This year, the DOJ has had two big wins at trials against individuals who opted not to settle the FCPA-related charges, leaving the pool of prospective defendants, whether corporate or individuals, with strategy decisions to contemplate. In April, a federal jury in Miami convicted a former Comptroller General of Ecuador, Carlos Ramon Polit Faggioni (Polit), for conspiracy to commit money laundering and other infractions associated with the acceptance of more than $10 million in bribe payments from Brazil-based Odebrecht S.A. Just a couple months earlier, a federal jury in Brooklyn found oil and gas trader Javier Aguilar guilty of conspiracy to violate the FCPA and other charges for his role in bribing officials at state-owned oil and gas companies in Ecuador and Mexico to procure business for his employer at the time, Houston-based Vitol, Inc. The Anti-Corruption Report spoke to experts in the field to understand the implications of these convictions for both individuals and corporations. See “DOJ’s New VSD Program Offers NPAs to Individuals Who Can Help Catch Bigger Fish” (May 8, 2024).