Sang Woo (also known as John Woo), is a South Korean national and worked as a real estate broker in New York City. Joo Hyun Bahn (“Bahn”), also known as Dennis Bahn, was a commercial real estate broker in New York, New York, whose father, Ban Ki Sang (“Ban”), was a senior executive at a South Korean construction company, Keangnam Enterprises Co., Ltd. Keangnam built and owned Landmark 72, a large commercial building in Hanoi, Vietnam. Malcolm Harris is, according to the DOJ, a “self-described arts and fashion consultant and blogger” who resided in New York.
The DOJ claims that beginning in 2013, Keangnam began searching for an investor to buy or refinance Landmark 72 for approximately $800 million to ease liquidity problems it was facing at the time. Ban allegedly convinced his company to enter an exclusive broker agreement with his son and his realty firm that offered a multi-million dollar commission upon completion.
In his search for investors, Bahn allegedly initiated discussions with Harris, who claimed to have connections to the royal family of a Middle Eastern country. According to the DOJ, Harris offered to use his connections to secure the investment of the country’s sovereign wealth fund in Landmark 72 in exchange for a portion of Bahn’s commission from the sale. As part of the scheme, Bahn and his father allegedly arranged for Keangnam to pay a $500,000 commission-advance to Bahn’s firm. To facilitate the scheme, Woo assisted Bahn and Ban to obtain the $500,000 which Bahn then passed to Harris to be ostensibly used as a bribe in hopes of finalizing the investment in Landmark 72. According to the DOJ, upon receipt of the $500,000, Harris pocketed the funds for himself, never having intended to complete the bribery scheme.
On January 10, 2017, the DOJ unsealed its charges filed against Bahn, Ban, Woo, and Harris in the Southern District of New York. Woo was charged with conspiracy to violate the FCPA.