FIFA Indictments With Full List of Charges

CMP:EMN/AH/DAL/BDM
F.#2013R01652
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
- -X
UNITED STATES OF AMERICA

- against DARYAN WARNER,
Defendant.
I N F 0 R MA T I 0 N
Cr. No. 13-584 (WFK)
(T. 18, U.S.C.,
981 (a) (1) (C), 982 (a) (1),
982 (b), 1349, 1956 (h), 2
and 3551 et seq.i T. 21,
U.S.C., 853 (p) i T. 28,
U.S.C., 2461(c) i T. 31,
u.s.c., 5317(c) (1),
53 2 4 (a) ( 3 ) and 53 2 4 (d) ( 2 ) )
- - - - - - - - - - - - - - -X
THE UNITED STATES ATTORNEY CHARGES:

INTRODUCTION TO COUNTS ONE AND TWO
At all times relevant to Counts One and Two of this
Information:
1.
The Federation Internationale de Football
Association ("FIFA") was the international body governing

organized soccer, commonly known outside the United States as
football.
FIFA was an entity registered under Swiss law and
headquartered in Zurich, Switzerland.
FIFA was composed of as
many as 208 member associations, each representing organized

soccer in a particular nation or territory, including the United
States and four of its overseas territories: American Samoa,
Guam, Puerto Rico and the United States Virgin Islands.
2.
The World Cup, soccer's premier event, was a
quadrennial international tournament organized by FIFA involving

the senior men's teams of 32 nations.
3.
In 2006, the World Cup was held in Germany (the
"2006 World Cup"), and in 2010 the next World Cup was held in
South Africa (the "2010 World Cup").
4.
FIFA established rules governing, among other
things, the sale and use of tickets to the 2006 World Cup and
the 2010 World Cup.
The FIFA Ticketing Office ("FTO") was the
official sales agent with respect to the distribution of tickets

for the 2006 World Cup and the 2010 World Cup.
The FTO was
operated by an event-management company engaged by FIFA.

5.
From in or about and between 2005 and 2011, both
dates being approximate and inclusive, the defendant DARYAN

WARNER, together with others, participated in a scheme to obtain
World Cup tickets from FIFA based on materially false and
fraudulent pretenses, representations and promises, and to
resell those tickets to others for a substantial profit.
The 2006 World Cup Tickets Scheme
6.
In advance of the 2006 World Cup, the defendant
DARYAN WARNER and Co-Conspirator #1, a ticket broker based in

Florida whose identity is known to the United States Attorney,
agreed to be partners for the purpose of obtaining tickets to
the 2006 World Cup and reselling them at a substantial mark-up.
2
WARNER's role in the scheme was to purchase tickets from the

FTO.
After purchasing the tickets, WARNER would sell them to
Co-Conspirator #1, who, in turn, would sell them to, among

others, travel agencies, tour operators and other ticket
brokers.
7.
Prior to 2006, the FTO had advised the defendant
DARYAN WARNER that it would not sell him tickets if WARNER

intended to resell the tickets to or through Co-Conspirator #1.
8.
It was part of the scheme that the defendant
DARYAN WARNER attempted to purchase, and did purchase, tickets

from the FTO.
Because WARNER knew that the FTO would not sell
the tickets to him for resale to Co-Conspirator #1, WARNER

disguised and concealed his intention to resell the tickets to
Co-Conspirator #1.
For example, on one occasion, when asked by
a representative of the FTO if WARNER was working with CoConspirator #1, WARNER lied and said he was not.
9.
It was further part of the scheme that the
defendant DARYAN WARNER sought to disguise and conceal his

intention to resell tickets to the 2006 World Cup to CoConspirator #1 from an auditing firm that had been hired by FIFA
to investigate irregularities in the resale of tickets to the
2006 World Cup.
10.
Among other things, the defendant DARYAN WARNER,
together with Co-Conspirator #1, agreed to provide, and did

3
provide, to the FTO and to the auditing firm documents that

falsely represented that WARNER intended to resell tickets to
the 2006 World Cup directly to certain travel agencies and tour
operators not associated with Co-Conspirator #1.
11.
As a result of the scheme, the defendant DARYAN
WARNER and Co-Conspirator #1 made a substantial profit from the

sale of the 2006 World Cup tickets that WARNER procured from the
FTO based on false pretenses.
The 2010 World Cup Tickets Scheme
12.
FIFA became aware that the defendant DARYAN
WARNER had resold 2006 World Cup tickets obtained from the FTO
to Co-Conspirator #1.
As a result, WARNER understood and
believed that the FTO would not sell him tickets for the 2010
World Cup.
Further, WARNER understood and believed that the FTO
would not sell such tickets to any other individual if the FTO
knew the tickets would later be provided to WARNER for resale.
13.
Nevertheless, the defendant DARYAN WARNER
continued his scheme with Co-Conspirator #1 to obtain 2010 World

Cup tickets and resell them at a substantial mark-up, as they
did in 2006.
14.
It was part of the scheme that, for the purpose
of causing the FTO to provide him with tickets that he could

resell at a substantial mark-up, the defendant DARYAN WARNER
asked two of his family members, whose identities are known to
4
the United States Attorney (the "Two Family Members"), to obtain

tickets from the FTO on his behalf.
WARNER understood and
believed that his Two Family Members, who, at the time, were
FIFA officials entitled to purchase a certain allotment of
tickets, obtained the tickets without disclosing to the FTO that
they intended to provide the tickets to WARNER for resale.
15.
After receiving the tickets from his Two Family
Members, the defendant DARYAN WARNER, along with Co-Conspirator

#1, resold the tickets at a substantial mark-up.
WARNER and Co-
Conspirator #1 made a substantial profit from the sale of

tickets to the 2010 World Cup.
COUNT ONE
(Wire Fraud Conspiracy)
16.
The allegations contained in paragraphs 1 through
15 are realleged and incorporated as if set forth fully in this

paragraph.
17.
In or about and between 2005 and 2011, both dates
being approximate and inclusive, within the Southern District of

Florida and elsewhere, the defendant DARYAN WARNER, together
with others, did knowingly and intentionally conspire to devise
a scheme and artifice to defraud FIFA, and to obtain money and
property from FIFA, by means of materially false and fraudulent
pretenses, representations and promises, and for the purpose of
executing such scheme and artifice did transmit and cause to be
transmitted in interstate and foreign commerce, writings, signs,

signals, pictures and sounds, to wit: interstate and
international emails and wire transfers, contrary to Title 18,
United States Code, Section 1343.
(Title 18, United States Code, Sections 1349 and 3551
et seq.)
COUNT TWO
(Money Laundering Conspiracy)
18.
17 are realleged and incorporated as if fully set forth in this

paragraph.
19.
In or about and between 2005 and 2011, both dates
being approximate and inclusive, within the Southern District of

Florida and elsewhere, the defendant DARYAN WARNER, together
with others, did knowingly and intentionally conspire to
transport, transmit and transfer monetary instruments and funds,
to wit: wire transfers, from a place in the United States to and
through a place outside the United States and to a place in the
United States from and through a place outside the United
States, with intent to promote the carrying on of specified
unlawful activity, to wit: wire fraud, contrary to Title 18,
United States Code, Section 1343, all contrary to Title 18,

United States Code, Section 1956(a) (2) (A).
(Title 18, United States Code, Sections 1956(h) and
3551 et seq.)
INTRODUCTION TO COUNT THREE
At all times relevant to Count Three of this
Information, the currency reporting requirements provided as
follows:
Structuring and Currency Reporting Requirements
20.
Transactions in currency were defined as
transactions involving the physical transfer of money, as

defined in Title 31, Code of Federal Regulations, Section
1 0 1 0 . 1 0 0 ( bbb) .
21.
Domestic financial institutions were required to
file a Currency Transaction Report (FinCEN Form 104, hereinafter

referred to as a "CTR") with the United States Department of the
Treasury for each transaction in currency, such as a deposit,
withdrawal, exchange of currency or other payment or transfer
by, through or to such financial institution, in excess of
$10,000, as required by Title 31, United States Code, Section
5313 and Title 31, Code of Federal Regulations, Section
1010.311.
22.
CTRs were filed on forms that required, among
other things, the identity of the individual who conducted the

7
transaction (Part One of the CTR) and the individual or

organization for whom the transaction was completed (Part Two of
the CTR) .
23.
CTRs were required to be filed to assist the
United States in criminal, tax and regulatory investigations and

proceedings, as stated in Title 31, United States Code, Section
5311.
24.
"Structuring" a financial transaction was defined
in Title 31, Code of Federal Regulations, Section 1010.100(xx),

as conducting, or attempting to conduct, one or more
transactions in currency, in any amount, at one or more
financial institutions, on one or more days, in any manner, for
the purpose of evading the currency reporting requirements,
including, without limitation, by breaking down a sum of
currency exceeding $10,000 into smaller sums, including sums at
or below $10,000, and conducting a currency transaction or a
series of currency transactions at or below $10,000.
COUNT THREE
(Structuring)
25.
The allegations contained in paragraphs 20
through 24 are rea1leged and incorporated as if fully set forth

in this paragraph.
26.
In or about and between July 2011 and December
2011, both dates being approximate and inclusive, within the
Eastern District of New York and elsewhere/ the defendant DARYAN

WARNER
together with others/ for the purpose of evading the
reporting requirements of Title 31

5313(a)
United States Code
Section
and the regulations prescribed thereunder/ did
knowingly and intentionally structure/ assist in structuring and

attempt to structure one or more transactions with one or more
domestic financial institutions/ by (a) breaking down sums of
currency exceeding $10 000 into smaller sums/ including sums at
1
or below $10 000

1
and depositing the smaller sums of currency
into accounts with one or more domestic financial institutions/

and (b) conducting a series of currency transactions/
including
transactions at or below $10 1 000 1 at one or more domestic

financial institutions/ all as part of a pattern of illegal
activity involving more than $100 000 in a twelve-month period.
1
(Title 31
United States Code/ Sections 5324 (a) (3) and
5324 (d) (2); Title 18
United States Code/ Sections 2 and 3551 et
seq.)
CRIMINAL FORFEITURE ALLEGATION AS TO COUNT ONE
27.
The United States hereby gives notice to the
defendant that/ upon his conviction of the offense charged in

Count One/ the government will seek forfeiture in accordance
with Title 18
Title 28
United States Code/ Section 981(a) (1) (C) and
United States Code/ Section 2461(c)
which require any
person convicted of such offense to forfeit any and all

9
property/ real or personal/ which constitutes or is derived from

proceeds traceable to a violation of such offense.
28.
If any of the above-described forfeitable
property/ as a result of any act or omission of the defendant:

(a) cannot be located upon the exercise of due
diligence;
(b) has been transferred or sold to
with
or deposited
a third party;
(c) has been placed beyond the jurisdiction of
the court;
(d) has been substantially diminished in value;
or
(e) has been commingled with other property which
cannot be divided without difficulty;
it is the intent of the United States/ pursuant to Title 21
United States Code/ Section 853(p)
as incorporated by Title 28
United States Code/ Section 2461(c)
to seek forfeiture of any
other property of the defendant up to the value of the

forfeitable property described in this forfeiture allegation.
(Title 28
18
United States Code/ Section 2461(c); Title
United States Code/ Section 981(a) (1) (C); Title 21
States Code/ Section 853(p))
10
United
CRIMINAL FORFEITURE ALLEGATION AS TO COUNT TWO

29.
defendant that, upon his conviction of the offense charged in

Count Two, the government will seek forfeiture in accordance
with Title 18, United States Code, Section 982(a) (1), which
requires any person convicted of such offense to forfeit any and
all property, real or personal, involved in such offense, or any
property traceable to such offense.
30.
property, as a result of any act or omission of the defendant:

diligence;
(b) has been transferred or sold to, or deposited
with, a third party;
the court;
or
it is the intent of the United States, pursuant to Title 21,
United States Code, Section 853(p), as incorporated by Title 18,
11
United States Code, Section 982(b), to seek forfeiture of any

(Title 18, United States Code, Sections 982(a) (1) and
982(b); Title 21, United States Code, Section 853(p))
CRIMINAL FORFEITURE ALLEGATION AS TO COUNT THREE
31.
defendant that, upon conviction of the offense charged in Count

Three, the government will seek forfeiture in accordance with
Title 31, United States Code, Section 5317(c) (1), which requires
any person convicted of such offense to forfeit any property,
real or personal, involved in such offense and any property
traceable to such property.
32.

(a)
cannot be located upon the exercise of due
(b)
has been transferred or sold to, or
diligence;
deposited with, a third party;

(c)
has been placed beyond the jurisdiction of
the court;
12
(d)
has been substantially diminished in value;
(e)
has been commingled with other property
or
which cannot be divided without difficulty; it is the intent of

the United States, pursuant to Title 21, United States Code,
Section 853(p), to seek forfeiture of any other property of the
defendant up to the value of the forfeitable property described
in this forfeiture allegation.
(Title 31, United States Code, Section 5317(c) (1);
Title 21, United States Code, Section 853(p))
""'~/
\_"
~r-~ G
LORETTA E. LYNCH
j
UNITED STATES ATTORNEY
13
DSS : EMN/AH
F . #2013R01093
- -X
- against DARYLL WARNER,
Cr . No. 13-402 (WFK)
(T. 18, U . S . C.,
1343, 2 and 3551 et ggg.;
T. 21, u.s . c .
85,3 (p);
T. 31, U.S.C.,
5317 (c) (1), 5324 (a) (3)
and 53 2 4 ( d) ( 2 ) )
I
Defendant.
- - - - - - - -X
INTRODUCTION TO COUNT ONE
At all times relevant to Count One of this Information,
unless otherwise indicated:
The Mortgage Fraud Scheme
1.
From in or about and between November 2005 and
January 2006, both dates being approximate and inclusive, the

defendant DARYLL WARNER, together with others, participated in a
scheme to obtain a mortgage loan on the basis of false
information, and to use the proceeds of the loan to finance the
purchase of a residential property located at 2101 Brickell
Avenue, Unit No . 3504, in Miami, Florida (the "Miami
Condominium").
2.
WARNER, a dual citizen of the United States and
Trinidad and Tobago who resided in Trinidad and Tobago, sought to
purchase the Miami Condominium on behalf of himself and two

family members
(the "Two Family Members"), the identities of whom
are known to the United States Attorney, who agreed that the
purchase would be in WARNER's name.
WARNER and the Two Family
Members ultimately agreed to purchase the Miami Condominium for a

contract sales price of $990,000 financed,
in part, by a
mortgage.
3.
In furtherance of the scheme, WARNER caused the
preparation of a fraudulent mortgage application (the "Mortgage

Application"), which was submitted to Lender 1, a mortgage lender
with offices in Plantation, Florida, the identity of which is
known to the United States Attorney.
The Mortgage Application
sought to obtain a mortgage loan totaling approximately $690,000

(the "Mortgage Loan"), to be used to purchase the Miami
Condominium.
The Mortgage Application was materially false, in
that it contained false residence, employment, income and asset

information as to WARNER.
The Mortgage Application also was
materially false in that it included a representation that the

source of the down payment on the Miami Condominium would be the
checking and savings accounts of WARNER.
4.
It was further part of the scheme that WARNER
provided Lender 1 with a business telephone number with a New

York area code, representing it to be associated with his
employer (the "Telephone Number"), and arranged with another
individual to answer the Telephone Number and falsely confirm

details regarding WARNER's employment.
5.
After reviewing the Mortgage Application
containing the false information, Lender 1 approved funding for

the Mortgage Loan in the amount of $690,000.
The closing was
scheduled for December 28, 2005.

6.
It was further part of the scheme that, on or
about December 26, 2005, WARNER sent an email from Trinidad and
Tobago to a loan officer employed by Lender 1 in Florida seeking
to delay the closing by one day.
WARNER sent the email because
he needed additional time to obtain funds representing the

contributions toward the closing costs on the Miami Condominium
made by the Two Family Members.
7.
It was further part of the scheme that WARNER
obtained two closing checks (the "Closing Checks") and traveled

from Trinidad and Tobago to Florida to attend the closing on the
Miami Condominium, which took place on or about December 29,
2005.
At the closing, WARNER provided the Closing Checks to a
representative of Settlement Agent 1, a real estate settlement

services company with 9ffices in Fort Lauderdale, Florida, the
identity of which is known to the United States Attorney.
The
first of the Closing Checks was a $100,000 cashier's check drawn

at a bank in Trinidad and Tobago with the remitter listed as
"CONCACAF Centre of Excellence."
The second of the Closing
Checks was a $200,000 cashier's check drawn at the same bank with
the remitter listed as "Nauti Krew Ltd."
Neither of the Closing
Checks was drawn on a checking or savings account of WARNER .

COUNT ONE
(Wire Fraud)
8.
The allegations contained in paragraphs 1 though 7
are realleged and incorporated as if set forth fully in this

paragraph.
9.
In or about and between November 2005 and January

Southern District of Florida, the defendant DARYLL WARNER,
together with others, did knowingly and intentionally devise a
scheme and artifice to defraud Lender 1, and to obtain money and
property from Lender 1, by means of materially false and
fraudulent pretenses, representations and promises, and for the
purpose of executing such scheme and artifice did transmit and
cause to be transmitted in interstate and foreign commerce,
writings, signs, signals, pictures and sounds, to wit: an email
dated December 26, 2005, sent from Trinidad and Tobago to a
representative of Lender 1 located in the United States.
(Title 18, United States Code, Sections 1343, 2 and
3551 et seq.)
INTRODUCTION TO COUNT TWO
At all times relevant to Count Two of this Information,
the currency reporting requirements provided as follows:
4
Structuring And Currency Reporting Requirements

10.
Transactions in currency were defined as
transactions involving the physical transfer of money, as defined

in Title 31, Code of Federal Regulations, Section 1010 . 100(bbb) .
11.
Domestic financial institutions were required to
file a Currency Transaction Report (FinCEN Form 104, hereinafter

referred to as a "CTR") with the United States Department of the
Treasury for each transaction in currency, such as a deposit,
withdrawal, exchange of currency or other payment or transfer by,
through or to such financial institution, in excess of $10,000,
as required by Title 31, United States Code, Section 5313 and
Title 31, Code of Federal Regulations, Section 1010.311.
12.
CTRs were filed with the Internal Revenue Service
("IRS") on forms which required, among other things, the identity

of the individual who conducted the transaction (Part One of the
CTR) and the individual or organization for whom the transaction
was completed (Part Two of the CTR) .
13 .
CTRs were required to be filed to assist the
United States in criminal, tax and regulatory investigations and

proceedings, as stated in Title 31, United States Code, Section
5311.
14.
"Structuring" a financial transaction was defined
in Title 31, Code of Federal Regulations, Section 1010.100(xx),

as conducting, or attempting to conduct, one or more transactions
in currency, in any amount, at one or more financial

institutions, on one or more days, in any manner, for the purpose
of evading the currency reporting requirements, including,
without limitation, by breaking down a sum of currency exceeding
$10,000 into smaller sums, including sums at or below $10,000,
and conducting a currency transaction or a series of currency
transactions at or below $10,000.
COUNT TWO
(Structuring)
15.
14 are rea1leged and incorporated as if fully set forth in this

paragraph.
16.
In or about and between July 2011 and December

Southern District of Florida, the defendant DARYLL WARNER,
together with others, for the purpose of evading the reporting
requirements of Title 31, United States Code, Section 5313(a),
and the regulations prescribed thereunder, _d id knowingly and
intentionally structure, assist in structuring and attempt to
structure one or more transactions with one or more domestic
financial institutions, by (a) breaking down sums of currency
exceeding $10,000 into smaller sums, including sums at or below
$10,000, and depositing the smaller sums of currency into
accounts with one or more domestic financial institutions, and
(b) conducting a series of currency transactions, including
6
transactions at or below $10,000, at one or more domestic

financial institutions, all as part of a pattern of illegal
activity involving more than $100,000 in a twelve-month period.
(Title 31, United States Code, Sections 5324 (a) (3) and
5324(d) (2); Title 18, United States Code, Sections 2 and 3551 et
seq.)
17.
defendant that, upon conviction of the offense charged in Count

Two, the government will seek forfeiture in accordance with Title
31, United States Code, Section 5317(c) (1), which requires any
person convicted of such offense to forfeit any property, real or
personal, involved in such offense and any property traceable to
such property.
18.

a.
b.
has been transferred or sold to, or deposited
diligence;

c.
the court;
d.
e.
has been commingled with other property which
or

United States Code, Section 853(p), to seek forfeiture of any
(Title 31, United States Code, Section 5317(c) (1);
Title 21, United States Code, Section 853(p))
LORETTA E. LYNCH
DSS:EMN/AH/DAL/SPN/BDM
F.#2014R00190
-
-X
- against -
Cr. No. 14-609 (RJD)

(T. 18, u.s.c. I
9 8 1 ( a ) ( 1 ) ( C) , 9 8 2 ( a) ( 1 ) ,
982 (b) 1 13491 1512 (b) (3) 1
1512 (c) (2) t 1956 (h) t
1962 (d) I 1963 I 1963 (a) t
1963(m) and 3551 et seq.;
T. 21, U.S.C., 853 (p);
T. 28, U.S.C. 2461(c))
JOSE HAWILLA,
TRAFFIC SPORTS USA, INC., and
TRAFFIC SPORTS _INTERNATIONAL, INC.,
Defendants.
- - - - - - - - - - - - - - - -
~x

INTRODUCTION TO ALL COUNTS
At all times relevant to this Information, unless
otherwise indicated:
I.
The Enterprise
1.
The Federation Internationale de Football
Association ("FIFA") and its six constituent continental

confederations - the Confederation of North, Central American
and Caribbean Association Football ("CONCACAF"), the
Confederaci6n Sudamericana de Futbol ("CONMEBOL"), the Union des
Associations Europeennes de Football ("UEFA"), the Confederation
Africaine de Football ("CAF"), the Asian Football Confederation
( "AFC") , and the Oceania Football Confederation ( "OFC") -
'
together with affiliated regional federations, national member

associations, and sports marketing companies, collectively
constituted an "enterprise," as defined in Title 18, United
States Code, Section 1961(4), that is, a group of legal entities
associated in fact
(hereinafter the "enterprise").
The
enterprise constituted an ongoing organization whose members

functioned as a continuing unit for a common purpose of
achieving the objectives of the enterprise.
The enterprise was
engaged in, and its activities affected, interstate and foreign

commerce.
2.
The principal purpose of the enterprise was to
regulate and promote the sport of soccer worldwide.
The members
of the enterprise carried out this purpose by using a variety of

methods and means, including creating and enforcing uniform
standards and rules, organizing international competitions, and
commercializing the media and marketing rights associated with
the sport.
The members of the enterprise, as well as
individuals and entities employed by and associated with the

enterprise, frequently engaged in banking and investment
activities with United States financial institutions.
3.
The enterprise operated in the Eastern District
of New York and elsewhere, including overseas.
---------1
A.
FIFA
4.
FIFA was the international body governing
organized soccer, commonly known outside the United States as

football.
FIFA was an entity registered under Swiss law and
headquartered in Zurich, Switzerland.
FIFA was composed of as
many as 208 member associations, each representing organized

soccer in a particular nation or territory, including the United
States and four of its overseas territories.
The United States
first became affiliated with FIFA in 1914; Puerto Rico first

became affiliated with FIFA in 1960, with Guam, American Samoa,
and the United States Virgin Islands following suit in the
1990s.
At various times, FIFA maintained offices both in Zurich
and elsewhere in the world, including in the United States,

where FIFA maintained a development office since at least 2011.
5.
Each of FIFA's member associations also was a
member of one of the six continental confederations recognized

by FIFA: CONCACAF, CONMEBOL, UEFA, CAF, AFC, and OFC.
Since at
least 1996, under FIFA's statutes, no national soccer

association could become a member of FIFA without first joining
one of the six continental confederations.
Since at least 2004,
member associations were required to pay to FIFA annual dues,

known as subscriptions.
6.
FIFA was governed by: a congress composed of its
member associations, which acted as the association's highest

legislative body; an executive committee, which acted as the
executive body; and a general secre'tariat, which acted as the
admin1strative body.
FIFA also had a president, who represented
the association worldwide and was responsible for the

implementation of decisions.
FIFA also operated several
standing committees, including a committee that organized

Olympic soccer qualifying tournaments, whose members included
soccer officials from various national member associations.
FIFA also operated through a number of subsidiaries, including
subsidiaries that assisted with FIFA's media and marketing
activities.
7.
The FIFA congress was composed of delegates from
each of its member associations, as well as observers appointed

by each of the confederations.
Among other things, the congress
was responsible for amending FIFA's statutes and electing the

FIFA president.
The congress convened in ordinary sessions
biennially or annually, and at other times in extraordinary

sessions, in various countries around the world, including the
United States.
8.
The FIFA executive committee, often referred to
as the "ExCo," was composed of the FIFA president and a number

4
of ordinary members, some of whom also held the title vice

president.
The president was elected by the FIFA congress.
The
vice presidents and ordinary members were appointed by the

confederations.
Each confederation was entitled to appoint a
specific number of vice presidents and ordinary members, as set

forth in the FIFA statutes.
Since at least 1996, the executive
committee was required by FIFA statutes to meet at least twice

per year.
The executive committee held meetings at FIFA's
headquarters in Zurich, as well as in various countries around

the world, including the United States.
9.
Among other duties, the executive committee was
responsible for selecting the host nations of FIFA tournaments,

including, among others, the World Cup, the Women's World Cup,
the Confederations 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.
10.
The World Cup, the sport's premier event, was a
quadrennial international tournament involving the senior

national men's teams of 24 and, beginning in 1998, 32 nations.
In selecting the host nation for the World Cup, the executive
committee typically followed a process in which bid committees
for the competing nations campaigned for votes among the members
of the executive committee.
Following this process, and at

5
least six years prior to each World Cup, the executive committee
typically held a vote in which its members cast their votes via
secret ballot.
The winners, or host nations, for the World Cups
from 1990 to 2022, as well as the other bidding nations that

maintained their bids to the end of the process, are reflected
in the table below:
World I Date Selected
I Winning Nation
I Other Bidding
Nation/Nations
Cup
by the ExCo
1990
May 19, 1984
Italy
Soviet Union
1994
July 4, 1988
United States
Morocco
Brazil
1998
July 2, 1992
France
Morocco
2002
May 31, 1996
Japan/South Korea
Mexico
2006
July 6, 2000
Germany
South Africa
England
Morocco
2010
May 15, 2004
South Africa
Morocco
Egypt
2014
October 30, 2007
Brazil
2018
December 2, 2010
Russia
Spain/Portugal
Netherlands/Belgium
England
2022
December 2, 2010
Qatar
United States
South Korea
Japan
Australia
11.
Since at least 1996, under FIFA's statutes, the
six continental confederations had certain rights and

obligations, including, among other things, that they comply
----------
with and enforce FIFA's statutes, regulations, and decisions and

work closely with FIFA to further FIFA's objectives and organize
international soccer competitions.
12.
FIFA' s purpose was, among other things, to
develop and promote the game of soccer globally by organizing

international competitions and creating and enforcing rules that
govern the confederations and member associations.
FIFA
financed its efforts in significant part by commercializing the

media and marketing rights associated with the World Cup.
According to its published income statement for the 2007-2010
financial period, FIFA had total revenues of $4.189 billion, 83%
)
of which ($3.480 billion) was attributable to the sale of

television and marketing rights to the 2010 World Cup.
profits during this same period were $631 million.
FIFA's
FIFA, in
turn, helped finance the confederations and their member

associations, including by providing funds through the Financial
Assistance Program and the Goal Program.
13.
FIFA first instituted a written code of ethics in
October 2004, which code was revised in 2006 and again in 2009
(generally, the "code of ethics").
The code of ethics governed
the conduct of soccer "officials," which expressly included,

among others, various individuals with responsibilities within
FIFA, the confederations, member associations, leagues, and
7
~--------
------------ -- -------1
I
clubs.
Among other things, the code of ethics provided that
soccer officials were prohibited from accepting bribes or cash

gifts and from otherwise abusing their positions for personal
gain.
The code of ethics further provided, from its inception,
that soccer officials owed certain duties to FIFA and its

confederations and member associations, including a duty of
absolute loyalty . . By 2009, the code of ethics explicitly
recognized that FIFA officials stand in a fiduciary relationship
to FIFA and its constituent confederations, member associations,
leagues, and clubs.
B.
The Continental Confederations

14.
In addition to providing representatives who
helped to govern FIFA, the six continental confederations worked

closely with FIFA and one another to organize international
soccer competitions and carry out FIFA directives on a regional
basis.
The leaders and representatives of the confederations
conducted business with one another, as well as with the leaders

and associates of FIFA, throughout the year at locations around
the world, including in the United States.
Each confederation
was governed by its own congress, general secretariat, executive

committee and standing committees.
From time to time, some of
the confederations, like FIFA, also operated through
subsidiaries, including subsidiaries that assisted with media

and marketing activities.
15.
CONCACAF was a continental soccer confederation
incorporated, since 1994, as a non-profit corporation in Nassau,

Bahamas.
CONCACAF comprised as many as 41 member associations,
representing organized soccer in North America, Central America,

the Caribbean and three South American countries.
The United
States and two of its overseas territories, Puerto Rico and the
United States Virgin Islands, were members of CONCACAF.
From
approximately 1990 to 2012, CONCACAF's principal administrative

office was located in New York, New York, where the former
general secretary was based (until the end of 2011) and where
CONCACAF regularly conducted business.
Beginning in 2012,
CONCACAF's principal administrative office was located in Miami,

Florida, where the new general secretary was based.
CONCACAF
also conducted business at various times throughout the United

States,, including in the Eastern District of New York, as well
as in foreign countries within and outside the confederation.
Among other tournaments, CONCACAF organized the Gold Cup,
featuring the men's national teams from CONCACAF and, from time
to time, other confederations, as well as a tournament featuring
the top men's professional league- or club - teams.
----1
16.
CONMEBOL was a continental soccer confederation
domiciled in Paraguay and headquartered in Asuncion, Paraguay

and, later, Luque, Paraguay.
CONMEBOL comprised as many as 10
member associations, representing organized soccer in South

America.
Among other tournaments, CONMEBOL organized the Copa
America, featuring the men's national teams of its ten members

and two non-CONMEBOL national teams that were invited to
participate, as well as tournaments featuring the top men's club
teams.
Since 1993, the United States has participated in the
Copa America as an invitee three times, and in 2016 the United

States will host and participate in a special edition of the
tournament to commemorate its centennial.
17.
UEFA was a continental soccer confederation
registered as a legal entity under the laws of Switzerland and

headquartered in Nyon, Switzerland.
UEFA comprised as many as
54 member associations, representing organized soccer in Europe

and certain nations in the Middle East and Central Asia.
other tournaments, UEFA organized the European
Among
Championship~
featuring the top men's national teams, as well as tournaments

featuring the top men's club teams.
18..
CAF was a continental soccer confederation
headquartered in Cairo, Egypt.
CAF comprised as many as 56
member associations, representing organized soccer in Africa.

10
Among other tournaments, CAF organized the Africa Cup of

Nations, featuring the top men's national teams, as well as a
tournament featuring the top men's club teams.
19.
AFC was a continental soccer confederation
registered as a legal entity under the laws of Malaysia and

headquartered in Kuala Lumpur, Malaysia.
AFC comprised as many
as 47 member associations, representing organized soccer in

Asia, as well as on the island of Guam, a territory of the
United States.
Among other tournaments, AFC organized the Asian
Cup, featuring the top men's national teams, as well as a

tournament featuring the top men's club teams.
20.
OFC was a continental soccer confederation
incorporated under the laws of New Zealand and headquartered in

Auckland, New Zealand.
OFC comprised as many as 14 member
associations, representing organized soccer in New Zealand and

the Pacific Island countries, including American Samoa, a
territory of the United States.
Among other tournaments, OFC
organized the Nations Cup, a tournament founded in 1996

featuring the top men's national teams, as well as a tournament
featuring the top men's club teams.
21.
The confederations also organized World Cup
qualifying matches, using a variety of formats, and, from time
11
--
---------~----
-----
------
-------~------------------------------,
to time, worked together to organize inter-confederation

competitions, often with the support and approval of FIFA.
C.
The Regional Federations and National Associations

22.
In addition to being members of FIFA and their
respective continental confederations, some of the national

associations were also members of smaller, regional federations.
23.
For example, CONCACAF's member associations were
organized into three smaller regional federations: the Caribbean

Football Union ("CFU"), the Central American Football Union
( "UNCAF") , and the North American Football Union ( "NAFU") .
The
United States Soccer Federation was thus a member association of

CONCACAF as well as NAFU, whiie Puerto Rico and the United
States Virgin Islands were both members of CONCACAF and CFU.
24.
The national associations promoted, organized,
and governed soccer, often including club-level soccer, within

individual nations.
The national association of the United
States was the United States Soccer Federation ("USSF"), which

was based in Chicago, Illinois.
25.
The national associations, also often referred to
as "federations," worked together to organize exhibition soccer

matches between national teams, known as "friendlies," which
also took place on the club level.
12
Friendlies took place in
--- --------- ---l

I
venues throughout the United States, including the Eastern

District of New York, as well as in other venues worldwide.
D.
The Sports Marketing Companies

26.
FIFA, the continental confederations, the
regional federations and the national member associations often

entered into contracts with sports marketing companies to
commercialize the media and marketing rights to various soccer
events, including the World Cup and other tournaments, World Cup
and Olympic qualifiers, friendlies, and other events, as well as
other rights associated with the sport.
These sports marketing
companies, including multinational corporations with

headquarters, offices, or affiliates located in the United
States, often acquired an array of media and marketing rights,
including television and radio broadcasting rights, advertising
rights, sponsorship rights, licensing rights, hospitality
rights, and ticketing rights.
These sports marketing companies
often sold these rights to, among others, television and radio
stations, sponsors, and sub-licensees, including those located
in the United States.
27.
The revenue generated by the commerciali.zation of
the media and marketing rights associated with soccer

constituted an essential source of revenue for the enterprise.
13
The United States was an increasingly important and lucrative

market for the commercialization of these rights.
II.
The Defendants
28.
The defendant JOSE HAWILLA was an individual
employed by and associated with the enterprise.
In or about and
between 1980 and the present, HAWILLA was the founder and owner
of the Traffic Group, a multinational sports marketing company
based in Sao Paulo, Brazil.
In South America, Traffic's
operations focused on, among other things, the commercialization

of soccer through the purchase and sale of media and marketing
rights associated with the sport.
HAWILLA, a Brazilian citizen,
resided in Sao Paulo, where he oversaw Traffic's principal

operations and staff.
29.
The defendant TRAFFIC SPORTS USA, INC. was an
entity employed by and associated with the enterprise.

Beginning in or about 1990, HAWILLA expanded Traffic's
operations to the United States, partnering with and later
acquiring a Florida company called Inter/Forever Sports, Inc.,
which was renamed TRAFFIC SPORTS USA, INC.
"TRAFFIC USA")
in or about 2003.
(collectively,
TRAFFIC USA was a Florida
corporation that had its headquarters and principal place of

business in Miami and was involved in the purchase and sale of
media and marketing rights associated with soccer in the United
14
----
----------------------------------------
States and other parts of the CONCACAF region.
TRAFFIC USA .also
participated in the ownership and management of the North

American Soccer League ("NASL"), a division of United States
men's club soccer sanctioned by the USSF, as well .as the
ownership and management of multiple clubs within the league.
The NASL was headquartered in New York City and its teams were
based in various cities in Canada and the United States,
including in the Eastern District of New York.
30.
The defendant TRAFFIC SPORTS INTERNATIONAL, INC.
("TRAFFIC INTERNATIONAL") was an entity employed by and

associated with the enterprise.
TRAFFIC INTERNATIONAL was a
British Virgin Islands corporation.
In a lawsuit filed in
Florida state court in 2011, TRAFFIC INTERNATIONAL described

itself as "one of the leading sports event and management
companies in the world, with primary emphasis on the sport of
soccer."
31.
From time to time, TRAFFIC USA and TRAFFIC
INTERNATIONAL did business with each other and with other

entities within the Traffic Group, including the Brazilian
affiliate, Traffic Assessoria e Comunicac;oes S/C Ltda.
Brazil").
("Traffic
Except where otherwise indicated, TRAFFIC USA,
TRAFFIC INTERNATIONAL, and Traffic Brazil, along with their
15
---- --
--------~
affiliates, predecessors, and assigns, are referred to herein

collectively as "Traffic" or the "Traffic Group."
32.
In connection with their activities with the
enterprise, HAWILLA and Traffic maintained business operations

in the United States.
In connection therewith, at various
times, HAWILLA resided in and traveled to and from the United

States, and he arranged for TRAFFIC USA employees, other Traffic
employees, and other members of the enterprise to travel to and
from the United States.
In addition, HAWILLA, TRAFFIC USA,
TRAFFIC INTERNATIONAL, and other Traffic affiliates used the

wire facilities of the United States and engaged in banking and
investment activities with United States financial institutions.
33.
Traffic was privately held.
Prior to 1999,
HAWILLA controlled all outstanding shares of TRAFFIC

INTERNATIONAL and Traffic Brazil and 50% of TRAFFIC USA.
Between approximately 1999 and 2002, HAWILLA owned approximately
25% of TRAFFIC USA and a majority share of TRAFFIC INTERNATIONAL
and Traffic Brazil, and an American private equity firm owned a
minority share of TRAFFIC INTERNATIONAL and Traffic Brazil and
approximately 75% of TRAFFIC USA.
Beginning in 2002, HAWILLA
controlled all outstanding shares of Traffic directly or through

offshore holding companies as to which he owned an approximately
99% interest.
16
--------
--~------------~-----------------
III. The Defendants' Co-Conspirators

34.
The identities of the following individuals and
business entities are known to the United States Attorney:

35.
At various times relevant to this Information,
Co-Conspirator #1 was a high-ranking official of FIFA and

CONMEBOL.
36.
Co-Conspirator #2 and Co-Conspirator #3 were senior executives

of a group of companies under :ommon ownership and control
referred to individually and collectively below as the
Intermediary.
37.
At various times
~elevant
to this Information,
Co-Conspirator #4 and Co-Conspirator #5 were senior executives

of a group of companies under common ownership and control
referred to individually and collectively below as Sports
Marketing Company A.
38.
Co-Conspirator #6 was a senior executive of a group of companies

under common ownership and control referred to individually and
collectively below as Sports Marketing Company B.
39.
Co-Conspirator #7 was a senior executive of TRAFFIC USA and an

official of FIFA.
17
40.
Co-Conspirator #8 was a high-ranking official of FIFA, CONMEBOL,

and one of FIFA's national member associations.
41.
Co-Conspirator #9 was a senior executive of TRAFFIC USA, a highranking official of CONCACAF, and an official of FIFA.
42.
Co-Conspirator #10 was a senior executive of TRAFFIC USA.

43.
Co-Conspirator #11 was a high-ranking official of FIFA,

CONCACAF, a regional federation, and one of FIFA's national
member associations.
44.

CONCACAF.
45.

Confederac;ao Brasileira de Futebol ("CBF"), Brazil's national
soccer federation and one of FIFA's national member
associations, and an official of CONMEBOL.
46.
Co-Conspirator #14 was a senior executive of a group of

companies under common ownership and control referred to
18
------------------------
--------------------
individually and collectively below as Sports Marketing Company
c.
47.
Co-Conspirator #15 was a high-ranking official of CBF and an

official of FIFA and CONMEBOL.
48.
Co-Conspirator #16 was ,a high-ranking official of FIFA and CBF.

49.
The foregoing officials of FIFA, CONCACAF, and
other soccer governing bodies were bound by fiduciary duties to

their respective organizations.
IV.
The Conspirators' Corruption of the Enterprise

50.
Certain individuals and entities employed by and
associated with the enterprise, including the defendants JOSE

HAWILLA, TRAFFIC SPORTS USA, INC., and TRAFFIC SPORTS
INTERNATIONAL, INC., conspired with one another to use their
positions within the enterprise to engage in schemes involving
the offer, acceptance, payment, and receipt of undisclosed and
illegal payments, bribes, and kickbacks.
Although they also
helped pursue the principal purpose of the enterprise, HAWILLA

and his co-conspirators corrupted the enterprise by engaging in
various criminal activities, including fraud, bribery, and money
laundering, in pursuit of personal and commercial gain.
also participated in the corruption of the enterprise by
19
HAWILLA
-----~-------;-----------------------
conspiring with and aiding and abetting his co-conspirators in

the abuse of their positions of trust and the violation of their
fiduciary duties.
51.
To further their corrupt ends, HAWILLA and his
co-conspirators provided each other with mutual aid and

protection.
The conspirators engaged in conduct designed to
prevent detection of their illegal activities, to conceal the

location of proceeds of those activities, and to promote the
carrying on of those activities.
The conduct engaged in by
various members of the conspiracy included, among other things:

the use of contracts to create an appearance of legitimacy for
illicit payments; the use of various mechanisms, including
trusted intermediaries, bankers, financial advisors, and
currency dealers, to make and facilitate the making of illicit
payments; the creation and use of shell companies, nominees, and
numbered bank accountso in tax havens and other secretive banking
jurisdictions; the active concealment of foreign bank accounts;
the structuring of financial transactions to avoid currency
reporting requirements; bulk cash smuggling; the purchase of
real property and other physical assets; the use of safe deposit
boxes; income tax evasion; and obstruction of justice.
Within
the United States, such conduct took place within the Eastern
District of New York and elsewhere.
20
---------------
v.
------------------------
The Criminal Schemes

52.
In connection with their activities with the
enterprise, the defendants JOSE HAWILLA, TRAFFIC SPORTS USA,

INC., and TRAFFIC SPORTS INTERNATIONAL, INC., together with
others, agreed to engage in multiple schemes, including schemes
involving the offer, acceptance, payment, and receipt of
undisclosed and illegal payments, bribes, and kickbacks.
Such
schemes related to numerous soccer events and other rights

associated with the sport.
53.
A.
Four such schemes are described in detail below:
Copa America Bribery Scheme

54.
In 1916, CONMEBOL organized the first edition of
the Copa America, a tournament featuring the men's national

teams of its members.
According to CONMEBOL, the tournament,
which continues to be played today,' is the longest continuouslyrunning such tournament in the world.
55.
In or about 1986, Traffic Brazil entered into
negotiations with CONMEBOL to acquire the media and marketing

rights associated with the Copa America.
On or about October 3,
1986, HAWILLA caused Traffic Brazil to enter.into a $1.7 million

contract with CONMEBOL officials for the exclusive worldwide
commercial rights associated with the 1987 edition of the
tournament, to be held in Argentina and to be contested by its
21
-------~-~-------
----
--------~--
------~l
10 members: Argentina, Bolivia, Brazil, Chile, Colombia,

Ecuador, Paraguay, Peru, Uruguay, and Venezuela.
56.
Beginning with the 1987 edition and continuing
thereafter through 2011, Traffic held the exclusive worldwide

commercial rights for each edition of the Copa America
tournament, which rights were secured through a series of
contracts between Traffic and CONMEBOL.
As discussed further
below, in 2013, TRAFFIC INTERNATIONAL formed a Uruguayan company

with Sports Marketing Company A and Sports Marketing Company B
called Datisa S.A.
("Datisa") that obtained the exclusive
worldwide commercial rights for the 2015, 2016, 2019, and 2023
editions of the tournament.
57.
Beginning in the early 1990s, as the value of the
rights associated with the commercialization of the Copa America

increased, various CONMEBOL officials, including Co-Conspirator
#1, began demanding bribe payments from HAWILLA in exchange for
the performance of various acts, and HAWILLA agreed to pay.
As
set forth below, the bribe payments began in the six figures
(United States dollars) and ultimately were frequently in the
seven figures.
58.
The commercial rights to all editions of the
tournament starting with the 1993 edition and continuing through

Unless otherwise specified, all currency amounts are in United
States dollars.
22
1
--------1
the 2023 edition were obtained through bribery.
The table below
reflects the host nations, participation of the United States

men's national team, and commercial rights holders for each
edition of the tournament during this period:
Edition
I Host
Nation
I u.S.
Team
Participated
I Commercial
Rights
Holder
1993
Ecuador
./
Traffic Brazil
1995
Uruguay
./
Traffic Brazil
1997
Bolivia
Traffic Brazil
1999
Paraguay
TRAFFIC INTERNATIONAL
2001
Colombia
2004
Peru
2007
Venezuela
2011
Argentina
2015
Chile
Dati sa
2016
United States
2019
2023
./
./
Dati sa
Brazil
TBD
Dati sa
Ecuador
TBD
Dati sa
The 1991 Copa America Contract

59.
On or about January 23, 1991, Traffic Brazil
entered into a contract with CONMEBOL to acquire the exclusive

worldwide commercial rights for the 1993, 1995, and 1997
editions of the Copa America (as amended, the "1991 Copa America
Contract").
The 1991 Copa America Contract, signed by HAWILLA
and three CONMEBOL officials in Asuncion, Paraguay, was for $6.6

million: $2.2 million per edition.
23
On or about July 7, 1992,
~---------~----------------
- ---------1
!
after the United States and Mexico accepted invitations to

compete in the 1993 edition of the tournament, the parties
executed an addendum to the 1991 Copa America Contract
increasing the price for the 1993 edition by 20%, to $2.64
million.
The addendum provided that a similar price increase
would be required in the event the United States and Mexico also
participated in the 1995 and 1997 editions.
The addendum was
signed by HAWILLA and Co-Conspirator #1.

60.
In addition to paying the rights acquisition fee
specified in the contract, HAWILLA paid a bribe to CoConspirator #1 to obtain the latter's signature on the 1991 Copa
America Contract.
On or about January 23, 1991, there was a
signing ceremony at CONMEBOL headquarters in Asuncion with other

CONMEBOL officials.
At that time, HAWILLA signed the contract,
as did the various CONMEBOL officials except Co-Conspirator #1.

Thereafter, in a private meeting, Co-Conspirator #1 told
HAWILLA, in sum and substance, that HAWILLA would make a lot of
money from the rights he was acquiring and that Co-Conspirator
#1 did not think it was fair that he (Co-Conspirator #1) did not
also make money.
Co-Conspirator #1 told HAWILLA that he would
not sign the contract if HAWILLA did not agree to pay him a
bribe.
After HAWILLA agreed to make the payment, Co-Conspirator
#1 signed the contract.
HAWILLA caused the payment - a six24
--
---------------------------
--------------------
--------------------
figure U.S. dollar payment - to be made to an account designated

by Co-Conspirator #1.
61.
In approximately 1993 or 1995, Co-Conspirator #1
began demanding additional bribe payments around the time each

edition of the tournament contemplated by the 1991 Copa America
Contract was played,
HAWILLA agreed to make these payments and
caused them to be made.

62.
On or about March 6, 1996, Traffic, operating
through TRAFFIC INTERNATIONAL, entered into a new contract with

_CONMEBOL to acquire the exclusive worldwide commercial rights
for the 1999, 2001, and 2003 editions of the Copa America (as
amended, the "1996 Copa America Contract").
(In response to a
later request by FIFA to ultimately make the tournament a

quadrennial instead of biennial event to ease the pressure on
European clubs, CONMEBOL moved the 2003 edition to 2004.
The
move was part of a transitional period during which the

tournament was held once every three years, in 2001, 2004, and
2007, before switching thereafter to a quadrennial format.)
63.
The 1996 Copa America Contract, signed by
HAWILLA and nine CONMEBOL officials inMar del Plata, Argentina,

was for $24 million: $6 million for 1999, $8 million for 2001,
and $10 million for 2003.
By virtue of a subsequent addendum

25
------~--------------------------------
----------------------
executed by the parties in 2001, the value of the contract

increased by a further $4 million - reflecting a $2 million
increase for each of the remaining two editions. The 1996 Copa
America Contract expressly contemplated that the United States
and Mexico might again be the two teams invited from other
confederations to participate in the tournament.
64.
Once again, in addition to paying the rights
acquisition fee specified in the contract, HAWILLA paid a bribe

to Co-Conspirator #1 to obtain the latter's signature on the
contract.
The bribe demand followed the same general pattern as
with the 1991 Copa America Contract.
Co-Conspirator #1 again
withheld his signature from the contract and made the bribe
demand in a private meeting with HAWILLA after HAWILLA and the
other CONMEBOL officials had signed it.
HAWILLA again agreed to
make the payment, which was significantly higher, and caused the
payment to be made to an account designated by Co-Conspirator
#1.
65.
In addition, Co-Conspirator #1 continued to
demand additional bribe payments, in increasing amounts, around

the time each edition of the tournament contemplated by the 1996
Copa America Contract was played.
HAWILLA again agreed to make
these payments and caused them to be made.
26
-----,-
66.
------------------------------ - - - - - - - - - - - - - - - -
-----------,
As early as 1997, Traffic maintained bank
accounts in the United States and used the wire facilities of

the United States to transfer payments in connection with
Traffic's exploitation of media and marketing rights associated
with the Copa America.
67.
In 2004, TRAFFIC INTERNATIONAL used the wire
facilities of the United States to transfer funds from its

account at Delta National Bank & Trust Co. in Miami, Florida in
satisfaction of the $12 million in contract payments due to
CONMEBOL for the rights associated with the 2004 edition of the
Copa America:
DATE
WIRE COMMUNICATION
January 12, 2004
Wire transfer of $1,200,000 from

TRAFFIC INTERNATIONAL's account at
Delta National Bank & Trust Co. in
Miami, Florida, to a Banco do
Brasil correspondent account in
New York, New York, for credit to
an account in the name of CONMEBOL
at Banco do Brasil in Asuncion,
Paraguay.
March 29, 2004

Brasil correspondent account 1n
Paraguay.
May 13, 2004

27

Miami, Florida; to a Banco do
Paraguay.
June 2, 2004

Paraguay.
June 3, 2004
Wire transfer of $600,000 from

Paraguay.

68.
On or about January 12, 2001, TRAFFIC
INTERNATIONAL entered into a new contract with CONMEBOL to

'
acquire the exclusive worldwide commercial rights for the 2005,

2007, and 2009 editions of the Copa America (as amended, the
"2001 Copa America Contract").
(By virtue of the shift in
schedule noted above, the three editions contemplated by this

contract were ultimately re-scheduled to 2007, 2011, and 2015.)
28
69.
The 2001 Copa America Contract, signed by HAWILLA
and 14 CONMEBOL officials in Bogota, Colombia, was for $46

million: $13 million, $15 million, and $18 million for the three
editions, respectively.
By virtue of subsequent agreements, the
value of the 2001 Copa America Contract increased by a further

$9 million - reflecting a $2 million increase for the 2007
edition and a $7 million increase for the 2011 edition.

70.
Once again, in addition to paying the rights
acquisition fee specified in the contract, HAWILLA paid a bribe

to Co-Conspirator #1 to obtain the latter's signature on the
contract.
The bribe scheme followed the same general pattern as
with the 1991 Copa America Contract and the 1996 Copa America
Contract.
Moreover, Co-Conspirator #1 again demanded an
additional payment in connection with the first tournament

contemplated by the 2001 Copa America Contract, and HAWILLA
again agreed to make the payment and caused it to be made.
71.
From 2006 to 2007, TRAFFIC INTERNATIONAL used the
wire facilities of the United States to transfer funds from its

account at Delta National Bank & Trust Co. in Miami, Florida in
satisfaction of the $15 million in contract payments due to
CONMEBOL for the rights associated with the 2007 edition of the
Copa America:
29
DATE
WIRE COMMUNICATION
July 21, 2006

Paraguay.
March 14, 2007

Paraguay.
March 26, 2007

Paraguay.
May 30, 2007

Paraguay.
June 13, 2007

30

Paraguay.
72.
From 2010 to 2011, TRAFFIC INTERNATIONAL again
used the wire facilities of the United States to transfer funds

from its account at Delta National Bank & Trust Co. in Miami,
Florida in satisfaction of the $22 million in contract payments
due to CONMEBOL for the rights associated with the 2011 edition
of the Copa America:
DATE
WIRE COMMUNICATION
November 8, 2010

Paraguay.
November 12, 2010

Paraguay.
March 4, 2011

New York, New York, for cr.edi t to
31

Paraguay.
June 10, 2011

Paraguay.
June 28, 2011

TRAFFIC INTERNAT-IONAL's account at
Paraguay.
Money Laundering Techniques

73.
HAWILLA and his co-conspirators used a number of
sophisticated money laundering techniques, including the use of

a numbered account at a Swiss bank, currency dealers, and
trusted intermediaries, to effect bribe and kickback payments in
a manner that concealed their true source and nature and
promoted the corrupt schemes.
HAWILLA was particularly reliant

'
on intermediaries to make the bribe payments to Co-Conspirator

#1 in connection with the Copa America, described above.
One
such intermediary was a late friend of HAWILLA and two of that

friend's surviving family members, Co-Conspirator #2 and Co32
Conspirator #3.
This family, which controlled the Intermediary,
used accounts held in the names of offshore corporations at

United States financial institutions to make payments on
HAWILLA's behalf.
Revenues, Profits, and the United States Market
74.
The revenue generated by the commercialization of
media and marketing rights associated with the Copa America

increased dramatically over the course of the tournament
editions covered by the 1991 Copa America Contract, 1996 Copa
America Contract, and 2001 Copa America Contract, all of which
HAWILLA obtained through bribery.
Over time, these increases in
revenue, and associated increases in profits, arose in

significant part from HAWILLA and Traffic's successful promotion
and commercialization of the Copa America in the United States,
including through contractual relationships with an array of
broadcasters and advertisers based in the United States.
75.
For example, the 2001 Copa America- the second
edition of the tournament played under the 1996 Copa America

Contract - was quite profitable for Traffic.
According to its
internal financial records, Traffic's revenues from the

tournament totaled $31.9 million, with profits totaling over
$9.9 million, owing in part to the sale of broadcast and
33
advertising rights to broadcast networks and beverage companies

based in the United States.
76.
To take another example, the 2007 Copa America-
the first edition of the tournament played under the 2001 Copa
America Contract - was even more profitable for Traffic than the
2001 edition.
According to its internal financial records,
Traffic's revenues from the tournament totaled $64.2 million,

comprising $45.9 million from the sale of broadcasting rights
and $18.3 million from the sale of sponsorship rights.
Traffic's profits from the tournament were $29.1 million.
Traffic's television broadcasting revenues from the United
States/Canadian market - $12.8 million - were its highest from
any market worldwide.
Traffic's revenues from radio
broadcasting and mobile telephone/Internet services in the

United States market were similarly its highest worldwide.
77.
The value of the sponsorship rights owned. by
Traffic also increased over time, owing in part to increased

interest in the tournament in the United States.
For example,
for the 2011 edition of the Copa America, Traffic sold

sponsorship rights to 10 official sponsors, up from seven
official sponsorships sold for the 2007 edition.
The official
sponsors included major beverage companies based in the United

States.
Sponsorship fees more than tripled between 2007 and

34
---------------~----
2011.
--~--------------------~----
In a lawsuit filed in Florida state court, described
further below, Traffic described the 2011 Copa America as "the

most popular sporting event in the world in 2011[, which] was
watched by a cumulative audience of over five billion people
worldwide."
78.
Traffic used its presence "in the United States to
assist it in exploiting the United States market.
For example,
TRAFFIC INTERNATIONAL - the rights holder for the Traffic Group

beginning with the 1999 edition - assigned to TRAFFIC USA a
portion of the rights it held under the 2001 Copa America
Contract.
TRAFFIC USA exploited those rights in the United
States by contracting directly with television and radio

networks based in the United States and serving as an agent for
Traffic in connection with the sale of global sponsorship
rights.
The Florida Lawsuit and the 2013 Copa America Contract
79.
In late 20i1, TRAFFIC INTERNATIONAL and TRAFFIC
USA filed a complaint alleging breach of contract against

CONMEBOL and various affiliated officials and sports marketing
companies.
The lawsuit was filed in Florida state court by
virtue of a forum selection clause in the 2001 Copa America

Contract designating the courts of Florida as the forum of
35
-------
-----------------------
choice in the event FIFA declined to arbitrate, as it ultimately

did.
80.
The original complaint alleged in pertinent part
as follows:
This Complaint seeks urgent injunctive relief to
prevent a willful, flagrant and deliberate breach of
contract. The contract at issue grants to Traffic the
unique and exclusive rights to promote, market and
commercially exploit the 44th edition of the Copa
America soccer tournament to be conducted in 2015 and
an option to retain those rights for the following
three editions of the Copa America tournament.
The
CONMEBOL defendants [CONMEBOL and its federations] ,
who expressly granted those exclusive commercial
rights to Traffic, have, without the least
justification or defense, purported to enter into an
agreement authorizing a third party . . . - Defendant
[Sports Marketing Company A] - to exercise the very
same rights.
(~
1) .
According to the complaint, at a meeting held in April
2010, CONMEBOL, through its president and executive committee

and without Traffic's knowledge, passed a resolution granting
the rights to the 2015, 2019, and 2023 editions of the Copa
America, among other tournaments, to Sports Marketing Company A,
and entered into a contract with Sports Marketing Company A six
weeks later.
(~
77 & Ex. I).
81.
The lawsuit was settled in or about June 2013.
82.
In the months preceding the settlement, HAWILLA
and other representatives of Traffic began meeting with CoConspirator #4, Co-Conspirator #5, and Co-Conspirator #6 - high36
ranking executives of Sports Marketing Company A and Sports

Marketing Company B - to discuss a resolution of the lawsuit
that would involve Sports Marketing Company A and Sports
Marketing Company B agreeing to share with Traffic the
commercial rights obtained by Sports Marketing Company A from
CONMEBOL to exploit the above editions of the Copa America in
exchange for Traffic agreeing to end the lawsuit and assume its
share of the costs associated with those rights.
Specifically,
the representatives of the three companies discussed forming a

new company that would obtain and exploit the commercial rights
to the 2015, 2019, and 2023 editions of the tournament, as well
as a special centennial edition of the tournament to be held in
the United States in 2016.
83.
By in or about March 2013, the discussions
regarding the formation of the company advanced significantly.

Those discussions included settlement of the Florida state court
litigation, the percentage of shares each member would hold in
the new company, and the operations of the new company.
After a
larger meeting in Buenos Aires in or about March 2013, HAWILLA

had a brief, smaller meeting with representatives of Sports
Marketing Company A and Sports Marketing Company B.
representative of Sports Marketing Company A told HAWILLA that

Sports Marketing Company A and Sports Marketing Company B had
37
already agreed to make bribe payments to CONMEBOL officials in

connection with the Copa America rights.
HAWILLA was asked to
contribute $10 million toward the cost of expenses to date.

HAWILLA understood some or all of what he was being asked to
contribute would go to bribe payments.
HAWILLA agreed to make
these bribe payments and caused them to be made.

84.
The creation of the new company, Datisa, was
formalized in a shareholders' agreement dated May 21, 2013.

Among other things, the agreement provided that TRAFFIC
INTERNATIONAL, Sports Marketing Company A, and Sports Marketing
Company B each held a one-third interest in the company.
85.
Four days later, in London, Datisa entered into a
contract with CONMEBOL and Sports Marketing Company A whereby

Datisa obtained from CONMEBOL the exclusive worldwide commercial
rights to the 2015, 2019, and 2023 editions of the Copa America
and the 2016 Copa America Centenario, and CONMEBOL and Sports
Marketing Company A assigned to Datisa the contracts related
thereto that they had already executed with third parties (the
"2013 Copa America Contract").
The 2013 Copa America Contract,
dated May 25, 2013 and signed by representatives of each of

Datisa's three shareholders and 12 CONMEBOL officials, was for
$317.5 million: $75 million for the 2015 edition, $77.5 million
38
for the 2016 edition, $80 million for the 2019 edition, and $85
million for the 2023 edition.
86.
Datisa agreed to pay $100 million in bribes to
CONMEBOL officials - all of whom were also FIFA officials - in

exchange for the 2013 Copa America Contract: $20 million for
contract signature and $20 million for each of the four editions
of the tournament.
Each $20 million payment was to be divided
among the bribe recipients: $3 million to each of the "top"

three CONMEBOL officials; $1.5 million to each of seven other
CONMEBOL officials; and $500,000 to an eleventh CONMEBOL
official.
87.
The following four payments, including three
international wire transfers using the wire facilities of the

United States, represent TRAFFIC INTERNATIONAL's one-third
contribution to the other shareholders of Datisa, who were
responsible for paying the first $40 million in bribes to the
CONMEBOL officials (i.e., for contract signing and the 2015
edition), totaling $13.333 million.
DATE
WIRE COMMUNICATION
June 17, 2013

Miami, Florida, to a Citibank
correspondent account in New York,
New York, for credit to an account
in the name of Sports Marketing
39
------------------------l
Company A at Banco Hapoalim Ltd.
in Zurich, Switzerland.
June 17, 2013

Miami, Florida, to a JP Morgan
Chase correspondent account in New
York, New York, for credit to an
account in the name of Sports
Marketing Company B at Bank Julius
Baer & Co. in Zurich, Switzerland.
September 11, 2013

Datisa's account at Banco Hapoalim
Ltd. in Zurich, Switzerland, via
Citibank and JP Morgan Chase
correspondent accounts in New
York, New York, for credit to
Sports Marketing Company B at Bank
Julius Baer & Co. in Zurich,
Switzerland.
A fourth payment of $1,666,667 was made, also on or about

September 11, 2013, by a transfer from an account in the name of
Datisa S.A. at Banco Hapoalim Ltd. in Zurich, Switzerland to an
account in the name of Sports Marketing Company A at the same
bank.
Copa America Centenario
88.
In 2012, the then-acting president of CONCACAF
informally announced that a special, Pan-America edition of the

Copa America would be held in 2016, involving teams from
CONMEBOL and CONCACAF, to celebrate the 100th anniversary of the
first edition of the tournament.
40
The acting president stated
that he hoped the tournament would be hosted in the United

States because "the market is in the United States, the stadiums
are in the United States, [and] the people are in the United
States."'
89.
At a press conference held in Miami, Florida on
May 1, 2014, high-ranking officials of CONMEBOL and CONCACAF

officially announced that CONMEBOL would celebrate the 100th
anniversary of the Copa America by organizing a special edition
of the tournament for the entire hemisphere - to be called the
Copa America Centenario - to include all 10 CONMEBOL men's
national teams and the men's national teams of six CONCACAF
member associations, including the United States.
The
tournament was to be played at major sporting venues in various

cities in the United States in June 2016.
Datisa
representatives attended the press conference and the logo of

Datisa's trade name was included alongside the logos of CONCACAF
and CONMEBOL in various promotional materials.
90.
As set forth above, Datisa acquired the exclusive
commercial rights to the Copa America Centenario as part of the

2013 Copa America Contract.
In addition, Datisa contracted with
CONCACAF, in its capacity as the co-organizer of the tournament,

to acquire CONCACAF's rights to that tournament as well.
letter agreement dated March 4, 2014 (the "2014 Centenario
41
By
-------
Contract"), Datisa agreed to pay $35 million to CONCACAF for

those rights, which amount was in addition to the $77.5 million
Datisa had already agreed to pay to CONMEBOL, pursuant to the
2013 Copa America Contract, for CONMEBOL's rights to the same
tournament.
91.
Co-Conspirator #7, a senior TRAFFIC USA
executive, told HAWILLA that, following negotiations with CoConspirator #8, Co-Conspirator #9, and others, Datisa had agreed
to pay a multi-million dollar bribe to Co-Conspirator #8 to
secure the rights set forth in the previous paragraph.
HAWILLA
agreed to the bribe payment.

92~
In August 2014, a high-ranking CONMEBOL official
stated publicly: "The Americas are one, it is man who creates

frontiers.
I believe in a single America in a working context
with CONCACAF and we've reached something real which will go

ahead in 2016."
93.
On or about September 25, 2014, at a meeting of
the FIFA executive committee in Zurich, FIFA put its imprimatur

on the Copa America Centenario by placing the tournament on its
official calendar.
94.
By the terms of the 2014 Centenario Contract, the
first contract payment of $7 million from Datisa to CONCACAF was
42
due on or about April 3, 2014.
International wire transfer
records confirm the payment:
B.
DATE
WIRE COMMUNICATION
April 1, 2014

Datisa's account at Banco Hapoalim
Ltd. in Zurich, Switzerland, to a
JP Morgan Chase account in Miami,
Florida in the name of CONCACAF.
CONCACAF Gold Cup Bribery Scheme

95.
In or about 1991, CONCACAF began organizing and
promoting the Gold Cup, a tournament featuring member nations of

CONCACAF and, in later years, those of other confederations.
96.
In or about 1992, HAWILLA relocated to the United
States for various reasons, including to seek additional

business opportunities for. Traffic's United States affiliate in
the period leading up to the 1994 World Cup.
During this
period, HAWILLA and Co-Conspirator #10, a TRAFFIC USA executive

based in Miami, variously began negotiations with high-ranking
CONCACAF officials, including Co-Conspirator #11 and CoConspirator #12, for TRAFFIC USA to purchase the media and
marketing rights associated with the Gold Cup.
HAWILLA's pitch
to CONCACAF, in sum and substance, was that Traffic could

replicate the commercial and sporting success it had had with
the Copa America and make the Gold Cup a similar success.
On or
about October 3, 1994, TRAFFIC USA entered into a contract with

43
CONCACAF for $9,750,000 for the commercial rights associated

with the 1996, 1998, and 2000 editions of the Gold Cup.
97.
Beginning with the 1996 Gold Cup and continuing
for four subsequent editions of the tournament (1998, 2000,

2002, and 2003), pursuant to the contract with TRAFFIC USA (as
subsequently amended and renewed following additional
negotiations), CONCACAF granted to TRAFFIC USA the exclusive
worldwide commercial rights to the Gold Cup.
98.
During this period, HAWILLA and Co-Conspirator
#10 together caused hundreds of thousands of dollars in bribe

payments to be made to Co-Conspirator #11 and Co-Conspirator
#12.
99.
Traffic did not hold the media and marketing
rights associated with the Gold Cup for the 2005, 2007, 2009,
and 2011 editions.
100. In 2011, Co-Conspirator #11 and Co-Conspirator
#12 resigned from CONCACAF and were ultimately replaced the
following year by two other high-ranking officials, CoConspirator #8 and Co-Conspirator #9.
101. Co-Conspirator #9, the former employee of TRAFFIC
USA, entered into negotiations with TRAFFIC USA for the
commercial rights associated with the 2013 Gold Cup.
Co-
Conspirator #7 was involved in those negotiations on behalf of

44
TRAFFIC USA.
Ultimately, on or about November 27, 2012,
CONCACAF and TRAFFIC USA entered into a $15.5 million contract

for the exclusive worldwide commercial rights for the 2013
edition of the Gold Cup and the 2013-14 and 2014-15 seasons of
the CONCACAF Champions League, a club tournament (the "2012 Gold
Cup/Champions League Contract").
102. Co-Conspirator #7 told HAWILLA that, in addition
to the contract price, TRAFFIC USA agreed to pay Co-Conspirator
#8 an approximately $1 million bribe in exchange for CoConspirator #8's agreement to award the 2012 Gold Cup/Champions
League Contract to TRAFFIC USA.
HAWILLA agreed to the bribe
payment.
103. The following domestic and international wire
transfers are examples of bribe and contract payments made in
connection with the 2012 Gold Cup/Champions League Contract:
DATE
WIRE COMMUNICATION
February 15, 2013

TRAFFIC USA's account at Citibank
N.A. in Miami, Florida, to
CONCACAF's account at JP Morgan
Chase Bank N.A. in New York, New
York.
March 28, 2013

York.
45
June 28, 2013

York.
August 28, 2013

York.
December 4, 2013

Miami, Florida, to a Wells Fargo
correspondent account in New York,
New York, for credit to an account
in the name of Company D, a
Panamanian company, the identity
of which is known to the United
States Attorney, at Capital Bank
Inc. in Panama City, Panama.
April 30, 2014

York.
104. On or about November 15, 2013, TRAFFIC USA

entered into a $60 million renewal contract for exclusive
sponsorship rights associated with the 2015, 2017, 2019 ' and
2021 .editions of the Gold Cup and the 2015-16, 2016-17, 2017-18,
2018-19, 2019-20, 2020-21, and 2021-22 editions of the CONCACAF
Champions League (the "2013 Gold Cup/Champions League
46
Contract").
Co-Conspirator #7 led the negotiations on behalf of
TRAFFIC USA and Co-Conspirator #9 led the negotiations on behalf

of CONCACAF.
105. Co-Conspirator #7 told HAWILLA that, in addition
to the contract price, TRAFFIC USA agreed to pay Co-Conspirator
#8 a $2 million bribe in exchange for Co-Conspirator #8's
agreement to award the 2013 Gold Cup/Champions League Contract
to TRAFFIC USA.
HAWILLA agreed to the bribe payment.
106. The following domestic wire transfer represents

the only payment due under the 2013 Gold Cup/Champions League
Contract until 2015:
c.
DATE
WIRE COMMUNICATION
December 20, 2013

York.
Sponsorship Bribery and Kickback Scheme

107. The Brazilian national team won the 1994 World
Cup, which was hosted by the United States in June and July of
that year.
Around the same time, a representative of a
multinational sportswear company headquartered in the United

States ("Sportswear Company E") approached CBF to determine
whether CBF, Brazil's national soccer federation and one of the
47
constituent member associations of FIFA, was interested in being

sponsored by Sportswear Company E.
At the time, CBF already had
a sponsorship agreement with another American sportswear company

("Sportswear Company F").
Thereafter Co-Conspirator #13, a
high-ranking CBF official, and HAWILLA, on behalf of Traffic

Brazil, which at the time served as CBF's marketing agent, began
negotiations with representatives of Sportswear Company E.
108. The negotiations lasted into 1996.
The parties
ultimately agreed to a 10-year deal, which required, among other

things, that Sportswear Company E compensate Sportswear Company
F, which agreed to terminate its existing contract with CBF.
109. On or about July 11, 1996, the parties met in New
York City for the closing.
The contract was executed by Co-
Conspirator #13 on behalf of CBF, HAWILLA on behalf of Traffic

Brazil, and four representatives of Sportswear Company E.
Among
other terms, the contract, a 44-page Sponsorship and Endorsement

Agreement (the "Agreement"), required Sportswear Company E to
pay CBF $160 million over 10 years for the right to be one of
CBF's co-sponsors and to be CBF's exclusive footwear, apparel,
accessories, and equipment supplier.
CBF remitted a percentage
of the value of the payments it received under the Agreement to

Traffic Brazil.
48
110. HAWILLA agreed to pay and did pay Co-Conspirator

#13 half of the money he made from the deal, totaling in the
millions, as a bribe and kickback.
111. On or about January 25, 2002, the parties agreed
to terminate the Agreement before the end of the 10-year term,
ending any further obligations thereunder between Sportswear
Company E and CBF, and between Sportswear Company E and Traffic
Brazil.
D.
Copa do Brasil Bribery Scheme

112. Between approximately 1990 and 2009, Traffic
Brazil entered into a series of contracts with CBF to acquire

the commercial rights associated with the Copa do Brasil, an
annual tournament for Brazil's top club teams.
113. From time to time during the above period, CoConspirator #13 would demand, and HAWILLA would pay, bribes in
connection with the Copa do Brasil contracts.
114. On or about January 22, 2009, Traffic Brazil and
CBF entered into three contracts covering the commercial rights
for each edition of the Copa do Brasil tournament from 2009
through 2014.
Traffic Brazil agreed to pay approximately 55
million Brazilian reais, which at the time equated to

approximately $23.4 million, for the rights.
49
115. On or about December 8, 2011, one of Traffic's

competitors, Sports Marketing Company C, entered into a contract
with CBF to purchase the commercial rights for all editions of
the Copa do Brasil between 2015 and 2022.
Sports Marketing
Company C agreed to pay approximately 128 million reais, which

at the time equated to approximately $70.6 million, for the
rights.
116. The signing of the foregoing contract led to a
dispute between HAWILLA and Co-Conspirator #14, a senior
executive of Sports Marketing Company C.
117. On or about August 15, 2012, Traffic Brazil and
Sports Marketing Company C entered into a contract to pool their
marketing rights for future editions of the tournament, from
2013 to 2022, and to share equally in the profits.
As part of
the contract, Traffic Brazil also agreed to pay 12 million reais

to Sports Marketing Company C over the course of the contract.
118. Co-Conspirator #14 informed HAWILLA that he had
agreed to pay a yearly bribe to Co-Conspirator #13.
co-
Conspirator #14 informed HAWILLA that he had traveled to the

United States at one point to discuss the matter with CoConspirator #13.
Co-Conspirator #14 informed HAWILLA that the
bribe payment subsequently increased when other CBF officials,

specifically, Co-Conspirator #15 and Co-Conspirator #16,
50
required bribe payments as well.
HAWILLA agreed to pay half the
cost of the bribe payments, which totaled 2 million reais per

year, to be divided among Co-Conspirator #13, Co-Conspirator
#15, and Co-Conspirator #16.
119. The following two wire transfers using the wire
facilities of the United States - one from TRAFFIC
INTERNATIONAL, the other from Sports Marketing Company C - were
made in furtherance of the Copa do Brasil bribery scheme:
DATE
WIRE COMMUNICATION
December 5, 2013

Sports Marketing Company C's
account at Itau Unibanco S.A. in
New York, New York, to a J.P.
Morgan Chase correspondent account
in New York, New York, for credit
to the account of a luxury yacht
manufacturer at HSBC Bank PLC in
London, England.
December 23, 2013

Miami, Florida, to a Banco Itau
S.A. account in New York, New York
in the name of Sports Marketing
Company C.
* * * *
120~
Though HAWILLA's co-conspirators in the foregoing
bribery and kickback schemes included FIFA and CONCACAF

officials, among others, no disclosure of any of the foregoing
51
schemes was made to the FIFA or CONCACAF executive committee or

congress.
COUNT ONE
(Racketeering Conspiracy)
121. The allegations contained in paragraphs 1 through
paragraph.
122. In or about and between January 1991 and the
present, both dates being approximate and inclusive, within the
Eastern District of New York and elsewhere, the defendant JOSE
HAWILLA, together with others, being a person employed by and
associated with the enterprise, which engaged in, and the
activities of which affected, interstate and foreign commerce,
did knowingly and intentionally conspire to violate Title 18,
United States Code, Section 1962(c), that is, to conduct and
participate, directly and indirectly, in the conduct of the
affairs of such enterprise through a pattern of racketeering
activity, as defined in Title 18, United States Code, Sections
1961(1) and 1961(5).
123. The pattern of racketeering activity through
which the defendant JOSE HAWILLA, together with others, agreed
to conduct and participate, directly and indirectly, in the
52
conduct of the affairs of the enterprise consisted of multiple

acts indictable under:
(a)
Title 18, United States Code, Section 1343

(wire fraud, including honest-services wire
fraud) ;
(b)
Title 18, United States Code, Sections 1956

and 1957 (money laundering and money
laundering conspiracy) ;
(c)

(interstate and foreign travel in-aid-of
racketeering) ; and
(d)

(obstruction of justice) ;
and multiple acts involving bribery, in violation of New York

State Penal Law Sections 180.03 and 180.08.
HAWILLA agreed that
a conspirator would commit at least two acts of racketeering

activity in the conduct of the affairs of the enterprise, the
last of which would occur within 10 years of a prior act of
racketeering activity.
(Title 18, United States Code, Sections 1962(d), 1963
and 3551 et seq.)
53
COUNT TWO
(Wire Fraud Conspiracy - Copa America Bribe Scheme)
paragraph.
125. In or about and between April 2010 and February
Southern District of New York, the defendants JOSE HAWILLA,
TRAFFIC SPORTS USA, INC., and TRAFFIC SPORTS INTERNATIONAL,
INC., together with others, did knowingly and intentionally
conspire to devise a scheme and artifice to defraud FIFA and
CONCACAF, including to deprive FIFA and CONCACAF of their
respective rights to honest and faithful services through bribes
and kickbacks, and to obtain money and property by means of
materially false and fraudulent pretenses, representations and
promises, and for the purpose of executing such scheme and
artifice, to transmit and cause to be transmitted by means of
wire communication in interstate and foreign commerce, writings,
signs, signals, pictures and sounds, to wit: wire transfers,
contrary to Title 18, United States Code, Section 1343.
(Title 18, United States Code, Sections 1349 and 3551
et seq.)
54
COUNT THREE
(Money Laundering Conspiracy - Copa America Bribe Scheme)
paragraph.
127. In or about and between April 2010 and February
Southern District of New York, the defendant JOSE HAWILLA,
together with others, did knowingly and intentionally conspire
to transport, transmit and transfer monetary instruments and
funds, to wit: wire transfers, from places in the United States
to and through places outside the United States and to places in
the United States from and through places outside the United
States, with the intent to promote the carrying on of specified
unlawful activity, to wit: wire fraud, contrary to Title 18,
United States Code, Section 1343, all contrary to Title 18,
United States Code, Section 1956(a) (2) (A).
(Title 18, United States Code, Sections 1956(h) and
3551 et seq.)
55
COUNT FOUR
(Obstruction of Justice)
paragraph.
129. In or about and between June 2012 and February
Eastern District of New York and elsewhere, the defendant JOSE
HAWILLA, together with others, did knowingly, intentionally and
corruptly (1) attempt to persuade another person, to wit: John
Doe, an individual whose identity is known to the United States
Attorney, with intent to hinder, delay and prevent the
communication to one or more law enforcement officers of the
United States, to wit: Special Agents of the Federal Bureau of
Investigation, of information relating to the commission and
possible commission of federal offenses, and (2) obstruct,
influence and impede, and attempt to obstruct, influence and
impede, an official proceeding, to wit: a Federal Grand Jury
investigation in the Eastern District of New York.
(Title 18, United States Code, Sections 1512(b) (3),
1512(c) (2) and 3551 et seq.)
56
CRIMINAL FORFEITURE ALLEGATION AS TO COUNT ONE

130. The United States hereby gives notice to the
defendant JOSE HAWILLA that, upon his conviction of the offense
charged in Count One, the government will seek forfeiture in
accordance with Title 18, United States Code, Section 1963(a),
which requires any person or entity convicted of such offense to
forfeit:
(a) any interest acquired or maintained in violation of
Title 18, United States Code, Section 1962;
(b) any interest in,
security of, claim against, or property or contractual right of

any kind affording a source of influence over, any enterprise
which the defendant established, operated, controlled,
conducted, or participated in the conduct of, in violation of
Title 18, United States Code, Section 1962, and (c) any property
constituting, or derived from, any proceeds obtained, directly
or indirectly, from racketeering activity in violation of Title
18, United States Code, Section 1962.
131. If any of the above-described forfeitable
(a)
(b)
has been transferred or sold to, or
diligence;
deposited with, a third party;
57
(c)
(d)
(e)
has been commingled with other property
the court;
or
which cannot be divided without difficulty;

United States Code, Section 1963(m), to seek forfeiture of any
forfeitable property.
(Title 18, United States Code, Sections 1963(a) and
1963 (m) )
defendants that, upon their conviction of the offense charged in
Count Two, the government will seek forfeiture in accordance
with Title 18, United States Code, Section 981(a) (1) (C) and
Title 28, United States Code, Section 2461(c), which require any
person convicted of such offense to forfeit any and all
property, real or personal, which constitutes or is derived from
proceeds traceable to a violation of such offense.
property, as a result of any act or omission of the defendants:
58

diligence;
the court;
or
United States Code, Section 2461(c), to seek forfeiture of any
other property of the defendants up to the value of the
(Title 28, United States Code, Section 2461(c); Title
18, United States Code, Section 981(a) (1) (C); Title 21, United
States Code, Section 853(p))
59
CRIMINAL FORFEITURE ALLEGATION AS TO COUNT THREE

defendant JOSE HAWILLA that, upon his conviction of the offense
charged in Count Three, the government will seek forfeiture in
accordance with Title 18, United States Code, Section 982(a) (1),
which requires any person convicted of such offense to forfeit
any and all property, real or personal, involved in such
offense, or any property traceable to such offense.
diligence;
the court;
or
60
United States Code, Section 982(b), to seek forfeiture of any

forfeitable property described in this forfeiture allegation .
(Title 18, United States Code, Sections 982(a) (1) and
982(b); Title 21 , United States Code, Section 853(p))

61

FIFA Indictments With Full List of Charges

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CMP:EMN/AH/DAL/BDM

UNITED STATES OF AMERICA

THE UNITED STATES ATTORNEY CHARGES:

The Federation Internationale de Football

Association ("FIFA") was the international body governing

FIFA was an entity registered under Swiss law and

headquartered in Zurich, Switzerland.

FIFA was composed of as

many as 208 member associations, each representing organized

The World Cup, soccer's premier event, was a

quadrennial international tournament organized by FIFA involving

In 2006, the World Cup was held in Germany (the

FIFA established rules governing, among other

The FIFA Ticketing Office ("FTO") was the

official sales agent with respect to the distribution of tickets

The FTO was

operated by an event-management company engaged by FIFA.

From in or about and between 2005 and 2011, both

dates being approximate and inclusive, the defendant DARYAN

In advance of the 2006 World Cup, the defendant

DARYAN WARNER and Co-Conspirator #1, a ticket broker based in

WARNER's role in the scheme was to purchase tickets from the

After purchasing the tickets, WARNER would sell them to

Co-Conspirator #1, who, in turn, would sell them to, among

Prior to 2006, the FTO had advised the defendant

DARYAN WARNER that it would not sell him tickets if WARNER

It was part of the scheme that the defendant

DARYAN WARNER attempted to purchase, and did purchase, tickets

Because WARNER knew that the FTO would not sell

the tickets to him for resale to Co-Conspirator #1, WARNER

For example, on one occasion, when asked by

It was further part of the scheme that the

defendant DARYAN WARNER sought to disguise and conceal his

Among other things, the defendant DARYAN WARNER,

together with Co-Conspirator #1, agreed to provide, and did

provide, to the FTO and to the auditing firm documents that

As a result of the scheme, the defendant DARYAN

WARNER and Co-Conspirator #1 made a substantial profit from the

FIFA became aware that the defendant DARYAN

As a result, WARNER understood and

Further, WARNER understood and believed that the FTO

Nevertheless, the defendant DARYAN WARNER

continued his scheme with Co-Conspirator #1 to obtain 2010 World

It was part of the scheme that, for the purpose

of causing the FTO to provide him with tickets that he could

the United States Attorney (the "Two Family Members"), to obtain

WARNER understood and

After receiving the tickets from his Two Family

Members, the defendant DARYAN WARNER, along with Co-Conspirator

WARNER and Co-

Conspirator #1 made a substantial profit from the sale of

The allegations contained in paragraphs 1 through

15 are realleged and incorporated as if set forth fully in this

In or about and between 2005 and 2011, both dates

being approximate and inclusive, within the Southern District of

transmitted in interstate and foreign commerce, writings, signs,

The allegations contained in paragraphs 1 through

17 are realleged and incorporated as if fully set forth in this

In or about and between 2005 and 2011, both dates