We are on Episode V of a five-part exploration of the recent the Department of Justice and Securities Exchange Commission resolution of a Foreign Corrupt Practices Act enforcement action against the Russian telecom company, MTS. In this episode, I conclude with the lessons learned for the compliance professional. Today we focus on four key lessons: (1) due diligence, (2) business justification, (3) business valuation and (4) the long road of bribery.
The documents which are the subject of this series are:
- MTS Deferred Prosecution Agreement (DPA);
- MTS Criminal Information (MTS Information);
- SEC Cease and Desist Order (Order);
- Karimova and Akhmedov Indictment (Indictment);
- Kolorit Dizayn Ink LLC Plea Agreement (Plea Agreement); and
- Kolorit Dizayn Ink Information (Kolorit Information);
- DOJ Press Release and
- SEC Press Release.
For additional reading see the blog post, “MTS FCPA Settlement and Karimova Indictment: Part V – Lessons Learned”
