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October 28, 2025

Rick Hartunian Featured in Anti-Corruption Report Article on the Zaglin Conviction and DOJ's Individual Enforcement Priorities

Rick Hartunian, partner, was featured in the Anti-Corruption Report article “Zaglin Conviction Offers Insights on Individual Prosecutions in Trump 2.0,” which analyzes the Department of Justice’s conviction of Carl Zaglin, CEO of Atlanco, for paying bribes to Honduran officials to secure government contracts. Commenting on the DOJ’s charging decision, Rick noted that the department “charged Carl Zaglin, the individual corporate officer who orchestrated the bribery scheme, along with his knowing associates, rather than pursuing charges against Atlanco or other corporate entities.”

Rick explained that cooperation from co-defendants was key to the government’s success, stating that their plea agreements “provided the prosecution with direct evidence regarding the mechanics of the scheme, specifically, the use of sham consultancy contracts, offshore accounts in Belize, and the intermediaries involved in transmitting corrupt payments.”

He also emphasized the growing importance of cross-border collaboration in enforcement, observing that “the successful exchange of financial records shows that jurisdictions with historically opaque banking systems can be persuaded to provide evidence through established legal channels.” Rick added that the Zaglin case “underscores that U.S. enforcement efforts are increasingly capable of reaching offshore accounts, but only when supported by cooperative governments.”

Anti-Corruption Report subscribers can read the full article here.
 

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