On April 11, 2014, Presidential Decree No. 226 ("Decree") approved the 2014-2015 National Anticorruption Plan ("Plan").

The Decree gives executive and legislative authorities until July 1, 2014 to ensure that amendments intended to achieve specific results in fighting corruption are introduced in local and industry anticorruption plans, as well as to establish supervision over the implementation of anticorruption measures.

Notably, the Plan uses more imperative language than previous presidential acts against corruption, such as "ensure", "take action", "submit proposals", "consider issues", and "continue work". The Plan also sets dates for reports on action to achieve the established objectives.

The Plan is generally focused on fighting corruption in the public sector; however, some attention is being given to the effectiveness and implementation of anticorruption measures in the private sector. For example, one of the objectives of the Plan is to implement the requirements of article 13.3 of Federal Law on Combatting Corruption of December 25, 2008 No. 273-FZ, which establishes a list of actions to be taken by every organization to prevent corruption. The objectives also include implementation of article 19.28 of the Administrative Penal Code No. 195-FZ of December 30, 2001. Given that both objectives are formulated in a single item of the Plan, a link is being sought between observing mandatory requirements and liability. It is probable that failure to implement anticorruption measures will be treated as an indirect form of the legal entity's fault when considering corruption cases.

The Plan provides for the Russian Federation Government to submit, among other things, the following proposals:

on expanding the range of legal entities for which information on the ultimate beneficiaries must be disclosed. This change is likely to affect organizations operating in fields subject to special regulations relating to laundering income derived by criminal means.

on regulatory provisions for federal executive authorities to perform the function of developing, introducing and advising on measures to prevent corruption in organizations, and control over implementation thereof. This proposal may mean the impending appointment of a state authority responsible for anticorruption regulation in the private sector, which would undoubtedly result in a significant increase in the corresponding level of supervision of organizations.

on improvements in coordination and rules on interaction with control and supervisory state authorities in the course of their activities, in particular, in the course of investigations. In this way, increased attention is given to preventing corruption in organizations when interacting with state authorities, including (in our view, primarily) during state audits and inspections.

The Russian Federation Government is also instructed to monitor compliance with the established procedure for certain categories of persons to report on the receipt of gifts. These categories obviously include state officials, Central Bank RF officials, and certain other employees of state institutions. Stricter controls over such persons receiving gifts are likely to result in more frequent refusals to accept gifts from any individuals or organizations.

The activities of the recently created Presidential Anti-corruption Department ("Department") are also touched on in the Plan: the Department is instructed to conduct checks into prevention of corruption efforts in a number of federal agencies, state corporations, and regional state authorities. The investigative powers of the Department do not yet include private-sector organizations, and the Plan does not call for a review. However, the Department remains the central authority and reinforces its position in supervising anticorruption measures in the public sector.

As a declarative document, the Plan does not make any material amendments to applicable corruption prevention rules. However, the Plan marks certain trends for the private sector that will affect organizations operating on the Russian market. More detailed anticorruption regulation for the private sector should be expected and will likely be adopted in the form of binding acts in the near future.