Ann Sultan and Maryna Kavaleuskaya* commented on Miller & Chevalier's inaugural Europe-Caucasus-Asia (ECA) Corruption Survey and the corruption risks and mitigation strategies identified in the survey. "The main goal of our survey was really to look at this region and gauge, in particular, the experiences of business people with corruption in each country in the region," Sultan said, "and also to look at the various compliance practices and mechanisms that companies operating in the region have put in place to safeguard themselves."

Kavaleuskaya addressed the differences in corruption levels among the ECA countries. "It is important to pay close attention to dynamic anti-corruption reforms in Ukraine, Uzbekistan, and Armenia to ensure that compliance programs adequately reflect the current situation rather than historical trends."

*Former Miller & Chevalier attorney