August 17, 2020

Individuals sanctioned and charged with FCPA and money laundering violations in connection with adoption scheme

On August 13, 2020, the US Department of Justice, in a 13-count indictment filed in US District Court for the Northern District of Ohio, charged three women—Debra Parris, Dorah Mirembe, and Margaret Cole—with US Foreign Corrupt Practices Act and money laundering violations in connection with their alleged roles in corruptly and fraudulently arranging adoptions of children from Uganda and Poland by U.S. adoptive parents.

According to the indictment, Parris (who worked at an adoption agency run by Cole), Marembe (who worked at a Ugandan law firm that provided adoption-related services to Cole’s agency), and other unnamed co-conspirators bribed Ugandan welfare officers, judges, and court registrars to procure the adoption of Ugandan children by US families, including in some cases children who were not actually orphaned or who were not eligible for adoption.  Under the scheme, the bribe-takers would ensure that children were placed in specific orphanages, and that the adoption cases were assigned to judges participating in the scheme.  Parris and Marembe also charged the adoptive parents additional fees to pay for these bribes, while concealing the true purpose of the fees as well as information about the child’s well-being and history in Uganda.  The two also allegedly worked with co-conspirators to submit false documents to the US State Department in order to hide their scheme from authorities.

The indictment also alleges that Parris and Cole participated in a separate scheme to allow Parris’s relatives to adopt a Polish child despite one of these relatives having a criminal record and being ineligible for an intercountry adoption.  After reports that the child was physically abused, Parris and Cole took steps to conceal their unlawful conduct from the US and Polish authorities in charge of intercountry adoptions.

In a related action, on August 17, 2020, the US Department of the Treasury’s Office of Foreign Assets Control sanctioned Mirembe, along with her husband and two Ugandan judges, pursuant to Executive Order 13818 (which implements the Global Magnitsky Human Right Accountability Act).  OFAC imposed sanctions based on these individuals’ involvement in the above-mentioned adoption “scam,” which OFAC noted had resulted in the victimization of many Ugandan children.  As a result of these sanctions, all US property for these individuals is blocked, and all transactions and dealings with US persons are generally prohibited.  In addition, any entity in the US that is owned fifty percent or more, directly or indirectly, by a sanctioned individual is also blocked.

DOJ Press Release | OFAC Press Release | DOJ Complaint