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VimpelCom and the conscious indifference of a board under the FCPA

Tom Fox | March 15, 2016

In late February, the Justice Department and Securities and Exchange Commission announced a resolution of a longstanding FCPA probe into the Dutch telecom giant VimpelCom for a spectacular, longstanding bribery scheme where the company garnered the rights to the mobile communications business in Uzbekistan. The multiple bribery schemes used appear to have been approved at the highest levels of the company and should provide a wealth of case studies on bribery schemes for the compliance professional going forward. Indeed, the total fines and penalties exceeded $795 million.

This is one of the very few FCPA enforcement actions that rose to...

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