Lessons Learned and Trends from MTS FCPA Enforcement Action and Criminal Indictment of Karimova and Akhmedov (Part III of III)
The MTS FCPA enforcement action stands as one of several significant prosecutions in FCPA history. The breadth and depth of MTS’ corruption scheme stands as another example of systemic bribery cultures. The details of the enforcement action underscore several important trends and enforcement policies. Let’s review some of the more significant lessons learned and trends. Application of FCPA Corporate Enforcement Policy: MTS was not able...