Top 10 International Anti-Corruption Developments for April 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: What does the European Union’s new Anti-Corruption Directive mean for companies operating across Member States? Why did a federal judge acquit a defendant of Foreign Corrupt Practices Act (FCPA) charges post-trial in a case involving an alleged Mexican bribery scheme? How many FCPA cases did the U.S. Securities and Exchange Commission (SEC) report bringing in Fiscal Year (FY) 2025? The answers to these questions and more are here in our April 2026 Top 10.

1. European Union Adopts Bloc-Wide Anti-Corruption Directive

On April 21, 2026, the European Union adopted the new Anti-Corruption Directive (the “Directive”), taking a significant step toward a more harmonized EU anti-corruption framework. One of the Directive’s main goals is to close enforcement gaps by aligning national anti-corruption laws to a minimum standard and by promoting stronger cooperation between national authorities and EU institutions. The Directive establishes a broad corporate liability framework under which companies can be held responsible not only for misconduct by senior individuals but also for failures in supervision or control. It introduces significant financial penalties of up to 5% (bribery) or 3% (trading in influence) of worldwide turnover (or EUR 40 million/EUR 24 million), alongside additional sanctions such as exclusion from public procurement, withdrawal of permits, and business restrictions. It also introduces longer limitation periods of up to eight years, increasing exposure for past conduct and raising the importance of thorough compliance and due diligence, particularly in M&A transactions. While enforcement will continue to take place at the national level, the Directive is expected to significantly expand Member States’ jurisdiction in cross-border cases, reduce fragmentation, and promote more consistent enforcement across jurisdictions. Robust compliance programs will be critical, as the Directive provides that effective measures may serve as a mitigating factor in enforcement proceedings. Member States must transpose the Directive into national law within the next two years. The degree of harmonization throughout the EU will depend on how Member States transpose the Directive and enforce its provisions as they continue to have considerable discretion in this regard. (For more on this Directive, see our client alert.)

2. Texas Businessman Acquitted After Guilty Verdict in Mexico Bribery Case

On April 14, 2026, a judge in the Southern District of Texas dismissed the indictment against Ramon Alexandro Rovirosa Martinez and entered a judgment of acquittal following his December 2025 conviction by a jury on one count of conspiracy to violate the FCPA and two counts of violating the FCPA in connection with an alleged scheme to bribe officials at Mexico’s state-owned oil company, Petróleos Mexicanos (PEMEX), and its subsidiary, Pemex Exploración y Producción (PEP). The court held that the admission of English translations of electronic messages involving Rovirosa and his alleged co-conspirators, in the absence of testimony from the translators, violated Rovirosa’s Sixth Amendment right to confront the witnesses against him.

This ruling appears open to challenge on appeal. First, the emails themselves should be non-hearsay under Federal Rule of Evidence 801(d)(2) because they were offered against the defendant and were either statements of the defendant or statements of the defendant’s co-conspirators made during and in furtherance of the conspiracy. Second, the usual procedure for disputed translations is to allow both sides to submit their own translations to the jury. Third, to the extent that it believed that testimony from the government’s translators was nevertheless necessary, the court could have either required such testimony during the trial or ordered a new trial during which such testimony could be elicited; an acquittal may be viewed as an overly severe outcome under the circumstances. Even if not reversed, the order relates simply to an evidentiary issue and does not implicate any substantive FCPA issues. (The same judge was reversed in February 2023 for dismissing FCPA charges in another case. For more on the Rovirosa case, see our August 2025, September 2025, October 2025, and December 2025 Top 10s.)

3. Former Oil Industry Executive Ordered to Forfeit Funds Related to Mexico Bribery Scheme

On April 14, 2026, Diego Bergonzi, a U.S.-Italian dual citizen and former sales executive at Italian oil company Drillmec, was ordered to forfeit $1,019,757.60 to the United States in connection with an alleged bribery scheme connected to PEMEX and PEP, the same state-owned companies involved in the Rovirosa case discussed above.[1] In January 2025, the U.S. Department of Justice (DOJ) filed sealed charges in the Southern District of Texas alleging that Bergonzi, together with seven co-conspirators, worked through intermediary companies to bribe a senior PEMEX executive to help secure a contract worth over $500 million.[2] Between April and July 2023, Bergonzi was paid approximately $1.6 million in kickbacks by the intermediary companies. Bergonzi waived indictment and admitted to the charges in June 2025.[3] In March 2026, DOJ filed an FCPA conspiracy charge against one of the assumed co-conspirators, Alfonso Wilson, who later pleaded guilty. Wilson’s guilty plea and the allegations regarding five other co-conspirators suggest that charges against additional individuals will follow.

4. Former Waste Management Executive Extradited, Pleads Not Guilty in Latin America Bribery Case

On April 24, 2026, Abraham Cigarroa Cervantes, a Mexican citizen and former finance director at Stericycle, Inc., an Illinois-based international waste management company, was arraigned[4] in the Southern District of Florida on charges related to his alleged participation in a years-long scheme to pay more than $10 million in bribes to government officials in Argentina, Brazil, and Mexico to support the company’s bid for government contracts for medical waste collection. In March 2024, DOJ announced that Cigarroa had been indicted on charges that he conspired to violate the anti-bribery and books-and-records provisions of the FCPA. According to the indictment, Cigarroa and others typically paid the bribes in cash and tracked the payments through spreadsheets with code words. According to an April 29, 2026, court filing[5] by DOJ, Cigarroa was arrested in Argentina and subsequently extradited to Miami on April 23, 2026. Cigarroa’s supervisor, Mauricio Gomez Baez, pleaded guilty in February 2024 to one count of conspiracy to violate the FCPA’s anti-bribery provisions. Stericycle resolved related allegations with DOJ and SEC in April 2022, agreeing to pay $84 million in penalties.

5. DOJ Seeks Forfeiture of Beverly Hills Mansion Allegedly Linked to Iraq Bribery Scheme

On April 22, 2026, DOJ announced that it had filed a civil forfeiture complaint in the Central District of California seeking forfeiture of a Beverly Hills mansion allegedly purchased and renovated with $30 million obtained from a scheme to defraud the U.S. Department of Defense’s Defense Logistics Agency (DLA). According to the complaint, from 2016 to 2020, a Virginia-based defense contractor and others engaged in a corrupt scheme and conspiracy to obtain and retain over $700 million from DLA in connection with fuel-delivery services to the U.S. military during operations against the Islamic State in the Kurdistan region of Iraq. The complaint alleges that officers of the contractor paid General Mansour Barzani, a senior official in the Kurdish Peshmerga forces—which controlled the airport hosting U.S. military fuel deliveries—a bribe of $0.25 per liter of jet fuel for exclusive access to service the DLA contracts. DOJ alleges that the contractor transferred funds it received from DLA to a trust in Virginia for Barzani’s benefit, and that $30 million was transferred from the trust to purchase and renovate the Beverly Hills mansion.

6. U.S. Appellate Court Affirms FCPA Books-and-Records Conviction for Former Illinois House Speaker

On April 27, 2026, the U.S. Court of Appeals for the Seventh Circuit upheld the February 2025 trial conviction of Michael J. Madigan, former Speaker of the Illinois House of Representatives, on several corruption-related counts, including one count of conspiracy to violate the FCPA’s books-and-records provision. DOJ presented evidence at trial that Chicago-based utility Commonwealth Edison (ComEd) funneled payments through intermediaries to Madigan’s allies for little to no work in exchange for Madigan’s support in advancing ComEd’s legislative priorities and that ComEd created false books and records in connection with those payments. The Seventh Circuit found this evidence sufficient to support Madigan’s conviction on the books-and-records conspiracy. In September 2023, ComEd and its parent company agreed to a $46.2 million civil penalty to resolve FCPA accounting charges, among others, allegedly related to Madigan—a reminder that the FCPA’s accounting provisions can reach more than just foreign bribery offenses.

7. SEC Reports Six FCPA Enforcement Actions for FY2025

On April 7, 2026, the SEC released its enforcement results for FY2025 (ending September 30, 2025). Of 456 enforcement actions, more than half were filed between October 2024 and Inauguration Day. Six of those enforcement actions were classified by the SEC as FCPA enforcement actions, up from two FCPA actions in FY2024 and down from 11 in FY2023. The six enforcement actions were brought against U.S. motion controls systems manufacturer Moog Inc. (October 2024), U.S. defense contractor RTX Corporation (October 2024), China online sports betting company BIT Mining Ltd. (November 2024), Cyril Cabanes, an executive of Indian renewable energy company Azure Power Global Limited (November 2024), U.S. aviation company AAR Corp. (December 2024), and Deepak Sharma, a former executive of an AAR subsidiary (December 2024). In commentary to the results, the SEC expressed its disapproval of cases brought under the Biden administration, which it stated were “not sufficiently grounded in the federal securities laws.” The SEC criticized the prior Commission for bringing several books-and-records cases with significant penalties which “identified no direct investor harm . . . produced no investor benefit or protection, and demonstrate . . . a bias for volume of cases brought versus matters of investor protection.”

8. Spanish Court Acquits Corporate and Individual Defendants on Angola Bribery Counts

On April 28, 2026, Spain’s National Court announced that it had acquitted three companies and 15 individuals of bribing foreign officials in Angola between 2006 and 2016 in exchange for the construction of a wholesale market through the public food-distribution company Mercasa. The court concluded that construction work for the market was carried out in accordance with the law and the existence of bribes was not proven beyond speculation and hypotheses. Among other things, the court found that there had been “an excessive demonization” of the commissions agreed upon in the contracts.

9. Swiss Court Dismisses Case Against Daughter of Former Uzbek President, Continues Trial Against Bank and Former Employee

On April 28, 2026, a Swiss court dismissed the proceedings against Gulnara Karimova, the daughter of former Uzbek President Islam Karimov. Swiss authorities announced money laundering and bribery charges against Karimova in September 2023, alleging that she had “exploited her dual status as the daughter of the President and as an Uzbek public official” to demand bribes of companies wishing to enter and operate in the Uzbek telecommunications sector beginning in 2000 and that some of the corrupt proceeds were ultimately transferred into Swiss bank accounts for her benefit. The dismissal was based on Karimova’s continued imprisonment in Uzbekistan on convictions including embezzlement. Uzbek authorities indicated she would not be released until her full sentence is completed, at which point the statute of limitations for the Swiss charges will have expired. The proceedings will continue against Swiss private bank Lombard Odier and a former employee for their role in Karimova’s activities. (See our April 2015, September 2017, October 2018, March 2019, and September 2023 Top 10s for additional coverage on Karimova-linked cases.)

10. Singapore High Court Approves DPA Resolving Allegations of Corrupt Payments to Brazilian Authorities

On April 24, 2026, Singapore-based offshore, marine, and energy company Seatrium Limited disclosed in a securities filing that the Singapore High Court had approved the DPA between the company and the Singapore Attorney-General’s Chambers (AGC), signed in July 2025, to resolve an investigation into allegedly corrupt payments made by Seatrium’s Brazilian subsidiary to secure oil rig and other energy contracts. Among other things, the DPA includes provisions requiring the company to cooperate with law enforcement through the end of the DPA term and to ensure that its anti-bribery management system is certified to the International Organization for Standardization (ISO) 37001 standard or the Singapore Standard for ISO 37001 by an accredited certification body acceptable to the AGC. The company will also pay a US$110 million penalty, with US$57 million going to Singapore authorities and the remainder being a credit to offset fines paid to Brazilian authorities; in a previous securities filing from July 2025, the company said it signed a leniency agreement with the Brazilian Federal Prosecution Service (MPF) and expects to sign similar agreements with other Brazilian agencies. Singapore’s Corrupt Practices Investigation Bureau investigated Seatrium and individuals linked to the company for paying bribes to further the company’s interests in Brazil. In March 2024, two former company executives were charged in Singapore with related corruption offenses.

[1] Agreed Order Imposing Money Judgment, United States v. Diego Bergonzi, Case No. 4:25-cr-00020, ECF No. 55 (S.D. Tex. Apr. 14, 2026).

[2] Information, United States v. Diego Bergonzi, Case No. 4:25-cr-00020, ECF No. 1 (S.D. Tex. Jan. 23, 2025).

[3] Waiver of Indictment, United States v. Diego Bergonzi, Case No. 4:25-cr-00020, ECF No. 30 (S.D. Tex. June 30, 2025).

[4] Minute Order, United States v. Cervantes, Case No. 1:24-cr-20109, ECF No. 10 (S.D. Fla. Apr. 24, 2026).

[5] Unopposed Motion for Protective Order, United States v. Cervantes, Case No. 1:24-cr-20109, ECF No. 16 (S.D. Fla. Apr. 29, 2026).