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The Russian Ministry of Labour (“the Ministry”) issued three new sets of anti-corruption guidelines for companies:

  1. “Measures for Preventing Corruption at Organizations”1
  2. “Memorandum on Establishing the Duties of Employees for Preventing Corruption, Employee Liability, and Incentive Programs”2
  3. “Recommendations on the Procedure for Assessing Corruption Risks at Organizations”3

The new guidelines complement and extend previous recommendations of the Ministry concerning prevention of corporate corruption.

A company may avoid liability for public or private sector bribery under Article 19.28 of the Administrative Offences Code if it can prove that it has taken all possible measures to prevent this corrupt activity taking place. It is unlikely to be successful in this defense if it has not followed these latest guidelines (as well as the earlier recommendations of the Ministry).





Paul Melling is an English solicitor, founding partner of Baker McKenzie’s Moscow and Almaty offices, and founder of the CIS offices’ pharmaceuticals and healthcare practice. He leads the CIS offices’ Compliance Practice Group and is a steering committee member of the Europe Compliance and Pharmaceuticals & Healthcare groups. He joined the London office in 1980 as a member of the East-West Trade Department, focusing on the COMECON countries of Eastern Europe, particularly the former USSR. He moved to Moscow in January 1989 and has spent over 24 years as a partner in the CIS. In 2009, he received the AIPM’s Distinguished Service Award for his contribution to the development of the Russian pharmaceuticals market.


Edward Bekeschenko is a partner in Baker & McKenzie's Moscow office. He is ranked as a leading lawyer in dispute resolution by Chambers and Legal 500. Prior to joining the Firm in 2001, Mr. Bekeschenko headed the legal department of a major Russian metallurgical company and was vice president of a Belarusian law firm.


Anton Subbot heads the Antitrust & Competition Practice Group in Baker McKenzie's Moscow office. Prior to joining Baker McKenzie, he worked as a legal adviser in a Russian firm. Mr. Subbot has been ranked by Chambers Europe and recognized in Global Competition Review’s GCR 100 for his work on antitrust matters.


Maxim Kalinin serves as managing partner of Baker & McKenzie’s St. Petersburg office and head of the Mergers & Acquisitions, Corporate, Real Estate & Construction and Employment practice groups. He was named a European legal expert in Russia by European Legal Experts 2008, and was recognized by Chambers Europe "for his expertise in M&A and real estate work". He is also cited by Legal 500, Who’s Who Legal 2009, The International Who’s Who of Real Estate Lawyers 2008 and the Private Equity Handbook 2007/2008 for his corporate and real estate work