Anti-corruption Compliance

Anti-corruption Compliance


  • Each company must combat corruption (article 13.3 of the Federal Law “On combating corruption”).

  • If a corruption offence is identified in the form of illegal remuneration on behalf of a legal entity, the company could face a fine in an amount from RUB 1 million to RUB 100 million and even higher (article 19.28 of the Russian Code of Administrative Offences).

  • According to the Register of the General Prosecutor's Office, more than 1,500 legal entities have been held liable for corruption in Russia since 2015.

  • For international corporations, there is a high risk of liability being imposed under the American FCPA and the UK Bribery Act, which have extraterritorial effect.

  • The total amount of penalties for companies under FCPA from 2010 to 2021 amounted to more than USD 20 billion.

  • The top 10 largest fines in the history of FCPA include two Russian companies, which paida total of USD 1.65 billion in penalties.

  • According to surveys, every second major company in the corporate sector faces facts of corporate fraud with damage from USD 1 million.



  • Developing a full set of necessary documents and activities to introduce an anti-corruption policy in a client’s company.

  • Conducting an audit and devising recommendations on how to improve the current anti-corruption policy, how to bring it into line with the the best global standards, and how to comply with the requirements of the Federal Law “On combating corruption”, FCPA and the UK BA; assessing and mitigating corruption risks in such company’s current business model.

  • Structuring work with contracting parties from the standpoints of the requirements of anti-corruption legislation. Developing anti-corruption clauses.

  • Conducting internal investigations and internal control measures and an audit aimed at preventing corporate fraud and bad-faith conduct in the company.

  • Automating compliance procedures by applying our own legal tech developments which are based on unique algorithms and IT solutions.

  • Stress-testing and checking the efficiency of anti-corruption measures that are being taken. Providing certification of the company as meeting anti-corruption rules and standards.

  • Organising training sessions and seminars for employees.


Legal support regarding compliance with the economic substance regulation in the UAE
Our Middle East Desk advised a global fast-food chain on complying with the economic substance regulation in the UAE.
Built up and implemented an anti-corruption compliance system
Pepeliaev Group’s lawyers handled a project aimed at building up and implementing a modern anti-corruption compliance system within the client’s company.
Other projects