Latin America Enforcement Trends in 2026

The Department of Justice's (DOJ) Fraud Section released its 2025 Year in Review in January 2026, marking the Section's 70th anniversary with record-breaking results: 265 defendants charged, over $16 billion in aggregate intended fraud loss, 25 trials in 17 districts, and 15 corporate enforcement actions totaling approximately $1 billion in resolutions.

DOJ has affirmed that Latin America remains a central focus of U.S. enforcement, even as FCPA policy has evolved under revised DOJ guidance issued in 2025. Recent DOJ memoranda, enforcement actions, and coordinated cross-border initiatives demonstrate concentrated efforts to combat corruption and fraud that intersects with cartels, transnational criminal organizations (“TCOs”), consumer fraud schemes, and U.S. economic and national security interests.

Companies operating in, sourcing from, or transacting with Latin America should expect continued scrutiny, particularly where third parties, state-owned entities, customs and logistics, financial intermediaries, or consumer-facing business models are involved.

The Shifting Enforcement Landscape

Despite the February 2025 Executive Order temporarily pausing FCPA enforcement and reduced FCPA Unit staffing, the Year in Review makes clear that "the Criminal Division is prosecuting FCPA violations, consistent with the Deputy Attorney General's Guidelines, in a way that vindicates U.S. interests by ensuring that criminal actors in this space are held to account." The Deputy Attorney General's Guidelines in June 2025 reinforce that a “primary consideration” for DOJ in determining whether to proceed with an FCPA matter is the nexus between the alleged misconduct and cartel and TCO activity.  

Specifically, the Guidelines direct prosecutors to prioritize cases involving:

1. Criminal operations of a cartel or TCO; 
2. Misconduct utilizing money launderers or shell companies that engage in money laundering for cartels or TCOs; or 
3. Misconduct linked to employees of state-owned entities or other foreign officials who have received bribes from cartels or TCOs. See our previous alert here.

These priorities have particular implications for Latin America given the region's significant cartel presence. Companies should not interpret the enforcement pause or policy shifts as signaling diminished FCPA risk, particularly in Latin America.

Enforcement Actions from the Year in Review with Latin America Connections

• US$118 Million Resolution of TIGO Guatemala/Millicom

  In November 2025, Comunicaciones Celulares S.A., d/b/a TIGO Guatemala, a wholly-owned subsidiary of Millicom International Cellular, S.A., entered into a two-year Deferred Prosecution Agreement (DPA). Between 2012 and 2018, TIGO Guatemala made monthly cash payments to Guatemalan Congress members in exchange for legislative support. Critically, some of the cash originated from laundered narcotrafficking proceeds.

  TIGO Guatemala agreed to pay a $60 million criminal penalty and $58.2 million in forfeiture. DOJ afforded a 50% reduction based on voluntary self-disclosure in 2015, and subsequent cooperation. However, the company did not qualify for a CEP declination due to continuation of misconduct after disclosure.
   

• Indictment Against SGO Corporation Limited and Venezuelan Individuals

  In October 2025, DOJ indicted SGO Corp., a/k/a Smartmatic Group, an election technology company, along with three executives, including Venezuelan and Israeli nationals, for an alleged bribery scheme involving Philippine election officials. This marked the Fraud Section's first corporate FCPA indictment in 15 years, signaling that corporate indictments remain a tool in the FCPA enforcement arsenal.
   

• Individual Prosecutions Involving Latin America

  The Year in Review highlights several individual enforcement actions involving bribery schemes that spotlight Latin America: Carl Zaglin, the owner and CEO of Atlanco LLC, was convicted in September 2025 for bribing Honduran officials in connection with $10 million in government contracts, resulting in being sentenced to 8 years in prison and ordered to forfeit over $2 million; and Ramon Alexandro Rovirosa Martinez, a Mexican citizen and Houston business man, was convicted in December 2025 for bribing Mexican government officials at  Petróleos Mexicanos (PEMEX) in exchange for $2.5 million in contracts, facing a maximum penalty of 15 years in prison.

  In addition, two Guyanese nationals, Nazar Mohamed and Azruddin Mohamed, were indicted in October 2025 for a $50 million tax evasion scheme involving bribes to customs officials, money laundering, conspiracy and wire fraud. These actions underscore DOJ's continued focus on individual accountability.

Beyond FCPA: Consumer Fraud Enforcement with Latin America Connections

The Year in Review also highlights significant enforcement activity by the Fraud Section's MGC Unit involving Latin America-based schemes targeting U.S. victims.

In July 2025, DOJ charged Michael Shannon Sims and Juan Carlos Reynoso in connection with wire fraud and money laundering for a $650 million investment fraud scheme. Reynoso allegedly operated the fraud scheme across Latin America and Puerto Rico. In September 2025, David Cornejo Fernandez, a Peruvian national, was sentenced to over 6 years in prison for providing services to fraudulent call centers in Peru that targeted Spanish-speaking U.S. victims, defrauding more than 8,800 individuals. Additionally, in July 2025, Roger Roger, a Costa Rica resident, received a more than 15 years sentence for leading a Costa Rica-based telemarketing fraud scheme that stole over $4 million from U.S. victims. These prosecutions reflect DOJ's broader commitment to dismantling cross-border fraud operations that exploit the region's infrastructure to victimize U.S. consumers.

Key Takeaways

• Cartel Connections Trigger Heightened Scrutiny. DOJ has demonstrated aggressive pursuit of conduct with connections to cartels, TCOs, and narcotrafficking, as the TIGO Guatemala resolution demonstrates. Companies should assess risks related to third-party intermediaries and government-facing transactions in high-risk jurisdictions, including whether third parties, distributors, customs brokers, or payment channels may have organized crime links.
• Self-Disclosure Benefits Require Full Compliance. Voluntary self-disclosure yields significant penalty reductions, but requires complete disclosure and immediate cessation of misconduct. TIGO Guatemala received a 50% penalty reduction for cooperation, underscoring the value of robust document preservation and timely engagement with DOJ.
• Individual Accountability Remains a Priority. The Zaglin and Rovirosa trial convictions demonstrate DOJ's continued commitment to holding individuals accountable for FCPA violations. Companies should ensure employees understand the personal consequences of misconduct.
• Cross-Border Fraud Schemes Face Aggressive Prosecution. The MGC Unit cases involving Peru, Costa Rica, and Latin America-wide operations reflect DOJ's focus on dismantling fraud networks that exploit the region to target U.S. victims. Companies with consumer-facing operations, marketing, or payment flows connected to Latin America – including tourism, financial services, e-commerce, and digital platforms – should anticipate increased scrutiny of cross-border fraud risks, particularly where schemes target U.S. consumers.
• What to Do Now When Considering Latin America Operations. With DOJ intensifying its Latin America enforcement focus, companies should treat compliance as a value driver, mitigating risk through recalibrated risk assessments, rigorous third-party diligence, and strengthened internal controls around heightened risk activities. Specifically, companies should consider mapping, including updating their risk assessment scope, to evaluate activities in Latin America, including: (i) government interactions; and (ii) potential cartel/TCO touchpoints (e.g., logistics providers, customs brokers, security and permitting requirements, etc.). Companies would also be well advised to reevaluate diligence scope, risk ranking, and contractual obligations, as well as ongoing monitoring requirements for those higher risk third party engagements in Latin America. In addition, companies may consider tightening approvals and documentation requirements for business courtesy, sponsorship, and donation activities in the region. Further, developing and delivering targeted training for Latin America facing teams focused on, for instance, foreign officials, third-party red flags, and cartel and TCO risks, will help empower employees to identify potential issues or concerns and to escalate them accordingly.

Womble Bond Dickinson (US) LLP’s White Collar Defense and Criminal Investigations Team navigates domestic and international clients in all manner of white collar, regulatory, corporate and congressional investigations. Our team includes a distinguished roster of veteran defense attorneys, former federal prosecutors and U.S. Attorneys who served at the highest levels of the Department of Justice and at leading United States Attorneys’ Offices. Our team includes Chambers Ranked (Band 1) lawyers and alumni of the U.S. Department of Justice, the SEC’s Enforcement Division, the U.S. Senate, House of Representatives, and in-house compliance specialists of publicly traded companies.