Saturday, May 02, 2020

Bank Hapoalim Agrees to Pay More Than $30 Million for its Role in Money Laundering Conspiracy Involving FIFA Bribery Scheme


Bank Hapoalim B.M. and Hapoalim (Switzerland) Ltd. Enter Into Three-Year Non-Prosecution Agreement

BROOKLYN, NY – Bank Hapoalim B.M. (“BHBM”), an Israeli bank with international operations, and its wholly owned subsidiary, Hapoalim (Switzerland) Ltd. (“BHS”), have agreed to forfeit $20,733,322 and pay a fine of $9,329,995 to resolve an investigation into their involvement in a money laundering conspiracy that fueled an international soccer bribery scheme.  Specifically, BHBM and BHS have admitted that they, through certain of their employees, conspired to launder over $20 million in bribes and kickbacks to soccer officials with Fédération Internationale de Football Association (“FIFA”) and other soccer federations.

Richard P. Donoghue, United States Attorney for the Eastern District of New York, Brian A. Benczkowski, Assistant Attorney General of the Justice Department’s Criminal Division, William F. Sweeney, Assistant Director-in-Charge, Federal Bureau of Investigation, New York Field Office (FBI), and Ryan L. Korner, Special Agent-in-Charge, Internal Revenue Service Criminal Investigation, Los Angeles Field Office (IRS-CI), made the announcement.

“Today’s resolution marks another successful chapter in this District’s effort to hold accountable those corporations and individuals who participated in a bribery scheme that corrupted international soccer,” stated United States Attorney Donoghue.  “This Office, along with our law enforcement partners, will continue to identify wrongdoers who manipulate international soccer in order to reap illicit profits and bring them to justice.”

“For nearly five years, Bank Hapoalim employees used the U.S. financial system to launder tens of millions of dollars in bribe payments to corrupt soccer officials in multiple countries,” stated AAG Benczkowski.  “Today’s announcement demonstrates the Department’s commitment to holding financial institutions to account when they knowingly facilitate corruption and other criminal conduct.”

“This announcement illustrates another aspect in the spider web of bribery, corruption and backroom deals going on behind the scenes as soccer games were played on the field. Bank Hapoalim admits executives looked the other way, and allowed illicit activity to continue even when employees discovered the scheme and reported it. The New York FBI Eurasian Organized Crime Task Force and our law enforcement partners have doggedly pursued every strand uncovered in this criminal investigation, and will keep at it until they root out all of the bad actors,” stated FBI Assistant Director-in-Charge Sweeney.

“This forfeiture sends a clear message that no matter how complex or far reaching the conspiracy, justice will prevail.  Bank Hapoalim B.M. and its subsidiary, Hapoalim Ltd., participated in a conspiracy that corrupted international soccer, its confederations, and member associations,” stated IRS-CI Special Agent-in-Charge Korner.  “IRS-CI is proud to work alongside our international law enforcement partners, the FBI, and the United States Attorney’s Office to bring closure to this egregious international scandal that corrupted the sport of soccer.”

According to admissions in the statement of facts stipulated to by BHBM and BHS as part of the agreement, from approximately December 10, 2010 to February 20, 2015, BHBM and BHS personnel conspired with sports marketing executives, including executives associated with Full Play Group S.A. (“Full Play”), a sports media and marketing business based in Argentina, and others, to launder at least $20,733,322 in bribes and kickbacks to soccer officials.  In exchange for those bribes and kickbacks, the soccer officials awarded or steered broadcasting rights for soccer matches and tournaments to the sports marketing executives and their companies.  Full Play allegedly executed the illegal payments from accounts held at BHS and BHBM’s branch in Miami, Florida, which were held in the names of Full Play subsidiaries and affiliates.

BHBM and BHS admitted they, through BHS and BHBM’s Miami branch, conspired to launder money for Luis Bedoya, who at various times served as the president of the Federación Colombiana de Futbol, a vice president of the Confederación Sudamericana de Fútbol (CONMEBOL), and a member of FIFA’s executive committee.  BHBM and BHS allowed accounts controlled by Bedoya to be used to receive illicit bribe and kickback payments.  In November 2015, Bedoya pleaded guilty to racketeering conspiracy and wire fraud conspiracy in the Eastern District of New York.  He is awaiting sentencing.

Despite BHS compliance personnel repeatedly raising concerns about certain payments made to soccer officials from the accounts associated with Full Play, BHBM and BHS failed to take action.  Instead, the banks’ relationship managers continued executing illicit bribe and kickback payments on behalf of Full Play.

As outlined in the agreement, the government’s decision to enter into a three-year, non-prosecution agreement with BHBM and BHS was premised upon the banks’ thorough and complete cooperation, BHBM’s pledge to review and improve its anti-money laundering program, and the banks’ other substantial remedial efforts, which include closing Bank Hapoalim (Latin America) S.A. and BHBM’s branch in Miami.  BHS is also in the process of closing its operations.

The agreement announced today is part of an investigation led by the U.S. Attorney’s Office for the Eastern District of New York, the Bank Integrity Unit in the Money Laundering and Asset Recovery Section of the Justice Department’s Criminal Division in Washington, D.C., the FBI New York Field Office, and the IRS-CI Los Angeles Field Office.  Assistant U.S. Attorneys Sam Nitze, Lauren Howard Elbert and Brian Morris of the U.S. Attorney’s Office and Trial Attorney Michael P. Grady of the Bank Integrity Unit are responsible for the matter on behalf of the U.S. Department of Justice.  The government of Switzerland provided significant assistance in this matter, as did the Criminal Division’s Office of International Affairs.

The Defendants:

BANK HAPOALIM B.M.

BANK HAPOALIM (SWITZERLAND) LTD.

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