This post highlights 8 FCPA enforcement actions concerning conduct (in whole or in part) in Poland.
The enforcement action concerned conduct in Russia, Poland and Mexico.
As to Poland, the allegations were: HP Poland “(i) caused the falsification of HP’s books and records; and (ii) circumvented HP’s existing internal controls, in connection with a scheme to make corrupt payments to one or more foreign officials in Poland, including the Polish Official [the Director of Information and Communications Technology within the Polish National Police Agency (“KGP”) which was part of the Polish Ministry of the Interior and Administration].” Between 2006 and 2010 HP Poland “provided Polish Official cash worth the equivalent of approximately $600,000, gifts valued in excess of $30,000, and several thousand dollars in improper travel and entertainment benefits.” “During this same time span, the Polish government awarded to HP Poland at least seven contracts for KGP-related information technology products and services, with a total value of approximately $60 million.”
In 2019, Alvaro Pulido Vargas was criminally charged with laundering the proceeds of violations of the FCPA in connection with a scheme to pay bribes to take advantage of Venezuela’s government controlled-exchange rate. (See here).
In 2021, the DOJ also announced the unsealing of an indictment charging various individuals including Alvaro Pulido Vargas for their alleged roles in laundering the proceeds of contracts to provide food and medicine to Venezuela that were obtained through bribes. (See here for the prior post).
Yesterday, the DOJ announced that Pulido Vargas was arrested and will be making an initial appearance on October 13th in the Southern District of Florida to face federal prosecution.
This post highlights seven FCPA enforcement actions concerning conduct (in whole or in part) in South Africa.
The enforcement action concerned conduct in South Africa and Nepal.
As to South Africa, the allegations were: “between January 2016 and at least January 2020, AAR, through its agents, knowingly and willfully conspired and agreed with others to corruptly offer and pay bribes to, and for the benefit of, government officials in South Africa […] to secure improper advantages in order to assist AAR in obtaining and retaining business from SAAT [South African Airways Technical – a wholly owned subsidiary of South African Airways – that provided technical services for SAA and other airlines], namely the award of a five-year aircraft component support contract (“SAAT Contract”) and disbursement of payments by SAAT pursuant to that contract.”
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 motion for a judgement of acquittal pending, in September 2026 (through new counsel) Hobson filed a motion to dismiss based on the court’s supervisory powers.
In a rather cavalier response, the DOJ sort of responded to the motion, but also stated that if “the Court wishes to resolve the substance of Defendant’s claims, the government respectfully requests 60 days to respond more fully.” (See here).
The Foreign Corrupt Practices Act has always been a law much broader than its name suggests.
Sure, the FCPA contains anti-bribery provisions which concern foreign bribery.
Sure, the FCPA’s books and records and internal controls provisions can be implicated in foreign bribery schemes.
However, the fact remains that most FCPA enforcement actions (that is enforcement actions that charge or find violations of the FCPA’s books and records and internal controls provisions) have nothing to do with foreign bribery. For lack of a better term, these enforcement actions have longed been called non-FCPA, FCPA enforcement actions by this site.
The latest example concerns an SEC enforcement action against Latch, Inc. (a Missouri based company that develops and manufactures smart access hardware and software products for multi-family residential properties).