3/2/16: In answer to suggestions that the US’ interest in FCPA enforcement has faded, the US Securities and Exchange Commission (SEC), along with the DOJ and Dutch officials, recently entered into a settlement with telecommunications provider VimpelCom for FCPA violations. The settlement will cost the company $795 million in addition to requiring it to retain an independent corporate monitor for 3 years. The SEC allegations center on what SEC calls “… old fashioned bribes, hidden through sham contracts and charitable contributions …” The enforcement action is a solid reminder that the US DOJ and SEC remain focused on FCPA compliance and continue to cooperate with their foreign counterparts in enforcing the US law – even if the violations are “old fashioned.”
