DOJ secures conviction in long-anticipated FCPA trial of ex-coal executive

On February 18, 2026, a Pennsylvania federal jury found Charles Hunter Hobson, a former Vice President at Corsa Coal Corp., guilty of charges stemming from a bribery scheme involving an Egyptian government-affiliated company. Hobson was convicted on two counts of violating the FCPA, conspiracy to violate the FCPA, money laundering, conspiracy to commit money laundering, and conspiracy to commit wire fraud.

The jury’s verdict follows recent changes to DOJ enforcement and policy under the Trump Administration and provides insight into the types of FCPA cases DOJ continues to pursue.

Below, we set out key details of United States v. Charles Hobson and similar cases, as well as their implications for companies.

Case background

The government contended that certain Corsa Coal employees and agents engaged in a multi-year scheme to bribe Egyptian government officials to obtain lucrative coal-supply contracts to an Egyptian state-owned coal company. In March 2023, DOJ agreed to decline prosecution of the company itself based on the company’s voluntary self-disclosure of the misconduct, cooperation with the government’s investigation, and timely and appropriate remediation, including a disgorgement of profits. (While DOJ calculated the total profits at roughly $33 million, a “declination with disgorgement” resulted in disgorgement of $1.2 million due to the company’s demonstrated inability to pay more than that amount.)

According to prosecutors, Hobson knowingly allowed his Egyptian sales agent to use portions of his commissions as bribes to officials at the Egyptian state-owned coal company in exchange for the coal contracts. The scheme allowed Corsa Coal to secure contracts worth approximately $143 million in total between 2016 and 2018.

Trial amid FCPA policy shifts

Hobson’s decision to exercise his right to trial resulted in one of a relatively small number of full jury trials of FCPA matters – believed to be less than 30 – since the FCPA’s enactment in 1977. The trial was originally scheduled to proceed in April 2025 but was among many cases paused as a result of a February 2025 Executive Order directing a review of extant FCPA prosecutions, with the stated goal of restoring American competitiveness abroad. (For our earlier analysis of the initial Executive Order, see our discussion here and a further analysis in our webinar here.) This reassessment led to a number of investigations and indicted cases being dropped and dismissed. This included longstanding FCPA charges against former high-ranking executives of Cognizant Technology Solutions Corporation, which were dismissed on the eve of trial.

In June 2025, the temporary enforcement pause concluded with the release of revised “Guidelines for Investigation and Enforcement of the Foreign Corrupt Practices Act” (FCPA Guidance), which we summarized in this client alert here.

In September 2025, CEO of Atlanco LLC, Carl Alan Zaglin, was convicted by a federal jury in Miami following the first FCPA trial after the pause was lifted. Like Hobson, Zaglin was convicted for his role in a years-long bribery scheme to secure business from foreign state officials. Zaglin’s trial centered around bribes made to Honduran government officials for uniform contracts, and he was later sentenced to eight years in prison.

Although decisions on which cases to drop and which to pursue have varied, the Hobson and Zaglin trials indicate that DOJ continues to prosecute culpable individual executives. One stated focus under the new policies is a continued emphasis on individual liability for core anti-bribery cases with a priority on instances of serious misconduct. Both Hobson and Zaglin were alleged to have played central roles in multi-million dollar and multi-year schemes with significant personal pecuniary benefit (and Zaglin was both the majority owner and CEO of his company).

By way of brief summary, under the FCPA Guidance and as stressed by various DOJ leaders since its roll-out, priority for FCPA prosecutions will include the following types of cases:

• Prosecutions of cartels and transnational criminal organizations (TCOs)


• Cases safeguarding fair opportunities for US companies, with a focus on conduct that undermines competitive markets


• Corruption prosecutions advancing US national security (priority will be given to corruption occurring in sectors like defense, intelligence, or critical infrastructure)


• Cases involving serious misconduct like substantial bribe payments and efforts to obstruct justice

Trial overview

Prosecutors alleged that Hobson personally benefited from more than $200,000 in kickbacks from the arrangement by way of financial transfers routed through a shell company in the United Arab Emirates, Western Union transfers, and cash handovers, such as when Hobson traveled to Dubai and returned with $30,000 in cash.

Hobson’s defense argued at trial that Hobson did not pay or direct anyone to bribe foreign officials, nor did he believe the coal company at issue was a government-affiliated company at the time of the alleged scheme. A predicate element of the FCPA is that the bribes or promises in question must be directed at a government official or employee of a government “instrumentality,” and the Hobson prosecution successfully argued that the coal company qualified. Hobson’s defense further challenged the conclusions of the prosecution’s expert in Egyptian law, questioning whether bribery was illegal in Egypt.

Hobson, whose counsel indicated he would appeal the conviction, faces up to five years in prison for each bribery, conspiracy, and substantive FCPA charge. He additionally faces up to 20 years for each money laundering and wire fraud charge.

Key takeaways

The trials and convictions in Hobson and Zaglin provide insight into DOJ’s FCPA enforcement approach in practice. In addition to a demonstrated focus on the Trump Administration’s priorities of safeguarding US national security interests, American competitiveness, and promoting fairness and efficiency, recent FCPA convictions, such as those of Hobson and Zaglin, signal that DOJ remains committed to prosecuting and holding individual executives accountable, at least in circumstances involving significant personal misconduct and personal benefit, even without an apparent connection to cartels, national security, or other subject areas included in the new FCPA Guidance.

Moving forward, companies should ensure that their compliance programs are dynamic and developed to appropriately address DOJ’s demonstrated FCPA priorities including complex bribery schemes, money laundering, and attempts to conceal culpable behavior. While companies are encouraged to reassess their risk profiles in areas now prioritized by DOJ (such as national security and operations in areas with cartel activity), and possibly shift resources to those risks, the Hobson and Zaglin cases underscore that DOJ continues to pursue core FCPA enforcement actions.

Notably, DOJ continues to emphasize individual accountability and attribution of misconduct to specific actors instead of corporate structures. Companies should be prepared to demonstrate to DOJ that they have taken immediate action in response to any serious misconduct that surfaces in order to avoid prosecution of the corporation itself. Much like Corsa Coal in the above FCPA investigation, companies are encouraged to prioritize voluntary disclosure, cooperation with authorities, and implementation of remediation measures such as disgorgement.

Contact

For more information about Hobson and FCPA enforcement, please contact your DLA Piper relationship attorney or any of the authors of this client alert.