DSS:EMN/AH/DAL/SPN/KDE/BDM
F.#2015R00747
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
- - - - - - - - - - - - - - - - - - -X
UNITED STATES OF AMERICA
- against -
JEFFREY WEBB,
EDUARDO LI,
JULIO ROCHA,
COSTAS TAKKAS,
JACK WARNER,
EUGENIO FIGUEREDO,
RAFAEL ESQUIVEL,
JOSÉ MARIA MARIN,
NICOLÁS LEOZ,
ALEJANDRO BURZACO,
AARON DAVIDSON,
HUGO JINKIS,
MARIANO JINKIS, and
JOSÉ MARGULIES,
also known as José Lazaro,
Defendants.
- - - - - - - - - - - - - - - - - - -X
I N D I C T M E N T
Cr. No. __________________
(T. 8, U.S.C., § 1451(e);
T. 18, U.S.C., §§
981(a)(1)(C), 982(a)(1),
982(a)(6), 982(b), 1343,
1349, 1425(a), 1512(c)(2),
1956(a)(2)(A),
1956(a)(2)(B)(i), 1956(h),
1957(a), 1957(b),
1957(d)(1), 1962(d), 1963,
1963(a), 1963(m), 2, and
3551 et seq.; T. 21,
U.S.C., § 853(p); T. 26,
U.S.C. § 7206(2); T. 28,
U.S.C. § 2461(c))
15 CR 0252(RJD)(RML)
DEARIE, J.
LEVY, M.J.
Case 1:15-cr-00252-RJD Document 1 Filed 05/20/15 Page 1 of 164 PageID #: 1
i
CONTENTS
INTRODUCTION TO ALL COUNTS..................................... 1 
I. 
The Enterprise.......................................... 1 
A. 
FIFA................................................ 2 
B. 
The Continental Confederations...................... 8 
C. 
The Regional Federations and National Associations. 12 
D. 
The Sports Marketing Companies..................... 13 
II. The Defendants......................................... 14
III. The Defendants’ Co-Conspirators........................ 22
IV. The Conspirators’ Corruption of the Enterprise......... 28
V. 
Overview of the Racketeering Conspiracy................ 31 
A. 
The Initial Corruption of the Enterprise........... 32 
B. 
The Growth of the Sports Marketing Companies....... 36 
C. 
The Centrality of the U.S. Financial System........ 39 
D. 
Scandal and the Resignations of WARNER and LEOZ.... 41 
E. 
The Continued Corruption of the Enterprise......... 42 
F. 
Obstruction of Justice............................. 47 
VI. The Criminal Schemes................................... 48
A. 
CONMEBOL Copa América Scheme....................... 48 
B. 
CONCACAF Gold Cup Scheme........................... 61 
C. 
CONMEBOL Copa Libertadores Scheme.................. 63 
D. 
CBF Copa do Brasil Scheme.......................... 70 
E. 
CBF Sponsorship Scheme............................. 74 
F. 
CFU World Cup Qualifiers Scheme #1................. 76 
G. 
2010 FIFA World Cup Vote Scheme.................... 80 
H. 
UNCAF Region World Cup Qualifiers Scheme........... 86 
I. 
2011 FIFA Presidential Election Scheme............. 89 
J. 
CFU World Cup Qualifiers Scheme #2................. 94 
K. 
CONCACAF Gold Cup/Champions League Scheme.......... 99 
L. 
CONMEBOL/CONCACAF Copa América Centenario Scheme.. 102 
CRIMINAL COUNTS.............................................. 113 
CRIMINAL FORFEITURE ALLEGATIONS.............................. 152 
Case 1:15-cr-00252-RJD Document 1 Filed 05/20/15 Page 2 of 164 PageID #: 2
1
THE GRAND JURY CHARGES:
INTRODUCTION TO ALL COUNTS
At all times relevant to this Indictment, unless
otherwise indicated:
I. The Enterprise
1.
The Fédération Internationale de Football
Association (“FIFA”) and its six constituent continental
confederations – the Confederation of North, Central American
and Caribbean Association Football (“CONCACAF”), the
Confederación Sudamericana de Fútbol (“CONMEBOL”), the Union des
Associations Européennes de Football (“UEFA”), the Confédération
Africaine de Football (“CAF”), the Asian Football Confederation
(“AFC”), and the Oceania Football Confederation (“OFC”) –
together with affiliated regional federations, national member
associations, and sports marketing companies, collectively
constituted an “enterprise,” as defined in Title 18, United
States Code, Section 1961(4), that is, a group of legal entities
associated in fact (hereinafter the “enterprise”). The
enterprise constituted an ongoing organization whose members
functioned as a continuing unit for a common purpose of
achieving the objectives of the enterprise. The enterprise was
engaged in, and its activities affected, interstate and foreign
commerce.
Case 1:15-cr-00252-RJD Document 1 Filed 05/20/15 Page 3 of 164 PageID #: 3
2
2.
The principal purpose of the enterprise was to
regulate and promote the sport of soccer worldwide. The members
of the enterprise carried out this purpose by using a variety of
methods and means, including creating and enforcing uniform
standards and rules, organizing international competitions, and
commercializing the media and marketing rights associated with
the sport. The members of the enterprise, as well as
individuals and entities employed by and associated with the
enterprise, frequently engaged in banking and investment
activities with United States financial institutions.
3.
The enterprise operated in the Eastern District
of New York and elsewhere, including overseas.
A.
FIFA
4.
FIFA was the international body governing
organized soccer, commonly known outside the United States as
football. FIFA was an entity registered under Swiss law and
headquartered in Zurich, Switzerland. FIFA was composed of as
many as 209 member associations, each representing organized
soccer in a particular nation or territory, including the United
States and four of its overseas territories. The United States
first became affiliated with FIFA in 1914; Puerto Rico first
became affiliated with FIFA in 1960, with Guam, American Samoa,
and the United States Virgin Islands following suit in the
Case 1:15-cr-00252-RJD Document 1 Filed 05/20/15 Page 4 of 164 PageID #: 4
3
1990s. At various times relevant to the Indictment, FIFA
maintained offices both in Zurich, Switzerland and elsewhere in
the world, including in the United States, where FIFA maintained
a development office since at least 2011.
5.
Each of FIFA’s member associations also was a
member of one of the six continental confederations recognized
by FIFA: CONCACAF, CONMEBOL, UEFA, CAF, AFC, and OFC. Since at
least 1996, under FIFA’s statutes, no national soccer
association could become a member of FIFA without first joining
one of the six continental confederations. Since at least 2004,
member associations were required to pay to FIFA annual dues,
known as subscriptions.
6.
FIFA was governed by: a congress composed of its
member associations, which acted as the association’s highest
legislative body; an executive committee, which acted as the
executive body; and a general secretariat, which acted as the
administrative body. FIFA also had a president, who represented
the association worldwide and was responsible for the
implementation of decisions. FIFA also operated several
standing committees, including a committee that organized
Olympic soccer qualifying tournaments, whose members included
soccer officials from various national member associations.
FIFA also operated through a number of subsidiaries, including
Case 1:15-cr-00252-RJD Document 1 Filed 05/20/15 Page 5 of 164 PageID #: 5
4
subsidiaries that assisted with FIFA’s media and marketing
activities.
7.
The FIFA congress was composed of delegates from
each of its member associations as well as observers appointed
by each of the confederations. Among other things, the congress
was responsible for amending FIFA’s statutes and electing the
FIFA president. The congress convened in ordinary sessions
biennially or annually, and at other times in extraordinary
sessions in various countries around the world, including the
United States.
8.
The FIFA executive committee, often referred to
as the “ExCo,” was composed of the FIFA president and a number
of ordinary members, some of whom also held the title of vice
president. The president was elected by the FIFA congress. The
vice presidents and ordinary members were appointed by the
confederations. Each confederation was entitled to appoint a
specific number of vice presidents and ordinary members, as set
forth in the FIFA statutes. Since at least 1996, the executive
committee was required by FIFA statutes to meet at least twice
per year. The executive committee held meetings at FIFA’s
headquarters in Zurich, Switzerland, as well as in various
countries around the world, including the United States.
Case 1:15-cr-00252-RJD Document 1 Filed 05/20/15 Page 6 of 164 PageID #: 6
5
9.
Among other duties, the executive committee was
responsible for selecting the host nations of FIFA tournaments,
including, among others, the World Cup, the Women’s World Cup,
the Confederations Cup, the Under-20 World Cup, the Under-20
Women’s World Cup, the Under-17 World Cup, the Under-17 Women’s
World Cup, and the Club World Cup.
10. The World Cup, the sport’s premier event, was a
quadrennial international tournament involving the senior
national men’s teams of 24 and, beginning in 1998, 32 nations.
In selecting the host nation for the World Cup, the executive
committee typically followed a process in which bid committees
for the competing nations campaigned for votes among the members
of the executive committee. Following this process, and at
least six years prior to each World Cup, the executive committee
typically held a vote in which its members cast their votes via
secret ballot. The winners, or host nations, for the World Cups
from 1990 to 2022, as well as the other bidding nations that
maintained their bids to the end of the process, are reflected
in the table below:
Case 1:15-cr-00252-RJD Document 1 Filed 05/20/15 Page 7 of 164 PageID #: 7
6
TABLE 1: World Cup Host Selection
World
Cup
Date Selected
by the ExCo
Winning Nation
Other Bidding
Nation/Nations
1990 May 19, 1984
Italy
Soviet Union
1994 July 4, 1988
United States
Morocco
Brazil
1998 July 2, 1992
France
Morocco
2002 May 31, 1996
Japan/South Korea Mexico
2006 July 6, 2000
Germany
South Africa
England
Morocco
2010 May 15, 2004
South Africa
Morocco
Egypt
2014 October 30, 2007 Brazil
-
2018 December 2, 2010 Russia
Spain/Portugal
Netherlands/Belgium
England
2022 December 2, 2010 Qatar
United States
South Korea
Japan
Australia

The U.S. men’s national team qualified for each edition of the
World Cup from 1990 to 2014.
11. Since at least 1996, under FIFA’s statutes, the
six continental confederations had certain rights and
obligations, including, among other things, that they comply
with and enforce FIFA’s statutes, regulations, and decisions and
work closely with FIFA to further FIFA’s objectives and organize
international soccer competitions.
Case 1:15-cr-00252-RJD Document 1 Filed 05/20/15 Page 8 of 164 PageID #: 8
7
12. FIFA’s purpose was, among other things, to
develop and promote the game of soccer globally by organizing
international competitions and by creating and enforcing rules
that govern the confederations and member associations. FIFA
financed its efforts in significant part by commercializing the
media and marketing rights associated with the World Cup.

According to its published income statement for
the 2007-2010 financial period, FIFA had total
revenues of $4.189 billion, 83% of which ($3.480
billion) was attributable to the sale of
television and marketing rights to the 2010 World
Cup. FIFA’s profits during this same period were
$631 million.


According to its published income statement for
the 2011-2014 financial period, FIFA had total
revenues of $5.718 billion, 70% of which ($4.008
billion) was attributable to the sale of
television and marketing rights to the 2014 World
Cup. FIFA’s profits during this same period were
$338 million.

FIFA, in turn, helped finance the confederations and their
member associations, including by providing funds through the
Financial Assistance Program (“FAP”) and the Goal Program, which
were established in the late 1990s to support the development of
youth academies, soccer fields, technical centers, and other
infrastructure projects. According to its published income
statement for the 2011-2014 financial period, FIFA spent $1.052
billion on development projects, including $538 million for the
FAP program.
Case 1:15-cr-00252-RJD Document 1 Filed 05/20/15 Page 9 of 164 PageID #: 9
8
13. FIFA first instituted a written code of ethics in
October 2004, which code was revised in 2006, again in 2009, and
most recently in 2012 (generally, the “code of ethics”). The
code of ethics governed the conduct of soccer “officials,” which
expressly included, among others, various individuals with
responsibilities within FIFA, the confederations, member
associations, leagues, and clubs. Among other things, the code
of ethics provided that soccer officials were prohibited from
accepting bribes or cash gifts and from otherwise abusing their
positions for personal gain. The code of ethics further
provided, from its inception, that soccer officials owed certain
duties to FIFA and its confederations and member associations,
including a duty of absolute loyalty. By 2009, the code of
ethics explicitly recognized that FIFA officials stand in a
fiduciary relationship to FIFA and its constituent
confederations, member associations, leagues, and clubs.
B.
The Continental Confederations
14. In addition to providing representatives who
helped to govern FIFA, the six continental confederations worked
closely with FIFA and one another to organize international
soccer competitions and carry out FIFA directives on a regional
basis. The leaders and representatives of the confederations
conducted business with one another, as well as with the leaders
Case 1:15-cr-00252-RJD Document 1 Filed 05/20/15 Page 10 of 164 PageID #: 10