2 Marshallese Nationals Plead Guilty to Violating FCPA by Bribing Marshall Island Officials

Marshall Islands citizens Cary Yan and Gina Zhou pleaded guilty Dec. 1 to conspiring to bribe Marshallese officials for legislation that would benefit the pair's business interests, DOJ announced. The two admitted to one count of conspiracy to violate the anti-bribery provisions in the Foreign Corrupt Practices Act and face a maximum of five years in prison.

From 2016 to at least 2020, Yan and Zhou led a New York-based nongovernmental organization and worked with others to pay tens of thousands of dollars in bribes to officials in the Marshall Islands. The money went toward efforts to pass a bill creating a semi-autonomous region within the Marshall Islands called the Rongelap Atoll Special Administrative Region "that would benefit the business interests of Yan, Zhou and their associates," DOJ said. Thai authorities arrested the pair in 2020, extraditing them to the U.S. in September.

The announcement came the same day as remarks from Acting Principal Deputy Assistant Attorney General Nicole Argentieri promising the likely release of several more resolutions under the FCPA in the coming months (see 2212010060). The guilty plea from Yan and Zhou adds to the list of DOJ's FCPA enforcement actions taken against individuals, which Argentieri touted in her speech at an annual FCPA conference.