FCPA Compliance Report18 Mars 2019

MTS Foreign Corrupt Practices Act Enforcement Action: Part III – Missed Red Flags and Overridden Controls

In a stunning resolution to one of the longest running bribery, corruption and money-laundering sagas on the international stage, the Department of Justice and Securities Exchange Commission both announced settlement of a Foreign Corrupt Practices Act (FCPA) enforcement action against the Russian telecom company, Mobile TeleSystems PJSC (MTS). This podcast continues a five-part series will examine the background facts of the case, provide a detailed review of the bribery schemes involved, the compliance failures of MTS and its actions during the investigation which contributed to the size of the penalty, the individual criminal prosecutions brought by the Department of Justice as a part of this action and the key lessons learned by the compliance practitioner. In this Part 3, I discuss the failures in the MTS compliance regime, the override of internal controls and local business unit management actions which facilitated the bribery schemes. The schemes involved: a. Purchase of entities controlled by or through Karimova; b. Purchase of telecom licenses at inflated prices; and c. Fraudulent charitable donations. 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); andKolorit Dizayn Ink Information (Kolorit Information);DOJ Press Release andSEC Press Release.For additional reading see the blog post, "MTS FCPA Settlement and Karimova Indictment: Part III – Missed Red Flags and Overridden Controls" Learn more about your ad choices. Visit megaphone.fm/adchoices

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