U.S. Department of Justice Indicts Smartmatic on Foreign Corruption Charges

“Electronic Voting Technology Firm Accused of Bribing Foreign Officials — A Global Warning for Electoral Integrity”

In October 2025, the U.S. Department of Justice formally indicted SGO Corporation Limited, a London-based parent company of Smartmatic, on charges of bribery of foreign officials and money laundering.The case was filed in the U.S. District Court for the Southern District of Florida (Case No. 1:24-cr-20343-KMW).Co-defendants include Juan Andres Donato Bautista, former chairman of the Philippine Commission on Elections (COMELEC), along with Smartmatic executives Roger Piñate, Jorge Vásquez, and Elie Moreno.

▪︎ Charges under the Foreign Corrupt Practices Act (FCPA)

At the heart of the indictment lies the allegation that Smartmatic paid over one million U.S. dollars in bribes to senior COMELEC officials to secure favorable contracts for electronic voting machines and VAT rebate benefits.The Department of Justice (DOJ) identified these acts as violations of the Foreign Corrupt Practices Act (FCPA) — a U.S. federal law enacted in 1977 to prohibit bribery of foreign officials by American corporations or any company using the U.S. financial system.

The FCPA makes it illegal for

“any person or company within the United States, or any foreign company utilizing U.S. financial channels, to offer or provide anything of value to a foreign public official in order to obtain or retain business advantages.”

In other words, if a dollar-denominated transaction is processed within U.S. territory or routed through American banks, the U.S. government has the authority to investigate and prosecute even foreign bribery schemes.

The law was introduced after widespread scandals involving multinational corporations in the 1970s, when overseas lobbying and bribery became endemic.The United States established the FCPA to protect the integrity of the global financial order, and the statute later inspired the OECD Anti-Bribery Convention, which many nations have since adopted.

▪︎ Why the U.S. Prosecuted a “Philippine Election Scandal”

Although the case originated in the Philippines, the legal basis for the indictment lies in the movement of funds through the U.S. financial network. According to the DOJ, Smartmatic funneled money through bank accounts in the Philippines, Hong Kong, and Singapore, and during that process, U.S. dollar transfers were routed through a correspondent bank in New York.Once the transactions entered the U.S. financial system, they became subject to American jurisdiction.

The DOJ characterized the conduct as

“an international corruption scheme utilizing the U.S. financial system,”and determined that it undermines both U.S. economic order and the credibility of international finance.

For decades, the United States has invoked its role as a global financial hub to investigate and prosecute foreign bribery, money laundering, and sanctions violations that pass through its banks — a principle commonly known as “long-arm jurisdiction.”

▪︎ Exposing the Transparency Problem in Electronic Voting Technology

This case extends far beyond a single instance of corporate corruption.Smartmatic is one of the world’s three largest electronic voting technology firms, providing voting and tabulation systems in Venezuela, the Philippines, the Dominican Republic, several U.S. states, and other countries.

The DOJ’s indictment signals a willingness to test in court whether election-technology firms have won contracts through political collusion rather than fair competition.Globally, this has reignited debate over the principle of electoral integrity — the idea that every vote must be transparent, auditable, and immune from manipulation.

Electoral integrity is a foundational rule of democracy:every stage of voting and counting must be verifiable by human oversight and free from interference.This case highlights the risk that voting technology can be transformed from a tool of democracy into an instrument of power.

▪︎ Global Ripple Effects

Experts predict that the indictment will trigger a comprehensive reevaluation of electronic vote-counting systems worldwide.In the United States, the controversy follows earlier debates surrounding Smartmatic and Dominion Voting Systems after the 2020 presidential election.In the Philippines and across Latin America, questions over the vulnerability of Smartmatic’s equipment have surfaced repeatedly.

Observers say the case will likely pressure election commissions in many countries to strengthen manual ballot auditability and independent transparency mechanisms for all electronic counting systems.

▪︎ “Electoral Integrity Comes from Institutions, Not Technology”

The Smartmatic case is not merely a story of corporate misconduct — it serves as a warning about the fragility of modern democratic infrastructure. The DOJ’s prosecution effectively declares that

“corruption wrapped in technology will no longer be protected by borders.”

Ultimately, the case underscores that electoral integrity depends on transparent institutions, not on machines or algorithms. It reminds democracies worldwide that trust in elections — the cornerstone of political legitimacy — must always rest on human accountability and verifiable procedures, not on opaque digital systems.

▪︎ Case Overview and Background

The criminal case was filed in the U.S. District Court for the Southern District of Florida.

Defendants (as listed in the indictment):

• Juan Andres Donato Bautista

• Roger Alejandro Piñate Martinez

• Jorge Miguel Vásquez

• Elie Moreno

• SGO Corporation Limited (a.k.a. “Smartmatic”)

  
  

The indictment cites multiple provisions of U.S. law, including 18 U.S.C. §§ 371, 1956, 1957, 981, 982 and 15 U.S.C. §§ 78dd-2, 78dd-3 (FCPA).

On October 16, 2025, the DOJ unsealed the Superseding Indictment, stating that the case focuses on a “voting technology company that sought to obtain and retain business through corruption overseas.”

▪︎ Core Allegations

Type of Offense	Description
Bribery of Foreign Officials (FCPA)	Between 2015 and 2018, Smartmatic executives allegedly conspired to bribe officials of the Philippine Commission on Elections (COMELEC) to secure contracts, VAT refunds, and other advantages.
Money Laundering & International Financial Transfers	Prosecutors allege that the defendants disguised bribe payments using fake contracts, sham loans, shell companies, and offshore bank accounts. Transfers reportedly moved through Hong Kong → New York → Singapore before reaching accounts controlled by Bautista, who later used some of the funds to purchase U.S. real estate.
Forfeiture Allegations	Upon conviction, the U.S. government seeks to confiscate all assets traceable to the offenses, including property located in San Francisco.

▪︎ Time Frame and Scope

The alleged conspiracy ran from 2015 through at least 2018.Some defendants lived in or maintained accounts in the United States — for example, Vásquez reportedly resided in Florida — strengthening the jurisdictional link.The indictment also names SGO Corporation Limited as a corporate defendant, opening the door to potential corporate criminal liability.

▪︎ Key Legal and Procedural Issues

• Ambiguity of Indictment Details: Defendants, particularly Piñate and Vásquez, argued that the indictment was overly broad and lacked specificity about particular transactions, seeking a Bill of Particulars. The court denied the motion.

• Jurisdiction Under the FCPA: For FCPA charges to apply, the defendants must qualify as a “domestic concern” or have substantial U.S. connections. Whether U.S. courts can assert jurisdiction over such foreign bribery remains a point of contention.

• Evidentiary Burden:Prosecutors must prove that funds were illicit and that the payments carried corrupt intent, while the defense is expected to argue that the transfers were legitimate business transactions.

• Potential Penalties: Each money-laundering count carries up to 20 years in prison, in addition to possible corporate fines and asset forfeitures.

  
  

▪︎ Current Status and Outlook

The case remains pending trial, and the DOJ has reiterated its commitment to pursuing prosecution. Some defense attorneys have sought expanded discovery to obtain the government’s evidence. Smartmatic, meanwhile, issued statements denying wrongdoing and calling the trial politically motivated. Observers expect the case to become a landmark precedent defining the extent to which the United States can exercise its anti-corruption jurisdiction, and whether global election technology companies can be held criminally accountable for manipulating contracts abroad.