Former Soviet republics take different approaches to anti-corruption legislation
Thursday, July 25, 2019 at 8:18AM
Hannes Lubitzsch and Anna Fufurina in Azerbaijan, Kazakhstan, Kyrgyzstan, Russia, Turkmenistan, Uzbekistan

Enforcement actions by U.S. and European enforcement agencies as well as the World Bank have drawn attention to bribery offenses committed by multinational companies in Russia and other former Soviet republics, in particular in Central Asia.

Together with local law firms, we have therefore taken a closer look at the anti-bribery and corruption legislation of Russia, Azerbaijan, Kazakhstan, Kyrgyzstan, Turkmenistan, and Uzbekistan. Our review of these countries’ legislation revealed significant differences: 

The findings show that an assessment of the local liability risks for companies operating in these countries -- which should also take into account the unpredictability of enforcement actions by local law enforcement agencies -- must be conducted for each jurisdiction individually. Further details can be found in this overview (pdf). 


Hannes Lubitzsch, pictured above left, is a partner in the Moscow office of Noerr and heading the Russian compliance & investigations practice. He can be contacted here

Anna Fufurina, above right, is a senior associate in Noerr’s Moscow office.  

Article originally appeared on The FCPA Blog (
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