While in 2019, mobile TeleSystems DPA was only the fifth NPA or DPA in dollars, this is the second largest agreement in 2019 to set up an independent compliance monitor.  Consistent with its previous practice of imposing controls for which it considers companies` compliance programs to be immature, the DOJ states with Mobile TeleSystems that it is implementing a monitor “because the company [i.e., Mobile TeleSystems] has not yet implemented or tested its compliance program.”  The TeleSystems mobile DPA is also the second surveillance imposed in recent years on a foreign telecommunications company for alleged corruption against Uzbekistan. Only one of the FCPA`s decisions included self-declaration by the implementing company, and four of the seven agreements required independent compliance monitors. A more detailed analysis of this year`s FCPA resolutions can be found in our 2019 FCPA year-end update. In concluding the DPA, the Cartel Department found that “Rising cooperated substantially and in a timely manner with the U.S. investigation,” including the disclosure of information about other alleged cartel violations that are not included in the DPA.  The DPA also cited the fact that “Rising`s cooperation allowed the United States to advance its investigation of criminal antitrust conspiracies among other generic drug manufacturers,” and Rising`s agreement to pay reimbursement. .