Russian Risks: Reconciling the Novo Nordisk Standard with the FCPA

The central challenge faced by any corporation seeking to address the risks of corruption is to understand where its risks lie and what tools it can employ to mitigate those risks.  Typically, those areas presenting the greatest risk of corruption will call for correspondingly strong anti-corruption tools.  This challenge may be even greater for companies doing business in Russia, where they must not only confront the challenges of the Russian business environment but also may be forced to do so without many of the anti-corruption tools normally at their disposal.  In a guest article, Joseph Terry, partner at Williams & Connolly LLP, and Jessica Hayden, former associate at Williams & Connolly, discuss the Russian business environment and the challenges posed by the so-called “Novo Nordisk Standard” – set after the Russian Federal Antimonopoly Service found that Novo Nordisk’s anti-corruption diligence program violated Russian competition law – and present topics for companies to consider when designing a compliance program that protects against corruption risks in Russia.  See also “Alan Kartashkin and Dmitri Nikiforov of Debevoise & Plimpton LLP Discuss the Ins and Outs of Russian Bribery Law” (Nov. 14, 2012).

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