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Former Colliers broker jailed six months for FCPA offenses

A former real estate broker was sentenced to six months in prison Thursday for trying to bribe a Middle Eastern official to finance the sale of a high-rise building complex in Vietnam.

Joo Hyun Bahn, also known as Dennis Bahn, 39, of Tenafly, New Jersey, was sentenced in federal court in Manhattan.

He also agreed Thursday to disgorge $225,000 to the SEC to settle civil FCPA violations.

Bahn pleaded guilty in January this year in the criminal case to one count of conspiracy to violate the Foreign Corrupt Practices Act and one count of violating the FCPA.

He was acting as a broker for Colliers International Group, Inc., intending to help a South Korean construction company sell the Landmark 72 building complex in Hanoi to Qatar's sovereign wealth fund.

The purported bribes were supposed to be $2.5 million. Landmark 72 was valued at $800 million. Bahn would have made $5 million for brokering the deal.

The SEC said Bahn "circumvented Colliers’ internal accounting controls, fabricated documents, created fictitious email messages, and lied to Colliers executives."  

Bahn also falsely represented that a buyer had committed to acquire the building, causing Colliers to improperly record commission revenue that it wouldn't receive, the SEC said.

The SEC settled Thursday with Bahn by an internal administrative order (pdf) and didn't go to court.

The DOJ charged Bahn and his father, Ban Ki Sang, 69, and Malcolm Harris in December 2016.

Ban Ki Sang was a senior executive at the company that developed Landmark 72, Keangnam Enterprises. Ban's brother is former United Nations Secretary-General Ban Ki-moon.

Harris, 53, was sentenced to 42 months in prison in October 2017. He pleaded guilty to one count of wire fraud and one count of money laundering.

Harris took $500,000 from Ban and Bahn by posing in text messages and emails as an agent of a Qatari official.

Landmark 72 opened in 2012. It includes two 50-story office buildings and one 72-floor tower, the tallest building in Vietnam. There are apartments, offices, and hotels in the complex.

The chairman of Keangnam, Sung Woan-jong, committed suicide in April 2015 after being investigated in South Korea for alleged corruption. He reportedly left a list of politicians in Korea he claimed to have bribed.

A wire service report said Bahn told Judge Edgardo Ramos that his "bad judgment led to other bad judgments."

Judge Ramos said he believed that Bahn deserved a lenient sentence because he "acted in part to try to help his father overcome financial difficulties," the report said.


Harry Cassin is the managing editor of the FCPA Blog.