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Issues To Consider From The Marshall Islands Enforcement Action

Issues

This recent post discussed the DOJ’s announcement 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.

This post continues the analysis by highlighting additional issues to consider.

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DOJ Announces 2020 Criminal Charges Against Individuals In Connection With Alleged Marshall Islands Bribery Scheme

Yan&Zhou

Last Friday, the DOJ announced that two Marshall Island nationals (Cary Yan and Gina Zhou – pictured) 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 (NGO) 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.

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