World Organization of Governance and Competitiveness ("WOGC") was a non-governmental organization established in 2016 with its principal place of business in New York. At various times, WOGC was registered as a corporation in New York State and, at other times, as an unincorporated organization. WOGC purported to maintain a "special consultative status" with the United Nations Department of Economic and Social Affairs from 2016 to at least 2018. Though WOGC is not directly identified in the documents in this case, the Clearinghouse determined through independent research that the non-governmental organization noted in the documents was likely WOGC.
Cary Yean, a/k/a "Hong Hui Yan" or "Chen Hong," was a Marshall Islands businessman who operated in New York, Hong Kong, the Marshall I slands, and other places. Yan served as the President and Chairman of the WOGC.
Gina Zhou, a/k/a "Chaoting Zhou" or "Angel Zhou," a Marshall Islands national, acted as the executive assistant for Yan at WOGC.
According to the documents in this case, beginning in 2016 and continuing through August 2020, Yan and Zhou conspired with others to bribe several elected officials in the Marshall Islands in exchange for the officials' support of legislation creating a semi-autonomous region within the Marshall Islands called the Rongelap Atoll Special Administrative Region that would benefit the business interests of WOGC, Yan, and Zhou. The indictment alleges that Yan and Zhou carried out the bribery and related money laundering schemes from WOGC's offices in New York.
On August 10, 2020, the DOJ filed a five count indictment under seal in the Southern District of New York against Yan and Zhou alleging conspiracies to violate the antibribery provisions of the FCPA and to commit money laundering as well as direct violations of the antibribery provisions of the FCPA and money laundering statutes. Both Yan and Zhou were arrested on November 17, 2020, in Thailand at the request of the U.S., and they were subsequently extradited to the U.S. on September 2, 2022. The DOJ unsealed the indictment against the defendants the same date. The DOJ announced in a press release on December 1, 2022, that both Yan and Zhou had pled guilty.
On February 16, 2023, the court sentenced Zhou to time served in prison, giving credit for the time she spent under arrest in Thailand, and ordered her to pay a mandatory assessment of $100.
On May 16, 2023, the court sentenced Yan to 42 months in prison to be followed by two years of supervised release and ordered him to pay a mandatory assessment of $100.
