Russia’s Federal Anti-Corruption Law No. 273, Article 13.3 requires companies operating in the country to implement anti-corruption compliance programmes containing specific anti-corruption measures. Failure to comply carries the risk of heavy fines, the extent of which depends on a company’s willingness to cooperate with authorities. Russian law does not provide an ‘adequate procedures’ legal defence against corruption offences.
- Designate responsibility for the prevention of bribery offences
- Adopt procedures for cooperating with authorities
- Implement procedures to ensure ethical business conduct
- Adopt a code of conduct for all employees
- Create policies for conflicts of interest
- Prevent the use of false documents
Russia has made a significant leap towards strengthening its legislative framework and aligning it with other internationally recognised national legislations, such as the FCPA and the Bribery Act. Companies doing business in Russia should review their anti-corruption programmes for compliance with the requirements of Russian law.