2 Defendants in Marshall Islands FCPA Bribery Scheme Extradited to US
Cary Yan and Gina Zhou, two Marshall Islands nationals charged with violating the Foreign Corrupt Practices Act, arrived in the U.S. Sept. 2 after being extradited from Thailand, the DOJ announced Sept. 2. The pair is charged with violating the FCPA, money laundering and conspiracy in a scheme to bribe elected officials in the Marshall Islands to get certain legislation passed. The August 2020 five-count indictment charged Yan and Zhou with one count of conspiring to violate the FCPA, two counts of violating the FCPA, one count of conspiring to commit international money laundering and one count of committing international money laundering.
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From 2016 to 2020, Yan and Zhou served as the president and assistant to the president, respectively, of a New York-based nongovernmental organization and allegedly worked with other co-conspirators on a bribery and money laundering scheme, the DOJ said. Yan and Zhou allegedly offered and paid tens of thousands of dollars in bribes to Marshall Islands officials to influence them to pass legislation creating a semi-autonomous region called the Rongelap Atoll Special Administrative Region that would benefit the pair's business interest. The NGO allegedly was used to make the bribe payments.
Yan and Zhou were arrested in Thailand in 2020 and extradited following proceedings in Thai courts. Each faces a maximum penalty of 20 years in prison for each count of money laundering and conspiracy to commit money laundering and a maximum sentence of up to five years for each count of violating the FCPA and conspiracy to violate the FCPA, the DOJ said.
“Yan and Zhou allegedly engaged in a multi-year scheme to bribe elected officials in the Marshall Islands and to corrupt the legislative process,” Assistant Attorney General Kenneth Polite said. “The department is committed to prosecuting individuals who participate in international corruption and undermine the integrity of democratic institutions and the free marketplace.”