There were no mitigating factors in this case: the company, Shen Zhen New World 1 LLC is owned by HUANG Wei, a resident of Shenzhen, China with a residence in San Marino, California. HUANG has absconded and is named as a fugitive. It is believed that he is in China, says the US Department of Justice.

The DOJ allege that the company is an instrument or agent of HUANG, saying that, in 2010, the company purchased The L.A. Grand in Los Angeles. In 2018, Shen Zhen applied to redevelop the hotel into a mixed use residential and commercial building.

But the DoJ is confused: having alleged that the company was an agent of Huang, it also claims " Shen Zhen, acting through Huang, provided Huizar with cash." Huizar was at all material times the chairman of the Planning and Land Use Management Committee, considered a PLUM job. Pun intended.

Cash was far from the only benefit, it was proved: " casino gambling chips, flights on private jets and commercial airlines, stays at luxury Las Vegas hotels and casinos, expensive meals, spa services, prostitution services, political contributions, and a $600,000 collateral for Huizar to confidentially settle a pending sexual harassment lawsuit against Huizar by a former staffer that threatened his career." It was alleged that the total value of the benefits amounted to more than USD1 million.

Here is the legally interesting allegation: "At the time Shen Zhen provided these items, it did so intending to influence Huizar" and "Shen Zhen intended that Huizar benefit the project."

The charges were not under e.g. OFAC or the Foreign Corruption Prevention Act where corporate liability is long established under what amounts to a "failure to prevent" approach. The charges were "honest service wire fraud, four counts of interstate and foreign travel in aid of bribery, and one count of bribery."

The case therefore stands as precedent that, under US law, a corporation is capable of forming intent and acting on it.

This is contrary to the basic principle that a corporation cannot form intent and that the intent is that of its controllers but, in some circumstances, the company can be punished for actions it takes in law at the direction of its controllers.