Tagged: BIT Mining

BIT Mining FCPA Settlement and Lessons Learned (Part III of III)

Bit Mining, formerly 500.com, was a doomed company from the beginning,  When a CEO orchestrates a bribery scheme with the assistance of other senior executives, shareholders and the public have little chance of ensuring a business operating with ethics and integrity. 500.com’s future was sealed when it embraced bribery as a means to avoid head-to-head competition against established US and European companies seeking to enter...

BIT Mining Bribery Scheme — CEO Directed Payments and the Cover-Up (Part II of III)

In reviewing FCPA bribery fact patterns, it is a rare occasion when a company’s CEO is at the epicenter of the criminal conspiracy.  In the BIT Mining case, standing atop all of the actors is the CEO  Zhengming Pan, Bit Mining’s former CEO and a Chinese national. DOJ had no choice but to charge Pan with a criminal FCPA conspiracy. Others could have been charged...