled “Indicators of Foreign Bribery” to help businesses, compliance teams, and the public recognize potential red flags associated with bribery of foreign officials. The guidance was published by the International Foreign Bribery Taskforce, combining information from the SFO, the UK’s National Crime Agency, Australian Federal Police, Royal Canadian Mounted Police, New Zealand Police, New Zealand Serious Fraud Office, and the U.S. Federal Bureau of Investigation. The guidance distills a set of risk factors commonly associated with foreign bribery cases, including disproportionate high-value property ownership, registered charities with the same name as the company, complex corporate ownership structures, unusual secrecy around transactions, and contracts awarded to incapable parties. The indicators are not standalone proof of criminality but are intended to raise awareness of patterns that may warrant further scrutiny. Balinder Matharu, head of Intelligence Analysis at the SFO, said, “[t]his guidance brings together decades of intelligence and investigative experience from the world’s leading law enforcement agencies. Prevention is always better than prosecution, and this collaborative approach demonstrates our commitment to working with our law enforcement partners to tackle economic crime.”

[1] United States v. Oztemel, No. 3:23-cr-26, Docket No. 422 (D. Conn. Dec. 2, 2025).

[2] United States v. Detelina Subeva, et al., Case No. 1:18-cr-00681-NGG, ECF No. 841 (E.D.N.Y. Dec. 12, 2025).

[3] United States v. Webb, et al., Case No. 1:15-cr-00252-PKC (E.D.N.Y. Dec. 16, 2025).