First Post-Pause FCPA Charges Target Individuals Under New DOJ Priorities

The Justice Department on August 11 unsealed an indictment in the Southern District of Texas charging two Mexican nationals residing in Texas with bribing officials of Petróleos Mexicanos (PEMEX) and its subsidiary PEMEX Exploración y Producción to secure $2.5 million in contracts.

Ramon Alexandro Rovirosa Martinez, 46, and Mario Alberto Avila Lizarraga, 61, allegedly conspired between 2019 and 2021 to provide at least $150,000 in cash, luxury goods, and other valuables to three PEMEX officials. DOJ says the scheme was designed to rig bidding and retain business for companies linked to Rovirosa.

The charges—one conspiracy count and three substantive FCPA counts each—are the first individual prosecutions since the  enforcement pause ended June 9. They reflect DOJ Criminal Division Chief Matthew R. Galeotti’s June policy directive to focus on “specific misconduct of individuals” rather than corporate liability in FCPA cases. Rovirosa was arraigned; Avila remains a fugitive.

If convicted, each faces up to five years in prison per count.