Action against Respondent, a Russian telecom company, for alleged violations of the FCPA’s anti-bribery, books and records, and internal accounting control provisions. According to the SEC, Respondent made improper payments to Uzbek government officials to gain market access and improperly recorded the payments in its books and records. Respondent has agreed to pay a civil penalty of $100 million. In parallel criminal proceedings, Respondent has entered into a deferred prosecution agreement with the Department of Justice and has agreed to pay $850 million in criminal fines and forfeiture. Respondent’s subsidiary has pleaded guilty to federal charges.