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VEON (Formally Known As VimpelCom) Emerges From DPA


As highlighted in this previous post, in February 2016 telecommunications company VimpelCom (now known as VEON) resolved a Foreign Corrupt Practices Act enforcement action concerning conduct in Uzbekistan.

In resolving the matter through a three-year deferred prosecution agreement, the company agreed to pay a net $397.5 million FCPA settlement and also agreed to engage a compliance monitor.

Veon recently announced that the DPA has concluded. As stated in the release:

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Supreme Court To Hear Another SEC Disgorgement Case


As highlighted in this previous post, in 2017 the Supreme Court unanimously bench slapped the SEC in Kokesh v. SEC and held that disgorgement “in the securities-enforcement context is a ‘penalty’ within the meaning of [28 U.S.C.] 2462 and so disgorgement actions must be commenced within five years of the date the claim accrues.”

It was noted that while Kokesh was not an FCPA case, the decision was FCPA relevant given that disgorgement has become the dominant remedy sought by the SEC in corporate FCPA enforcement actions.

In covering the Kokesh decision, this prior post highlighted how a footnote in the Supreme Court’s decision seemed to be inviting another disgorgement case. Specifically, footnote 3 of the decision stated:

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This Week On FCPA Professor


FCPA Professor has been described as “the Wall Street Journal concerning all things FCPA-related,” and “the most authoritative source for those seeking to understand and apply the FCPA.”

Set forth below are the topics discussed this week on FCPA Professor.

As highlighted in this post, six years after being charged in connection with conduct that took place approximately 15 years ago, the trial of Lawrence Hoskins finally begins.

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Unaoil – The Trace International Piece Of The Puzzle


Trace International describes itself as “a globally recognized anti-bribery business organization and leading provider of third party risk management solutions.” (See here). According to Trace, its “due diligence solutions” are “based on internationally accepted best practices and our experience and familiarity with the compliance needs of multinational companies.”

According to Trace, being “Trace Certified” “means that you or your company have completed a comprehensive due diligence process administered by TRACE, the world’s leading anti-bribery standard setting organization.” Trace states that “the successful completion of TRACE certification demonstrates your commitment to commercial transparency, allowing you to serve as a valued business partner to multinational companies” and that one of the advantages of being Trace certified is “gain[ing] a valuable compliance credential that differentiates you from competitors and is widely recognized in the international business community.” (See here).

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DOJ Announces Guilty Pleas By Former Unaoil Executives


Yesterday, the DOJ announced that Cyrus Ahsani and Saman Ahsani (the former CEO and Chief Operations Officer of Monaco-based Unaoil) pleaded guilty in March 2019 to one count of conspiracy to violate the FCPA for their roles in a scheme to corruptly facilitate millions of dollars in bribe payments to officials in multiple countries. The DOJ also announced that Steven Hunter (a former business development manager at Unaoil) pleaded guilty in August 2018 to one count of conspiracy to violate the FCPA.

Prior Foreign Corrupt Practices Act enforcement actions against Rolls-Royce and SBM Offshore (see here and here) involved, in whole or in part, Unaoil and the Ahsani information refers to approximately 25 other companies including approximately ten U.S. based issuers. Thus, it is likely that additional FCPA enforcement actions involving, in whole or in part, Unaoil will be forthcoming.

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