We are on Episode V of a five-part exploration of the recent the Department of Justice and Securities Exchange Commission resolution of a Foreign Corrupt Practices Act enforcement action against the Russian telecom company, MTS. In this episode,  I conclude with the lessons learned for the compliance professional. Today we focus on four key lessons: (1) due diligence, (2) business justification, (3) business valuation and (4) the long road of bribery.  The documents which are the subject of this series are: MTS Deferred Prosecution Agreement (DPA);MTS Criminal Information (MTS Information);SEC Cease and Desist Order (Order);Karimova and Akhmedov Indictment (Indictment);Kolorit Dizayn Ink LLC Plea Agreement (Plea Agreement); andKolorit Dizayn Ink Information (Kolorit Information);DOJ Press Release andSEC Press Release.For additional reading see the blog post, "MTS FCPA Settlement and Karimova Indictment: Part V – Lessons Learned" Learn more about your ad choices. Visit megaphone.fm/adchoices