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Gerald Green and Draconian Results of an Adverse FCPA Verdict

Tom Fox | August 28, 2015

Gerald Green died this week. He is one of the few individuals who went to trial against the Justice Department in a case where the government alleged violations of the Foreign Corrupt Practices Act.

Back in 2009, Green and his wife Patricia were convicted. According to the DOJ press release, from 2002 through 2007 the Greens conspired with others to bribe the former governor of the Tourism Authority of Thailand (to the tune of $1.8 million) to acquire lucrative film festival contracts, as well as other deals for the development of a Thai Privilege Card, a website, book, video, calendars and public relations services.

The Greens used different business entities, some with dummy addresses and telephone numbers, to hide how much they were receiving under the contracts. The jury found that Greens disguised the bribes as “sales commissions” and made the payments through foreign bank accounts of intermediaries in Singapore, the United Kingdom and Jersey, some in the name of...

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