On October 23, 2025, Carlos Leopoldo Alvelais Alarcón, a Mexican customs broker operating in the United States and Mexico, pled guilty to conspiring to violate the Foreign Corrupt Practices Act (“FCPA”) at a courthouse in the Western District of Texas.  See United States v. Alvelais, No. 3:25-cr-02512, (W.D. Tex.).  The plea agreement and criminal information in this case are sealed, and the defendant is currently scheduled to be sentenced on January 8, 2026.

DOJ didn’t issue a press release, and all the key documents are sealed.  But when DOJ continues to work in an area, particularly if there are covert investigations afoot, they often choose to walk softly and carry a big stick. Although the case was charged under the FCPA, because the case involves a corrupt customs broker at the Mexican border, the big stick may be DOJ’s Trade Fraud Task Force, which is aggressively pursuing tariff evasion cases. https://viewpoints.reedsmith.com/post/102ltzo/a-primer-on-parallel-investigations-given-heightened-tariff-enforcement-risk

Companies should take notice.  Indeed, for companies involved in cross-border shipments, especially those engaging with third-party logistics companies and customs-brokers, this case serves as a clear warning: review and tighten your customs controls, third-party due diligence, and tariff-compliance frameworks now—before a surge of tariff evasion cases land.

Additional authors: Daniel Ahn, Julia Ensor, Michael Lowell, Scott Marrah, Adria Perez, Kate Seikaly, Justin Angotti