Business Crimes Hotline

The bribery plot commenced in March 2013, when Ban Ki Sang (“Sang”), an executive at Keangnam Enterprises Co. Ltd. (“Keangnam”), a construction company in South Korea, sought to sell a skyscraper in Hanoi, Vietnam. As Keangnam was faced with a liquidity crisis, Sang convinced the company to enter into an agreement with his son, Joo Hyun Bhan (“Bhan”), and his real estate firm to sell the complex, Landmark 72. According to Assistant Director in Charge of the FBI's New York Field Office, William F. Sweeney Jr., “instead of lawfully obtaining financing for the deal, [Sang and Bhan] allegedly entered into an illegal agreement with Harris to bribe a foreign official into purchasing the property.”

Sang and Bahn approached Harris, whom they believed to have connections with officials in a Middle Eastern government, and agreed to pay him a $500,000 up-front fee — with an additional $2 million due at closing — for arranging the sale of Landmark 72 to the unnamed country's sovereign wealth fund. San Woo (“Woo”), also charged in the case, assisted Sang and Bahn in securing funds for the $500,000 bribe.

Harris, who had no connection to any Middle Eastern government, falsified emails and text messages from government officials agreeing to the transaction. Rather than funneling the bribe payment to the foreign government as promised, Harris pocketed the funds for his own use, spending it on a lavish condo in Brooklyn, NY. In turn, Bahn lied to Keangnam and its creditors by forging emails and documents, regarding the sovereign wealth fund's interest in the property. The purported sale was for $800 million, from which Bahn would receive a multimillion dollar commission through his exclusive brokerage agreement with Keangnam.

— Colleen Snow, Mayer Brown