Christian Sapsizian was employed by Alcatel S.A. or an Alcatel subsidiary starting in around 1981. From around 2001 to around late 2004, Sapsizian was the Deputy Vice President of Latin America for Alcatel CIT, S.A., a wholly-owned subsidiary of Alcatel in France, and reported to Alcatel CIT's Vice President of Latin America. During this time, Alcatel's Vice President of Latin America delegated the responsibility for Costa Rica to Sapsizian. His responsibilities included negotiating contacts in Latin America on behalf of Alcatel and Alcatel CIT.
Edgar Valverde Acosta was a Costa Rican national who managed Alcatel de Costa Rica, S.A on a day-to-day basis. From at least 2000 to around late 2004, Valverde was the Senior Country Officer of Alcatel de Costa Rica. Sapsizian supervised Valverde with regard to the approval and hiring of consultants in Costa Rica.
According to the allegations in the indictment, from around February 2000 through around September 2004, Sapsizian and Valverde offered and agreed to pay money to an official with El Instituto Costarricense de Electricidad ("ICE"), the state-owned telecommunications authority in Costa Rica. They knew that the payments would be shared with a Senior Government Official in Costa Rica, and the payments were made in exchange for the two officials' assistance in obtaining favorable policy decisions and obtaining and retaining contracts with ICE, including a contract to develop a GSM mobile network in Costa Rica and to provide 400,000 lines of mobile telephone service, which was valued at approximately $149 million. In total, approximately $2.56 million in improper payments were made.
On March 20, 2007, the DOJ filed a ten count superseding indictment in the Southern District of Florida against Sapsizian and Valverde alleging conspiracy to violate the anti-bribery provisions of the FCPA and direct violations of the anti-bribery provisions of the FCPA. Sapsizian was charged in all ten counts, and Valverde was charged in counts 1 and 3-10.
On June 6, 2007, Sapsizian entered into a plea agreement with the DOJ. Under the terms of the agreement, Sapsizian pleaded guilty to counts 1 and 2 of the superseding indictment (the DOJ dismissed the remaining counts), agreed to forfeit $261,500 and to pay a mandatory assessment of $200, and agreed to be sentenced according to the sentencing guidelines, which recommended a range of 87-108 months imprisonment. Prior to sentencing, the DOJ moved for a 30% downward departure in Sapsizian's sentence for substantial assistance pursuant to rule 5K1.1. On September 24, 2008, the court sentenced Sapsizian to 30 months in prison plus 3 years of supervised release, which included mandatory participation in an approved inpatient/outpatient mental health treatment program, and to the forfeiture and assessment noted above.
Valverde appears to remain a fugitive from United States law enforcement, but he served a one year prison sentence in Costa Rica for related charges.
