Global Corporations

Corporate corruption in 2025 has seen high-profile convictions in bribery cases, such as the conviction of a Swiss commodities trader and its former CEO in January 2025

. It has also been shaped by new enforcement guidance, like the U.S. Commodity Futures Trading Commission’s (CFTC) advisory on self-reporting and cooperation credit in February 2025, and new legislation like the Combating Global Corruption Act of 2025 in January 2025. Technological advancements, especially the use of AI, are becoming a focus for both combating corruption and for companies’ internal compliance efforts. 

Key legal and enforcement developments

  • New guidance: The CFTC introduced a new advisory in February 2025 that provides a three-tiered system for self-reporting and a four-tiered system for cooperation credit, along with a mitigation credit matrix.
  • Legislative action: The Combating Global Corruption Act of 2025 was introduced in January 2025, requiring the State Department to annually rank foreign countries based on their efforts to eliminate corruption.
  • DOJ guidelines: The U.S. Department of Justice updated its Foreign Corrupt Practices Act (FCPA) guidelines in June 2025, which may affect enforcement in areas like national security, infrastructure, and energy.
  • Increased focus on technology: The OECD Global Anti-Corruption & Integrity Forum in March 2025 highlighted how technologies like AI, data analytics, and digital forensics can be used to combat corruption and improve integrity. 

Notable cases and investigations

  • Swiss commodities trader: In January 2025, Swiss commodities trader Trafigura and its former CEO were convicted for bribing an Angolan official in a case that was the first of its kind in Switzerland.
  • Pharmaceutical company: In June 2025, an Indiana-based pharmaceutical company, Inotiv Inc., disclosed that the SEC had concluded its FCPA investigation into the company’s non-human primate importation practices without recommending enforcement action.
  • U.S. politician’s family member: In April 2025, the wife of a former U.S. Senator was convicted for her role in a corruption scheme involving bribery and influence peddling related to Egyptian officials. 

Emerging trends

  • Digital asset fraud: Despite challenges in tracking precise figures, evidence suggests that fraud involving cryptocurrencies and other digital assets remained a significant issue in 2025.
  • Social media ad fraud: Meta is reportedly focusing on reducing the revenue from fraudulent ads to meet specific targets by the end of 2025. 

  • 2025, corporate corruption continues to pose a severe global economic threat, with major developments centered on 
    shifting enforcement priorities and the increasing role of technology in both committing and combating financial crime. The US Department of Justice (DOJ) altered its approach to the Foreign Corrupt Practices Act (FCPA), while international bodies introduced new regulations to address evolving threats. 

    Global Trends and Statistics
    Economic Impact Corporate fraud and corruption globally account for estimated annual losses of at least $2.6 trillion, or about 5% of the global GDP.
    Technological Influence Fraud schemes are becoming more sophisticated through the use of Artificial Intelligence (AI), while anti-fraud professionals are exploring how to use data analytics and AI to detect and prevent these crimes.
    Vulnerable Sectors Industries such as construction, extraction, life sciences, and finance remain particularly vulnerable to corruption and bribery schemes.
    Transparency International (TI) The 2024 Corruption Perceptions Index (CPI), published in February 2025, indicated that 148 out of 180 countries have stagnated or declined in their anti-corruption efforts since 2012. The U.S. and Canada were noted as “significant decliners” over the past decade. 

    Key Enforcement Developments in 2025

    United States
    Enforcement efforts were significantly impacted by policy changes introduced by the new administration: 
    FCPA Enforcement Shift A Presidential executive order in February 2025 initially paused most FCPA enforcement for 180 days to review its impact on U.S. economic competitiveness. New DOJ guidelines were issued in June 2025, resuming enforcement with a focus on misconduct tied to national security, cartels, transnational criminal organizations, and schemes that specifically harm U.S. companies abroad.
    Major Prosecutions The DOJ continued to pursue large-scale fraud cases, including a significant healthcare fraud takedown in June that charged over 300 defendants in schemes totaling more than $14.6 billion.
    Company Self-Reporting New guidance from the DOJ and the Commodity Futures Trading Commission (CFTC) emphasized the benefits for companies that self-report misconduct and cooperate with investigations, potentially receiving reduced penalties. 

    United Kingdom
    The UK implemented the “failure to prevent fraud” offense under the Economic Crime and Corporate Transparency Act, effective September 2025, which creates new compliance obligations for large organizations. The Serious Fraud Office (SFO) announced a new international taskforce with Switzerland and France to target bribery and corruption. 

    International
    High-Profile Convictions In January 2025, Swiss trading company Trafigura and a former executive were convicted of corruption for bribing an Angolan official to secure oil contracts.
    Regional Focus China announced it would ramp up its anti-corruption campaign, focusing on finance, state-owned enterprises, and energy sectors. India also saw an increase in corporate fraud cases related to an influx of private capital and digitalization.
    OECD Efforts The OECD continued to work with member nations to strengthen anti-bribery mechanisms, evaluating the implementation of anti-corruption conventions in several countries throughout the year. 

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