Antimonopoly compliance in Russia: status and suggested reforms

The development and implementation of antimonopoly compliance – an internal corporate system to prevent violations of antimonopoly legislation – is one of the tools available to companies to prevent and mitigate antimonopoly risks.

For the time being, the use of antimonopoly compliance has not been enshrined in Russian legislation, although discourse on the need to do so has been heard over the last few years and is being actively supported by the antimonopoly authority – the Federal Antimonopoly Service of Russia (“FAS”). The goal of the initiatives for legislative regulation of antimonopoly compliance, namely the identification and prevention by companies of violations of antimonopoly legislation, is clear and is not cause for debate. However, there are significant differences in the various proposed incentives for companies to establish such a compliance system. During the discussions both the introduction of a full exemption from liability for a committed violation (especially the exemption of company officials from criminal liability) and various options to limit liability (for example, limiting it to its minimum amount) have been proposed...

Please download the full articel about Antimonopoly compliance in Russia.