Corruption is not unique to any one country—but the ways in which it manifests, is addressed, or is institutionalized vary significantly across legal systems. Having spent over two decades in the Russian prosecutorial system, including 15 years in leadership roles, I witnessed both the efforts to combat corruption and the systemic barriers that allowed it to persist. Now, as I prepare to launch a U.S.-based legal consulting practice focused on cross-border risk and compliance, I believe there is significant value in examining the differences and commonalities between American and Russian anti-corruption strategies. By understanding these contrasts, U.S. businesses, institutions, and legal professionals can better prepare for operating in high-risk international environments.
The Russian Context: Enforcement as a Tool of Influence
In Russia, anti-corruption laws are extensive and well-developed on paper. Federal statutes prohibit abuse of office, bribery, embezzlement, and unlawful enrichment. However, enforcement often lacks consistency and transparency. In my experience, anti-corruption prosecutions can be used not just to uphold legality, but to exert political or economic leverage. While there are many prosecutors and investigators committed to their duties, the system is susceptible to selective enforcement, where legal tools are applied unevenly depending on political affiliation, economic interests, or administrative rivalry.
During my tenure as Deputy Prosecutor of Ufa, I oversaw a number of internal investigations into public officials and worked to enforce regulatory compliance in city infrastructure and procurement. In some cases, we were able to expose and eliminate abuses; in others, the underlying structures made sustained reform difficult. What became clear was that rules alone are not enough. Integrity in enforcement depends on leadership, institutional accountability, and public pressure.
The U.S. Approach: Transparency, Disclosure, and Deterrence
In contrast, the United States has developed a multifaceted system designed not only to punish corruption but to prevent it through transparency and deterrence. The Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley, and other frameworks create legal obligations for corporate disclosures, audit trails, and ethical compliance. These laws are backed by active regulatory bodies, including the SEC and DOJ, which maintain investigative independence and pursue cross-border cases in cooperation with foreign governments.
The American approach emphasizes corporate self-regulation, whistleblower protections, and legal liability for executives. Importantly, enforcement actions are highly publicized—not only to penalize wrongdoing but to shape norms across industries. This is something Russian institutions can learn from: corruption thrives in silence, but loses power in sunlight.
Bridging the Gap: Lessons for U.S. Entities Operating Abroad
For American businesses or NGOs entering post-Soviet markets, it is crucial to understand that local legal frameworks may appear familiar, but the operational realities are different. A clean audit or signed contract may not be sufficient protection if local officials decide to weaponize regulations. One of the most powerful strategies American organizations can adopt is internal resilience.
This includes:
Institutional Trust and Public Accountability
One of the most striking differences between the two systems is the role of civil society and public oversight. In the U.S., journalists, NGOs, and public records create layers of scrutiny that complement legal enforcement. In Russia, public oversight exists but is more limited, and legal decisions are rarely reversed through media exposure or civic pressure. This means that U.S. institutions cannot rely on the same support mechanisms when working abroad—making advance risk mitigation all the more important.
The Role of Consultants and Advisors
Legal advisors with firsthand experience in post-Soviet prosecutorial systems can play a crucial role in helping U.S. organizations avoid mistakes, anticipate vulnerabilities, and develop compliance architectures suited to foreign environments. My own consulting practice will offer this type of insight, helping clients map legal exposure, understand informal enforcement dynamics, and implement practical solutions.
Conclusion: Toward a Global Standard of Integrity
Corruption undermines economic development, weakens institutions, and distorts fair competition. But fighting it requires more than laws—it requires cultural, procedural, and leadership alignment. By learning from both the strengths and shortcomings of different systems, we can begin to build a more consistent global standard for integrity in law and business. For U.S. companies and agencies operating abroad, this means taking nothing for granted, planning with precision, and partnering with those who understand the terrain. That’s the bridge I hope to build.
