Joo Hyun Bahn, Foreign Bribery and Fraud, New York 2024

Four individuals are facing federal charges in a sprawling foreign bribery and fraud scheme tied to an $800 million attempt to sell Landmark 72, a 72-story commercial skyscraper in Hanoi, Vietnam, to a Middle Eastern sovereign wealth fund. The indictment, unsealed in Manhattan, names JOO HYUN BAHN, a/k/a “Dennis Bahn,” BAN KI SANG, MALCOLM HARRIS, and SANG WOO, a/k/a “John Woo,” in a criminal conspiracy involving violations of the Foreign Corrupt Practices Act (FCPA), wire fraud, money laundering, and aggravated identity theft.

According to the indictment, BAHN and his father BAN schemed to bribe a foreign official—referred to as “Foreign Official-1”—from a Middle Eastern country known as “Country-1,” to secure approval for the sale of the landmark tower through Keangnam Enterprises Co., Ltd., a South Korean construction company where BAN held a senior executive role. The alleged bribe totaled $2.5 million, to be funneled through a web of shell companies and forged documents, with BAHN—operating as a Manhattan-based real estate broker—slated to earn millions in commissions if the deal closed.

The scheme unraveled not by law enforcement, but betrayal. Malcolm Harris, the man allegedly recruited to set up the bribery channel, is accused of taking the $2.5 million bribe payment and disappearing with the funds. Investigators say Harris never contacted the foreign official and instead laundered the money for personal gain, effectively double-crossing the conspirators in what prosecutors call a crime rooted in corruption and capped by fraud.

Manhattan U.S. Attorney Preet Bharara said the case exemplifies the rot of international graft: “The father-son defendants, Ban Ki Sang and Joo Hyun Bahn, allegedly conspired to bribe a foreign official to close an $800 million deal… But these alleged schemers were themselves double-crossed.” Bharara added the case stands as a warning: “Those who bring international corruption to New York City… will face the scrutiny of American law enforcement.”

FBI Assistant Director William F. Sweeney Jr. detailed the desperation behind the crime: BAN, under pressure from mounting corporate debt, turned to his son BAHN to find a buyer. Instead of lawful finance channels, they allegedly chose corruption—enlisting Harris to broker the bribe. “In the end,” Sweeney said, “they were hoodwinked by their very own criminal activity.”

The charges include multiple counts of FCPA violations, wire fraud, money laundering, and aggravated identity theft for BAHN, BAN, and HARRIS. SANG WOO is separately charged in a complaint with conspiracy to violate the FCPA. All remain in federal custody or are subject to extradition. The case is being prosecuted by the U.S. Attorney’s Office for the Southern District of New York’s Public Integrity and Money Laundering Units, underscoring the DOJ’s aggressive stance on global corruption with U.S. ties.