News from Pohlmann & Company


GIR: VEON’s Chief Compliance Officer on Monitorship challenges

On December 2, 2019, an interview with Joshua Drew, Chief Compliance Officer of VEON Ltd. (formerly known as VimpelCom) was published on the Global Investigations Review website.

We are very pleased about Joshua Drew’s detailed statements and the positive resume regards our joint compliance monitorship which VEON recently completed successfully. In 2016, VEON accepted a three-year compliance monitorship which was based on a deferred prosecution agreement (DPA) with the US Department of Justice (DOJ) and the US Securities and Exchange Commission (SEC). In October of this year, after expiry of the three years term, the DOJ filed a motion to finally refrain from prosecuting VEON after Dr Andreas Pohlmann – as Independent Compliance Monitor – had confirmed in September 2019 that VEON had fulfilled its contractual obligations and that its compliance program is now reasonably designed, implemented and effective to prevent and detect violations of anti-corruption laws.

In his interview, Joshua Drew emphasizes the trustful relationship between the authority-imposed Monitor and his team. VEON is happy to have worked “really closely” with Andreas Pohlmann and his team. Andreas Pohlmann’s in-house experience also helped to keep an eye on the cost of the monitorship, Drew said. He highlighted the regular and close communication between the Monitor team and the company as an essential basis for the successful cooperation.

We are happy to endorse Joshua Drew’s positive remarks. We share his view that the key to a successful compliance monitorship lies in an open and constructive communication and interaction between the monitor and the company. From the outset, clear rules, roles and expectations of all parties involved should be defined. This avoids complex starting difficulties as well as later frictions but promotes successful collaboration.

Read the full article.