FCPA Trials and Appeals: Convicted, Then Acquitted

FCPA trial convictions and acquittals show why the payment trail and the person directing it both matter. In a Foreign Corrupt Practices Act case involving Alstom, a judge acquitted an executive after a jury convicted him, while his money-laundering convictions survived. A Texas businessman’s December 2025 jury verdict included convictions and an acquittal on different bribery charges. If you know who approved a commission, concealed an intermediary or moved a payment, these cases show why the details inside the business matter more than the headline.

The company’s resolution has its own history. Alstom pleaded guilty, the Justice Department declined to prosecute Corsa Coal, and Vitol admitted bribery under an agreement with the government. Their employees’ cases followed separate paths. For a whistleblower, the useful comparison connects a particular person’s decisions to the contract, the money and the records that explained them.

An Alstom Executive’s FCPA Convictions Became Acquittals

A jury convicted the Alstom executive of foreign bribery and money laundering. The trial court later acquitted him of every foreign-bribery charge because the government had not proved he was working for, or acting under the control of, Alstom’s U.S. business. His money-laundering convictions survived. The relationship between the person and the company mattered independently of the movement of money.

Alstom’s own guilty plea concerned books and records and internal accounting controls. In its plea agreement’s account of consultant payments, a commission fell from 3% to 1% when part of the assignment moved to another consultant. The payment changed when the consultant’s assignment changed. Who allocated that work, approved the revised commission and directed the consultant helps explain a relationship that an expense entry alone cannot.

FCPA Trial Convictions Follow Particular Decisions and Payments

Haiti Teleco Defendants and the Official Who Took the Money

The Haiti Teleco proceedings produced convictions on different charges against different defendants. Two defendants’ jury verdicts included foreign-bribery and money-laundering charges. The official who took the money was convicted of money laundering.

The customer’s public role mattered too. The appeals court’s account of Haiti Teleco described ownership by Haiti’s national bank, presidential board appointments, and monopoly and tax privileges. Those facts connected a telecommunications business to government control and public functions. An employee who knows how a customer is governed brings that public role into view alongside the payment to its manager.

The official’s role at the customer and the route by which the money reached that person belong in the same account. Haiti Teleco shows why a whistleblower’s knowledge of the commercial relationship matters alongside bank records.

The Banker in the 1MDB Bond Transactions

A Goldman Sachs banker was convicted by a jury in April 2022 of conspiracies involving foreign bribery, accounting controls and money laundering. Another participant pleaded guilty separately. Goldman Sachs’s own agreement with the government and its Malaysian subsidiary’s guilty plea were separate from the banker’s trial.

Under its deferred prosecution agreement, Goldman Sachs admitted a conspiracy involving the bond transactions. The agreement described three offerings that raised approximately $6.5 billion, with the offerings and related transactions producing more than $600 million in fees and revenue. These were financing transactions with approval committees, client checks and decisions about where the proceeds would go. The accounting-controls evidence belonged to the deal itself.

The SEC’s separate order found that compliance personnel had rejected an intermediary as a client because of concerns about his wealth. Senior employees kept working with him because they believed he could deliver government business. When an approval committee asked about his involvement, the order recorded this answer:

We see the absurdity: the intermediary was too suspect to become a client, but useful enough to keep bringing in government business. The people checking the client had raised concerns, while the people pursuing the transaction concealed his role. Someone who knew both sides of that exchange could explain why an apparently approved deal told an incomplete story.

A Georgia Uniform Supplier’s Honduras Contracts

The owner and chief executive of Atlanco, a Georgia manufacturer of law-enforcement uniforms and accessories, was convicted in September 2025 of foreign bribery and conspiracies involving bribery and money laundering. The Justice Department’s account of the criminal trial evidence traced payments to officials at TASA, the Honduran government body buying goods for national police and other security agencies.

The contracts were worth more than $10 million. The executive authorized sham invoices that sent $2.5 million to a Florida intermediary, through whom officials received bribes. Officials helped secure both the contracts and payment on them. The benefit extended beyond winning the order to getting the customer’s money released.

The trial evidence described false brokerage agreements, personal email accounts and encrypted messages. Participants called bribes commissions and fees, then moved money from Atlanco through the intermediary’s U.S. front company to accounts benefiting Honduran officials in the United States, Belize and elsewhere. We see a revealing mismatch: the paperwork described brokerage services while the money bought decisions from the customer. Officials for hire.

The intermediary and two former Honduran officials separately pleaded guilty to money-laundering conspiracy. Their roles make this a concrete procurement-bribery comparison for someone who knows the invoices, the customer contacts or the reason a payment was suddenly approved.

A Texas Businessman’s Mixed Verdict in Mexican Oil Procurement

The Texas businessman’s December 2025 jury verdict included both convictions and an acquittal. The jury convicted him of FCPA conspiracy and two FCPA violations, while finding him not guilty of another FCPA violation.

According to the criminal trial evidence, the businessman paid more than $150,000 in bribes to officials of Pemex’s exploration and production subsidiary to retain contracts and payments and obtain business advantages. Cash, luxury goods and other valuable items helped companies associated with him obtain contracts worth at least $2.5 million. For someone working on procurement or accounts receivable, the connection runs from a benefit to an official to the contract or payment that followed.

A Coal-Sales Executive and Egyptian Commissions

Corsa Coal’s former international-sales vice president was convicted in February 2026 of foreign bribery, money laundering and conspiracies involving those offenses and wire fraud. The Justice Department’s criminal trial account describes nearly $140 million in coal supply contracts with Al Nasr, then an Egyptian state-owned and state-controlled chemical manufacturer.

The trial evidence followed more than $4.8 million in purported sales commissions to an Egyptian intermediary. The intermediary used the commissions to pay bribes and also paid the executive more than $200,000 in kickbacks. Money passed through accounts in the United States and the United Arab Emirates. The executive was benefiting personally from payments his company made to obtain business.

The payment described as a selling expense also funded a private benefit for the person overseeing international sales. An insider who knows the commission approvals and the intermediary’s work helps connect that private benefit to the company payments.

The Justice Department had declined to prosecute Corsa in March 2023. Another executive separately pleaded guilty, while the international-sales vice president’s case went to a jury.

A Banker and Ghana’s Power-Plant Approvals

A former Goldman Sachs investment-banking executive was convicted in August 2026 of foreign bribery and conspiracies involving bribery and money laundering concerning a Ghanaian power plant. This was a separate matter from the bank’s 1MDB business. The Justice Department’s account of the trial describes the executive’s role in a development and financing deal between Turkish energy company Aksa Enerji and Ghana during a national energy crisis.

The trial evidence showed a scheme to pay more than $1 million in bribes to officials at several levels of government. Officials received cash during a trip to Turkey to inspect equipment, while messages discussed payments connected to project approvals. The commercial sequence gave those benefits their meaning: a bid, approvals, equipment and the financing needed to build the plant.

The executive lied to the bank’s compliance team and discussed bribes through a personal email account. Shell companies, sham invoices, accounts held in other people’s names and cash withdrawals concealed the payments. Goldman Sachs ultimately withdrew from the deal because of corruption concerns.

For someone inside a financing or project team, the difference between the internal approval story and the outside communications is especially significant. The Ghana trial showed both, connecting the representations made to compliance with the payments discussed away from it.

A Vitol Trader’s Ecuador Verdict and Mexico Guilty Plea

The Vitol trader’s jury verdict concerned foreign bribery and bribery conspiracy in Ecuador, plus money-laundering conspiracy involving Ecuador and Mexico. He separately pleaded guilty to a conspiracy involving the Foreign Corrupt Practices Act and the Travel Act in the Mexico scheme.

The trial evidence described a $300 million fuel-oil contract for Vitol. Participants used a Middle Eastern state-owned entity to get around Petroecuador’s restrictions on contracting with private companies. Fake contracts, sham invoices and shell entities in Curaçao, Panama and the Cayman Islands concealed the scheme. The same payment system also moved bribes to officials at Pemex Procurement International to obtain ethane-supply contracts.

That intermediary structure matters to someone who knows the trade. The government company named in the contract and the private business receiving the commercial benefit occupied different places in the deal. Understanding who negotiated the purchase, who benefited and who received the payments helps explain the transaction behind its formal counterparties.

Vitol itself admitted bribing officials in Ecuador, Mexico and Brazil under its December 2020 deferred prosecution agreement. That corporate admission belongs beside the trader’s verdict and separate plea.

The Evidence an Insider Can Explain

Across these cases, useful whistleblower evidence connects decisions and payments that otherwise sit in separate files. A sales employee may understand the intermediary’s assignment. Someone in finance may know why a commission changed or why an invoice was approved. A project employee may know which official controlled the next approval. Together, those observations can explain what the paperwork was designed to obscure.

The value of speaking up also reaches beyond the cases that become trial announcements. The 2019 working paper Do Corporate Whistleblower Laws Deter Accounting Fraud?, hosted by MIT Sloan, studied companies exposed to state False Claims Act incentives through pension-fund investment. It found lower estimated accounting-fraud risk after that exposure. Its relevance here is the incentive for people inside a business to reveal facts outsiders cannot see.

Foreign-bribery information can support SEC whistleblower awards, generally sharing 10% to 30% of qualifying collected sanctions among eligible whistleblowers. A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers. These are separate programs. Which one fits your facts is a question we work through with you.

You Know What Was Behind the Approval

If you know why the intermediary was paid or what an executive concealed to get a deal approved, speak with our foreign-bribery whistleblower experts. We assess the people, payments and company relationships together, develop the case strategy and bring in FCPA whistleblower lawyers with the expertise your facts require. We stay beside you throughout the case, working to turn that inside knowledge into your strongest foreign-bribery whistleblower case.