A recent federal bribery conviction and a separate indictment provide insight on the Department of Justice’s reset on Foreign Corrupt Practices Act (FCPA) prosecutions. Together, the two efforts signal the DOJ is pressing both cartel adjacent and conventional bribery cases, underscoring risks for companies competing abroad and in government procurement.
Background
In September 2025, the DOJ secured a conviction from a Miami jury of Carl Zaglin, the owner and chief executive officer of Atlanco LLC, in the first FCPA trial since the Trump administration ordered a pause in FCPA enforcement in a February 2025 executive order. Indicted in 2023 under the Biden administration, Zaglin’s Atlanco pursued contracts with the Honduran government to manufacture the country’s law enforcement uniforms. Prosecutors presented evidence that Zaglin paid bribes to Honduran officials to secure these contracts, moving the bribery funds from Atlanco to a co-conspirator’s domestic company to the accounts of Honduran officials in the United States and other countries.
Zaglin’s bribery scheme resulted in a conviction for violating the FCPA, conspiracy to violate the FCPA, and conspiracy to commit money laundering. On December 3, 2025, the trial judge sentenced Zaglin to eight years in prison and ordered him to forfeit $2 million. Three co-conspirators have pled guilty in this investigation — one sentenced to seven years, the other two awaiting sentencing.
A month before the Zaglin trial, the DOJ indicted two Mexican businessmen for a scheme to bribe officials of the Petroleos Mexicanos (PEMEX), the state-owned oil company of Mexico. In the investigation, DOJ alleges that one of the defendants, Ramon Rovirosa, has ties to Mexican cartel members.
DOJ Enforcement Priorities Demonstrated in Zaglin and Rovirosa
These efforts may foreshadow DOJ’s continued prosecution of FCPA violations. The Zaglin case survived DOJ’s reassessment of FCPA cases following the enforcement pause President Trump imposed and subsequent directives from DOJ leadership. In a May 12, 2025 memorandum, then-acting Assistant Attorney General Matthew Galeotti, the head of DOJ’s Criminal Division, outlined the priorities in the prosecution of white collar crimes with a heavy focus on foreign cartels, “transnational criminal organizations” (TCOs), and fraud that could impact U.S. national security. Deputy Attorney General Todd Blanche — second in command at the Department — later distributed a memorandum emphasizing DOJ’s goal of prosecuting FCPA violations in the form of bribes used by cartels and TCOs in order to harm U.S. businesses by reducing the competitiveness of U.S. companies in bidding for contracts in foreign jurisdictions.
Taken together, the DOJ has sought to underscore the need for efficient investigation of white collar crime, to — per Galeotti’s memo — be “laser-focused” on threats to the United States and to prioritize fairness in criminal prosecution. Galeotti’s memo identifies DOJ’s “high-impact” priorities (described in detail in Blanche’s memorandum) are crimes involving bribery and money laundering that “enrich foreign corrupt officials” under the FCPA.
Although these memoranda (specifically Blanche’s) emphasize attention to cases involving cartels and TCOs, Zaglin shows instead that the DOJ has not abandoned all other forms of bribery crimes. Blanche’s FCPA memorandum focuses on four main factors: cartels, safeguarding economic prosperity, national security, and prioritizing instances of serious misconduct.
While the recent Rovirosa investigation includes an alleged bribery scheme involving a defendant with cartel ties, no such ties were present in Zaglin. Despite this, Zaglin appears to meet at least two of the other enumerated factors of Blanche’s memo: the presence of serious misconduct by the defendant and the safeguarding of U.S. economic prosperity by eliminating improper benefits for foreign companies obtained through illegal payments to foreign governments. The bribery scheme allegedly carried out in Zaglin showed a “strong indicia of corrupt intent tied to particular individuals, such as substantial bribe payments” and “sophisticated efforts to conceal bribe payments.” DOJ also highlighted the harm to American businesses resulting from bribes paid by Zaglin and his co-conspirators. In particular, the DOJ argued that “Zaglin and his co-conspirators competed with other American companies for contracts with the Honduran government, depriving them of a fair playing field.”
Juxtaposed with the Rovirosa indictment and investigation, Zaglin does not involve cartels, TCOs or national security, and indicates that the DOJ is not eliminating prosecution of international corruption beyond DOJ’s stated priorities.
Practical Takeaways for Mitigating the Risk of Corrupt Activities and Prosecution
Blanche’s memorandum indicates the listed factors are non-exhaustive, and Zaglin demonstrates that FCPA cases involving at least some of Blanche’s factors are still ripe for prosecution. Prosecutorial efforts in Zaglin appear primarily focused on the serious misconduct factor regardless of any ties to foreign terrorist organizations. Despite the DOJ focus on cartels and TCOs, Zaglin shows that conventional cases may survive review under the recent prioritization efforts.
To that end, no American company — especially those doing business in the government procurement industry — should conclude that the change in administration allows it to walk away from the targeted compliance activity of proactively implementing and enforcing anti-corruption and anti-money laundering controls. For example, companies should review their risk controls, including whether responsibilities are appropriately segmented across internal teams and employees in supervisory roles adequately understand indicators of potential fraud to mitigate corruption risk. Implementing corporate training for all employees, not just management, to address how to identify potentially improper high-dollar transactions, suspicious cash payments, and transfers to unsubstantiated offshore accounts can mitigate anti-money laundering risk.
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