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Getting The Deal Through

The Eurasian Economic Union

Yury Panasik, Natalia Malyarchuk and Lilia Bayguzhina


Thursday 14 February 2019

Form of government

1    Constitution

What is the basic source of law? Describe the scope of, and limitations on, government power relevant to the regulation of lobbying and government relations.

The main source of Eurasian Economic Union (EAEU) law is the Treaty on the Eurasian Economic Union (the Treaty). Russia, Belarus and Kazakhstan signed the Treaty on 29 May 2014, and it came into force on 1 January 2015. Armenia and Kyrgyzstan acceded to the Treaty on 2 January 2015 and 12 August 2015 respectively. Thus, currently, the EAEU consists of five countries: Armenia, Belarus, Kazakhstan, Kyrgyzstan and Russia.

The Treaty codified provisions of the pre-existing agreements regulating the functioning of the Customs Union and common economic space. These agreements constituted the basis of the Treaty, which aims to ensure their implementation and bring their provisions in line with the rules and norms of the World Trade Organization.

Implementation of the Treaty and the provisions included therein is scheduled for a 10-year period. It should lead to transformation of the EAEU by 2025 into a full-rate economic alliance (this implies free circulation of goods, services, capital and labour force, and formation of a common market in the energy, finance and transport sectors, etc). Further deepening and expansion of integration will depend on whether the EAEU member states achieve all the targets set by the Treaty by 2025.

The Treaty defines the major objectives of the EAEU, its competence, its institutional structure and the procedure of formation and operation of the EAEU bodies. In addition, the Treaty regulates the mechanisms of economic integration of the EAEU member states and the obligation to carry out a unified, conciliatory or coordinated policy in certain economic sectors.

Unlike the European Union, the EAEU does not regulate the fundamental rights and freedoms relevant for lobbying (freedom of speech, assembly, etc). However, the Treaty defines the basic principles of the EAEU that influence the decision-making process, such as respect for fundamental principles of international law, sovereign equality and specifics of the political systems of the member states, and ensures equality and consideration of national interests. In accordance with these principles, the EAEU bodies (the Supreme Eurasian Economic Council, the Eurasian Intergovernmental Council and the Council of the Eurasian Economic Commission) make their decisions on the basis of a consensus to prevent dominance of any EAEU member state (see question 2). However, there are occasional conflicts among the EAEU bodies as a result of divergence of interests of the member states in various spheres.

In addition, an important principle of the EAEU is the transparency of its activities. Information on the activities of the EAEU bodies is available on the official website: International treaties within the EAEU and with third parties must be published on the website. In addition, draft decisions are subject to preliminary publication (at least 30 days prior to the planned adoption date). Adopted decisions enter into force following their official publication.

2    Legislative system

Describe the legislative system as it relates to lobbying.

Currently, the EAEU involves economic integration only.

The project of Eurasian integration was originally based on the idea of creating a single economic space. The question of political integration within the EAEU, including creation of a Eurasian parliament, was discussed during preparation for the launch of the Eurasian integration project. During this period, the Russian political establishment sought to maximise the number of Union participants (the inclusion of Ukraine in the integration process was one of the priorities). Political integration was considered to be a way of strengthening Eurasian integration.

However, at the final stage of negotiations on the Treaty, the parties did not consider the opportunity to expand integration to the political sphere or create supranational political bodies for the following reasons. First, Russia’s interest in political integration declined after Ukraine signed the association agreement with the European Union. Secondly, Kazakhstan and Belarus were against political integration and the creation of a Eurasian parliament. Thus, the final version of the Treaty does not include any provisions that provide for the expansion of integration to the political sphere or the creation of a supranational political body (a parliament or an inter-parliamentary assembly).

Regarding the decision-making process within the EAEU, decisions can be adopted by the following bodies: the Supreme Eurasian Economic Council, the Eurasian Intergovernmental Council and the Eurasian Economic Commission (EEC). The composition and powers of these bodies are outlined below.

At the same time, the process of forming EAEU supranational bodies is ongoing. The Treaty provides for the establishment of a single market regulator by 2025. In addition, the EAEU member states may establish other supranational institutions, such as commissions on the economy, environment and raw materials. The establishment of these bodies was discussed during negotiations on the Treaty, but was not enshrined in the Treaty.

It is also noteworthy that there is a trend towards further expansion of the powers of the EAEU bodies. First, the sphere of competence of the EAEU authorities will be broadened with the formation of common markets: for example, financial, pharmaceutical, oil and gas common markets.

Second, the powers of the supranational bodies in the antimonopoly sphere can also be expanded. For example, the EEC advocates the need to develop a public initiative mechanism that will allow the EEC to take proactive measures to identify and prevent violations of competition rules. Within this mechanism, the EEC may be entitled to identify on its own initiative (without a filed complaint of a market participant or EAEU member state) priority markets for competition investigation and issue warning letters following investigations so that entities in breach of the competition rules could take measures to remedy the violations.

Apart from the expansion of powers, the EAEU sees a trend towards active development of trade relations with third countries. In fact, the EAEU has an exclusive right to conclude agreements on the establishment of free trade areas (FTAs). This means that the EAEU member states cannot sign these agreements themselves.

The EAEU has already established an FTA with Vietnam (operational since October 2016). In 2018, it also signed a temporary FTA agreement with Iran that is to come into effect in 2019. The temporary FTA agreement provides for reduction or cancellation of customs duties for a limited list of goods. However, a comprehensive FTA with Iran is planned to launch by 2022.

In addition, the EAEU conducts FTA negotiations with Egypt, India, Israel, Serbia and Singapore.

The Supreme Eurasian Economic Council

The Supreme Council consists of the heads of the EAEU member states. The position of the chairman of the Supreme Council is occupied, in turn, by the heads of the member states, who replace each other once a year. The Supreme Council holds its meetings at least once a year, during which it addresses fundamental strategic issues, and determines the areas and prospects of integration. It also considers the issues relating to changes to or cancellation of the decisions of the Intergovernmental Council or the EEC if those bodies are unable to reach a consensus.

The Intergovernmental Council

The lower level in the EAEU authorities’ hierarchy is occupied by the Intergovernmental Council, comprised of the heads of the governments of the EAEU member states. The chairman of the Intergovernmental Council is determined on a rotational basis once a year.

Meetings of the Intergovernmental Council must be held at least twice a year, however, in practice, they can be postponed if conflicts arise between the EAEU member states.

The Council has the power to prepare the issues for approval by the Supreme Council and has control over the EEC’s activities. With regard to monitoring the EEC’s activities, the Council gives instructions to the EEC and may cancel, change or suspend its decisions.


The EEC is a permanent body regulating the issues within the EAEU’s competence. The EEC has a two-tier structure consisting of the EEC Council and the EEC Board.

The EEC Council is composed of Deputy Prime Ministers of the EAEU member states. The member states decide who will represent their interests in the EEC. The Council holds its meetings at least once a month. It approves key decisions that fall within the EEC’s competence (eg, establishment of customs duties, adoption of technical regulations) and controls the activities of the EEC Board.

The EEC Board is a permanent executive body (similar to the European Commission in the EU) that makes most of the decisions in the EAEU. The Board consists of 10 members, two from each EAEU member state. Members of the Board are appointed by the Supreme Council for four years (though their term can be extended). The Chair of the Board is appointed for four years on a rotational basis between the EAEU member states without the right to extend his or her term. Each member of the EEC Board is responsible for a specific economic sphere (eg, trade issues, technical regulation, customs regulation). The position of Board member is quite influential because of the significant and increasing powers of the EEC.

The meetings of the Board are usually held once a week.

The Board may adopt legally binding decisions, orders (which are of an administrative nature and, as a rule, are aimed at organising interaction and exchange of documents between the member states) and recommendations (non-binding). Decisions are adopted by a qualified majority (two-thirds of the total number of members) but decisions on sensitive issues (eg, approval of common sanitary and epidemiological and hygienic requirements for goods), the list of which is established by Appendix No. 2 to the EEC Rules and Regulations, must be adopted by consensus. In the exercise of their powers, the EAEU’s officials, including members of the EEC Board, work independently from the government authorities of their member states.

However, in practice, the EEC officials still take into account the position of the executive authorities of their countries.

Upon adoption of a decision, the EAEU member states and the EEC Council members may request changes or cancellation of the decisions of the EEC Board within 15 days from the date of their publication. In this case, the issue is considered by the EEC Council or the Intergovernmental Council, or subsequently by the Supreme Council if the EEC Council fails to reach a consensus.

There are certain issues that the EEC Board is not entitled to consider at its own discretion. For instance, the introduction of special protective, anti-dumping or countervailing measures can be considered only after the manufacturer or association of manufacturers file a respective application to the Department of Domestic Market Protection.

In addition, there are 25 departments within the EEC (including the Department of Customs Legislation and Law Enforcement Practice, and Customs Policy Department) that support the activities of the EEC Council and the EEC Board. The departments are supervised by the members of the Board and include officials and employees selected on a competitive basis. Departments prepare draft EAEU documents, monitor enforcement of EAEU law by the member states, prepare proposals for consideration by the EEC Board based on the monitoring results, and interact with the government authorities in the member states.

In addition, the EEC Board may establish advisory bodies that primarily have the aim of conducting consultations with the representatives of the EAEU member states and preparing recommendations for the EEC in a particular regulatory sphere. Advisory bodies can include government authorities, representatives of the business community and independent experts. Thus, advisory bodies can ensure interaction of the Board members with national authorities and businesses.

3    National subdivisions

Describe the extent to which legislative or rule-making authority relevant to lobbying practice also exists at regional, provincial or municipal level.

The EAEU is a supranational organisation, therefore, there is no division of power into federal, regional and municipal levels. Powers in the EAEU are divided among the Supreme Council, the Intergovernmental Council and the EEC (which has its own hierarchy). Each EAEU body has a determined range of powers and an established procedure for decision-making.

The Treaty does not provide for a clear division of competency between the supranational and national levels, which is linked to the fact that there is a different degree of integration in the various economic sectors. Thus, division of powers depends on the scope of regulation, the commodity market and certain exceptions, such as the non-application by a member state of the general rules of functioning of the EAEU’s internal market.

With regard to the above approach, the Treaty provides for the implementation of a unified, conciliatory or coordinated policy among the EAEU member states. A unified policy involves unified regulation in the member states, including through decisions of the EAEU bodies; a conciliatory policy provides for harmonisation of regulations within the EAEU; and a coordinated policy implies cooperation between the EAEU member states on the basis of a common approach.

Examples of the division of powers in the EAEU are as follows: customs tariff regulation is the exclusive competence of the EAEU; and macroeconomic policy relates to joint regulation of the EAEU and its member states (the EAEU establishes quantitative values of macroeconomic indicators determining sustainability of their economic development). A number of other important areas are regulated by the member states independently with due regard for their commitments in the EAEU (eg, tax policy).

The EAEU bodies do not have the authority to enforce compliance with the adopted decisions. Ensuring compliance with the decisions is the task of the member states. The EEC can ensure the enforcement of EAEU law only under specific conditions. It may, for instance, impose fines on economic entities for violation of the general competition rules, but the fines are collected by the national authorities of the EAEU member states.

The EEC departments can monitor the implementation of regulations in specific areas. Following monitoring, the departments may prepare and submit their proposals to members of the EEC Board for consideration. The EEC Board may also exercise general control and supervision over enforcement of EAEU law and inform the member states about the need to comply with the established norms. However, such notices are not legally binding and carry only reputational risks for the member states. Furthermore, the EEC does not have any authority to apply to court in cases of identified violation of the rules of law by the member states.

4    Consultation process

Does the legislative process at national or subnational level include a formal consultation process? What opportunities or access points are typically available to influence legislation?

There are several ways of protecting business interests within the EAEU.

Public consultations on draft decisions (governed by Chapter VIII of the EEC Rules and Regulations)

Draft decisions of the EAEU bodies prepared by the EEC are released for public consultation at least 30 calendar days before the planned date of their adoption.

A public consultation is not conducted in relation to draft decisions on the issues of customs regulation, application of special protective anti-dumping and countervailing measures or issues subject to regulatory impact assessment. The department responsible for the draft decision (the department) publishes the decision on the official EEC website. The period of public consultation is determined by the department, but it cannot be less than 20 days from the date of the publication of the draft decision. In exceptional cases requiring prompt decision-making, a public consultation may not be held or the length of time for it may be reduced.

All parties concerned may take part in a public consultation. The department must publish a summary of comments and suggestions from participants of the consultation within five days of the end of the public consultation. Based on the contents of the summary, the department can do the following:

  • amend the draft decision taking into account the comments and suggestions provided (it is not required to incorporate all of the recommended changes);
  • dismiss all suggestions – in this case, the draft decision will be submitted to the EEC for further consideration without any substantial amendments; or
  • refuse to elaborate the draft decision, which means that it will not be subject to further consideration and will not be adopted.

Regulatory impact assessment (Chapter IX of the EEC Rules and Regulations)

Draft decisions of the EEC Council and the EEC Board that may influence the business environment (with a few exceptions) are subject to regulatory impact assessment.

Regulatory impact assessment is carried out in two stages. In the first stage, the draft decision is subjected to a public consultation with business entities and other parties concerned (the decision is published on the EEC’s portal for this purpose). The period of public consultation cannot be less than 30 days. The business community can submit comments on draft decisions or fill in a standardised questionnaire as a means of giving feedback. Within 10 days after the end of the public consultation, the department responsible for the draft decision provides a summary of comments and suggestions. Following the public consultation, the department can amend the draft decision (if necessary) and submit it for further consideration. It may also refuse to further elaborate the draft decision.

The second stage is preparation of an opinion on the regulatory impact assessment by a special EEC working group headed by an EEC Board member in charge of economy and financial policy. The opinion must be prepared within 15 days. On the basis of the opinion, the department can finalise the draft decision. Following the consideration, the EEC Council or the EEC Board (depending on which body considers the decision) may either adopt the decision, submit it for further amendments or refuse to adopt it.

Sending official enquiries to the EEC (Chapter III, article 7 of the EEC Rules and Regulations)

According to the regulation, legal entities may send enquiries to the EEC in written form or in the form of an electronic document. Enquiries are logged and processed by the relevant departments (this must be completed within 30 days). In addition, the EEC may request legal entities to provide additional information necessary for exercising its powers.

Cooperation with the EEC via the Advisory Board for Interaction between the EEC and the Business Council of the EAEU (Regulation on the Advisory Board for Interaction of the EEC and the EAEU Business Council)

The Advisory Board for Interaction between the EEC and the EAEU Business Council (an advisory body that includes cross-industrial business unions of the EAEU member states and represents their positions) provides interaction between the business community and the EEC representatives in certain spheres, including: entrepreneurship development; manufacturing; mutual and foreign trade; and technical regulation. Proposals of the Business Council submitted to the EEC are considered by the Advisory Board. The Advisory Board includes the chairman of the EEC Board, members of the EEC Board, members of the Presidium of the Business Council and business community representatives. Decisions of the Advisory Board are not binding, which means the Board does not have much influence on decision-making.

Interaction within the framework of advisory bodies and working groups under the EEC Board

According to Chapter III, article 44 of the Treaty, the EEC Board is entitled to form advisory bodies, which may include representatives of the government authorities of the member states and the business community. Narrow practical issues are discussed within the advisory bodies.

5    Judiciary

Is the judiciary deemed independent and coequal? Are judges elected or appointed? If judges are elected, are campaigns financed through public appropriation or candidate fundraising?

The EAEU Court is an independent body composed of 10 judges (two from each member state). The Court activities are governed by the Treaty and the statute of the EAEU Court.

Judges are appointed for nine years by the Supreme Council on the proposal of the member states. The court is located in Minsk (Belarus). The Court chairman and his or her deputy (who represent different states) are elected by the panel of judges for three years. Upon expiry of the term, the judges select the next chairman and his or her deputy from among the judges representing other member states (ie, the chairman and deputy cannot be elected from the same states that the former chairman and deputy represented).

The EAEU Court can prepare advisory opinions on interpretation of the sources and rules of EAEU law, and it can consider disputes related to enforcement of EAEU law. In case of disputes, claims may be filed by the member states or economic entities. Economic entities can apply to the Court if their rights and interests are affected by the actions or inaction of the EEC. However, a dispute can be examined by the Court only after the parties have tried to settle the dispute in a pretrial order through consultations, negotiations, etc (the parties are given three months to settle).
Court decisions on consideration of disputes are legally binding. However, in practice, the EAEU Court is an ineffective body to protect the interests of the private sector for the following reasons.

First, the Court is not entitled to consider issues of non-compliance with its decisions. These issues are considered by the Supreme Council. However, enforcement of a court decision can be blocked in the Supreme Council by any member state, since all decisions of the Supreme Council are passed on a consensus basis.

Secondly, the EAEU Court is not popular as a dispute resolution body as it is perceived as having little influence. In addition, the business community is insufficiently informed about the activities of the Court.

Thirdly, challenging statutory legal acts and actions of the EEC is possible in other international courts (eg, the World Trade Organization Dispute Settlement Body) and the national courts of the EAEU countries. Foreign investors frequently use international courts, rather than the EAEU Court, to challenge EEC decisions.

Regulation of lobbying

6    General

Is lobbying self-regulated by the industry, or is it regulated by the government, legislature or an independent regulator? What are the regulator’s powers?

There is no separate statutory legal act governing lobbying in the EAEU.

However, the Treaty, the EEC Rules and Regulations, and the Regulation on the Advisory Board for Interaction between the EEC and the EAEU Business Council provide certain mechanisms by which the business community can protect its interests in decision-making processes in the EAEU (see question 4).

7    Definition

Is there a definition or other guidance as to what constitutes lobbying?

There is no definition of lobbying in EAEU law.

8    Registration and other disclosure

Is there voluntary or mandatory registration of lobbyists? How else is lobbying disclosed?

Owing to a lack of regulation on lobbying, there are no requirements in the EAEU for registering lobbyists or disclosing information on carrying out lobbying activities.

In practice, sending formal written enquiries is the preferred form of interaction with the EEC. It is also recommended to send written enquiries in case business community representatives have already discussed the issue with the EEC members at forums, etc, or within the framework of oral negotiations.

9    Activities subject to disclosure or registration

What communications must be disclosed or registered?

Oral negotiations with the employees of the EAEU bodies are not subject to disclosure or registration.
Official written enquiries and enquiries sent to the EEC by legal entities are registered by the EEC.

10    Entities and persons subject to lobbying rules

Which entities and persons are caught by the disclosure rules?

There is no legal regulation of lobbying or requirements to disclose information about lobbying in the EAEU.

11    Lobbyist details

What information must be registered or otherwise disclosed regarding lobbyists and the entities and persons they act for ? Who has responsibility for registering the information?

There is no legal obligation to register or otherwise disclose information regarding lobbyists and the entities and persons they act for.

12    Content of reports

When must reports on lobbying activities be submitted , and what must they include?

There are no requirements in the EAEU to provide reports on lobbying.

13    Financing of the registration regime

How is the registration system funded?

There is no registration system for lobbyists in the EAEU.

14    Public access to lobbying registers and reports

Is access to registry information and to reports available to the public?

EAEU law does not regulate lobbying and does not specify the need to submit reports on lobbying. Therefore, such information is not disclosed and is not published in open sources.

15    Code of conduct

Is there a code of conduct that applies to lobbyists and their practice?

There is no code of conduct for lobbyists in the EAEU.

16    Media

Are there restrictions in broadcast and press regulation that limit commercial interests’ ability to use the media to influence public policy outcomes?

Media activities are not regulated in the EAEU.

Political finance

17    General

How are political parties and politicians funded in your jurisdiction?

There are no legislative bodies or political parties in the EAEU because it is an economic, rather than a political integration organisation.

The activities of the EAEU bodies and their officials are financed by the EAEU budget, which is formed on the basis of contributions from the member states. According to the EEC Rules and Procedures, EEC Board members and officials are not entitled to receive remuneration from individuals or legal entities in connection with exercising their authority.

18    Registration of interests

Must parties and politicians register or otherwise declare their interests? What interests, other than travel, hospitality and gifts, must be declared?

According to the EEC Rules and Regulations, EEC Board members and other EEC officials are not entitled to combine their work in the EEC with any other work, except for scientific, creative and teaching activities. In particular, they may not participate in the activities of the management body of a commercial entity or carry out entrepreneurship activity. Members of the EEC Board and other EEC officials who are shareholders of organisations or who hold income-generating securities must transfer the securities or shares held by them to a trustee who will be responsible for their management.

In general, the regulation establishes that the EEC members must take measures to resolve and prevent conflicts of interest when exercising their powers in the EEC.

According to the Regulation on the provision by the EEC Board members and other EEC employees of income details, information on property and property obligations, the EEC employees and members of the EEC Board must annually provide the following information about themselves and their family members, including minor children:

  • information on income from all sources (pensions, allowances, other payments);
  • information on property;
  • details of funds held in bank accounts or in accounts in other banking institutions; and
  • information on shares and participation in commercial organisations, including grounds for obtaining a stake in organisations (acquisition, donation, inheritance, etc), and information on other securities.

Failure to provide information on income and property, or provision of false information, is subject to disciplinary action.

Judges from the EAEU Court cannot engage in any activities related to income generation, except for scientific, creative and teaching activities. In addition, judges are not entitled to represent the interests of commercial organisations.

19    Contributions to political parties and officials

Are political contributions or other disbursements to parties and political officials limited or regulated? How?

This issue is not applicable to the EAEU as there are no political parties.

20    Sources of funding for political campaigns

Describe how political campaigns for legislative positions and executive offices are financed.

This issue is not applicable to the EAEU. All executive officials in the EAEU are appointed.

21    Lobbyist participation in fundraising and electioneering

Describe whether registration as a lobbyist triggers any special restrictions or disclosure requirements with respect to candidate fundraising.

This issue is not applicable to the EAEU as the registration of lobbyists is not provided for in EAEU law.

22    Independent expenditure and coordination

How is parallel political campaigning independent of a candidate or party regulated?

According to the Treaty, EEC Board members are not entitled to use material resources, technical facilities and other resources and property of the Board for purposes not related to the exercise of authority. Use of the EAEU budgetary funds by Union bodies is monitored within the audit of financial and economic activities (which is conducted at least once every two years) and the annual external audit to monitor formation, management and disposal of the budget, property and other assets of the EAEU.

According to the EEC Rules and Regulations, members of the EEC Board and other EEC employees are not entitled to use their powers in the interests of any political parties, or public or religious associations. They are also prohibited from publicly expressing their attitude to such organisations or associations. In addition, Board members and other EEC officials are not allowed to create political parties or subdivisions of political parties, or public and religious associations in the EEC (with the exception of trade unions, associations of war veterans and other public activity bodies), or to contribute to the creation of such structures. Violation of the above-mentioned restrictions leads to early termination of powers. Such restrictions are related to the fact that the EAEU does not imply any political integration.

According to the statute of the Court, judges cannot represent the interests of any political parties and movements, social or religious groups, or individuals.

Ethics and anti-corruption

23    Gifts, travel and hospitality

Describe any prohibitions, limitations or disclosure requirements on gifts, travel or hospitality that legislative or executive officials may accept from the public.

According to the EEC Rules and Regulations, members of the EEC Board and other EEC officials are not entitled to receive any gifts, remuneration, services, payment for entertainment, leisure time activities, travel costs, etc, from individuals or legal entities in connection with the exercise of authority. Gifts received at events or during business trips are recognised as the EEC’s property and are handed over to the Board under a certificate. A Board member may then buy this gift under the procedure approved by the EEC Council.

In addition, members of the EEC Board and its officials are not entitled to go on trips related to the exercise of authority at the expense of individuals or legal entities.

24    Anti-bribery laws

What anti-bribery laws apply in your jurisdiction that restrict payments or otherwise control the activities of lobbyists or holders of government contracts?

There are no anti-corruption laws or regulations in the EAEU. Unlike the European Union, the EAEU is not a member of the United Nations Convention against Corruption. Measures on combating corruption and corrupt business practices are regulated by the EAEU member states at the national level.
Scholars and experts on anti-corruption issues from the EAEU member states noted the need for harmonisation of the anti-corruption laws in these states and the adoption of common documents (eg, a convention) in this field. The aim is to fight corruption more effectively within the EAEU.

25    Revolving door

Are there any controls on public officials entering the private sector after service or becoming lobbyists, or on private-sector professionals being seconded to public bodies?

This issue is not governed by EAEU law.

In general, a revolving door practice among former EEC employees who used to hold management positions is not very common, though they may hold positions related to the private sector. The most well-known example is that of Viktor Khristenko who became president of the EAEU Business Council in 2016 after the end of his term as chair of the EEC Board.

As the activity of the EAEU bodies, including the EEC, is based on a rotational principle, the common practice is that former officials of the EAEU bodies continue their bureaucratic career in national state bodies. By way of example, Andrey Slepnev (Russia) used to be a member (minister) of the EEC Board in charge of trade issues from 2012 to 2016, and then served as Deputy Chief of the government staff of the Russian Federation and Director of the Department of Project Activities of the government of the Russian Federation. In May 2018, Mr Slepnev was appointed head of the Russian Export Centre, the state-run development institute (it was established by the government to support non-primary export).

The leading positions in the EEC are occupied by officials from the national executive authorities with bureaucratic experience. For example, Timur Suleimenov, who was previously the EEC Board member in charge of economy and financial policy, is currently the Minister of National Economy of Kazakhstan.

In addition, a political career for former EEC employees in their countries is possible but unlikely.

26    Prohibitions on lobbying

Is it possible to be barred from lobbying or engaging lobbying services? How?

This is not applicable as there is no regulation of lobbying in the EAEU.

Recent cases and sanctions

27    Recent cases

Analyse any recent high-profile judicial or administrative decisions dealing with the intersection of government relations, lobbying registration and political finance?

No such cases were registered.

28    Remedies and sanctions

In cases of non-compliance or failure to register or report, what remedies or sanctions have been imposed?

This issue is not applicable to the EAEU as there is no relevant regulation.

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