On October 31, 2019, Netherlands-based VEON Ltd. (formerly known as VimpelCom Ltd.), one of the largest global telecommunications companies in the world, announced that its independent monitor had “certifie[d]” VEON’s compliance program. In 2016, VimpelCom and its wholly-owned Uzbek subsidiary paid over $795 million to US and Dutch authorities to resolve criminal charges and civil proceedings arising out of the payment of over $114 million in bribes to an Uzbek government official. This included entering into a deferred prosecution agreement with the DOJ.
The DPA, and a related judgment by the US Securities and Exchange Commission, required that VEON implement a compliance and ethics program designed to prevent and detect violations of the Foreign Corrupt Practices Act and other applicable anti-corruption laws. VEON also undertook a review of its existing controls and compliance policies and procedures. The DOJ and the SEC agreed VEON had successfully completed the term of the monitorship, and the DOJ filed a motion to dismiss the charges deferred by the DPA.