Michael Volkov (JD Supra Russia)

In another blockbuster FCPA prosecution, the Justice Department and the SEC announced an $850 million settlement with Mobile Telesystems (“MTS”), Russia’s largest mobile carrier.

The Treasury Department’s Office of Foreign Asset Control (OFAC) rarely backs down. Recently, in response to significant ownership and governance changes, OFAC removed three Russian companies, EN+ Group (EN+), UC Rusal plc (Rusal), and JSC EuroSibEnergo (ESE) from the sectoral sanctions list.

Okay, I have to admit – it is getting hard to keep up with all the changes to the Russia Sanctions Program. The Treasury Department, Office of Foreign Asset Control’s imposition of the Oligarch Sanctions and Congress’ passage of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”) has made life difficult.

The Trump Administration Treasury Department’s Office of Foreign Asset Control activity has been interesting to watch. On the one hand, OFAC has been implementing aggressive sanctions against Russia in reaction to Russia’s global misconduct.

On April 6, 2018, OFAC announced a new round of sanctions against Russian individuals and companies. Relying on its authority under existing executive orders, OFAC designated seven Russian oligarchs and 12 companies they own or control, 17 senior Russian government officials and a state-owned weapons trading company, and its subsidiary, a Russian bank.

The Russian government has targeted the pharmaceutical industry for growth and development, adopting a program Pharma 2020 Strategy. This program aims to improve the competitiveness of the Russian pharmaceutical industry and localize production resources of international pharmaceutical companies.

The Russian government adopted significant reforms to the country’s pharmaceutical industry starting in 2008. According to a 2012 survey of the Russian pharmaceutical industry conducted by Ernst & Young, both foreign and domestic manufacturers projected significant growth in Russia’s pharmaceutical markets.

Cisco’s 2009 audits concerning its operations in Russia revealed that its interactions with the state-owned company, Svyazinvest and local resellers, could not be “verified.” An interesting phraseology to say the least, Cisco’s counsel should be applauded for creativity.

International enforcement of corruption laws is increasing but far slower than many predicted.

With the political forces aligned to fight corruption, Russia may be finally making a serious and sincere effort to address corruption in Russian society.

My heritage is Russian; I know how Russians think and what makes them tick. Like its literary history, Russians are complex.

For many businesses, now is the time to expand into Russia. In 2011, the Russian economy grew by 4.3%. The IMF projects the $1.8 billion economy will continue to grow by 3.3% in 2012 and 3.5% in 2013, over twice the pace of growth compared with so called, “advanced economies.” The Kremlin is doing its part to lure foreign business by offering investment in state-owned industries like oil/gas,...

If You Can’t Stand the Heat, Get Out of the Kyxh? (Russian for kitchen”) When discussing business opportunities in Russia, the prevailing message seems to be, if you can’t stand the heat, get out of the kitchen. This take it or leave it attitude was certainly true in the past but recent events suggest that maybe, just maybe, the tables are turning. Armed with an awareness of the risk (heat),