Anti-Bribery & Corruption in Ukraine 2025

Relevant international and domestic law

International anti-corruption conventions

To which international anti-corruption conventions is your country a signatory?

Foreign and domestic bribery laws

Identify and describe your national laws and regulations prohibiting bribery of foreign public officials (foreign bribery laws) and domestic public officials (domestic bribery laws).

Successor liability

Can a successor entity be held liable for violations of foreign and domestic bribery laws by the target entity that occurred prior to the merger or acquisition?

Civil and criminal enforcement

Is there civil and criminal enforcement of your country’s foreign and domestic bribery laws?

Out-of-court disposal and leniency

Can enforcement matters involving foreign or domestic bribery be resolved through plea agreements, settlement agreements, prosecutorial discretion or similar means without a trial? Is there a mechanism for companies to disclose violations of domestic and foreign bribery laws in exchange for lesser penalties?

Foreign bribery

Legal framework

Describe the elements of the law prohibiting bribery of a foreign public official.

Definition of a foreign public official

How does your law define a foreign public official, and does that definition include employees of state-owned or state-controlled companies?

Gifts, travel and entertainment

To what extent do your anti-bribery laws restrict providing foreign officials with gifts, travel expenses, meals or entertainment?

Facilitating payments

Do the laws and regulations permit facilitating or ‘grease’ payments to foreign officials?

Payments through intermediaries or third parties

In what circumstances do the laws prohibit payments through intermediaries or third parties to foreign public officials?

Individual and corporate liability

Can both individuals and companies be held liable for bribery of a foreign official?

Private commercial bribery

To what extent do your foreign anti-bribery laws also prohibit private commercial bribery?

Defences

What defences and exemptions are available to those accused of foreign bribery violations?

Agency enforcement

What government agencies enforce the foreign bribery laws and regulations?

Patterns in enforcement

Describe any recent shifts in the patterns of enforcement of the foreign bribery rules.

Prosecution of foreign companies

In what circumstances can foreign companies be prosecuted for foreign bribery?

Sanctions

What are the sanctions for individuals and companies violating the foreign bribery rules?

Recent decisions and investigations

Identify and summarise recent landmark decisions or investigations involving foreign bribery.

Laws and regulations

What legal rules require accurate corporate books and records, effective internal company controls, periodic financial statements or external auditing?

Disclosure of violations or irregularities

To what extent must companies disclose violations of anti-bribery laws or associated accounting irregularities?

Prosecution under financial record-keeping legislation

Are such laws used to prosecute domestic or foreign bribery?

Sanctions for accounting violations

What are the sanctions for violations of the accounting rules associated with the payment of bribes?

Tax-deductibility of domestic or foreign bribes

Do your country’s tax laws prohibit the deductibility of domestic or foreign bribes?

Domestic bribery

Legal framework

Describe the individual elements of the law prohibiting bribery of a domestic public official.

Scope of prohibitions

Does the law prohibit both the paying and receiving of a bribe?

Definition of a domestic public official

How does your law define a domestic public official, and does that definition include employees of state-owned or state-controlled companies?

Gifts, travel and entertainment

Describe any restrictions on providing domestic officials with gifts, travel expenses, meals or entertainment. Do the restrictions apply to both the providing and the receiving of such benefits?

Facilitating payments

Have the domestic bribery laws been enforced with respect to facilitating or ‘grease’ payments?

Public official participation in commercial activities

What are the restrictions on a domestic public official participating in commercial activities while in office?

Payments through intermediaries or third parties

In what circumstances do the laws prohibit payments through intermediaries or third parties to domestic public officials?

Individual and corporate liability

Can both individuals and companies be held liable for violating the domestic bribery rules?

Private commercial bribery

To what extent does your country’s domestic anti-bribery law also prohibit private commercial bribery?

Defences

What defences and exemptions are available to those accused of domestic bribery violations?

Agency enforcement

What government agencies enforce the domestic bribery laws and regulations?

Patterns in enforcement

Describe any recent shifts in the patterns of enforcement of the domestic bribery rules.

Prosecution of foreign companies

In what circumstances can foreign companies be prosecuted for domestic bribery?

Sanctions

What are the sanctions for individuals and companies that violate the domestic bribery rules?

Recent decisions and investigations

Identify and summarise recent landmark decisions and investigations involving domestic bribery laws, including any investigations or decisions involving foreign companies.

Key developments of the past year

Please highlight any recent significant events or trends related to your national anti-corruption laws.