On January 1, 2013, Russia implemented an amendment to its anti-corruption laws that appears to go beyond the reach of both the U.S. Foreign Corrupt Practices Act (“FCPA”) and the U.K. Bribery Act (“UKBA”) to the extent it requires all corporations organized in Russia to develop anti-corruption compliance measures.
Background: The Law and the Amendment -
The new law, or Article 13.3, “The Obligation of Organizations to Undertake Anti-Corruption Measures” (“Article 13.3”), amends Russian Federal Law 273, “On Countering Corruption” (“FL 273”), which Russia enacted on January 10, 2009 in response to Russia’s ratification of the United Nations “Convention Against Corruption” and the Council of Europe’s “Criminal Law Convention on Corruption.” Until the passage of Article 13.3, FL 273 did not impose any affirmative obligation on companies doing business in Russia to implement anti-corruption compliance measures. Now it does.
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