In June 2023, the DOJ announced an enforcement action against Amadou Kane Diallo (pictured – a Senegalese national and California resident who was the CEO of two California-based companies: Virtual Advisors LLC and Liquide Inc).
As stated in the DOJ release:
“Diallo allegedly solicited investments in his companies from at least 11 individuals for purported business opportunities in technology, health care, real estate, home ownership, and service to the African diaspora. Diallo allegedly made various false representations, including that investor funds would be spent to further investors’ interests, or not be spent at all, and instead used as “skin in the game” to attract institutional investors. Diallo is also alleged to have lied to potential investors, claiming that he had raised hundreds of millions of dollars for another investment firm and its real estate investment fund when, in fact, he had never raised any such funds.
Diallo allegedly caused at least 11 victim-investors to pay him, Virtual Advisors, and Liquide, more than $1.8 million. Contrary to his representations to investors, Diallo allegedly used their money to fund his own extravagant lifestyle, including making rent payments on his home; paying for luxury vehicles; buying clothes and fancy dinners; joining fitness clubs and spas; and hosting lavish events for foreign government officials.
Diallo is charged with 19 counts of wire fraud and two counts of money laundering.”
In September, the DOJ filed this superseding indictment adding an FCPA anti-bribery charge.
According to the superseding indictment:
“In addition to, and in connection with, defendant DIALLO’s fraudulent scheme… defendant DIALLO corruptly sought a grant of land in Senegal from Senegalese government officials, from which defendant DIALLO intended to extract value by taking a loan on the property that defendant DIALLO sought to corruptly obtain, or by other means. Defendant DIALLO’s corrupt efforts included the following, among others:
a. In or around November 2018, and in furtherance of his corrupt efforts to obtain a grant of land in Senegal from government officials, defendant DIALLO hosted Official 1 (described as an official in the government of Senegal with responsibilities related to real estate development, investment, and government contracting) in Orange County, California and provided him with luxury accommodations, transportation, and lavish entertainment. Among other things, defendant DIALLO chartered a helicopter for Official 1 to attend a Los Angeles Lakers basketball game.
b. In or around December 2018, after receiving an invitation from Official 2 (also described as an official in the government of Senegal with responsibilities related to real estate development, investment, and government contracting) to visit Senegal, defendant DIALLO, accompanied by other victim-investors, traveled to Senegal. In Senegal, defendant DIALLO attended a meeting with Official 2 on or about December 31, 2018, and in an effort to induce Official 2 to authorize the land-grant that defendant DIALLO sought, defendant DIALLO corruptly offered to provide five vehicles to Official 2 to assist with a political campaign.”
Diallo has pleaded not guilty as to all of the charges.
