In this special bonus podcast, I am joined by Mike Volkov to discuss the stunning resolution to one of the longest running bribery, corruption and money-laundering sagas on the international stage, the FCPA enforcement action against the Russian telecom company, MTS. The FCPA enforcement action came in at $850 million which makes it Number 3 in the Top 10 of all-time FCPA settlement. Some of the highlights include:

  • The background facts;
  • Similarities with VimpleCom and Telia;
  • Criminal Indictments of Gulnara Karimova and Bekhzod Akhmedov;
  • Jurisdictional issues raised;
  • Lessons learned for the compliance professional;
  • The clear delineation from Yates Memo to the FCPA Pilot Program to the 2017 FCPA Corporate Enforcement Policy to this enforcement action; and final thoughts.


  1. MTS Deferred Prosecution Agreement (DPA);
  2. MTS Criminal Information (MTS Information);
  3. SEC Cease and Desist Order (Order);
  4. Karimova and Akhmedov Indictment (Indictment);
  5. Kolorit Dizayn Ink Plea Agreement (Plea Agreement);
  6. Kolorit Dizayn Ink Information (Kolorit Information);
  7. DOJ Press Release; and
  8. SEC Press Release.