Dear Clients and Friends,
We’re pleased to share our review of key updates and developments in anti-bribery and anti-corruption legislation, policy and enforcement from the past year. These updates and developments are likely to affect compliance requirements in 2026 for companies operating in Israel and worldwide and underscore the importance of proactively planning and refreshing compliance programs for the year ahead.
Global Regulatory and Policy Updates
Updates to FCPA Enforcement Policy
On February 10, 2025, President Trump signed an Executive Order directing, among other things, a suspension on opening certain new FCPA-related investigations for 180 days. During this period, the US Department of Justice (DOJ) was required to re-examine enforcement policy and present updated enforcement priorities, emphasizing US economic and security interests. The Order does not alter the applicability of the law itself, and potential exposures may still arise through parallel enforcement channels (including securities laws, export control legislation, and internal control obligations).
On June 9, 2025, the DOJ published updated guidelines for FCPA enforcement. These updates shifted priorities, including among other things, emphasizing a focus on cartels and transnational criminal organizations, protecting US economic competitiveness by addressing corruption that harms American companies; protecting national security, particularly in areas such as defense, sensitive technologies, and critical infrastructure; and prosecuting cases with clear indications of corrupt intent, such as significant bribe payments, use of sophisticated concealment mechanisms, and obstruction of justice.
Establishment of International Task Force to Combat Corruption (UK-France-Switzerland)
On March 20, 2025, the UK (SFO), France (PNF), and Switzerland (OAG) announced the establishment of an international task force to fight corruption. This initiative aims to deepen cooperation between the three countries in the fight against bribery and international corruption, and to coordinate cross-border investigations efficiently. The establishment of the task force institutionalizes and concretizes the successful cooperation demonstrated in the past, and signals to companies operating in Europe regarding coordinated and potentially stricter enforcement.
US States Signal Use of Local Legislation as Alternative/Supplement to FCPA Enforcement
On April 2, 2025, the California Attorney General’s Office published an opinion stating state laws may be used to fill potential gaps in federal enforcement. Similarly, the District Attorney of New York declared that they have the authority to prosecute local bribery and corruption offenses.
UK SFO Launches New Self-Reporting Route in Bribery Cases
On April 24, 2025, the UK Serious Fraud Office (SFO) published new guidelines offering businesses a clear path to avoid prosecution in bribery cases. A company which suspects has committed an offense, and which decides to cooperate fully with investigators, can expect to be invited to negotiate a Deferred Prosecution Agreement (DPA) instead of standing trial. The guidelines clarify what constitutes “genuine cooperation,” including preserving physical and digital materials, presenting facts, and early sharing of any internal investigation with the SFO. Additionally, the guidelines present examples of situations considered non-cooperative behavior, including attempts to minimize or obscure the involvement of individuals
DOJ Guidelines for Appointing an External Compliance Monitor in Corporate Resolutions
On May 12, 2025, the DOJ published an updated guidance document clarifying the Criminal Division’s policy regarding the appointment of an external compliance monitor in corporate resolutions and the manner of their supervision. An external monitor is intended to reduce the risk of recurring offenses and ensure the implementation of an effective compliance program. The guidance document details the considerations for deciding to appoint a monitor, primarily the risk of recidivism harming economic interests. The document also includes mechanisms for cost reduction and preventing overreach of authority. Finally, the document defines the formal selection process for the compliance monitor.
Update to DOJ White Collar Enforcement Program and Incentives for Voluntary Disclosure
On May 12, 2025, the DOJ Criminal Division updated the pilot program for rewarding corporate whistleblowers as part of the publication of the new White Collar Enforcement Program. Under this program, the enforcement policy for voluntary disclosure was updated, increasing the fine reduction to up to 75% of the minimum fine for companies that fully cooperate and remediate. Furthermore, it allows for case closure without a financial penalty for companies that voluntarily report before being exposed by authorities, provided specific conditions are met. The goal is to incentivize corporations to voluntarily report, take responsibility, and rehabilitate, while fully cooperating with authorities.
European Union Publishes Rule of Law Report and Anti-Corruption Trends
On July 8, 2025, the EU published its Rule of Law Report for 2025, showing a positive trend in several areas, including strengthening anti-corruption policies, increasing budgets, and reinforcing judicial systems. For corporations operating in Europe, these trends are reflected, inter alia, in deepened expectations for disclosure, transparency, and implementation of effective compliance mechanisms, as well as variations between member states regarding actual enforcement levels.
US Securities and Exchange Commission (SEC) – Cross-Border Anti-Fraud Task Force
On September 5, 2025, the SEC announced the establishment of a task force to strengthen and increase enforcement efforts to identify and combat cross-border fraud harming US investors. The task force’s increased focus on gatekeepers, financial reporting accuracy, and internal controls of foreign companies may indirectly impact exposures regarding bribery and corruption aspects—particularly within the “books and records” and internal accounting control components of the FCPA. Any deficiency revealed in the control system may serve as an entry point for examining payments, use of intermediaries, and compliance with accounting standards.
Progress Toward European Union Unified Framework for Corruption Offenses Anti-Corruption Directive
Following previous developments, on December 2, 2025, the EU published a press release regarding a general agreement against corruption brokered between the EU Parliament and the Council. The proposed law is intended to replace two separate EU laws, one from 2003 dealing with private sector corruption and one from 1997 regarding corruption involving EU or member state officials. Key points in the agreement included presenting unified definitions for corruption offenses including active and passive corruption, minimum criminal penalties, corporate criminal liability in situations where company employees commit corruption offenses for its benefit, and more. The legislation is still in process, with the next step being the approval of the agreement in the Parliament and the formal Council before entering into force.
UK Publishes Bribery Indicators (SFO/IFBT)
On December 22, 2025, the SFO, together with the International Foreign Bribery Taskforce (IFBT), published guidelines for identifying potential indicators of foreign bribery. The guidelines highlight factors that may indicate foreign bribery activity, aiming to assist businesses and professionals operating in high-risk sectors to identify concerning patterns. In compliance terms, these are ‘red flags’ such as unusual commissions, unconventional payment routes, missing documentation, and vague services. These indicators are intended to enable early prevention rather than just retroactive reaction.
Publication of 2025 Corruption Perceptions Index (CPI)
On February 10, 2026, Transparency International published its 2025 Corruption Perceptions Index (CPI), ranking the perception of public sector corruption levels in approximately 180 countries. Israel received a score of 62 out of 100, where 0 signifies “highly corrupt” and 100 signifies “very clean” under the CPI scoring system. Israel’s ranking decreased two points from 64 to 62 compared to the previous year and was ranked 35th out of 180 countries. In terms of compliance, the index does not create a legal obligation per se but serves as a relevant indication for prioritizing due diligence, controlling intermediaries, and planning audits in countries with higher risk profiles.
Local Regulatory and Policy Updates
Legal Assistance Between Countries Law (Amendment 12), 2025 – Expansion of Asset Forfeiture and Freezing Scope
On March 19, 2025, a bill to amend the Legal Assistance Between Countries Law was submitted to the Knesset, aiming to align the law with international standards. The bill was subsequently published, aiming to assist Israel in aligning with international standards. The bill expands the authority to confiscate and freeze assets of Israelis suspected or convicted of an offense in a foreign country. Under the previous version of the law, when proceedings were conducted against an Israeli citizen in a foreign country for various offenses potentially related to bribery (such as money laundering), that country could request Israel to confiscate property only that was connected to the offense. The new bill proposes allowing the confiscation of property of equivalent value, even if not directly related to the offense.
Ministry of Defense Calls on Defense Exporters to Develop Anti-Bribery and Corruption Compliance Programs
On November 18, 2025, the Director General of the Ministry of Defense (MoD) published a letter to defense exporters calling on them to formulate a compliance program for preventing bribery and corruption. The Ministry emphasized the importance of anti-bribery and corruption policy in defense exports. The appeal comes against the backdrop of Israel’s commitment to the fight against corruption, alongside the need for defense exporters to maintain a program for preventing bribery and corruption. The Director General also requested exporters who’ve already adopted anticorruption programs to re-examine their procedures, update them, and verify their efficient implementation within the framework of the company’s activity.
Israel State Comptroller Recommends Tightening Oversight of Marketing Agents in Defense Export Transactions
On December 2, 2025, the State Comptroller published the annual audit report on the defense establishment. Among the subjects addressed was the Israeli Ministry of Defense’s (IMOD) oversight of defense companies’ use of agents providing marketing services in defense export transactions. The State Comptroller’s key recommendations for IMOD include:
- Formulating recommendations delineating the extent of the Ministry’s involvement in overseeing defense companies’ use of marketing agents, including regarding commissions.
- Considering introducing minimal compliance rules on bribery and corruption that small and medium-sized defense companies must adopt and implement, including with respect to due diligence processes regarding marketing agents.
- Determining whether and how to supervise the compliance programs of small and medium-sized defense companies, alongside establishing a database for managing information on compliance programs.
- Considering a requirement for detailed statements regarding marketing agents within agreements related to defense exports.
- Defining specific criteria for requiring personal statements from defense company personnel concerning the use of marketing agents.
- Building a complete database on those acting as marketing agents for defense companies, both Israeli and foreign, including marketing licenses they have received or marketing and export licenses in which their names were mentioned.
- Determining the required level of board involvement in approving engagements with marketing agents, especially where the identity of the agent or the commission amount is unusual (according to criteria to be set).
- Addressing conflicts of interest of marketing agents, particularly former senior officials in IMOD, and requiring disclosure regarding compliance with cooling-off laws.
- Regulating commissions for marketing agents in defense export transactions by defense companies.
- Regulating the interface of IMOD employees with defense companies’ marketing agents and prohibiting participation of marketing agents in activities organized by IMOD departments.
- Regulating IMOD’s activities to ensure defense companies’ compliance with OECD guidelines, including anchoring in the Ministry’s directives all required anti-bribery and anti-corruption measures in defense export transactions and the officials responsible for their implementation, including a coordinating authority.
Key Local Enforcement Events in 2025
Employment as a Means of Bribery: Conviction of Company and Manager for Bribing a Senior Official in Eilat Municipality and Ancillary Tax Offenses
On January 21, 2025, the Beersheba District Court convicted a security company and its manager of bribery, fraud and breach of trust, and managing false books of account. The bribe was given through the employment of a senior municipality official (Director of the Sports Department) as an event manager on its behalf, and payment of salary for this work. The Court ruled that this employment, carried out with the manager’s knowledge of the official’s public role and ability to influence the company’s business vis-à-vis the municipality, constitutes a prohibited form of bribery. Additionally, the conviction was based on serious tax offenses under the Income Tax Ordinance. It was determined that the company and its manager managed false books of account by transferring part of the official’s salary to his sons’ bank accounts, at his request, to assist him in evading full tax payment. The Court viewed this mechanism, intended to grant the official an additional financial benefit, as an inseparable part of the bribery act. The verdict emphasizes that bribery can also be embodied in payments that appear legitimate, such as salary, when given to an influential party in exchange for promoting interests. Furthermore, it serves as a warning sign to companies that the use of false tax mechanisms to conceal or transfer illicit payments is not a technical offense, but a serious criminal offense standing on its own and strengthening the elements of the bribery offense.
Court Convicts in Plea Bargain in Yehuda Regional Council Bribery Affair
On December 3, 2025, the Court convicted a company, and its controlling shareholder within the framework of a plea bargain for the offense of bribing the former Head of the Mateh Yehuda Regional Council. During the years 2010-2015, the company received confidential insider information and influenced threshold conditions in infrastructure and construction tenders in the Council, which the company won. In exchange for promoting the company’s interest, a cash bribe totaling NIS 200,000 was given to the Council Head.
Under the plea bargain and sentenced the shareholer to 22 months of actual imprisonment, 12 months of suspended imprisonment, and a significant financial fine of NIS 3,000,000. A symbolic fine only was imposed on the company. In his decision, the Judge noted that the arrangement is balanced considering the severity of the bribery offense and the corruption of public administration on one hand, versus the evidentiary difficulties in the case, the saving of considerable judicial time, and the total economic component paid by the defendant (approx. NIS 25 million in two parallel cases).
Key Global Enforcement Events in 2025
UK SFO Charged British Insurance Agent with Failure to Prevent International Bribery (Section 7 of UK Bribery Act)
On April 17, 2025, the UK Serious Fraud Office (SFO) published an announcement that United Insurance Limited was charged with failure to prevent bribery under Section 7 of the UK Bribery Act 2010, due to payments made by intermediaries in the US to government officials in Ecuador between October 2013 and March 2016, to obtain insurance contracts totaling $38 million. This is a seminal case where the defense argument of whether the company did everything required to prevent bribery (“adequate procedures”) will be examined in court. The next hearing is expected to take place in May 2026.
FIFA Affair: Commercial Bribery as Honest Services Fraud
On July 2, 2025, the US Court of Appeals remanded the issue of the FIFA corruption affair to the District Court, ruling that the “Honest Services Fraud” offense (1346) also applies to international commercial bribery. Later, on December 9, 2025, a request was submitted on behalf of the State to remand the discussion to the District Court for the dismissal of the indictment due to justice and “prosecutorial discretion.” On January 12, 2026, the Supreme Court approved the request. The hearing will be returned to the District Court where the request to dismiss the indictment will be discussed.
Decision Not to Prosecute Liberty Mutual for FCPA Violations
On August 7, 2025, the US DOJ, in cooperation with the US Attorney’s Office for the District of Massachusetts, announced a decision not to prosecute Liberty Mutual for FCPA violations. The decision came despite information that between 2017-2022, bribes amounting to $1.47 million were paid through its Indian subsidiary (LGI) to officials in six state-owned banks, aiming to obtain or retain business. The payments were disguised as marketing expenses and were also executed through intermediaries. The decision was made in accordance with the enforcement and voluntary self-disclosure policy updated in May 2025. The DOJ clarified that the arrangement does not grant immunity to individuals, and in the case of new information, the state may reopen the investigation.
This case demonstrates the incentives available to a company when choosing to voluntarily disclose and fully cooperate with the regulator, alongside the continued risk at the individual level.
Smartmatic Group Accused of Bribery and Money Laundering in the Philippines
On October 16, 2025, the US Attorney’s Office in Florida published an announcement regarding the filing of an indictment against SGO Corporation Limited (known as part of “Smartmatic”), three of its executives, and the former Chairman of the Commission on Elections in the Philippines (COMELEC). The charges were for conspiracy to pay bribes and money laundering in an amount exceeding $1 million between 2015-2018, aiming to obtain and retain favorable deals and payments vis-à-vis COMELEC regarding tenders and contracts related to the 2016 elections. Allegedly, the bribe was funded via a “slush fund” created by over-inflating the cost of machines sold by the company, and concealment was executed using coded language, false contracts, and fictitious loan agreements. Funds were transferred through accounts in Asia, Europe, and the US. The charges include conspiracy to violate the FCPA, FCPA violation, conspiracy to launder money, and international money laundering. Among the defendants is a dual Israeli-Venezuelan citizen, for conspiracy to launder money.
This case illustrates the risk a company is exposed to even through its supply chain. Consultancy fees, unusual discounts, loan agreements, and high pricing may be considered red flags and trigger compliance obligations from banks and partners.
US Businessman Convicted of Bribing Mexican Government Officials (PEMEX)
On December 5, 2025, a US businessman was convicted for involvement in bribing Mexican government officials at the state oil company PEMEX and its subsidiary PEMEX Exploration Production, and faces a maximum sentence of 15 years in prison. According to court documents, between 2019 and 2021, over $150,000 in bribes were paid by the businessman and his partners to officials in the subsidiary, aiming to maintain contracts and gain an unfair advantage. The bribe was given in various ways, including cash payments, luxury goods, and other valuable items.
This case serves as a reminder that bribery carries personal liability and that bribery is not only accepted in the form of cash but also in cash equivalents such as valuable gifts.
TIGO Guatemala (Millicom) Paid Fine to Settle International Bribery Investigation
On December 12, 2025, the US DOJ announced that TIGO Guatemala, a subsidiary of Millicom, paid over $118 million in November 2025 to settle an international bribery investigation, and entered into a Deferred Prosecution Agreement (DPA) for two years regarding an indictment in South Florida for conspiracy to violate FCPA provisions. According to the announcement, between 2012 and 2018, the company operated a systematic bribery scheme involving monthly cash payments to congressmen in Guatemala or their security personnel, in exchange for promoting the company’s regulatory and legislative interests, with extensive money laundering which involved local cartels. The settlement established a criminal fine of $60 million and administrative forfeiture of approximately $58.2 million, alongside commitments to cooperate and strengthen the compliance system.
Among other things, this case highlights that even with early contact with authorities, a company may not enjoy full leniency if cooperation is blocked or delayed, and that strengthening control, monitoring, and compliance are necessary conditions for reducing exposure.
World Bank Enforcement Events – Cross-Debarment and Stricter Compliance Requirements
During 2025, the World Bank published several settlement agreements and suspensions regarding corruption and fraud, where the central trend is stricter compliance requirements. The World Bank is not satisfied with removal from the market, but requires companies to prove the construction of internal corruption prevention mechanisms as a condition for canceling or reducing the removal
World Bank Suspended Panaque S.R.L Due to Bribery and Conflict of Interest
On March 19, 2025, the World Bank announced the suspension of the Italian company Panaque S.R.L and its manager for a period of two years. The decision was made following an investigation finding that the company was involved in “corrupt and collusive practices” within an agricultural project in Montenegro.
World Bank Group Suspended L.S.D. Construction & Supplies Due to Fraud
On May 28, 2025, the World Bank announced the suspension of the Philippine infrastructure company L.S.D. Construction & Supplies for a period of 54 months, after an investigation revealed a web of corruption and fraud in a rural development project. The investigation revealed that the company used practices of “collusion” and “corruption,” including prohibited payments to officials and secret contracts to rig tenders. According to the Bank’s findings, the company participated in corrupt practices by making prohibited payment to an official aiming to ensure its win in a contract and approve its invoices.
World Bank Group Suspended GenKey Solutions B.V
On July 8, 2025, the World Bank Group announced the suspension of the Dutch company GenKey Solutions B.V for a period of 18 months, due to its involvement in fraudulent practices in a humanitarian aid project in Liberia. According to the Bank’s findings, the company failed to report commissions to agents due to deficiencies in internal controls, constituting a violation of international procurement guidelines. Within a settlement agreement, the company admitted liability and committed to adopting a strict compliance program as a condition for ending the suspension; the suspension was reduced against the backdrop of cooperation, but the company is still exposed to the cross-debarment mechanism.
This update highlights certain developments in the fields of anti-bribery and anti-corruption that can assist in meeting compliance requirements. It does not review all the updates that took effect in 2025 and is not intended to provide a comprehensive summary. This client update provides general information and may not be relied upon in any particular situation without additional legal advice.
