Professional Documents
Culture Documents
ANSWERS BY RUSSIA
Reducing corruption remains a top priority for the G20. The G20 is committed to lead by exam-
ple and to hold itself accountable for its anti-corruption commitments, including by regularly
monitoring individual and collective progress in the implementation of the G20 anti-corruption
agenda and by preparing an annual report1. In the 2017/2018 G20 Anti-Corruption Action Plan,
G20 leaders pledged to continue to implement existing commitments and to strengthen the
work of the Anti-Corruption Working Group (ACWG). They asked the ACWG to report in 2017
on progress made against the Action Plan.
Responses by delegations to this questionnaire provided the input for the ACWG’s activities and
achievements to date, and assisted the Co-chairs in writing the Accountability Report as well as
in identifying individual and collective actions G20 countries have made in implementing the
2017/2018 Action Plan.
1Cf. St. Petersburg Strategic Framework for the G20 Anti-Corruption Working Group; for the Monitoring/
Progress/ Accountability Reports of 2011 - 2015 cf. http://www.bmjv.de/DE/Themen/G20/G20_node.html.
Summary of National Progress
1. Please provide a high-level summary (maximum 1 paragraph) of the most significant anti-
corruption measures or initiatives that your country has introduced or implemented since
the progress report of 2015 (annexed to the G20 Leaders’ Communiqué of the Antalya
Summit of 15-16 November 2015). The 2015 Accountability Report as well as previous
reports can be accessed at http://www.bmjv.de/DE/Themen/G20/G20_node.html. The
completed questionnaires from 2015 are not published, but can be requested from the
Co-chairs, if required.
In accordance with the National Anti-Corruption Plan approved by the
Presidential Decree № 147 of 1 April, 2016 Russia, in particular, improves legal
framework and organisational mechanisms of detecting and preventing conflict of
interest in relation to public officials; strengthens the impact of ethical and moral
standards on the adherence of bans, restrictions and requirements, established for the
purposes of corruption prevention, by public officials; enhances the effectiveness of
informational, propagandistic and educational measures, intended to establish the
atmosphere of zero-tolerance to corruption in the society, improves the effectiveness of
anti-corruption cooperation between public authorities and business community paying
special attention to the implementation of the Russian Anti-Corruption Charter for
Business, takes particular steps to enhance the effectiveness of corruption prevention in
procurement of goods, works and services for provisioning governmental and municipal
needs, extends the use of international cooperation mechanisms for detection, seizure
and return of corrupt assets from foreign jurisdictions etc.
3. Has your country begun or completed an UNCAC peer review process as a country un-
der review?
Yes No
4. For either or both cycles, has your country made use of any of the UNCAC peer review
voluntary options, or committed to do so?
a. Publication of full report
aa. First Cycle Yes No Committed to do so
bb. Second Cycle Yes No Committed to do so
c. Involvement of business
d. Country visits
aa. First Cycle Yes No Committed to do so
bb. Second Cycle Yes No Committed to do so
If yes, please provide details (e.g. web link for published report, how and when civil socie-
ty and/or business were engaged during the review process, date of country visit).
The country visits were organized on 10-11 August, 2012. Within the framework
of the peer review process the representatives of the major Russian business
associations met with the reviewers and presented their position.
The full report is published (in Russian) at the official website of the Prosecutor
General’s Office of the Russian Federation:
http://www.genproc.gov.ru/anticor/doks/document-82921.
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5. Since the last progress report, has your country taken steps to respond to recommenda-
tions identified in its UNCAC peer review report?
Yes No
b. If you have responded to all or some of the recommendations, have you made those
responses publicly available?
Yes No
7. Has your country begun or completed an OECD Anti-Bribery Convention peer review
process as a country under review?
Yes No
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a. Phase 1 Begun Completed
Stage completed: Date of Completion:
March 2012
8. Since the last progress report, has your country taken steps to respond to recommenda-
tions identified in previous OECD Anti-Bribery Convention evaluations?
Yes No
If yes, please provide details (including a link to the written follow-up report, if available).
Federal Law № 64-FZ of 9 March, 2016 «On Amendments to the Code of the
Russian Federation on Administrative Offenses» supplemented Articles 1.8 and 2.6 of
the Code of Administrative Offenses of the Russian Federation with provisions
according to which a foreign legal entity that committed an administrative offense
outside the Russian Federation as provided for in Article 19.28 of the Code «Unlawful
remuneration on behalf of a legal entity» and directed against the interests of the Russian
Federation shall be administratively liable on general grounds.
The amendments to the Code of Criminal Procedure of the Russian Federation
entered into force in December 2016. According to the amendments the Prosecutor in
criminal proceedings is entitled to bring a civil action in defense of the interests of the
subjects of the Russian Federation, municipalities, state and municipal unitary
enterprises.
The Federal Law № 324-FZ of 3 July, 2016 amended the Criminal Code of the
Russian Federation: Articles 184 (unlawful influence on the outcome of an official sports
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competition or an entertaining commercial contest), 204 (commercial bribery), 290
(receiving bribery), 291 (giving bribery) of the Criminal Code of the Russian Federation
have been amended to recognize the transfer of money, securities, other property, and/or
provision of monetized services, and/or granting of property rights not only to the
official directly, but to another person or entity indicated by him/her, as the crimes.
The same law introduces criminal liability for mediation in commercial bribery,
as well as for the promise or offer of mediation in a commercial bribery. The degree of
the criminal liability depends on the size of the bribe.
A separate regulation sets the criminal liability for small bribery and small
commercial bribery which do not exceed RUB 10,000. This novel will enable to sort out
the major crimes from the small offenses and to guide the law enforcement bodies on
identification of the major facts of giving and receiving a bribe, and not just to
combatting the so-called domestic corruption.
In order to fulfill partially implemented Recommendations 1(b), 3(c), 7(a) of the
OECD Anti-Bribery Working group Ministry of Economic Development of the Russian
Federation conducts in the frames of its competence measures of organization of
prevention and countering bribery of foreign officials for Russian business-community
and state institutions of financial export support (The Recommendations are given to the
Russian Federation in October, 2013 according to the results of assessment of fulfillment
of the OECD Anti-Bribery Convention 1997 by the Russian Federation).
Therefore, on regular basis Ministry of Economic Development of the Russian
Federation coordinates and provides effective work of the Working Group on issues of
joint participation of business-community and government bodies in countering
corruption, established in October, 2011 by the decision of the President Council on
countering corruption. The WG works among others on issues of involvement of
business-community in activities of prevention and countering bribery of foreign
officials.
In pursuance of the WG’s decisions the four leading business-associations
organize on the regular basis events for Russian business-community on clarifying
requirements of national and international anti-corruption legislation and highlightening
countering bribery of foreign official as well.
Ministry of Economic Development of the Russian Federation initiated
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distribution among business-associations of Good Practice Guidance on Internal
Controls, Ethics and Compliance which was adopted by the OECD Council as
an integral part of the Recommendation of the Council for Further Combatting Bribery
of Foreign Public Officials in International Business Transactions of 26 November,
2009. This effort was made for further enlightment of the OECD Good Practice
Guidance among companies-members of the business-associations and for practice of its
provisions in their anti-corruption activities.
Ministry of Economic Development of the Russian Federation initiated Trade
Representations of the Russian Federation in foreign countries to organize
informational events for representatives of Russian and foreign business communities
dedicated to explaining the issues of prevention of bribery of foreign public officials in
international business transactions. The events are made for representatives of Russian
companies and their foreign partners doing business abroad and for foreign companies
doing business in Russia. Besides these companies participation of representatives of
business unions, business associations, international organizations and scientific experts
in the sphere of combatting corruption and bribery is provided as well. Information on
most significant events is available on official websites of Trade Representations of the
Russian Federation in foreign countries.
Some companies conduct activities on countering bribery of foreign officials on
the regular basis and in accordance with their internal documents which contain
mechanisms of check-ups, monitoring and forehanded detection of bribery of foreign
officials. The documents were developed on the basis of the OECD Council
Recommendations «On bribery and Export Credits» on 14 December, 2006.
In order to provide its publicity and transparency Ministry of Economic
Development of the Russian Federation initiated downloading on these companies’
official websites information on anti-bribery activities in the sphere of export credits.
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The Council of Europe Criminal Law Convention on Corruption
10. Has your country been under review related to any kind of international or regional anti-
corruption review mechanism other than the UNCAC peer review process?
Yes No
If yes, please provide details, indicate what stage of review your country has completed
and provide links to review and any compliance reports, if available.
After joining GRECO the joint first and second evaluation rounds were held in
respect of Russia. During these evaluation rounds various aspects of activities of the
specialized agencies of the country involved in the prevention and suppression of
corruption (the independence of these bodies, their competence, the adequacy of
resources and other support, working efficiency), issues of reasonableness and scope of
provision to certain categories of officials of immunity from criminal prosecution, as
well as peculiarities of the national legislation and law enforcement practice in the
identification, seizure and confiscation of proceeds and other assets derived from corrup-
tion, prevention of corruption in public administration, liability of legal persons for
corruption offenses committed for their benefit were examined. Russia successfully
completed the evaluation rounds under consideration in 2012.
In October 2016, the 73rd plenary session of GRECO was held in Strasbourg,
which adopted a report on the implementation by the Russian Federation of the recom-
mendations of the third GRECO evaluation round. According to the report,
11 recommendations are recognized as fully implemented, 10 as partially implemented,
and there are no recommendations that have not been implemented. The work on the
implementation of the remaining GRECO recommendations continues.
In addition, in 2016 the fourth evaluation round of the Russian Federation was
launched on the topic «Corruption prevention in respect of Members of Parliament,
Judges and Prosecutors». The evaluation visit of GRECO’s Secretariat and experts was
held in Moscow in March 2017.
International Cooperation
11. Is your country’s approach consistent with the G20 High Level Principles on Mutual Legal
Assistance?
Yes No
Since the last progress report, has your country proposed or made significant changes to
its legislation relating to mutual legal assistance?
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Yes No
12. Has your country either used the UNCAC, or stated that it will allow the use of UNCAC,
as treaty basis for mutual legal assistance (MLA) and/or extradition?
13. Is your country’s approach consistent with the G20 Common Principles for Action: Denial
of Safe Haven?
Yes No
Since the last progress report, has your country proposed or made significant changes to
its legislation, regulations or powers to deny entry to foreign officials based on corrup-
tion?
Yes No
14. Please describe the measures your country has in place or intends to take to meet the
objectives of the G20 High-Level Principles on Cooperation on Persons Sought for Cor-
ruption and Asset Recovery.
On the instructions of the Presidium of the Council of the President of the
Russian Federation for Countering Corruption of 18 April, 2017 the General
Prosecutor’s Office of the Russian Federation together with the stakeholders is preparing
draft legal acts concerning internal procedures connected with identification, arresting
and returning from foreign jurisdictions assets obtained as a result of corruption
offenses.
15. Is your country’s approach consistent with the Nine Key Principles on Asset Recovery?
Yes No
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Since the completion of the Benchmarking Survey on the 2011 Nine Key Principles on
Asset Recovery , has your country proposed or made significant changes to its legisla-
tion, regulations or powers related to asset recovery?
Yes No
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establish their beneficial owners. Individuals and legal entities that are founders or
participants of a legal entity or otherwise supervising it are required to provide this legal
entity with the information they need to establish its beneficial owners.
Furthermore, a legal entity is required to provide all available documented
information about its beneficial owners or on measures taken to establish the above data
with respect to its beneficial owners upon the request of Rosfinmonitoring or tax
authorities.
Within the framework of Principle Five of Key Principles on Asset
Recovery:
Rosfinmonitoring signed 99 bilateral Agreements on cooperation in countering
the legalization (laundering) of proceeds of crime and financing of terrorism.
16. Is your country included in the G20 Step by Step Guide on International Cooperation in
Civil and Administrative Proceedings relating to Corruption?
Yes No
17. Since the last progress report, have there been any significant changes or proposed
changes to your country’s legislation related to international cooperation in civil and ad-
ministrative proceedings?
Yes No
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Beneficial Ownership Transparency
18. Has your country published and submitted a National Implementation Plan on the G20
High Level Principles on Beneficial Ownership?
Yes No
If no, please indicate any steps taken towards submission and publication.
19. Please give an update on the progress made against your National Implementation Plan
(if applicable) and/or on any other steps taken by your country since the last progress re-
port to meet the G20 High Level Principles on Beneficial Ownership Transparency and
the relevant FATF recommendations on beneficial ownership transparency.
As a part of the implementation of the National Action Plan aimed at resisting tax
evasion and hiding the beneficial owners of companies (2014) the following Federal
Laws were drafted and adopted:
The Federal Law № 424-FZ of 30 December, 2015 amending the Federal Law
№ 115-FZ stipulating that subjects of primary financial monitoring to conduct due
diligence of the customers who are foreign entities without the formation of a legal
entity, including trusts, funds, partnerships and other forms of collective investment and
(or) trust management.
In addition, this law stipulated that credit institutions must record and submit to
Rosfinmonitoring the information on all cases of refusal to conclude contracts and (or)
termination of contracts with customers on the initiative of the credit institution based on
the grounds related to the existence of suspicions that the purpose of concluding such
contract is to commit operations for the purpose of legalizing (laundering) proceeds of
crime or financing of terrorism, or if during one year period there were two or more
refusals to execute an operation on the basis of the presence of said suspicions or failure
to provide the necessary documents by the customer itself.
Information about such individuals submitted by Rosfinmonitoring to the Central
Bank of Russian Federation, which brings it to the attention of credit institutions,
professional participants of securities market, insurance companies (with the exception
of health insurance companies, operating exclusively in the field of compulsory health
insurance), insurance brokers, asset management companies of investment funds, mutual
funds and private pension funds, credit consumer cooperatives, including agricultural
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credit consumer cooperatives, microfinance institutions, mutual insurance companies,
private pension funds and pawnshops.
This information is taken into account when determining the degree (level) of
customer's risk profile.
The Federal Law № 215-FZ of 23 June, 2016 introducing the Article 6.1 of the
Federal Law № 115-FZ, was adopted. According to this article, all legal beneficial
owners and to take reasonable steps in the circumstances to establish their beneficial
owners. In addition, legal entities are required to update information on their beneficial
owners, record it and keep it for at least five years from the date of obtaining of such
information.
Legal entities have the right to request information from individuals and legal
entities that are founders or participants in this legal entity or otherwise controlling it to
establish their beneficial owners. Individuals and legal entities that are founders or
participants of a legal entity or otherwise supervising it are required to provide this legal
entity with the information they need to establish its beneficial owners.
Furthermore, a legal entity is required to provide all available documented
information about its beneficial owners or on measures taken to establish the above data
with respect to its beneficial owners upon the request of Rosfinmonitoring or tax
authorities.
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attention to implementation and promotion among business-community of provisions of
the Russian Anti-Corruption Charter for Business, article 13.3 of Federal Law № 273
«On Combatting Corruption» and Guidelines for development and adoption of measures
by organizations to prevent and combat corruption, adopted on 8 April, 2014 by the
President Council on countering corruption.
At the same time Ministry of Economic Development of the Russian Federation
promotes among business-community guidelines and recommendations on questions of
prevention of corruption in business-environment, issued by international organizations
which take part in international anti-corruption cooperation. For example, Ministry of
Economic Development of the Russian Federation initiated distribution among business-
associations of Good Practice Guidance on Internal Controls, Ethics and Compliance
was adopted by the OECD Council as an integral part of the Recommendation of the
Council for Further Combatting Bribery of Foreign Public Officials in International
Business Transactions of 26 November, 2009. This effort was made for further
enlightment of the OECD Good Practice Guidance among companies-members of the
associations and for usage of its provisions in anti-corruption activities.
It’s also necessary to mention that Trade Representations of the Russian Federa-
tion in foreign countries conduct on the regular basis and in accordance with their inner
plans approved in 2013 informational events for representatives of Russian and foreign
business communities dedicated to explaining the issues of prevention of bribery
of foreign public officials in international business transactions.
Today this work has been boosted in order to fulfill Recommendations of the
OECD Anti-Bribery Working group in the field of raising the awareness of business-
community about issues of prevention of bribery of foreign officials and stimulating
companies for further development and adoption of proper programs and measures of
internal control, ethics and compliance.
The events are made for representatives of Russian companies and their foreign
partners doing business abroad and for foreign companies doing business in Russia.
Besides these companies participation of representatives of business unions, business
associations, international organizations and scientific experts in the sphere of
combatting corruption and bribery is provided as well. Information about most signifi-
cant events is available on official websites of Trade Representations of the Russian
Federation in foreign countries.
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21. Since the last progress report, have there been any significant changes or proposed
changes to your country’s legislation or other measures related to private sector integrity?
Yes No
23. Since the last progress report, has your country taken significant steps to propose or to
make changes to your country’s legislation or other measures related to the criminaliza-
tion of active and/or passive bribery of domestic and/or foreign public officials and/or offi-
cials of public international organizations?
Yes No
24. Is your country’s approach consistent with the G20 Guiding Principles to Combat Solicita-
tion?
Yes No
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Since the last progress report, has your country taken significant steps to propose or to
make changes to your country’s legislation or other measures related to the combat of
solicitation?
Yes No
25. Please give an update on any significant steps taken since your country’s Self Assess-
ments on Implementation and Enforcement of G20 Commitments on Foreign Bribery to
meet the G20 Guiding Principles on Enforcement of the Foreign Bribery Offence.
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If no, is your country taking steps to establish the liability of legal persons for corruption
and corruption-related offences?
Yes No
Since the last progress report, has your country taken significant steps to propose or to
make changes to your country’s legislation or other measures related to open data?
Yes No
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open data (actual version 3.0 is approved in 2014).
By the results of this work more than 17,000 sets of open data were published by
state bodies, 13,700 of them (most actual and systemized) were published at the Portal of
open data of the Russian Federation. The same portals were created in 23 federal
subjects, 62 regions published data sets on their official websites. Many kinds of data in
different spheres are open now, among them education, housing and utilities, medical
care, public procurement and statistics.
An important part of this project is the Portal of open data of the Russian Federa-
tion created in 2013. It has united the following functions:
– joint register of all government and municipal data sets;
– source of actual and full information about open data;
– public platform for discussion of all open data issues;
– platform for development and publication of tools necessary for work with
open data.
The Portal accumulates applications for disclosure of information of state infor-
mation systems which can be useful for development of innovation services by business.
Educational seminars, forums, conferences of various levels as well as annual all-
Russian contest «The Open Data of the Russian Federation» are organized on the regular
basis, as well as regional hackathons for development of apps and services on the basis
of open data.
In the framework of Council of open data project development there was adopted
The Plan of efforts «The Open Data of the Russian Federation» for 2016-2017.
28. Is your country’s approach consistent with the G20 Principles for Promoting Integrity in
Public Procurement?
Yes No
Since the last progress report, have you taken other steps than those steps included in
the Compendium of Good Practices for Integrity in Public Procurement?
According to the Federal Law, which came into force on 9 January, 2017, the
legal entities that have been subjected to administrative liability under Article 19.28 of
the Code of the Russian Federation on Administrative Offenses (for unlawful
remuneration on behalf of a legal entity) within two years before the date of submission
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of procurement applications, cannot participate in state procurements.
This law also changed the requirements to natural persons participating in the
procurement. While the previous edition required that the participating natural person or
a head, board members, a chief accountant of the participating legal entity had no
criminal records for the economic crimes, the new edition also requires the absence of
the history of corruption crimes (giving, receiving, or mediation in bribery).
29. Is your country’s approach consistent with the G20 High Level Principles on Asset Dis-
closure by Public Officials?
Yes No
Since the last progress report, has your country taken significant steps to propose or to
make changes to your country’s legislation or other measures related to public disclosure
by public officials?
Yes No
If no, is your country taking steps to become a member of the Open Government Part-
nership?
Yes No
If yes, please provide details including information on the collective actions taken by your
country.
31. Has your country conducted a periodic assessment on fiscal transparency using an inter-
nationally adopted diagnostic framework1?
Cf. Implementation Plan: „G20 countries will promote fiscal transparency, leading by example in con-
1
32. Since the last progress report, have there been any significant changes or proposed
changes to your country’s legislation or other measures related to fiscal and budget
transparency?
Yes No
Sectors
33. Have there been any recent changes or proposed changes to your country’s legislation or
other measures related to combatting corruption:
a. in Sports? Yes No
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If yes, please provide details.
c. in Customs? Yes No
Others
Please specify.
Implementing Yes No
Supporting Yes No
Please provide notable details on each of the sectorial initiatives supported by your
country or domestic measures taken in relation to specific sectors.
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35. Please provide any relevant item that is not listed above but could be key information on
the domestic background of your country, impacting the fight against corruption.
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