We weren’t sure this article would happen.
Since 2016, we’ve published an annual roundup of the biggest Foreign Corrupt Practices Act (FCPA) cases. But 2025 started in a way that made it look like this tradition might be put on hold—along with the law itself.
On January 20, 2025, Donald Trump was sworn in as the 47th President of the United States. Just weeks later, on February 10, 2025, the White House announced a 180-day pause on initiating new FCPA investigations, arguing that “overbroad” and unpredictable enforcement harms the competitiveness of U.S. companies, U.S. foreign policy interests, and national security.
During that period, the Attorney General was instructed to halt new cases (with limited exceptions), review ongoing investigations, and prepare updated enforcement guidelines. The pause could also be extended for an additional 180 days.
In the end, this story wasn’t about the FCPA being “canceled”—it was about a reset. On June 9, 2025, the DOJ released new Guidelines that brought enforcement back, but with a sharper focus: prioritizing serious corruption, matters that directly affect U.S. interests, and cases intersecting with transnational crime (including drug trafficking and money laundering).
By November 2025, the shift moved from theory to practice. The first corporate resolution after the pause (TIGO Guatemala) resulted in payments of more than $118 million and a two-year deferred prosecution agreement (DPA). It was a clear signal that FCPA enforcement was back, but under a new playbook.
That’s why this roundup still happened. Below, we’ve collected the key 2025 cases that best illustrate how the approach has changed—and what now sits in the highest-risk zone.
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Company / Individual
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Total penalty (USD, millions)
|
Industry
|
Misconduct
|
|
|
1
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Manuel Chang (former Mozambique finance minister)
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7.0*
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Government / Finance
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Bribery, international loan fraud, money laundering, investor deception
|
|
2
|
Atlanco LLC / Carl Alan Zaglin
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2.0*
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Law enforcement uniforms & equipment
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Bribery of foreign officials, FCPA conspiracy, money laundering
|
|
3
|
Ramon Alexandro Rovirosa
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0.15*
|
Oil & gas services / trading
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Bribes to officials at a state-owned oil company; FCPA conspiracy and substantive violations
|
|
4
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Glenn Oztemel
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0.3
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Oil & refined products trading
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Bribery of Petrobras officials, insider information, money laundering
|
|
5
|
Freepoint Commodities LLC
|
98
|
Energy commodities trading
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Corporate bribery of foreign officials; FCPA violations
|
|
6
|
TIGO Guatemala (Millicom)
|
118.2
|
Telecommunications
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Systemic bribery of officials; use of drug-trafficking proceeds; FCPA violations
|
|
Total penalties
|
225,65
|
|
|
* Amount reflects known financial sanctions (forfeiture, fines, or established bribe amounts), excluding potential or future restitution/compensation.
Prepared by Ethicontrol based on DOJ press releases.
In January 2025, former Mozambique finance minister Manuel Chang was sentenced in the United States to 102 months in prison for his role in a massive fraud, bribery, and money-laundering scheme involving more than $2 billion.
Between 2013 and 2015, he took $7 million in bribes for approving sovereign guarantees tied to loans that were supposedly meant to fund maritime projects—but were partly diverted and used to pay bribes.
The loans were sold to investors worldwide, including in the United States, allowing U.S. authorities to pursue a foreign official for conduct that harmed the U.S. financial system.
In 2025, a long-running case against U.S. businessman Carl Alan Zaglin, the owner and CEO of Atlanco LLC, came to a close. The court found that between 2015 and 2019 he orchestrated hundreds of thousands of dollars in bribes to Honduran officials through an intermediary to secure contracts worth more than $10 million to supply uniforms and equipment for the Honduran National Police.
The bribes were disguised as sham brokerage and consulting services, with coded language, encrypted messaging, and front accounts used to conceal the scheme.
In December 2025, Zaglin was sentenced to eight years in prison and ordered to forfeit more than $2 million—an illustrative example of personal accountability for overseas corruption.
In 2025, U.S. courts brought the case against Texas-based businessman Ramon Alexandro Rovirosa Martinez to a verdict, tied to corruption schemes involving Mexico’s state-owned oil company Petróleos Mexicanos (PEMEX).
Between 2019 and 2021, he paid more than $150,000 in bribes to PEMEX officials and those at a PEMEX subsidiary in exchange for preserving contracts and gaining improper business advantages worth at least $2.5 million for companies associated with him.
In December 2025, a jury found him guilty of conspiracy and FCPA violations, reinforcing the U.S. willingness to prosecute corruption schemes run from U.S. soil even when the conduct takes place abroad.
In December 2025, former senior oil and gas trader Glenn Oztemel of Connecticut was sentenced to 15 months in prison and fined $300,000 for his role in a long-running bribery scheme involving Brazil’s state-owned oil company Petróleo Brasileiro S.A. (Petrobras).
He paid more than $1 million in bribes to obtain confidential information on pricing and competitor bids, giving Arcadia Fuels and Freepoint Commodities an edge in winning lucrative contracts.
The scheme relied on layered concealment tactics, including coded language and encrypted communications, and the individual case followed a separate corporate resolution in which Freepoint agreed to pay more than $98 million.
In November 2025, telecom provider TIGO Guatemala, a Millicom subsidiary, agreed to pay more than $118 million to resolve an investigation into systemic bribery in Guatemala.
From 2012 to 2018, the company made regular cash payments to members of Congress and their security teams in exchange for legislative support that benefited the business, with some of the cash sourced from laundered drug-trafficking proceeds. The resolution included a two-year DPA, significant financial penalties, and extensive compliance obligations.
While the company received credit for early disclosure and later remediation, continued misconduct prevented it from avoiding liability entirely.
The 2025 cases reflect a new enforcement pattern under the FCPA: fewer matters overall, but concentrated on serious corruption, links to transnational crime, strategic sectors, and personal accountability.
Both corporate resolutions and real prison sentences underscore that the FCPA remains a key tool for the United States to protect its economic and national security interests globally.
Find out where the offenders are headquartered, which regions saw the most misconduct, and how each case contributes to the total penalty amount. Explore our detailed 2025 FCPA infographic.
Total penalties imposed by the DOJ. The full infographic is available here.
To learn more about past FCPA cases, visit our FCPA tag for prior-year reports.