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DOJ Returns To Ugandan Bribery Scheme To Bring Additional Individual Charges


As highlighted in this prior post, in August 2019 the DOJ announced that Robin Longoria (an individual associated with European Adoption Consultants – an Ohio-based adoption agency) pleaded guilty to one count of conspiring to violate the FCPA’s anti-bribery provisions and to commit wire fraud and visa fraud “for her role in a scheme to corruptly facilitate adoptions of Ugandan children through bribing Ugandan officials and defrauding U.S. adoptive parents and the U.S. Department of State.”

Yesterday, the DOJ announced additional individual FCPA criminal charges, among others, in connection with the same Ugandan bribery scheme.

In this indictment, Debra Parris (an individual responsible for managing aspects of the Adoption Agency’s Uganda program) and Dorah Mirembe (a Ugandan citizen and resident who provided adoption-related services to the Adoption Agency including legal representation) were charged with one count of conspiracy to violate the FCPA, three substantive FCPA charges, as well other criminal charges.

Separately, Parris and Margaret Cole (Executive Director of the Adoption Agency) were also charged with various criminal charges in connection with Polish adoption issues (that did not implicate the FCPA).

In summary fashion, the indictment alleges that Parris, Mirembe and others engaged in:

“a criminal scheme to offer and pay bribes to Ugandan judges, Ugandan welfare officers, and other Ugandan officials to corruptly procure adoptions of Ugandan children in order to assist Adoption Agency with obtaining and with directing business to Adoption Agency, Mirembe, and others.”

The indictment also alleges that Parris, Mirembe and others:

“also lied to, and concealed material information from, Adoption Agency clients – including concealing facts relating to the circumstances of the children to be adopted and concealing that the adoptions were procured through bribery and fraud – in order to obtain money from Adoption Agency clients. Parris, Mirembe, and their co-conspirators also caused Adoption Agency’s clients to submit fraudulent visa applications to the United States Department of State in connection with certain adoptions.”

Regarding the Poland conduct, the indictment alleges that Parris, Cole and others engaged in a criminal scheme:

“to deceive authorities in the United States responsible for regulating intercountry adoptions about a scheme to transfer a child from Poland to Parris’s relatives without verifying that Parris’s relatives were eligible for intercountry adoption. Cole also lied to the Polish authority responsible for intercountry adoptions about the transfer of the child to Parris’s relatives in an attempt to maintain Adoption Agency’s ability to procure intercountry adoptions from Poland.”

As alleged in the indictment, the Ugandan bribes included:

“(1) bribes to a welfare officer, so that the welfare officer would recommend that children be placed into orphanages without first ensuring that the children were actually orphaned or that putting them up for adoption was in their best interest; (2) bribes to a Ugandan magistrate judge, so that the magistrate judge would issue care orders based on the corruptly procured welfare reports and place the children in a orphanage in the Kampala district of Uganda that was willing to accept the children without inquiring into whether they were actually orphans; (3) bribes to court registrars to get them to assign cases to corruption ‘adoption-friendly’ judges; and (4) bribes to Ugandan High Court judges to obtain guardianship orders to permit Adoption Agency’s clients to bring the children to the U.S. for adoption.”

According to the indictment:

“Many of the Ugandan children whose adoptions Parris and Mirembe had procured through bribery and fraud were not properly determined to be orphans, and certain of the children were ultimately returned to their birth mothers in Uganda after Adoption Agency clients came to believe that these birth mothers had not knowingly given their children up for adoption. […] Adoption Agency, in collaboration with Mirembe, procured the adoption of more than 30 Ugandan children by U.S. clients. Adoption Agency received more than $900,000 from these clients. Mirembe received more than $430,000 from Adoption Agency, as well as tens of thousands of dollars directly from Adoption Agency’s clients for representing them in Uganda.”

According to the indictment, Adoption Agency “sent invoices via e-mail to Adoption Agency clients that falsely and fraudulently concealed the bribes to court registrars as “court filing fees” and Mirembe sent invoices to Adoption Agency that falsely described bribes to Ugandan Judges as “judge’s fees.”

In the DOJ release, Acting Assistant Attorney General Brian Rabbitt  stated:

“The defendants allegedly resorted to bribery and fraud to engage in an international criminal adoption scheme that took children from their home countries in Uganda and Poland without properly determining whether they were actually orphaned.  The defendants sought to profit from their alleged criminal activity at the expense of families and  vulnerable children.These charges clearly show that the Department of Justice is committed to protecting children worldwide, including those involved in the international adoption process.”

U.S. Attorney Justin Herdman (N.D. Ohio) stated:

“These defendants are accused of orchestrating an alleged scheme that bribed Ugandan officials, defrauded the United States and manipulated parents inside and outside of the country. As a result of this alleged conduct, prospective parents were deceived, hundreds of thousands of dollars were misused and innocent children were displaced from their homes.”

Eric Smith (Special Agent in Charge of the FBI’s Cleveland Office) stated:

“These three defendants preyed on the emotions of parents, those wanting the best for their child, and those wishing to give what they thought was an orphaned child a family to love. These defendants allegedly lied to both sides of the adoption process, and bribed Ugandan officials who were responsible for the welfare of children.  Parents, prospective parents and children were emotionally vested and were heartbroken when they learned of the selfishness and greed in which these three engaged.  The FBI will never cease in its efforts to protect the innocent and unwitting from those who prey on that trust and confidence and we will vigorously pursue and hold those responsible accountable.”

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