Restarting Accountability in the US: FCPA Enforcement Reignites with PEMEX Arrests

In a significant development marking the revival of Foreign Corrupt Practices Act (FCPA) enforcement, two businessmen have been arrested for bribing officials at Mexico’s state-owned oil company, PEMEX.

This case is the first unsealed FCPA prosecution since President Trump issued an executive order in February 2025 pausing enforcement of the statute.

Ramon Alexandro Rovirosa Martinez, 46, of The Woodlands, and Mario Alberto Avila Lizarraga, 61, of Spring, both Mexican citizens and U.S. lawful permanent residents, are accused of conspiring to pay at least $150,000 in bribes to PEMEX and PEP officials. The duo hoped to retain business for companies connected to Rovirosa.

SOURCE https://www.fox26houston.com/news/ramon-rovirosa-mario-avila-pemex-bribes-pep-houston

This follows the DOJ’s recent declination in the Liberty Mutual case, where the company avoided prosecution due to voluntary disclosure, cooperation, and remediation efforts.

Key Details of the Case:

• Defendants: The two unnamed businessmen allegedly provided PEMEX officials with cash and luxury goods in exchange for favourable treatment in energy contracts.
• Jurisdiction: The case was filed in the U.S. District Court for the Southern District of Texas, indicating cross-border implications.
• Charges: The charges fall under the FCPA, which prohibits U.S.-linked entities from bribing foreign officials to gain business advantages.

Enforcement Resumes:

The PEMEX bribery case signals that enforcement has resumed under narrower criteria, likely focusing on cases involving:

• National security
• Critical infrastructure
• Transnational criminal organisations
• Clear-cut bribery involving state-owned entities

Background on the FCPA Pause:

President Trump’s executive order, issued on February 10, 2025, initiated a 180-day moratorium on FCPA investigations and enforcement actions. The rationale was to reassess enforcement practices that were deemed overly expansive and potentially harmful to U.S. economic competitiveness and national security.

During the pause:

• The DOJ was instructed to review existing investigations, halt new ones unless specifically authorised by Attorney General Pamela Bondi, and revise enforcement guidelines.
• Local U.S. Attorney’s Offices lost autonomy to initiate FCPA actions without Main Justice approval.
• The DOJ retained discretion to pursue cases deemed critical to national interests.

References

• US arrests two over PEMEX bribes, reviving dormant FCPA enforcement https://www.lexology.com/pro/content/us-arrests-two-over-pemex-bribes-reviving-dormant-fcpa-enforcement
• Takeaways from the Pause on Foreign Corrupt Practices Act Enforcement https://corpgov.law.harvard.edu/2025/02/24/takeaways-from-the-pause-on-foreign-corrupt-practices-act-enforcement/
•  Compliance lessons from the first FCPA declination of Trump’s second ...https://vinciworks.com/blog/compliance-lessons-from-the-first-fcpa-declination-of-trumps-second-term/
• https://www.fox26houston.com/news/ramon-rovirosa-mario-avila-pemex-bribes-pep-houston