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Russian authorities launched 487 bribery investigations last year that led to 439 convictions, but virtually all of those cases targeted small and midsize businesses or individuals, according to a new report from European law firm Noerr.

The Munich-based firm analyzed the latest corruption enforcement statistics from the General Prosecutor's Office of the Russian Federation and found that authorities continue to turn a blind eye to large-scale corporate corruption.

“These cases are not prosecuted. Large companies are not touched. They can feel safe that they're not subject to risk of prosecution by Russian authorities,” Hannes Lubitzsch, who heads Noerr's compliance practice in Moscow, said in an interview Friday.

Michael Dobson, a former senior sanctions policy adviser for the U.S. Treasury Department's Office of Foreign Assets Control and now of counsel at Morrison & Foerster in Washington, D.C., noted that “a lot of these larger players are directly or indirectly controlled by oligarchs.”

“To the extent that they are in the Kremlin's good graces, I am not at all surprised that they wouldn't find themselves in the targeting scope,” he said.

In Russia last year, the average penalty in a bribery case was 1 million rubles, or about $15,400, according to Lubitzsch. The nearly 440 corruption convictions in 2018 resulted in administrative fines totaling about $10.6 million. That pales in comparison to the $850 million fine that Russia's largest mobile network operator, Mobile TeleSystems, agreed to pay in March to settle a corruption case with U.S. authorities.

While Russian authorities appear to be interested primarily in pursuing minnows in the corruption pond, authorities in the U.S. and U.K. are increasingly going after the lunkers, according to Lubitzsch.

“What you should take into account in Russia is the foreign enforcement,” he added.

Noerr's report also showed that Russian prosecutors are ramping up on-site inspections to determine whether organizations, including Russian subsidiaries of foreign companies, have adopted anti-corruption compliance measures required under a 2012 law. But the law is silent on sanctions for noncompliance.

“Compliance in Russia is a fairly new concept,” Lubitzsch said. “And, for a typical Russian company, it's pure paper-based compliance.”

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