MUR #7624
IMPERIAL PACIFIC INTERNATIONAL HOLDINGSSummary
RESPONDENTS: Imperial Pacific International Holdings; Alter City Group Holdings Limited; Angel Demapan for House; CNMI Republican Party; DelaCruz, Geralyn C.; Demapan for Congress; Demapan, Angel; Friends of Ralph; HPIL LTD.; Honest Profit International, LTD; Hong King Entertainment (Overseas) Investment Ltd,; Imperial Pacific International (CNMI) LLC; Lady Diann Torres Foundation; Pangelinan, Judith; Ralph Torres Campaign; Torres, Diann; Torres, Ralph
COMPLAINANT:
SUBJECT: Contributions-Prohibited; Foreign Nationals
DISPOSITION: The Commission decided by a vote of 6-0 to take the following actions in MUR 7624: 1. Substitute Imperial Pacific International (CNMI) LLC as Respondent for Imperial Pacific International Holdings.2. Take no further action as to Imperial Pacific International (CNMI) LLC, Angel Demapan, Angel Demapan for House, Friends of Ralph, Ralph G. Torres, the Ralph G. Torres Campaign, and Hong Kong Entertainment.3. Approve the appropriate letters.4. Close the file effective 30 days from the date of certification of this vote (or on the next business day after the 30th day, if the 30th day falls on a weekend or holiday).
The Commission decided by a vote of 6-0 to take the following actions in MUR 7624:1. Find reason to believe that the CNMI Republican Party violated 52 U.S.C. § 30121.2. Approve the Factual and Legal Analysis, as recommended in the Second General Counsel’s Report dated November 12, 2020, ...REDACTED...3. Authorize pre-probable cause conciliation with CNMI Republican Party and approve the conciliation agreement, as recommended in the Second General Counsel’s Report dated November 12, 2020.4. Approve the appropriate letter.
The Commission decided by a vote of 6-0 to take the following actions in MUR 7624:1. Accept the signed conciliation agreement with Alter City Group Holdings, Ltd., as recommended in the Memorandum from the Acting General Counsel dated August 11, 2020.2. Approve the appropriate letter.3. Close the file as to Alter City Group Holdings, Ltd.
The Commission decided by a vote of 4-0 to take the following actions in MUR 7624:1. Accept the signed conciliation agreement with Honest Profit International, Ltd., as recommended in the Memorandum from the Acting General Counsel dated January 15, 2020.2. Approve the appropriate letter.3. Close the file as to Honest Profit International, Ltd.
The Commission decided by a vote of 4-0 to:1. Open a Matter Under Review with respect to Pre-MUR 609.2. Find reason to believe that Ralph G. Torres and the Ralph G. Torres Campaign violated 52 U.S.C. § 30121(a)(2) by accepting foreign national contributions.3. Find reason to believe that Angel A. Demapan and Angel Demapan for House violated 52 U.S.C. § 30121(a)(2) by accepting foreign national contributions.4. Find reason to believe that Imperial Pacific International Holdings, Alter City Group Holdings Limited, Honest Profit International Limited, and Hong Kong Entertainment violated 52 U.S.C. § 30121(a)(1)(A) by making foreign national contributions.5. Find reason to believe that Friends of Ralph violated 52 U.S.C. § 30121(a)(1)(A) and 11 C.F.R. § 110.20(h) by accepting foreign national donations in connection with a federal election.6. Find no reason to believe that Demapan for Congress and Geralyn C. DelaCruz in her official capacity as treasurer violated 52 U.S.C. § 30121(a)(1)(A) by accepting foreign national contributions.7. Dismiss the allegation that the Lady Diann Torres Foundation violated the Act.8. Approve the Factual and Legal Analyses, as recommended in the First General Counsel’s Report dated May 23, 2019, and last circulated by Chair Weintraub’s Office on July 25, 2019; ...REDACTED...9. Enter into conciliation with Ralph G. Torres and the Ralph G. Torres Campaign, Angel A. Demapan and Angel Demapan for House, Friends of Ralph, Imperial Pacific International Holdings, Alter City Group Holdings Limited, Honest Profit International Limited, and Hong Kong Entertainment prior to a finding of probable cause to believe.10. Approve the conciliation agreements, as recommended in the First General Counsel’s Report dated May 23, 2019, ...REDACTED...11. Approve the appropriate letters.
The Commission failed by a vote of 2-2 to:1. Open a Matter Under Review with respect to Pre-MUR 609.2. Find reason to believe that Ralph G. Torres and the Ralph G. Torres Campaign violated 52 U.S.C. § 30121(a)(2) by accepting foreign national contributions.3. Find reason to believe that Angel A. Demapan and Angel Demapan for House violated 52 U.S.C. § 30121(a)(2) by accepting foreign national contributions.4. Find reason to believe that Imperial Pacific International Holdings, Alter City Group Holdings Limited, Honest Profit International Limited, and Hong Kong Entertainment violated 52 U.S.C. § 30121(a)(1)(A) by making foreign national contributions.5. Find reason to believe that Friends of Ralph violated 52 U.S.C. § 30121(a)(1)(A) and 11 C.F.R. § 110.20(h) by accepting foreign national donations in connection with a federal election.6. Find no reason to believe that Demapan for Congress and Geralyn C. DelaCruz in her official capacity as treasurer violated 52 U.S.C § 30121(a)(1)(A) by accepting foreign national contributions.7. Dismiss the allegation that the Lady Diann Torres Foundation violated the Act.8. Approve the Factual and Legal Analyses, as recommended in the First General Counsel’s Report dated May 23, 2019, subject to the edits last circulated by Chair Weintraub’s Office on June 19, 2019.9. Enter into conciliation with Ralph G. Torres and the Ralph G. Torres Campaign, Angel A. Demapan and Angel Demapan for House, Friends of Ralph, Imperial Pacific International Holdings, Alter City Group Holdings Limited, Honest Profit International Limited, and Hong Kong Entertainment prior to a finding of probable cause to believe.10. Approve the conciliation agreements, as recommended in the First General Counsel’s Report dated May 23, 2019, ...REDACTED...11. Approve the appropriate letters.
Disposition
| Disposition | Penalty | Respondent | Citation |
|---|---|---|---|
| Conciliation: Pre Probable Cause | $15,000.00 | CNMI Republican Party | 52 U.S.C. §30121 |
| CNMI Republican Party | 52 U.S.C. §30121 | ||
| Alter City Group Holdings Limited | 52 U.S.C. §30121(a)(1)(A) | ||
| Conciliation: Pre Probable Cause | HPIL LTD. | 52 U.S.C. §30121(a)(1)(A) | |
| Dismissed-Other | Lady Diann Torres Foundation | 52 U.S.C. §30121 | |
| No Reason to Believe | Demapan for Congress | 52 U.S.C. §30121(a)(1)(A) | |
| DelaCruz, Geralyn C. | 52 U.S.C. §30121(a)(1)(A) | ||
| Take No Further Action | Friends of Ralph |
52
U.S.C.
§30121
11 CFR 110.20 |
|
| Hong King Entertainment (Overseas) Investment Ltd, |
52
U.S.C.
§30121
11 CFR 110.20 |
||
| Imperial Pacific International (CNMI) LLC |
52
U.S.C.
§30121
11 CFR 110.20 |
||
| Ralph Torres Campaign |
52
U.S.C.
§30121
11 CFR 110.20 |
||
| Demapan, Angel |
52
U.S.C.
§30121
11 CFR 110.20 |
||
| Torres, Ralph |
52
U.S.C.
§30121
11 CFR 110.20 |
||
| Angel Demapan for House |
52
U.S.C.
§30121
11 CFR 110.20 |
Documents
Participants
| Relationship | Name |
|---|---|
| Primary respondent | Imperial Pacific International Holdings |
| Previous respondent | Alter City Group Holdings Limited |
| Angel Demapan for House | |
| CNMI Republican Party | |
| DelaCruz, Geralyn C. | |
| Demapan for Congress | |
| Demapan, Angel | |
| Friends of Ralph | |
| HPIL LTD. | |
| Honest Profit International, LTD | |
| Hong King Entertainment (Overseas) Investment Ltd, | |
| Imperial Pacific International (CNMI) LLC | |
| Lady Diann Torres Foundation | |
| Pangelinan, Judith | |
| Ralph Torres Campaign | |
| Torres, Diann | |
| Torres, Ralph | |
| Respondent's counsel | Hogan Lovells US LLP |
| Long, George Anthony |