US activity holds steady after FCPA pause, Brazil leads anti-corruption enforcement, and South Africa gains momentum post-FATF delisting. Lexology PRO uncovers the key ABC enforcement trends in 2025 impacting businesses.
The data in this article is based on Lexology PRO’s Scanner, our automated regulatory monitoring tool covering 18 regulatory areas and tracking over 1500 regulatory sources. Full details on Scanner’s regulatory coverage can be found here.
Enforcement in this series includes any action regulators have taken as part of their enforcement powers, including active investigations, audits, decisions, fines, penalties, settlements, and/or orders. This report covers data – primarily agency announcements – released between 1 November 2024 and 1 November 2025.
Anti-bribery and corruption (ABC) enforcement activity was strong over the last 12 months, with key regulators clamping down on public-sector procurement and organised criminal networks.
Our data shows major ABC enforcement action in Brazil, where authorities launched large-scale, multi-agency operations targeting public sector corruption and procurement fraud.
ABC enforcement action in the US generally held steady year-on-year, despite shifting regulatory priorities and a turbulent political climate. President Donald Trump’s pause and subsequent reinstatement of the Foreign Corrupt Practices Act 1977 (FCPA) appeared to do little to change enforcement activity.
Lexology PRO explores the ABC enforcement trends demonstrated in Scanner’s data, spotlighting key enforcers, regulatory jurisdictions, and penalties.
Brazil clamps down on organised corruption networks
Brazil dominated ABC enforcement this year, combining hefty fines with multi-agency operations targeting criminal organisations and public sector fraud. Notable actions include Operation Rejeito in September 2025, which dismantled a criminal network involved in fraudulent mining licences. There was also the 500 million reais (US$94 million) penalty imposed by the Office of the Comptroller General (CGU) on Toyo Engineering Corporation in April 2025 over bribery payments and fraud involving state-owned oil company Petrobras.
Brazil’s dominance, however, is counterbalanced by limited ABC activity in other Latin American jurisdictions.
APAC regulators step up ABC enforcement
Thailand retained its position as a top enforcer amid domestic corruption scandals – through joint raids and arrests targeting public officials. In March 2025, the National Anti-Corruption Commission, the Office of the Public Sector Anti-Corruption Commission, and the Office of the Public Sector Anti-Corruption Commission arrested seven officials from the Bangkok Metropolitan Administration's Department of Culture, Sports, and Tourism over fraudulent bus repair contracts.
Elsewhere, regulators in Indonesia cracked down on bribery and corruption with multiple raids and arrests, including a sting operation related to forest management permits in August 2025, which resulted in nine arrests.
US enforcement activity holds steady despite FCPA pause
ABC enforcement activity continued in the US, driven by the Department of Justice (DOJ) and the Office of Foreign Assets Control (OFAC), but dipped slightly year-on-year. Major actions include a US$202 million settlement with Gilead Sciences over illegal kickback payments in July 2025, and the DOJ’s 13-year prison sentence for the CEO of a shipbuilding company involved in a US$29 million investment fraud scheme.
Global perceptions of US enforcement power remain strong even after Trump paused the FCPA in February 2025. Despite the pause, some companies were hit with major penalties and the FCPA was reinstated in June. In October, a US federal grand jury charged Smartmatic with conspiracy to violate the FCPA, while in November, a subsidiary of Millicom agreed to pay US$118 million to settle FCPA charges over alleged bribe payments to Guatemalan officials.
South Africa gains momentum on ABC enforcement
South Africa also made headlines for ABC enforcement in 2025. The Department of Home Affairs dismissed six officials for fraud and corruption, and the Police Minister was suspended over alleged ties to organised crime networks. South Africa’s efforts formed part of a wider regulatory overhaul culminating in the country’s removal from the Financial Action Task Force grey list on 24 October 2025.
What can we expect from ABC enforcement in 2026 and beyond?
Authorities are expected to continue their crackdown on ABC globally, with highly active jurisdictions and authorities doubling down on enforcement.
Brazil is likely to see increased investigative momentum ahead of the upcoming 2026 general election.
“Corruption is a topic of debate in the political arena in Brazil (and elsewhere) and new cases are likely to appear during the campaign” says José Alexandre Buaiz Neto, Brazil-based partner at Pinheiro Neto Advogados.
Eloy Rizzo Neto, Brazil-based partner at Demarest, offers a similar prediction: “2026 is likely to consolidate more stable, predictable, and comprehensive enforcement, with an emphasis on effective prevention, proportional accountability, and transparency, reflecting the incorporation of integrity as a structuring pillar of public governance in Brazil.”
In the US, FCPA enforcement will be narrower and more targeted in 2026 under new guidance issued by the DOJ in June 2025. Enforcement is expected to concentrate on serious bribery schemes tied to cartels and transnational criminal organisations, and corruption that harms US companies operating abroad. Routine or low-value misconduct is expected to fall off the enforcement agenda. The DOJ’s guidance also encourages US companies to investigate and report misconduct by competitors – especially non-US ones. Foreign entities should prioritise compliance as the regulatory landscape sharpens.
Following its removal from the FATF grey list in October 2025, South Africa is expected to continue strengthening corruption-related enforcement to maintain progress ahead of the next FATF review in 2026.