Top 10 International Anti-Corruption Developments for January 2025

Designed for the busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important anti-corruption law and enforcement developments from the past month, with links to primary sources. This month we ask: How many foreign bribery cases did the U.S. Department of Justice (DOJ) bring in 2024? How many corruption cases did Chinese authorities file in 2024? Which company was convicted in Switzerland for foreign bribery? The answers to these questions and more are here in our January 2025 Top 10.

1. DOJ Releases Final Criminal FCPA Statistics for 2024

On January 17, 2025, DOJ’s Fraud Section published its annual Year in Review for 2024. According to the Year in Review, in 2024, the Fraud Section’s Foreign Corrupt Practices Act (FCPA) Unit obtained nine corporate resolutions, which resulted in total U.S. criminal monetary amounts of more than $1.357 billion and total global monetary amounts of more than $2.306 billion. According to the Year in Review, the FCPA Unit charged 23 individuals and convicted 16 individuals, either through guilty pleas or at trial. The Year in Review noted that, in December 2024, DOJ published an addendum to the Resource Guide to the U.S. Foreign Corrupt Practices Act (2d ed), discussing the Foreign Extortion Prevention Act (FEPA), which was amended in July 2024. The Year in Review also stated that in May 2024, four experienced FCPA Unit prosecutors were selected to serve as regional representatives for the Criminal Division’s International Corporate Anti-Bribery (ICAB) initiative, the creation of which was announced in November 2023.

2. Swiss Commodities Trader and Former Senior Executive Convicted in Switzerland for Bribing Angolan Official

On January 31, 2025, trading company Trafigura and Mike Wainwright, the company’s former chief executive officer, were found guilty of corruption after Switzerland’s top criminal court found the defendants made over $5 million in payments to an Angolan official in exchange for oil contracts. Trafigura was fined $148.9 million and Wainwright was sentenced to 32 months with 20 months suspended. He is appealing his conviction. For Switzerland, this was the first time that a company was charged at its highest court with corrupting a foreign official. Charges against Trafigura were first announced in December 2023. Its parent company, Trafigura Beheer B.V., pleaded guilty to FCPA-related charges in March 2024 after the U.S. government alleged the company paid officials at Brazil’s national oil company nearly $20 million in exchange for business advantages in the oil market.

3. Former U.S. Senator Sentenced to 11 Years in Prison Following Bribery and Corruption Conviction

On January 29, 2025, former U.S. Senator for New Jersey, Bob Menendez, was sentenced to 11 years in prison following his July 2024 conviction on 16 counts of bribery, conspiracy, acting as a foreign agent, wire fraud, extortion, and obstruction of justice. The trial focused on overlapping bribery schemes in which the senator and his wife allegedly accepted hundreds of thousands of dollars of bribes in the form of cash, gold bars, a car, and mortgage payments in exchange for, among other things, helping to steer billions of dollars in American aid to Egypt and making favorable statements about Qatar. In addition to his prison sentence, Menendez was ordered to forfeit $992,000 in allegedly ill-gotten gains. Two alleged co‑conspirators in the bribery scheme, Fred Daibes and Wael Hana, were also sentenced. Daibes, a New Jersey real estate developer accused of delivering gold and cash to Menendez, was sentenced to seven years in prison, fined $1.75 million, and ordered to forfeit $125,000. Hana, an Egyptian American businessman accused of brokering deals between Menendez and the Egyptian government, was sentenced to eight years in prison and a $1.25 million fine. (For more on the Menendez case, see our September 2023, October 2023, January 2024, and July 2024 Top 10s.) 

4. Former Finance Minister of Mozambique Sentenced in $2 Billion Fraud and Money Laundering Scheme

On January 17, 2025, Manuel Chang, the former Finance Minister of Mozambique, was sentenced to 102 months in prison following his August 2024 conviction for conspiracy to commit wire fraud and conspiracy to commit money laundering in connection with his role in an alleged scheme to steal approximately $200 million from a total of $2 billion in loans issued to state‑controlled companies between 2012 and 2016 for three maritime projects, including one related to tuna fishing. In addition to his prison sentence, Chang was ordered to forfeit $7 million, the amount he allegedly received in exchange for signing guarantees to secure the loans, with restitution to be determined later. (For more on Chang and the “tuna bonds” case, see our January 2019, March 2019, July 2023, and May 2024 , and August 2024 Top 10s.)  

5. United States Enters into Agreement to Transfer Corruption Proceeds to Nigeria

On January 10, 2025, DOJ announced that the United States has entered into an agreement to transfer approximately $52.88 million in forfeited assets to the Federal Republic of Nigeria in recognition of Nigeria’s assistance in a corruption investigation involving the Nigerian oil industry. The funds, forfeited through the Kleptocracy Asset Recovery Initiative, will support electrification projects and counterterrorism efforts in Nigeria. Specifically, $50 million will be allocated to the Nigeria Distributed Access Through Renewable Energy Scale-Up project, an existing electrification project, while $2.88 million will support Nigeria’s contribution to the International Institute for Justice and the Rule of Law. The agreement, signed in Abuja by Nigerian and U.S. officials, includes measures to ensure transparency and accountability, with funds managed under World Bank oversight and subject to auditing and public reporting requirements.

6. DOJ Secures Civil Forfeiture Related to Venezuelan Bribery Scheme

On January 10, 2025, DOJ announced that Southern District of Florida Judge Melissa Damian had ordered the forfeiture of over $20 million in proceeds from an alleged foreign bribery and money laundering scheme involving Venezuelan national Naman Wakil. From 2008 to 2014, Wakil allegedly paid tens of millions in bribes to secure lucrative food contracts with Venezuela’s state-owned food agency, Corporación de Abastecimiento y Servicios Agrícola (CASA). The illicit proceeds were allegedly laundered through accounts in the Cayman Islands, Switzerland, and subsequently into South Florida. DOJ announced charges against Wakil in August 2021.

7. DOJ Recovers More Assets Misappropriated from Malaysia

On January 17, 2025, DOJ announced that it had reached an agreement to recover an additional $20 million in funds misappropriated from 1Malaysia Development Berhad (1MDB), a state-owned strategic financing company formed to promote economic development in Malaysia through global partnerships and foreign direct investment. According to DOJ, the misappropriation was facilitated by bribes paid to 1MDB officials and other Malaysian officials. This adds to the approximately $1.4 billion already recovered and returned to Malaysia as of June 2024. The recovery is part of a broader effort involving 43 civil forfeiture actions, making it the largest-ever recovery under the Kleptocracy Asset Recovery Initiative. (For more on 1MDB, see our July 2016, August 2016, June 2017, December 2017, May 2018, June 2018, August 2018, October 2018, February 2019, May 2019, April 2020, August 2021, September 2021, December 2021, February 2022, March 2023, April 2023, December 2023, and June 2024 Top 10s.) 

8. Former French President’s Corruption Trial Begins in Paris

On January 6, 2025, the trial of former French President Nicolas Sarkozy began in Paris. Sarkozy faces allegations that his 2007 campaign received illegal financing from the Libyan government of Colonel Muammar el-Qaddafi.  French prosecutors are calling the scheme a “corruption pact” and say that they plan to introduce evidence showing that Sarkozy’s campaign received at least $6.2 million from the Libyan government. Sarkozy was placed under formal investigation for the Libyan conduct in March 2018. In December 2024, Sarkozy exhausted his final appeal in a separate corruption and influence peddling case and became the first former French president sentenced to actual detention, although his time will be served under house arrest.

9. Chair of OECD Working Group Highlights Anti-Corruption Achievements, Calls for Authorities to Ensure That “Corruption Still Has Profile” 

In a January 21, 2025 interview marking the 25th Anniversary of the Organisation for Economic Co-Operation and Development (OECD) Anti-Bribery Convention, Kathleen Roussel, chair of the OECD Working Group on Bribery, emphasized the importance of maintaining focus on the fight against corruption, especially during economic downturns and political instability. She highlighted the convention's achievements in establishing a common legislative framework and fostering peer learning among its 46 member countries. Roussel identified key challenges such as prioritizing enforcement, improving mutual legal assistance, and managing long-term cases. She stressed the need for whistleblower protections and the role of the Working Group as a resource for both member and non-member countries. Roussel called on governments, the private sector, and civil society to keep corruption in the spotlight and make clear connections between corruption, economic wellness, and societal health.

10. China Reports on 2024 Anti-Corruptions Statistics, Previews Focus of Anti-Corruption Efforts

On January 10, 2025, China’s Central Commission for Discipline Inspection (CCDI) reported that it had filed more than 4,000 disciplinary cases against officials in 2024. A record 58 senior officials were investigated, with 47 at the vice-ministerial level or above. Two days earlier, the CCDI had stated that it will rigorously investigate corruption cases in which political and economic issues intertwine and that it would focus its efforts in the areas of development zones, energy, engineering construction and tenders, finance, firefighting, higher education, medicine, sports, state-owned enterprises, and tobacco. The CCDI also stated that it plans to draft a law to combat cross-border corruption. On January 6, 2025, China’s President Xi Jinping stated that corruption is the “biggest threat” to the Communist Party, emphasizing the need for rigorous anti-corruption measures.