Although the UK Bribery Act has received the majority of attention recently, it is not the only recent notable event in the global expansion of anti-bribery and corruption legislation. Others are also joining the effort, including Russia, which established the Federal Anti-Corruption Act, No. 273 “On Combatting Corruption,” in December 2012.
Russia has intensified its anti-corruption activities. In 2003, Russia joined the United Nations Convention against Corruption, and in 2012, it acceded to the Organisation for Economic Cooperation and Development’s (OECD) Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Anti-Bribery Convention). Russia completed the first phase of OECD country monitoring in March of 2012, shortly after joining the Anti-Bribery Convention, and will undergo an additional two rounds of monitoring.
Even more recently, in February of this year Russia amended its Anti-Corruption Act to require companies to have anti-bribery compliance programs. According to a report by law firm Baker & McKenzie, the new Amendment requires:
- Designating departments and structural units and officers who will be responsible for the prevention of bribery and related offenses;
- Cooperating with law enforcement authorities;
- Developing and implementing standards and procedures designed to ensure ethical business conduct;
- Adopting a code of ethics and professional conduct for all employees;
- Means for identifying, preventing and resolving conflicts of interest; and
- Preventing the creating and use of false and altered documents.
Not only must organizations have an anti-bribery compliance program, but these new requirements also define the specific tasks that must be taken by organizations in order to protect themselves against bribery and corruption within the country. Thomas Firestone, of Baker & McKenzie, writes on the FCPABlog that the new law, “now appears to have gone beyond the FCPA and the UK Bribery Act.”
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