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Roman Butenko

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Roman Butenko is an associate in Baker Mckenzie's Moscow office. Mr. Botenko specializes in the area of compliance and dispute resolution.

Baker McKenzie’s newest report, Russia: Corporate Anti-Corruption Enforcement Trends, aims to provide both international companies operating in Russia and Russian businesses with an international footprint with practical and informative guidance on evaluating their corporate compliance programs. Focusing on the risks of prosecution under Russian law, this report will be particularly valuable…

Baker McKenzie’s newest report, Russia: Corporate Anti-Corruption Enforcement Trends, aims to provide both international companies operating in Russia and Russian businesses with an international footprint with practical and informative guidance on evaluating their corporate compliance programs. Focusing on the risks of prosecution under Russian law, this report will be particularly valuable…

Russia’s Supreme Court confirmed that a company can be liable under Article 19.28 of the Administrative Procedure Code (“Illegal remuneration on behalf of a legal entity”) for the actions of third parties with whom that company has no formal contractual, employment, or other legal relationship.1

The court clarified that a company may be held liable if its officers either knew about such actions, or approved or instructed the respective third parties with regard to such actions. Another requirement for prosecution is that the company must have an “economic or other material interest (for example, a reputational one)” in the performance of such actions.

In light of this clarification, companies now face increased risk under Article 19.28 for the illegal actions of persons such as employees of their dealers, distributors and other counterparties.

Baker McKenzie is pleased to present the following report on Russian corporate anti-corruption enforcement that will provide both international companies operating in Russia and Russian businesses with an international footprint with practical and informative guidance on evaluating their corporate compliance programs. Focusing on the risks of prosecution under Russian law,…