The United States vs Jeffrey Webb, Jack Warner and Others

United States District Court

Eastern District of New York

Extract

G 2010 FIFA World Cup Vote Scheme

185. In or about 2004, the FIFA executive committee considered bids front Morocco, South Africa and Egypt, as well as other nations that withdrew before the vote, to host the 2010 World Cup.

186. Previously, the defendant JACK WARNER and his family had cultivated ties with South African soccer officials in connection with and subsequent to a failed bid by South Africa to host the 2006 World Cup. In the early 2000s, Co­ Conspirator #14, a member of WARNER's family, had used WARNER's contacts in South Africa to organize friendly matches for CONCACAF teams to play in South Africa.

At one point, WARNER also directed Co-Conspirator #14 to fly to Paris, France and accept a briefcase containing bundles of U.S. currency in $10,000 stacks in a hotel room from Co-Conspirator #15, a high­ ranking South African bid committee official. Hours after arriving in Paris, Co-Conspirator #14 boarded a return flight and carried the briefcase back to Trinidad and Tobago, where Co­ Conspirator #14 provided it to WARNER.

187. In the months before the selection of the host nation for the 2010 World Cup, which was scheduled to take place in May 2004, the defendant JACK WARNER and Co-Conspirator #1 traveled to Morocco as they had done in 1992, in advance of the voting for the 1998 World Cup host. While in Morocco during the 2004 trip, a representative of the Moroccan bid committee offered to pay $1 million to WARNER in exchange for his agreement to cast his secret ballot on the FIFA executive committee for Morocco to host the 2010 World Cup.

188. Subsequently, Co-Conspirator #1 learned from the defendant JACK WARNER that high-ranking officials of FIFA, the South African government, and the South African bid committee, including Co-Conspirator #16, were prepared to arrange for the government of South Africa to pay $10 million to CFU to "support the African diaspora." Co-Conspirator #1 understood the offer to be in exchange for the agreement of WARNER, Co-Conspirator #1, and Co-Conspirator #17 to all vote for South Africa, rather than Morocco, to host the 2010 World Cup.

At the time, Co-Conspirator #17, like WARNER and Co-Conspirator #1, was a FIFA executive committee member. WARNER indicated that he had accepted the offer and told Co-Conspirator #1 that he would give a $1 million portion of the $10 million payment to Co-Conspirator #1.

189. In FIFA's executive committee vote held on May 15, 2004, South Africa was selected over Morocco and Egypt to host the 2010 World Cup. The defendant JACK WARNER , Co-Conspirator #1, and Co-Conspirator #17 indicated that they voted for South Africa.

190. In the months and years after the vote, Co-Conspirator #1 periodically asked WARNER about the status of the $ 10 million payment.

191. At one point, Co-Conspirator #1 learned that the South Africans were unable to arrange for the payment to be made directly from government funds. Arrangements were thereafter made with FIFA officials to instead have the $10 million sent from FIFA - using funds that would otherwise have gone from FIFA to South Africa to support the World Cup - to CFU.

192. In fact, on January 2, 2008, January 31, 2008 and March 7, 2008, a high-ranking FIFA official caused payments of $616,000, $1,600,000, and $7,784,000 - totaling $10 million - to be wired from a FIFA account in Switzerland to a Bank of America correspondent account in New York, New York , for credit to accounts held in the names of CFO and CONCACAF, but controlled by the defendant JACK WARNER, at Republic Bank in Trinidad and Tobago.

193 . Soon after receiving these wire transfers, the defendant JACK WARNER caused a substantial portion of the funds to be diverted for his personal use. For example, on January 9, 2008, WARNER directed Republic Bank officials to apply $200,000 of the $616,000 that had been transferred into a CFO account from FIFA one week earlier toward a personal loan account held in his name.

194. The defendant JACK WARNER also diverted a portion of the funds into his personal accounts by laundering the funds through intermediaries. For example, during the period from January 16, 2008 to March 27, 2008, WARNER caused approximately $1.4 million of the $10 million to be transferred to Individual #1, a Trinidadian businessman whose identity is known to the Grand Jury, and Trinidadian Company A, a large supermarket chain in Trinidad and Tobago controlled by Individual #1. Weeks later, checks totaling approximately the same amount and drawn on an account held in the name of Trinidadian Company B, a real estate and investment company also controlled by Individual #1, were deposited into a bank account held in the name of WARNER and a family member at First Citizens Bank in Trinidad and Tobago. The identities of Trinidadian Company A and Trinidadian Company B are known to the Grand Jury.

195. During the three years following WARNER's receipt of the $10 million from FIFA, WARNER made three payments to Co­ Conspirator #1, totaling over $750,000, in partial payment of the $1 million that WARNER had earlier promised Co-Conspirator #1 as part of the bribe scheme.

196. The first payment, in the amount of $298,500, was made by wire transfer sent on or about December 19, 2008 from an account held in the name of CFU at Republic Bank in Trinidad and Tobago, to a Bank of America correspondent account in New York, New York, for credit to an account controlled by Co-Conspirator i1 at a bank in te Cayman Islands.

197. The second payment, in the amount of $205,000, was made by check drawn on an account held in the name of CFU at Republic Bank in Trinidad and Tobago. On or about September 27, 2010, Co-Conspirator #1 caused the check to be deposited into his Merrill Lynch brokerage account in New York, New York.

Approximately one month earlier, on or about August 23, 2010, WARNER sent an email to Co-Conspirator #1 to advise him that the payment was forthcoming.

198 . The third payment, in the amount of $250,000, was made by check drawn on an account held in the name of CFU at Republic Bank in Trinidad and Tobago. The check was delivered to Co-Conspirator #1 .by another individual who traveled by airplane from Trinidad and Tobago to JFK International Airport in Queens, New York , and hen to CONCACAF 's headquarters in New York , New York, where he delivered the check o Co-Conspirator #1. A representative of FirstCaribbean International Bank in the Bahamas, where Co-Conspirator #1 held another account, subsequently traveled by airplane to New York , landing at Kennedy Airport . After arriving, the ban k representative traveled to New York, New York, where he took custody of the check . He subsequently traveled to the Bahamas and, on or about May 3, 2011, deposited the check into Co-Conspirator #1's account. Approximately two months earlier, on or about March 13, 2011, WARNER sent an email to Co-Conspirator #1 to advise him that the payment was forthcoming.

199. Co-Conspirator #1 never received the balance of the promised $1 million payment.

Transcribed from the PDF. The full document can be accessed here.

Issued by the US DOJ, May 27 2015