In what some see as a lesson in what happens when a company experiencing a corruption problem opts not to self-disclose or to cooperate with the U.S. government, Moscow-based Mobile TeleSystems PJSC and Kolorit Dizayn Ink LLC, a subsidiary in Uzbekistan, have agreed to pay a combined penalty of $850 million to settle cases with the DOJ and the SEC involving bribes in Uzbekistan. The federal government continues to pursue two individuals involved in the matter. The Anti-Corruption Report considers the implications of the widespread investigation and the record-setting penalty for the regulated community. See “Anti-Corruption Enforcement Continues Apace Under New Administration” (Jun. 13, 2018),  “DOJ’s FCPA Corporate Enforcement Policy: Cooperation and Compliance Expectations (Part Three of Three)” (Feb. 7, 2018), and “DOJ and SEC Continue to Stress the “Holy Trinity” of Self-Disclosure, Cooperation and Remediation” (Nov. 9, 2016).