Top 10 International Anti-Corruption Developments for September 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: Why did a federal judge again refuse a motion by the U.S. Department of Justice (DOJ) to dismiss Foreign Corrupt Practices Act (FCPA) charges arising from an alleged Indian bribery scheme? Why was a U.S. Securities and Exchange Commission (SEC) whistleblower denied a monetary award in a successful foreign bribery case? How is China expanding international cooperation against corruption while considering a new cross-border corruption law? The answers to these questions and more are here in our September 2026 Top 10.

1. Court Again Rejects DOJ Request to Dismiss India-Related FCPA Charges

On September 3, 2026, Eastern District of New York Judge Nicholas G. Garaufis again declined to dismiss FCPA and obstruction charges arising from an alleged bribery scheme involving a solar energy project in India. DOJ moved in May 2026 to dismiss all charges related to that alleged scheme. In August 2026, the court dismissed fraud-related charges against defendants who had appeared in the case but required DOJ to provide additional factual support for its request to dismiss FCPA conspiracy charges against five defendants who had not appeared and obstruction charges against four of them. The court concluded that DOJ had “refus[ed] to provide additional facts as requested in the August 10 order” and instead “resubmit[ted] the proffered reasons already rejected by this Court[.]” The court denied DOJ’s motion without prejudice and “continue[d] to encourage the Department to submit sufficient factual support for its proffered reasons for dismissal.” On September 28, 2026, DOJ petitioned the U.S. Court of Appeals for the Second Circuit for a writ of mandamus directing the district court to grant DOJ’s motion to dismiss the remaining charges.

2. Maduro Ally Pleads Guilty in Venezuelan Public-Contract Bribery Scheme

On September 15, 2026, DOJ announced that Alex Nain Saab Moran, a former Venezuelan Minister of Industry and ally of former Venezuelan President Nicolás Maduro, had pleaded guilty in the Southern District of Florida to conspiracy to launder proceeds of a bribery and fraud scheme involving a Venezuelan government food-and-medicine program. Saab admitted that he organized bribes and other illegal payments to Venezuelan public officials so that entities that were secretly controlled by the conspirators could obtain lucrative government contracts to import food and medicine under Venezuela’s Comité Local de Abastecimiento y Producción (CLAP) program. According to DOJ, the conspirators failed to deliver fully on the contracts and used fake companies, false invoices, false shipping records, and other fraudulent documents to skim hundreds of millions of dollars, which Saab helped launder through shell companies outside Venezuela, including through the United States. Saab faces up to 20 years’ imprisonment. As part of his plea agreement, he agreed to forfeit $195 million and to cooperate with ongoing U.S. investigations. Saab had previously been charged in the United States in July 2019 in connection with another bribery and money laundering scheme but was granted clemency and released to Venezuela in December 2023 as part of a prisoner exchange also involving the return of Leonard Glenn (“Fat Leonard”) Francis, who had fled to Venezuela to avoid sentencing in a U.S. Navy bribery scheme. DOJ obtained a new indictment against Saab in January 2026 and brought him back to the United States in May 2026. CLAP was also at the center of an FCPA enforcement action announced in October 2021.

3. Former Commodities Trader Sentenced to Four Years for Ecuador and Mexico Bribery Schemes

On September 21, 2026, DOJ announced that former Vitol trader Javier Aguilar had been sentenced in the Eastern District of New York to 48 months’ imprisonment for his role in schemes to bribe government officials in Ecuador and Mexico. Aguilar was convicted at trial in February 2024 of FCPA and money laundering offenses arising from a scheme to bribe officials of Petroecuador, Ecuador’s national oil company, and pleaded guilty in August 2024 to charges involving bribes provided to officials of PEMEX Procurement International, an affiliate of Mexico’s national oil company. According to DOJ, Aguilar conspired to pay more than $1 million in bribes to obtain over $500 million in oil and gas contracts. The court also ordered Aguilar to forfeit more than $7.1 million and pay a $100,000 fine. Seven of Aguilar’s co-conspirators, including three foreign officials, have pleaded guilty. In December 2020, Vitol agreed to pay more than $135 million in coordinated resolutions with DOJ, the Commodity Futures Trading Commission (CFTC), and Brazilian authorities arising from related conduct.

4. D.C. Circuit Upholds Denial of SEC Whistleblower Award in Foreign Bribery Case

On September 9, 2026, a divided U.S. Court of Appeals for the D.C. Circuit upheld SEC’s denial of a whistleblower award to a former employee who suspected that his employer was facilitating a foreign bribery scheme. (Both the employee and the employer were anonymized in the opinion. Context clues in the opinion suggest that this matter involved the Unaoil case (see, e.g., our September 2019 Top 10).) Rather than initially reporting information directly to SEC, the employee provided information and documents to a journalist, who shared the information with DOJ and published articles about the alleged misconduct. Although a DOJ attorney subsequently suggested that the employee submit the information to SEC, he waited more than a year before doing so, by which time SEC had been investigating the company for approximately eight months. The majority held that the Dodd-Frank Act and the SEC’s implementing regulations require a whistleblower to provide original information directly to SEC that leads to a successful enforcement action. Because the whistleblower’s belated submission did not cause SEC to open its investigation or materially advance it, the majority concluded that he was not entitled to an award. The dissent reasoned that the employee was eligible for an award because his original information caused the SEC investigation and successful enforcement action, even though SEC initially received that information indirectly through the journalist and DOJ before he personally submitted it to SEC.

5. DOJ Returns $2.5 Million in Corruption Proceeds to The Gambia

On September 18, 2026, DOJ announced that it was returning approximately $2.5 million in forfeited corruption proceeds to The Gambia for use in compensating victims of former Gambian President Yahya Jammeh’s regime. According to DOJ’s civil forfeiture complaint, Jammeh obtained millions of dollars through embezzlement of public funds and solicitation of bribes from businesses seeking monopoly rights in sectors of the Gambian economy and used shell companies and overseas trusts to launder the proceeds. Jammeh and his wife allegedly used criminal proceeds and misappropriated public funds to purchase a mansion in Potomac, Maryland, which DOJ announced in May 2022 had been forfeited and which was later sold. Under the agreement with The Gambia, the approximately $2.51 million in net proceeds will be used to compensate eligible victims under the Gambian Victims Reparations Act of 2023.

6. Former Head of Swiss Bankers Association Convicted of Foreign Bribery

On September 8, 2026, Switzerland’s Federal Criminal Court convicted Pierre Mirabaud, a former senior partner of Geneva private bank Mirabaud & Cie and former president of the Swiss Bankers Association, of bribery of foreign public officials and aggravated money laundering and imposed a two-year suspended prison sentence. Mirabaud admitted that, between 2000 and 2012, he caused approximately CHF 82 million (approximately $101 million) in improper payments to Fahad Al-Rajaan, then director-general of Kuwait’s Public Institution for Social Security (PIFSS). In exchange, Al-Rajaan directed more than $500 million in PIFSS assets to the bank. Mirabaud also admitted to aggravated money laundering involving 122 transfers totaling nearly CHF 77 million that obscured the illicit origin of the funds. Mirabaud, who resolved the case through Switzerland’s simplified procedure, also cooperated with authorities.

7. SFO Settles Litigation Arising from ENRC Corruption Investigation

On September 2, 2026, the UK Serious Fraud Office (SFO) announced that it had reached a confidential settlement with Eurasian Natural Resources Corporation Limited (ENRC), an international law firm, and a former partner of that firm, ending long-running civil litigation arising from the SFO’s investigation of ENRC. From 2013 until August 2023, the SFO investigated suspected bribery and corruption involving ENRC’s mining assets in the Democratic Republic of Congo and elsewhere but closed the investigation without charges because of insufficient admissible evidence. In related civil litigation that ENRC began in 2017, the High Court found that the SFO had breached its duties through unauthorized dealings with the former law firm partner and that, but for that misconduct, the criminal investigation would not have been opened. In announcing the settlement, the SFO stated that it had since overhauled its governance, oversight, and safeguards and was confident that the misconduct could not reoccur.

8. Ireland Launches National Strategy to Combat Economic Crime and Corruption

On September 10, 2026, the Irish government announced a new multi-year Strategy to Combat Economic Crime and Corruption (the “Strategy”). The Strategy is intended to strengthen Ireland’s ability to prevent, detect, investigate, and prosecute economic crime and corruption, while protecting public trust, economic integrity, and the country’s international reputation. The Strategy establishes several objectives, including improving collection, analysis, and use of data to identify emerging threats, ensuring investigators and prosecutors have the ability to tackle economic crime and corruption effectively, and strengthening Ireland’s ability to seize and confiscate criminal assets. The Strategy also recommends considering deferred prosecution agreements (DPAs) and other non-trial resolutions for economic crime cases, legislation to facilitate private-sector information sharing, and enhanced public-private partnerships. The Strategy could have an impact on foreign bribery enforcement, given Ireland’s role as a major center of international commerce.

9. Former Singapore Marine Contractor Executives Acquitted in Brazil Corruption Case

On September 24, 2026, Singapore’s State Courts granted discharges amounting to acquittals to former Sembcorp Marine President and CEO Wong Weng Sun and former Jurong Shipyard Senior General Manager Lee Fook Kang on corruption charges related to the company’s business in Brazil. The discharges followed prosecutors’ decision to issue stern warnings to the two former executives in lieu of prosecution. The charges, initially brought in March 2024, alleged that the executives participated in approximately $44 million in payments through a Brazilian intermediary, some of which were allegedly intended as bribes to Brazilian officials to advance Sembcorp Marine’s business interests. According to the Singapore Attorney-General’s Chambers, prosecutors considered developments in related Brazilian proceedings, including the dismissal of criminal proceedings against the intermediary. In April 2026, Seatrium, Sembcorp Marine’s successor, disclosed that the Singapore High Court had approved a DPA under which the company agreed to pay approximately $110 million to resolve allegations arising from the Brazilian conduct.

10. China and European Public Prosecutor’s Office Strengthen Cross-Border Anti-Corruption Cooperation

On September 4, 2026, the European Public Prosecutor’s Office (EPPO) announced that it had signed a working arrangement with China’s Supreme People’s Procuratorate establishing practical mechanisms for judicial cooperation between the two authorities. According to EPPO, the arrangement is intended to intensify cooperation against organized crime, money laundering, and corruption and to improve recovery of illicit assets. The authorities also adopted a 2026–2028 action plan to develop cooperation practices in these areas. Anti-corruption cooperation between China and the European Union could have significant implications for multinational companies. The EPPO-China arrangement comes as China considers its proposed Anti-Cross-Border Corruption Law, which would address international cooperation in cross-border corruption matters as well as enterprise integrity and compliance obligations. The draft law and the EPPO arrangement involve different Chinese institutions but together reflect an increased focus on mechanisms for addressing corruption with a cross-border dimension. (For more on China’s proposed Anti-Cross-Border Corruption Law, see our August 2026 Top 10 and our client alert discussing the key takeaways for multinational companies.)