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.
- MTS Deferred Prosecution Agreement (DPA);
- MTS Criminal Information (MTS Information);
- SEC Cease and Desist Order (Order);
- Karimova and Akhmedov Indictment (Indictment);
- Kolorit Dizayn Ink Plea Agreement (Plea Agreement);
- Kolorit Dizayn Ink Information (Kolorit Information);
- DOJ Press Release; and
- SEC Press Release.