Settlements In Brief: Notable Settlements In February

Enforcement actions by criminal and supervisory authorities are settled regularly. In light of these developments, companies are advised to take appropriate measures. This month we highlight some notable settlements that were reached in the US and the Netherlands in February. Enforcement in February mainly focused on the bribery of foreign officials in both the US and the Netherlands. The Dutch Public Prosecution Service, the U.S. Department of Justice and the Securities and Exchange Commission settled with Vimpelcom Ltd. for a record amount of approximately USD 795 million in connection with allegations of bribery of foreign officials. Furthermore, both the DOJ and the SEC settled with PTC Inc. for bribing Chinese officials in order to obtain certain contracts. In addition, there was also a noteworthy settlement that was not based on the U.S. Foreign Corrupt Practices Act. This was the USD 2.5 million settlement that the U.S. Office of Foreign Assets Control entered