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Cary Yan and Gina Zhou

Updated: Feb 29

Category: Covert Action

Date: 2016 - 2020



Between 2016 and 2020, the defendants, Cary Yan (a.k.a “Hong Hui Yan,” a.k.a “Chen Hong”) and Gina Zhou (a.k.a “Chaoting Zhou,” a.k.a “Angel Zhou”) violated the US Foreign Corrupt Practices Act by bribing high-level officials with the Republic of the Marshall Islands in exchange for passing certain legislation within the semi-autonomous region of the Rongelap Atoll.

This legislation would significantly change the laws to attract foreign businesses and investors by lowering or eliminating taxation and relaxing immigration regulations to benefit chinese businesses. During this time, the defendants also engaged in money laundering efforts with funds from China.  The new Chinese investor-backed zone would also have occupied a geographically sensitive spot just 200 kilometers of open water away from Kwajalein Atoll, where the U.S. Army runs facilities that test intercontinental ballistic missiles and track foreign rocket launches.

In 2016, Yan and Zhou established a UN-affiliated NGO with headquarters in New York and began meeting with Marshall Island officials to discuss the development of the Rongelap Atoll. Throughout these meetings, travel expenses and accommodations were paid for by the defendants. In April 2018, the NGO hosted a conference in Hong Kong to publicly launch the Rongelap Atoll Special Administrative Region (RASAR), which was attended by various Marshall Island officials. At this conference, Yan and Zhou proposed the RASAR Bill which would lower or eliminate taxation and relax immigration regulations in order to attract foreign businesses and investors to the region.  Yan and Zhou bribed several legislators to support the Bill. The Bill was defeated but Yan and Zhou continued meeting with Officials to discuss creating RASAR.

Yan and Zhou were in contact with a PRC intelligence official in New York during this time period. The exact nature of the relationship is unknown. Yan and Zhou pled guilty to one count of conspiracy to violate the anti-bribery provisions of the Foreign Corrupt Practice Act. In 2023, Yan was sentenced to three years and six months, and Zhou was sentenced to two years and seven months. 

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