Cary Yan, Bribery, New York 2022

Bribery Scheme Uncovered in Marshall Islands

Cary Yan, a/k/a “Hong Hui Yan,” a/k/a “Chen Hong,” and Gina Zhou, a/k/a “Chaoting Zhou,” a/k/a “Angel Zhou,” pled guilty to conspiring to violate the Foreign Corrupt Practices Act (“FCPA”) in connection with a multi-year scheme to bribe government officials in the Republic of the Marshall Islands (the “RMI”) to pass legislation that would benefit the business interests of Yan, Zhou, and their associates.

The scheme, which began at least in 2016, involved YAN and ZHOU communicating and meeting with RMI officials in both New York City and the RMI concerning the development of a semi-autonomous region within a part of the RMI known as the Rongelap Atoll.

As proposed by YAN and ZHOU, the so-called Rongelap Atoll Special Administrative Region (the “RASAR”) would be created by legislation (the “RASAR Bill”) that, if enacted by the RMI legislature, would significantly change the laws on the Rongelap Atoll to attract foreign businesses and investors, such as by lowering or eliminating taxation and relaxing immigration regulations.

Starting before the introduction of the RASAR Bill, and continuing until at least November 1, 2018, YAN and ZHOU offered and provided a series of cash bribes and other incentives to obtain the support of RMI legislators for the RASAR Bill.

In this case, YAN and ZHOU were arrested by Thai authorities in November 2020, and subsequently extradited to the United States on September 2, 2022.

U.S. Attorney Damian Williams said, “As they have now admitted, the defendants sought to undermine the democratic processes of the Republic of the Marshall Islands through bribery in order to advance their own financial interests.  I commend the career prosecutors of this Office and our law enforcement partners for bringing this corruption to light and ensuring that justice is done.”

Defendant:

Cary Yan a/k/a “Hong Hui Yan,” a/k/a “Chen Hong”

Criminal Charges:

Conspiring to violate the Foreign Corrupt Practices Act (“FCPA”)

City and State:

New York

Date:

September 2, 2022 (extradition)

Sentence or Outcome:

Pled guilty

Dollar Amounts:

$7,000 in cash

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