SEC v. Yaw Osei Amoako (D.N.J. 2005)
SEC v. Steven J. Ott and Roger Michael Young (D.N.J. 2006)

• Case Name
• SEC v. Yaw Osei Amoako (D.N.J. 2005)
  SEC v. Steven J. Ott and Roger Michael Young (D.N.J. 2006)

• Date Filed
• 11/17/2016

• Enforcement Agency
• SEC

• Countries
• Nigeria, Rwanda, Senegal

• Foreign Official
• Senior officials of government-owned telephone companies.

• Date of Conduct
• 2006 to 2013

• Nature of Business
• Procurement of telecommunication services contracts by ITXC Corp. (“ITXC”), a U.S.-based provider of global telecommunications services.  In 2004, ITXC merged with Teleglobe International Holdings, Ltd. (“Teleglobe”), a U.S.-based provider of international voice, data, Internet, and mobile roaming services.  Yaw Osei Amoako (“Amoako”), Steven J. Ott (“Ott”), and Roger Michael Young (“Young”) were former senior employees involved in operations in Africa for ITXC.

• Influence to be Obtained
• According to the criminal and SEC complaints in these actions, Amoako, Ott, and Young helped arrange several payments to officials at government‑owned telephone companies, Nitel, Rwandatel, and Sonatel.  In exchange for the payments, they sought the award of lucrative telephone contracts to provide individual and business telecommunication services in those countries.

• Enforcement
• After identifying the potential improper payments, Teleglobe notified the SEC and DOJ and conducted its own internal investigation.  After conducting their own investigations, the SEC and DOJ in June 2005 brought separate cases against Amoako for violations of the FCPA.  On September 6, 2006, the DOJ reported that Amoako had pled guilty to one count of conspiring to violate the anti‑bribery provisions of the FCPA.  On April 22, 2008, without admitting or denying the allegations of the complaint, Amoako consented to the entry of final judgment with the SEC, by which he is permanently enjoined from violating the anti‑bribery, internal controls, and books and records provisions of the FCPA.  Amoako also agreed to disgorge $150,411 in profits, together with $38,042 in interest.  The SEC brought an action against Ott and Young on September 6, 2006 for three counts of violating the anti‑bribery and books and records provisions of the FCPA, seeking injunctive relief, penalties, and disgorgement.  In April 2008, Ott and Young, without admitting or denying the facts in the complaint, settled with the SEC and agreed to an order enjoining them from committing future violations of the FCPA.

• Amount of the Value
• $267,468.95.

• Amount of Business Related to Payment
• Not Stated

• Intermediary
• Not Stated

• Citizenship of Parent Entity
• United States

• Total Sanction
• $ 226,495

• Compliance Monitor
• No

• Reporting Requirements
• No

• Case is Pending?
• No

• Total Combined Monetary Sanction
• $ 226,495

• Related Enforcement Actions
• United States v. Yaw Osei Amoako (D.N.J. 2005)
  United States v. Steven J. Ott (D.N.J. 2007)
  United States v. Roger Michael Young (D.N.J. 2007)
  

Yaw Osei Amoako 

• Citation
• SEC v. Amoako, No. 3:05-cv-01122 (D.N.J. 2005); 

• Date Filed
• 11/17/2016

• Filed Under Seal
• No

• FCPA Statutory Provision
• • Aiding and Abetting: Books-and-Records
  • Anti-Bribery
  • Books-and-Records
  • Internal Controls

• Other Statutory Provision
• None

• Disposition
• Complaint and Consent Order

• Defendant Jurisdictional Basis
• Agent of Issuer

• Defendant's Citizenship
• United States

• Individual Sanction
• 226495

Steven J. Ott

• Citation
• SEC v. Ott, et al., No. 3:06-cv-04195 (D.N.J. 2006).

• Date Filed
• 11/17/2016

• Filed Under Seal
• No

• FCPA Statutory Provision
• • Aiding and Abetting: Books-and-Records
  • Aiding and Abetting: Internal Controls
  • Anti-Bribery
  • Books-and-Records
  • Internal Controls

• Other Statutory Provision
• None

• Disposition
• Complaint and Consent Order

• Defendant Jurisdictional Basis
• Agent of Issuer

• Defendant's Citizenship
• United States

Roger Michael Young

• Citation
• SEC v. Ott, et al., No. 3:06-cv-04195 (D.N.J. 2006).

• Date Filed
• 11/17/2016

• Filed Under Seal
• No

• FCPA Statutory Provision
• • Aiding and Abetting: Books-and-Records
  • Aiding and Abetting: Internal Controls
  • Anti-Bribery
  • Books-and-Records
  • Internal Controls

• Other Statutory Provision
• None

• Disposition
• Complaint and Consent Order

• Defendant Jurisdictional Basis
• Agent of Issuer

• Defendant's Citizenship
• United States