anticorruption regulations in Moldova are recent and therefore unclear on certain practical issues. Since the range of legally unproblematic gifts is narrow, we highly recommend developing and implementing an anticorruption corporate policy with assistance of qualified Moldovan counsel.
Among particulars of such policy the following cornerstone provisions need to be incorporated:

• Corporate anticorruption policy should be binding on all the company’s employees without exceptions;
• Corporate anticorruption policies need to thoroughly describe the list of persons who are subject to anticorruption regulations, including the Corruption Infringers, the ‘executive officers’, and ‘high executive officers’, as described above;
• Corporate anticorruption policy should directly and strictly oblige the employees to inform the senior management about making any gift or providing any benefit to any public officials;
• As a general rule, “symbolic signs of attention and souvenirs” could be offered as gifts (and services) to public officials only during official delegations and other official meetings, according to “unanimously recognised norms of protocol and courtesy”. Value of such symbolic signs of attention or souvenirs could not exceed the amount of one minimum monthly wage in Moldova, which is currently set at MDL 600 Lei (about USD 50). As both the amount of minimum monthly wage and the official MDL/USD exchange rate could fluctuate – corporate anticorruption compliance policy should instruct the company’s personnel to check the current figures before granting any gift;
• It is highly recommended at all times to avoid creating the perception that the purpose of any gift offering might be connected, directly or indirectly, with exercise by the public official of its official duties;
• Corporate anticorruption policy should specify that the Company and its employees are not allowed to finance public officials, grant them whatsoever material and/or intangible assistance, perform works free of charge, or render services free of charge.