Top 10 International Anti-Corruption Developments for February 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: Did the U.S. Department of Justice (DOJ) continue its streak of trial victories in cases related to the Foreign Corrupt Practices Act (FCPA)? Why did foreign bribery prosecutions fail in the United Kingdom (UK) and Belgium? What countries finished at the top and at the bottom of the latest Transparency International (TI) Corruption Perceptions Index (CPI)? The answers to these questions and more are here in our February 2026 Top 10.

1. U.S. Jury Convicts Former Coal Executive in Egyptian FCPA Bribery and Money Laundering Scheme

On February 19, 2026, DOJ announced that Charles Hunter Hobson, the former vice president responsible for international sales at Corsa Coal Corporation, was found guilty after a trial in the Western District of Pennsylvania on seven FCPA and money laundering counts in connection with his efforts to bribe Egyptian officials to secure nearly $140 million in coal supply contracts from state-owned Al Nasr Company for Coke and Chemicals. According to DOJ, between 2016 and 2020, Hobson caused an intermediary in Egypt to receive more than $4.8 million in purported sales commissions, which were used to pay bribes to the officials, as well as $200,000 in kickbacks to Hobson himself. DOJ announced Hobson’s arrest in March 2022 and, in April 2025, stated that it intended to proceed to trial against him, despite the February 2025 Executive Order pausing FCPA enforcement. Another Corsa Coal vice-president responsible for international sales, Frederick Cushmore Jr., pleaded guilty to related charges in November 2021, and DOJ declined to proceed against the company in March 2023. This trial victory underscores DOJ’s sustained focus on individual accountability in serious foreign bribery schemes, as well as its continued run of success in FCPA-related trials. (See, e.g., our December 2025 Top 10 and September 2025 article for more on DOJ’s recent FCPA-related trial victories.)

2. Two Companies Announce Declinations in FCPA Investigations

• Indian Pharmaceutical Company Announces Declination. In a February 24, 2026 Form 6-K filing, Dr. Reddy’s Laboratories Ltd. disclosed that the U.S. Securities and Exchange Commission (SEC) had informed the company the previous day that it had concluded its investigation concerning allegations of improper payments to healthcare professionals in Ukraine and potentially in other countries. Dr. Reddy’s disclosed the matter to DOJ, SEC, and the Securities Exchange Board of India.
• Michigan-Based Medical Device Company Announces Declination. In a February 11, 2026 Form 10-K filing, Stryker Corporation disclosed that it was informed in 2025 by SEC and DOJ that each had closed its inquiries into potential FCPA violations “in certain foreign countries.” The company had previously reported the DOJ declination in a May 2025 securities filing.

3. U.S. Lawmakers Urge DOJ to Increase Enforcement of the Foreign Extortion Prevention Act (FEPA)

On February 6, 2026, bipartisan members of the U.S. Helsinki Commission, a U.S. government commission that promotes human rights, military security, and economic cooperation in 57 countries in Europe, Eurasia, and North America, announced that they had sent a letter to the U.S. Attorney General to urge “robust enforcement” of FEPA, which criminalizes foreign officials’ solicitation of bribes from U.S. persons and issuers. The lawmakers argued that FEPA enforcement is central to advancing key priorities of the Trump administration, including those outlined in the President’s February 2025 memo on “Defending American Companies and Innovators from Overseas Extortion and Unfair Fines and Penalties,” and the DOJ Criminal Division’s May 2025 memo outlining its white-collar enforcement priorities. The letter also argued that FEPA enforcement was particularly important for the energy, mining, and defense sectors, and for advancing U.S. national security interests, including by prioritizing FEPA cases involving foreign adversaries, sanctions evasion, and corruption that undermines U.S. businesses abroad. (As we discuss, the letter from the Helsinki Commission appears to be consistent, at least in part, with the June 2025 FCPA Enforcement Guidelines, which direct prosecutors to “consider [in bringing FEPA charges] whether specific and identifiable U.S. entities or individuals have been harmed by foreign officials’ demands for bribes.”) The reason for the timing of the Helsinki Commission’s letter is unclear, but lawmakers (and perhaps their constituents) might be concerned that DOJ has not brought any public charges under FEPA since its enactment in December 2023.

4. SDNY Publishes Corporate Enforcement and Voluntary Self-Disclosure Policy

On February 24, 2026, the U.S. Attorney’s Office for the Southern District of New York (SDNY) published its “Corporate Enforcement and Voluntary Self-Disclosure Program for Financial Crimes” policy. Similar to corporate enforcement policies from other DOJ components, the SDNY policy is meant to “encourage early voluntary self-disclosure of criminal conduct, to promote timely and effective enforcement of criminal laws, to encourage repayment of victims, and to provide companies with greater certainty when reporting potential financial misconduct to federal prosecutors.” Under the policy, SDNY will provide what it describes as a “conditional” declination letter within two to three weeks after the company self-discloses certain categories of financial fraud and commits to cooperate and remediate the misconduct. The conditional declination can be converted into a final declination if the company fully cooperates and completes restitution to all victims. The policy applies to corporate, securities, or commodities fraud, misconduct involving auditors or financial regulators, or other criminal securities law violations, but does not apply to bribery or money laundering offenses and treats “foreign corruption” as an aggravating circumstance that will render a company ineligible for a declination. Thus, the SDNY policy will likely have little to no impact on FCPA enforcement, although it could have a significant impact in other white-collar areas. (For more on the SDNY policy, see our client alert.)

5. SEC Enforcement Director Outlines Enforcement Priorities and SEC Issues Significant Updates to Enforcement Manual

On February 11, 2026, then-SEC Division of Enforcement Director Margaret Ryan[1] outlined her enforcement priorities during a speech at the Los Angeles County Bar Association’s 56th Annual Securities Regulation Seminar. The speech focused on enforcement of the federal securities laws, the value of the Wells process for evaluation of potential enforcement actions, the need for timely action from defense counsel, and the Division of Enforcement’s continued prioritization of stopping fraud that harms retail investors. The speech did not expressly cover SEC’s plans for FCPA enforcement. (For more on former the speech, see our client alert.) Also on February 24, 2026, the SEC’s Enforcement Division announced what it described as “significant updates” to its Enforcement Manual. Consistent with the speech, the updates to the Enforcement Manual reflect the Commission’s stated goals of improving transparency with the companies it regulates and consistency, fairness, and predictability in the enforcement process. Among other things, the updated Manual revises the process for obtaining a formal order of investigation, the Wells process, and the criteria for self-reporting, cooperation, and remediation credit. The Manual was last updated in 2017. Given SEC’s role in FCPA enforcement, companies and practitioners should be aware of these revisions.

6. UK SFO Drops Foreign Bribery Prosecution and Acknowledges Additional Disclosure-Platform Failings

On February 12, 2026, the UK Serious Fraud Office (SFO) informed the Southwark Crown Court that the SFO was no longer proceeding with the prosecution of London Mining Plc’s former CEO and CFO, along with an international business consultant, for allegedly conspiring to make multiple corrupt payments to secure preferential treatment in Sierra Leone. Following a thorough review, the SFO determined that there was no realistic prospect of conviction. According to the SFO, the decision was based on a combination of factors, including significant delays to trial, difficulties obtaining and reviewing material, and challenges with witness evidence; among other things, these issues appeared related to problems with the SFO’s e-discovery systems, which led to a large number of documents not being examined for potential disclosure to the defense in a timely fashion. Following the SFO’s announcement, the court entered not guilty verdicts against the three defendants. The SFO opened its investigation into the alleged Sierra Leone bribery scheme in 2016 and announced the charges against the three individual defendants in June 2023.

7. UK High Court Refuses Leave to Appeal in First-Ever UK DPA Breach Proceedings

Following its January 2026 decision to uphold a Deferred Prosecution Agreement (DPA) alleged to have expired, the UK High Court has refused leave to appeal to the Supreme Court in the first-ever UK enforcement proceedings alleging a breach of a DPA. As outlined in last month’s Top 10, the case involves Güralp Systems Ltd., which entered into a DPA with the SFO in 2019 concerning allegations of conspiracy to make corrupt payments and failure to prevent bribery. After the SFO brought proceedings alleging that Güralp had breached the terms of that agreement, the High Court upheld the lower court’s jurisdiction to entertain the breach application and later refused Güralp’s application for permission to appeal that ruling to the Supreme Court. This refusal, handed down on February 10, 2026, affirms the court’s willingness to interpret the statutory framework governing DPAs as permitting enforcement actions even after the notional expiration of the agreement where its terms remain enforceable.

8. UK SFO Appoints Interim Director Following Leadership Changes

On February 26, 2026, the SFO announced that its Chief Operating Officer, Graham McNulty, will assume the role of Interim Director on April 6, 2026, following the surprise announcement in January 2026 that current SFO Director Nick Ephgrave would step down early at the end of March 2026. McNulty, who joined the SFO in September 2024, brings extensive law-enforcement experience from a 31-year policing career and has overseen key organizational priorities such as the rollout of the agency’s first case management system and expanded use of artificial intelligence in investigations. This leadership change comes amid broader efforts to sustain momentum on complex economic crime cases and implement strategic priorities in the wake of recent enforcement challenges.

9. Belgian Dredging Company Acquitted in Russian Bribery Case

On February 24, 2026, the Ghent Court of Appeal acquitted DEME Group, a Belgian offshore energy and dredging company, five of its former executives, and an external consultant in a bribery and money laundering case relating to a €420 million contract for the dredging of a canal in Siberia, awarded to a joint venture between DEME and a Russian company. DEME’s competitor for the contract, Jan De Nul NV, filed a criminal complaint with the East Flanders Public Prosecutor’s Office in 2015 or 2016, alleging that email messages demonstrated that DEME and the external consultant had engaged in a bribery scheme during the negotiation phase of the project and later used foreign bank accounts to deliver the bribe payments. The court of first instance dismissed the charges in September 2024 on the grounds that the emails had been illegally obtained by Jan De Nul NV and, therefore, that the emails and the evidence derived therefrom were inadmissible. The Court of Appeal reversed this finding but found on the merits that the defendants were not guilty of public bribery because the bribe recipients were not public officials. The Court of Appeal further held that the prosecution could not prove private bribery because there was no evidence that the acts had occurred without the consent or knowledge of the private company’s board of directors or shareholders.

10. Transparency International Releases Annual Corruption Perceptions Index

On February 10, 2026, Transparency International (TI) published its annual Corruption Perceptions Index (CPI) for 2025. The CPI, which ranks 180 countries and territories around the world by their perceived levels of public sector corruption on a scale of 0 (highly corrupt) to 100 (very clean), provides one of the major data points used by compliance professionals, outside counsel, and enforcement officials in assessing the anti-corruption risk of doing business in particular countries. The top five countries for 2025 were Denmark, leading for its eighth year in a row (89); Finland (88); Singapore (84); New Zealand and Norway with equivalent scores (81); and Sweden and Switzerland also tied (80). The bottom five were South Sudan and Somalia (9, both ranked 181); Venezuela (10, ranked 180); Yemen, Libya, and Eritrea (13, all ranked 177); and Nicaragua and Sudan (14, both ranked 173). As discussed in our client alert examining CPI results in the Asia-Pacific region (APAC), China (43, ranked 76), and Indonesia (34, ranked 109) were two of the countries exhibiting a positive anti-corruption trajectory in the APAC region, however, much of the Southeast Asian region has experienced stagnation or decline from a CPI perspective, apart from Singapore, which is a consistent CPI top performer. At the global level, this year’s global average score was 42, the lowest on record. In particular, TI observed that “[w]hile 31 countries have significantly reduced their corruption levels since 2012, the rest are failing to tackle the problem—they have stayed stagnant or got worse during the same period.” The United States, for example, fell to its lowest ranking ever, 29th, in the CPI for 2025 (64 points); for comparison, the United States was ranked 16th in the CPI for 2017 (75 points).

[1] Ms. Ryan resigned shortly before this Top 10 went to publication.