Top 10 International Anti-Corruption Developments for January 2026

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 many Foreign Corrupt Practices Act (FCPA) enforcement actions did the U.S. Department of Justice (DOJ) bring in 2025? How many Chinese officials faced discipline for alleged corruption offenses in 2025? Why is the director of the UK’s Serious Fraud Office (SFO) stepping down halfway through his tenure? The answers to these questions and more are here in our January 2026 Top 10.

1. DOJ Releases Final Criminal FCPA Statistics for 2025

On January 17, 2026, DOJ’s Fraud Section published its annual Year in Review for 2025. According to the Year in Review, in 2025, the Fraud Section’s FCPA Unit had three corporate enforcement actions, which resulted in total criminal monetary amounts of $122.8 million, down from nine corporate resolutions and $1.357 billion in total U.S. criminal monetary amounts in 2024. According to the Year in Review, one of 2025’s three corporate enforcement actions, the Smartmatic case in October 2025, was “the Section’s first corporate indictment in fifteen years.” This appears to be a reference to the Lindsey Manufacturing indictment in 2010; however, the Fraud Section also indicted Cinergy Telecommunications as part of the Haiti Teleco line of cases in 2011. The Year in Review also noted the Liberty Mutual declination with disgorgement from August 2025. According to the Year in Review, the FCPA Unit charged five individuals and convicted six individuals, down from 23 individuals charged and 16 individuals convicted in 2024. The Year in Review noted that the FCPA Unit “conducted a thorough review of its cases” following the February 2025 Executive Order pausing FCPA enforcement “and carried out fair and firm enforcement during the second half of the year” under the Deputy Attorney General’s Guidelines for Investigations and Enforcement of the FCPA, issued in June 2025. According to the Year in Review, “[t]he throughline from this record of enforcement is clear. The Criminal Division is prosecuting FCPA violations, consistent with the Deputy Attorney General’s Guidelines, in a way that vindicates U.S. interests by ensuring that criminal actors in this space are held to account. We are enforcing this law firmly, fairly, and efficiently—regardless of the identity of the offender, in a way that promotes the rule of law and ensures an equal playing field so that companies win business based on merits.”

2. After Service Standoff, SEC Moves Forward in Securities Case Related to India Bribery Allegations

In November 2024, the U.S. Securities and Exchange Commission (SEC) announced enforcement actions related to an alleged bribery scheme involving a large solar energy project in India associated with two Indian renewable energy companies, one of which was Adani Green Energy Ltd. SEC filed two related complaints in the Eastern District of New York, one of which alleged that Gautam and Sagar Adani violated various provisions of the Securities Act and the Exchange Act related to the project. After more than a year of unsuccessful attempts to serve the Adanis in India under the Hague Convention, SEC moved on January 21, 2026, for an order authorizing alternative service under Federal Rule of Civil Procedure 4(f)(3), representing that India’s Ministry of Law and Justice had twice declined to effect service.[1] On January 23, 2026, U.S. counsel for the Adanis agreed to accept service, effectively mooting the SEC’s motion. The parties subsequently filed a stipulation and proposed order providing defendants 90 days to move to dismiss or otherwise respond, while expressly preserving defenses, including personal jurisdiction challenges.[2] These events suggest that the SEC case will likely move forward, but the DOJ case against the Adanis appears to remain in limbo, at least publicly.

3. Ex-NATO Official and Turkish Defense Contractor Indicted in Bribery Scheme Tied to U.S. & NATO Military Contracts

On January 26, 2026, DOJ announced the unsealing of an indictment,[3] filed in the United States District Court for the District of Columbia, against Bahadir Hatipoglu and Ralf Grywnow, charging each with conspiracy to commit wire fraud and four counts of wire fraud in connection with a years-long bribery scheme involving U.S. military and NATO construction contracts. According to the indictment, Hatipoglu, a Turkish national who owns companies that received construction contracts with NATO and the U.S. military, bribed Grywnow, a German national and former NATO procurement official, with cash, a romantic encounter in Dubai, and assistance building and furnishing Grywnow’s home in Poland in exchange for favorable treatment. Grywnow also allegedly falsified performance reviews of Hatipoglu’s companies to conceal deficiencies and ensure continued eligibility of Hatipoglu-affiliated entities for defense construction projects that helped Hatipoglu win or retain lucrative military and NATO contracts. DOJ stated that Hatipoglu and Grywnow were arrested on provisional arrest warrants in Lithuania and Poland, respectively, and that it is working with local authorities to extradite them to the United States. The indictment underscores DOJ’s continued focus on corruption in defense, procurement, and multinational contracting, particularly where U.S. funds or allied defense spending are involved. (Although designated as a “public international organization” for some purposes, NATO does not fall within the FCPA’s definition of that term and, therefore, Grywnow was not a “foreign official” for purposes of the FCPA. Even if he were, it does not appear that there would be jurisdiction for an FCPA charge. Hatipoglu’s company does not appear to have been an “issuer,” neither Hatipoglu nor his companies were “domestic concerns,” and although there was a nexus to the United States for purposes of the wire fraud statute—including the use of a U.S.-based messaging app in furtherance of the alleged bribery scheme—none of the alleged conduct appears to have taken place “while in the territory of the United States.” And that ends the FCPA-issue spotter exam portion of this Top 10.)

4. Convicted Oil Trader Ordered to Forfeit Over $1.7 Million in Brazilian Bribery Case

On January 13, 2026, the United States District Court for the District of Connecticut entered a final order of forfeiture against Glenn Oztemel,[4] who was convicted by a jury of FCPA and money laundering counts in September 2024 and sentenced to 15 months in prison in December 2025. Oztemel was ordered to forfeit $1,709,138, which DOJ stated was “equal to the amount of U.S. dollar bribes paid to Rodrigo Berkowitz in connection with the charged scheme.”[5] DOJ alleged that Oztemel funneled bribe payments to 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. Berkowitz testified against Oztemel at trial, which the district court found significant in denying Oztemel’s motion for acquittal or new trial in August 2025.

5. U.S. Supreme Court Clears the Way for Dismissal of Bribery and Money Laundering Charges in International Soccer Case

In December 2025, DOJ moved the United States District Court for the Eastern District of New York to dismiss, with prejudice, charges against two defendants, Hernán López and Full Play Group, who were convicted at trial in March 2023 in connection with the global bribery scandal involving the Fédération Internationale de Football Association (FIFA) and affiliated continental and regional soccer confederations. On the same day, DOJ asked the Supreme Court to grant the defendants’ cert. petition challenging the Second Circuit’s July 2025 decision upholding their convictions, vacate, and remand the case to allow the district court to grant the motion to dismiss. On January 12, 2026, the U.S. Supreme Court granted DOJ’s request as to both López and Full Play, paving the way for dismissal.

6. UK SFO Director Nick Ephgrave to Step Down Early

On January 15, 2026, Nick Ephgrave, Director of the UK SFO, announced that he will retire at the end of March 2026, approximately two-and-a-half years before the scheduled end of his tenure. Ephgrave, whose appointment was announced in July 2023 and whose service began in September 2023, stated that there was no single factor behind his decision and denied that he was being pushed out, describing the move as a personal decision after 38 years in public service. During Ephgrave’s tenure, the SFO announced 12 new investigations and made 34 arrests. Ephgrave championed U.S.-style reforms, including new deferred prosecution agreement guidance published in April 2025 encouraging corporate self-reporting and helped establish a new anti-corruption taskforce with Swiss and French authorities in March 2025. His early departure introduces a measure of uncertainty for several cases that are scheduled for trial in the coming years, though Ephgrave stated that he believes the agency is headed in the right direction. A new director has not yet been announced.

7. UK High Court Ruling Upholds SFO’s Ability to Enforce DPA Terms

On January 13, 2026, the UK High Court held that the SFO could enforce its 2019 Deferred Prosecution Agreement (DPA) with Güralp Systems Limited, rejecting the company’s argument that the DPA expired in October 2024 and could not be enforced. According to the Statement of Facts accompanying the DPA, from 2003 to 2015, the company paid Dr. Heon‑Cheol Chi, the director of the Earthquake Research Center at the Korea Institute of Geoscience and Mineral Resources, approximately $1 million in concealed “technical advice fees” to recommend the company’s products, influence specifications, advise on bid strategy and pricing, and provide non‑public information. (Chi was convicted in the United States in July 2017 of laundering the bribes that he received from Güralp and another company. In August 2018, DOJ declined to prosecute Güralp in light of its anticipated resolution with the SFO.) The SFO alleged, and the company did not dispute, that the company had failed to pay approximately £2 million in disgorgement required under the DPA. The court held that a DPA only expires if a company has fully complied with its terms and that a DPA must remain in force for the purpose of dealing with a breach of contract. Therefore, the SFO’s application for a determination that the company had breached the DPA was not too late, even though it was filed in November 2024, after the DPA was scheduled to end. The ruling thus strengthens the SFO’s ability to enforce the terms of a DPA in the face of an alleged breach.

8. Bribery Trial of Former Nigerian Official Begins in the UK

On January 26, 2026, the corruption trial of former Nigerian Minister of Petroleum Resources Diezani Alison-Madueke began at Southwark Crown Court in London. Alison-Madueke, who served as Nigeria’s oil minister from 2010 to 2015 and chaired the Organization of the Petroleum Exporting Countries (OPEC) in 2014 to 2015, faces five counts of accepting bribes and one count of conspiracy to commit bribery. The UK National Crime Agency (NCA) announced the charges against Alison-Madueke in August 2023. According to the NCA, Alison-Madueke received at least £100,000 in cash, along with “financial or other advantages,” including private jet flights, chauffeur-driven cars, the use and refurbishment of London properties, luxury goods, and school fees for her son, in exchange for the awarding of multimillion-pound oil and gas contracts during her time in office. The trial is expected to last several weeks and could result in a sentence of up to 10 years’ imprisonment and/or an unlimited fine if she is convicted.

9. Norwegian Prosecutors Move Forward in Congo Bribery Case After DOJ Closes FCPA Inquiry

On January 26, 2026, Norway’s National Authority for Investigation and Prosecution of Economic and Environmental Crime (Økokrim) announced that it had indicted two Norwegian citizens and a wholly owned subsidiary of PetroNor E&P ASA (PetroNor) for gross corruption in connection with oil licenses in the Republic of Congo. According to Økokrim, the bribes to the President of Congo and his close family members began in 2016 and were linked to efforts to obtain oil licenses. Økokrim noted that Norway does not have jurisdiction to prosecute the bribe recipients. In April 2025, PetroNor announced that DOJ had closed its FCPA investigation into the company. The Norwegian indictment is a reminder that a DOJ declination does not necessarily bring a matter to a close, particularly in cross-border corruption cases where non-U.S. authorities may still choose to press ahead. Indeed, we suspected at the time of PetroNor’s announcement that DOJ might have declined prosecution in deference to the Norwegian authorities, pursuant to the Executive Order’s admonition against “wast[ing] limited prosecutorial resources” in FCPA cases, a principle later reflected in the FCPA Guidelines direction to prosecutors to consider the likelihood that a foreign law enforcement authority “is willing and able to investigate the same alleged misconduct,” which we interpret to mean that DOJ will be less likely to pursue cases where a competent foreign authority is willing to do so.

10. China Vows to Continue Aggressive Anti-Corruption Push

On January 14, 2026, the Central Commission for Discipline Inspection (CCDI), the Chinese Communist Party’s disciplinary body, called for reinforced anti-corruption efforts and directed intensified political oversight, discipline enforcement, and anti-graft measures. One theme from Chinese authorities was the need to focus on “invisible graft,” which includes shadow companies (companies operated by officials through family members or through behind-the-scenes manipulation), complex financial derivatives, and the use of connections, resources, or influence to seek personal gain, such as officials taking positions in companies they once regulated. Chinese authorities also released prosecution figures for 2025, a year during which China intensified anti‑corruption efforts in key sectors, such as energy, finance, firefighting, higher education, pharmaceuticals, sports, state-owned enterprises, and tobacco. A record 65 senior officials were detained in 2025, a 12 percent rise from 2024 and 260 percent rise from 2020. Reflecting China’s efforts to crack down on corruption that impacts the daily lives of ordinary people, 536,000 low‑level officials were also disciplined, and 20,000 were referred for prosecution, between January and November 2025. During the same time frame, China repatriated 782 fugitives and recovered approximately $3 billion in illicit assets. Chinese authorities vowed “no pause or retreat” in their anti-corruption efforts in 2026. 

[1] SEC v. Gautam Adani and Sagar Adani, Case No. 1:24-cv-08080-NGC-JRC, ECF No. 14 (E.D.N.Y. Jan. 21, 2026).

[2] SEC v. Gautam Adani and Sagar Adani, Case No. 1:24-cv-08080-NGC-JRC, ECF No. 21 (E.D.N.Y. Jan. 30, 2026).

[3] United States v. Bahadir Hatipoglu and Ralf Grywnow, Case No. 1:25-cr-00289-JDB, ECF No. 1 (D.D.C. Sept. 16, 2025).

[4] United States v. Oztemel, Case No. 3:23-cr-00026-KAD, ECF No. 455 (D. Conn. Jan. 13, 2026).

[5] United States v. Oztemel, Case No. 3:23-cr-00026-KAD, ECF No. 446 (D. Conn. Jan. 6, 2026).