In late 2023, the DOJ announced the unsealing of an indictment criminally charging: Carl Alan Zaglin (the owner of a Georgia-based manufacturer of law enforcement uniforms and accessories); Francisco Roberto Cosenza Centeno (former Executive Director of the Comité Técnico del Fideicomiso para la Administración del Fondo de Protección y Seguridad Poblacional (TASA) a Honduran governmental entity that procured goods for the Honduran National Police); and Aldo Nestor Marchena (a dual citizen of the U.S. and Peru) for their alleged participation in a scheme to pay and conceal bribes to Honduran government officials to secure contracts to provide uniforms and other goods to the Honduran National Police. (See here for the prior post).
The indictment contained allegations regarding: (i) a $4.8 million uniform contract with TASA; (ii) a $5.6 million uniform contract with TASA; (iii) a $480,000 contract for tear gas launchers and ammunition; and (iv) a bid for a $7.5 million uniform contract with TASA.
Zaglin and Marchena were charged with conspiracy to violate the FCPA’s anti-bribery provisions and Zaglin was charged with substantive violations of the anti-bribery provisions. Zaglin, Marchena and Francisco Roberto Cosenza Centeno (the alleged foreign official) were further charged with conspiracy to commit money laundering and the later two individuals are charged with substantive money laundering offenses and engaging in transactions in criminally derived property.
A June 2nd docket entry stated that a change of plea hearing will be held on June 5th and that trial is cancelled as to Marchena.
Yesterday, the DOJ filed a Superseding Information charging Marchena with conspiracy to commit money laundering.
The short superseding information alleges that Marchena and others conspired to violate 18 USC 1957 by knowingly engaging in a monetary transaction through a financial institution, affecting interstate and foreign commerce, in criminally derived property of a value greater than $10,000, such property having been derived from a specified unlawful activity.
The superseding information alleges that the specified unlawful activity was, among other things, a violation of the FCPA’s anti-bribery provisions.
