Regulators across Asia Pacific are targeting companies where it hurts. Singapore’s first Deferred Prosecution Agreement (DPA), changes in Vietnamese criminal policy, personal liability for directors in China for corporate misconduct – all signify a marked shift in APAC enforcement trends.
More and more, domestic regulators in APAC work with their foreign counterparts. These enforcers can pool resources and information as needed, giving them access to companies’ conduct overseas. Together, they pose a formidable threat.
Here’s an overview of what businesses should look out for:
Singapore seals first DPA
Singapore broke new ground in 2025 with its first-ever DPA to resolve corporate criminal liability. A Singapore-listed global engineering company entered into a DPA with the Singapore Attorney-General’s Chambers to resolve alleged bribery offenses. The charges were linked to Operation Car Wash, the Brazilian investigation into widespread political and corporate corruption.
Under the DPA, an agreement was reached for the company to pay a US$110 million penalty to Singapore authorities and improve its compliance framework, or the DPA may be revoked. Examples of other terms that may be imposed under a Singapore DPA include orders to disgorge profits, compensate victims, appoint a monitor, or donate to charities. This development is novel; even though Singapore introduced the DPA framework in 2018 this is the first time the DPA process has been used.
Vietnam overhauls penalties
The Vietnamese government has introduced an anti-corruption plan that reinforces stricter oversight of public finances, mandatory job rotations for government officials, and stronger whistleblower protections. In addition, amends to the Penal Code have replaced the death penalty for serious bribery offenses, with life imprisonment as the maximum sentence, alongside asset confiscation and higher fines. Reduced sentences will require cooperation and the voluntary return of 75 percent of illicit assets.
Indonesia cracks down on SOE corruption
Investigations into state-owned entities (SOEs) have intensified, targeting bribery allegations and procurement irregularities in the banking, consumer, and energy sectors. In several cases, asset recovery has become the Attorney General’s Office and the Corruption Eradication Commission’s go-to tool. For example, in a recent crude palm oil export case, the Attorney General’s Office recovered IDR 13.255 trillion (US$784 million) from several agribusiness groups operating in Indonesia. Businesses dealing with SOEs may face heightened regulatory scrutiny, including dawn raids, regulatory inquiries, and asset recoveries.
Businesses in this region should strengthen their internal controls and embed a culture of compliance now, or risk being caught in the next wave of enforcement.
Japan hit by enforcement surge
A wave of Japanese-related enforcement actions has redefined the country’s bribery and corruption environment in 2026. Scrutiny is sharper, penalties are larger, and enforcement comes from more directions.
For a start, cross-border enforcement has become direct and assertive, as seen in a November 2024 U.S. action after alleged attempts to bribe Japanese parliamentarians to facilitate a resort and casino project. This foreign-led scrutiny comes while Japan has been trying to modernise its own anti-bribery and anti-corruption framework, including efforts to extend domestic laws to Japanese multinationals and overseas conduct. Yet the Organisation for Economic Co-operation Development still flags Japan’s enforcement as falling short, citing low prosecution rates and limited pursuit of foreign bribery cases.
Meanwhile, U.S. authorities no longer dominate enforcement activity. Brazil’s anti-corruption regulator recently fined a Japanese engineering company US$96 million – one of the largest Japanese-linked penalties by a non-U.S. agency in recent years. While U.S. and UK anti-bribery and corruption laws have been the benchmark for extraterritorial effect and active regulators, these laws are no longer the only ones. Japanese companies should expect material exposure from any jurisdiction where they do business – and be prepared for parallel investigations.
Construction and infrastructure projects remain corruption hotspots. Recent global enforcement trends show how cash-heavy budgets, sprawling contractor chains, and weak oversight can create fertile ground for bribes to go undetected. Add zoning approvals, licensing requirements, and government touchpoints, and the risk spikes fast. Greater attention is likely on politically exposed persons, shadow intermediaries, lobbying-adjacent conduct, and influence channels that previously may have escaped scrutiny.
This exposure is set to grow. Japan’s push to expand its overseas infrastructure – under long-term national strategies to secure major transport, energy, and digital infrastructure projects across Asia, Africa, and the Indo-Pacific – will place Japanese companies deeper into jurisdictions where procurement transparency varies. Regulators will likely keep these projects in their crosshairs through 2026.
The recent discovery of a US$90 million trading fraud involving inflated positions and falsified documentation in China – which prompted a major Japanese trading house to shut down an entire business line – illustrates how internal fraud can both conceal and catalyze bribery. When traders can manipulate positions, bypass approvals, or fabricate paperwork, the same weak controls can mask illicit payments, distort procurement flows, or obscure corrupt counterparties. Trading desks, procurement pipelines, and high-volume local operations are emerging as the most fragile points in the control environment.
India FCPA case rewards compliance
India attracts significant cross-border investment. A recent high-profile Foreign Corrupt Practices Act (FCPA) case, one of just a few under Trump’s second term, involves a U.S.-headquartered insurance multinational with Indian operations. Between 2017 and 2022, the company’s Indian subsidiary allegedly paid bribes totaling US$1.47 million to officials at six state-owned banks to secure product referrals, generating US$9.2 million in revenue and US$4.7 million in profit.
On discovering the bribes, the parent company voluntarily disclosed the misconduct, cooperated extensively with the U.S. Department of Justice (DOJ), and implemented substantial remedial measures, including employee sackings, structural reorganization, and enhanced oversight of third-party payments. In recognition, DOJ issued a formal declination in August 2025, requiring the disgorgement of profits.
Although there remains some uncertainty about how U.S. enforcers, in particular the FCPA Units at DOJ and the SEC, will apply new FCPA enforcement guidelines, this resolution reflects the extent to which cross-border bribery risk remains real and proactive compliance – not just reactive clean-up – matters. We have some clues from our recent dealings with both agencies.
First, voluntary disclosure with robust remediation can mitigate enforcement outcomes, though immunity isn’t guaranteed. So, companies must ensure their compliance programs are effective, independently tested, and capable of addressing direct and third-party risks.
Second, the case sheds light on structural weaknesses that remain relevant in India. The use of third‑party intermediaries and the disguise of bribes as marketing, promotion, or business development payments reflect well-known corruption typologies in the Indian market. These practices persist because large portions of commercial activity involve SOEs, public sector banks, and intermediated referral pipelines. Indian and multinational firms must double down on third-party risk management, contract safeguards, financial controls, and transparency.
Finally, the declination in this insurance multinational’s case reflects an important enforcement message: despite a temporary U.S. FCPA enforcement slowdown in 2025, DOJ retains full discretion to pursue cases globally. Companies can’t assume that cases outside current “priority” categories – such as national security or cyber-enabled crime – will go unscrutinized.
China tightens health care compliance
China is intensifying its anti-corruption campaign especially in the health care sector, marking a new era of regulatory enforcement. The 2025 revision of the Anti-Unfair Competition Law introduces significant changes: individuals can now be held personally liable for violations, fines have been substantially increased, and the law extends to misconduct occurring outside China that affects its domestic market. These provisions underscore the government’s determination to curb unethical practices and strengthen market integrity.
In January 2025, the State Administration for Market Regulation released comprehensive compliance guidelines identifying nine high-risk scenarios for health care companies. The guidelines call for robust internal controls, frequent employee training, and effective whistleblower programs to mitigate exposure. Companies are encouraged to take proactive steps to align with these requirements.
Regulators are also deploying advanced technologies, including big data analytics and artificial intelligence, to detect and investigate fraud, particularly in medical insurance. This technology-driven approach enhances enforcement efficiency and broadens the scope of oversight.
In 2026, enforcement is expected to remain strict, with continued focus on health care, technology-enabled investigations, and higher compliance standards. Businesses should act now to strengthen governance frameworks and implement comprehensive risk management strategies to navigate this evolving regulatory landscape.