MTS FCPA Settlement and Karimova Indictment: Part III – Missed Red Flags and Overridden Controls
Tom Fox continues a five-part series about the recent DOJ and SEC resolution of a Foreign Corrupt Practices Act enforcement action against Russian telecom giant Mobile TeleSystems, discussing the failures in the MTS compliance regime, the override of internal controls, and local business unit management which facilitated the bribery schemes.
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