On November 20, 2017, federal officials announced the unsealing of a criminal complaint filed in the Southern District of New York against the head of a Hong Kong-based non-governmental organization (“NGO”) and the former Foreign Minister of Senegal in connection with an alleged multiyear foreign bribery scheme.  According to the complaint, Hong Kong resident Chi Ping Patrick Ho, head of an NGO funded by a Chinese conglomerate (the “Energy Company”), conspired with then–Senegalese Foreign Minister Cheikh Gadio to bribe high-level officials of Chad and Uganda to secure business advantages for the Energy Company.  Authorities maintain Gadio assisted Ho in paying bribes on behalf of the Energy Company to the President of Chad.  In exchange for the alleged bribes, the Energy Company purportedly received an exclusive, non-competitive opportunity to obtain Chadian oil rights.  Gadio is accused of connecting Ho with the President of Chad and conveying the alleged bribe, services for which he was allegedly paid $400,000.  Authorities further allege Ho caused a $500,000 bribe to be paid to an account designated by the Ugandan Minister of Foreign Affairs, who at the time had recently completed a term as the President of the United Nations General Assembly.  Ho is also accused of providing the Minister of Foreign Affairs of Uganda and the President of Uganda with gifts and offers of future profit-sharing in exchange for assistance in obtaining business advantages for the Energy Company.  Ho and Gadio have each been accused of conspiring to violate the FCPA, violating the FCPA, conspiring to commit international money laundering, and committing international money laundering.  Both were arrested in mid-November and have made initial appearances in court.  U.S. v. Ho, 17-mag-8611 (S.D.N.Y.)

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