On April 30, 2020, the US Department of Justice announced that it had entered into a non-prosecution agreement with Bank Hapoalim B.M., an Israeli bank, and its wholly owned subsidiary, Hapoalim (Switzerland) Ltd. According to the banks’ admissions, for over four years between 2010 and 2015, employees and executives conspired with Full Play Group S.A., a sports media and marketing business based in Argentina, and others, to launder over $20 million of bribe payments and kickbacks through the US financial system for the benefit of officials of several international soccer federations, including the Fédération Internationale de Football Association (FIFA), in exchange for steering broadcasting rights to Full Play. According to the DOJ, Bank Hapoalim executives allowed illicit activity to occur even after employees discovered and reported the money laundering scheme.
As noted in the non-prosecution agreement, the DOJ premised its decision to enter an NPA on the banks’ thorough and complete cooperation, and remedial efforts such as the closing of a Latin American subsidiary, Bank Hapoalim (Latin America) S.A., the Miami branch, and in the future, Hapoalim (Switzerland) Ltd. Pursuant to the three-year NPA, Hapoalim B.M. and Hapoalim (Switzerland) will jointly pay a criminal penalty of $9,329,995, and forfeit $20,733,322.
In related actions, Full Play and others were charged on March 18, 2020, with racketeering conspiracy, wire fraud, wire fraud conspiracy and money laundering conspiracy, in the US District Court for the Eastern District of New York, and Luis Bedoya, former president of the Colombian and South American soccer federations and member of FIFA’s executive committee, pleaded guilty to racketeering conspiracy and wire fraud conspiracy in the EDNY in November 2015.
April 30, 2020