Anti-Bribery & Corruption in Ukraine 2025

Ukraine is a party to the following international anti-corruption conventions:

• United Nations Convention against Corruption (entered into force in Ukraine on 1 January 2010);
• United Nations Convention against Transnational Organized Crime and three Protocols thereto (the Convention and Protocols 1 and 2 entered into force in Ukraine on 21 May 2004, and Protocol 3 entered into force in Ukraine on 4 July 2013);
• Council of Europe Criminal Law Convention on Corruption and the Additional Protocol thereto (both entered into force in Ukraine on 1 March 2010); and
• Council of Europe Civil Law Convention on Corruption (entered into force in Ukraine on 1 January 2006).

Also, since 2006 Ukraine is a member of the Group of States against Corruption (GRECO) functioning under the auspices of the Council of Europe.

Ukraine's anti-bribery legal framework is primarily defined by the Law of Ukraine ‘On Prevention of Corruption’, the Criminal Code of Ukraine and the Code of Ukraine on Administrative Offences.

The Law ‘On Prevention of Corruption’ is the main anti-corruption legislative Act in Ukraine. It defines the list of persons who are considered domestic public officials and lays down certain restrictions for them (prohibition of bribery, restrictions on gifts, conflict of interest limitations, ethical rules, compulsory filing of yearly asset declarations and others). The Law also establishes the pillars of Ukraine’s corruption prevention infrastructure: the existence and competence of the National Agency on Corruption Prevention (NACP), adoption of the state anti-corruption strategy and programme, anti-corruption rules for legal entities etc.

The Criminal Code of Ukraine (CCU) sets forth an exhaustive list of criminal corruption offences and establishes punishments for them. Regarding bribery, the CCU establishes criminal liability for:

• acceptance of an offer, promise or receipt of an unlawful benefit by a public official (article 368); and
• offering, promising or giving an unlawful benefit to a public official (article 369).

The term ‘public official’ in the CCU generally covers both domestic and foreign public officials. Thus, the above articles of the CCU prohibit bribery of domestic as well as foreign public officials.

The Code of Ukraine on Administrative Offences (CUAO) stipulates minor corruption-related offences and establishes penalties for them. These include violation of restrictions on presents for public officials, operating under a conflict of interest etc. While these administrative offences are corruption-related, they are not of criminal nature. Only domestic public officials are liable under the CUAO.

Under Ukrainian law, a legal entity in some cases may be subject to criminal liability measures. For example, a fine may be imposed on a legal entity if an authorised person of the entity (director, board member, etc) committed bribery of a domestic or foreign public official on behalf and/or in the interest of that entity. If such legal entity is subject to further reorganisation, the fine may be applied to its successor(s) which obtained property or rights and obligations related to the committed criminal offence.

There is extensive court practice in cases of domestic bribery under article 368 (acceptance of an offer, promise or receipt of an unlawful benefit by a public official) and article 369 (offering, promising or giving an unlawful benefit to a public official) of the CCU. In fact, these are the most widespread criminal charges related to corruption in Ukraine.

When deciding on domestic bribery cases, courts consider the sum of the unlawful benefit, the rank of the official’s position, and how exactly that official position was used to obtain unlawful benefit. The percentage of acquittal verdicts remains low: if the person is charged and the case reaches the court, the probability of being convicted is around 85–98 per cent, depending on the court in question.

Although articles 368–369 of the CCU also establish criminal liability for bribery of foreign public officials, the de facto enforcement practice in such cases is currently absent. At present, we are unaware of any public court cases in Ukraine regarding bribery of foreign public officials.

Regarding civil enforcement mechanisms, Ukraine has a separate procedure of confiscation of unjustified assets (so-called ‘civil confiscation’). Under this special civil law procedure, the court may declare assets to the amount of 1,003,500–9,841,000 hryvnas (for 2025) unjustified if it is proven that the public official did not have sufficient legitimate incomes to acquire them. For an asset to be confiscated, its acquisition should take place after 28 November 2019 (date of entry into force of the respective law). If the sum exceeds the civil threshold of 9,841,000 hryvnas, a person may be subject to criminal charges for unlawful enrichment (article 368-5 of the CCU).

The civil confiscation applies only to domestic public officials or their related parties. Cases of civil confiscation are heard in the High Anti-Corruption Court (HACC). Up to now, the HACC has issued 16 decisions in civil confiscation cases (eight lawsuits fully satisfied, six partially satisfied, and two dismissed). Courts focus on the financial capacity of officials or their related parties to acquire such assets given their legitimate income, savings and significant expenses. Most cases are initiated after the lifestyle monitoring procedure performed by the NACP.

Enforcement matters for individuals involving foreign or domestic bribery can be resolved by entering into a plea agreement. In cases regarding criminal corruption offences, such plea agreement with individuals may only be concluded if (1) the suspect/accused incriminates another person(s) in committing a corruption or corruption-related offence and (2) the disclosed information is confirmed by evidence and (3) the suspect/accused compensates in full or in part for the losses or damages caused (if existent). If case files suggest that the corruption offence was committed by the suspect/accused alone, a plea agreement can be concluded simply after the full compensation of the losses or damages caused (if existent).

The plea agreement must be approved by a sentence of the court. In the sentence, the court also stipulates the punishment for the convicted individual agreed by the prosecution and defence. Such punishment may be more lenient than the lowest limit established in the original sanction of the respective CCU article.

Ukrainian law does not provide mechanisms for companies to disclose violations of domestic bribery laws in exchange for lesser penalties. However, for legal entities in cases of foreign bribery, Ukrainian legislation specifically provides for the conclusion of a settlement agreement between the prosecutor and the legal entity on the application of criminal law measures to the legal entity. When concluding such an agreement, the prosecution must inter alia consider the degree and nature of the entity's cooperation during pre-trial investigation and the provision of all necessary information to identify the individuals who committed the offence. Therefore, cooperation and provision of additional information may result in more favourable terms of the agreement. After signing, such agreement must be approved by a court ruling.  

Regarding bribery of public officials, the Criminal Code of Ukraine (CCU) prohibits the following:

• acceptance of an offer, promise, or receipt of an unlawful benefit by a public official, as well as a request to give such unlawful benefit to oneself or a third party in exchange for the performance or non-performance by such official of actions with the use of his or her powers or official position in the interests of the briber or a third party (article 368); and
• offering, promising, or giving an unlawful benefit to a public official or a third party in exchange for the performance or non-performance by such official of actions with the use of his or her powers or official position in the interests of the briber or a third party (article 369).

In both cases, the term ‘public official’ entails domestic as well as foreign public officials.

The punishment for the above bribery crimes ranges from fines to up to 10–12 years’ imprisonment, depending on the circumstances (rank of the official, size of the bribe, existence of conspiracy, repeated offence, etc).

Criminal fines, special confiscation and additional (non-financial) criminal law measures under the CCU may be applied to a legal entity if its authorised person failed to fulfil the duties imposed on him or her by law or statutory documents of the entity with regard to the performance of corruption prevention measures or with regard to the supervision and/or control of the actions of persons who were acting on behalf of the entity or upon the instructions of its authorised persons, or members of its collective bodies or employees, which in turn led to foreign bribery on behalf of or in the interests of such entity.

Ukrainian law does not establish criminal liability for individuals who fail to prevent bribery of a foreign public official. However, there is administrative liability for such individuals under the Code of Ukraine on Administrative Offences (CUAO). A public official of a state/self-government body, or a company official may be fined 2,125–6,800 hryvnas (in 2025) for failure to take measures provided by law in the event of detecting a corruption offence.

Under the CCU, the term ‘foreign public officials’ includes the following persons:

• officials of foreign states (ie, persons holding positions in a legislative, executive or judicial body of a foreign state, including jurors, in a local self-government body or autonomous entity in the territory of state, other persons performing state functions for a foreign state, in particular for a state or local body, state or municipal enterprise);
• foreign arbitrators;
• persons authorised to resolve civil, commercial or labour disputes in foreign countries in an alternative out-of-court procedure;
• officials of international organisations (employees of an international organisation or any other persons authorised by such organisation to act on its behalf);
• members of international parliamentary assemblies to which Ukraine is a party; and
• judges and officials of international courts.

According to the above definition, employees of state and municipal enterprises performing state functions fall under the category of foreign officials.

Ukrainian law contains anti-bribery restrictions only on receiving gifts (including travel expenses, meals or entertainment) and only for domestic public officials. There are no such restrictions for foreign public officials.

However, a gift to a foreign official may be qualified as a bribe (‘unlawful benefit’) under criminal law if it was aimed at inducing a foreign official to take certain actions with the use of his or her powers or official position in the interests of the giver or a designated third party. If the said aim and link is proven, the parties concerned may be subject to criminal liability. It should also be noted that the definition of ‘unlawful benefit’ in the CCU is quite broad; it covers money and other property, benefits, privileges, services, intangible assets, any other benefits of intangible or non-monetary nature that are offered, promised, provided or received without legal grounds.

There is no concept of facilitating (‘grease’) payments in Ukrainian law. A payment made to a foreign public official to expedite or speed up a certain administrative process may qualify as a bribe (‘unlawful benefit’) and result in criminal liability under the CCU.

Under Ukrainian law, any payment made to foreign public officials without legal grounds (ie, not under a contract or other lawful basis) in exchange for the performance or non-performance by such official of actions with the use of his or her powers or official position in the interests of the giver or third party is a crime.

The CCU criminalises such actions, holding all involved parties accountable, regardless of whether the official receives the benefit directly or through third parties. Intermediaries facilitating these illegal payments are considered accomplices to the crime of bribery.

Under Ukrainian law, both individuals and companies may be held liable for bribing a foreign public official.

Individuals who offer, promise or give an unlawful benefit to a foreign official in exchange for the performance or non-performance by such official of actions with the use of his or her powers or official position in the interests of the briber or a third party are subject to criminal liability.

Legal entities may be held liable for bribery of a foreign public official in the following cases: (1) the foreign bribery is committed by its authorised representative, founder (participant), ultimate beneficial owner or member of the supervisory board acting on behalf of and/or in the interests of the legal entity; (2) its authorised person failed to fulfil the duties imposed on him or her by law or statutory documents of the legal entity with regard to the performance of corruption prevention measures which, in turn, led to foreign bribery on behalf of and/or in the interests of the legal entity; (3) the authorised person failed to exercise proper supervision and/or control, as assigned by law or statutory documents, over the actions of persons who were acting on behalf of the legal entity or upon the instructions of its authorised persons, or members of its collective bodies or employees, which in turn led to foreign bribery on behalf and/or in the interests of such entity; (4) the foreign bribery was committed on behalf of and/or in the interests of the legal entity with the knowledge of its authorised persons, founder (participant), ultimate beneficial owner, member of the supervisory board. Those criminal law measures in cases of foreign bribery may be imposed upon the legal entity if at least one of the above facts is established by the court, regardless of whether any individual is found guilty of a crime of foreign bribery.

Ukrainian legislation does not contain specific provisions on prohibition of commercial bribery with regard to officials of foreign private-owned companies.

A lot of standard exemptions from criminal liability in Ukraine are unavailable to individuals accused of bribery of foreign public officials. In such cases, an individual is not entitled to exemption from criminal liability due to: (1) effective remorse; (2) reconciliation between the perpetrator and victim; (3) bailment to the staff of a company; and (4) change of circumstances.

The remaining defences and exemptions for the accused include:

• exemption from criminal liability due to expiration of the statute of limitations – the general statute of limitations for crimes applies to bribery offences as well;
• plea bargain – in bribery cases, a plea agreement may only be concluded if (1) the suspect/accused incriminates another person(s) in committing a corruption or corruption-related offence and (2) the disclosed information is confirmed by evidence and (3) the suspect/accused compensates in full or in part for the losses or damages caused (if existent). If case files suggest that the bribery was committed by the suspect/accused alone, a plea agreement can be concluded simply after full compensation of the losses or damages caused (if existent). If approved by the court, the mutually agreed punishment under the plea agreement may be more lenient than the lowest limit established in the original sanction for bribery in the CCU;
• reference to mitigating circumstances – the standard mitigating circumstances that may reduce criminal punishment also apply to bribery offences (eg, voluntary confession, sincere remorse, influence of complicated life circumstances, etc); and
• agreement on the application of criminal law measures to the legal entity – in cases of foreign bribery, it is possible to conclude an agreement between the prosecution and the entity on the application of criminal law measures. In the agreement, the parties may agree on more lenient criminal measures.

There is no separate government agency that specifically deals with enforcing national laws and regulations on bribery of foreign officials. Therefore, standard rules on distribution of powers between government anti-corruption agencies apply.

As a rule, pre-trial investigation of criminal bribery cases related to foreign officials is carried out by the National Anti-Corruption Bureau of Ukraine (NABU). Meanwhile, general policy mechanisms to prevent corruption offences are handled by the NACP.

At present, we are unaware of any Ukrainian court decisions or publicly disclosed pre-trial investigations regarding bribery of foreign public officials.

Foreign companies may be prosecuted for foreign bribery under Ukrainian law. This applies to private and public legal entities that are non-residents of Ukraine, including enterprises, institutions or organisations, as well as international (non-governmental) organisations and other legal entities established in accordance with national or international law.

Such foreign companies may be prosecuted for foreign bribery under Ukrainian law in the following cases: (1) foreign bribery is committed by its authorised representative, founder (participant), ultimate beneficial owner or member of the supervisory board acting on behalf of and/or in the interests of the legal entity; (2) its authorised person failed to fulfil the duties imposed on him or her by law or statutory documents of the legal entity with regard to the performance of corruption prevention measures which, in turn, led to foreign bribery on behalf of and/or in the interests of the legal entity; (3) the authorised person failed to exercise proper supervision and/or control, as assigned by law or statutory documents, over the actions of persons who were acting on behalf of the legal entity or upon the instructions of its authorised persons, or members of its collective bodies or employees, which in turn led to foreign bribery on behalf and/or in the interests of such entity; (4) the foreign bribery was committed on behalf of and/or in the interests of the legal entity with the knowledge of its authorised persons, founder (participant), ultimate beneficial owner, member of the supervisory board. Such criminal law measures in cases of foreign bribery may be imposed upon the legal entity if at least one of the above facts is established by the court, regardless of whether any individual is found guilty of a crime of foreign bribery.

The acceptance of an offer, promise or receipt of an unlawful benefit by a public official (article 368 of the CCU) implies the following sanctions for individuals:

• Basic qualification: a fine of 17,000–68,000 hryvnas (in 2025) or probational supervision for up to three years' imprisonment for two to four years, with prohibition to hold certain positions or engage in certain activities for up to three years.
• If the sum of unlawful benefit was substantial (over 151,400 hryvnas in 2025): three to six years' imprisonment with prohibition to hold certain positions or engage in certain activities for up to three years and confiscation of property.
• If the sum of unlawful benefit was large (over 302,800 hryvnas in 2025), or the crime was committed by a public official holding a responsible position, or by prior group conspiracy, or repeatedly, or combined with extortion of an unlawful benefit: five to 10 years' imprisonment with prohibition to hold certain positions or engage in certain activities for up to three years and confiscation of property.
• If the sum of unlawful benefit was extremely large (757,000 hryvnas in 2025), or the crime was committed by a public official holding an especially responsible position: eight to 12 years' imprisonment with prohibition to hold certain positions or engage in certain activities for up to three years and confiscation of property.

The offering, promising or giving an unlawful benefit to a public official (article 369 of the CCU) provides the following sanctions for individuals:

• Basic qualification: a fine of 17,000–68,000 hryvnas (in 2025) or restriction of liberty for two to four years/two to four years' imprisonment.
• Repeated offence: three to six years' imprisonment with a fine of 8,500–17,000 hryvnas and possible confiscation of property.
• If unlawful benefit was given to a public official holding a responsible position or by prior group conspiracy: four to eight years' imprisonment with possible confiscation of property.
• If unlawful benefit was given to a public official holding an especially responsible position or if a crime was committed by an organised group of people or its member: five to 10 years' imprisonment with possible confiscation of property.

For legal entities, the sanctions for bribery include a fine, special confiscation and additional (non-financial) criminal law measures:

• The sum of the fine equals two times the amount of the unlawful benefit which was obtained, proposed, promised or given in the interests of the legal entity. If the unlawful benefit was not received or its amount cannot be calculated, the court applies fixed amounts established in the CCU, depending on the severity of the bribery offence. In addition, the legal entity is obliged to compensate for the damages caused and return any unlawfully obtained benefit.
• Special confiscation entails the uncompensated seizure of funds, valuables or other property of a legal entity if they: (1) were obtained as a result of bribery or constitute income obtained directly from the use of such property; (2) were intended for financing or providing material support for bribery, or as a reward for its commission; (3) were the subject of bribery; and (4) were used as a means to commit bribery.
• Additional non-financial criminal law measures include temporary restriction of a legal entity's activities (eg, prohibition to participate in public and defence procurements, use certain licences, take part in privatisation of state or municipal property, etc) and temporary restriction on receiving rights and/or benefits (eg, prohibition to receive state aid, employ funds of international technical assistance projects, etc). Such additional measures may be imposed for a period of six months to three years.

As a collateral sanction, convicted individuals or legal entities are included in the Unified State Register of persons that committed corruption or corruption-related offences (the Register). Such status entails significant political and reputational risks, creates serious obstacles to further career advancement or business prospects, restricts participation in state procurement procedures. The record about an individual or legal entity in the Register exists for an indefinite amount of time. The Register, together with all its records, is available online to the public 24/7.

There are also collateral sanctions for domestic public officials in labour law. Most of the laws regulating the activities of a certain category of domestic public officials contain provision on termination of employment with a person after a criminal corruption-related court verdict. For instance, the powers of a member of Parliament shall be terminated in the event of entry into force of a guilty verdict against him or her.

At present, we are unaware of any Ukrainian court decisions or publicly disclosed pre-trial investigations regarding bribery of foreign public officials.

In Ukraine, the above matters are governed by the following legal Acts:

• Law of Ukraine ‘On Accounting and Financial Reporting in Ukraine’;
• Law of Ukraine ‘On Audit of Financial Statements and Auditing Activities’;
• Tax Code of Ukraine;
• Commercial Code of Ukraine;
• Law of Ukraine ‘On Prevention and Counteraction to Legalisation (Laundering) of the Proceeds of Crime’; and
• other specific laws and regulations depending on the type of company in question (eg, Law of Ukraine ‘On Limited Liability and Additional Liability Companies’, Law of Ukraine ‘On Joint Stock Companies’, Law of Ukraine ‘On Capital Markets and Regulated Commodity Markets’, etc).

Officials of public law legal entities (ie, state/municipal-owned enterprises, certain other types of companies related to the state/municipality) or their structural divisions as well as officials of companies that participate in substantial public procurements are required to inform relevant state anti-corruption agencies in writing on detected corruption offences of their employees within 24 hours.

Also, regardless of company type, companies must develop and implement measures that are necessary to prevent and combat corruption in its activities under the Law of Ukraine ‘On Prevention of Corruption’. Company management, employees and contractors are obliged by law to immediately report any cases of corruption or corruption-related offences to the company’s compliance officer, CEO or owners. Additional anti-corruption and reporting obligations may be established in the internal anti-corruption programme of the company (if adopted).

In Ukraine, financial accounting laws can be used to prosecute both domestic and foreign bribery. While the main purpose of these laws is to ensure the accuracy and transparency of financial reporting, violations of financial accounting rules can be a sign of corrupt practices such as bribery.

There is no separate liability for accounting irregularities directly related to corrupt practices such as bribery in Ukraine. However, such accounting irregularities may potentially fall within the scope of accounting crimes in the Criminal Code of Ukraine: falsifying of financial documents and reports of a financial organisation (article 220-2), fraud with financial resources (article 222), official forgery (article 366), etc. Criminal sanctions may vary from fines to up to 5 years' imprisonment, depending on the qualification and severity of the offence.

The Tax Code of Ukraine law prohibits the deductibility of both domestic and foreign bribes. Expenses incurred for the purpose of providing an unlawful benefit may not be taken into account when determining the taxable object, and the financial result before tax shall be subject to adjustment by the amount of such expenses.

In terms of bribery of a domestic public official, the Criminal Code of Ukraine (CCU) prohibits the following:

• acceptance of an offer, promise, or receipt of an unlawful benefit by a public official, as well as a request to give such unlawful benefit to oneself or a third party in exchange for the performance or non-performance by such official of actions with the use of his or her powers or official position in the interests of the briber or a third party (article 368); and
• offering, promising, or giving an unlawful benefit to a public official or a third party in exchange for the performance or non-performance by such official of actions with the use of his or her powers or official position in the interests of the briber or a third party (article 369).

The punishment for the above bribery crimes ranges from fines to up to 10–12 years' imprisonment, depending on the circumstances of the crime (rank of the official, size of the bribe, existence of conspiracy, repeated offence, etc).

Regarding failure to prevent bribery, Ukrainian law does not provide for individual criminal liability for persons who fail to take measures to prevent bribery of a domestic public official. However, there is administrative liability under the Code of Ukraine on Administrative Offences (CUAO). A public official of a state/self-government body, or a company official may be fined 2,125–6,800 hryvnas (in 2025) for failure to take measures provided for by law in the event of detecting a corruption offence. Also, a criminal fine under the CCU may be applied to the company if its authorised person failed to take corruption prevention measures provided for by law or statutory documents, which in turn led to bribery.

In current Ukrainian legislation, the term ‘unlawful benefit’ is used instead of ‘bribe’.

Regarding domestic public officials, the CCU establishes criminal liability both for receiving unlawful benefit (article 368) and paying unlawful benefit (article 369). The paying of unlawful benefit to and receiving of such benefit by an official of a private legal entity is also criminalised in the CCU (article 368-3).

For the purposes of bribery crimes (articles 368 and 369 of the CCU), the following individuals are considered domestic public officials:

• persons who permanently, temporarily or under special powers perform the functions of representatives of government or local self-government;
• persons who, permanently or temporarily, hold positions related to the performance of organisational and administrative functions in state authorities, local self-government bodies, state or municipal enterprises, institutions or organisations; and
• persons who perform organisational and administrative functions based on special powers granted by a state or self-government body, a central public administration body with a special status, an authorised body or an authorised person of an enterprise, institution, organisation, a court or a law.

A legal entity is a state/municipal enterprise if the state/municipal share exceeds 50 per cent of its authorised capital or provides the state/territorial community with the right to exercise decisive influence over its business activities.

Employees of state enterprises may be recognised as domestic public officials if they hold positions related to the performance of organisational, administrative or business functions, or perform such functions based on specially granted powers.

The Law of Ukraine ‘On Prevention of Corruption’ imposes restrictions on receiving gifts by domestic public officials. Notably, the law restricts only the receipt of gifts by domestic public officials, and not the act of providing such gifts by third parties.

A ‘gift’ is legally defined as money or other property, benefits, services or intangible assets that are provided/received free of charge or at a price lower than the minimum market price. Given the established Ukrainian court practice, compensation of travel expenses, free meals or entertainment fall into the definition of a ‘gift’.

A domestic public official must never request or receive gifts of any value, both for himself or his relatives, in connection with the performance of his official duties, as well as gifts from subordinates.

A domestic public official is also generally prohibited to receive all other gifts. However, there are certain exceptions to this general prohibition. Gifts that meet the ‘generally accepted notions of hospitality’ (eg, payment for a business lunch, a bottle of wine as a birthday present etc.) are allowed if their value does not exceed 6,056 hryvnas for one gift and 12,122 hryvnas for the whole year from one person or group of persons (in 2025). These value restrictions do not apply to gifts from close relatives, publicly available discounts/winnings/prizes/bonuses (e.g, 50 per cent discount for all customers in a clothing store), covering of business travel expenses (eg, tickets, hotel, meals) from the state or municipal budget, funds of international intergovernmental organisations, funds of international technical assistance, as well as funds of the organiser (co-organiser) of the event for which the person is on a business trip. For the latter reimbursement to be legal, the domestic public official must be in an official business trip under the order of his or her employer.

If gift restrictions are violated, a domestic public official may be subject to administrative liability under article 172-5 of the CUAO. The penalty includes a fine of 1,700–6,800 hryvnas (in 2025) and confiscation of the unlawfully received gift. In the case of a repeated violation during the year, apart from the confiscation and a 3,400–6,800 hryvnas fine (in 2025), the official may be deprived of the right to hold certain positions for a period of one year. The latter deprivation in practice results in the dismissal of the official in question.

There is no concept of facilitating (‘grease’) payments in Ukrainian law. A payment made to a domestic public official to expedite or speed up a certain administrative process may qualify as a bribe (‘unlawful benefit’) and result in criminal liability under the CCU.

Domestic public officials are generally prohibited:

• to engage in any other paid activity (except for teaching, scientific and creative activities, medical practice, sports instructing and refereeing) or entrepreneurship; and
• to be members of the executive or supervisory board, other executive or controlling bodies of enterprises or organisations engaged in commercial activities and aimed at earning profit (the exception being cases where an official represents the interests of the state or territorial community in the entity).

These prohibitions do not apply to certain categories of domestic public officials such as members of the local self-government councils (except for those who exercise their powers on a permanent basis), employees of patronage services, jurors, etc.

Violation of the above restrictions entails administrative liability under article 172-4 of the CUAO. The sanctions include a fine of 5,100–8,500 hryvnas (in 2025) and confiscation of income derived from such activities. In case of a repeated violation during the year, apart from the confiscation and a fine of 8,500–13,600 hryvnas (in 2025), the official may be deprived of the right to hold certain positions for a period of one year. The latter deprivation in practice results in the dismissal of the official in question.

On a separate note, Ukrainian law does not prohibit a domestic public official to own corporate rights (shares) in commercial companies. However, the official is obliged to put such shares under the management of an unrelated third party within 60 days after his or her appointment or election to the official post.

Under Ukrainian law, any payment made to a domestic public official without legal grounds (ie, not under a contract or other lawful basis) in exchange for the performance or non-performance by such official of actions with the use of his or her powers or official position in the interests of the giver or third party is a crime.

The CCU criminalises such actions, holding all involved parties accountable, regardless of whether the official receives the benefit directly or through third parties. Intermediaries facilitating these illegal payments are considered accomplices to the crime of bribery.

Under Ukrainian law, both individuals and legal entities may be held liable for bribing a domestic public official.

Individuals who offer, promise or give an unlawful benefit to a domestic official in exchange for the performance or non-performance by such official of actions with the use of his or her powers or official position in the interests of the briber or a third party are subject to criminal liability. The punishment to the individual for such actions ranges from fines to 10 years' imprisonment with confiscation, depending on the circumstances of the crime (rank of official, size of the bribe, existence of conspiracy, repeated offence, etc.).

Legal entities may be liable for corruption offences committed by its authorised persons (director, board member, etc). This includes situations where such authorised person committed bribery of a domestic public official on behalf and in the interest of that entity. In the case where an authorised person commits bribery or fails to take corruption prevention measures which led to bribery, a fine may be imposed on the legal entity under the CCU.

Ukrainian law prohibits commercial bribery with regard to officials of domestic private-owned companies. Liability exists for officials that receive bribes as well as for individuals that give them.

Article 368-3 of the CCU establishes criminal liability for:

• an offer or promise to an officer of a legal entity of private law, regardless of organisational and legal form, to provide him or her or a third party with an unlawful benefit, as well as the provision of such benefit or a request to provide it for the performance by the said officer of actions or his or her inaction with the use of powers granted to him or her in the interests of the briber or a third party; and
• acceptance of an offer, promise or receipt by an officer of a legal entity of private law, regardless of organisational and legal form, of an unlawful benefit for himself or herself or a third party for performing actions or inaction with the use of powers granted to him or her in the interests of the briber or a third party.

The sanctions for the above crimes range from fines to up to four to seven years' imprisonment, depending on the circumstances (rank of official, size of the bribe, existence of conspiracy, repeated offence, etc).

A lot of standard exemptions from criminal liability in Ukraine are unavailable to individuals accused of bribery of domestic public officials. In such cases, an individual is not entitled to exemptions from criminal liability due to (1) effective remorse, (2) reconciliation between the perpetrator and victim; (3) bailment to the staff of a company; and (4) change of circumstances.

The remaining defences and exemptions for the accused include:

• Exemption from criminal liability due to expiration of the statute of limitations – the general statute of limitations for crimes applies to bribery offences as well.
• Plea bargain – in bribery cases, a plea agreement may only be concluded if (1) the suspect/accused incriminates another person(s) in committing a corruption or corruption-related offence and (2) the disclosed information is confirmed by evidence and (3) the suspect/accused compensates in full or in part for the losses or damages caused (if existent). If case files suggest that the bribery was committed by the suspect/accused alone, a plea agreement can be concluded simply after full compensation of the losses or damages caused (if existent). If approved by the court, the mutually agreed punishment under the plea agreement may more lenient than the lowest limit established in the original sanction for bribery in the CCU.
• Reference to mitigating circumstances – the standard mitigating circumstances that can reduce criminal punishment also apply to bribery offences (eg, voluntary confession, sincere remorse, influence of complicated life circumstances, etc).

In Ukraine, the fight against domestic bribery is carried out by a complex system of state bodies:

• National Agency on Corruption Prevention (NACP) – its key role is to prevent corruption through a set of legal and policy mechanisms. NACP’s powers include the audit of electronic asset declarations of public officials, lifestyle monitoring of public officials, control over the observance of various anti-corruption restrictions, development of state anticorruption programme, anti-corruption expertise of legal acts etc. The NACP has the right draw up administrative protocols for violations of anti-corruption legislation (in case of administrative violations) or submit materials to law enforcement agencies for further criminal investigation (in case of criminal violations).
• National Anti-Corruption Bureau of Ukraine (NABU) – focuses on investigation of bribery cases where top officials or large sums of bribes are involved. Pre-trial investigations are conducted by NABU detectives.
• State Bureau of Investigation (SBI) – investigates corruption offences within its competence, in particular bribery committed by NABU and SAPO employees.
• National Police of Ukraine (NPU) – investigates corruption offences that do not fall within the competence of the NABU and the SBI, including cases of minor bribery committed by low-level domestic officials.
• Asset Recovery and Management Agency (ARMA) – is responsible for the identification, seizure and management of assets derived from corruption and other crimes. ARMA performs an important function in ensuring the confiscation of illegally acquired property and its subsequent transfer into state ownership.
• Specialised Anti-Corruption Prosecutor's Office (SAPO) – is an independent structural unit of the Prosecutor General’s Office. SAPO prosecutors provide procedural guidance in investigations conducted by NABU detectives and support state prosecution in high-profile bribery cases. Meanwhile, lower-level bribery cases are handled by ordinary prosecutors.
• High Anti-Corruption Court (HACC) – is a specialised judicial body that decides on high-profile corruption cases handed to them by the NABU and the SAPO. Lower-level bribery cases are heard in ordinary local courts.

Martial law has been in force in Ukraine since 24 February 2022. It has brought about a lot of major shifts in enforcement patterns, inter alia:

• Martial law has led to legal and factual changes in criminal procedures aimed at simplifying pre-trial investigations. This results in increased activity of investigative organs and presents new challenges to white-collar crime lawyers.
• Military conflict has caused a rapid increase in defence procurements and humanitarian aid supply. Law enforcement bodies are rigorous in investigating potential bribery and embezzlements during public procurements, especially in the defence sector.
• A lot of attention is given to bribery in military drafting offices and medical expert commissions during the mobilisation process, as well as to bribery related to smuggling of men eligible for military service across the state border. Court practice in these types of cases is rapidly developing.
• The NACP has drastically increased its activities in lifestyle monitoring of public officials and members of their families. In 2016–2022, only a few dozen monitorings were conducted. However, after the full-scale invasion of Ukraine in 2022, the monitoring procedure was upgraded, and in 2023 alone the NACP already conducted 552 monitorings. The results of those NACP monitorings became the basis for numerous corruption-related criminal cases.
• For the first time in Ukrainian history, in 2024 official rewards were paid to two corruption whistle-blowers for providing valuable information. The provision on payment of whistle-blower rewards appeared in Ukrainian law in 2019 but was implemented in practice only in 2024.

Ukrainian law does not provide for direct criminal liability of foreign companies for domestic bribery.

However, if a director or other employee of a foreign company commits bribery in Ukraine, such individual may be held liable under Ukrainian criminal law. The CCU also provides for the possibility of prosecuting foreigners or stateless persons who do not permanently reside in Ukraine if they have committed corruption offences outside Ukraine in complicity with or provided undue advantage to Ukrainian officials.

The acceptance of an offer, promise or receipt of an unlawful benefit by a public official (article 368 of the CCU) implies the following sanctions for individuals:

• Basic qualification: a fine of 17,000–68,000 hryvnas (in 2025) or probational supervision for up to three years or two to four years' imprisonment, with prohibition to hold certain positions or engage in certain activities for up to three years.
• If the sum of unlawful benefit was substantial (over 151,400 hryvnas in 2025): three to six years' imprisonment with prohibition to hold certain positions or engage in certain activities for up to three years and confiscation of property.
• If the sum of unlawful benefit was large (over 302,800 hryvnas in 2025), or the crime was committed by a public official holding a responsible position, or by prior group conspiracy, or repeatedly, or combined with extortion of an unlawful benefit: five to 10 years' imprisonment with prohibition to hold certain positions or engage in certain activities for up to three years and confiscation of property.
• If the sum of unlawful benefit was extremely large (757,000 hryvnas in 2025), or the crime was committed by a public official holding an especially responsible position: eight to 12 years' imprisonment with prohibition to hold certain positions or engage in certain activities for up to three years and confiscation of property.

The offering, promising or giving an unlawful benefit to a public official (article 369 of the CCU) provides the following sanctions for individuals:

• Basic qualification: a fine of 17,000–68,000 hryvnas (in 2025) or restriction of liberty for two to four years/two to four years' imprisonment.
• Repeated offence: three to six years' imprisonment with a fine of 8,500–17,000 hryvnas and possible confiscation of property.
• If unlawful benefit was given to a public official holding a responsible position or by prior group conspiracy: four to eight years' imprisonment with possible confiscation of property.
• If unlawful benefit was given to a public official holding an especially responsible position or if a crime was committed by an organised group of people or its member: five to 10 years' imprisonment with possible confiscation of property.

For legal entities, the only sanction for domestic bribery is a fine. The sum of a fine equals two times the amount of the unlawful benefit which was obtained, proposed, promised or given in the interests of the legal entity. If the unlawful benefit was not received or its amount cannot be calculated, the court applies fixed amounts established in the CCU, depending on the severity of the bribery offence. In addition, the legal entity is obliged to compensate for the damages caused and return any unlawfully obtained benefit.

Recent landmark decisions and investigations involving bribery of domestic public officials are as follows:

• One of the most notable bribery cases is the case against the Head of the Supreme Court. In May 2023, NABU detectives exposed the Head of the Supreme Court for accepting an unlawful benefit of US$2.7 million. This case was recognised as the ‘most high-profile case’ in the history of the NABU and the SAPO, as no one of such high rank in the Ukrainian judiciary had ever been suspected of corruption before. According to investigation results, the Head of the Supreme Court, acting in collusion with a notary and an attorney-at-law, organised a scheme to receive unlawful benefits for passing favourable court decisions. One of these decisions allegedly concerned the interests of a well-known Ukrainian billionaire. In August 2024, the HAAC started hearing the case against the defendant on its merits.
• Another recent high-profile case concerned an incumbent member of the Ukrainian Parliament (MP). The MP was accused of attempting to bribe the Head of the State Agency for the Restoration and Development of Infrastructure of Ukraine in November 2023. According to the prosecution, the MP offered the Head of the Agency an unlawful benefit to the amount of US$50,000 in exchange for assistance in allocating money from the Fund for the elimination of the consequences of armed aggression to repair the buildings of the university where the MP held the position of rector. The MP was uncovered after giving the first instalment of the bribe in bitcoin. An interesting fact is that this was the first documented criminal case in Ukrainian history where unlawful benefit was given in cryptocurrency. In November 2024, the HACC found the MP guilty and sentenced him to eight years' imprisonment with confiscation of property and disqualification to hold certain official positions for three years.
• In March 2024, another MP allegedly voiced a demand to the head of a village council in Sumy region to provide unlawful benefit for non-interference in the tender process for the repair of a local water supply system. According to the investigators, the MP demanded a kickback to the amount of 10 per cent of the value of the tender contract. An additional 4 per cent was to be transferred to local law enforcement officers for non-interference in the project. The total amount of the alleged unlawful benefit was 3.4 million hryvnas. In July 2024, the MP was presented with an official notice of suspicion.

At present, we are unaware of any recent high-profile Ukrainian court decisions or publicly disclosed pre-trial investigations involving foreign companies.

• For one and a half years after the beginning of the full-scale invasion of Ukraine by Russia on 24 February 2022, the obligation to file electronic asset declarations of public officials was put on hold. However, in October 2023 the Ukrainian Parliament adopted a law that renewed mandatory asset e-declarations for most domestic public officials. Since the restoration of e-declaring, the National Agency on Corruption Prevention (NACP) completed over 600 declaration audits, some of which resulted in further administrative or criminal charges. The NACP also reviewed its internal by-laws on the approach to auditing e-declarations and established a new automatic mechanism for risk-based assessment of every filed declaration.
• At the end of 2023, the Ukrainian Parliament restored the lifetime status of politically exposed persons (PEPs) for the purpose of financial monitoring. The recognised anti-money laundering principle ‘once a PEP, always a PEP’ now applies in Ukraine.
• The latest legislative efforts are focused on increasing the autonomy and efficiency of anti-corruption enforcement agencies. In December 2023, the Parliament passed a 40 per cent increase of National Anti-Corruption Bureau (NABU) of Ukraine staff, and in March 2024 the Parliament supported the strengthening of autonomy of the Specialised Anti-Corruption Prosecutor's Office by separating it from the Office of the Prosecutor General.
• In February 2024, the Parliament adopted the long-awaited Law of Ukraine ‘On Lobbying’. For the first time in Ukrainian history, a legal framework for lobbying was introduced. The law addresses a wide range of lobbying methods, sets ethical boundaries and transparency measures, obliges lobbyists to report on their activities and provides for the establishment of a Transparency Register of lobbyists.
• In October 2024, legislators adopted a law that improves the procedure for concluding plea agreements in corruption cases. According to the new amendments, a suspect or accused may plead guilty in exchange for a reduced sentence if he or she exposes another person(s) in committing a corruption or corruption-related offence, the disclosed information is confirmed by evidence and the losses or damages and the suspect or accused compensates in full or in part for the losses or damages caused (if existent).
• In December 2024, the Parliament adopted amendments to the Tax Code of Ukraine to incorporate OECD recommendations. The amendments prohibit the deduction of expenses related to providing unlawful benefits to both domestic and public officials, regardless of ongoing investigations or court decisions. Additionally, tax authorities are now required to report to the NABU any findings during audits that may indicate the provision of unlawful benefit.
• In December 2024, the Parliament passed amendments to the Criminal Code of Ukraine and other laws to enhance mechanisms for holding legal entities accountable for foreign bribery. Among other things, the amendments set forth specific cases when an entity may be held liable for foreign bribery, establish a special kind of settlement agreement between the prosecution and entity in foreign bribery cases, introduce additional criminal measures that may be imposed on legal entities in foreign bribery cases.