Anti-Corruption Practices


On 1 February 2012 the President signed Federal Law No. 3-FZ “On the Accession of the Russian Federation to the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions” (the “Law”).

The Convention was approved by the Organization for Economic Co-operation and Development (“OECD”) on 21 November 1997. The Convention is designed to promote international co-operation in combating bribery of public officials and encouraging international competition.

In particular, the Convention legally defines the offense of “bribery of a foreign public official” and clarifies the notion of “foreign public official”. The provisions of the Russian Criminal Code have recently been adjusted in accordance with these terms of the Convention (please see our update for 9 – 22 May 2011 regarding anti-corruption practices).

The Convention pays special attention to the liability of legal entities and demands effective, proportionate and dissuasive sanctions, including monetary sanctions, for bribery of foreign public officials. In the Russian Federation, legal entities are subject to an administrative fine which may exceed RUB 100 million for this offence. The Convention also regulates international co-operation in respect of mutual legal assistance and extradition of a person guilty of bribing a public official.

The Law entered into force on 13 February 2012, the Convention will enter into force for the Russian Federation on the sixtieth day following the date of the deposit of the Law with the Secretary-General of OECD.

For further information please contact Igor Ostapets or Grigory Chernyshov in the Moscow office of White & Case, tel + 7 495 787 3000 .