On February 18, 2026, consistent with our warnings that Foreign Corrupt Practices Act (FCPA) enforcement had not disappeared—just evolved—a jury in Pennsylvania delivered a clear message. Charles Hunter Hobson, a former vice president at Corsa Coal, was convicted of conspiring to bribe officials at Al Nasr Co. for Coke and Chemicals, an Egyptian state‑affiliated entity, to secure coal‑supply contracts worth roughly $143 million. The government’s case drew on WhatsApp messages, coded commission‑splitting discussions, and testimony from Hobson’s successor—who had already pleaded guilty—showing how payments flowed through an Egyptian intermediary.
Even though the prior year’s Executive Order had “paused” most new DOJ FCPA investigations, Hobson’s case survived the review and proceeded to trial. The verdict underscored that enforcement would continue where the facts aligned with the government’s recalibrated priorities. Rather than disappearing, FCPA enforcement refocused, particularly on foreign entities and individuals.
A Narrower Pipeline, but a Clearer Through‑Line
The year’s developments reinforced that shift.
In October 2025, DOJ unveiled a superseding indictment against SGO Corporation Limited (Smartmatic) and several executives, alleging more than $1 million in bribes to the former chairman of the Philippines’ elections commission to obtain and retain contracts for the 2016 national elections. Prosecutors described a scheme built on over‑invoiced voting machines and transactions routed across Asia, Europe, and the US This was no routine filing: it was the first corporate FCPA indictment in roughly 15 years, and it targeted a foreign election system—an area increasingly viewed through a national‑security lens.
In December 2025, DOJ announced that TIGO Guatemala (TIGO), a telecommunications provider owned by Luxembourg-based Millicom Cellular, agreed to pay over $118 million in criminal penalties and forfeiture to resolve a long-running FCPA investigation into allegations that from 2012 to 2018, TIGO engaged in a bribery scheme involving monthly cash payments to Guatemalan legislators and their security teams in exchange for legislative support that benefited the company. Some of the cash used to fund these bribes came from laundered narcotrafficking proceeds. The resolution, implemented through a two-year deferred prosecution agreement, was notable as the first significant corporate FCPA action since updated DOJ FCPA and white-collar enforcement guidance emphasized prioritizing cases involving serious misconduct, organized crime links, and voluntary self-disclosure.
Just months earlier, DOJ had unsealed the first post‑pause FCPA charges: a bribery scheme involving two Mexican nationals and more than $2.5 million in payments to secure contracts with PEMEX, Mexico’s state‑owned oil company. These indictments were announced against the backdrop of heightened geopolitical tensions between the United States and Mexico, the US State Department’s February 2025 designation of Mexican cartels as foreign terrorist organizations, and the US Department of the Treasury’s Financial Crimes Enforcement Network’s (FinCEN) June 2025 decision to target three Mexican banks for alleged money laundering. Although the fact pattern was familiar, the timing of the charges signaled that foreign state‑owned enterprises in strategically important sectors remain firmly in DOJ’s focus. Throughout the year, DOJ officials emphasized that individual accountability remains the top enforcement priority under the revised guidelines. Cases like Hobson’s, selected for their evidentiary strength and taken through trial, reflect that commitment.
What Was Cut—and What That Says About the Future
The 180‑day review ordered in February 2025 dramatically thinned DOJ’s FCPA docket. In applying the administration’s new enforcement priorities, DOJ ended four DPAs, one NPA, a corporate monitorship, and roughly half of all open FCPA investigations.
One of the most visible closures involved the dismissal of charges against two former Cognizant executives. The SEC soon followed, shutting down its civil FCPA case. At first glance, these moves suggested an extended lull. But the subsequent Smartmatic indictment, PEMEX unsealing, and Hobson trial made the dynamic clear: the government had not withdrawn from enforcement—it had tightened the criteria for which cases merit federal action.
A New Enforcement Lens: National Security, US Competitiveness, and Cross‑Border Reach
The DOJ’s June 9, 2025 Guidelines made this evolution explicit. Prosecutors were instructed to prioritize cases that:
- Target bribery linked to cartels or transnational criminal organizations,
- Protect competitive opportunities for US companies,
- Advance US national‑security interests, and
- Focus on serious, high‑impact misconduct.
Lower‑level or routine conduct would be deprioritized, and collateral consequences—such as harm to legitimate business operations—were to be considered at all stages of an investigation.
Viewed through this lens, the cases that moved forward—Smartmatic (elections), PEMEX (energy), and Corsa Coal (SOE contracting in a sensitive region)—fit the template exactly.
The SEC: A Quiet Year, but a Strategic Reset
In 2025, the SEC brought no new FCPA actions, the first such year in recent memory. It wound down its existing Cognizant action and reallocated attention to investor‑protection matters.
But beneath that stillness, the SEC was reorganizing. It established cross‑border enforcement capacity designed to address complex international misconduct. Although not framed as an FCPA initiative, this task force is positioned to surface exactly the kinds of issues—foreign subsidiaries, intermediaries, state‑owned counterparties, and cross‑border payments—that often form the basis of civil FCPA actions. As staffing stabilizes, this new structure could reignite a meaningful SEC FCPA pipeline.
What the Numbers Say
In 2025, DOJ brought three corporate FCPA actions, generating about $123 million in penalties. The reduced number reflects not a retreat, but a deliberate narrowing of what qualifies as an enforcement‑worthy case.
What Comes Next
Taken together, the past 14 months reveal not an FCPA program in eclipse but one that has been redrawn. What emerges is a framework defined by fewer cases, but higher‑stakes ones:
- More trials against individuals, with cases built for court and tied to identifiable US interests.
- Selective but consequential corporate resolutions, especially in matters touching critical infrastructure, state‑owned enterprises, or unfair competition against US companies.
- A likely SEC re‑entry, with future cases emerging from its cross‑border enforcement channels.
- Deepening international coordination, as foreign authorities expand their own anti‑corruption agendas.
The Hobson verdict shows that while the government is closing cases that no longer fit its priorities, it remains fully prepared to prosecute those that do. Today’s FCPA enforcement environment may involve fewer actions overall, but those that proceed will be more strategically chosen, more closely tied to national security and competitiveness concerns, and more likely to be taken all the way to trial.
