What happens when a Chief Executive Officer becomes the architect of a global bribery scheme? In this episode of Corruption, Crime, and Compliance, Michael Volkov delivers an in-depth analysis of the BIT Mining FCPA case — a landmark matter that underscores the severe consequences of C-suite misconduct. With CEO Zhengmin Pan at the center of the conspiracy, BIT Mining’s efforts to infiltrate Japan’s emerging casino market were built on fraudulent payments, sham contracts, and falsified financial records.
Michael examines the tactics used to conceal illicit payments, the role of Japanese authorities in uncovering the misconduct, and the broader implications for corporate compliance and executive accountability.
You’ll hear him discuss:
- How BIT Mining’s former CEO, Zhengming Pan, supervised a $2 million bribery scheme targeting Japanese government officials to secure entry into Japan’s integrated resort (IR) market.
- The tactics used to launder bribe payments include sham consulting agreements, inflated lecture fees, and misclassifying bribes as “management advisory fees” and “travel expenses” in company records.
- The DOJ’s charges against Pan included conspiracy to violate the FCPA’s anti-bribery and books-and-records provisions, multiple counts of books-and-records violations, and substantive anti-bribery offenses.
- The terms of Bit Mining’s three-year Deferred Prosecution Agreement (DPA) with the DOJ, which included an agreed-upon $10 million criminal penalty, were reduced from an initial $54 million based on the company’s inability to pay.
- The SEC’s parallel enforcement action, which resulted in a $4 million civil penalty, was later credited against the DOJ’s settlement amount.
- How did Japanese enforcement authorities play a crucial role in uncovering the scheme, and what ultimately led to Bit Mining’s failure to win the integrated resort bid?
- Practical compliance takeaways for corporate boards and executive teams, including the importance of strong third-party due diligence, financial control safeguards, and executive oversight to prevent and detect misconduct at the top.
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