What the $850 Million MTS Settlement Signals About FCPA Enforcement, Disclosure and Cooperation

In what some see as a lesson in what happens when a company experiencing a corruption problem opts not to self-disclose or to cooperate with the U.S. government, Moscow-based Mobile TeleSystems PJSC and Kolorit Dizayn Ink LLC, a subsidiary in Uzbekistan, agreed to pay a combined penalty of $850 million to settle cases with the DOJ and the SEC involving bribes in Uzbekistan. The federal government continues to pursue two individuals involved in the matter. The Anti-Corruption Report examines the implications of the widespread investigation and the record-setting penalty for the regulated community.

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