As highlighted here, in September 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.
Last week, the DOJ announced that “Yan and Zhou each pleaded guilty to one count of conspiracy to violate the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA). They each face a maximum penalty of five years in prison. A sentencing date has not yet been set.”
As stated in the DOJ release:
“According to court documents, beginning in or around 2016 and continuing until at least August 2020, Cary Yan, 50, and Gina Zhou, 34, the heads of a New York-based non-governmental organization (NGO), conspired with others in connection with a multi-year bribery scheme. Yan and Zhou offered and paid tens of thousands of dollars in bribes to elected RMI officials – including, among others, members of the RMI legislature – in exchange for supporting legislation creating a semi-autonomous region within the RMI called the Rongelap Atoll Special Administrative Region (RASAR) that would benefit the business interests of Yan, Zhou, and their associates. Yan and Zhou carried out the bribery and money laundering scheme using the New York NGO, including the physical use of its headquarters in Manhattan, to meet with and communicate with RMI officials.”