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Issues To Consider From The Marshall Islands Enforcement Action

By on September 8, 2022 in Cary Yan, Foreign Official, Foreign Officials, Gina Zhou, Influence Legislation, Marshall Islands, Uncategorized, United Nations
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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Bribery Involving The United Nations

By on December 28, 2017 in United Nations
united nations

The United Nations has a number of anti-corruption initiatives. For starters, there is the United Nations Convention Against Corruption, it hosts the Conference of the States Parties (COSP) (the main policy-making body of the Convention), and the U.N.’s Global Compact states that “businesses should work against corruption in all its forms, including extortion and bribery.”

Instead of looking outward, perhaps the United Nations should look more inward as several Foreign Corrupt Practices Act enforcement actions, highlighted below, have involved U.N. officials or U.N. programs.

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DOJ Charges Two Individuals With FCPA And Other Violations In Connection With An African Bribery Scheme On Behalf Of CEFC China Energy Company Ltd.

By on November 21, 2017 in 2017 Enforcement Actions, Anything of Value, CEFC China Energy Company Limited, Chad, Charitable Contributions, Cheikh Gadio, Chi Ping Patrick Ho, DOJ Enforcement Action, Gifts, Individual Enforcement Action, Jurisdiction, Uganda, United Nations
ChinaEnergy

Yesterday, the DOJ announced that Chi Ping Patrick Ho (of Hong Kong, China) and Cheikh Gadio (of Senegal) were criminally charged with conspiring to violate the Foreign Corrupt Practices Act, violating the FCPA, conspiring to commit international money laundering, and committing international money laundering.

Although not specifically mentioned in the DOJ’s indictment, it is easy to connect the dots that Ho is associated with China Energy Fund Committee (CEFC) and as noted here, CEFC is “fully funded by CEFC China Energy Company Limited.” Gadio is associated with Sarata Holding (a consulting and advising firm specializing in business and development partnerships with Africa).

Big picture – in the past two weeks – the DOJ has announced three core FCPA enforcement actions involving 9 individuals. (See here for the November 7th action against 5 individuals associated with Rolls-Royce and here for the November 9th action against 2 individuals associated with SBM Offshore).

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Corruption & International Laws and Judgments

By on November 20, 2017 in Guest Posts, United Nations
corruption

Professor Juliet Sorensen (Northwestern University Pritzker School of Law) and Northwestern Law students David Hall and Kobby Lartey recently attended the Seventh Conference of States Parties to the United Nations Convention Against Corruption in Vienna, Austria.  See here for more information on the Conference. This post is from David Hall.

One of the most difficult barriers to enforcing anti-corruption regulations is that entities with the power to do so are often corrupt governments with no impetus to act. The” Corruption & International Laws and Judgments” event at this year’s Conference of the States Parties to the UN Convention Against Corruption considered how to overcome this barrier. Its consensus was that effective anti-corruption regulation will require better processes through which those regulations are created, better review of their implementation, and enforcement which is capable of compelling state action. In addition, focusing on procedures which circumvent the common causes of corruption will help us to avoid negative externalities that incentivize the spread of corruption in the first place.

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From The Dockets

By on December 6, 2016 in 2016 Enforcement Actions, Anything of Value, Bio-Rad, China, DOJ Enforcement Action, Individual Enforcement Action, Jeff Yin, Ng Lap Seng, Noisy Exit, Related Civil Litigation, United Nations
Judicial Decision

This previous post mentioned that the DOJ filed a superseding indictment adding Foreign Corrupt Practices Act charges to its existing 2015 enforcement action against Ng Lap Seng and Jeff Yin.

This previous post highlighted the May 2015 civil case brought by Sanford Wadler (the former General Counsel of Bio-Rad) asserting various employment claims against the company in the aftermath of the company’s 2014 FCPA enforcement action in which it agreed to pay approximately $55 million to resolve DOJ and SEC FCPA enforcement actions.

This post further highlights the DOJ’s individual criminal charges against Ng and Yin as well as the strange twist in the Wadler – Bio-Rad litigation.

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