The DOJ also announced that Steven Hunter (a former business development manager at Unaoil) pleaded guilty in August 2018 to one count of conspiracy to violate the FCPA.

As noted in the DOJ’s release, the Ahsanis were scheduled to be sentenced in April 2020 and Hunter was scheduled to be sentenced in March 2020.

However, this August 2022 post highlighted how the defendants still had yet to sentenced and wondered when sentencing would occur.

According to court dockets, sentencing of Cyrus Ahsani and Saman Ahsani was pushed back until October 2020, then February 2021, then September 2021, then December 2021, then June 2022, then December 2022, and then January 30, 2023. Each time sentencing was delayed, there were sealed filings on the court docket.

As highlighted in this prior post, Saman Ahsani was sentenced in January 2023 and the docket entry stated as follows:

“Minute Entry for proceedings held before Judge Andrew S Hanen: Sentencing held on 1/30/2023 for Saman Ahsani (1) as to Count 1 of the Indictment. The Court ruled on pending motions on the record. There being no objections to the PSR, the Court adopted the PSR and sentenced Defendant to the custody of the BOP for a term of 12 months and 1 day; 1 year SRT; no fine; $100 SA. The Court recommended that Defendant be permitted to return to his home country to serve his supervised release. The Court further recommended placement in the facility at Beaumont, Texas. The Defendant may self-surrender at a time and place to be determined by the BOP.”

When will Cyrus Ahsani and Hunter be sentenced?

According to court dockets, Cyrus Ahsani’s sentencing date was pushed back to August 21, 2023, then February 2024, then November 2024, then May 2025, then November 2025, then May 18, 2026, and is currently set for December 1, 2026.

Ahsani’s most recent unopposed motion to continue sentencing (which the court granted in October 2025) stated:

As set forth in the prior motions, Mr. Ahsani has been cooperating with the Australian Federal Police (“AFP”) in their prosecution of David Savage and Russell Waugh in connection with Leighton Offshore Pte Ltd (the “Leighton Defendants”). Mr. Ahsani has already provided live testimony in those proceedings. The Australian prosecutors have now informed counsel that the trial of the Leighton Defendants is expected to be scheduled for the beginning of next year, at which time Mr. Ahsani will be called to testify again in person.

Continuing Mr. Ahsani’s sentencing and related deadlines will benefit both parties in this case, as well as the Australian government and the interests of justice. As stated in the prior motions, Mr. Ahsani wishes to continue fulfilling his commitment to the Australian government, and have his ongoing, truthful testimony considered by this Court at the time of sentencing. Testifying truthfully under oath in a foreign prosecution is a significant form of cooperation that should be fully weighed at sentencing.

This request is not made for purposes of delay, but to ensure that justice is done. Counsel for Mr. Ahsani has conferred with counsel for the United States, who has indicated that the United States is unopposed to this motion.”

In the past six months, there have been five filings relevant to sentencing, but all filings are under seal.

According to court dockets, sentencing of Hunter was pushed back until October 2020, then January 2021, then May 2021, then September 2021, then December 2021, then July 2022, then December 2022, then February 2023, then September 2023, then March 2024, then December 2024, then December 2025, then June 1, 2026, and is currently scheduled for December 14, 2026.  Each time sentencing has been delayed, there are sealed filings on the court docket.

In short, Cyrus Ahsani pled guilty over 7 years ago and still has not been sentenced. Hunter pled guilty approximately 8 years ago and still has not been sentenced.

In late 2023, Kodiak announced its intent to acquire CSI Compressco LP whose customers included various business in several foreign countries including Mexico, Canada, Argentina, and Chile.

This previous post highlighted a 2025 disclosure by Kodiak regarding compliance issues in Mexico.

Kodiak’s most recent quarterly filing (May 11th) states:

“In the first quarter of 2025, the Company received a report regarding certain payments to local government officials in Mexico that commenced prior to the Company’s acquisition of its Mexican business in connection with the acquisition of CSI Compressco LP (the “CSI Acquisition”) that presented potential compliance issues under U.S. law.”

The disclosure continues:

“In response, the Company retained outside counsel to conduct an internal investigation of the reported payments, including whether any payments made may have indirectly benefited individuals associated with certain criminal cartel organizations, some of which may be designated as foreign terrorist organizations (FTOs) and Specially Designated Global Terrorists (SDGTs) per Executive Order 14157 of January 20, 2025. The investigation determined that certain payments likely were made to persons associated with an organization designated as an FTO or SDGT. The payments appear to have been made in order to protect employees of the Mexican business from threats of harm or harassment, and to ensure access to work sites. The aggregate amount of these payments was not material. The Company sold its operations and legal entities in Mexico on September 30, 2025.

The Company voluntarily self-reported this matter to governmental authorities in the United States, including the Department of Justice (“DOJ”) and the Office of Foreign Assets Control (“OFAC”), and is cooperating with the investigative steps being taken by the DOJ and OFAC into the matter as a result of the voluntary self-disclosure. The Company also voluntarily self-reported to the SEC and intends to cooperate fully should there be any investigation by the Commission. This matter could result in U.S. governmental authorities seeking criminal and/or civil sanctions, including monetary fines and penalties, against the Company, as well as requiring additional changes to the Company’s business practices and compliance programs. To the extent any of the payments at issue are determined to be illegal in a foreign jurisdiction, it is possible that there could be civil or criminal penalties assessed in that jurisdiction.

Although the Company does not expect the findings from the investigation or actions taken by governmental authorities to have a significant adverse impact on its business, results of operations, financial condition and cash flows, there can be no assurance as to the ultimate outcome of these matters at this time.”

Which makes this recent Morrison & Foerster alert which addressed the recent dismissal in U.S. v. Rovirosa a bit unusual.

First, some background.

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.

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.”

With that motion pending Rovirosa also filed a “Motion to Dismiss Case with Prejudice Based on the Court’s Supervisory Powers.” Among the reasons stated were the following: “the Government attorneys in this case (1) made misrepresentations to the Court and/or to the jury that willfully mispresented both the record and the legal standards; (2) failed to provide evidence to defense counsel, and (3) failed to present any witnesses at trial with actual knowledge of the facts. Even more alarming, the case was under the legal supervision of a Department of Justice supervisory attorney, who apparently allowed such conduct to occur.”

U.S. District Court Judge Kenneth Hoyt (S.D. Texas) granted the motion to dismiss and motion for acquittal. He concluded:

“After considering the relevant circumstances surrounding the government’s case, and its intended use of electronic messages between the alleged co-conspirators and the co-defendant, the Court determines that the messages are testimonial and are governed by common law and the Confrontation Clause of the Sixth Amendment. The Court finds that the messages of the coconspirators and, in particular, the co-defendant Avila, while they constitute hearsay messages, and would be admissible in a conspiracy setting, they are not automatically admissible here because, as translations, and when used to establish the case, they are testimonial. The government’s primary purpose for offering the messages was to convict Rovirosa, i.e. to prove the elements of the crimes charged in the Indictment. See Crawford, 541 U.S. at 51.

In reaching this conclusion, the Court finds that the government has not produced evidence showing that the Translators were unavailable or that Rovirosa was given an opportunity to cross-examine them prior to trial. The precedent is clear, the government had a duty to produce the Translators for cross examination.

The government turns next to the certification sequence for admissibility. It argues that Google or Yahoo and WhatsApp recorded the transmittals between Rovirosa, and between the alleged co-conspirators that were made on their own electronic devices capturing them in the regular course of their business activities. Hence, the government argues the messages are admissible under the business [records] exceptions rules. See Fed. R. Evid. 803(6). The government also argues that the Translators certified their translations under oath; and that Special Agent Varga reviewed the Translators’ translations and certified the accuracy of their translations. The Court will address these arguments, however, they are all unavailing.

Fed. R. Evid. 801(c) and (d) and 803(6), address hearsay exceptions that apply to business records or electronic messages when they are offered into evidence. Rovirosa does not argue that the translations were not properly certified by Google or others, or that the business records exception, generally, satisfies the hearsay rule exception such that out-of-court hearsay statements or documents may be admitted. Instead, he argues that, even if the federal rules of procedure or evidence are satisfied, the electronic messages must be excluded because: (a) the messages offered were translations from Spanish to English, between and among alleged co-conspirators and, as such, the Confrontations Clause prohibits admission if they are testimonial statements by a non-testifying witness. The precedent exceptions to this rule do not apply here because Rovirosa had no prior opportunity to cross-examine the witnesses.

The record shows that the government intentionally did not call as witnesses the Translators. Hence, Rovirosa was not provided an opportunity to cross-examine them prior to or during trial. Moreover, there is no evidence that the government could not have produced them. Nor is there evidence that the government made an effort to produce them. Hence, the Court concludes that Rovirosa’s right to cross-examine the Translators and the co-defendant, cannot be truncated by offering certifications, particularly since the Translators were available to the government. Moreover, Rovirosa’s right to cross-examine the Translators is not satisfied by the government’s tender of Special Agent Varga to testify that she re-examined the Translator’s translations and is of the opinion that they are accurate. To permit this type of “expert” evidence, turns on its head the science and art of proper translation considerations.

It is well accepted that Translators fall into one of two camps, those who use the pedagogic/literal format – word for word, or exercise poetic/dynamic, where the Translator seeks the pulse and tone of expressions in order to capture words and expressions. Cross-examination permits recognition of cultural sensitivity issues, specialized knowledge, and the level at which the Translator’s education and usage of the language may rest. To that add regional nuances and contextual consideration as the occasion dictates. To ignore the art and science of the translation process is to render cross-examination of the Translators, useless or questionable.

The jury recognized that the English translations short-circuited its review of the evidence, an evidentiary fact missed by the Court. During deliberations, the jury requested that the Court provide the Spanish messages during deliberations. The Court could not provide the Spanish messages because they had not been offered into evidence by the government. This failing by the government becomes more poignant when considered in the light of Rovirosa’s complaint that the government failed to produce forensic copies of the Spanish messages taken from both defendants’ electronic devices.

The government promised to produce the screen shots on at least two occasions. On September 26 and October 1, 2025, Department of Justice Attorney, Bennett Starnes, promised the materials. The materials were never produced, and this failing is also fatal to the government’s case.”

In conclusion, Judge Hoyt stated:

“Based on the Court’s findings and conclusions, the Court GRANTS the defendant Rovirosa’s motion to dismiss the Indictment pursuant to Fed. R. Crim. Pro. 29(c); alternatively, to ACQUIT him of all charges based on lack of evidence to support his conviction in violation of the Confrontation Clause of the Sixth Amendment. He is ORDERED released, forthwith.”

Among the authors of the Morrison & Foerster alert is former DOJ FCPA attorneys Charles Duross and James Koukios. In pertinent part, the alert states:

“This ruling appears open to challenge on appeal. First, the emails themselves should be non-hearsay under Federal Rule of Evidence 801(d)(2) because they were offered against the defendant and were either statements of the defendant or statements of the defendant’s co-conspirators made during and in furtherance of the conspiracy. Second, the usual procedure for disputed translations is to allow both sides to submit their own translations to the jury. Third, to the extent that it believed that testimony from the government’s translators was nevertheless necessary, the court could have either required such testimony during the trial or ordered a new trial during which such testimony could be elicited; an acquittal may be viewed as an overly severe outcome under the circumstances. Even if not reversed, the order relates simply to an evidentiary issue and does not implicate any substantive FCPA issues. (The same judge was reversed in February 2023 for dismissing FCPA charges in another case)”

The Company’s solutions are found in the end markets of transportation (including automotive, commercial vehicle, e-bike, aerospace, bus and rail), cloud computing infrastructure, construction equipment and consumer appliance.

As highlighted in this prior post, in late 2024 Methode disclosed FCPA scrutiny.

The company stated:

“The Company received a subpoena from the SEC dated November 1, 2024 seeking documents and information relating to, among other things, the Company’s operations in certain foreign countries, certain financial and accounting matters relating thereto, compliance with the Foreign Corrupt Practices Act and other anti-corruption laws, and material weaknesses in the Company’s internal control over financial reporting previously reported in its public filings. The Company is cooperating with the SEC. The subpoena and related investigation or other future requests for information could result in costs to the Company, including the expenditure of financial and managerial resources. In addition, this request may lead to the assertion of claims or the commencement of legal proceedings against the Company, which in turn may lead to material fines, penalties or other liabilities. However, at this time, the Company is unable to reasonably estimate an amount or range of reasonably possible loss, if any, that may result from these matters.”

Methode’s most recent quarterly filing (March 2026) likewise stated:

“The Company received subpoenas from the SEC dated November 1, 2024 and March 12, 2025 seeking documents and information relating to, among other things, the Company’s operations in certain foreign countries, certain financial and accounting matters relating thereto, compliance with the Foreign Corrupt Practices Act and other anti-corruption laws, material weaknesses in the Company’s internal control over financial reporting previously reported in its public filings, deficiencies and significant deficiencies in the Company’s internal control over financial reporting, accounting and finance policies and procedures and other accounting and finance matters including new business bookings, certain financial metrics and performance indicators, performance relative to targets and guidance for certain periods, executive compensation policies and amounts, hotline tips and complaints, and terminations or resignations of company executives. The Company is cooperating with the SEC. The subpoenas and related investigation or other future requests for information have resulted and could result in future costs to the Company, including the expenditure of financial and managerial resources. In addition, this request may lead to the assertion of claims or the commencement of legal proceedings against the Company, which in turn may lead to material fines, penalties or other liabilities. However, at this time, the Company is unable to reasonably estimate an amount or range of reasonably possible loss, if any, that may result from these matters.”

In a recent filing, the company stated:

“As previously disclosed, the Company was subject to an investigation by the Securities and Exchange Commission. On May 14, 2026, the SEC Staff notified the Company that it has concluded its investigation and does not intend to recommend an enforcement action.”

Yesterday, the SEC rescinded the policy.

The SEC release states:

“The Securities and Exchange Commission today rescinded a policy, codified in Rule 202.5(e) of its informal rules of procedures, stating that when it chooses to settle an enforcement action in which a sanction is imposed, it will not settle unless the defendant or respondent also agrees not to publicly deny the allegations in the complaint or administrative order. Rescinding Rule 202.5(e) aligns the Commission with the overwhelming majority of federal agencies that do not have a similar rule and gives the Commission more flexibility in settling enforcement actions, which conserves resources, provides certainty, and potentially expedites the return of money to injured investors. The recission recognizes that the effect on the public interest from such denials may be minimal and that the policy itself may have created an incorrect impression that the Commission is trying to shield itself from criticism.”

The release further states:

“For more than 50 years, the Commission has conditioned settlement on a defendant’s promise not to publicly deny the Commission’s allegations. I am pleased that we are rescinding the no-deny policy today,” said SEC Chairman Paul S. Atkins. “Speech critical of the government is an important part of the American tradition. This recission ends the policy prohibiting such criticism by settling defendants.”

There is no known instance of the Commission seeking to reopen an administrative or civil proceeding as a consequence of a defendant or respondent violating a no-deny provision to which they have consented.

In light of the recission of Rule 202.5(e), the Commission will not enforce existing no-deny provisions that have already been entered. In the event of a breach of an existing no-deny provision, the Commission will take no action to ask a district court to vacate a settlement (or to reopen an adjudicatory proceeding) in connection with the terms of the settlement agreement.

The Commission generally does not require settling defendants to admit to allegations. Today’s recission does not affect the Commission’s practice related to admissions in settlements and does not affect the Commission’s discretion to settle with defendants who decline to admit facts or liability or its discretion to negotiate for admissions as part of a settlement.”

SEC Commissioner Hester Peirce, long a critic of the settlement policy, released the following statement.

“[T]he Commission rescinded its decades-old no-admit/no-deny policy governing the settlement process. Under this policy, settling defendants cannot publicly deny the allegations in a complaint or permit anyone else to do so.  The Commission will no longer require and demand that defendants in its enforcement actions curtail their right to speak as a condition of settlement.  For reasons I have explained before, this result is good and brings the Commission into alignment with nearly every other part of the federal government. Settlements shrouded in forced silence by the non-governmental party do not serve either the markets or the Commission’s investor-protection mission.  To the contrary, people’s freedom to speak against the government contributes to its ability to govern well. Transparent enforcement of the securities laws helps create the environment in which free markets thrive, and enabling both parties in an enforcement action to speak freely contributes to transparency.

Ending this imprudent policy, of course, does not mean that the Commission will stop resolving cases through settlement.  The excellent investigative work of our professional, dedicated staff stands on its own ground, notwithstanding a defendant’s protestations of innocence.  The public now will be able to assess the Commission’s case in light of a defendant’s denials.  The result, I expect, will be what free speech often produces: somewhere between cacophony and euphony—neither terribly pleasing to the ear, not entirely unpleasant to hear.  That the noise happens at all, however, is a substantial step forward for both the Commission and the right of a free people to speak their mind.”

Both the SEC and DOJ enforcement actions included a Foreign Corrupt Practices Act component (see here and here), but not as to Gautam Adani (a citizen of India and founder of the Adani Group which includes numerous portfolio companies including Adani Green Energy – and Indian energy company) and Sagar Adani (a citizen of India and Gautam Adani’s nephew and Executive Director of Adani Green’s Board of Directors) perhaps due to jurisdiction issues.

Nevertheless, Gautam Adani and Sagar Adani were civilly charged with securities fraud in connection with the same core conduct.

As alleged in the SEC civil complaint:

“In 2021, two senior executives of Adani Green Energy Ltd. (“Adani Green”)— Gautam Adani, Adani Green’s founder and controlling shareholder, and Sagar Adani, Adani Green’s Executive Director (collectively, “Defendants”)—engaged in a bribery scheme involving the equivalent of hundreds of millions of dollars to obtain contracts that benefitted Adani Green, while, at the same time, falsely touting the company’s compliance with antibribery principles and laws in connection with a $750 million bond offering (the “Offering”).

Gautam Adani founded Adani Green and Defendants are part of a four-person management team that controls it. For years, Defendants positioned Adani Green to investors and the public as a leader among its peers and within India in principles of good corporate governance, highlighting Adani Green’s purportedly rigorous anti-bribery and anti-corruption principles and policies, and seeking to appeal to investors who valued governance factors.

In September 2021, Defendants leveraged that narrative in the Offering to sell $750 million of Adani Green corporate bonds (“Notes”), including more than $175 million in Notes to investors in the United States.

In connection with the Offering, Adani Green told purchasers of the Notes that none of Adani Green’s directors or officers, including Defendants themselves, had paid or promised to pay bribes to government officials or attempted to unduly influence those officials. Adani Green and Defendants also emphasized to underwriters and potential investors that Adani Green had implemented robust anti-bribery and anti-corruption processes and that Adani Green was a leader in India in good corporate governance.

None of this was true. In the months and weeks before making these representations in connection with the Offering, Defendants were personally involved in paying or promising the equivalent of hundreds of millions of dollars in bribes to Indian state government officials to induce Indian state governments to enter into contracts necessary for Adani Green to develop India’s largest solar power plant project, from which Adani Green stood to earn billions of dollars.

A second company involved in that power plant project, Azure Global Power Limited (“Azure”), agreed to pay a portion of those bribes and Defendants were also personally involved in collecting payment from Azure.

Gautam Adani and Sagar Adani lied to purchasers of Adani Green’s Notes about Adani Green’s and their own involvement in a complex and high value bribery scheme. Those lies, made in connection with the offer and sale of Notes to investors in the United States, violated the antifraud provisions of the federal securities laws.”

Last week, the SEC announced:

“Without admitting or denying the allegations in the complaint, Gautam Adani and Sagar Adani each consented to the entry of final judgments, subject to court approval, that would permanently enjoin each from violating [various securities law provisions]. In addition, the final judgments, if approved by the court, would order Gautam Adani and Sagar Adani to pay civil monetary penalties of $6,000,000 and $12,000,000, respectively.”

In connection with the same core conduct Gautam Adani and Sagar Adani were also criminally charged with securities fraud conspiracy and wire fraud conspiracy.

Today, the DOJ filed a consent motion to dismiss the case, not just against the Adanis but other defendants as well.

The motion states;

“The government respectfully submits this motion, pursuant to Federal Rule of Criminal Procedure 48(a), requesting that the Court dismiss the indictment in this case with prejudice. The Department of Justice has reviewed this case and has decided, in its prosecutorial discretion, not to devote further resources to these criminal charges against individual defendants. See United States v. Blaszczak, 56 F.4th 230, 238-42 (2d Cir. 2022) (“The government may elect to eschew or discontinue prosecutions for any of a number of reasons. Rarely will the judiciary overrule the Executive Branch’s exercise of these prosecutorial decisions.”). No defendant has appeared. Counsel for all defendants consent to this relief.”

Woodcock stated that his goals are “to return the enforcement program back to basics” with an “emphasis on quality over quantity.”

Whether Woodcock’s speech was relevant to the Foreign Corrupt Practices Act (part of the securities laws after all) is your call.

Off the rails FCPA enforcement by the SEC has been highlighted on these pages for years.

In pertinent part, Woodcock stated:

“I want to share a bit about how I intend to lead the Division.

Simply put, my role is to ensure that our staff are empowered, supported, and equipped to execute the Commission’s mission. I intend to provide hands-on leadership that allows our teams to focus on the fundamentals – the blocking and tackling if you will, with professionalism, efficiency, and fairness. In doing so, I am committed to ensuring the Division remains the global gold standard in securities law enforcement.

As a matter of first principles, my goals are aligned to those of Chairman Atkins: to return the enforcement program back to basics. That means vigorously protecting investors and safeguarding markets, while also providing transparency and certainty to those we regulate.

A quick aside, there has been considerable attention paid to the decline in the number of cases brought over the last several years. Let me be clear: this Commission has deliberately shifted toward an emphasis on quality over quantity, and I fully support that direction.

Our focus is, and will remain, on protecting investors and safeguarding markets from real harm. That means identifying and stopping fraud and manipulation in all its forms—for instance, offering frauds, accounting and disclosure fraud, insider trading, market manipulation, fraud by foreign actors targeting U.S. markets and investors, and breaches of fiduciary duties by advisers misusing client assets.

These are the types of cases contemplated when the Division was created, and these are the cases the Division intends to pursue aggressively during my tenure.”

In 2020, based upon the same core conduct, Goldman Sachs resolved a net $1.66 billion FCPA enforcement action – the largest ever FCPA settlement.

Leissner pleaded guilty, was ordered to forfeit $43.7 million, and in 2025 was sentenced to prison for two years. (See here for the prior post).

In 2022, Ng was found guilty at trial of FCPA and related charges and in 2023 was sentenced to ten years in prison. (See here for the prior post).

Jho Low remains a fugitive and there has not been any entry on the court docket for the case in approximately three years.

However, according to the DOJ Office of the Pardon Attorney website, this year Low petitioned for a pardon. Below is the entry on the DOJ’s website.

For additional reading, see here from the Wall Street Journal.

“In October 2023, the Group received a document request from the U.S. Securities and Exchange Commission (“SEC”) as it relates to Telkom Infra’s involvement in a project with the Indonesian Information and Telecommunication Accessibility Agency of the Ministry of Communication and Informatics (“BAKTI Kominfo”) regarding the provision of 4G Base Transceiver Station (“BTS”) infrastructure.”

The disclosure continues:

“The SEC has since expanded its investigation to include accounting and disclosures issues relating to the Group’s revenue recognition and financial reporting practices and internal control over financial reporting, as well as public reports regarding certain Indonesian legal proceedings involving the Group, certain subsidiaries and affiliates, and certain of the Group’s clients and suppliers. Through our internal audit process and investigations, we have determined, or we suspect (for those projects and transactions which are still under investigation) that certain transactions lack economic substance. Beginning in May 2024, the Group also received additional requests for information from the U.S. Department of Justice (“DOJ”) focused on compliance with the U.S. Foreign Corrupt Practices Act (“FCPA”). The Group retained outside counsel and a forensic accounting firm to assist with its internal investigation into the issues being investigated by the SEC and DOJ. The Internal Investigation is substantially complete while the SEC and DOJ’s investigations remain ongoing and the Group continues to cooperate with the U.S. authorities.

Based on the results of the Internal Investigation to date, the Group has identified that approximately 140 transactions, primarily those occurring prior to 2021 and particularly between 2016 and 2019 and relate primarily to the enterprise business segment, lacked economic substance and were not in compliance with applicable financial reporting standards as well as the Group’s policies and internal controls, resulting in an overstatement of certain financial information.

[…]

The Group has also cooperated with Indonesian government law enforcement authorities, and has in certain instances self-reported to them various matters involving alleged or potential violations of Indonesian laws and regulations by the Group, certain subsidiaries and affiliates, including anti-corruption, alleged fraud, embezzlement, and issues associated with trade receivables, some of which are related to the above-described matters investigated by the SEC and the DOJ. The Group has implemented various remedial actions, including strengthening policies, procedures, and internal controls, as well as enhancing its compliance function and corporate governance.”

Unlike certain other lists, the below list is calculated after consistently accounting for certain credits or deductions in several enforcement actions involving foreign companies and/or related foreign law enforcement actions.

1. Goldman Sachs

• $1.66 billion
• ($1.263 billion DOJ)($400 million SEC)
• 2020

2. Ericsson

• $1.27 billion
• ($727 million DOJ)($540 million SEC)
• 2019 / 2023

3. MTS

• $850 million
• ($750 million DOJ)($100 million SEC)
• 2019

4. Siemens

• $800 million
• ($450 million DOJ)($350 million SEC)
• 2008

5. Alstom

• $772 million
• ($772 million DOJ)
• 2014

6. KBR/Halliburton 

• $579 million
• ($402 million DOJ)($177 million SEC)
• 2009

7. Teva Phrama

• $519 million
• ($283 million DOJ)($236 million SEC)
• 2016

8. Telia

• $483 million
• ($275 million DOJ)($208 million SEC)
• 2017

9. Gunvor

• $474.4 million
• ($474.4 million DOJ)
• 2024

10. Glencore

• $443 million
• ($443 million DOJ)
• 2022