Margaret Cole was the Executive Director of an unnamed international adoption agency in Strongsville, Ohio. The "Adoption Agency," which Cole co-founded in 1991, facilitated intercountry adoptions from Uganda and elsewhere for prospective adoptive parents in the United States.
Debra Parris worked for the Adoption Agency, where she was responsible for managing aspects of the Adoption Agency's Uganda program.
Dorah Mirembe, a Ugandan citizen and co-owner of a law firm with an office in Kampala, Uganda, provided adoption-related services to the Adoption Agency and legal representation and adoption-related services to the Adoption Agency's clients in Uganda.
According to the documents in this case, between 2013 and 2016 Parris and Mirembe, together with others, engaged in a scheme to pay bribes to Ugandan officials to procure the adoption of Ugandan children by families in the United States, including the adoption of children who were not properly determined to be orphaned and who had to be ultimately returned to their birth parents. Specifically, Parris, Mirembe, and their co-conspirators allegedly (1) paid bribes to social welfare officers in exchange for them issuing welfare reports recommending that certain children be placed into orphanages without first ensuring that the children were actually orphaned or that putting them up for adoption was in the children’s best interest; (2) paid bribes to Ugandan magistrate judges to obtain court orders placing those children in an orphanage that was willing to accept the children without inquiring into whether they were actually orphans; (3) paid bribes to court registrars to cause the court registrars to assign the cases of these children to two corrupt “adoption-friendly” judges; and (4) paid bribes to the corrupt Ugandan judges to obtain orders to permit their clients to bring the children to the United States for adoption. Parris, Mirembe, and others also allegedly lied to, and concealed material information from, adoptive parents, including lying about the bribe payments and whether the children were properly determined to be eligible for adoption, and concealing other material information about the children’s history. In all, the Adoption Agency received more than $900,000 in connection with these adoptions.
A separate alleged scheme in Poland did not implicate the FCPA.
On August 13, 2020, the DOJ filed a 13 count indictment in the Northern District of Ohio against Cole, Parris, and Mirembe alleging (1) conspiracy to violate the anti-bribery provisions of the FCPA and to commit visa fraud; (2-4) direct violations of the anti-bribery provisions of the FCPA; (5) conspiracy to commit mail and wire fraud; (6) mail fraud; (7) conspiracy to commit money laundering; (8-10) money laundering; (11) conspiracy to defraud the U.S.; (12) false statement to the Council on Accreditation; and (13) false statement to the Polish Central Authority. Only Parris and Mirembe were charged on the FCPA counts.
Parris entered into a plea agreement on November 16, 2021. On November 4, 2022, the court sentenced Parris to one year and a day in prison to be followed by three years of supervised release. The court further ordered Parris to pay a fine of $10,000 plus restitution of $118,197.79 to undisclosed parties and a mandatory assessment of $200.
On February 4, 2022, Cole changed her plea to guilty subject to a plea agreement entered the same day. On May 19, 2022, the court sentenced Cole to 3 months in prison to be followed by 3 years of supervised release, the first year of which would be served under house arrest. The court further ordered Cole to pay a fine of $7,500 plus a mandatory assessment of $200.
In a related proceeding, on August 12, 2019, the DOJ filed a single count Information in the Northern District of Ohio against Robin Longoria, an employee of the Adoption Agency, alleging a conspiracy to violate the anti-bribery provisions of the FCPA, to commit wire fraud, and to commit visa fraud. On August 29, 2019, Longoria pled guilty to the charge; however, any plea agreement entered between Longoria and the government was not available at the time of entry into the database. On March 23, 2022, the court sentenced Longoria to one year and a day in prison to be followed by one year of supervised release, and the court further ordered Longoria to pay restitution of $78,978.70 to redacted parties plus a mandatory assessment of $100.
