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Telia Deferred Prosecution Agreement

[2] The DOJ awarded Telia the sentence imposed by the OM and the SEC awarded Telia the forfeiture payment imposed by the DOJ. The SEC also agreed to credit Telia, up to $208.5 million, for all recovery or forfeiture payments to be made by OM or Swedish authorities in related proceedings. See press release, Dep`t of Justice, Telia Company AB and its Uzbek subsidiary conclude a global foreign bribery resolution of more than $965 million for corruption payments in Uzbekistan; The companies approve a resolution coordinated between the Department of Justice, the U.S. Securities and Exchange Commission (SEC) and the Kingdom of the Netherlands, which represents the second major resolution on the corruption of telecommunications companies in Uzbekistan (September 21, 2017) www.justice.gov/opa/pr/telia-company-ab-and-its-uzbek-subsidiary-enter-global-foreign-bribery-resolution-more-965. In accordance with Telia`s agreement, the company will monitor and, where appropriate, improve its compliance program and internal controls and has already reported all those involved in the misconduct and their superiors. Telia has reached a deferred prosecution agreement as part of a criminal investigation filed today in the Southern District of New York, which accuses the company of conspiracy to violate the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA). The case was assigned to U.S. District Judge George B. Daniels. In addition, Coscom pleaded guilty and was convicted by Judge Daniels for an avowed criminal investigation that accused the company of conspiracy to violate FCPA anti-bribery rules. Pursuant to its agreement with the Ministry, Telia agreed to pay the United States a total fine of $US 274,603,972, including a fine of US$500,000 and US$40 million in criminal forfeiture that Telia was willing to pay on Behalf of Coscom.

Telia has also agreed to put in place strict internal controls and fully cooperate with the ministry`s ongoing investigations, including the investigation of individuals. On September 21, 2017, Swedish telecommunications company Telia Co. AB agreed to pay fines of $548.6 million under a deferred prosecution agreement (DPA) with the U.S. Department of Justice (DOJ) to settle allegations that Telia violated the Foreign Corrupt Practices Act (FCPA) by paying bribes to foreign officials. This comparison is another recent example: (1) the effectiveness of data protection authorities in ensuring cooperation between companies in investigations; and (2) the increasingly multilateral nature of FCPA investigations. According to a DOJ report, the corruption began in 2007, when Telia, which wanted to expand its business in Uzbekistan, bought the communications company Coscom LLC. Telia understood that in order to access and work in the Uzbek telecommunications market, they had to make regular payments to Uzbek officials – in this case Gulnara Karimova, eldest daughter of the late President Islam Karimov. This obligation to bribe civil servants has been explained to Telia`s management and the Board of Directors. . .

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