by Andrew M. Levine, Winston M. Paes, Erich Grosz, and Andrew Noh
Left to Proper: Andrew M. Levine, Winston M. Paes, Erich Grosz, Andrew Noh (photographs courtesy of Debevoise & Plimpton LLP)
On March 16, 2026, the U.S. Division of Justice introduced prices towards a Texas businessman for conspiring to bribe workers of state-owned Petróleos Mexicanos (“PEMEX”) and its subsidiary PEMEX Exploración y Producción (“PEP”). In a prison data filed within the U.S. District Courtroom for the Southern District of Texas, DOJ alleged that Alfonso Wilson, a twin U.S.-Mexican citizen, acted as an middleman to assist a Texas-based gear firm (the “Gear Firm”) safe enterprise from PEMEX and PEP.[1] On March 31, Wilson pleaded responsible.
In line with the prison data, Wilson started planning the bribery scheme with three co-conspirators in January 2020.[2] In a sequence of WhatsApp conversations, the co-conspirators mentioned paying bribes to a senior PEP official on behalf of the Gear Firm. Ultimately, the group determined to supply a PEP official “hundreds of thousands of {dollars} in bribes” in change for help in acquiring a $540 million contract to provide PEMEX with drilling gear.[3]
The conspiracy allegedly concerned a multistep construction and used three middleman firms to hide the bribes. The Gear Firm employed a Mexico-based middleman (“Middleman Firm 1”), which in flip employed an organization owned and managed by Wilson (“Middleman Firm 2”). The Gear Firm ostensibly paid the businesses commissions on drilling gear gross sales to PEMEX. Though Wilson was primarily accountable for speaking with the PEP govt concerning the drilling gear contract, the bribes had been finally paid by way of a 3rd middleman firm (“Middleman Firm 3”), a Mexico-based subcontractor for the Gear Firm.
In December 2021, PEMEX awarded the Gear Firm the contract, and Wilson was paid $415,800 in commissions. The prison data alleges that the conspiracy continued by way of at the very least 2025, although it doesn’t specify any extra contracts or advantages obtained by way of corrupt funds.[4]
This case seems to current a typical FCPA truth sample, with U.S. businesspeople allegedly paying overseas officers to safe unfair enterprise benefits. The fee of commissions to middleman firms can also be a typical step to hide corrupt funds. Of observe, the data doesn’t allege that the bribery scheme concerned drug cartels or transnational prison organizations (key enforcement targets for the Trump Administration).
The Wilson prosecution additionally displays DOJ’s emphasis beneath the Trump Administration of holding people accountable for company prison conduct. A Could 2025 memo from the Head of the Legal Division famous that “[t]he Division’s first precedence is to prosecute particular person criminals” and “[i]t is people—whether or not executives, officers, or workers of firms—who commit . . . crimes.”[5]
This matter comes amid continued scrutiny of corruption involving Mexico’s state-owned oil sector, together with proceedings involving former PEMEX officers, although such enforcement exercise in Mexico has been comparatively restricted.[6] Notably, that is the second PEMEX-related bribery motion introduced by DOJ because it launched the revised FCPA enforcement tips.
In August 2025, DOJ charged two Mexican businessmen, Ramon Alexandro Rovirosa Martinez and Mario Alberto Avila Lizarraga, for conspiring to pay roughly $150,000 in bribes to workers of PEMEX and PEP.[7] In change, the officers promised to award $2.5 million in contracts to Rovirosa’s power firms, resolve audits into Rovirosa’s enterprise with PEP, and approve technical compliance studies for power initiatives. In December 2025, a federal jury convicted Rovirosa of two counts of violating the FCPA.[8] As of the date of this publication, Avila stays at giant.
DOJ started this motion with a prison data slightly than a criticism or grand jury indictment. Wilson waived the requirement to be indicted by a grand jury, which generally occurs the place the defendant pleads responsible and cooperates with DOJ. In line with that posture, on March 31, 2026, Wilson pleaded responsible to the charged conspiracy offense and agreed to forfeit roughly $384,000 in proceeds from the scheme. In line with prosecutors, the overall quantity of corrupt funds really made ranged between roughly $1.5 million and $3.5 million.[9]
Wilson’s responsible plea after waiving indictment by a grand jury, and the truth that the prison data identifies 5 co-conspirators and alleges that the conspiracy continued by way of 2025, counsel that we might even see prices towards different people on this case. Wilson’s sentencing is presently scheduled for June 26, 2026, though that’s prone to be adjourned if he’s cooperating with DOJ.
[1] Legal Info, U.S. v. Wilson, No. 4:26-cr-00135 (S.D. Tex. Mar. 16, 2026).
[2] Id. at 4.
[3] Id. at 5.
[4] Id. at 4.
[5] U.S. Dep’t of Justice, Memorandum from Matthew R. Galeotti, Head of the Legal Division, Focus, Equity, and Effectivity within the Struggle In opposition to White-Collar Crime (Could 12, 2025), https://www.justice.gov/prison/media/1400046/dl?inline.
[6] See Andrew J. Ceresney et al., “The 12 months 2025 in Overview: An FCPA Enforcement Reset and Different World Anti-Corruption Developments,” FCPA Replace, Vol. 17, No. 6 (Jan. 2026), https://www.debevoise.com/insights/publications/2026/01/fcpa-update-january-2026.
[7] See Andrew M. Levine, Douglas S. Zolkind, Andreas A. Glimenakis, and Scott J. Woods, “DOJ Prices Mexican Nationals with Bribing PEMEX Staff in First FCPA Case Since Resuming Enforcement,” FCPA Replace, Vol. 17, No. 1 (Aug. 2025), https://www.debevoise.com/insights/publications/2025/08/fcpa-update-august-2025.
[8] U.S. Dep’t of Justice Press Launch No. 25-1146, Texas Businessman Convicted for Scheme to Bribe Mexican Authorities Officers (Dec. 5, 2025), https://www.justice.gov/opa/pr/texas-businessman-convicted-scheme-bribe-mexican-government-officials.
[9] Sentence Knowledge Sheet, U.S. v. Wilson, No. 4:26-cr-00135 (S.D. Tex. Mar. 31, 2026).
Andrew M. Levine, Winston M. Paes are Companions, Erich Grosz is Counsel, and Andrew Noh is an Affiliate at Debevoise & Plimpton LLP. This submit first appeared as a article for the agency.
The views, opinions and positions expressed inside all posts are these of the writer(s) alone and don’t characterize these of the Program on Company Compliance and Enforcement (PCCE) or of the New York College Faculty of Regulation. PCCE makes no representations as to the accuracy, completeness and validity or any statements made on this website and won’t be liable any errors, omissions or representations. The copyright of this content material belongs to the writer(s) and any legal responsibility as regards to infringement of mental property rights stays with the writer(s).
by Andrew M. Levine, Winston M. Paes, Erich Grosz, and Andrew Noh
Left to Proper: Andrew M. Levine, Winston M. Paes, Erich Grosz, Andrew Noh (photographs courtesy of Debevoise & Plimpton LLP)
On March 16, 2026, the U.S. Division of Justice introduced prices towards a Texas businessman for conspiring to bribe workers of state-owned Petróleos Mexicanos (“PEMEX”) and its subsidiary PEMEX Exploración y Producción (“PEP”). In a prison data filed within the U.S. District Courtroom for the Southern District of Texas, DOJ alleged that Alfonso Wilson, a twin U.S.-Mexican citizen, acted as an middleman to assist a Texas-based gear firm (the “Gear Firm”) safe enterprise from PEMEX and PEP.[1] On March 31, Wilson pleaded responsible.
In line with the prison data, Wilson started planning the bribery scheme with three co-conspirators in January 2020.[2] In a sequence of WhatsApp conversations, the co-conspirators mentioned paying bribes to a senior PEP official on behalf of the Gear Firm. Ultimately, the group determined to supply a PEP official “hundreds of thousands of {dollars} in bribes” in change for help in acquiring a $540 million contract to provide PEMEX with drilling gear.[3]
The conspiracy allegedly concerned a multistep construction and used three middleman firms to hide the bribes. The Gear Firm employed a Mexico-based middleman (“Middleman Firm 1”), which in flip employed an organization owned and managed by Wilson (“Middleman Firm 2”). The Gear Firm ostensibly paid the businesses commissions on drilling gear gross sales to PEMEX. Though Wilson was primarily accountable for speaking with the PEP govt concerning the drilling gear contract, the bribes had been finally paid by way of a 3rd middleman firm (“Middleman Firm 3”), a Mexico-based subcontractor for the Gear Firm.
In December 2021, PEMEX awarded the Gear Firm the contract, and Wilson was paid $415,800 in commissions. The prison data alleges that the conspiracy continued by way of at the very least 2025, although it doesn’t specify any extra contracts or advantages obtained by way of corrupt funds.[4]
This case seems to current a typical FCPA truth sample, with U.S. businesspeople allegedly paying overseas officers to safe unfair enterprise benefits. The fee of commissions to middleman firms can also be a typical step to hide corrupt funds. Of observe, the data doesn’t allege that the bribery scheme concerned drug cartels or transnational prison organizations (key enforcement targets for the Trump Administration).
The Wilson prosecution additionally displays DOJ’s emphasis beneath the Trump Administration of holding people accountable for company prison conduct. A Could 2025 memo from the Head of the Legal Division famous that “[t]he Division’s first precedence is to prosecute particular person criminals” and “[i]t is people—whether or not executives, officers, or workers of firms—who commit . . . crimes.”[5]
This matter comes amid continued scrutiny of corruption involving Mexico’s state-owned oil sector, together with proceedings involving former PEMEX officers, although such enforcement exercise in Mexico has been comparatively restricted.[6] Notably, that is the second PEMEX-related bribery motion introduced by DOJ because it launched the revised FCPA enforcement tips.
In August 2025, DOJ charged two Mexican businessmen, Ramon Alexandro Rovirosa Martinez and Mario Alberto Avila Lizarraga, for conspiring to pay roughly $150,000 in bribes to workers of PEMEX and PEP.[7] In change, the officers promised to award $2.5 million in contracts to Rovirosa’s power firms, resolve audits into Rovirosa’s enterprise with PEP, and approve technical compliance studies for power initiatives. In December 2025, a federal jury convicted Rovirosa of two counts of violating the FCPA.[8] As of the date of this publication, Avila stays at giant.
DOJ started this motion with a prison data slightly than a criticism or grand jury indictment. Wilson waived the requirement to be indicted by a grand jury, which generally occurs the place the defendant pleads responsible and cooperates with DOJ. In line with that posture, on March 31, 2026, Wilson pleaded responsible to the charged conspiracy offense and agreed to forfeit roughly $384,000 in proceeds from the scheme. In line with prosecutors, the overall quantity of corrupt funds really made ranged between roughly $1.5 million and $3.5 million.[9]
Wilson’s responsible plea after waiving indictment by a grand jury, and the truth that the prison data identifies 5 co-conspirators and alleges that the conspiracy continued by way of 2025, counsel that we might even see prices towards different people on this case. Wilson’s sentencing is presently scheduled for June 26, 2026, though that’s prone to be adjourned if he’s cooperating with DOJ.
[1] Legal Info, U.S. v. Wilson, No. 4:26-cr-00135 (S.D. Tex. Mar. 16, 2026).
[2] Id. at 4.
[3] Id. at 5.
[4] Id. at 4.
[5] U.S. Dep’t of Justice, Memorandum from Matthew R. Galeotti, Head of the Legal Division, Focus, Equity, and Effectivity within the Struggle In opposition to White-Collar Crime (Could 12, 2025), https://www.justice.gov/prison/media/1400046/dl?inline.
[6] See Andrew J. Ceresney et al., “The 12 months 2025 in Overview: An FCPA Enforcement Reset and Different World Anti-Corruption Developments,” FCPA Replace, Vol. 17, No. 6 (Jan. 2026), https://www.debevoise.com/insights/publications/2026/01/fcpa-update-january-2026.
[7] See Andrew M. Levine, Douglas S. Zolkind, Andreas A. Glimenakis, and Scott J. Woods, “DOJ Prices Mexican Nationals with Bribing PEMEX Staff in First FCPA Case Since Resuming Enforcement,” FCPA Replace, Vol. 17, No. 1 (Aug. 2025), https://www.debevoise.com/insights/publications/2025/08/fcpa-update-august-2025.
[8] U.S. Dep’t of Justice Press Launch No. 25-1146, Texas Businessman Convicted for Scheme to Bribe Mexican Authorities Officers (Dec. 5, 2025), https://www.justice.gov/opa/pr/texas-businessman-convicted-scheme-bribe-mexican-government-officials.
[9] Sentence Knowledge Sheet, U.S. v. Wilson, No. 4:26-cr-00135 (S.D. Tex. Mar. 31, 2026).
Andrew M. Levine, Winston M. Paes are Companions, Erich Grosz is Counsel, and Andrew Noh is an Affiliate at Debevoise & Plimpton LLP. This submit first appeared as a article for the agency.
The views, opinions and positions expressed inside all posts are these of the writer(s) alone and don’t characterize these of the Program on Company Compliance and Enforcement (PCCE) or of the New York College Faculty of Regulation. PCCE makes no representations as to the accuracy, completeness and validity or any statements made on this website and won’t be liable any errors, omissions or representations. The copyright of this content material belongs to the writer(s) and any legal responsibility as regards to infringement of mental property rights stays with the writer(s).
