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We asked ChatGPT Again

What is ChatGPT?:

“ChatGPT is an artificial-intelligence chatbot developed by OpenAI and launched in November 2022. It is built on top of OpenAI’s GPT-3.5 and GPT-4 families of large language models and has been fine-tuned using both supervised and reinforcement learning techniques” (Wikipedia).

UN Bribery and Money Laundering Networks

Since 2015 a number of bribery and money laundering networks were identified by the U.S. Department of Justice operating at the United Nations, resulting in arrests and criminal trials. In one case, an appeal reached the U.S. Supreme Court. Here is what ChatGPT has to say about convicted bad actors in these networks.

On the Patrick Ho network:

“Title: The Patrick Ho Bribery Network at the United Nations: An In-depth Analysis

Introduction:

The Patrick Ho bribery network at the United Nations (UN) represents a complex web of corruption and illicit activities that operated within the realm of international diplomacy. Led by Patrick Ho, a former Hong Kong government official and the head of a prominent non-profit organization, the network aimed to influence UN officials and advance the interests of specific individuals and entities. This essay delves into the inner workings of the network and provides an ordered list of key actors involved.

I. Background of Patrick Ho and the Bribery Network:

Patrick Ho, the former Secretary for Home Affairs of Hong Kong, rose to prominence as the Deputy Chairman and Secretary-General of the China Energy Fund Committee (CEFC), a non-profit organization with strong ties to the Chinese government. The CEFC presented itself as a platform for international cooperation and development but, in reality, served as a conduit for Patrick Ho’s corrupt activities.

II. The Modus Operandi of the Bribery Network:

The Patrick Ho bribery network employed various tactics to achieve its objectives. These tactics typically involved bribery, money laundering, and the provision of illicit financial benefits to UN officials and other influential individuals. The following steps outline the modus operandi:

  1. Identification of Targets: The network strategically targeted UN officials who held significant decision-making power or influence over key issues. This included officials from countries of interest to the network’s objectives.
  2. Establishing Relationships: Through intermediaries and personal connections, the network established relationships with the targeted UN officials. These relationships often involved exploiting personal or professional vulnerabilities, such as financial difficulties or the promise of career advancement.
  3. Offering Bribes and Illicit Financial Benefits: The network would offer bribes, kickbacks, or other illicit financial benefits to the targeted UN officials. These benefits could include cash payments, luxury goods, travel expenses, or even shares in lucrative business ventures.
  4. Influencing Decision-making: Once the network successfully established a relationship with a UN official, it would seek to influence the official’s decision-making processes. This could involve swaying votes, advocating for specific policies, or providing confidential information to advance the network’s interests.
  5. Concealing Illicit Transactions: The bribery network employed sophisticated money laundering techniques to conceal the illicit origins and transfers of funds. These techniques included the use of shell companies, offshore bank accounts, and complex financial transactions across multiple jurisdictions.

III. Key Bad Actors in the Patrick Ho Bribery Network:

  1. Patrick Ho: As the mastermind behind the network, Patrick Ho orchestrated its operations and served as the primary point of contact for UN officials. He utilized his position at the CEFC and his personal connections to facilitate bribery and exert influence within the UN system.
  2. CEFC China Energy Company Limited: The CEFC, under Patrick Ho’s leadership, played a central role in funding the network’s activities. The company provided financial resources and logistical support for bribery schemes, enabling Ho to carry out his illicit operations effectively.
  3. Intermediaries and Facilitators: The network relied on a network of intermediaries and facilitators to establish connections with targeted UN officials. These individuals acted as liaisons, coordinating meetings, arranging payments, and maintaining communication channels between the network and its targets.
  4. Corrupt UN Officials: The bribery network involved several UN officials who willingly participated in illicit activities in exchange for personal gain. These officials abused their positions of trust, compromising the integrity and impartiality of the UN system.

IV. Investigation, Arrest, and Legal Consequences:

In 2017, Patrick Ho was arrested in the United States on charges of bribery and money laundering related to his activities within the UN. Following an extensive investigation, evidence of the network’s operations …”

On the Ng Lap Seng network:

“Title: The Ng Lap Seng Bribery Network at the United Nations: An In-depth Analysis

Introduction:

The Ng Lap Seng bribery network at the United Nations (UN) represents a far-reaching scheme of corruption and illicit activities aimed at influencing UN officials and advancing personal interests. Led by Ng Lap Seng, a wealthy Chinese billionaire and philanthropist, the network operated within the complex realm of international diplomacy. This essay provides a comprehensive examination of the inner workings of the network and presents an ordered list of key actors involved.

I. Background of Ng Lap Seng and the Bribery Network:

Ng Lap Seng, a prominent figure in the business world, amassed significant wealth through his ventures in real estate and international trade. As the Chairman of Sun Kian Ip Group, he sought to leverage his financial resources and influence to advance his personal agenda within the UN.

II. The Modus Operandi of the Bribery Network:

The Ng Lap Seng bribery network employed a range of tactics to achieve its objectives, including bribery, money laundering, and the provision of illicit financial benefits. The following steps outline the modus operandi:

  1. Identifying Targeted UN Officials: The network strategically identified UN officials who held key decision-making positions or had influence over critical matters. These officials were often from countries or departments of interest to the network.
  2. Establishing Relationships and Exploiting Vulnerabilities: Through intermediaries, personal connections, and various social engagements, the network sought to establish relationships with the targeted UN officials. They exploited personal or professional vulnerabilities, such as financial difficulties, to gain their cooperation.
  3. Offering Bribery and Financial Benefits: The network would offer bribes, kickbacks, or other illicit financial benefits to the targeted UN officials. These benefits could range from cash payments, luxury gifts, expensive trips, to investment opportunities in lucrative business ventures.
  4. Influencing Decision-making and Policy: Once a relationship was established, the network sought to influence the decision-making processes and policies within the UN. This involved manipulating votes, advocating for specific agendas, and providing insider information to further their own interests.
  5. Concealing Illicit Transactions: The bribery network employed sophisticated money laundering techniques to conceal the origins and transfers of illicit funds. This included the use of shell companies, offshore bank accounts, complex financial transactions, and networks of intermediaries to obscure the paper trail.

III. Key Bad Actors in the Ng Lap Seng Bribery Network:

  1. Ng Lap Seng: As the mastermind of the bribery network, Ng Lap Seng orchestrated its operations and provided the necessary financial resources. He utilized his wealth, connections, and philanthropic endeavors to establish influence within the UN and carry out his corrupt activities.
  2. Jeff Yin: Jeff Yin, a business associate of Ng Lap Seng, acted as a key facilitator within the network. He helped establish relationships with targeted UN officials, coordinated meetings and payments, and played a crucial role in executing bribery schemes on behalf of Ng Lap Seng.
  3. John Ashe: John Ashe, a former President of the UN General Assembly, played a central role in the bribery network. He accepted bribes from Ng Lap Seng and his associates in exchange for advancing their interests within the UN. Ashe abused his position of power to manipulate decision-making processes and facilitate corruption.
  4. Francis Lorenzo: Francis Lorenzo, the Deputy Permanent Representative of the Dominican Republic to the UN, was another key actor within the network. He acted as an intermediary, facilitating bribes and providing assistance in influencing UN officials. Lorenzo used his diplomatic status to further the network’s agenda.
  5. Sheri Yan: Sheri Yan, the CEO of Global Sustainability Foundation (GSF), played a significant role in the bribery network. GSF acted …”

On New York-based South-South News (funded and founded by Ng Lap Seng):

“Title: The Role of South-South News in Facilitating Ng Lap Seng’s Bribery and Money Laundering Network

Introduction:

South-South News, a news service founded by Ng Lap Seng in 2010, served as a crucial tool in facilitating his bribery and money laundering network within the United Nations (UN) and beyond. This essay explores the ways in which South-South News was utilized to advance Ng Lap Seng’s illicit activities, including bribery schemes and the concealment of funds.

I. Establishing Credibility and Influence:

  1. Ng Lap Seng’s Vision: Ng Lap Seng envisioned South-South News as a platform to promote cooperation and development among countries in the Global South. By presenting it as a reputable news service, he aimed to establish credibility and gain influence within the international community.
  2. Garnering Access to UN Officials: South-South News positioned itself as an organization dedicated to reporting on UN affairs, allowing Ng Lap Seng and his associates to gain proximity to UN officials. They leveraged the news service to foster relationships, identify potential targets, and exploit vulnerabilities for their bribery schemes.

II. Manipulating News Coverage:

  1. Shaping the Narrative: Ng Lap Seng and his network utilized South-South News to shape the narrative surrounding certain issues and individuals within the UN. By controlling the content and tone of news articles, they aimed to influence public opinion and sway decision-making processes in their favor.
  2. Positive Coverage for Targeted Officials: South-South News provided favorable coverage to targeted UN officials who were part of Ng Lap Seng’s bribery network. This positive portrayal aimed to enhance their reputation, deflect suspicion, and maintain their cooperation in furthering Ng Lap Seng’s interests.

III. Channeling Bribery Funds:

  1. Concealing Illicit Transactions: South-South News acted as a conduit for channeling bribery funds and facilitating money laundering activities. Ng Lap Seng and his associates used the news service’s financial infrastructure to transfer funds discreetly and obscure the origins of illicit transactions.
  2. Payments Disguised as Media Services: Bribe payments were often disguised as legitimate media services, such as advertising or sponsorships, provided by South-South News. By issuing invoices and receipts for these services, the network could legitimize the movement of funds and create a semblance of a genuine business transaction.

IV. Expanding the Network’s Reach:

  1. Extending Influence Beyond the UN: South-South News allowed Ng Lap Seng’s bribery network to extend its influence beyond the UN. The news service provided a platform for networking and establishing connections with government officials, business leaders, and influential individuals from various countries, thereby expanding the network’s reach and potential for corruption.
  2. Securing Political Support: Ng Lap Seng strategically utilized South-South News to secure political support for his initiatives. By showcasing favorable coverage and highlighting the accomplishments of politicians sympathetic to his cause, he aimed to garner political backing and protect his network’s operations from scrutiny.

V. Legal Consequences and Exposure:

  1. Arrest and Investigation: Ng Lap Seng’s involvement with South-South News and its role in facilitating corruption came under scrutiny, leading to his arrest in 2015. Authorities launched investigations into the network’s operations, exposing the extent of bribery, money laundering, and illicit activities conducted through the news service.
  2. Legal Accountability: Ng Lap Seng and his associates were prosecuted for their involvement in bribery and money laundering. The exposure of South-South News as a tool for facilitating corruption contributed to the legal consequences faced by the individuals involved in Ng Lap Seng’s network.

Conclusion:

South-South News, founded by Ng Lap Seng, played a pivotal role in facilitating his bribery and money … “

Creative Commons License

This work is licensed under a
Creative Commons Attribution-Noncommercial-No Derivative Works 3.0 License.

ORCID iD: https://orcid.org/0000-0001-5311-1052.

© David South Consulting 2023

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Anti-bribery Website in India Inspires Others

By David SouthDevelopment Challenges, South-South Solutions

SOUTH-SOUTH CASE STUDY

An Indian website tackling corruption has been so successful it has inspired a wave of followers in China.

The I Paid a Bribe website – motto: “Uncover the Market Price of Corruption” – was set up by the Janaagraha Centre for Citizenship and Democracy (http://www.janaagraha.org), a non-profit organisation based in Bangalore, India.

Janaagraha is dedicated to working with government and citizens to “improve the quality of life in Indian cities and towns,” according to its website.

Janaagraha’s initiatives strive “to make government departments transparent and accountable,” and the ipaidabribe programme (http://www.ipaidabribe.com) fits in with that goal. It seeks to harness the collective voices of the citizens to report and quantify incidents of corruption. The website will help to paint a picture of the level of corruption in cities and help the NGO in its fight to improve government oversight systems and procedures and to improve law enforcement and adherence to regulations.

The website tackles the “pernicious effect of corruption on destroying city life and disempowering citizens,” according to Raghunandan Thoniparambil, the site’s programme coordinator. “The original idea was that the website could become a simple means of tracking the market price of corruption – a kind of price prediction mechanism.”

He said the original idea was tongue in cheek and propelled by cynicism – but the site’s creators soon realized that “such an effort was indeed a very powerful one.”

The website displays reports and analytics on bribe patterns by city and by transaction amounts, frequency and averages.

The long-term goal is to reduce corruption faced by Indians when they use government services. The website asks users to log both recent and past incidences of bribery. It says: “Please tell us if you resisted a demand for a bribe, or did not have to pay a bribe, because of a new procedure or an honest official who helped you. We do not ask for your name or phone details, so feel free to report on the formats provided.”

Neither accusers nor accused are identified by name – only the incidents are logged. The website is funded by a grant of US $3 million and the NGO is planning to launch a mobile phone application as well.

The website doesn’t pursue individuals because it has found this approach is a distraction to getting systemic improvements by government.

“By not allowing names to be published, we have eliminated any incentive for any individual to make a false or malicious complaint,” said Thoniparambil. “Since nobody will gain anything by reporting a false complaint on our site because we do not act on complaints, we expect that the stories on the site are true.”

The site has been so popular it has spawned imitators in China and elsewhere. Thoniparambil said Janaagraha has been approached by civil society organisations in 13 countries about collaborating.

After a story was published in the Beijing News about I Paid a Bribe, a flurry of ‘tips’ and accusations flooded the Internet in China, and people set up similar websites to gather information on bribery and corruption in their country. One web developer called “Peater Q” set up a Chinese version of I Paid a Bribe, calling it wohuilule.com. Another two websites that popped up included “I Bribe…” (http://www.wxhwz.com) and http://www.tmzg.org. Some of the dozens of websites have been taken down, but others have received official support and encouragement.

“Peater Q” says he is a young Communist Party member and has received government permission for his site. He says the name of his site, wohuilule.com, is a Chinese translation of “I paid a bribe.”

These are still early days as these websites work out how to balance the need to ferret out corruption and bribery and the need to avoid gossip, rumour and slander. It is clear the damage done to a country when corruption and bribery get out of control is significant.

The United Nations’ Global Compact on anti-corruption calls it “one of the world’s greatest challenges.”

A report by the Carnegie Endowment for International Peace on Chinese corruption (http://carnegieendowment.org/2007/10/09/corruption-threatens-china-s-future/g4) found it threatens the country’s future by increasing socioeconomic inequality and social unrest. The report found 10 percent of government spending, contracts, and transactions goes to kickbacks and bribes, or is simply stolen. It also found the indirect costs of corruption to include efficiency losses, waste and damage to the environment, public health, education, credibility and morale.

“Corruption both undermines social stability (sparking tens of thousands of protests each year), and contributes to China’s environmental degradation, deterioration of social services, and the rising cost of health care, housing, and education,” the report said.

I Paid a Bribe is being used to build up an intelligent picture of corruption and bribery in India so that real change can be made.

“Citizens’ reports on the nature, number, pattern, types, locations and frequency of actual corrupt acts and values of bribes will add up to a valuable knowledge bank that will contribute to a reduction in bribe payments,” Thoniparambil said.

Not only does the website raise awareness about the problem and its dynamics, it maps out the path corruption takes through a public service. This, the website hopes, will enable better “more consistent standards of law enforcement and better vigilance and regulation.”

“We believe that every citizen who reports a story on our website about paying a bribe is angry enough to begin to resist it,” explains Thoniparambil.

“Except for using the data that we receive for further analysis, we will not take the complaints and stories forward. We do not intend to invoke the courts.”

But these websites need to be run with caution and care and they do have their critics.

“If you wanted to tarnish the reputation of the government or a department within it, or settle a vendetta, you could just get all of your friends to post claims against them,” Raymond Fisman, a professor at Columbia Business School who has studied corruption, told the BBC.

“There is no way of credibly aggregating the information to assess the magnitude of the problem,” he added.

Thoniparambil, however, remains positive that corruption and bribery are problems that can be tackled.

“I believe that corruption has grown this big only because as citizens, we have tolerated it,” he explains. “If we actively oppose it and there are enough of us, the government has to buckle down and tackle the problem effectively.

“Corruption may be rampant in India, but it is not endemic,” believes Thoniparambil. “Blaming it on our value systems is a poor alibi with no substance in it. I do not believe that Indians are inherently corrupt; our value systems are as good or as bad as anybody else’s. Corruption is not a social trend that arises out of an erosion of value systems; it is born out of systems failure. Corruption flourishes because we have poorly designed governance systems in the country.”

Thoniparambil sites a number of Indian successes to back up his optimism: competition in telephone service providers has reduced corruption; booking of railway tickets online has taken the power away from corrupt ticket sellers; and government departments have been forced to state how long services will take to complete.

Thoniparambil believes it is about changing the relationship between citizens and the public services they receive.

“We would like citizens to begin to realize that public services are our entitlements,” he says. “These are not favours dispensed from above. They ought not to be pessimistic about corruption. Countries have cleaned up very dramatically and the processes by which it has been done have been documented.

“Reduction of bribery in India will improve access to government services, particularly for the poor, reduce the cost of delivery of such services, speed up business and recourse to legal remedies. It will improve the quality of infrastructure and will be deeply empowering for Indian citizens.”

“It is only the collective energy of people that can turn the tables on the corrupt.”

Published: August 2011

Resources

1) United Nations Global Compact: A website packed with resources on how to tackle corruption and how to network globally with others to tackle corruption. Website:http://www.unglobalcompact.org/Issues/transparency_anticorruption/

2) India Against Corruption: India Against Corruption movement is an expression of collective anger of people of India against corruption. This is their campaign website. Website:http://www.indiaagainstcorruption.org/

Read more about the perils of bribery here: The Strange Saga of “South-South News”

Development Challenges, South-South Solutions was launched as an e-newsletter in 2006 by UNDP’s South-South Cooperation Unit (now the United Nations Office for South-South Cooperation) based in New York, USA. It led on profiling the rise of the global South as an economic powerhouse and was one of the first regular publications to champion the global South’s innovators, entrepreneurs, and pioneers. It tracked the key trends that are now so profoundly reshaping how development is seen and done. This includes the rapid take-up of mobile phones and information technology in the global South (as profiled in the first issue of magazine Southern Innovator), the move to becoming a majority urban world, a growing global innovator culture, and the plethora of solutions being developed in the global South to tackle its problems and improve living conditions and boost human development. The success of the e-newsletter led to the launch of the magazine Southern Innovator. 

Creative Commons License

This work is licensed under a
Creative Commons Attribution-Noncommercial-No Derivative Works 3.0 License.

ORCID iD: https://orcid.org/0000-0001-5311-1052.

© David South Consulting 2022

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Disrupted! Whatever happened to Southern Innovator Issue 6?

Macau News Agency: Audit uncovers trail of ‘support’ (April 24, 2016).

Disrupted!! Issue 6 of Southern Innovator never came about and here is the story of why. One part of the story is very positive and inspiring; the other part is disappointing and frustrating (though always a risk when working in the international realm). 

First, the disappointing and frustrating part. We had been working with the UNOSSC (the funder of Southern Innovator) on a scale-up plan which would provide the funds for the brand to better chronicle the global South innovator culture of the 21st century. What we had not anticipated was various individuals involved with the UNOSSC not only acting in bad faith, but actually being involved with a multinational network to bribe UN officials and launder money into the United States, as was exposed during arrests by US authorities in late 2015 in New York (home of the UNOSSC and the UN’s headquarters). As we found out, gradually, through media coverage and court trial testimonies and confessions under oath by co-conspirators following the arrests, there was a fundamental conflict of interest between the work we were doing and the UNOSSC’s funding relationship with an entity that had its own news agency working out of the United Nations, South-South News. South-South News was established and funded by an Interpol Watch List individual, flagged up as a person not to do business with because of his involvement with human and sex trafficking and international criminal networks. South-South News’ executives pushed for the building of a new “Geneva of Asia” for the UN in Macau, which would also host the UNOSSC’s annual Global South-South Development Expo (GSSD Expo). As confessed by the executives of South-South News, the news agency was established to facilitate bribes to UN officials and launder money into the United States – violating the Foreign Corrupt Practices Act (FCPA). This bribery and corruption case led to the UNOSSC’s budget being suspended pending two internal UN audits.

For the first time, setting a legal precedent, an FCPA case involving bribery and money laundering at the United Nations went all the way to the U.S. Supreme Court. Wrongly, many senior UN officials believe their diplomatic status affords them immunity to legal prosecution, especially under the FCPA. However, this case was a successful enforcement of the FCPA, appealed all the way to the U.S. Supreme Court. The question remains: will future FCPA enforcement actions at the international level test the protection of ‘diplomatic immunity’?

United Nations officials are “foreign officials” under the FCPA

“The FCPA is explicit in defining ‘foreign official’ to include ‘any officer or employee . . . of a public international organization.’ The FCPA defines a public international organization as an organization designated by Executive Order pursuant to Section 1 of the International Organizations Immunities Act (22 U.S.C. § 288) or by Executive order of the President. This includes any ‘public international organization in which the US participates pursuant to any treaty or under the authority of any Act of Congress authorizing such participation or making an appropriation for such participation.’ (22 U.S.C. § 288). For instance, The UN was declared a public international organization by Executive Order 9698 in 1946.”

Criminal Accountability of United Nations Officials, Experts on Mission Crucial When Administering Justice, Combating Impunity, Sixth Committee Hears

When the UNOSSC eventually re-booted in 2016/2017, Southern Innovator was not included in its programming budget. You can read more about this case here: http://www.davidsouthconsulting.com/blog/2018/3/4/the-strange-saga-of-south-south-news-may-2018.html

Read more on this case from the Supreme Court of the United States here:

Read more on this case from the U.S. Department of Justice here: https://www.justice.gov/criminal-fraud/fcpa/cases/ng-lap-seng

Executives of the UNOSSC audited by UNDP in 2016: Yiping Zhou, Inyang Ebong-Harstrup, Adam Rogers.

‘Jacked! | The Taking Of The American Order

A selection of books covering the bribery and money laundering network targeting the United Nations from 2010 to 2015:  From Baksheesh to Bribery: Understanding the Global Fight Against Corruption and Graft Edited by T. Markus Funk and Andrew S. Boutros, Oxford University Press, 30 May 2019, Chinese Spies: From Chairman Mao to Xi Jinping by Roger Faligot, Hurst, 2019, Historical Dictionary of Chinese Intelligence by I. C. SmithNigel West, Rowman & Littlefield Publishers, 5 February 2021, ONU: la grande imposture by Pauline Liétar, Albin Michel, 4 October 2017, Organized Crime and Corruption Across Borders: Exploring the Belt and Road Initiative Edited ByT. Wing Lo,Dina SiegelSharon Kwok, Routledge, 1 April 2021.
Books covering the 2015 United Nations SDGs bribery scandal: ONU: La Grande Imposture, Organized Crime and Corruption Across Borders, New Humanitarianism and the Crisis of Charity: Good Intensions on the Road to Help, Historical Dictionary of Chinese Intelligence.
Journalists and scholars alike have probed deep into the criminogenic networks across the global South. Crime and Development in the Global South by Jarrett Blaustein, Graham Ellison, Nathan Pino, The Palgrave Handbook of Criminology and the Global South, January 2018, Criminology and the UN Sustainable Development Goals: The Need for Support and Critique by Jarrett Blaustein, Nathan W Pino, Kate Fitz-Gibbon, Rob White, The British Journal of Criminology, Volume 58, Issue 4, July 2018,
Corruption in the Global Era: Causes, Sources and Forms of Manifestation edited by Lorenzo Pasculli and Nicholas Ryder, Taylor & Francis, 2019, Who Blunders and How: The Dumb Side of the Corporate World by Robin Banerjee, Sage Publications, 2019,
Wilful Blindness: How a Network of Narcos, Tycoons and CCP Agents Infiltrated the West by Sam Cooper, Optimum Publishing International, May 2021.

And now the positive and inspiring part: Southern Innovator evolved from the e-newsletter Development Challenges, South-South Solutions, first launched in 2006 (and we came on board to research and write stories in 2007). Much has happened since, including the Global Financial Crisis, and the global financial system re-boot that occurred afterwords. Both the e-newsletter and the magazine Southern Innovator fall into the category of ‘crisis media’: media used to bring together a response where the old methods and methodologies no longer work and something has caused system failure. Back in 2007, there was little discussion in the media about the global South, innovation, innovators, social entrepreneurship, and the mobile and information technology revolution occurring in the global South. Both the e-newsletter and the magazine identified a global 21st-century innovator culture that was unique since it was being fuelled by the rapid adoption of mobile and information technologies, often in places with high levels of poverty and turmoil.

According to the Final evaluation of the performance of the United Nations Office for South-South Cooperation under its strategic framework, 2014-2017, in light of the adoption of the 2030 Agenda for Sustainable Development, prepared by Marcia Brewster, Consultant for the United Nations Office for South-South Cooperation (UNOSSC): 

“The reviewer observed that, although the Policy and UN Coordination Unit had produced all of the reports requested by intergovernmental bodies, especially for the High-level Committee, it had not been able to produce many of the publications (evidence-based analytical reports) that had previously been within its purview. Such publications included Southern Innovator magazine and the monthly e-newsletter “Development Challenges, South-South Solutions. In the case of Southern Innovator, one issue (No. 5 on waste and recycling) was published during the four-year period of the framework but did not have wide online distribution, and issue No. 6 was awaiting funds for publication. The e-newsletter was last issued in July 2014 even though the reviewer found it a good way to communicate with focal points at the national and inter-agency levels. In fact, the shortage of funds for those knowledge products was the main reason that they had ceased being produced during the evaluation period.”

“With respect to the analytical reports previously produced by the Office, such as Southern Innovator, they have not been produced in recent years owing to lack of funding.” 

From the beginning, the e-newsletter and magazine were about changing perspectives and inspiring action. And so they have. Rather than say so in my words, I shall offer the words of others as we received them: 

“Great economic and business reporting! Very helpful for us.”Africa RenewalAfrica Section, Strategic Communications Division, United Nations Department of Public Information

“I just went over your June newsletter. It’s very well done and far reaching. Congratulations!” Violette Ruppanner, Director, 3D -> Trade – Human Rights – Equitable Economy, Geneva, Switzerland

“Just to let you know I enjoyed the newsletter a lot – it was interesting to learn about things going on that I would never otherwise find out about, and also the listing of future conferences and events proved very useful.” Ian Sanderson, Deloitte, Geneva, Switzerland

“Congratulations on another great newsletter that’s packed with fascinating information! I really enjoy getting it each month.” Whitney Harrelson, Making Cents, Washington D.C.

Blogger Taline Haytayan from Brighton, England, found a case study on story telling in the South particularly interesting: “I came across this interesting article entitled ‘The South Has a Good Story to Tell’, which talks about storytelling in developing countries, and its use as a critical tool for passing on history, while teaching morals and ethics – so I would like to share it here with you. It’s a nice surprise to see that this article appears in UNDP’s South to South Cooperation unit newsletter. It gives an overview of storytelling in a number of countries, such as the movement of urban storytellers in Colombia, inspired by Italo Calvino; tale-spinners in Argentina; the halakis, or storytelling sages, of Morocco; and digital storytelling by women in South Africa.” (http://talinita.blogspot.com/2008/05/south-has-good-story-to-tell.html)

“A few weeks ago, David South, Development consultant and author of UNDPs Development Challenges, South-South Solutions Newsletter, came by the betterplace office to take a look at our work. When I asked him how he had come about betterplace.org, he answered: he found me on twitter! So much for the twitter-scepticts.” Joana Breidenbach, betterplace.org, Berlin, Germany (http://blog.betterplace.org/en/2009/09/15/690/)

“This is a WONDERFUL site. I read–and at least bookmarked to read again–your stories with the photo of the homeless gentleman “will write HTML code for food,” and of the young African girl who was hungry, and how they are predicting (and it seems inevitable) famine an a high voltage bolt in the poverty percentages. … your writing is phenomenal–the few stories that I have seen are actually SUPERIOR in their professional, technical, and relevant accounts. Their VERY interesting, and I unfortunately have not seen other sources of news lately (other than from my school’s library database, and old Public Broadcasting documentaries). God has blessed your works, and I am thankfully blessed by them!”  Sincerely, J. (Au) Whi, (from NowPublic site)

“Many thanks for sending me a copy of your interesting work. I read just one article in Spanish thus far but found it well written and useful. For us here in Colombia, it will be most useful having regular access to your publication and, of course, I am pleased that the articles are in Spanish as well as French and English. I hope that one day I might invite you to take a closer look at the Arranque Automático operation in Colombia and perhaps invite you to do a write-up on the technique and its ample theoretical foundations.”  David Cuanespero Boriol, Colombia

“What a tremendous magazine your team has produced! It’s a terrific tour de force of what is interesting, cutting edge and relevant in the global mobile/ICT space… Really looking forward to what you produce in issues #2 and #3. This is great, engaging, relevant and topical stuff.” Rose Shuman, Founder & CEO, Open Mind and Question Box

“Question Box was featured in Southern Innovator, a new publication of UNDP that profiles some of the most innovative ideas coming out of the global South. We were pleased to see many friends in the sector profiled as well, such as UshahidiMedic Mobile, and TxtEagle. Take a look at the magazine, as it is a great primer on ICT and mobile innovation from around the globe.” Question Box News

“Looks great. Congratulations. It’s Brill’s Content for the 21st century!” Conan Tobias, Managing Editor, Canadian Business

What they are saying about SI on Twitter: From @CapacityPlus Nice job RT @ActevisCGroup: RT @UNDP: Great looking informative @SouthSouth1 mag on South-South Innovation; @UNDP Great looking informative @SouthSouth1 mag on South-South Innovation; @JeannineLemaireGraphically beautiful & informative @UNDP Southern Innovator mag on South-South Innov. 

And on Pinterest:Peggy Lee • 1 year ago 

“Beautiful, inspiring magazine from UNDP on South-South innovation. Heart is pumping adrenaline and admiration just reading it”

“Thank you David – Your insight into the issues facing us a[s] [a] “global Village” is made real in the detail of your article – 10 out of 10 from the moladi team.” Moladi, South Africa (http://www.moladi.net/index.htm)

“I liked your latest Southern innovator! Always inspiring.” Joana Breidenbach, betterplace.org, Berlin, Germany

“The magazine looks fantastic, great content and a beautiful design!”

“Btw, I really enjoyed reading them, impressive work & a great resource. Looking forward to Issue 6. My best wishes to you & your team at SI.”

“… great magazine, nice design.”

2014 proved a significant year for our work, as Southern Innovator is cited in various strategy documents as a resource contributing to a shift in funding priorities at the United Nations and other international development funders, and the adoption of South-South innovation as a key part of the UN’s work. The e-newsletter and magazine are also cited in many papers and books and are clearly contributing to a better understanding of the 21st-century global South innovator culture.  

By 2015, Southern Innovator was still drawing praise for its timely resources on South-South innovation and innovators:

“@SouthSouth1 is one of the best sources out there for news and info on #solutions to #SouthSouth challenges.” Adam Rogers, Assistant Director, Regional Representative, Europe, United Nations Office for South-South Cooperation (UNOSSC) 

This work is licensed under a Creative Commons Attribution 4.0 International License.

ORCID iD: https://orcid.org/0000-0001-5311-1052.

© David South Consulting 2021

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Hijacked! | The Taking of the American Order

“We will be asking: is bribery business as usual at the UN?”, US Attorney Preet Bharara, October 2015

“If proven, today’s charges will confirm that the cancer of corruption that plagues too many local and state governments infects the United Nations as well.”, US Attorney Preet Bharara, October 2015

“Corruption at any level of government undermines the rule of law and cannot be tolerated. But corruption is especially corrosive when it occurs at an international body like the United Nations. By paying bribes to two U.N. ambassadors to advance his interest in obtaining formal support for the Macau conference center project, Ng Lap Seng tried to manipulate the functions of the United Nations. The sentence handed down today demonstrates that those who engage in corruption will pay a heavy price and serves as a reminder that no one stands above the law.”, Acting Assistant General John P. Cronan, May 2018

“It is important to send a message, to the people at the UN itself and to other institutions in this country, that perverting the decision-making or attempting to pervert the decision-making through bribes will not be tolerated.”, US District Judge Vernon Broderick, May 2018

It first came to light in 2015. Arrests by the FBI (Federal Bureau of Investigation) in New York – steps away from the headquarters of the United Nations – began a journey of discovery that led to a remarkable story of global order and power upended. Since World War II one country alone reigned supreme over the global economy and the rules and norms that underpinned it: the United States.

In this brief taster, I will flesh out what I have learned to date, framing it in the context of the post-WWII global order.

Oh, what a tangled web we weave, when first we practice to deceive!” (Sir Walter Scott, 1808)

“We lead double lives. We deal in sex and beautiful women,” Burke’s Law, ‘Who Killed Alex Debbs?’, Episode aired 25 October 1963

Chapter One

The Strange Saga of ‘South-South News’ https://davidsouthconsulting.org/the-strange-saga-of-south-south-news/

It is a story that has it all: the gambling sin-bin of Macau, human and sex trafficking, bribery, corruption, money laundering, spies, and, if they are to be believed, naive UN officials hiding behind their laissez-passer passports who knew nothing about all of this but were happy to take the money for a five-star conference and a trip to China (and a free iPad). How the UN ended up in this quagmire leaves many puzzled and perplexed. Then there is a so-called “21st century” media service that really is a “conduit” for bribery and money laundering (and possibly fake news), and who to this day is still reporting from the United Nations.

May 2018 saw the ending of one chapter in the ongoing corruption saga surrounding the executives of South-South News and their alleged bribery and money laundering conduit targeting the United Nations (UN). On 11 May 2018 Ng Lap Seng was sentenced to 4 years in prison for being the ring leader of an elaborate, multi-year, multinational scheme to bribe UN officials and launder money into the United States.

On 28 February 2018 Jeff Yin received a seven-month prison sentence related to the corruption scandal that first erupted in September 2015, with the arrests in New York (home of the UN’s global headquarters) of his boss, Macau casino owner and businessman Ng Lap Seng and assistant, Yin, by the FBI (Federal Bureau of Investigation). Foreign Policy called the case one of “The Worst Corruption Scandals of 2015”. Read the US Justice Department Docket here: https://www.justice.gov/criminal-fraud/fcpa/cases/ng-lap-seng-and-jeff-c-yin.

The US Attorney for the Southern District of New York at the time, Preet Bharara, released a flowchart showing how the alleged bribery scheme targeting the United Nations worked. A series of court trials followed for the various co-conspirators, including senior executives and board members for South-South News, culminating in the 27 July 2017 conviction of the alleged ring leader of the scheme, Macau casino billionaire Ng Lap Seng, on six counts “for his role in a scheme to bribe United Nations ambassadors to obtain support to build a conference center in Macau that would host, among other events, the annual United Nations Global South-South Development Expo“. He used the news service South-South News as a “conduit for bribery and money laundering” at the United Nations, according to the FBI, something admitted to by various co-conspirators in court and under oath.

“South-South staff found him to be ‘humble, very happy to host a meeting and become closer to the U.N.,’ said Inyang Ebong-Harstrup, deputy director of the United Nations Office for South-South Cooperation, a division of the U.N., who met Mr. Ng in August when she traveled to Macau.” The Wall Street Journal (9 October 2015)

Foreign Policy called the case one of “The Worst Corruption Scandals of 2015”.

In March 2015 UNOSSC Director Yiping Zhou (left) signed a cooperation agreement with the Sun Kian Ip Group of Macau to “set up a multi-partner trust fund to promote the cause of South-South Cooperation” (https://usanewsonline.com/2015/03/07/south-south-cooperation-and-chinese-sun-kian-ip-group-signs-cooperation-agreement/). In April 2015 UNOSSC Deputy Director Inyang Ebong-Harstrup (middle) met with the Chairman of the Sun Kian Ip Group, Ng Lap Seng, in Macau (https://www.wsj.com/articles/u-n-team-had-cleared-group-at-center-of-bribery-case-1444432560). “Adam Rogers (right), an assistant director at the UN Office for South-South Cooperation [UNOSSC], said Ng made hosting that UN event possible.” (http://www.uniindia.com/us-charges-expected-in-un-corruption-probe-involving-macau-developer-source/international/news/225908.html). Sources: Statement Concerning the United Nations Office for South-South Cooperation, UNDP (May 5, 2016); United Nations Audit Raises Red Flag: Graft. Complimentary travel and free iPads. And moving project goalposts., Macau Business Daily, April 25, 2016.

Subsequent Roles

Yiping Zhou: Special Envoy of Director General of the World Women Organization/Chief Advisor of the WWO

Inyang Ebong-Harstrup: Chief of Partnerships, ID 2020

Adam Rogers: Board Member, ConnectAID

UNDP’s Office of Audit and Investigation (OAI) recently published an Audit of UNOSSC which rated the Office ‘unsatisfactory’. The Audit makes 16 recommendations with the objective of improving UNOSSC’s effectiveness in the areas of: governance; programme and project activities; and operations.

US District Judge Vernon Broderick: “there was substantial damage done to the UN itself and the image of the UN”.

Read more from Canada’s CBC News: UN internal audit uncovers lapses tied to bribery scandal | Report highlights the need for greater transparency within the United Nations, officials say

“The United Nations’ internal investigations office has uncovered serious lapses and due-diligence failures in the world body’s interaction with organizations tied to an alleged bribery scheme involving a former UN General Assembly president.

The 21-page confidential report by the UN Office of Internal Oversight Services’ (OIOS), reviewed by Reuters, outlines the results of an audit ordered by Secretary General Ban Ki-moon in response to charges against John Ashe, General Assembly president in 2013-2014, and six other people. …

It noted “important deficiencies” in the way United Nations and its staff interacted with non-governmental organizations (NGOs) and oversees UN employees.

It is the biggest financial corruption crisis to rock the United Nations since the Oil-for-Food scandal hit the world body during the tenure of Ban’s predecessor Kofi Annan.” 

Chapter Two: Sustainable Bribery Goals

Chapter Three: Mr Rogers’ ‘Neighborhood’

The Networks

Network 1

Source: The Age, NOVEMBER 11, 2018.

Network 2

Source: The Wall Street Journal, Nov. 23, 2018. “Bribery Trial Spotlights China’s ‘Belt and Road’: Justice Department prosecutes pitchman for company key to Beijing’s global program”.

Network 3

Network More?

(Sources: Department of Justice, Federal Bureau of Investigation, Supreme Court of the United States)

Chapter Four: I Spy with My Little Eye

Chapter Five: America’s “Bitch” or China’s “Partner”?

Chapter Nine: Pax Chaotica

Pax Chaotica: A Re-evaluation of Post-WWII Economic and Political Order

Chapter Ten: War, Peace & Development

War, Peace And Development | May 2018

Many books now chronicle the multiple facets of the bribery and money laundering network targeting the United Nations from 2010 via South-South News and other entities. From Baksheesh to Bribery: Understanding the Global Fight Against Corruption and Graft Edited by T. Markus Funk and Andrew S. Boutros, Oxford University Press, 30 May 2019, Chinese Spies: From Chairman Mao to Xi Jinping by Roger Faligot, Hurst, 2019, Historical Dictionary of Chinese Intelligence by I. C. SmithNigel West, Rowman & Littlefield Publishers, 5 February 2021, ONU: la grande imposture by Pauline Liétar, Albin Michel, 4 October 2017, Organized Crime and Corruption Across Borders: Exploring the Belt and Road Initiative Edited ByT. Wing Lo,Dina SiegelSharon Kwok, Routledge, 1 April 2021.
Books covering the 2015 United Nations SDGs bribery scandal: ONU: La Grande Imposture, Organized Crime and Corruption Across Borders, New Humanitarianism and the Crisis of Charity: Good Intensions on the Road to Help, Historical Dictionary of Chinese Intelligence.

Further Reading

Books

From Baksheesh to Bribery: Understanding the Global Fight Against Corruption and Graft Edited by T. Markus Funk and Andrew S. Boutros, Oxford University Press, 30 May 2019

Blood Brothers: The Criminal Underworld of Asia by B. Lintner, Springer, 2016

“From pirates singing Ricky Martin to mob hits carried out with samurai swords, Bertil Lintner offers a fascinating look at organized crime in the Asia Pacific. Both Western and Asian pundits assert that shady deals are an Asian way of life. Some argue that corruption and illicit business ventures – gambling, prostitution, drug trafficking, gun running, oil smuggling – are entrenched parts of the Asian value system. Yet many Asian leaders maintain that their cities are safer than Sydney, Amsterdam, New York, and Los Angeles. Making use of expertise gained from twenty years of living in Asia, Lintner exposes the role crime plays in the countries of the Far East. In Blood Brothers , he takes you inside the criminal fraternities of Asia, examining these networks and their past histories in order to answer one question: How are civil societies all over the world to be protected from the worst excesses of increasingly globalised mobsters?”

Chinese Spies: From Chairman Mao to Xi Jinping by Roger Faligot, Hurst, 2019

Crime and Development in the Global South by Jarrett Blaustein, Graham Ellison, Nathan Pino, The Palgrave Handbook of Criminology and the Global South, January 2018

Criminology and the UN Sustainable Development Goals: The Need for Support and Critique by Jarrett Blaustein, Nathan W Pino, Kate Fitz-Gibbon, Rob White, The British Journal of Criminology, Volume 58, Issue 4, July 2018

Corruption in the Global Era: Causes, Sources and Forms of Manifestation edited by Lorenzo Pasculli and Nicholas Ryder, Taylor & Francis, 2019

“Corruption is a globalising phenomenon. Not only is it rapidly expanding globally but, more significantly, its causes, its means and forms of perpetration and its effects are more and more rooted in the many developments of globalisation. The Panama Papers, the FIFA scandals and the Petrobras case in Brazil are just a few examples of the rapid and alarming globalisation of corrupt practices in recent years. The lack of empirical evidence on corrupt schemes and a still imperfect dialogue between different disciplinary areas and between academic and practitioners hinder our knowledge of corruption as a global phenomenon and slow down the adoption of appropriate policy responses.”

The Foreign Corrupt Practices Act Handbook: A Practical Guide for Multinational General Counsel, Transactional Lawyers and White Collar Criminal Practitioners by Robert W. Tarun, American Bar Association, 2010

Historical Dictionary of Chinese Intelligence by I. C. SmithNigel West, Rowman & Littlefield Publishers, 5 February 2021

The Long Game: China’s Grand Strategy to Displace American Order by Rush Doshi, Oxford University Press, 08 July 2021

This introductory chapter summarizes the book’s argument. It explains that U.S.-China competition is over regional and global order, outlines what Chinese-led order might look like, explores why grand strategy matters and how to study it, and discusses competing views of whether China has a grand strategy. It argues that China has sought to displace America from regional and global order through three sequential “strategies of displacement” pursued at the military, political, and economic levels. The first of these strategies sought to blunt American order regionally, the second sought to build Chinese order regionally, and the third — a strategy of expansion — now seeks to do both globally. The introduction explains that shifts in China’s strategy are profoundly shaped by key events that change its perception of American power.

ONU: la grande imposture by Pauline Liétar, Albin Michel, 4 October 2017

“Au terme d’un long travail d’investigation, la journaliste Pauline Liétar en dévoile les pratiques hallucinantes… et courantes : les soutiens politiques s’achètent, les gaspillages sont légion.”

Organized Crime and Corruption Across Borders: Exploring the Belt and Road Initiative Edited byT. Wing Lo,Dina SiegelSharon Kwok, Routledge, 1 April 2021

Chapter: A hard-boiled Belt and Road Backlash to the UN-Bribes-for-OBOR scandals By Daniel Garrett

The Palgrave Handbook of Criminology and the Global South Edited by Kerry CarringtonMáximo SozzoRussell HoggJohn Scott, 12 January 2018

“The first comprehensive collection of its kind, this handbook addresses the problem of knowledge production in criminology, redressing the global imbalance with an original focus on the Global South. Issues of vital criminological research and policy significance abound in the Global South, with important implications for South/North relations as well as global security and justice. In a world of high speed communication technologies and fluid national borders, empire building has shifted from colonising territories to colonising knowledge. The authors of this volume question whose voices, experiences, and theories are reflected in the discipline, and argue that diversity of discourse is more important now than ever before.   Approaching the subject from a range of historical, theoretical, and social perspectives, this collection promotes the Global South not only as a space for the production of knowledge, but crucially, as a source of innovative research and theory on crime and justice. Wide-ranging in scope and authoritative in theory, this study will appeal to scholars, activists, policy-makers, and students from a wide range of social science disciplines from both the Global North and South, including criminal justice, human rights, and penology.”

Who Blunders and How: The Dumb Side of the Corporate World by Robin Banerjee, Sage Publications, 2019

Wilful Blindness: How a Network of Narcos, Tycoons and CCP Agents Infiltrated the West by Sam Cooper, Optimum Publishing International, May 2021

The role of Ng Lap Seng in the “Vancouver Model” in Canada.
Journalists and scholars alike have probed deep into the criminogenic networks across the global South. Crime and Development in the Global South by Jarrett Blaustein, Graham Ellison, Nathan Pino, The Palgrave Handbook of Criminology and the Global South, January 2018, Criminology and the UN Sustainable Development Goals: The Need for Support and Critique by Jarrett Blaustein, Nathan W Pino, Kate Fitz-Gibbon, Rob White, The British Journal of Criminology, Volume 58, Issue 4, July 2018,
Corruption in the Global Era: Causes, Sources and Forms of Manifestation edited by Lorenzo Pasculli and Nicholas Ryder, Taylor & Francis, 2019, Who Blunders and How: The Dumb Side of the Corporate World by Robin Banerjee, Sage Publications, 2019,
Wilful Blindness: How a Network of Narcos, Tycoons and CCP Agents Infiltrated the West by Sam Cooper, Optimum Publishing International, May 2021.

Media Reports by Month and Year

The Strange Saga of ‘South-South News’ https://davidsouthconsulting.org/the-strange-saga-of-south-south-news/

In the Headlines

Legal Documents

What is the FCPA? “The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (“FCPA”), was enacted for the purpose of making it unlawful for certain classes of persons and entities to make payments to foreign government officials to assist in obtaining or retaining business. Specifically, the anti-bribery provisions of the FCPA prohibit the willful use of the mails or any means of instrumentality of interstate commerce corruptly in furtherance of any offer, payment, promise to pay, or authorization of the payment of money or anything of value to any person, while knowing that all or a portion of such money or thing of value will be offered, given or promised, directly or indirectly, to a foreign official to influence the foreign official in his or her official capacity, induce the foreign official to do or omit to do an act in violation of his or her lawful duty, or to secure any improper advantage in order to assist in obtaining or retaining business for or with, or directing business to, any person.”

The Docket

“As to §666, the Second Circuit
held that the statutory term “organization” covers not
only private organizations, but also quasi-sovereign
public international bodies like the UN
…”

Navigating the Foreign Corrupt Practices Act: The Increasing Cost of Overseas Bribery

“… corrupt payments to officers and employees of public international organizations are prohibited by the FCPA’s anti-bribery provisions. Public international organizations covered by the FCPA include, among others: the United Nations, International Monetary Fund, World Bank, African Development Bank, Asian Development Bank, European Bank for Reconstruction and Development,Inter-American Development Bank,International Maritime Organizations, International Bank for Reconstruction and Development, International Finance Corporation, Multilateral Investment Guarantee Organization,Organization for African Unity,and the Organization of American States.” (Navigating the Foreign Corrupt Practices Act: The Increasing Cost of Overseas Bribery by Robert C. Blume and J. Taylor McConkie)

FCPA Professor: Bribery Involving The United Nations (December 28, 2017)

“The United Nations has a number of anti-corruption initiatives. For starters, there is the United Nations Convention Against Corruption, it hosts the Conference of the States Parties (COSP) (the main policy-making body of the Convention), and the U.N.’s Global Compact states that “businesses should work against corruption in all its forms, including extortion and bribery.”

Instead of looking outward, perhaps the United Nations should look more inward as several Foreign Corrupt Practices Act enforcement actions … have involved U.N. officials or U.N. programs.”

JDSupra: Court to World: Yes, FCPA Is Still Sweeping

“Compliance officers may have seen news of a recent federal appeals court decision that upheld an expansive view of Foreign Corrupt Practices Act enforcement

One said the ruling might be “the tip of the iceberg” that heralds more individuals challenging FCPA enforcement. 

We rarely get appellate court rulings on the scope of the FCPA, so the case spurred numerous headlines. One said the ruling might be “the tip of the iceberg” that heralds more individuals challenging FCPA enforcement. 

For corporate compliance officers running entire programs, however, the case is just more of the same blizzard you’ve been enduring for years – trying to find a steady path forward. 

The case itself, U.S. v. Ng Lap Seng, is straightforward. A Chinese national, David Ng, was a wealthy real estate developer in Macau. In the early 2010s he bribed two United Nations officials by giving them sham consulting contracts worth hundreds of thousands of dollars, in exchange for them trying to convince other U.N. officials to declare one of Ng’s convention centers the permanent home for a lucrative annual development conference. 

Eventually the scheme unraveled, and in 2017 a jury convicted Ng in federal district court of violating the FCPA. 

Ng appealed. He argued that any bribery prosecution must meet the high standards of an “official act” as spelled out in McDonnell v. U.S. — a U.S. Supreme Court ruling from 2016 that addresses cases of domestic bribery of U.S. government officials. Ng wanted that same standard to apply to FCPA cases involving bribery of foreign government officials.

Um, no. The 2nd Circuit Court of Appeals ruled against Ng on Aug. 9, noting that the text of the FCPA defines the quid pro quo of bribery much more expansively than other parts of U.S. law that address domestic bribery. Therefore, the narrow standards of McDonnell don’t apply for FCPA prosecution.”

How to Report Corruption and Bribery at UNDP (United Nations Development Programme)

The Office of Audit and Investigations (OAI) “provides UNDP with effective independent and objective internal oversight that is designed to improve the effectiveness and efficiency of UNDP’s operations in achieving its development goals and objectives through the provision of internal audit and related advisory services, and investigation services.”  

They can be directly emailed here: reportmisconduct@undp.org

Ethics @UNDP

“UNDP’s ethical culture demands that we all hold each other to the same standards of behavior. We expect that if integrity pervades the organization and those who commit misconduct are called to task, the message will become ingrained. The UN is looked upon as the standard bearer for ethical and humanitarian behavior. Our personnel have an obligation to uphold that legacy because individual actions affect UNDP’s image, credibility and reputation.