Winter Is Coming: Responding to a Chilling Enforcement Landscape in Russia

Eager to attract foreign investment and counteract the currency crisis, the Russian government continues to position the country as a more transparent place to do business than a generation ago. Although Russia’s anti-corruption laws have been on the books for years, and were recently revised to OECD standards, weak enforcement limited their effectiveness. At the same time, economic sanctions and rising tensions with Western nations bring renewed urgency to the Kremlin’s long-sought objective to reduce dependence on Western countries for high-value goods. Competing efforts to market Russia to a global audience while continuing to privilege domestic producers are likely to enhance the importance of Russia’s Federal Anti-Monopoly Service (FAS), the agency responsible for carrying out a lengthening list of enforcement mandates from Moscow. A spike in FAS action is likely to increase the risk to multinationals of unwarranted regulatory scrutiny, selective prosecution, and exclusion from public procurements.

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