The MTS bribery scandal in Uzbekistan represents the culmination of several significant FCPA violations involving VimpelCom, Telia Sonera, MTS, and Gulnara Karimova, the notoriously corrupt daughter of the former Uzbek President.  Karimova is perhaps one of the most notorious corrupt offenders in the world.  She has been under house arrest in Uzbekistan since 2014. (Indictment Here). According to MTS’ admissions, MTS and its subsidiaries, Uzdunrobita...

In another blockbuster FCPA prosecution, the Justice Department and the SEC announced an $850 million settlement with Mobile Telesystems (“MTS”), Russia’s largest mobile carrier.  At the same time, the Justice Department announced criminal indictments against an MTS executive and the notorious corrupt Uzbek official, Gulnara Karimova, on criminal charges. MTS is the largest mobile telecommunications company in Russia, and has stock that is publicly-traded in...

The corporate governance landscape is littered with companies that have suffered major legal and reputational damage as a result of failure to promote and protect a safe workplace environment.  Companies have failed to hold offenders accountable for sexual misconduct and violation of applicable legal and code requirements. The #MeToo era has resulted in increased reporting of sexual misconduct allegations and requires enhanced monitoring of corporate...

The Justice Department’s sprawling and successful prosecution of bribery and money laundering surrounding PDVSA, Venezuela’s state-owned energy company, shows no signs of letting up.  DOJ’s prosecutions began in 2015, and with the recent announcement of two new defendants, DOJ’s scorecard has reached a total of 21 defendants, 15 of whom have pleaded guilty.  Given PDVSA’s reputation for corruption, which is well earned (or as I...

Webinar: Best Practices for Investigation Sexual Misconduct Allegations in the #MeToo Era March 26, 2019, 12 Noon EST SIGN UP HERE The corporate governance landscape is littered with companies that have suffered major legal and reputational damage as a result of failure to promote and protect a safe workplace environment. Companies have failed to hold offenders accountable for sexual misconduct and violation of applicable legal...

OFAC is definitely off to a fast start this year – it recently announced its fourth enforcement action for 2019.  So far, OFAC has collected over $7 million in civil penalties.  While this may not appear to be a lot of money in civil penalties, it is important to remember the consequences of an OFAC settlement and scrutiny for future violations, restrictions on exports, and...

In January 2019, the Justice Department brought an interesting FCPA prosecution involving a Hawaii-based businessman, Frank James Lyon, and Master Halbert, a government official from Micronesia.  DOJ’s prosecution was interesting for two significant reasons – first, it was another example of DOJ enforcement efforts against the payor of the bribe for violating the FCPA and the recipient of the bribe, the foreign official, for money...

The Department of Justice has launched two separate criminal cases against Huawei China, the controversial Chinese telecommunications equipment provider.  For years, US government officials have questioned the ownership, control and practices of Huawei, claiming that it is owned by the Chinese government and  acting as an agent for Chinese interests.  At the end of January, the Justice Department announced two separate indictments against Huawei, and...