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United States FCPA enforcement post-pause: DOJ prioritises serious, concealed individual bribery harming US businesses; Zaglin and related cases guide compliance

Published on: 26 November 2025

Published by a Law360 reporter

Legal News

Article summary

A US entrepreneur was convicted of FCPA breaches and money laundering after joining a plan to pay bribes to Honduran officials to secure contracts to supply law enforcement uniforms in Honduras. The Zaglin matter provides an early signal of how the US DOJ could deploy the new guidance—especially in prosecutions of individuals. It underscores a continued focus on individuals in such matters. Importantly, the conduct did not touch drug cartels, national security issues, or a non-US corporate accused. The lack of such factors indicates that, although the administration stresses aligning FCPA enforcement with foreign policy aims, the DOJ still intends to bring individual cases largely in line with its historic practice going forward.

Background

On 28 November 2023, the US Attorney’s Office for the Southern District of Florida charged Carl Alan Zaglin, a US national and the proprietor of Atlanco LLC, a Georgia-based maker of law-enforcement uniforms, with one count of conspiring to violate the FCPA, one substantive FCPA count, and one count of conspiracy to commit money laundering...

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