This post highlights twenty-four FCPA enforcement actions concerning conduct (in whole or in part) in India.
The enforcement action concerned conduct in India and the allegations were: “The Government’s investigation found evidence that, from in or around 2017 until in or around 2022, Liberty Mutual, through its subsidiary in India, Liberty General Insurance (“LGI”), paid bribes totaling approximately $1.47 million to officials at six state-owned banks in India, in order to obtain or retain business with those state-owned banks. Specifically, in exchange for the bribes, the officials caused the state-owned banks to refer bank customers to LGI’s insurance products. Certain LGI employees took steps to conceal the true nature of the payments, including by classifying the payments as marketing expenses and using third-party intermediaries to make the payments to the officials. In total, the bribe scheme resulted in revenue of approximately $9.2 million and profits of approximately $4.7 million.”
This post highlights FCPA enforcement actions concerning conduct (in whole or in part) in Pakistan and Nepal.
The enforcement action concerned conduct in Russia, Azerbaijani, China, Kuwait, South Korea, Pakistan, Thailand, and Indonesia.
As to Pakistan, the allegations were: “In addition to the purely leisure trips arranged by Otis to influence foreign officials, at times UTC businesses provided excessive leisure travel and entertainment in conjunction with legitimate business travel. For example, from 2012 to 2014, the Pratt Belgium Engine Center paid for excessive, leisure hotel stays in Belgium and Amsterdam for Air Force officials from Pakistan …”.
Previous posts have focused on Foreign Corrupt Practices Act enforcement actions concerning conduct (in whole or in part) in Thailand, Vietnam, Indonesia, Malaysia and other Southeast Asian countries.
This post shifts the focus a bit west and highlights seven FCPA enforcement actions concerning conduct (in whole or in part) in Bangladesh.
The enforcement action concerned conduct in Angola, Bangladesh, Indonesia, Thailand, China, and Egypt.
As to Bangladesh, the allegations stated that an indirect subsidiary paid “$43,700 to an agent in Bangladesh with the understanding that the agent would use the money, in part, for corrupt purposes.”
In February 2026 Charles Hunter Hobson (who served in a variety of roles at Corsa Coal from 2013 to 2018) was found guilty by a jury for various Foreign Corrupt Practices Act and related offenses in connection with an Egyptian bribery scheme.
With a separate motion for a judgement of acquittal pending, recently Hobson filed a motion to dismiss based on the court’s supervisory powers.
The motion began:
“When confronted with coercive prosecutorial tactics . . . , the [Supreme] Court has often condoned those practices or let them pass in silence.” Hunter v. United States, 146 S. Ct. 1702, 1715 (2026) (Gorsuch, J., concurring). This Term, it “begins to correct course.” Id.
This case is directly in Hunter’s cross hairs. The government improperly used a five-year-old proffer to deprive a United States citizen of his constitutional right to a fair trial. Its threats disabled the adversarial process throughout the trial. The government then cashed in on this unlawful effort, calling its proof “overwhelming and uncontradicted.” The government never sought a ruling that the proffer waiver was knowing, voluntary, triggered, or enforceable. Even if it had, Hunter confirms that a valid waiver does not compel enforcement. On a lesser record, where the court did rule and no proffer statement was ever admitted, the Second Circuit vacated and ordered a new trial. United States v. Oluwanisola, 605 F.3d 124 (2d Cir. 2010).
At a minimum, Hobson is entitled to a new, fair trial—one in which he can confront the government’s witnesses, test its evidence, and present a defense without one hand tied behind his back. But the government’s deliberate actions warrant more. Hobson asks this Court to dismiss the indictment with prejudice under its supervisory power, protect the integrity of the federal courts, and prevent them from “making . . . themselves accomplices in willful disobedience of law.”
Earlier this month, Asante Berko (a former Executive Director of Goldman Sachs International) was convicted by a jury of FCPA and related offenses in connection with a Ghana bribery scheme after a trial in the E.D. of New York.
Recently, Berko filed a motion for acquittal and a new trial.
In summary fashion the motion states:
“Defendant Asante Kwaku Berko moves pursuant to Rule 29 of the Federal Rules of Criminal Procedure for a judgment of acquittal on all counts because the evidence admitted at trial was insufficient for any rational trier of fact to find that the Government had proven Mr. Berko’s guilt with respect to any of the charged offenses. Specifically, the evidence at trial was insufficient for any reasonable jury to conclude, beyond a reasonable doubt, (1) that Mr. Berko agreed with the alleged co-conspirators to violate the FCPA by paying bribes to Ghanaian government officials, as necessary to sustain a conviction as to Count One, (2) that any of the elements of Count Two were established, including that Mr. Berko offered or paid anything of value, with corrupt intent for an improper purpose, and (3) that the transfers of funds that served as the basis of conviction as to Count Three were the result of a separate agreement among the alleged coconspirators with the specific intent to promote the alleged bribery scheme or substantive FCPA violation. In addition, the evidence was insufficient for the jury to conclude by a preponderance of the evidence that venue in the Eastern District of New York was proven as to all Counts. In the alternative, Mr. Berko moves pursuant to Federal Rule of Criminal Procedure 33 for a new trial on all counts.”