b'Odebrecht has admitted that, between 2001 and 2016, it paid approximately $788 million in bribes toThe DOJ approximates that $28 million in government officials and political parties in order to gain improper business advantages in various coun- bribery proceeds were received by offshore tries. Per directives of high-ranking company officers,accounts, roughly $19 million of which Odebrecht created a department within the company called the Division of Structured Operations, the soleflowed through U.S. correspondent bank purpose of which was to manage the accounting andaccounts located in New York. disbursement of bribery payments to foreign govern-ment officials and political parties. Individuals within the Division of Structured Operations used a separate communications system to conceal their correspon- United States v. Margaret Cole et al.,dence with co-conspirators and managed the shadowNo. 20-CR-00424 (N.D. Ohio) budget using an off-network computer system. FundsOn August 17, 2020, the DOJ announced that it had for the bribery program were provided by Odebrechtscharged three women in a 13-count indictment, Finance Department and certain Odebrecht subsid- including conspiracy to violate the FCPA, for their iaries, then funneled into a series of secret, off-shorealleged roles in bribing Ugandan officials to obtain shell company bank accounts, including through Newadoptions of Ugandan and Polish children. The indict-York-based accounts. Bribery payments reachedment also alleges that the three women, Margaret their recipients through both wire transfers and cashCole, Dorah Mirembe, and Debra Parris, defrauded U.S. paymentssometimes using suitcases dropped off atadoptive parents, U.S. authorities, and a Polish regula-predetermined locations.tory authority. Brazilian political parties and officials received $349Defendant Cole is a resident of Strongsville, Ohio, million in corrupt bribery payments from 2003 throughand was the Executive Director of European Adoption 2016. In exchange, Odebrecht won contracts thatConsultants (EAC), which was an international adop-generated $1.9 billion in profits. In all, Odebrecht paidtion agency that facilitated intercountry adoptions from more than $788 million in bribes to illegally secure proj- Uganda, Poland, and elsewhere for adoptive parents in ects in twelve different countries. The scheme resultedthe United States. Defendant Parris was an employee at in benefitsi.e., profits earned on a particular projectEAC in the U.S., and Defendant Mirembe is a Ugandan won only as a result of a bribery paymenttotalingcitizen and resident who provided adoption-related approximately $3.336 billion.services to EAC. According to the indictment, the This year, two brothersLuis Enrique Martinelli Linareswomen were engaged in an international adoption and Ricardo Alberto Martinelli Linares (together, thescheme whereby they took children from their home Martinelli Linares brothers)were charged for theircountries in Uganda and Poland without properly deter-participation in Odebrechts scheme. The Martinellimining that the children were actually orphaned. The Linares brothers are accused of facilitating $28 millionDOJ charged the three women with three substantive in bribery payments to an unnamed, high-rankingFCPA counts, money laundering, mail and wire fraud, Panama government official with whom they are closelyand visa fraud, in furtherance of this illegal scheme.related.The DOJ alleges that Parris and Mirembe, with Coles From August 2009 through September 2015, theknowledge and assistance, paid bribes to Ugandan Martinelli Linares brothers are alleged to have openedsocial welfare officers in return for welfare reports that and managed secret bank accounts held in therecommended certain children be placed in orphan-names of shell companies in foreign jurisdictions toages, despite the fact that the children were not actually receive and deliver bribery payments to the Panamaput up for adoption by their parents. The defendants government official. The DOJ approximates that $28also allegedly falsified documents submitted to the U.S. million in bribery proceeds were received by offshoreDepartment of State in order to conceal their fraudulent accounts, roughly $19 million of which flowed throughscheme. As a result of their scheme, the co-defendants U.S. correspondent bank accounts located in New York.received more than $900,000 in connection with their The Martinelli Linares brothers served as signatoriescorrupt adoption services to U.S. families. on certain of the offshore accounts and personallyThe women also allegedly infiltrated the Ugandan directed the wire transfers.judicial system in a variety of ways. First, the women The Martinelli Linares brothers have not yet enteredallegedly paid bribes to Ugandan magistrate judges so pleas. that the judges would issue court orders placing the children in an orphanage without questioning whether 30'