On August 29, the DOJ announced that it had unsealed a criminal complaint and FBI affidavit charging retired U.S. Army colonel Joseph Baptiste “for his alleged role in a foreign bribery and money laundering scheme in connection with a planned $84 million port development project in Haiti.” The DOJ alleges that Baptiste solicited bribes “from undercover [FBI] agents in Boston who posed as potential investors,” telling the agents “that he would funnel the payments to Haitian officials through a non-profit entity that he controlled . . . in order to secure government approval of the project.” Baptiste allegedly received a $50,000 payment from the FBI, which he wired to his non-profit organization. While Baptiste ultimately used the payment for personal purposes, rather than his promised bribery, he allegedly “intended to seek additional money from the undercover agents to use for future bribe payments in connection with the port project.” The DOJ also alleges that FBI agents intercepted telephone calls where Baptiste “discussed bribing an aide to a senior Haitian official by giving him a job on the port development project after he left his position.”

FCPA sting operations are relatively rare. An infamous FCPA sting operation involving Africa resulted in charges for 22 defendants, but it concluded unsuccessfully in 2012 after a series of acquittals and hung juries caused the DOJ to dismiss the remaining indictments.