Jenner & Block

Client Alert: New Russian Anti-Corruption Guidance in Conflict with U.S. FCPA Requirements

In this article, Partners Reid Schar, Iris Bennett and Robert Stauffer, and Associate Michael Khoo raise the possibility that the new Russian Supreme court guidance, which draws a much narrower definition of a bribe than other anticorruption regimes, including under the U.S. Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act, could create a gap between payments that may be tolerated in Russia and what is permissible under U.S. or U.K. law.