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U.S.

Department of Justice
[Type text]
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007

February 20, 2018

By Email
Derek A. Cohen, Esq.
Goodwin Procter LLP
The New York Times Building
620 Eighth Avenue
New York, NY 10018
(212) 459-7060
dcohen@goodwinprocter.com

Re: United States v. Julia Vivi Wang,


S1 16 Cr. 495 (GBD)

Dear Mr. Cohen:

This prosecution and the protection against prosecution set forth below have been approved
by the Tax Division, Department of Justice.

On the understandings specified below, the Office of the United States Attorney for the
Southern District of New York and the Department of Justice, Criminal Division, Fraud Section
(together, “the Offices”) will accept a guilty plea from Julia Vivi Wang, a/k/a “Vivian Wang,”
a/k/a “Vivian Pink,” a/k/a “Wang Wei” (the “defendant”) to superseding criminal information S1
16 Cr. 495 (GBD) to be filed in three counts (the “Superseding Information”).

Count One charges the defendant with conspiracy to violate the Foreign Corrupt Practices
Act (“FCPA”) from at least in or about 2012 up to and including at least in or about 2015, in
violation of Title 18, United States Code, Section 371. Count One carries a maximum sentence of
five years’ imprisonment, a maximum term of three years’ supervised release, a maximum fine
under 18 U.S.C. § 3571(d) of the greatest of $250,000, twice the gross pecuniary gain derived from
the offense, or twice the gross pecuniary loss to persons other than the defendant, and a mandatory
$100 special assessment.

Count Two charges the defendant with offering, paying, promising to pay, and authorizing
payments of bribes from at least in or about 2012 up to and including at least in or about 2015, in
violation of the FCPA, Title 15, United States Code, Sections 78dd-2(a)(1)(A), 78dd-2(a)(3)(A),
78dd-2(g)(2)(A), and Title 18, United States Code, Section 2. Count Two carries a maximum
sentence of five years’ imprisonment, a maximum term of three years’ supervised release, a
maximum fine under 18 U.S.C. § 3571(d) of the greatest of $250,000, twice the gross pecuniary
gain derived from the offense, or twice the gross pecuniary loss to persons other than the defendant,
and a mandatory $100 special assessment.