On December 11, 2009, the DOJ filed indictments charging the 22 executives and employees with conspiring to violate the FCPA, substantive violations of the FCPA, and conspiring to engage in money laundering. The original indictments did not charge a single conspiracy but a number of separate conspiracies. However, on March 16, 2010, the DOJ filed a superseding indictment replacing the original 16 indictments in the “SHOT-Show” cases with one indictment that alleges a single overarching conspiracy. The 44 count superseding indictment seeks forfeiture of any proceeds traceable to FCPA offenses or money laundering. In support of the conspiracy allegation, the superseding indictment alleges that the defendants attended a dinner in Washington, DC on October 5, 2009 to celebrate the completion of the first phase of the contract with the African company and that they traveled to the “SHOT-Show” conference in Las Vegas in January 2010 in connection with the same business.
Three defendants pleaded guilty to conspiring to violate the FCPA: Daniel Alvirez on March 11, 2011; Jonathan Spiller on March 29, 2011; and Haim Geri on April 28, 2011.
The trials resulted in a series of mistrials and acquittals, and, in February 2012, the court granted the DOJ’s motion to dismiss the charges against the remaining defendants. Later that month, charges against Alvirez, Spiller, and Geri were dismissed as well.
