Russia's Amended Anti-Bribery Law: Extended Statute of Limitations, Greater Penalties and More

Developing and Implementing Mandatory Affirmative Anti-Corruption Measures, Navigating Interplay with FCPA

Recording of a 90-minute CLE webinar with Q&A

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Conducted on Wednesday, November 19, 2014

Recorded event now available

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Course Materials

This CLE course will provide guidance for counsel to companies doing business in Russia to develop and implement a compliance program consistent with not only guidance from U.S. and U.K. authorities, but also from the Russian Ministry of Labor. The panel will review recent anti-corruption enforcement actions involving allegations of misconduct in Russia and discuss approaches to the unique anti-corruption compliance challenges presented in Russia.


Due to the perceived endemic nature of corruption in Russia, conducting business in Russia presents complex challenges for counsel to U.S. and multinational companies, executives, and employees in complying with the FCPA, who will undoubtedly face the challenges of complying with applicable anti-corruption laws, including the FCPA, the U.K. Bribery Act, laws enacted by member states of the Organization for Economic Cooperation and Development, and the amended Russian law on countering corruption.

The amended Russian law now not only includes greater penalties (including longer prison terms) and extended statutes of limitations, but also requires all organizations operating in Russia to develop, implement, and undertake affirmative measures to prevent corruption. This goes further than the FCPA and the UK Bribery Act and perhaps signals a more expansive approach to anti-corruption enforcement in Russia than in the past.

The recent sanctions against Russia by the U.S. and other countries have added to the complexity of doing business in Russia, and U.S. and multinational companies operating in Russia are well advised to develop, implement, and maintain robust anti-corruption policies and procedures.

Listen as our authoritative panel discusses the risks of doing business in Russia and conduct that may trigger FCPA and anti-corruption violations, as well as violations under the amended Russian laws. The panel will examine the impact of Russia becoming a signatory to the OECD Anti-Bribery Convention and the interplay between the FCPA and Russian anti-corruption laws and enforcement. The panel will offer best practices for mitigating the risk of violations.



  1. Corruption in Russia
  2. FCPA and anti-corruption risks in Russia
    1. Russian anti-corruption laws
    2. Enforcement activity in Russia
    3. Reach of the FCPA and UK Bribery Act in Russia
  3. Best practices for identifying and mitigating risk
    1. Risk factors
    2. Mitigating risk


The panel will review these and other key issues:

  • What are the risk factors that make companies conducting business in Russia vulnerable to possible violations of the amended anti-corruption laws and the FCPA?
  • How are the U.S. and Russian governments acting to enforce their respective anti-corruption laws?
  • What are the best practices for companies to utilize in developing anti-corruption compliance programs and due diligence efforts?
  • What unique considerations under Russian law need to be taken into account when implementing compliance programs?


Ethan Heinz
Ethan Heinz

Of Counsel

Mr. Heinz works in the corporate group on M&A and private equity transactions. He has extensive experience in...  |  Read More

William D. Semins
William D. Semins

K&L Gates

Mr. Semins concentrates his practice on complex commercial litigation and compliance with the Foreign Corrupt...  |  Read More

Snezhanan Sharova
Snezhanan Sharova

Ms. Sharova's practice is focused on anti-monopoly regulation, merger control filings, competition and...  |  Read More

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