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4 min read

How a Bribery Scandal Led to a Conviction: The Case of Heon-Cheol Chi



Heon-Cheol Chi's legal battle highlights the importance of compliance with international trade regulations, specifically ITAR (International Traffic in Arms Regulations) compliance. This case sheds light on the risks and consequences associated with unlawful activities and the severe penalties that can result from violations.

Chi's involvement with seismometer manufacturers, Guralp Systems and Kinemetrics, showcased their disregard for ITAR compliance. By offering monetary bribes to Chi in exchange for special treatment and insider information, they violated the arms regulations established by the United States State Department. These regulations are in place to safeguard national security and prevent the unauthorized export of defense articles and sensitive technical data.

It is crucial for businesses operating within the defense industry to understand and adhere to ITAR regulations. Compliance requires strict adherence to guidelines, including obtaining the necessary licenses for exporting defense articles, maintaining proper documentation, and implementing robust security measures to protect sensitive data.

In Chi's case, his attempts to hide the illicit transactions by transferring funds to multiple bank accounts did not go unnoticed. The FBI took notice of his activities and intervened, leading to his arrest and subsequent prosecution. This demonstrates the importance of effective monitoring and enforcement of ITAR compliance by government agencies.

To strengthen ITAR compliance programs, organizations should establish clear guidelines and procedures, conduct regular internal audits, and provide comprehensive training to employees. It is also essential to stay updated on any changes or amendments to ITAR regulations, as failure to comply could result in severe penalties, including fines and imprisonment.

The story of Heon-Cheol Chi serves as a cautionary tale for businesses involved in international trade of defense articles and technical data. ITAR compliance should be treated as a top priority to ensure national security, maintain legal integrity, and avoid potential legal consequences.

Specified Unlawful Activity

The court's analysis of Chi's case sheds light on the interpretation of "specified unlawful activity" under 18 U.S.C. § 1956, an important aspect of ITAR compliance. It is essential to understand how this statute is interpreted and applied in cases related to arms regulations and ITAR compliance.

In this case, the court relied on previous cases, such as United States v. Lazarenko and United States v. Chao Fan Xu, to provide the necessary context for interpreting § 1956(c)(7)(B). These cases emphasized the need for the violated foreign law to fall within specific categories. The court concluded that the South Korean law Chi had violated met the criteria of "bribery of a public official," further affirming Chi's conviction.

Furthermore, the court highlighted the significance of interpreting statutes based on their ordinary, contemporary, and common meanings. This approach aligns with ITAR compliance, as it requires a clear understanding of the regulations and their intended scope. The court referenced cases like Perrin v. United States, Taylor v. United States, and Scheidler v. National Organization for Women, Inc., which demonstrate the Supreme Court's reliance on the ordinary meaning of terms to define the statutes' boundaries. In Chi's case, the court disregarded his argument that "bribery of a public official" referred to 18 U.S.C. § 201 and instead consulted reliable legal sources like Black's Law Dictionary and the Model Penal Code to define the term "bribery."

Wire Transfers, Bribes, and Court Dismissal

Chi argued fiercely that the wire transfers from Kinemetrics were not bribes. However, the court dismissed his argument by presenting circumstantial evidence. Chi's correspondence with Kinemetrics and the provision of confidential information served as crucial indicators that the transfers indeed constituted bribes. These details highlight the importance of monitoring and verifying transactions and sensitive data transfers to maintain ITAR compliance.

Additionally, the court clarified that the indictment didn't necessarily have to accuse Chi of violating federal bribery law. This clarification further emphasizes the need for a comprehensive understanding of ITAR compliance regulations and how they interact with other laws and regulations.

As Chi challenged the jury instructions, the court dispelled his claim and upheld his conviction. The court determined that there was ample evidence to support the outcome. To gain further insights and a deeper understanding of this legal saga, interested readers can consult the authoritative case "United States v. Chi" (936 F.3d 888) from the United States Court of Appeals, Ninth Circuit.


The gripping story of Heon-Cheol Chi's bribery scandal and subsequent conviction is a cautionary tale that vividly underscores the paramount importance of upholding the law with regards to ITAR Compliance. The case serves as a stark reminder of the severe consequences that await those who engage in unlawful activities involving insider information and preferential treatment.

To fully grasp the significance of Chi's indictment, it is worth noting that one count of the charges brought against him was based on a specific financial deposit into his account. This revelation serves as a powerful reminder of the critical need for transparency in all financial transactions related to arms regulations. Transparency guarantees that any suspicious activities or potential violations can be thoroughly investigated and addressed in accordance with ITAR compliance guidelines.

It is interesting to consider Chi's defense, which claimed that he had obtained permission from the KIGAM president to enter into the contracts in question. This raises important questions about the regulatory framework of ITAR and the proper authorization required for defense-related agreements. It is a reminder that adherence to the United States State Department's regulations is of utmost importance. Compliance ensures that all defense-related agreements are executed in a manner that aligns with the established guidelines and promotes national security.

Furthermore, it is worth noting that the narrative in Footnote 3 simplifies the story by referring to both Quanterra and Kinemetrics as "Kinemetrics." This choice of terminology effectively portrays the interconnectedness of the entities involved in defense article manufacturing and trade. It serves as a poignant example of the complexity surrounding ITAR compliance and the technical data associated with defense articles.

When examining the international implications of ITAR compliance, Footnote 4 provides the translation of Article 129 from the South Korean Criminal Code. This translation illuminates the legal framework governing arms export control and sheds light on the global efforts made by various countries to enforce regulations related to defense services and prevent export violations. It serves as a reminder that ITAR compliance is not limited to the United States alone but rather extends to the international stage.

A key aspect of Chi's case was his request for a jury instruction on intent, as mentioned in Footnote 5. This highlights the critical importance of having a thorough understanding of ITAR requirements and compliance programs. In defense trade control cases, intent plays a pivotal role in determining culpability. The ability to effectively demonstrate intent or lack thereof underscores the need for organizations to have robust compliance programs in place to ensure adherence to ITAR regulations.

Finally, Footnote 6 delves deeper into the elements of Article 129, as defined by the district court. This provides readers with a more comprehensive understanding of the intricate legal nuances involved in ITAR compliance and the regulatory environment in which it operates. By exploring the complexities of ITAR compliance, we gain a deeper appreciation for the significance of adhering to regulations and the potential grave consequences that non-compliance can entail.

The story of Heon-Cheol Chi's bribery scandal serves as a powerful testament to the critical importance of ITAR compliance. It underscores the need for transparency in financial transactions related to arms regulations, emphasizes the significance of adhering to the United States State Department's regulations, and highlights the complexities surrounding defense article manufacturing and trade. Furthermore, it sheds light on the international implications of ITAR compliance, emphasizes the role of intent in defense trade control cases, and deepens our understanding of the legal nuances embedded within ITAR regulations. This article offers a comprehensive exploration of the multifaceted landscape of ITAR compliance, reinforcing the vital role it plays in upholding the law and ensuring national security.