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Editors

Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Bill Steinman
Contributing Editor

Due Diligence in Russia: A public register of bribe payers

Due diligence in Russia has never been simple. Two recent developments make it more complicated. One makes business more transparent. Sort of. The other makes it less transparent. Foreign companies working in Russia will place themselves at peril if they don’t pay close attention to both.… Continue Reading

MTS reserves $840 million for FCPA settlement

Alexey Kornya, MTS president and CEORussia’s biggest mobile phone company said it reserved $840 million to resolve a possible FCPA enforcement action by the DOJ and SEC.

Moscow-based MTS said it is cooperating with an investigation by U.S.… Continue Reading

Pa consultant loses appeal against five-year FCPA sentence

Dmitrij Harder (Image courtesy of Twitter @dmitrijharder)The Pennsylvania-based consultant who bribed an officer at the European Bank for Reconstruction and Development for loan approvals lost his appeal against a 60-month prison sentence for violating the Foreign Corrupt Practices Act.… Continue Reading

In Russia, new rules exempt companies from bribery liability

On August 14, 2018, new amendments to the Russian Code on Administrative Offenses (Administrative Code) related to bribery by legal entities went into effect. The new provisions establish conditions exempting companies from liability for bribery if those companies assist authorities in uncovering and investigating misconduct.… Continue Reading

Bill Browder: Magnitsky Act rattles Putin

Magnitsky Act architect Bill BrowderDuring the Helsinki summit Monday, Russian President Vladimir Putin offered American investigators a chance to interview 12 indicted Russian intelligence agents in exchange for Russian access to Bill Browder.Continue Reading

Compliance pros are rock stars, yes they are

Only yesterday they were pimply FCPA nerds. But a strange thing happened. They morphed into the cool kids.

Today’s compliance officers are famous and wanted.

Here’s some evidence.

The White House commuted ZTE’s corporate death sentence by arranging to embed hand-picked compliance officers in the outlaw Chinese company.… Continue Reading

Due diligence on the oligarchs: Predicting OFAC’s next move

Oleg DeripaskaWith the proliferation of OFAC designations of Russian businesspeople, trying to predict whether or not someone will be designated as a Specially Designated National (SDN) has become an important part of third party due diligence on Russian business partners. 

SDNs are completely cut off from the U.S.… Continue Reading

Spanish police release Bill Browder after red notice detention

From Bill Browder’s twitter account.A British critic of Russian president Vladimir Putin was detained by Spanish police Wednesday on an international arrest warrant that Russia requested through Interpol.

Financier Bill Browder tweeted that police in Madrid released him after Interpol’s general secretary in Lyon, France, instructed Spanish police not to honor Russia’s arrest request. 

He was held for about an hour.… Continue Reading

Firestone and Butenko: A Russian ‘Pilot Program’?

Russian President Putin recently submitted a new anti-corruption bill to the Russian parliament.

The proposal has two significant aspects. 

First, it would amend Article 19.28 of the Russian Code of Administrative Violations (which was previously amended in 2011 to impose liability on corporations for bribery, including domestic and foreign, public and private) to provide that companies can avoid liability in domestic bribery cases if

(i) they assist in the discovery or investigation of the bribe or

(ii) the bribe has been extorted. 

Second, the proposal would allow courts to freeze the property of corporations under investigation for bribery up to the maximum amount of possible fine. 

Given Russian practice, we can expect the amendments to pass relatively quickly and with few changes.… Continue Reading

Alec Puig: There are good things happening at some Russian companies

A Transparency International-Russia report published in January assessed the efficacy of the anti-corruption programs of over 200 Russian companies, who together generate more than 70 percent of Russia’s national income. 

While the report mainly calls for the majority of the companies named to implement remedial measures, it is worth noting and commending the highest-scoring companies, who provide exemplary models for their counterparts in the anti-corruption space.… Continue Reading