United States v. Si Chan Wooh (D. Or. 2007)

• Case Name
• United States v. Si Chan Wooh (D. Or. 2007)

• Date Filed
• 06/26/2007

• Enforcement Agency
• DOJ

• Foreign Official
• Managers of Government Customers.

• Date of Conduct
• 1995 to 2004

• Nature of Business
• Sale of scrap metal by SSI International Far East, Ltd. (“SSI Korea”), a wholly-owned South Korean subsidiary of Schnitzer Steel Industries, Inc. (“Schnitzer Steel”), a U.S. corporation.

• Influence to be Obtained
• From 1995 to August 2004, Wooh, a former Executive Vice President and head of SSI, conspired with Schnitzer Steel, SSI, and SSI International Far East, Ltd. (a South Korea‑based wholly‑owned subsidiary of Schnitzer managed by SSI) to make payments to officers and employees of government‑owned customers in China to induce them to purchase scrap metal.  The payments were made to foreign officials primarily in the form of commissions, refunds, and gratuities via off‑book foreign bank accounts.

• Enforcement
• Wooh pleaded guilty to violating the FCPA on June 29, 2007.  On that same day, he also settled related charges brought by the SEC.  Without admitting or denying the allegations of the SEC’s complaint, he agreed to pay approximately $40,000 in disgorgement, interest, and civil penalties. 
  
  On October 14, 2011, before a sentence was imposed, the DOJ moved to dismiss the criminal information against Wooh, citing “prosecutorial discretion in the interests of justice and the efficient use of government resources.”  That motion was granted on October 17, 2011.

• Amount of the Value
• $204, 537 (foreign officials) and $1,683,672 (private parties).

• Amount of Business Related to Payment
• Gross revenue of $96,396,740 and profits of $6,259,104 from government entities.

• Intermediary
• None

• Citizenship of Parent Entity
• United States

• Compliance Monitor
• No

• Reporting Requirements
• No

• Case is Pending?
• No

• Related Enforcement Actions
• SEC v. Si Chan Wooh (D. Or. 2007)
  United States v. SSI Int’l Far East, Ltd. (D. Or. 2006)
  In re Schnitzer Steel Industries, Inc. (2006)
  In the Matter of Schnitzer Steel Industries, Inc. (2006) 
  

Si Chan Wooh 

• Citation

• Date Filed
• 06/26/2007

• Filed Under Seal
• No

• FCPA Statutory Provision
• • Conspiracy: Anti-Bribery

• Other Statutory Provision
• None

• Disposition
• Plea Agreement, Plea Agreement

• Defendant Jurisdictional Basis
• Conspiracy

• Defendant's Citizenship
• United States