VimpelCom, a Russian-owned, Amsterdam-based telecommunications company, and its wholly owned Uzbek subsidiary Unitel, have come to a global agreement to settle allegations that VimpelCom bribed its way into the Uzbek cable market. Unitel pled guilty to bribery charges, while VimpelCom entered into a criminal DPA and reached a civil settlement with the SEC. Altogether, VimpelCom agreed to pay more than $795 million to the SEC, DOJ and Dutch authorities, and agreed to take on a compliance monitor for three years. The investigation involved more than 17 jurisdictions and was accompanied by a civil forfeiture case seeking the funds paid to the corrupt foreign official in Uzbekistan that are squirreled away in Swiss bank accounts. Here we dissect the settlement and VimpelCom’s significant discounts for cooperation, despite its failure to self-report. In our next issue we will explore how VimpelCom’s blasé attitudes about corruption at its highest levels led to this historic settlement. See “From Discounts to Slush Funds: Red Flags to Heed and Eight Steps to Take to Avoid SAP’s $3.9 Million Mistakes” (Feb. 10, 2016).