Back Before the Fifth Circuit: DOJ Appeals Another FCPA Acquittal
On May 8, 2026, the U.S. Department of Justice appealed Judge Kenneth Hoyt’s post-verdict acquittal in the FCPA prosecution of Ramón Alexandro Rovirosa Martínez, setting up what could become a significant Fifth Circuit decision on both double jeopardy and the use of translated foreign language evidence in federal criminal trials.
Although a Houston jury convicted Rovirosa in December 2025 on conspiracy and substantive FCPA charges tied to alleged bribery of officials at Mexico’s state-owned oil company, Pemex, Judge Hoyt later vacated the convictions, concluding that the Government’s reliance on certified English translations of Spanish language communications violated the Sixth Amendment’s Confrontation Clause because the translators themselves did not testify.
The appeal raises potentially consequential questions about whether post-verdict acquittals can be reviewed without violating double jeopardy protections, and whether certified translations of foreign language communications are “testimonial” statements requiring live confrontation. This blog post explores those issues and places the appeal in the broader context of the Fifth Circuit’s continuing scrutiny of major FCPA decisions.
“Don’t Wait”: DOJ Criminal Division Chief Signals Faster Disclosure Expectations and Uptick in Corporate Enforcement
On May 7, 2026, Assistant Attorney General A. Tysen Duva used his first major speech to the compliance community since DOJ’s March 2026 rollout of its department-wide Corporate Enforcement Policy (CEP) to deliver a clear message: corporate enforcement activity is expected to increase, companies should self-disclose misconduct early—even before completing internal investigations—and robust compliance programs remain central to DOJ’s expectations.
Clear and Present Danger: DOJ Trade Fraud and Anti-Corruption Priorities Signal Lasting Compliance Risk
This article, “Clear and Present Danger: How U.S. Department of Justice Trade-Fraud and Anti-Corruption Priorities Show Trade and Customs Risks Are Here to Stay,” published in The Global Trade Law Journal, examines the DOJ’s increased focus on trade fraud, tariff evasion and Foreign Corrupt Practices Act risks. The authors highlight key enforcement trends, including expanded whistleblower incentives and renewed use of the Trade Fraud Task Force, and explain how these developments are driving more aggressive investigations. The article also outlines practical steps companies can take to strengthen trade compliance, enhance oversight of third-party intermediaries and reduce enforcement risk.
Seventh Circuit Orders Release of Sidley Client
On April 14, 2026, a Seventh Circuit panel took the rare step of ordering the immediate release of Sidley client Anne Pramaggiore from federal custody pending a new trial. Pramaggiore, the former CEO of Commonwealth Edison, was convicted in May 2023 of charges including violations of the federal programs bribery statute (18 U.S.C. § 666), violations of books-and-records provisions of the Foreign Corrupt Practices Act (FCPA), and conspiracy. Following the Supreme Court’s decision in Snyder v. United States, 603 U.S. 1 (2024), the District Court vacated the bribery convictions but left the remaining convictions intact. On appeal, the Seventh Circuit panel indicated that because two of the alleged objects of the conspiracy were invalid following Snyder, the jury returned a general verdict form not specifying what object of the conspiracy it found the defendants agreed to commit, and the jury had received a co-conspirator liability instruction (commonly known as a Pinkerton instruction) over a defense objection, it would be impossible to tell whether the remaining convictions rested on valid or invalid grounds. A full written opinion is expected to follow.
Clear and Present Danger: How DOJ Trade-Fraud and Anti-Corruption Priorities Show Trade & Customs Risks Are Here to Stay
The U.S. Department of Justice (DOJ) has signaled a renewed and sharpened focus on trade and customs-related misconduct, including tariff evasion. While DOJ’s emphasis on this enforcement area is notable in its own right, this Update highlights how DOJ’s prioritization of trade and customs fraud also brings Foreign Corrupt Practices Act (FCPA) exposure back to the forefront of risks for multinational companies. (more…)
The Freeze Has Thawed: DOJ Issues New Directive to Pursue FCPA Cases that Vindicate U.S. National Interests
On June 10, 2025, the U.S. Department of Justice (DOJ)’s Deputy Attorney General, Todd Blanche, unveiled DOJ’s new “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)” (FCPA Guidelines). The FCPA Guidelines, directed to the head of the DOJ’s Criminal Division, Matthew R. Galeotti, follows President Donald Trump’s February 10, 2025 executive order (EO) generally pausing FCPA enforcement for 180 days and directing the Attorney General to develop new criteria for new FCPA investigations in that same time period. (The prior EO was analyzed in a Sidley alert available here.)
U.S. DOJ Hits the Brakes on FCPA Enforcement and Announces Other Key Policies at the Beginning of Attorney General Bondi’s Tenure
Through a series of presidential executive orders (EOs) and Attorney General (AG) memos, the new Trump administration has signaled dramatic changes in how the Department of Justice (DOJ) will enforce white collar crime and specifically the Foreign Corrupt Practices Act (FCPA). This alert analyzes the significant takeaways for corporations that operate in the United States and across borders.