Settlements

ST-529
VimpelCom Limited and Unitel LLC (Netherlands Settlement)
VimpelCom Limited
Netherlands
Openbaar Ministrie (Public Prosecution Service)
Uzbekistan
2016
2/18
United States
Legal Person
Criminal
Out of Court Settlement
Criminal Fine; Criminal Confiscation
$397,500,000
$100,000,000
$297,500,000
$0
$0
$0
NA
Art.16
Art. 1, Art. 2, Art. 8
Bribery of foreign officials, falsification of books and records; internal controls violations
Bribery of foreign officials, falsification of books and records; internal controls violations
No (License)
According to the Press Release issued by the Openbaar Ministrie (Public Prosecution Service, DPP), "The criminal investigation was initiated in 2013. The Dutch criminal investigation was carried out by the FIOD under supervision of the National Prosecutor’s Office for Serious Fraud, Environmental Crime and Asset Confiscation (“Functioneel Parket”). During the investigation, Vimpelcom’s head office in Amsterdam was searched in March 2014. Vimpelcom has initiated its own investigation into its activities in Uzbekistan. This investigation was conducted by internal investigators, by an American specialized law firm and by forensic accountants. Both the DPPS and the US authorities were regularly informed about the results of this internal investigation. [ ]" VipelCom was fined US$!00 million and subject to confiscation of illegally obtained proceeds totaling US$130 million; US$167.5 million was confiscated from its subsidiary Unitel. (Source: Openbaar Ministrie, Vimpelcom pays close to 400 million dollars to the Netherlands for bribery in Uzbekistan," February 16, 2016. See also, Statement of Facts. Both at https://www.om.nl/algemeen/english/@93227/vimpelcom-pays-close/) The US Department of Justice press release stated that "Under the terms of its resolution with the SEC, VimpelCom agreed to a total of $375 million in disgorgement of profits and prejudgment interest, to be divided between the SEC and OM." (Source: US DOJ Press Release, "VimpelCom Limited and Unitel LLC Enter into Global Foreign Bribery Resolution of More Than $795 Million; United States Seeks $850 Million Forfeiture in Corrupt Proceeds of Bribery Scheme," February 18, 2016.)