re: NYT Exclusive: Top FIFA officials (but not Blatter) indicted, face extradition to U.S.

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2010 FIFA World Cup Vote Scheme
185. In or about 2004, the FIFA executive committee
considered bids from 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, CoConspirator
#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 highranking
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 CoConspirator
#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, CoConspirator
#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 CoConspirator
#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, CoConspirator
#1, and Co-Conspirator #17 indicated that they voted
for South Africa.
190. In the months and years after the vote, CoConspirator
#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 CFU 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 CFU 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 CoConspirator
#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
#1 at a bank in the 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 then to CONCACAF’s headquarters in New
York, New York, where he delivered the check to 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 bank 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.

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