Global Anticorruption Alert: Two Los Angeles Film Executives Found Guilty of Violating the FCPA

On Friday, September 11, 2009, Gerald and Patricia Green were found guilty of violating and conspiring to violate the Foreign Corrupt Practices Act ("FCPA") and money laundering laws of the United States. The Greens, a married couple based in West Hollywood, California, were charged with paying kickbacks to the former governor of the Tourism Authority of Thailand ("TAT") in exchange for receiving contracts to manage and operate an annual film festival as well as contracts to provide an elite tourism "privilege card" marketed to wealthy foreigners. The Greens were convicted by a federal jury in the Central District of California after a two-and-a-half week trial.

This was the third FCPA trial of 2009, and the third guilty verdict. With FCPA enforcement on the rise, more individuals face investigation and prosecution for the bribery of foreign officials.

"As these convictions demonstrate, the Department of Justice will not waiver in its fight against corruption, whether perpetrated within our borders or abroad," said Assistant Attorney General Breuer. "The FCPA is a powerful tool that the Department will continue to use in an effort to stop individuals like the Greens who seek to further their own business interests through bribes paid to foreign officials."

According to the superseding indictment filed in the case, the Greens paid approximately $1.8 million in bribes to the former TAT governor through numerous bank accounts in Singapore, the United Kingdom and the Isle of Jersey in the name of the former governor’s daughter and a friend. The contracts received by the Greens resulted in more than $13.5 million in revenue. Evidence introduced at trial showed that the Greens used different business entities, some with dummy addresses and telephone numbers, in order to hide the money they received from the contracts.

In addition to bribery in violation of the FCPA, DOJ charged the Greens with money laundering, conspiracy, obstruction of justice and making false statements on their tax returns. DOJ dismissed some money laundering counts and the jury was unable to reach a verdict on one obstruction of justice count. The conspiracy and FCPA charges each carry a maximum penalty of five years in prison, and each of the money laundering counts carries a maximum penalty of up to twenty years in prison. The false subscription of a U.S. income tax return carries a maximum penalty of three years in prison and a fine of not more than $100,000. Sentencing has been set for December 17, 2009, before the Honorable George Wu in the Central District of California.

Press Release, U.S. Department of Justice, Film Executive and Spouse Found Guilty of Paying Bribes to a Senior Thai Tourism Official to Obtain Lucrative Contracts, (Sept. 14, 2009) available at

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Christopher Cook