The Russian government has begun to take creative approaches in the fight against corruption. These initiatives are aimed at raising public awareness of corruption among the general public.

Well its said whoever fights corruption should see to it that in the process he does not become corrupt. Most developed countries are seeking methods to curb corruption & find the best fit solutions for it. Anti-corruption has been a hot topic for almost every country for some time. The thirst to have a corrupt free mechanism for businesses where businesses should work against corruption in all its forms, including extortion and bribery. There are lot of organisations & multi-national companies and foundation have taken initiative to spread public awareness.

Recently, the Russian government has begun to take creative approaches in the fight against corruption. These initiatives are aimed at raising public awareness of corruption among the general public. What appears to be missing in this outreach is compliance guidance to companies in Russia. The Russian Anti-Corruption Law outlines a compliance framework but lacks specifics. Guidance to U.S. companies may be able to fill the gap.

Anti-Corruption Measures Guidance to Companies

The Russian anti-corruption laws offer very little guidance on what a company can and should do to ensure its compliance with anti-corruption laws. Compliance guidance to companies is limited to Article 13.3 of the Russian Anti-Corruption Law, which mandates that companies “develop and take anti-corruption measures.” The Article lists six measures compliance programs may include. They are:

  • (1) the appointment of a compliance officer;
  • (2) cooperation with law enforcement authorities;
  • (3) development and implementation of compliance policies and procedures;
  • (4) adoption of a code of ethics;
  • (5) prevention of conflicts of interest; and
  • (6) prevention of off-the-books record keeping and the use of falsified documents.

These measures are optional, and no additional guidance from the government appears to exist on the components of an effective compliance program.

But What About Businesses?

The government’s public outreach on anti-corruption is aimed at Russian citizens, including “pensioners and students.” But it leaves out businesses, a segment that is just as likely to engage in and suffer the consequences of corruption. In 2018, the Russian government opened 487 investigations against legal entities for bribery under Article 19.28 of the Administrative Offenses Code (Unlawful Remuneration on Behalf of a Legal Entity). These investigations resulted in the administrative fines imposed against 439 entities in the total amount of RUB 691 million (USD 10.7 million).

In 2019, the Prosecutor General’s Office added 35 entities to the public register of Article 19.28 offenders. These companies are prohibited from bidding in federal and municipal procurement tenders for a period of two years from the date of the administrative penalty. The register now lists over 1,200 entities in total.

While these numbers pale in comparison to prosecutions of corrupt government officials in Russia, they show businesses are far from being immune from corruption. This is why it is surprising that the government does not direct its outreach toward businesses as a segment that could benefit from anti-corruption education.

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