Officials of multiple Vietnamese government agencies, including the commercial branches of Vietnam's Ministries of Transport, Industry, and Public Safety
According to the indictment, Nexus Technologies Inc. ("Nexus"), a privately-held Delaware company, allegedly purchased a wide variety of equipment and technology, including underwater mapping equipment, bomb containment equipment, helicopter parts, chemical detectors, satellite communication parts, and air tracking systems, for export to agencies of the government of Vietnam. From approximately 1999 through 2008, the defendants allegedly engaged in a conspiracy to pay Vietnamese government officials bribes totaling at least $150,000 in order to secure lucrative contracts for Nexus. Customers are alleged to have included multiple Vietnamese government agencies, including the commercial branches of Vietnam's Ministries of Transport, Industry, and Public Safety. Kim Ahn Nguyen was an employee of Nexus responsible for identifying and negotiating with suppliers and handling the company's finances. According to the indictment, Nam Nguyen, the founder and president of Nexus, allegedly negotiated contracts and bribes with officials while Joseph Lukas established relationships with Vietnamese government officials, paid or cause to be paid bribes, and negotiated with vendors in the United States. Kim Ahn Nguyen allegedly arranged for the transfer of funds at Nam Nguyen's direction. The direct FCPA count against Kim Nguyen charged her (and others) with wire transfers of $22,325 on 5/23/2006, $18,854 on August 4, 2006, $63,360 on May 23, 2006, and $14,200 on December 22, 2006 from the account of Nexus to a Hong Kong company for the benefit of a Vietnamese official. On September 4, 2008, a federal grand jury indicted Nexus and the individual defendants in Philadelphia on one count of conspiracy to violate the FCPA and four substantive counts of violating the FCPA. On October 8, 2008, Nam Nguyen pleaded not guilty on behalf of Nexus. On November 20, 2008, the Court issued an Order for a Complex Criminal Case Designation, waiving the time limitations required under the Speedy Trial Act due to the complexity of the case and the quantity of evidence, particularly electronic evidence such as USB drives and CPU towers, to be reviewed.
On October 29, 2009, the government entered a superseding indictment against the remaining individual defendants and Nexus, adding charges of conspiracy to violate the Travel Act and to launder money, nine substantive counts of violating the Travel Act, nine substantive counts of money laundering, and five additional counts of violating the FCPA. On March 16, 2010, Nexus, Nam Nguyen, Kim Nguyen, and An Nguyen pleaded guilty to conspiracy, money laundering, and violating the FCPA. All but Kim Nguyen also pleaded guilty to violating the federal Travel Act. As part of the plea, Nexus agreed to cease operations in the U.S. and Vietnam within 90 days.
In September, 2010, Kim Nguyen was sentenced to 2 years of probation and a $20,000 fine, plus a $300 special assessment and requirement of 200 hours of community service.