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ANTICORRUPTION CORRUPTION CONTINUES AS A NORMAL BUSINESS PRACTICE AROUND MUCH OF THE GLOBE, BUT THE ENFORCEMENT TENTACLES OF THE SEC ARE EXPANDING TO COUNTER CORRUPT PRACTICES THAT TOUCH BOTH DOMESTIC— AND FOREIGN-BASED— COMPANIES. 38 CO R P O R AT E B OA R D M E M B E R S E CO N D Q UA RT E R 2 0 1 6 THE ANNOUNCEMENT OF A SETTLEMENT in February between government agencies and VimpelCom to resolve violations of the Foreign Corrupt Practices Act was certainly notable for its size. VimpelCom, a Dutch-based telecom provider, agreed to pay government authorities more than $795 million to resolve its violations, including bribery- related payments of $114 million it had made using sham contracts, as well as payments made under the guise of legitimate charitable contributions and sponsorships, according to a court filing. But the deal was also noteworthy due to the scope of the investigations. As part of the settlement, VimpelCom agreed to pay $167.5 million to the Securities and Exchange Commission, $230.1 million to the Department of Justice, and $397.5 million to Dutch regulators. The SEC relied on assistance from the Justice Department, Internal Revenue Service, and Department of Homeland Security. Internationally, it marked the first time the United States had produced an anticorruption settlement with the Netherlands. The SEC also received significant assistance from agencies in Norway, Sweden, Switzerland, and Latvia. Other government agencies helping out included those from the British Virgin Islands, Cayman Islands, Bermuda, Ireland, Estonia, Spain, United Arab Emirates, Marshall Islands, and Gibraltar. “It was a truly global settlement,” says Kara Brockmeyer, chief of the SEC Enforcement Division’s FCPA Unit. “It’s the first time the US has done a global settlement with the Dutch, but it’s not the last time you are going to see a settlement like that. It’s a model we are going to continue to be using.” As the business world becomes increasingly global, so has enforcement of anticorruption statutes, as regulators KEITH BISHOP IADA FCPA EXPANDS ITS GLOBAL