September 2, 2022

Two Marshall Island nationals extradited to US to face FCPA-related charges

On September 2, 2022, the US Department of Justice (DOJ) announced that Cary Yan and Gina Zhou, the former heads of an unnamed New York-based non-governmental organization (NGO), had been extradited to the US from Thailand in connection with a scheme in which they had allegedly bribed officials of the Republic of the Marshall Islands (RMI) in exchange for the passage of legislation to create a semi-autonomous region within the RMI.  The DOJ indicted Yan and Zhou on August 10, 2020, for multiple Foreign Corrupt Practices Act (FCPA) and money laundering violations for their alleged roles in the scheme, and they were arrested in Thailand on November 17, 2020.

As alleged in the indictment, between 2016 and 2019, Yan and Zhou, acting through the unnamed New York-based NGO, allegedly conspired with others to pay tens of thousands of dollars in bribes to elected officials in the RMI in exchange for obtaining their assistance to pass legislation establishing the Rongelap Atoll Special Administrative Region (RASAR) within the RMI.  The indictment alleges that the RASAR would have attracted investors to  participate in various development projects in the RMI, thereby benefiting the business of Yan, Zhou, and the NGO.

Yan and Zhou have both pleaded not guilty.  A trial date is not yet scheduled.

DOJ Press Release | Indictment