Home / Doing business in Russia 2020 / Anti-corruption and compliance / Liability and penalties for corruption
  1. Introduction
    1. Political and administrative structure
    2. Legal environment
  2. Common forms of business structures for foreign investors
    1. Main types of structure
    2. Registration, liquidation and reorganisation of business structures
    3. Shareholders’ and participants’ agreements
    4. Strategic industries
  3. Anti-monopoly issues
    1. General legal and regulatory framework
    2. Scope of application of the Competition Law
    3. Anti-competitive practices and restriction of competition
    4. Liability
  4. Tax system
    1. General approach
    2. Corporate taxation
    3. Incentives
    4. Special tax regimes
    5. Taxation of individuals
    6. Double taxation treaties
  5. Customs regulations
    1. General approach
    2. Trade between EEU and non-EEU countries
    3. Mutual trade between the EEU members
  6. Currency control
    1. Foreign currency transactions
    2. Consequences of breach/Penalties
  7. Lending in Russia
    1. Lending documents and governing law
    2. Jurisdiction
    3. International finance transactions and repatriation requirements
    4. Security interests
    5. Recognition of security trusts
    6. Syndicated loans
    7. Enforcement
    8. Suretyships and guarantees
    9. Bankruptcy considerations
    10. Other lending related issues
  8. Employment and migration
    1. Formalising the employment relationship
    2. Managing employment relationships
    3. Terminating an employment agreement
    4. Specifics of employing foreign nationals
  9. Personal data protection
    1. General approach
    2. Scope of the Data Protection Law
    3. Liability
    4. Right to be forgotten
  10. Intellectual property
    1. General approach
    2. Contractual aspects of intellectual property rights
    3. Rights over the results of intellectual activity
    4. Company names, trade names, trademarks and appellations of origin
    5. Intellectual property rights infringements
    6. IP Court
  11. Advertising issues
    1. General approach
    2. Scope of application of the Advertising Law
    3. Violations of the Advertising Law
    4. Liability
  12. Anti-corruption and compliance
    1. General approach
    2. Legal framework
    3. Compliance requirements for companies
    4. Concept of corruption in Russian law
    5. Possible targets of bribery
    6. Liability and penalties for corruption
    7. Example of sector-specific anti-corruption measures
  13. Real estate and construction
    1. Rights to real estate
    2. Real estate transactions
    3. Resolution of real estate disputes
    4. Planning and construction issues
  14. Corporate bankruptcy
    1. Insolvency criteria
    2. Stages of bankruptcy proceedings
  15. Import substitution and production localisation in Russia
    1. Measures affecting goods importation and current import substitution legislation
    2. Localisation incentives
    3. Sector-specific impact of import restrictions and localisation requirements
  16. Banking sector
    1. Legislative and regulatory framework
    2. Licensing and operations
    3. Deposit insurance
    4. The anti-money laundering law
    5. Bank secrecy
    6. FATCA and CRS
  17. Environment, energy efficiency and renewables
    1. Environment
    2. Energy efficiency
    3. Renewables
  18. Infrastructure and public private partnerships
    1. General approach
    2. Key PPP legislation
    3. Russian PPP environment
    4. Financing
    5. Legal issues
    6. Prospects for infrastructure projects
  19. Oil & gas
    1. Legislative framework
    2. Ownership and licensing
    3. Restrictions on foreign investors
    4. Licences
    5. PSAs

Liability and penalties for corruption

Public officials

Apart from bribery, the Criminal Code holds public officials liable for crimes committed against the state and/or municipal authorities, such as:

  • abuse of powers;
  • exceeding rank and authority;
  • illegal entrepreneurial activities; and
  • forgery by an official.

If a public official is prosecuted for several crimes, the court will first consider each of them independently and then as a whole to determine the gravity of the offence and resulting sentence.

Under the Criminal Code, only individuals may be held liable for crimes specified in the Code (including bribery/commercial bribery); however, legal entities may be punished for corrupt activities under the Code on Administrative Offences. The liability of a legal entity does not exempt a culpable individual from liability, and vice versa.

Interestingly, a bill extending the criminal liability of legal entities has been under consideration by the State Duma since 2015, although it is not yet known when the respective law will be enacted.


Individuals are subject to:

  • liability to reimburse losses in full (under the Russian Civil Code);
  • disciplinary actions resulting in the termination of employment (under the Russian Labour Code);
  • up to ten years’ imprisonment for abuse of authority;
  • up to eight years’ imprisonment for commercial bribery (for the bribe giver);
  • up to 12 years’ imprisonment for abuse of authority in conjunction with commercial bribery;
  • up to 15 years’ imprisonment for a public official who receives a bribe;
  • up to 15 years’ imprisonment for bribe giving; 
  • disqualification of a bribed public official from holding public office for up to 15 years;
  • up to seven years’ imprisonment for facilitating bribery in commercial and other organisations; and/or
  • up to 12 years’ imprisonment for facilitating bribery of public officials.

In addition to or instead of the abovementioned sanctions, those giving or receiving bribes (including commercial bribes) may be fined ten to 100 times the amount of the bribe offered/received. 

Legal entities 

Legal entities may be prosecuted for:

  • the illegal employment of a current or former public official, carrying a fine of up to RUB 500,000 (EUR 7,150); and
  • the illegal payment of a bribe on their behalf or that of any related legal entity, carrying a fine ranging from RUB 1m (EUR 14,300) to 100 times the amount of the bribe plus seizure of the amount paid. Also, the entity’s assets (including bank accounts and immovable property) up to a value equal to the potential fine may be frozen while the matter is being investigated. In that sense, the legal entity may be prohibited from selling or otherwise disposing of the property.

Key contacts

Yuryev Sergey
Sergey Yuryev
Head of Dispute Resolution