March 2026 produced two notable anti-corruption enforcement developments that illustrate the shifting but still active global bribery enforcement landscape.
On March 16, 2026, the U.S. Department of Justice filed an FCPA conspiracy charge against Alfonso Wilson, a dual U.S.-Mexican citizen who allegedly used a Texas-based intermediary to pay bribes to officials at PEMEX Exploración y Producción. Wilson pleaded guilty on or about March 31, 2026. Separately, on March 19, 2026, DOJ announced a coordinated foreign bribery resolution with France’s Parquet National Financier involving Balt USA, which agreed to a French Convention Judiciaire d’Intérêt Public requiring a fine of €1.76 million and a three-year compliance program. These cases carry important compliance implications.
The PEMEX matter is the second such case since DOJ’s FCPA enforcement resumed in June 2025, confirming that bribery linked to Mexico and Latin America remains a high priority. The Balt USA resolution — the 31st CJIP signed by France — underscores that European enforcement bodies are filling the gap left by the Trump Administration’s recalibrated FCPA stance. For multinational compliance teams, the lesson is clear: even where U.S. federal enforcement has narrowed its FCPA focus, parallel enforcement in France, the UK, and Switzerland remains vigorous. Compliance programs must maintain robust third-party due diligence, escalation protocols, and self-disclosure readiness across all jurisdictions, not just the U.S.
By FCCT Editorial Team
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