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...

Just when everyone was anticipating the beginning of an uptick in FCPA enforcement in 2017, the Justice Department and the SEC delivered a resounding message to remind everyone that FCPA enforcement is here to stay. However, the Telia decision may be the first indication of some changes in DOJ’s FCPA enforcement policies. It is hard to say from just one major DOJ enforcement action but...