As highlighted in this prior post, in September 2022 the DOJ announced that two Marshall Island nationals (Cary Yan and Gina Zhou) arrived in the U.S. after being extradited from Thailand based on 2020 criminal charges that the individuals violated the Foreign Corrupt Practices Act (and other laws) in connection with an alleged scheme to bribe elected officials in the Republic of the Marshall Islands (RMI) in exchange for passing certain legislation.
According to the indictment, Yan and Zhou acted as officers, directors, employees, and agents of a New York City based non-governmental organization (World Organization of Governance & Competitiveness (WOGC)) and, while in New York City and other locations in U.S. territory, to offer and pay bribes to government officials in the RMI to pass certain legislation that would benefit the business interests of Yan, Zhou and their associates. Specifically, to establish a semi-autonomous region within a region of the RMI known as the Rongelap Atoll.
In December 2022, Yan and Zhou pleaded guilty to one count of conspiracy to violate the FCPA’s anti-bribery provisions. (See here).
Yesterday, the DOJ announced that Yan was sentenced to 3.5 years in prison.