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Mobile TeleSystems (MTS) FCPA resolution (2019)

Last checked: 22 October 2026 · Case records

Yes, in the DOJ case. On 7 March 2019 DOJ announced that Mobile TeleSystems PJSC (MTS) entered a deferred prosecution agreement and its Uzbek subsidiary KOLORIT pleaded guilty 1. DOJ said the companies admitted paying about US$420 million in bribes to Gulnara Karimova 1. The combined penalty to US authorities was US$850 million 1. In its SEC order MTS settled "without admitting or denying the findings" 3. In 2022 DOJ extended the DPA term to 18 September 2023 4.
Resolution type
DOJ deferred prosecution agreement (MTS), guilty plea (KOLORIT), SEC administrative cease-and-desist order 1,3
Dates
SEC order 6 March 2019 3. DOJ announcement 7 March 2019 1. The court record dates the DPA 22 February 2019 4
Agencies
U.S. Department of Justice Criminal Division Fraud Section, U.S. Attorney's Office for the Southern District of New York, and the SEC 1,2
Court
Southern District of New York, Judge J. Paul Oetken, case 1:19-cr-00167-JPO 1,4
Total to US authorities
US$850 million. DOJ credited the US$100 million SEC civil penalty against the criminal penalty 1,2
DOJ breakdown
Criminal penalty including a US$500,000 criminal fine and US$40 million criminal forfeiture paid by MTS for KOLORIT 1
SEC amount
Civil penalty of US$100,000,000 3
Statutes
FCPA anti-bribery, books and records and internal controls provisions. SEC order under Exchange Act sections 30A, 13(b)(2)(A) and 13(b)(2)(B) 1,3
Admission
DOJ: "According to the companies' admissions" 1. KOLORIT pleaded guilty 1. SEC: "without admitting or denying the findings herein" 3
Monitor
Independent compliance monitor for three years, retained 18 September 2019 1,4
Status
DPA term extended by one year to 18 September 2023, by DOJ letter of 1 March 2022 4

The charges and the agreements

DOJ said MTS entered a deferred prosecution agreement on a criminal information filed in the Southern District of New York 1. KOLORIT, the Uzbek subsidiary, pleaded guilty to a one-count information charging conspiracy to violate the FCPA anti-bribery and books and records provisions 1. The MTS and KOLORIT matters were before U.S. District Judge J. Paul Oetken 1.

A joint court letter of 3 March 2022 says MTS and the government entered the DPA on 22 February 2019 4. DOJ announced the resolution on 7 March 2019 1. The SEC entered its order on 6 March 2019 3.

What MTS admitted

DOJ described the facts as "the companies' admissions" 1. According to DOJ, MTS and KOLORIT, through managers, employees and affiliated entities, paid about US$420 million in bribes to Gulnara Karimova between 2004 and 2012 1. DOJ described Karimova as a former Uzbek official and the daughter of Uzbekistan's former president 1.

DOJ said the bribes went through shell companies that MTS and Uzdunrobita management knew Karimova beneficially owned 1. DOJ said MTS acquired KOLORIT at an inflated price as part of the scheme, and that Uzdunrobita made payments to charities and sponsorships tied to Karimova 1.

The SEC said "MTS bribed an Uzbek official who was related to the former President of Uzbekistan" 2. The SEC said payments were "disguised in MTS's books as acquisition costs, option payments" and other items 2. MTS consented to the order "without admitting or denying the findings herein", except as to jurisdiction and subject matter 3.

Charges against individuals

On the same day DOJ unsealed charges against Karimova for conspiracy to commit money laundering 1. DOJ charged Bekhzod Akhmedov, a former Uzbek executive, with conspiracy to violate the FCPA, two FCPA counts and conspiracy to commit money laundering 1. DOJ said these charges are allegations and the defendants are presumed innocent 1. This page has not found a court ruling on either set of charges.

How DOJ set the penalty

DOJ said "A number of factors contributed to the Department's criminal resolution with the companies" 1. DOJ listed these factors 1:

  • The companies did not voluntarily disclose the conduct 1.
  • DOJ described their cooperation and remediation as "lacking, not proactive" 1.
  • DOJ cited the seriousness of the conduct, including about US$420 million in bribes to a high-level official 1.
  • As a mitigating factor, DOJ said the Uzbek government expropriated the companies' Uzbek assets and the companies realized no pecuniary gain 1.

Monitor and extension

DOJ said MTS agreed to "the imposition of an independent compliance monitor for a term of three years" 1. The SEC order sets a monitor term of at least 36 months 3. The joint court letter says MTS retained the monitor on 18 September 2019 and the DPA term was due to end on 18 September 2022 4.

In a letter dated 1 March 2022, DOJ extended the DPA term by one year to 18 September 2023 4. The government said MTS had made "significant improvements" but some anti-corruption compliance components were "not yet effective" 4. This page has not confirmed a later court filing on dismissal of the information.

Common questions

Did MTS plead guilty?

No. MTS entered a deferred prosecution agreement. Its subsidiary KOLORIT pleaded guilty to conspiracy to violate the FCPA anti-bribery and books and records provisions 1.

How much did MTS pay?

US$850 million to US authorities, with the US$100 million SEC penalty credited against the DOJ penalty 1,2.

Did MTS admit the SEC findings?

No. MTS consented to the SEC order "without admitting or denying the findings herein" 3. The DOJ case rests on the companies' admissions 1.

Was the MTS monitorship extended?

Yes. DOJ extended the DPA term by one year to 18 September 2023, according to a joint court letter of 3 March 2022 4.

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Sources

  1. U.S. Department of Justice, Office of Public Affairs: Mobile TeleSystems PJSC and Its Uzbek Subsidiary Enter into Resolutions of $850 Million with the Department of Justice for Paying Bribes in Uzbekistan, press release 19-200 (7 March 2019)
  2. U.S. Securities and Exchange Commission: Mobile TeleSystems Settles FCPA Violations, press release 2019-27 (6 March 2019)
  3. U.S. Securities and Exchange Commission: Order, In the Matter of Mobile TeleSystems PJSC, Exchange Act Release No. 85261, File No. 3-19022 (6 March 2019)
  4. U.S. District Court, Southern District of New York: joint letter and DOJ extension letter, United States v. Mobile TeleSystems PJSC, 1:19-cr-00167-JPO, Document 18 (3 March 2022)

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