On October 23, 2025, a customs broker operating in both the United States and Mexico pleaded guilty to conspiring to violate the Foreign Corrupt Practices Act (FCPA) before a magistrate judge in the U.S. District Court for the Western District of Texas. Although the plea agreement remains under seal, it was approved and adopted the following day, on October 24, 2025. 2025. According to court fillings, the individual—who owns a customs brokerage based in Chihuahua, Mexico, and a freight forwarding business in El Paso, Texas—is scheduled to be sentenced on January 8, 2026.
This case marks the latest in a series of FCPA prosecutions brought by the Department of Justice (DOJ), which resumed FCPA enforcement in June following a temporary freeze earlier in the year. Specifically, on February 10, 2025, President Donald Trump issued Executive Order 14209 temporarily halting new FCPA cases and investigations, describing enforcement of the statute at the time as “overexpansive and unpredictable” and asserting that it diverted limited prosecutorial resources to target U.S. citizens and businesses for engaging in “routine business practices [undertaken] in other nations.”
On June 9, 2025, U.S. Deputy Attorney General Todd Blanche issued a memorandum outlining the DOJ’s renewed approach to handling FCPA cases consistent with Executive Order 14209. In particular, Blanche’s memo directs prosecutors to prioritize serious misconduct and instructs prosecutors to pay particular attention to schemes that could implicate U.S. national security interests—such as customs fraud, which the DOJ has described as an unlawful means “to circumvent the rules and regulations that protect American consumers and undermine the Administration’s efforts to create jobs and increase investment in the United States,” thereby harming “the U.S. economy, American competitiveness, and our national security.”
Partner Mark Cipolletti of the firm’s White Collar Defense & Investigations Practice Group contributed to this article.