Ministry Higher Education of Russian Federation

Southern Federal University

Faculty of Economics
Department of Finance and Credit

Anti-corruption compliance

By : Ghazi Patang
MS Student of Global Business and Forensic Accounting
Group: 1.5
 Introduction
 Whistleblower Systems in General
 A whistleblowing system is an early-warning system for identifying and combating maladministration and
forms the basis for successful risk management.
 Informants can pass on information within a fully internal system, keeping the information from leaking to
external sources and thus avoiding reputation damage to the company.
 Employee feedback is the best way to detect compliance violations. Experience shows that companies and
organizations lose around 7% of their annual revenue through fraudulent activities.
 Evidence of such activity which is passed on anonymously and securely can help to detect a significant
proportion of these cases, thereby minimizing financial damage to companies caused by compliance issues.
 Article 33 of the UNCAC implies that whistleblowers report facts concerning crimes listed in Chapter III of
the Convention: Bribery of national public officials; Bribery of foreign public officials and officials of
public international organizations; Embezzlement, misappropriation or other diversion of property by a
public official; Trading in influence; Abuse of functions; Illicit enrichment; Bribery in the private sector;
Embezzlement of property in the private sector; Laundering of proceeds of crime;  Concealment; and
Obstruction of justice.
Whistle blowing
 The disclosure of information related to corrupt,
illegal, fraudulent or hazardous activities being
committed in or by public- or private-sector
organisations46 – which are of concern to or
threaten the public interest – to individuals or
entities believed to be able to effect action.
 Definition of Whistleblowing “Whistleblower” to
mean 'any person who reports or discloses
information on a threat or harm to the public
interest in the context of their work-based
relationship, whether public or private'.
How does Whistleblower Systems work ？
 As insiders to an organization, whistle-blowers have specific knowledge, access and expertise which
allow them to detect corruption or other matters of concern that might otherwise remain hidden.
However, they are often in a difficult situation owing to their possible loyalty to colleagues and
supervisors, contractual confidentiality obligations, and the risk of retaliation.
 A distinction can be made between open, confidential and anonymous forms of reporting (UNODC,
2015, p. 48):
 Open reporting: Where individuals openly report or disclose information, or state that they do not endeavor to
ensure or require their identity to be kept secret.
 Confidential reporting: Where the name and identity of the individual who disclosed information is known by
the recipient, but will not be disclosed without the individual's consent, unless required by law.
 Anonymous reporting: Where a report or information is received, but no one knows the source.
 There are also different channels through which to report. The three main reporting channels are:
 1) internal reporting;
 2) external reporting to a regulator, law enforcement agency or other specific authority , external
reporting to the media or another public platform (such as in the Mossack Fonseca Papers case).
How to protect yourself as a whistleblower
 Document everything. Document all of the information you have gathered and
store it in a safe place. ...
 Be reliable and credible. Make yourself a reliable and credible source. ...
 Raise the issue. ...
 Be careful who you disclose to. ...
 Choose a trustworthy journalist. ...
 Transmit safely. ...
 Know your rights. ...
 The world needs whistleblowers.
 Scope : protection
 It is practicable to deal separately with the public and private sectors. Indeed, the Netherlands provides an
example of a non-statutory approach to the private sector with its “Statement on dealing with suspected
malpractices in companies” operating as an informal standard to which the courts have regard. There are
differing views as to whether this is satisfactory.
 It could also be possible to have a phased introduction of the protections for each sector, maybe by beginning
with protections in the public sector and then extending the law to(Council of Europe ) the private sector.
However we argued in the comparative analysis of practices in CoE member states to protect whistleblower
that it is preferable to cover both private and public sectors in a single law at the outset.
 Moreover the European Court for Human Rights has made clear in several important cases that
whistleblowers in any walk of life who suffer retaliation may bring cases before it on the basis that their right
to freedom of expression under Article 10 of the European Convention on Human Rights has been violated51 .
 Our recommendation is therefore that an overarching law should be drafted to cover all workers, in public and
private sectors, who report any kind of wrongdoing.
 That might form part of Labour Law. That would ensure that it becomes well known, applies to all employees
and is recognized as an issue for the Lab our Inspectorate. Separate action would need to be taken for any
persons - for example entrepreneurs – who are not subject to Labor Law.
Overview of Article 33

 This section sets out the boundaries of Article 33 and hence of this study. It takes
account of the guidance issued by UNODC(United Nations Office on Drugs and
Crime) – the Legislative Guide and the Technical Guide.
 Article 33 states: ‘Each State Party shall consider incorporating into its domestic
legal system appropriate measures to provide protection against any unjustified
treatment for any person who reports in good faith and on reasonable grounds to
the competent authorities any facts concerning offences established in accordance
with this Convention.’
What kinds of protection?

 Article 33 is not about witness protection, which is covered by Article 32. The Technical
Guide explains the difference by saying Article 33 was made to cover indications of
corruption that fall short of evidence. In practice, there is an overlap as some whistleblowers
may possess solid evidence, and become witnesses in legal proceedings, but the main point
is that Article 33 covers early stages when there may well be no question of proceedings.
Indeed, the ideal situation is where a whistleblower raises concerns in time so that action can
be taken to prevent any offence.

 The Legislative Guide says that measures of protection may include psychological support,
institutional recognition of reporting, and transferring whistleblowers within the same
organization or relocating them to a different one. In its discussion of Article 8, the
Legislative Guide mentions that provision of confidential in-house advice to whistleblowers
is also part of an effective protection system. The Technical Guide mentions compensation
and civil damages as protective measures.
Protection against what?

 Article 33 encourages states to provide protection against ‘any unjustified

treatment’, and is thus not confined to physical threats or dismissal. Many legal
systems have measures to cover crude forms of retaliation, but there may be a gap
as regards more subtle forms, which can have equally serious consequences (e.g.
by forcing resignation). It is a strength of Article 33 that it has this wide scope, as
any finite list of forms of mistreatment would risk missing something.
Protection for whom?

 Article 33 applies to ‘any person’ who reports facts about offences. This study
generally uses ‘whistleblower’ as a more convenient term, but it does not have
quite the same broad scope. The term 'whistleblower' is traditionally reserved for
insiders – organization members who disclose wrongdoing under the control of
that organization – and this is generally the focus of national laws. It is also the
focus of this study, as insiders are best placed to assist corruption investigators,
and also run the most risks. However, under Article 33, the position of ordinary
citizens also needs to be considered.
What is required of the whistleblower?

 Article 33 requires the whistleblower to have not only ‘reasonable grounds’ but
also ‘good faith’. ‘Reasonable grounds’ is a sufficiently clear term, and there is
general agreement on the fundamental point that, provided whistleblowers have
reasonable grounds to suspect wrongdoing, their reports should be protected, even
if they are mistaken. ‘Good faith’ is less clear and there is no definition of the
term.
Whom to report to?

 Article 33 is about reports to ‘competent authorities’.10 These are the authorities

with the powers to address the wrongdoing exposed by the whistleblower – for
example an anticorruption commission, an ombudsman, audit body or the police.
If these authorities have effective enforcement powers and deal with the issue
promptly and discreetly, there may never be any possibility of retaliation against
the whistleblower. Article 33 does not cover reports to the media or anonymous
leaking platforms, but national laws will be more effective if they address this
issue
What are the reports about?
 Article 33 covers reports about facts concerning all offences under the Convention, which is wide-
ranging and understands corruption in a broad sense. In practice, most member states that have
developed whistleblower systems have given them a very wide scope, covering reports of all illegal
acts (and sometimes misconduct that is not actually illegal) in addition to Convention offences.
 However the view may be taken in some countries that corruption is the most serious and pressing
issue, and it is an option to start with corruption and extend the scope later. This was done in South
Korea.
State of implementation of Article 33

 This section makes a general assessment of the status of implementation and

enforcement of UNCAC Article 33, using all published materials from the
UNCAC review process and the UNCAC Coalition country reports.
Legislative Structure, Operation and Review
 Dedicated legislation – in order to ensure clarity and seamless application of the whistleblower framework, stand-
alone legislation is preferable to a piecemeal or a sectorial approach.
 Publication of data – the whistleblower complaints authority (below) should collect and regularly publish (at least
annually) data and information regarding the functioning of whistleblower laws and frameworks (in compliance with
relevant privacy and data protection laws).
 This information should include the number of cases received; the outcomes of cases (i.e. dismissed, accepted,
investigated, validated); compensation and recoveries (maintaining confidentiality if the whistleblower desires); the
prevalence of wrongdoing in the public and private sectors; awareness of and trust in whistleblower mechanisms; and
time taken to process cases.
 Involvement of multiple actors – the design and periodic review of whistleblowing laws, regulations and procedures
must involve key stakeholders including employee organizations, business/employer associations, civil society
organizations and academia.
Whistleblower training – comprehensive training shall be provided for public sector agencies and publicly traded
corporations and their management and staff. Whistleblower laws and procedures shall be posted clearly in public- and
private-sector workplaces where their provisions apply.
Whistleblower complaints authority

 An independent agency shall receive and investigate

complaints of retaliation and improper investigations of
whistleblower disclosures.
 The agency may issue binding recommendations and
forward relevant information to regulatory, investigative
or prosecutorial authorities for follow-up.
 The agency shall also provide advice and support,
monitor and review whistleblower frameworks, raise
public awareness to encourage the use of whistleblower
provisions, and enhance cultural acceptance of
whistleblowing.
 The agency shall be provided with adequate resources
and capacity to carry out these functions.
case related to corruption in USA

 Kellogg Brown & Root

 This company, now known as KBR, Inc., was spun off from a subsidiary of
Halliburton. It is one of the largest engineering and construction firms in the
world and has been connected to large U.S. military contracts.
 According to the New York Times, in 2009, the Department of Justice charged
the company with offenses under the FCPA, including paying hundreds of
millions of dollars to secure a natural gas plant construction contract to Nigerian
officials.
 KBR pleaded guilty, as did its CEO Albert Jack Stanley, and paid $402 million in
fines, as well as $177 million to the SEC. Stanley was sentenced to 2.5 in prison,
beginning in 2012.
The G20 principles
 The G20 (the informal group of some countries with the largest economies), has
been active on whistleblowing, at least on the theoretical side.
 In 2011 they published a study on law and practice in the G20 countries, including
Russia. It concludes with a compendium of best practices and guiding principles
on the protection of whistleblowers15.
 These guiding principles are very constructive, but though all G20 states
committed themselves to implementing these principles in legislation by the end
of 2012, it does not appear that they have fulfilled this pledge and there is no
review mechanism to check this.
The Council of Europe Recommendation
 In 2012 the Council of Europe commissioned a feasibility study16 which concluded that the most practical and swiftest means of
supplementing the existing measures within the Council of Europe would be a Recommendation.
 Its principles set out some of the basic requirements of a good whistleblower law:
 to cover all individuals working in the public or private sectors, irrespective of the nature of their working relationship and whether
they are paid or not (Principle 3);
  to also cover individuals whose work-based relationship has ended and, possibly, where it is yet to begin in cases where
information concerning a threat or harm to the public interest has been acquired during the recruitment process or other pre-contractual
negotiation stage (Principle 4);
  to permit a special scheme to apply to highly classified information. This refers to information only, so it does not permit categories
of persons (such as security service personnel) to be subject to a modified scheme. Rather, it is the category of information that may be
subject to a modified scheme. Security service personnel may have disclosures to make about issues that are not rightly secret (e.g.
corruption in procurement) (Principle 5);
  to prevent an employer from being able to rely on an individual’s legal or contractual obligations (e.g. confidentiality or loyalty) to
prevent whistleblowing or penalize someone for having done so (Principle 11);  to include disclosures to the public in the
whistleblower protection framework (Principle 14);
  to require whistleblowers’ reports to be investigated promptly (Principle 19);  to ensure protection is not lost if the
whistleblower’s report is mistaken. All that is required is that “he or she had reasonable grounds to believe in its accuracy”. There is no
mention of “good faith”, recognizing that motivation is not important, as long as there is a public interest (Principle 22);
  to entitle whistleblowers to raise the fact that they made a disclosure in accordance with the national framework in civil, criminal or
administrative proceedings (Principle 23);
 Watergate scandal
 The Watergate scandal was a political scandal in the United States involving the administration of U.S.
President Richard Nixon from 1972 to 1974 that led to Nixon's resignation. The scandal stemmed from the
Nixon administration's continuous attempts to cover up its involvement in the June 17, 1972 break-in of
the Democratic National Committee headquarters at the Washington, D.C. Watergate Office Building.
 After the five perpetrators were arrested, the press and the U.S. Justice Department connected the cash
found on them at the time to the Nixon re-election campaign committee.
 Further investigations, along with revelations during subsequent trials of the burglars, led the U.S. House
of Representatives to grant its judiciary committee additional investigation authority to probe into "certain
matters within its jurisdiction",] and the U.S. Senate to create a special investigative committee. The
resulting Senate Watergate hearings were broadcast "gavel-to-gavel" nationwide by PBS and aroused
public interest.
 Witnesses testified that the president had approved plans to cover up administration involvement in the
break-in, and that there was a voice-activated taping system in the Oval Office.[6][7] Throughout the
investigation, the administration resisted its probes, which led to a constitutional crisis.[
 Watergate scandal
 Several major revelations and egregious presidential action against the investigation later in 1973 prompted the
House to commence an impeachment process against Nixon.
 The U.S. Supreme Court ruled that Nixon must release the Oval Office tapes to government investigators. The
tapes revealed that Nixon had conspired to cover up activities that took place after the break-in and had attempted
to use federal officials to deflect the investigation.
 The House Judiciary Committee then approved articles of impeachment against Nixon for obstruction of justice,
abuse of power, and contempt of Congress. With his complicity in the cover-up made public and his political
support completely eroded, Nixon resigned from office on August 9, 1974. It is believed that, had he not done so,
he would have been impeached by the House and removed from office by a trial in the Senate. He is the only U.S.
president to have resigned from office. On September 8, 1974, Nixon's successor, Gerald Ford, pardoned him.
 There were 69 people indicted and 48 people—many of them top Nixon administration officials—were convicted.
 The metonym Watergate came to encompass an array of clandestine and often illegal activities undertaken by
members of the Nixon administration, including bugging the offices of political opponents and people of whom
Nixon or his officials were suspicious; ordering investigations of activist groups and political figures; and using
the Federal Bureau of Investigation, the Central Intelligence Agency, and the Internal Revenue Service as political
weapons.The use of the suffix "-gate" after an identifying term has since become synonymous with public scandal,
especially political scandal.
Watergate and the Constitution
 When Richard Nixon resigned in 1974 in the wake of the Watergate scandal, it was
only the second time in our history that impeachment of a President had been
considered. Nearly every action taken with regard to the case had some constitutional
significance. The document shown here deals with a specific question: Should the
Watergate Special Prosecutor seek an indictment of the former President?
 It is two pages of a three-page memorandum written for the Watergate Special
Prosecutor in August 1974, after Richard Nixon resigned the Presidency and before
President Ford pardoned him. (The third page adds one more item to the pro-
indictment list and adds another category, "delay decision.")
 The Office of the Special Prosecutor was created by Executive Order in May 1973 and
twice faced the question of whether to seek an indictment of Richard Nixon. The first
time was in March 1974, when the grand jury handed down indictments of seven
White House aides for perjury and obstruction of justice.
 Watergate and the Constitution
 President Nixon was named an "unindicted coconspirator" at that time because Watergate Special
Prosecutor Leon Jaworski advised the grand jury that in his opinion a sitting President could not be
indicted. In his view, the House Judiciary Committee was the appropriate body under the Constitution for
examining evidence relating to the President.
 The House Judiciary Committee pursued its constitutional mandate and drew up five articles of
impeachment, three of which they approved in the summer of 1974. When the President was forced by the
Supreme Court in August 1974 to surrender tape recordings that revealed his knowledge of the cover-up,
even his staunchest supporters in the House admitted that they would have to vote in favor of
impeachment. On August 9, 1974, President Richard Nixon resigned the Presidency and became citizen
Richard Nixon.
 Thus, for the second time the Watergate Special Prosecutor's Office faced the question of whether or not to
seek an indictment. Article I, section 3, clause 7 of the Constitution provides that a person removed from
office by impeachment and conviction "shall nevertheless be liable to Indictment, Trial, Judgment and
Punishment, according to the Law." But there are no guidelines in the Constitution about a President who
has resigned. The memorandum shown here is typical of others in this file. It outlines reasons for and
against pursuing an indictment against Richard Nixon. It is taken from Records Relating to Richard M.
Nixon, Records of the Watergate Special Prosecution Force, Record Group 460.
Siemens: corruption made in Germany
 Embed from Getty Images
 Did you know that certain bribes paid abroad were technically tax deductible for
German companies until 1999? They could simply categories them as “useful
expenditures”, as long as those expenses were not incurred in Germany and there were
no foreign state officials involved.

In 2006, however, it became clear that Siemens, one of Germany’s biggest companies,
was taking corporate bribery to a whole new level. For over a decade, it paid bribes to
government officials and civil servants around the world, amounting to approximately
US$1.4 billion. While corrupt decision makers profited, citizens in the affected
countries paid the costs of overpriced necessities such as roads and power plants.
 FOREIGN CORRUPT PRACTICES ACT OF 1977
 It contains the Department's policy regarding investigations and prosecutions of violations of the
Foreign Corrupt Practices Act (FCPA). The FCPA prohibits both United States and foreign
corporations and nationals from offering or paying or authorizing the offer or payment, of anything of
value to a foreign government official, foreign political party, party official, or candidate for foreign
public office, or to an official of a public international organization in order to obtain or retain
business.
 In addition, the FCPA requires publicly-held United States companies to make and keep books and
records which, in reasonable detail, accurately reflect the disposition of company assets and to devise
and maintain a system of internal accounting controls sufficient to reasonably assure that transactions
are authorized, recorded accurately, and periodically reviewed.
Policy Concerning Criminal Investigations and Prosecutions of the Foreign
Corrupt Practices Act.

 No investigation or prosecution of cases involving alleged violations of the antibribery provisions of

the Foreign Corrupt Practices Act (FCPA) of 1977 (15 U.S.C. §§ 78dd-1, 78dd-2, and 78dd-3) or of
related violations of the FCPA's record keeping provisions (15 U.S.C. § 78m(b)) shall be instituted
without the express authorization of the Criminal Division.
 Any information relating to a possible violation of the FCPA should be brought immediately to the
attention of the Fraud Section of the Criminal Division. Even when such information is developed
during the course of an apparently unrelated investigation, the. Fraud Section should be notified
immediately. Close coordination of such investigations and prosecutions with the United States
Securities and Exchange Commission (SEC) and other interested agencies is essential. Additionally, the
Department has established a FCPA Opinion Procedure concerning proposed business conduct See 
A Resource Guide to the U.S. Foreign Corrupt Practices Act.
 Policy Concerning Criminal Investigations and Prosecutions
of the Foreign Corrupt Practices Act.
 Unless otherwise agreed upon by the AAG, Criminal Division, investigations and prosecutions of alleged
violations of the ant bribery provisions of the FCPA will be conducted by Trial Attorneys of the Fraud
Section. Prosecutions of alleged violations of the record keeping provisions, when such violations are
related to an ant bribery violation, will also be conducted by Fraud Section Trial Attorneys, unless
otherwise directed by the AAG, Criminal Division.
 The investigation and prosecution of particular allegations of violations of the FCPA will raise complex
enforcement problems abroad as well as difficult issues of jurisdiction and statutory construction. For
example, part of the investigation may involve interviewing witnesses in foreign countries concerning
their activities with high-level foreign government officials. In addition, relevant accounts maintained in
United States banks and subject to subpoena may be directly or beneficially owned by senior foreign
government officials. For these reasons, the need for centralized supervision of investigations and
prosecutions under the FCPA is compelling.
 FCPA Corporate Enforcement Policy
 1. Credit for Voluntary Self-Disclosure, Full Cooperation, and Timely and Appropriate Remediation in
FCPA Matters: Due to the unique issues presented in FCPA matters, including their inherently
international character and other factors, the FCPA Corporate Enforcement Policy is aimed at providing
additional benefits to companies based on their corporate behavior once they learn of misconduct.
If a criminal resolution is warranted for a company that has voluntarily self-disclosed, fully cooperated, and
timely and appropriately remediated, the Fraud Section:
 will accord, or recommend to a sentencing court, a 50% reduction off of the low end of the U.S.
Sentencing Guidelines (U.S.S.G.) fine range, except in the case of a criminal recidivist; and
 generally will not require appointment of a monitor if a company has, at the time of resolution,
implemented an effective compliance program.    
To qualify for the FCPA Corporate Enforcement Policy, the company is required to pay all disgorgement,
forfeiture, and/or restitution resulting from the misconduct at issue.
 FCPA Corporate Enforcement Policy
 2.Limited Credit for Full Cooperation and Timely and Appropriate Remediation in FCPA Matters
Without Voluntary Self-Disclosure:
 
If a company did not voluntarily disclose its misconduct to the Department of Justice (the
Department) in accordance with the standards set forth above, but later fully cooperated and timely
and appropriately remediated in accordance with the standards set forth above, the company will
receive, or the Department will recommend to a sentencing court, up to a 25% reduction off of the
low end of the U.S.S.G. fine range. 
 Civil Injunctive Actions
 The SEC has authority to obtain civil injunctions against future violations of the record keeping and
ant bribery provisions of the FCPA by issuers. See 15 U.S.C. § 78u. Civil injunctions against
violations of the ant bribery provisions by domestic concerns and foreign nationals and companies
shall be instituted by Trial Attorneys of the Fraud Section in cooperation with the appropriate United
States Attorney, unless otherwise directed by the AAG, Criminal Division. 
 Legal entities' responsibility for corruption
 The imputation principle and conditions of American legal person:
 American courts apply two different principles to impute liability to legal persons. One is the employer responsibility system, and the other is the
imputation according to the judicial characteristics of different regions.
 According to the employer responsibility system, the criminal act committed by the agent for the benefit of the legal person within the scope of his
position should be attributed to the legal person. In addition to the criminal punishment of the agent, the legal person should also bear criminal
responsibility for the agent's behavior.
 Generally speaking, the American federal courts use the employer liability system in the legal person imputation, while the imputation principles
used by the state courts are different.
 Some states apply the same principle. According to the same principle, directors, managers and other senior managers with the status of a legal
person are the components of the legal person, and the criminal acts they commit, in addition to the criminal punishment to the perpetrator, the legal
person should also bear criminal responsibility.
 However, for general practitioners, the same principle stipulates that legal persons do not have to bear criminal liability, but only bear civil liability.
 The imputation conditions of a legal person can be divided into:
 The behavior of the agent occurs within the position. The legal person shall only bear criminal responsibility for the acts of the agent within the
scope of his duties. As long as an illegal act of an agent is actually authorized or obviously authorized, it is considered to be an act that takes place in
his position. However, there is a difference between the actual authorization and the obvious authorization.
 In order to meet this condition for the interests of the legal person, it does not require the legal person to get the actual benefit as long as the agent
has the intention to seek profit for the legal person.
 The understanding and behavior of the agent shall be attributed to the legal person. American courts have established a number of principles,
including the principle of collective cognition, the principle of intentional disregard, the principle of criminal complicity, the principle of merger or
division, and the principle of shielding felonies.
The cases of VimpelCom
 VimpelCom, the Russian mobile phone operator, has agreed to pay $795m in penalties to US and
Dutch authorities and admitted to bribing a government official related to the president of
Uzbekistan to gain entry into the country and win valuable telecom licenses.
 Its Uzbek subsidiary, Unite, pleaded guilty in a US court to conspiring to violate the US Foreign
Corrupt Practices Act by paying $114m in bribes to the official.
 US authorities at the Department of Justice and Securities and Exchange Commission say the
bribes that were paid between 2006 and 2012 gave VimpelCom entry into the Uzbek market and
allowed it to obtain 3G and 4G licences that generated more than $2.5bn in revenue.
 The DoJ also filed a civil forfeiture lawsuit seeking $550m that it says is linked to the official
who received the bribes from VimpelCom as well as TeliaSonera, the Swedish phone company,
and the Russian operator Mobile TeleSystems, according to the US forfeiture complaint.
Why can the VimpelCom be punished under the Foreign
corrupt practices Act
 Under FCPA rules, if funds used for overseas corruption programs are processed through US bank accounts,
the DoJ has extraterritorial jurisdiction and can be held accountable.
 VimpelCom Co., Ltd. violates the provisions of the United States Foreign corrupt practices Act prohibiting
the payment of bribes to foreign public officials.
 VimpelCom LLC also violated the Securities and Exchange Commission's Anti-Corruption Act, so the
Securities and Exchange Commission sought a civil fine: $167.5 million
 At the same time, in this case, according to the provisions of legal person imputation in the United States. For
multinational corporations, if the parent company does participate in some actual illegal and criminal acts of
the subsidiary, the legal person of the company needs to bear the relevant criminal responsibility and
punishment.
 The case was finally settled, and VimpelCom signed a deferred prosecution agreement and accepted penalties
from the U.S. Department of Justice and the Securities and Exchange Commission without criminal liability.
 But for the company itself, VimpleCom also adopted a strict internal control system and revised its anti-
corruption provisions, and the company also sold some shares in its subsidiary Unitel to reduce social impact.