The bribes were structured and concealed through payments to a shell company known by VimpelCom and Unitel to be beneficially owned by the Uzbek official. VimpelCom further concealed the scheme by falsifying its books and records and classifying the payments as charitable contributions as well as “equity transactions, consulting and repudiation agreements and reseller transactions.” VimpelCom executives “sought ways to give the company plausible deniability of illegality while knowingly proceeding with [the] corrupt business transactions.” In addition, VimpelCom failed to implement adequate internal accounting controls “which allowed the bribe payments to occur without detection or remediation.” When VimpelCom’s board of directors sought an FCPA legal opinion assessing corruption risks, “certain VimpelCom management withheld crucial information from outside counsel performing the review that restricted the scope of FCPA opinions, rendering them worthless.”

Source: A Bad Day for Kleptocracy: U.S. and Multiple International Authorities Coordinate to Prosecute and Forfeit Global Assets of VimpelCom – Lexology

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