There is a constant drumbeat of daily news about Russia and investigations of possible collusion to fix the election. Also, following the release of the “Panama Papers” stories about Russian corruption and offshore moneys leading to friends of Vladimir Putin added to the fuel of interest in the Russian way of business. As a result, independent Counsel Robert Mueller will have lots of leads from the information previously released by the investigative media which may connect to his investigation of meetings by election officials with Russian representatives.
Interestingly, a large number of U.S. companies not only still do business in Russia, but they own subsidiary companies there and those companies are doing quite well. However, a look at cases investigated and settled by either the Securities and Exchange Commission (SEC) or the Department of Justice (DOJ) reveals that many of the companies doing business in Russia are settling cases alleging that they have been paying substantial bribes to government officials in violation of the Foreign Corrupt Practices Act (FCPA). Also, there is another trend and that is that whistleblowers, seeking the allowed 15-30% reward of what the U.S. recovers are bringing forth cases under the False Claims Act (FCA) allowing for citizens or non-citizens to file cases on behalf of the government when they reveal new info not known by the Government. Because the whistleblowers are insiders with detailed information, often presenting supportive emails and document to corroborate their cases, the fact of cases alleging bribes to Russian officials is no longer uncommon.
What companies have settled such cases in recent years?