Traditionally, the SEC Enforcement Division releases its fiscal year (ends on September 30th) enforcement report in the Fall.
Yesterday, the SEC released its enforcement report for FY 2025 and it contains some zingers.
The SEC’s release begins: “Central to an effective enforcement program is determining which cases to bring and responsibly stewarding Commission resources. Regrettably, such resources have been misapplied in prior years to pursue media headlines and run up numbers, and in turn, led to misguided expectations on what constitutes effective enforcement.”
In December 2025, Ramon Alexandro Rovirosa Martinez was found guilty after a bizarre trial of various charges in connection with an alleged Mexican bribery scheme. (See here for the prior post).
As reported here, the trial featured no fact witnesses which led the judge to block the government from introducing most of its evidence until their closing argument.
Soon after the verdict, Rovirosa was taken into custody and has been in prison since.
Post-trial, Rovirosa filed a motion for a judgement of acquittal and among the reasons stated were the following:
(i) “the Government presented evidence to the jury that was either not properly admitted into evidence and/or that should not have been admitted into evidence;”
(ii) “the jury was provided with text messages to and from alleged co-conspirators that were never properly admitted into evidence, and the Government never offered evidence to satisfy any legal exception to the hearsay rule;” and
(iii) “the jury was provided with testimonial translations of text messages with no testimony by the translator, despite defense counsel’s request and objection, in violation of the Confrontation Clause.”
A year ago this week, the DOJ moved to dismiss its long-standing criminal indictment charging former Cognizant executives Gordon Coburn and Steven Schwartz with FCPA and related offenses. Shortly thereafter, U.S. District Court Judge Michael Farbiarz (D.N.J.) granted the motion.
Many assumed that the dismissal was solely based on the Executive Order issued by President Trump approximately 45 days prior to the dismissal which, among other things, directed the Attorney General to “review in detail all existing FCPA investigations or enforcement actions and take appropriate action with respect to such matters to restore proper bounds on FCPA enforcement …”.
Indeed, the DOJ’s short letter motion to dismiss the action stated the motion was “based on the recent assessment of the Executive Order’s application to this matter.”
However, linking the dismissal solely to the Executive Order was not warranted – as these pages mentioned at the time. In fact, in the weeks and months after the Coburn/Schwartz matter was dismissed, several other FCPA defendants tried unsuccessfully to dismiss actions based on the Executive Order.
A year later, it seems as if mention of the Executive Order in the DOJ’s motion to dismiss was just a convenient off-ramp for a case that should never have been brought in the first place.
As highlighted here, in March the DOJ filed a criminal information against Alfonso Wilson (CEO of Oil Technologies Consortium) alleging that he and others obtained and retained a December 2021 Contract with PEMEX for an Equipment Company through corrupt and fraudulent means including by offering and paying bribes to a Foreign Official.
The Equipment Company (described as a company based in Texas) is believed to be Drillmec.
The Foreign Official is described as a senior executive at PEMEX Exploración y Producción (“PEP” – a wholly owned exploration and production subsidiary of PEMEX) between 2018 and 2021.
If you believe that Foreign Corrupt Practices Act enforcement has stopped, you are either highly misinformed or perhaps informed but more interested in advancing false narratives.
This post provides a summary of Foreign Corrupt Practices Act enforcement activity and related developments from the first quarter of 2026.
DOJ Enforcement (Corporate)
The DOJ announced one corporate enforcement action in the first quarter.