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Whistleblowing and self-reporting


Are whistleblowers protected in your jurisdiction?

Russian law contains only one provision on the protection of whistleblowers. Article 9(4) of the Anti-corruption Law states that civil servants or state officials who report on corruption violations will enjoy state protection. However, this protection is afforded only in accordance with the general Russian legal provisions granting protection to participants in criminal cases (in particular, the Criminal Procedure Code and Federal Law 119-FZ on State Protection of Victims, Witnesses and Other Participants in Criminal Proceedings (August 20 2004).

In 2015 a draft law containing specific protection measures for whistleblowers who report corruption violations by civil servants or state officials to the police or the media was prepared by the Federal Labour Ministry. This draft law proposes, among other things, monetary penalties against employers which have punished whistleblowers through dismissal. However, it has yet to be introduced to the State Duma.


Is it common for leniency to be shown to organisations that self-report and/or cooperate with authorities? If so, what process must be followed?

Under Article 4.2(3) of the Administrative Offences Code, the voluntary disclosure of an offence to the competent law enforcement authority qualifies as an extenuating circumstance. This means that the amount of the fine imposed for violation of Article 19.28 of the Administrative Offences Code (unlawful remuneration on behalf of a legal entity) will be reduced. However, the court has sole discretion as to the scope of reduction of the fine.

Following the adoption of proposed legislative changes, if criminal liability is extended to legal entities then organisations that self-report may benefit from the leniency provisions of Articles 204 (bribery in a commercial organisation), 204.1 (mediation in bribery in a commercial organisation), 291 (bribe taking by a civil servant) or 291.1 (mediation in bribery of a civil servant) of the Criminal Code. Under these provisions, the bribe giver is released from criminal liability if he or she:

  • actively enabled the discovery or investigation of the crime;
  • was subject to blackmailing by the bribe taker; or
  • following commission of the crime, voluntarily informed the competent law enforcement authority of the bribe taking.

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