The third installment of a series of Foreign Corrupt Practices Act (FCPA) enforcement actions of escalating severity dropped on March 6, 2019, when the Russian telecommunications giant Mobile TeleSystems (MTS) agreed to $850 million in penalties for its alleged involvement in bribery related to access to the telecommunications market in Uzbekistan. This punishment followed penalties of $965 million in September 2017 and $795 million in February 2016 against European telecommunications companies that had engaged in similar conduct. The monetary penalty bloodletting has occurred on a vast stage stretching across Europe and into Central Asia, which has seen the downfall of ...
