Carl Zaglin Case Exposes How Bribery and Money Laundering Intertwine in Global Procurement

The conviction of Carl Alan Zaglin, the CEO of Georgia-based Atlanco LLC, has sparked global attention not only because of the criminal acts themselves but because it illustrates how bribery and money laundering can be intertwined to sustain corruption over years. What unfolded was not simply a case of one businessman seeking profit; it is being seen as a case study in how international procurement systems can be bent when corrupt payments are hidden behind carefully constructed laundering methods.

Atlanco, Zaglin’s company, appeared on the surface to be a legitimate manufacturer of law enforcement uniforms and equipment, supplying products that are in consistent demand worldwide. Yet beneath this corporate image, the firm was securing contracts worth over $10 million from the Honduran government through bribery. Those bribes were never as simple as passing cash under the table. Instead, they were pushed through a maze of intermediaries, shell entities, and financial accounts stretching across the U.S., Belize, and other jurisdictions.

The laundering element was essential in prolonging the scheme. By disguising the illicit payments as commissions, service fees, or brokerage contracts, Honduran officials could receive the funds without arousing immediate suspicion. The bribes were processed so smoothly through financial systems that they initially passed as legitimate transactions. It took years of investigation—led by Homeland Security Investigations in Miami and supported by international partners—to finally piece together the full scope of the operation.

At the core of the network sat Zaglin and Atlanco. To create a buffer between the U.S.-based company and Honduran officials, Zaglin depended on Aldo Nestor Marchena, an intermediary based in Florida. Marchena submitted fabricated invoices for services that never occurred, billing Atlanco for fake work and ultimately receiving about $2.5 million. These funds were then transferred to accounts held by Honduran officials or their associates, dispersed across the U.S., Belize, and elsewhere to create a layering effect that obscured the illicit origins. By the time payments reached figures like Francisco Roberto Cosenza Centeno, the former head of Honduras’ TASA procurement agency, the funds appeared to be legitimate consultancy payments rather than disguised bribes for contracts.

The scheme went further, employing coded language and sham agreements to maintain cover. Marchena was referred to as “Miami,” while terms like “the guys” or “the others” were used to signify Honduran officials. Paperwork was dressed up as brokerage contracts to fabricate legitimacy, while sensitive conversations were kept to encrypted apps and private emails. Together, these methods created a well-engineered system of concealment.

For banks and financial watchdogs, spotting such activity without advanced monitoring would have been highly difficult. Payments justified as “brokerage services” are a textbook warning sign, particularly when repetitive and linked to procurement in corruption-prone jurisdictions. Still, without coordinated international inquiry, such a scheme could have persisted undetected for much longer.

The anti-money laundering implications are stark. First, intermediaries in high-risk countries pose one of the greatest threats. While companies often justify hiring local brokers as a necessity for navigating bureaucracy, such arrangements can easily become channels for bribes. Compliance checks must therefore be particularly rigorous in these contexts.

Second, sham invoices remain a hallmark technique in laundering bribery proceeds. In this case, vague contracts and invoices carried on for years without substantive documentation, and Atlanco authorized payments regardless. Effective compliance programs should have flagged such transactions immediately.

Third, the case reaffirms the importance of international cooperation. Money moved from Georgia to Florida and then across multiple borders before arriving in Honduras and Belize. The case was eventually cracked only through collaboration between U.S. authorities and counterparts abroad, alongside the use of legal agreements for cross-border cooperation.

From a legal perspective, the case also illustrates how the Foreign Corrupt Practices Act (FCPA), which criminalizes bribery of foreign officials, operates in tandem with U.S. money laundering statutes. Zaglin was convicted for both bribery and laundering conspiracy, reinforcing the legal principle that these crimes are inherently connected.

The consequences for Zaglin are significant. Each FCPA charge carries a sentence of up to five years in prison, while the conspiracy to launder money could mean up to twenty years. Sentencing guidelines will dictate the final outcome, but the case underscores that executives cannot dismiss compliance risks as minor administrative concerns—the personal consequences can amount to decades behind bars.

The ripple effects of the Atlanco scandal stretch further still. In Honduras, the case demonstrates how state institutions like TASA, tasked with supplying police forces, can be corrupted, diverting public funds meant for security into corrupt networks. Citizens pay the price when such funds are siphoned away.

In the U.S., the case shows how domestic companies can become both drivers and facilitators of corruption abroad. By pushing illicit money through American banks, Atlanco compromised not only foreign procurement processes but also the integrity of U.S. financial systems. Honest businesses were cheated out of opportunities to compete fairly, damaging perceptions of American corporate practices internationally.

Globally, this case adds to the growing recognition that money laundering is not the exclusive domain of cartels or organized crime syndicates. Corporate executives, operating within legitimate industries, are fully capable of constructing laundering systems using intermediaries, forged contracts, and layered bank transfers that rival those of criminal organizations.

For compliance officers and regulators, the message is clear: vigilance must go beyond traditional crime typologies. Corruption and corporate bribery often hide behind the appearance of legitimate business practices. Training efforts need to focus on identifying the red flags—repetitive transfers to vague service providers, reliance on high-risk jurisdictions, and the use of personal channels for official communications. Without such scrutiny, corporate actors will continue to exploit the blind spots of international finance.

By fLEXI tEAM