Insights

On August 11, 2025, the U.S. Department of Justice (“DOJ”) announced that it had unsealed an indictment against two Mexican businessmen for alleged violations of the Foreign Corrupt Practices Act (“FCPA”). DOJ asserts that the defendants, both Mexican nationals living in Texas, paid bribes to officials at Petróleos Mexicanos (“PEMEX”), and its subsidiary, PEMEX Exploración y Producción (“PEP”) to secure contracts worth an estimated $2.5 million. These charges come amidst a period of uncertainty regarding FCPA enforcement following the Trump administration’s temporary pause on FCPA enforcement and the subsequent issuance of new investigation and enforcement guidelines.

On February 18, 2025, a District Court judge in the Eastern District of Texas entered an order staying the last remaining nationwide injunction of the CTA’s Beneficial Ownership Information Reporting Rule (BOI Rule) in Smith v. U.S. Dep’t of the Treasury.  The BOI Rule requires certain entities formed or registered to do business in the U.S. (Reporting Companies) to report information about themselves and their natural-person beneficial owners to the Financial Crimes Enforcement Network (FinCEN), a bureau of the Treasury Department.  Following the court’s order, FinCEN issued an alert notifying Reporting Companies that the BOI Rule is back in effect with an amended deadline of March 21, 2025.

On November 8, 2024 the SEC announced a settled enforcement action against Invesco Advisers, Inc. for making misleading statements about its integration of environmental, social, and governance (ESG) factors into the firm’s investment decisions. Invesco agreed to pay a $17.5 million civil penalty to settle the matter. This enforcement action makes it clear that, even though the SEC dissolved its ESG Task Force, the Commission continues to monitor firms’ statements and representations for misleading statements about ESG.