Russia’s Anti-Bribery Enforcement Efforts Show Signs of Improvement

Fines and Penalties Increase in 2019

Moscow, Russia - In recent years, Russia has taken significant steps to crack down on corporate bribery. According to a new report, the maximum fine imposed by a court during 2019 rose from RUB 30.5 million to RUB 50 million, while a single case saw a fine of RUB 100 million imposed along with the confiscation of a RUB 56 million bribe.

Tougher Penalties and Increased Enforcement

The report analyzed Russia’s anti-bribery enforcement efforts and found that while fines may still be relatively low in some cases, the courts are increasingly imposing tougher penalties on companies found guilty of bribery. In addition to fines, companies can also face the prospect of being added to a blacklist of companies convicted of bribery, which can have serious consequences for their reputation and even expose them to additional prosecution risks outside of Russia.

Key Lessons for Companies Operating in Russia

The report highlights several key lessons for companies operating in Russia, including:

• The importance of implementing effective compliance management systems
• The need for regular training and awareness programs for employees
• The importance of having a clear anti-corruption policy in place

In one notable case, a court ruled that a bank had taken sufficient measures to prevent bribery by adopting an internal anti-corruption regulation and familiarizing employees with it.

Challenges Ahead

While progress is being made, the report also notes that foreign companies may soon find themselves in the crosshairs of Russian authorities. New legislative changes have increased the possibility of prosecution for bribery offenses committed outside of Russia, and the duration of investigations can now be extended from two months to 12 months.

Conclusion

The report concludes by noting that while there are still challenges to overcome, Russia’s anti-bribery enforcement efforts are showing signs of improvement. Companies operating in or with operations in Russia would be well advised to take steps to ensure compliance with local laws and regulations to minimize the risk of fines, penalties, and reputational damage.

Recommendations

• Implement effective compliance management systems
• Regularly review and update anti-corruption policies and procedures
• Provide regular training and awareness programs for employees
• Conduct thorough due diligence on business partners and third-party vendors