Oil, wheat, fertilizer, neon, iron and other essential items are in limited supply, either directly because of sanctions or because the conflict has disrupted production in Russia and Ukraine. Corruption may occur in the form of bribes, whether it be to customs agents or other parties to move along production.
Kara Brockmeyer, a partner at Debevoise & Plimpton, told the Journal while she hasn’t counseled any clients involved in corruption from the Russia-Ukraine conflict, she has worked with clients who may have “run afoul” of anti-corruption laws because of pandemic shortages.
“It increases the pressure to make sure that you’re finding goods, that you are finding alternative suppliers,” Ms. Brockmeyer said. “Those are really some of the pain points where we encourage our clients and their compliance officers to be paying attention.”
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