On January 10, the DOJ announced the unsealing of an indictment charging four individuals, including the nephew and brother of former UN Secretary-General Ban Ki-moon, with violations of the FCPA and other offenses in connection with the attempted $800 million sale of a commercial building known as Landmark 72 in Hanoi, Vietnam. According to the government, Ban Ki Sang and Joo Hyun Bahn conspired to bribe a governmental official of an unnamed Middle Eastern country to get his country to purchase the building from Keangnam Enterprises Co., where Ban was then a senior executive. To facilitate the sale of Landmark 72, Keangnam hired Ban’s son Bahn to secure an investor for the deal.

According to the allegations, Bahn and Ban agreed to pay the foreign official $500,000 initially, and $2 million upon completion of the sale, through co-defendant Malcolm Harris, who had falsely held himself out as an agent of the foreign official; Harris Sang Woo allegedly assisted in obtaining the initial $500,000. In a twist, according to the DOJ, Harris then stole the money and used it for personal expenses instead of paying any bribes. After the Landmark 72 deal failed to go through, Bahn allegedly lied and provided forged emails from the foreign official and other documents to Keangnam regarding the status of the deal and stole approximately $225,000 that was advanced by Keangnam to cover brokerage expenses.