De volledige verklaring van Charles Blazer

8/9/2019 De volledige verklaring van Charles Blazer

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UNITED STATES DISTRICT

COURT

EASTERN

DISTRICT

OF

NEW YORK

x

UNITED STATES OF AMERICA

I N F 0 R M A T I 0 N

- aga i n s t -

CH RLES

BLAZER,

Defendant .

Cr.

(T.

No . 13-60 2 (RJD)

18, u.s.c.

§§

981

(a) (1)

(C), 982

(a)

(1),

982 (b) ,

134

9, 1956 (h) ,

1962 (d) 1963 1963

(a)

1963(m) and 3551

e t

seq . ;

21, U.S.C . , § 853 (p) ; T. 26,

u.s

.

c.

§

7201;

T .

28

,

U. S .

C. § 2 4 6 l c ) ;

T .

31,

U.S .

C.

§§ 5314 and 5322(b

T.

))

- - - - - - - - - - - - - x

THE

UNITED STATES

TTORNEY

CHARGES:

INTRODUCTION

TO

ALL

COUNTS

At

a l l

t imes

re l evan t

to

t h i s

In format ion , unless

otherwise

i nd ica t ed :

I . The

Ente rp r i se

1 . The Federa t ion In te rna t iona le

de Footba l l

Associa t ion

( FIFA ) and

i t s s i x cons t i tuen t con t inen ta l

confedera t ions - the

Confedera t ion

o f North , Cent ra l American

and

Car ibbean

Associa t ion Foo tba l l ( CONCACAF ),

t h e

Confederac i6n

Sudamericana de Futbol

( CONMEBOL ), the

Union des

Associa t ions Europeennes

de

Footba l l ( UEFA ) , t h e Confederat ion

Afr ica ine

de

Footba l l ( CAF ),

t h e Asian Fo o t b a l l

Confedera t ion


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("AFC

0

)

and

the Oceania

Footba l l Confederat ion ("OFC

0

) -

toge ther with

a f f i l i a t e d

reg iona l

federa t ions ,

na t iona l member

assoc ia t ions and spor t s market ing companies, c o l l e c t i v e l y

cons t i tu ted

an

en te rp r i s e ,

0

as def ined i n T i t le

18,

United

Sta t e s Code, Sec t i o n

1961 4) ,

t h a t

i s ,

a group

of

l ega l

en t i t i e s

assoc ia ted in

f a c t

(he re ina f t e r t he

en te rp r i s e

0

.

The

en t e r p r is e co n s t i t u t ed

an

ongoing

organ iza t ion whose

members

funct ioned as a con t inu ing un i t fo r a common purpose

o f

achieving

the objec t ive s o f the en te rp r i se . The

en t e r p r i s e was

engaged in ,

and

ts

a c t i v i t i e s

a f fec t ed ,

i n t e r s t a t e

and

fo re ign

commerce.

2.

The

pr inc ipa l purpose

of the

en t e r p r i s e was to

regu la t e and promote

t he spor t o f

soccer worldwide. The members

of the

en t e r p r i s e

c a r r i e d out t h i s purpose

by

using

a

var i e ty of

methods

and

means,

inc lud ing

c rea t ing

and

enforc ing

uniform

s tandards

and

ru les ,

organ iz ing

i n t e rna t iona l compet i t ions and

commercia l iz ing

the media and

market ing

r i g h t s

assoc ia t ed with

the spor t . The members of the

en t e r p r i s e ,

as well as

i nd iv idua l s

employed by and

assoc ia t ed

with

the

en te rp r i s e ,

f requen t l y engaged in

banking

and investment a c t i v i t i e s

with

Uni ted Sta tes

f i n an c i a l

i n s t i t u t i ons .

2


3/35

A.

FIFA

3 . FIFA was the i n t e r n a t i o n a l body

governing

organized soccer commonly known

outs ide

the United Sta tes as

foo tba l l .

FIFA was an e n t i t y

r eg i s t e r ed

under

Swiss law and

headquartered in

Zurich,

Switzerland. FIFA

was

composed

of

as

many as 208

member assoc ia t ions each rep re sen t ing

organized

soccer in a

p a r t i c u l a r na t ion o r

t e r r i t o r y

inc lud ing the

United

Sta tes and four

o f

ts overseas t e r r i t o r i e s .

The

United Sta tes

f i r s t became

a f f i l i a t e d with

FIFA

in 1914;

Puer to

Rico

f i r s t

became a f f i l i a t e d with FIFA in

1960,

with

Guam,

American Samoa

and

the United Sta tes

Virg in

Is lands

fo l lowing

s u i t

in

the

1990s.

At var ious t imes

FIFA mainta ined

o f f i c e s both in

Zurich

and

elsewhere

in the world, inc lud ing in

the

United Sta tes

where FIFA has main ta ined

a

development

o ff

i c e s ince

a t

l e a s t

2011.

4 . FIFA'S member assoc ia t ions were a l s o each a

member of one of the s ix con t inen ta l confedera t ions recognized

by

FIFA: CONCACAF

CONMEBOL

UEFA, CAF, AFC and OFC. Since a t

l e a s t 1996,

under

FIFA'S s t a t u t e s

no na t iona

l

soccer

assoc ia t ion cou ld become a member

of

FIFA withou t

f i r s t j o in ing

one

of

the

s i x

con t inen ta l confederat ions . Since

a t

l e a s t

2004,

member

assoc ia t ions

were

requ i red to pay

to FIFA

annual

dues,

known as subscr ip t ions .

3


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5. FIFA was governed by: a congress composed of i t s

member assoc ia t ions

which

ac ted as

the

assoc ia t ion ' s

highes t

l e g i s l a t i ve

body; an execu t ive committee, which

ac ted

as the

execu t ive body; and a genera l s e c r e t a r i a t which ac ted as the

admin i s t ra t ive body.

FIFA

a l so had

a

pre s iden t

who

represen ted

the assoc ia t ion worldwide and was respons ib le fo r t he

implementat ion of dec is ions . FIFA a l so opera ted seve ra l

s tand ing committees,

inc lud ing

a committee

t ha t

organ ized

Olympic soccer

qua l i fy ing tournaments,

whose members

included

soccer

o f f i c i a l s

from

var ious na t iona l member

assoc ia t ions .

FIFA a l so opera ted through a

number of

s u b s id i a r i e s

including

subs id ia r ies t ha t

a s s i s t e d

with FIFA'S media

and

market ing

a c t i v i t i e s .

6.

The

FIFA congress was

composed of de lega tes

from

each

of

ts

member

assoc ia t ions

as wel l as

observers

appoin ted

by each

o f the

confedera t ions . Among o th e r

t h ings the

congress

was respons ib le

f o r

amending FIFA's s t a tu t e s and e lec t ing the

FIFA pres iden t . The congress convened in ord inary

sess ions

b ien n i a l l y o r annual ly and

a t othe r

t imes in

ex t raord ina ry

sess ions

in

var ious count r ies around the

world ,

inc lud ing

the

United Sta tes .

7. The FIFA execu t ive committee, o f t en

r e f e r r ed to

as the

ExCo, was composed of the

FIFA

pre s iden t

and 23

4


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ord inary

members, some

of

whom a l so

held

the titl

vice

pre s iden t . The pres iden t

was

e lec ted

by

the FIFA congress . The

vice pre s iden t s

and

o rd i n a ry members were appoin ted

by

the

confedera t ions . Each

confedera t ion

was

e n t i t l e d

to appoin t a

s p ec i f i c

number

o f

vice p re s iden t s

and o rd i n a ry members, as

s e t

f o r th in

the FIFA s t a tu t e s . Since a t l e a s t

1996,

the

execu t ive

committee was

requ i red

by FIFA s t a t u t e s to meet a t

l e a s t twice

pe r

year .

The

execu t ive

committee

held meet ings

a t

FIFA S

headquar te rs in

Zurich,

as

wel l

as in

var ious coun t r i e s around

the world,

inc luding

the

United Sta t e s

.

8.

Among

othe r du t ies , the execu t ive committee was

respons ib le fo r se l e c t i n g the

host

na t ions

o f

FIFA tournaments ,

including,

among

o ther s ,

the World

Cup,

the Women s

World

Cup,

the

Confederat ions

Cup, the Under

20 World Cup, the

Under-20

Women s

World

Cup,

the

Under

17

World

Cup,

the

Under-17

Women s

World Cup and the Club World Cup.

9 . The World

Cup,

the

s p o r t s premier even t ,

was

a

quadrenn ia l i n t e rn a t i o n a l tournament involving

the

sen io r

na t iona l men s

teams

of 24

and,

beginning in

1998, 32

na t ions .

In se lec t ing

t he hos t na t ion

fo r the

World

Cup,

the

execu t ive

committee

t y p i c a l l y

fol lowed

a process in which bid committees

fo r the competing

na t ions

campaigned fo r votes among the members

of

the execu t ive committee. Following

t h i s

process , and a t


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l e a s t s i x years p r i o r to each World Cup,

the

execu t ive committee

t yp ica l ly

held a vote in which i t s members c a s t

t h e i r

vote v i a

sec re t ba l lo t . The winners , o r host na t ions

fo r

the

World Cups

from 1990

to

2022, as wel l

as

the othe r na t ion

s

t ha t were

st ll

under

cons ide ra t ion by the


a t the

t ime

o f

the vote are

r e f l e c t e d

in the t ab le

below:

World

up

Date

Selected

y the Ex o

Winning

Nation

Other Bidding

Nation Nations

1990

May 19,

1984

I t a l y

Soviet

Union

1994

J u l y

4, 1988

United

Sta t e s

rocc o

Braz i l

1998

J u l y

2,

1992

France Morocco

2002 May 31,

1996 Japan/South

Korea

2006

Ju ly

6,

2000

Germany

South A fr i ca

England

Morocco

2010 May 15, 2004

South Afr ica Morocco

Egypt

2014

October

30,

2007 Braz i l

2018 December

2,

2010 Russia Spain/Portugal

Nether lands/Belgium

England

2022

December

2,

2010 Qatar Uni ted Sta tes

South

Korea

Japan

A u s t r a l i a

10.

Since a t

l e a s t

1996,

under FIFA s s t a tu t e s

the

s i x con t inen ta l confedera t ions had c e r t a i n

r i g h t s and

obl iga t ions including

among

othe r

th ings

t h a t they comply

6


7/35

with

and

enforce

FIFA ' S s t a tu t e s , regula t ions

and

dec i s ions

and

wor

k

c lose ly

with

FIFA to fu r the r FIFA's objec t ive s and

organize

i n t e r n a t i o n a l

soccer

compet i t ions .

11

.

FIFA

' S

purpose was, among othe r

th ings ,

to

deve

l

op and pro

m

o te

the

game

of soccer g loba l ly by organ i z ing


compet i t ions and c r ea t i n g and enforc ing ru l e s t ha t

govern the confedera t ions and member assoc ia t ions .

FIFA

f inanced i t s

e f f o r t s

i n s i g n i f i c a n t p a r t by commercial iz ing the

media

and market ing r igh t s assoc ia t ed

with

the World Cup. For

the

2007-2010 f i n an c i a l

period, FIFA

had

t o t a l revenues

of

4

.

189

b i l l i on , 83% o f which ( 3.480 b i l l ion

was

a t t r i bu t a b l e

to

the

sa l e

o f

t e l e v i s i o n and market ing r i g h t s to the 2010 World

Cup.

FIFA's

p r o f i t s

dur ing

t h i s

same per iod were 631

mil l ion .

FIFA, in t u rn ,

he lped

f inance t he

confederat ions

and

t h e i r

member

assoc ia t ions ,

including

by

prov id ing

funds through

the

Financ ia l

Ass is tance

Program

and

the Goal

Program.

B.

The

Cont inental

Confedera t ions

12. In add i t ion

to

providing r ep resen ta t ives

who

helped

to govern FIFA,

the s i x con t inen ta l confedera t ions worked

c lose ly

with FIFA

and

one

ano ther

to

organ ize


soccer

compet i t ions and

ca r ry ou t

FIFA

d i rec t ives

on

a reg iona l

b a s i s .

The

l e ade rs and r ep resen ta t ives of

the

confedera t ions

conducted business

with one

another ,

as wel l as with

the

l eaders

7


8/35

and assoc ia tes

of

FIFA

throughout the year a t locat ions around

the world

inc luding

in

the United

Sta tes . Each confedera t ion

was governed by i t s own congress genera l s e c r e t a r i a t execut ive

committee

and

s tand ing

committees

.

From t ime to t ime

some

of

the confedera t ions , l i ke FIFA a l so opera ted

through

subs id ia r i e s inc lud ing

subs id ia r ies

t ha t

a s s i s t e d with media

and market ing a c t i v i t i e s .

13. CONC C F was a con t inen ta l soccer confedera t ion

incorpora ted s ince

1994

as

a

non-prof i t co rpora t ion

in

Nassau

Bahamas .

CONC C F

was comprised

o f as many as 40

member

assoc ia t ions

inc lud ing the United Sta tes Puerto

Rico

and

the

United

Sta tes

Virg in

I s l ands represent ing

organ ized

soccer

in

North America Cent ra l America

the

Caribbean and th ree South

American

countr ies .

The

United

Sta tes and

two of

ts overseas

t e r r i t o r i e s

Puer to

Rico and

the

United

Sta tes

Virgin

Is lands

were

members

o f CONC C F . While the

confedera t ion

pres iden t

maintained

an of f i c e

in Trin idad and Tobago CONCACAF's

pr inc ipa l admin i s t ra t ive off i ce was l oca t ed

in

New York New

York

where

the genera l

sec re ta ry was based and where

CONC C F

r egu la r ly

conducted

bus iness .

CONC C F a l so conducted business

a t var ious

t imes throughout the United Sta tes inc lud ing in the

Eastern D i s t r i c t of

New

York as

well

as

in fo re ign

coun t r i e s

with in and out s ide

the

confederat ion . Among othe r

tournaments

8


9/35

CONC C F

organized the Gold

Cup,

fea tu r ing the men s na t iona l

teams from CONC C F and, from t ime to t ime, o ther

confedera t ions

as

wel l

as

a tournament f ea tu r ing the top men s

profe ss iona l

league - o r

c lub

-

teams.

14

. CONMEBOL

was

a

con t inen ta l

soccer

confederat ion

domici led

in

Paraguay and headquar tered

in

Asuncion, Paraguay

and, l a t e r Luque,

Paraguay. CONMEBOL was

comprised o f as

many

as

10 member assoc ia t ions

represent ing organized soccer

in

South America. Among o ther tournaments, CONMEBOL

organized

the

Copa

America,

f ea tu r ing

the men s na t iona l

teams

of

ts

t en

members and two non-CONMEBOL na t iona l

teams

t ha t

were

inv i ted

to

pa r t i c ipa t e as wel l as tournaments fea tu r ing the

top

men s

club

teams.

15. UEF was a con t inen ta l soccer confedera t ion

reg i s t e red

as

a

l ega l

e n t i t y

under

the

laws

o f

Switzer land

and

headquar tered in Nyon, Switzer land . UEF was comprised of

as

many as 53 member assoc ia t ions represent ing organized soccer

in

Europe and

c e r t a in na t ions in the

Middle East and Cent ra l Asia.

Among o ther tournaments , UEF organized

the

European

Championship, fea tu r ing the

top men s na t iona l

teams, as wel l as

tournaments

f ea tu r ing the top men s club teams.

16. C F was a con t inen ta l soccer confedera t ion

headquar tered in Cairo , Egypt. C F

was comprised o f as many as

9


10/35

56 member assoc ia t ions ,

represent ing organized

soccer in

Africa

.

Among othe r tournaments

C F

organized

the Africa

Cup

of

Nations, f ea tu r ing

the top men's na t iona l teams, as wel l

as

a

tournament

f ea tu r ing

the top

men's

club teams

.

17. FC was a con t inen ta l soccer confedera t ion

r eg i s t e r ed

as a

l ega l

e n t i t y under

the

laws of M

a lays ia and

headquar tered in Kuala Lumpur, Malaysia . FC was comprised

of

as

many as 47

member

assoc ia t ions , rep re sen t ing organized soccer

in Asia,

as wel l as

on

the

i s l and

o f Guam a

t e r r i t o r y

o f the

United Sta tes . Among othe r tournaments, AFC

organized

the

Asian

Cup, f ea tu r ing the

top men's

na t iona l teams,

as wel l as a

tourna

m

en t

fea tu

r ing the top

me n s

club te a

m

s .

18. OFC was a con t inen ta l soccer confedera t ion

incorpora ted under the laws

of New Zealand

and headquar tered in

Auckland,

New

Zealand. OFC

was

comprised

of

as

many

as

15

member

assoc ia t ions

represent ing organized soccer in New

Zealand

and the Pac i f i c I s land

count r ies , inc luding Ame r i can

Samoa,

a t e r r i t o r y o f the United Sta tes . Among o ther

tournaments OFC

organized

the

Nat ions Cup,

a tournament

founded

in 1996 f ea tu r ing the top men's na t iona l teams,

as

wel l

as

a

tournament f ea tu r ing

the top

men's

club teams.

19. The

confederat ions

a l so

organized

World Cup

qua l i fy ing

matches,

us ing a var i e ty of

formats .

10


11/35

C. The

Regional

Federa t ions and Nat ional Assoc ia t ions

20. In ad d i t i o n t o

being

members

o f FIFA

and

t he i r

re spec t ive con t inen ta l confederat ions , some of the na t iona l

a s soc ia t ions

were

a l so members o f smal ler , reg iona l federa t ions .

21.

For

example,

CONCACAF's

member

assoc ia t ions

were

organ ized i n to th ree smal le r reg iona l fede ra t ions :

the

Caribbean

Footba l l Union ( CFU ), the

Cent ra l American

Footba l l Union

( UNCAF )

and

the North American

Footba l l Union ( NAFU ).

The

United

S ta t e s

Soccer

Federa t ion

was thus a

member

assoc ia t ion of

CONC C F as

wel l

a s

NAFU,

while Puer to Rico

and the

United

Sta tes

Virg in

I s l ands were both members

o f

CONC C F and CFU .

22 . The na t iona l assoc ia t ions promoted, organized and

governed soccer , o f t en

including club

- l eve l soccer ,

with in

i nd iv idua l na t ions . The na t iona l assoc ia t ion

o f

the United

Sta tes

was

the

Uni ted

S ta t e s

Soccer

Federat ion ,

which

was

based

in Chicago, I l l i n o i s .

23 . The na t iona l assoc ia t ions worked

toge ther

to

organize

exh ib i t ion

soccer

matches between

na t iona l

teams, known

as

f r i e nd l i e s ,

which a l so took place on

the

c lub l eve l .

F r iend l ies

took place

in

venues throughout the uni ted S ta tes ,

inc lud ing the Eas te rn D is t r i c t

of New York,

as wel l as

othe r

venues worldwide.


12/35

D. The

Sports Marketing Companies

24. FIFA,

t he con t inen ta l confedera t ions the

regiona l

fede ra t ions

and

the na t iona l member assoc ia t ions

of t en

ente red

i n to con t rac t s with

spor t s market ing companies

to

commercial ize the

media and market ing

r i gh t s to var ious

soccer

events inc luding the World Cup and o ther tournaments , World Cup

and

Olympic qua l i f i e r s

f r i e nd l i e s and

o ther even t s

as

wel l as

o ther r igh t s assoc ia t ed with the spor t .

These

spor ts market ing

companies, inc lud ing mul t ina t iona l corpora t ions with

headquarters o f f i c e s

o r

a f f i l i a t e s l oca t ed

in

the

United

S ta t e s o f t en acqu i red an ar ray

o f

media

and

market ing r igh t s

including t e l e v i s i o n and rad io broadcas t ing r i gh t s adve r t i s ing

r igh t s sponsorship r i gh t s l i cens ing

r i gh t s

hos p i t a l i t y r igh t s

and t i cke t ing r i gh t s .

These spor t s marketing companies

of t en

sold these

r i gh t s

to

among

o ther s

t e l e v i s i o n

and

radio

s t a t ions

sponsors and

sub- l icensees including those located in

the United Sta tes .

25.

The revenue generated

by

the

commercial izat ion

of

the

media

and market ing r i gh t s assoc ia ted with soccer

cons t i tu ted an

e s s e n t i a l

source

o f

revenue

fo r the

en te rp r i s e .

12


13/35

I I

.

The Defendant

26 . The defendant CH RLES BL ZER was an indiv idua l

employed

by

and assoc ia ted with the

en te rp r i se .

In o r about and

between

Apri l

1990

and December

2011

, BL ZER was employed

as

the

genera l sec re ta ry

o f

CONC C F

. BLAZER, a

United Sta tes c i t i zen

re s ided in New York, New York,

where he oversaw

CONCACAF s

p r in c ip a l

admin i s t ra t ive

off i ce

and

s t a f f . Beginning

in

o r

about February 1997, BL ZER was a l so a

member

o f FIFA's

execut ive committee,

serving as one

o f

the th ree

members

of t h a t

body

who had been

appo in ted

by CONC C F

and

the only

member

who

represented

the United Sta tes .

At

various t imes , BL ZER was

a l so

a

member

of var ious

FIFA

s tand ing committees , including the

market ing and t e l e v i s i o n committee.

27. BLAZER was compensated fo r h i s p o s i t i o n as

CONCACAF s

genera l

s ec r e t a r y

by

a

number

o f

methods,

including

an annual

fee

and a revenue-based

commission s t ru c t u re

tha t he

designed. BLAZER was a l so compensated fo r h i s pos i t ion

as

a

member o f FIFA'S execut ive

and

market ing

commit tees .

BL ZER

e lec ted to

rece ive

t h i s compensation in var ious

accounts ,

inc lud ing

accounts based in

the United

Sta tes

and

i n o f f

shore

banking

j u r i s d i c t i ons .

28

.

As an o f f i c i a l

of CONC C F

and FIFA

,

BL ZER was

bound by f iduc ia ry du t ies to

the two organiza t ions .

13


14/35

I I I .

The

Conspi ra tors

Corrupt ion of the Ente rp r i se

29.

Certa in indiv idua ls

employed

by

and

assoc ia ted

with the en te rp r i se , inc lud ing the defendant CH RLES BLAZER

conspired

with

one ano ther to use t he i r

p o s i t i o n s

with in the

en te rp r i se to enr ich themselves

through

schemes

involving the

o f fe r , acceptance payment and r ece ip t o f undisc losed and

i l l e g a l payments , br ibes and

kickbacks, as well as through othe r

money-making

schemes

such as

unauthorized World Cup t i c ke t

sa l e s .

Though

they a l so

helped

pursue the pr inc ipa l purpose of

the

en te rp r i se , BLAZER

and

h i s co-conspi ra tors cor rup ted the

en te rp r i se by engaging in var ious

cr imina l

a c t i v i t i e s including

fraud,

br ibery and money laundering, in p u r su i t

o f

persona

l

ga in .

BL ZER and h i s co -

conspi ra tors

cor rup ted the en te rp r i s e

by abusing

pos i t ions

of t ru s t , engaging

in

undisc losed s e l f

dea l ing ,

misappropr ia t ing

funds

and

v i o l a t i n g

t h e i r

f iduc ia ry

du t ies . To fu r the r t h e i r

corrupt

ends, BLAZER and h i s co

consp i ra to rs

prov ided

each o ther with mutual a id and protect ion .

30.

The consp i ra to rs

engaged

in conduct

designed to

prevent

de tec t ion

o f t h e i r i l l ega l

a c t i v i t i e s

to conceal the

loca t ion

of

proceeds

o f those a c t i v i t i e s , and to promote the

carry ing

on

o f

those a c t i v i t i e s . That

conduct included,

among

o ther th ings : the

use

o f con t rac t s to

c r ea t e

an appearance of

leg i t imacy

fo r illi it payments ; the

use o f

var ious mechanisms,

14


15/35

including

t rus ted intermediaries , bankers,

f inancial

advisors

and currency dealers , to make and

fac i l i t a te

the

making

of

i l l i c i t payments; the

creat ion

and

use

of she l l companies,

nominees and numbered bank

accounts

in

tax

havens

and

other

secret ive

banking ju r i sd ic t ions ; the

act ive

concealment

of

foreign bank accounts; the

st ructur ing

of

f inancial

t ransactions

to avoid currency repor t ing requirements; bulk

cash smuggling;

the

purchase

of rea l property and

other

physical

asse t s ;

the use

of safe deposi t boxes; income tax

evasion;

and

obst ruct ion of

jus t ice .

Within the

United States

such

conduct took

place

within the

Eastern

Dis t r i c t

of New

York

and

elsewhere

.

IV. The Criminal

Schemes

31. In furtherance of the conspiracy and to ef fec t

i t s objects ,

the

defendant

CHARLES

BLAZER together with others ,

conspired

to

engage

in

mult iple

schemes,

including

schemes

involving: (a)

the

offe r

acceptance,

payment and

receipt of

undisclosed and

i l l ega l payments

and

bribes in connection with

votes of the FIFA executive committee to

determine

the host

nat ion

for

World Cup tournaments; and b) the offe r

acceptance,

payment

and

receipt

of undisclosed and

i l l egal

payments,

bribes

and kickbacks in connection with contracts between

CONCACAF

and

a sports marketing company

involving

the

media

and marketing

15


16/35

r i g h t s

assoc ia t ed

with

CONCACAF s

Gold

Cup

tournament. Three

such schemes are descr ibed below :

A . 1998 World Cup Vote Bribery Scheme

32. In

o r about

1992,

the FIFA execut ive committee

considered

b ids

from

Morocco and France, as wel l as

a

t h i r d

na t ion

t h a t withdrew

before the vote , t o hos t the 1998 World

Cup.

In the months

before the

vote ,

BLAZER

t r ave led with

Co

Consp i ra to r

#1,

an i nd iv idua l whose i d e n t i t y i s known

to

the

United Sta tes

Attorney,

to

Morocco a t

the i nv i t a t i on of the

Moroccan bid

committee

.

At

the

t ime,

Co-Conspi ra tor

#1 held

a

number o f pos i t ions

in soccer ,

inc lud ing

high-rank ing

pos i t ions

with FI FA

and

CONCACAF

33.

While in Morocco, BLAZER was

pre sen t

when a

r ep resen ta t ive

o f the Moroccan bid committee of fe red a br ibe

payment

to

Co-

Conspirator

#1 in

exchange

fo r

Co-Conspi ra tor

l ' s

agreement

to

c a s t

h i s s ec r e t

ba l lo t on

the

FIFA execut ive

committee fo r Morocco to

host

the 1998

World

Cup.

co

Consp i ra to r #1 accepted the o f fe r .

34

. Afte r t he

t r i p ,

Co -

Consp i ra to r #1 d i r ec t ed

BLAZER

to

con tac t

r ep resen ta t ives

of the Moroccan bid

committee to

determine

when

the payment would

be made

. BLAZER t h e re a f t e r

spoke

with

r ep resen ta t ives

o f

the Moroccan bid

committee on

severa l

occas ions , including

by te lephone from the

CONCACAF

16


17/35

of f ices

in New York, New York, regard ing when the payment would

be

made.

35 . Though

the

payment was

made,

a t

FIFA's

execu t ive

committee

meeting held

on

Ju ly

2,

1992,

France

was se l ec t ed over

Morocco to hos t the 1998 World

Cup.

36. No di sc losure

of

t h i s br ibe ry scheme was made to

the FIFA o r CONCACAF


o r congress .

B.

CONCACAF Gold

Cup

Contrac t

Bribery

and

Kickback Scheme

37. In o r about 1991, CONCACAF began organ iz ing and

promoting the

Gold

Cup,

a

tournament f ea tu r ing the

member

nat ions o f CONCACAF and, in c e r t a i n years ,

those

o f

othe r

confedera t ions . As genera l

sec re ta ry

of

CONCACAF

BLAZER was

respons ib le

fo r nego t i a t ing

a

con t rac t to

s e l l

the media

and

market ing r i g h t s

assoc ia t ed

with the

tournament .

In connect ion

with

the

f i r s t

Gold

Cup

tournament,

BLAZER

on

behal f o f

CONCACAF

en te red

in to

such

a con t rac t with a media company

based in

Mexico.

38. In o r

about 1993, BLAZER and Co-Conspira tor

#1

en te red i n t o nego t i a t ions with Co-Conspira tor #2, an ind iv idua l

who

r an

a

spor t s market ing company t ha t was headquar te red

in

South

America

and

had an

a f f i l i a t e in

the

United Sta tes

i nd iv idua l ly and co l l ec t ive ly ,

"Company

A") . The i de n t i t i e s

of

Co-Conspira tor

#2

and

Company

A

a re

known to

t he United Sta tes

17


18/35

Attorney. During the course

of nego t i a t ions ,

Co-Conspi ra tor #2

of fe red

to

pay

a

s i x - f i g u re sum o f

money

pe rsona l ly

to

BL ZER

and

Co-Conspi ra tor

#1 as

a br ibe

and

kickback

fo r

t he i r

agreement to award the con t rac t fo r the media and

market ing

r igh t s

to

the

Gold

Cup to Company A. BLAZER and Co Consp i ra to r

#1,

who

was

a high

ranking CONC C F o f f i c i a l a t a l l

t imes

re l evan t

to

t h i s

scheme, accep ted the

of f e r

and

caused

CONC C F

t o en t e r

i n to a

con t rac t with

Company A

in

o r about October

1994.

39.

Beginning with the 1996

Gold Cup and

cont inuing

fo r

four subsequent

ed i t ions

of the tournament (1998, 2000,

2002

and

2003), pursuan t to the con t rac t with Company

A (as

subsequent ly

amended

and renewed fo l lowing add i t iona l

nego t ia t ions ,

CONC C F granted

to

Company

A,

among

othe r

th ings ,

t e l e v i s i o n

and

radio

r i g h t s

to

the

Gold

Cup,

as

wel l

as

revenue

from

the sa l e

o f t i c ke t s

to

the

tournament .

The

nego t i a t ions between CONC C F and Company

A

were

conducted over

the

te lephone

and

in person in

New York, New York,

Los Angeles,

Cal i fo rn ia , and Miami,

Flor ida ,

among o t h e r

p laces .

40. During

t h i s

per iod , Co-Conspi ra tor #2 and othe r

repre sen ta t ive s

o f Company

A caused hundreds of thousands of

d o l l a r s i n br ibe and kickback payments

to

be

wired i n to

accounts

con t ro l l ed

by

BLAZER

in

mult ip le wire

t r a n s fe r s . The

payments

18


19/35

were wired from accounts held in the

name of

e n t i t i e s

othe r

than

Company

A to di sgu i se the

source

and na tu re of the funds. The

payments were wired

to

e n t i t i e s

BLAZER

con t ro l l ed , such as

Spor tve r t i s ing , a

Cayman

Is lands

corpora t ion ,

to

fu r the r

disguise the

source and natu re o f

the

funds . One such wire

t r a n s fe r i s descr ibed be

low:

D TE

WIRE

COMMUNIC TION

March 29, 1999

Wire

t r a ns f e r of

$200,000

from

an

account

in the name of Company B,

a

Uruguayan

company, the i d e n t i t y

o f which

i s known

to

the United

Sta tes

Attorney, with

t i e s

to

Company

A, a t a bank

in

Montevideo, Uruguay to a

Barclays

Bank PLC correspondent account in

New

York,

New

York,

fo r c re d i t to

BLAZER'S Spor tver t i s ing account

( the Spor tver t i s ing

Cayman

Account

0

,

a t Barclays Bank

PLC

in

the

Cayman

I s l ands

41. In

February

2003,

fol lowing

the rece ip t of

another

such wire

t r a ns f e r ,

in

the amount of $600,000,

which

was

a l so c red i ted

to the Spor tver t i s ing

Cayman

Account ( then held a t

Fi r s t ca r ibbean

I n t e r n a t i o n a l Bank (Cayman) Limited,

a successor

to

Barclays

Bank PLC), BL ZER rece ived a l e t t e r from h i s bank

asking

t h a t

he

provide

the

source

of

funds , a long

with

suppor t ing

documents. BLAZER

forwarded

the

l e t t e r

v ia

email

to

Co-Conspira tor #2 ' s s ec re ta ry , say ing

we

w i l l

need to cons t ruc t

a con t rac t regarding

t h i s

and o ther t r a n s fe r s

0

and ask ing t h a t

19


20/35

the l e t t e r be prov ided to Co-Conspira tor

#2. BLAZER

subsequent ly

r ece i v ed a backdated

"Consul t ing

Serv ices

Agreement"

purpor t ing

to be between Spor tver t i s ing Ltd. and

Company

C a Panamanian corpora t ion the

i d e n t i t y

of which

i s

known to

the

Uni ted

Sta tes

Attorney, wi th

t i e s

to

Company A and

provided

the

agreement

t o h i s bank in the

Cayman

I s l ands

.

42 . On

mult ip le

occas ions

BLAZER ac t ing pursuant to

h is unders tanding

with

Co-Conspira tor

#1

t h a t

the

payments

BL ZER rece ived

from Co-Conspira tor #2

and

Company

A would be

div ided between

them,

shared

por t ions of

the br ibe and

kickback

payments he

r ece i v ed with

Co -

Consp i ra to r

#1 . For

example, on o r

about Apri l

23,

1999, shor t ly a f t e r he had rece ived $200,000

from Company A v ia Company B, as descr ibed above, BLAZER sen t a

wire t r a n s fe r from h i s Spor tve r t i s ing Cayman Account in the

amount

o f

$100,000

to

a

bank

account

co n t r o l l ed

by

Co

Consp i ra to r

#1

.

43.

No di sc losure of t h i s

br ibery and

kickback

scheme

was made

to the CONC C F execut ive

committee o r

congress .

C.

2010

World Cup

Vote Bribery Scheme

44 . In o r about 2004, the FIFA execu t ive committee

cons idered

bids

from

Morocco, South Afr ica

and Egypt,

as

wel l as

othe r nat ions t h a t

withdrew

before the vote

to

host the 2010

World

Cup.

20


21/35

45. In t h e months before the vo te , BLAZER

and

Co

Consp i ra to r #1

t r av e l ed to

Morocco as they had

done

previously .

At

the

t ime, Co-Conspira tor

#1 he ld

a

number o f

pos i t ions in

soccer , inc lud ing as

a high-rank ing

o f f i c i a l

o f

FIFA,

CONCACAF

and

CFU.

46. While in Morocco,

a

r ep resen ta t ive

of the

Moroccan

b id

committee of fe red to pay

$1 mil l ion to Co

Consp i ra to r #1 in

exchange

fo r h i s agreement

to c a s t

h i s sec re t

ba l lo t on the

FIFA

execu t ive

committee fo r

Morocco to

hos t the

2010 World Cup.

47. Subsequent ly , BLAZER

l ea rned

from Co-Conspi rator

#1

t h a t r ep resen ta t ives

of

FIFA, the

South

Afr ican government

and the South Afr ican b id committee were

prepared

to arrange

fo r

the

government of South

Afr i ca

to pay $10 mil l ion

to a

soccer

organiza t ion con t ro l l ed

by

Co-Conspira tor

#1

to

suppor t the

Afr ican

diaspora .

BLAZER unders tood

the

o f f e r to

be in

exchange fo r

the agreement of

Co Consp i ra to r #1, BLAZER and Co

Consp i ra to r #3,

whose i d e n t i t y

i s

known to

the Uni ted

Sta t e s

Attorney, to a l l

vote

f o r South Afr ica , r a t h e r

than Morocco, to

hos t

the

2010 World Cup. At the t ime,

Co

Consp i ra to r #3 was

a

high-rank ing o f f i c i a l

with

FIFA and

CONCACAF

Co Consp i ra to r

#1

i nd ica t ed t ha t he had

accep ted

the

o ff e r

and

t o l d BLAZER

t ha t he

21


22/35

would give a

$1

mil l ion por t ion

of

the $10 mi l l i o n payment to

BLAZER.

48 . In FIFA's execut ive

committee

vote he ld May

15,

2004, South

Afr i ca

was s e l ec t ed

over

Morocco and Egypt to host

the

2010 World

Cup. BLAZER Co-Conspira tor

#1

and Co

Conspirator #3 ind ica ted t ha t

they vo ted fo r

South Africa .

49.

In the

months

and

years a f t e r

the vote

BL ZER

would

per iod ica l ly

ask Co-Conspira tor

#1

about

the s t a tus o f the

$10

mil l ion

payment.

SO. At one

poin t

BL ZER l ea rned t h a t the

South

Afr icans

were unable

to arrange fo r the

payment

to

be made

d i rec t l y

from government funds.

Arrangements were

t h e re a f t e r

made with FIFA o f f i c i a l s to ins tead have the $10 mil l ion sen t

from FIFA - us ing

funds t ha t

would

otherwise have

gone from FIFA

to

South

Afr ica

to

support the

World

Cup

-

to

a

soccer

organiza t ion

con t ro l l ed by Co-Conspira tor

#1.

51. BLAZER f i na l ly l ea rned from a

high

- ranking FIFA

o f f i c i a l t h a t FIFA had

in

f ac t

sen t

Co-Conspira tor

#1 the $10

mil l ion .

Though

years had passed

s ince the

vo te BLAZER

ac t ing

pursuant

to

t h e i r

common

scheme

and unders tanding,

t o ld

Co

Conspirator #1 t ha t

he wanted

h i s por t ion o f the

money.

Co

Conspirator #1

agreed to give BLAZER the money but

s t a t e d

tha t

he would have to pay

him

in i ns t a l lmen t s

as

he had

a l ready spent

22


23/35

it Co-Conspira tor

#1

a l so

disc losed t ha t he

had

given two

smal le r por t ions

o f

the

money

to Co-Conspira tor #3 and

another

soccer

o f f i c i a l .

52.

From

in

o r

about

December 2008 to

i n o r

about

May

2011, BLAZER rece ived three payments

from Co-Conspira tor

#1,

t o t a l i n g

over $750,000.

53. The f i r s t payment,

in

the amount of $298,500, was

made

by wire

t r a ns f e r

sen t

on

o r about

December

19,

2008 from

an

account

he ld

in

the

name

of CFU

in

a bank

in

the Caribbean, to a

Bank

o f

America correspondent account

in

New York, New York,

fo r

c re d i t to BLAZER S Spor tver t i s ing

Cayman

Account .

54

.

The

second payment, in

the

amount of

$205,000,

was

made by check drawn

on

an

account

held

in the name of

CFU in

a

bank in

the Caribbean. On o r about

September 27,

2010,

BL ZER

caused

the

check

to

be

depos i t ed

i n to

h i s

Merr i l l

Lynch

brokerage account in New

York,

New York.

Approximately

one

month e a r l i e r on o r

about

August

23, 2010, Co-Conspira tor

#1

sen t

an email

to

BLAZER

to

adv ise

him t ha t the

payment

was

forthcoming

.

55. The t h i r d

payment, in the amount

of $250,000,

was

made by check

drawn

on an account held

in

the name of CFU

in

a

bank in the

Caribbean. The

check was de l ive red

to BL ZER by

another i nd iv idua l who t r ave led by a i rp lane from Trinidad and

23


24/35

Tobago to John

F.

Kennedy In te rna t iona l ("JFK") Airpor t in

Queens,

New York, and then to CONCACAF s headquarters

in

New

York, New York, where he

de l ive red

the

check to

BLAZER. A

r ep resen ta t ive

of

Fi rs tCar ibbean

I n t e r n a t i o n a l

Bank in

the

Bahamas, where BLAZER held another

account , subsequent ly

t r ave led by a i rp lane

to

New York, landing a t

JFK Airpor t . Af te r

a r r i v in g

the bank r ep resen ta t ive t r ave led to New York, New

York, where he

took

cus tody

of the check.

He subsequent ly

t r ave led to the Bahamas and,

on

o r about May 3, 2011, deposi ted

the check i n to BLAZER S account . Approximately two

months

e a r l i e r

on

o r

about

March

13, 2011, Co-Conspira tor #1 sen t an

emai l

to BLAZER to advise him t ha t the

payment

was forthcoming.

56. BLAZER never

rece ived

the balance

of the

promised

$1

mil l ion payment.

57.

No

di sc losure

of

t h i s

br ibery

scheme

was

made

to

the FIFA o r CONCACAF execut ive committee o r

congress .

COUNT ONE

(Racketeer ing Conspiracy)

58. The

a l lega t ions

contained

in

paragraphs 1

through

57

are r ea l l eged

and incorpora ted as i fu l l y s e t fo r th

in

t h i s

paragraph.

59. In o r about

and between

Apri l 1990

and December

2011, both

da tes

being

approximate

and inc lus ive

within

the

24


25/35

Eas te rn Di s t r i c t of New York and

elsewhere ,

the

defendant

CH RLES BLAZER toge ther with

o ther s , being

a

person employed by

and assoc ia t ed

with

the


which engaged in , and the

a c t i v i t i e s o f which a f fec t ed , i n t e r s t a t e

and

fo re ign commerce,

did

knowingly and

i n t en t iona l ly consp i re

to

v io la t e T i t l e

18,

United S ta t e s Code, Sect ion 1962(c) ,

t ha t

i s ,

to conduct and

p a r t i c i p a t e ,

d i r e c t ly and i nd i rec t ly , in the conduct o f the

a f f a i r s o f

such en te rp r i s e through

a

p a t t e rn

of racke teer ing

a c t iv i t y , as def ined in T i t l e

18,

United Sta tes

Code,

Sect ions

1961(1) and 1961(5) .

60.

The p a t t e rn

of racke tee r ing a c t i v i t y through

which

the

defendant CH RLES

BLAZER t oge the r

with othe rs , agreed

to

conduct

and p a r t i c i p a t e ,

d i r e c t l y

and

i nd i rec t ly ,

in the

conduct

o f the a f f a i r s o f

the en t e r p r i s e

cons i s t ed o f

mul t ip le

ac t s

i n d i c t ab l e

under :

(a)

T i t l e 18, United

S ta t e s

Code, Sect ion 1343

(wire

fraud, inc lud ing

hones t -se rvices

wire

f raud) ;

(b) T i t l e 18, United S ta t e s Code, Sect ions

1956

and 1957 (money l aunder ing and money

l aunder ing conspiracy)

;

(c)

T i t l e 18, United

S ta t e s

Code, Sect ion

1952

i n t e r s t a t e

and fo re ign t r a v e l i n - a id - o f

racke teer ing) ; and

(d) T i t l e 31, United Sta tes Code, Sect ions

5314

and 5322 wi l l fu l

f a i l u r e

to f i l e repor t

o f

fo re ign bank

and f i n an c i a l

accoun ts ) ;

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and

mult ip le

a c t s involving

br ibery ,

i n v i o l a t i o n of

New

York

Sta t e Penal

Law

Sect ions

180.03

and

180.08. BLAZER

agreed t ha t

a

consp i ra to r would commit a t l e a s t two a c t s o f

racke teer ing

a c t i v i t y in

the

conduct of the a f f a i r s of the


the

l a s t o f which

would occur

with in 10 years o f

a

pr io r ac t of

racke teer ing ac t i v i t y .

Ti t l e 18, United Sta tes Code, Sect ions 1962(d), 1963

and 3551 e t

seq . )

COUNT TWO

(Wire

Fraud Conspiracy)

61.

The a l lega t ions con ta ined in paragraphs

1

through

57

are r ea l l eged and incorpora ted as i f

fu l l y

s e t

fo r th in

t h i s

paragraph.

62.

In o r about

and

between Apri l 2004 and

May

2011,

both dates being

approximate

and

i nc lus ive , w i th in the Eas tern

D i s t r i c t of

New

York

and

elsewhere , the defendan t CHARLES

BLAZER

t oge the r with othe rs , d id

knowingly

and i n t en t iona l ly

conspire to dev ise

a

scheme

and

a r t i f i c e

to

defraud

FIFA

and

CONCACAF inc lud ing to deprive FIFA and

CONCACAF

of t he i r

re spec t ive

r i g h t s to honest and

f a i t h fu l

se rv ices

through br ibes

and

kickbacks ,

and

to

obta in

money

and

prope r ty

by

means

of

mater ia l ly fa l se and f raudu len t pre t enses , r ep re sen ta t ions and

promises , and

f o r

the

purpose

o f

execu t ing such scheme and

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a r t i f i ce , t o t r ansmi t

and

cause to be t r ansmi t t ed by means of

wire communication in i n t e r s t a t e and fo re ign commerce, wri t ings ,

s igns , s igna l s ,

p i c tu r e s and sounds, to

wit :

emai ls , te lephone

c a l l s and wire

t r a n s fe r s , con t ra ry

to

T i t l e

18, United

Sta tes

Code, Sect ion 1343.

Ti t l e 18, United Sta t e s Code, Sect ions 1349 and 3551

e t seq.)

COUNT THREE

(Money Laundering Conspiracy)

63

.

The

a l l eg a t i o n s

con ta ined

in

paragraphs

1

through

57

are r ea l l eged and incorporated

as i fu l l y

s e t

f o r th

in

t h i s

paragraph.

64

.

In o r about

and

between December 2008 and

May

2011, both

da tes

being approximate and inc lus ive , with in the

Eas tern D i s t r i c t o f

New

York

and

elsewhere , the

defendant

CH RLES

BLAZER

toge ther with othe rs , d id

knowingly

and

i n t en t iona l ly

consp i re

to

t r anspor t , t r ansmi t and

t r a n s fe r

monetary ins t ruments

and

funds,

to wit : wire t r a n s fe r s

and

checks,

from places

in

the United

S ta t e s t o and through

places

ou t s ide the United Sta tes and to places in

the

United

Sta t e s

from

and

through

places outs ide

the

United

Sta tes ,

(a)

with

the

i n t en t

to promote

the

car ry ing on

of

s p ec i f i ed unlawful

a c t iv i t y ,

to

wit :

wire fraud, con t ra ry to

Ti t l e

18, United

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Sta tes Code, Sec t i o n 1343,

a l l

co n t r a ry to T i t l e 18, United

Sta tes Code, Sec t i o n

1956(a) (2)

(A),

and (b)

knowing

t h a t

the

monetary ins t ruments and funds involved in the

t r anspor t a t ion ,

t ransmiss ion

and t r a n s f e r represen ted the

proceeds

o f some

form

o f

unlawful a c t i v i t y

and

knowing

t h a t

such

t r anspor ta t ion ,

t ransmiss ion and t r a ns f e r was designed

in whole and

i n

p a r t t o

concea l and

di sgu i se the na tu re , the l oca t ion , the

source ,

the

ownership

and

the con t ro l of the proceeds o f

s a id

spec i f i ed

unlawful a c t i v i t y ,

a l l

con t ra ry

to

Ti t l e 18, United Sta t e s

Code,

Sect ion 1956 (a)

(2)

B) i ) .

Ti t l e 18, United Sta tes

Code, Sect ions

1956(h) and

3551 e t

seq . )

COUNTS FOUR

THROUGH NINE

(Income Tax Evasion)

65. On

o r about the da tes s e t

f o r th below,

within the

Southern D i s t r i c t

o f New York and e lsewhere ,

the

defendant

CH RLES BLAZER, a

r e s id en t

o f New York, New York, did

knowingly

and

w i l l fu l l y a t t empt to

evade

and de fea t su b s t a n t i a l

income

tax

due and owing

by

him to the United Sta t e s o f

America

fo r each of

the ca lendar years s e t

f o r th below, by

, f a i l i ng

to f i l e

a uni ted

Sta tes i nd iv idua l

income

t ax r e tu r n

wi th

the

I n t e r n a l

Revenue

Serv ice ("IRS") as r eq u i r ed

by

law, f a i l i ng to pay

to

t h e

IRS

income t ax

and

engaging in a f f i rma t ive a c t s o f evas ion ,

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inc lud ing concea l ing and a t tempt ing to concea l

from

the IRS

h i s

t r u e and co r r ec t

income.

ount

alendar

Year o

Tax Return

Due Date o Tax Return

Four 2005

Apri l

17

2006

Five 2006

Apri l

17, 2007

Six

2007

Apri l 15, 2008

Seven

2008

Apri l

15,

2009

Eight

2009

Apri l

15,

201 0

Nine

2010

Apri l 18,

201 1

(T i t l e

26,

Uni ted Sta tes Code, Sect ion 7201 ; Ti t l e 18,

Uni ted

S ta t e s Code

Sect ions 3551 e t ~ .

COUNT TEN

(Wil l fu l Fa i lu re to

Fi le Repor t

of

Fore ign

Bank and Financ ia l

Accounts)

66. At a l l t imes

re levant

to Count Ten:

a .

Pursuant to

T i t l e 31, Code

o f

Federal

Regula t ions ,

Sect ions

103.24,

103 .27(c) ,

103.

27(d)

and

103.59(b) , c i t i z e ns and r es iden ts of the

Uni ted

Sta tes who

had

a

f inanc ia l i n t e r e s t in o r

s igna ture

au th o r i t y

over , a bank,

se c u r i t i e s and othe r f inanc ia l account in a fo re ign count ry with

an aggregate

value o f

more

than

$10,000 a t a n y t ime dur ing a

p a r t i c u l a r

yea r

were

requ i re

d

to f i l e

with

the

United

Sta tes

Department

of the

Treasury a

Report o f Foreign Bank and

Financ ia l Accounts

on Form TD-F 90-22. 1

( the

"FBAR").

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b .

The

FB R fo r a

given year was due by June 30

of the

fol lowing

year .

67.

During the ca lendar year

2010,

the

defendant

CH RLES BLAZER a

r e s id en t

o f New York, New

York, had

a

f inanc ia l i n t e r e s t in ,

and s igna tu re and othe r

au th o r i t y over ,

one o r

more

f i n an c i a l

accounts ,

having

an

aggregate

value

exceeding $10,000, a t Firs tCaribbean

I n t e r n a t i o n a l

Bank, a

bank

in the Bahamas.

68.

On

o r

before

June 30,

2011,

with in the

Eastern

D i s t r i c t of New York and

elsewhere ,

the

defendant

CH RLES BL ZER

did

knowingly

and

w i l l f u l l y

f a i l

to f i l e with

the

United

Sta t e s

Department

of the

Treasury

a Report of

Foreign

Financ ia l

and

Bank Accounts

on Form TD-F 90-22.1,

di sc los ing t h a t he

had

a

f inanc ia l

i n t e r e s t i n , and

s igna ture and

othe r au th o r i t y over,

a

bank,

s e c ur i t i e s

and

othe r f inanc ia l

account

in

a

fo re ign

count ry , to

wit : a

Bahamanian bank account a t

Fi r s t ca r ibbean

In te rna t iona l

Bank,

which account had an aggregate va lue of more

than

$10,000 dur ing

the year 2010,

while v i o l a t i n g

another

law

of the

Uni ted

Sta tes ,

to

wit :

Ti t l e 26, United S ta t e s Code,

Sec t ion 7201.

Ti t le 31, United Sta tes Code,

Sect ions

5314 and

5322(b) ;

Ti t l e

18, Uni ted Sta tes Code,

Sect ions 3551

e t

seq. )

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CRIMINAL FORFEITURE ALLEGATION AS TO

COUNT ONE

69.

The United

S ta t e s hereby

gives not i ce to

the

defendant t h a t upon h i s conv ic t ion

of

the offense charged in

Count

One,

the

government w i l l

seek

fo r f e i t u re i n accordance

with

Ti t l e

18

United

S ta t e s

Code, Sect ion

1963(a) , which

requ i re s

any person

convicted of such offense

to

f o r f e i t

: (a)

any i n t e r e s t acqu i red o r maintained i n v i o l a t i o n

of Ti t l e

18,

United S ta t e s

Code, Sect ion

1962;

(b)

any

i n t e r e s t

in s ecur i ty

o f

cla im aga ins t o r

prope r ty

o r con t rac tua l

r i gh t o f

any

kind

a f fo rd ing

a

source o f in f luence over , any

en t e r p r i s e which

the

defendant es tab l i shed operated con t ro l l ed conducted, o r

par t i c ipa ted i n the

conduc t

o f

in

v io la t ion of T i t l e 18, United

Sta tes Code, Sect ion 1962, and (c) any

proper ty

cons t i tu t ing o r

der ived from,

any

proceeds obta

i

ned

d i r e c t l y o r i n d i r e c t l y

from

racke tee r ing

a c t i v i t y

in

v io l a t i o n

of

Ti t l e

18,

United

Sta tes

Code,

Sect ion

1962.

70. I f any

o f

the above-descr ibed fo r f e i t a b l e

proper ty

as a

r e s u l t o f

any

ac t

o r

omission of the

defendant :

(a) cannot be

loca ted

upon the exe rc i se

o f

due

di l igence ;

(b)

has been

t r an s f e r r ed

o r

so ld to

o r

depos i t ed

with , a

t h i r d

p a r ty ;

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32/35

(c) has been

placed

beyond

the j u r i s d i c t i on o f

the

cour t ;

(d)

has been subs tan t i a l ly diminished in value;

o r

(e) has been commingled with o ther prope r ty

which

cannot be divided

without d i f f i c u l t y ;

t i s

the

i n t en t

of

the United

Sta tes ,

pursuant to Ti t l e 18,

United

Sta tes

Code, Sec t ion

1963(m),

to seek

fo r f e i t u re

of

any

o the r

proper ty of the

defendant , inc luding bu t no t l imi t ed to

the de fendan t s

pension from FIFA, up

to t he value of the

fo r f e i t a b l e

prope r ty .

(T i t l e

18,

United

S ta t e s Code, Sec t ions 1963(a) and

1963(m))

CRIMINAL FORFEITURE ALLEGATION

S TO COUNT

TWO

71.

The

United

Sta tes

hereby

gives

no t ice to

the

defendant t ha t , upon h is conv ic t ion

of

the of fense

charged

in

Count Two, the

government

w i l l seek fo r f e i t u re i n accordance

with

Ti t l e

18,

United

S ta t e s Code,

Sect ion

98l(a) (1)

C)

and

Ti t l e

28, United

Sta tes

Code, Sec t ion 246 l ( c ) ,

which

requi re any

person

convic ted o f

such offense to

f o r f e i t any

and

a l l

proper ty , r e a l o r persona l , which cons t i tu t es o r i s der ived from

proceeds t r a ceab le

to a

v i o l a t i o n of

such offense .

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72. I f any of

the

above-descr ibed


proper ty ,

as r e s u l t

of

any

ac t

o r

omission

of

the

defendant :

(a) cannot be

loca ted

upon

the

exe rc i se of due

d i l igence ;

(b)

has

been

t r an s f e r r ed

o r

so ld

to , o r depos i ted

with ,

t h i r d

par ty ;

(c)

has

been placed

beyond

the

j u r i s d i c t i on

of

the cour t ;

(d)

has

been su b s t a n t i a l l y dimin i

shed

in value;

o r

(e) has been commingled with o the r prope r ty

which

cannot be div ided

with

o

u t

d i f f i c u l t y ;

t i s the i n t e n t of t he United Sta tes ,

pursuant

to

Ti t l e

21,

United

S ta t e s Code,

Sec t ion 853(p) ,

as incorpora ted

by Ti t l e 28,

United

S ta t e s

Code,

Sec t ion

246l (c ) , to

seek

fo r f e i t u r e

of

any

o ther

prope r ty o f the

defendant ,

inc luding bu t not l imi t ed to

the

de fendan t s pens ion from FIFA,

up

to

the

value of

the


prope r ty descr ibed

in

t h i s

fo r f e i t u re a l l eg a t i o n .

(T i t l e

28,

United Sta tes Code, Sec t ion

246l (c ) ;

Ti t l e

18,

United

St a t e s Code, Sec t ion

98l(a)

(1)

(C);

Ti t l e

21, United

Sta tes Code, Sec t ion 853(p))

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CRIMINAL

FORFEITURE ALLEGATION AS TO

COUNT

THREE

73.

The

United

Sta tes hereby gives not ice

to the

defendant

tha t

upon his convict ion

of

the offense charged in

Count

Three, the

government

wil l seek

for fe i tu re in

accordance

with Ti t l e 18, United

Sta tes

Code,

Sect ion 982{a) (1), which

requi res any person

convicted

of such offense

to forfe i t

any and

a l l property,

rea l o r

personal , involved in such offense, o r any

property t raceable

to such

offense

74 I f

any

of the above-described

for fe i t ab le

property,

as

a r e su l t of any

ac t

or omission of the defendant:

(a) cannot

be located upon

the

exercise of due

di l igence;

(b) has been t r ans fe r red

or

sold to ,

or

deposi ted

with,

a

th i rd

party ;

(c)

has

been

placed

beyond

the

ju r i sd ic t ion

of

the court ;

(d) has

been

subs tan t i a l ly

diminished in value;

o r

(e)

has

been

commingled with other property which

cannot

be

divided

without di f f icu l ty ;

t

i s

the in ten t

of

the United Sta tes pursuant to Ti t le 21,

United Sta tes

Code, Section

853(p),

as incorporated by

Ti t l e 18,

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United S ta t e s

Code, Sect ion 982(b) , to seek

fo r f e i t u re of any

othe r p rope r ty

of the defendant , inc lud ing bu t not l imi t ed to

the de fendan t s pension from

FIFA, up to

the

value o f

the

fo r fe i t ab le p ro p e r t y

descr ibed

i n t h i s fo r f e i t u re a l lega t ion .

( T i t l e

18,

United

Sta tes Code, Sect ions 982(a) (1)

and

982(b); T i t l e

21, United Sta t e s Code, Sect ion 853(p) )

i .

LORETT E.

UNITED ST TES TTORNEY

E STERN DISTRICT OF NEW YORK

De volledige verklaring van Charles Blazer

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