In a court filing late last week, the DOJ said Hong Rose Carson, the former sales director for Control Components Inc. in China and Taiwan, should be sentenced to just six months of home confinement and fined $20,000.
Carson, 48, pleaded guilty in April to one count of violating the FCPA.
Her husband, Stuart Carson, 73, the former president of CCI, also pleaded guilty. He faces up to ten months in prison when he’s sentenced.
The DOJ said Rose Carson’s plea helped prosecutors obtain the guilty plea from her husband in a ‘package deal.’ She was also willing to testify against co-defendants Paul Cosgrove and David Edmonds if they’d gone to trial, the DOJ said.
Prosecutors also recommended that she placed on probation for three years and during the home confinement be allowed ‘to travel both domestically and internationally as necessary for her employment.’
In its sentencing memorandum, the government said Rose Carson ‘was born in China and lived there until age 26, lacked the American education and early business training of her co-defendants.’
For those reasons, the filing said, Rose Carson ‘viewed business [in China] through very different lenses based on her upbringing, education, and professional experience.’
Prosecutors also said Control Component’s sales model encouraged its people ‘to cultivate relationships with employees of its customers, commonly referred to as “friends-in-camp” or “FICs.” ‘
‘Ultimately,’ the DOJ said, ‘this sales model fostered the circumstances that led to defendant’s offense conduct, where defendant approved the payment of a commission to an employee of a state-owned customer.’
Rose and Stuart Carson are both scheduled to be sentenced on November 5 in federal court in in Santa Ana, California.