Anti-Bribery & Corruption 2026: Ukraine

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).

Since 2006, Ukraine has been a member of the Group of States against Corruption (GRECO), functioning under the auspices of the Council of Europe.

Also, in October 2025, the OECD Working Group on Bribery in International Business Transactions officially approved Ukraine's request to accede to the OECD Anti-Bribery Convention and become a fully fledged member of the Working Group. Pending certain technical procedures and amendments to national legislation, it is expected that Ukraine will ratify the Convention in the near future.

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, and operating under a conflict of interest. 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. Hor 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 of and/or in the interest of that entity. If the legal entity is subject to further reorganisation, the fine may be applied to its successor(s) that 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 (civil confiscation). Under this special civil law procedure, the court may declare assets to the amount of 1,505,250-9,984,000 hryvnas (for 2026) unjustified if it is proven that the public official did not have sufficient legitimate income 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 9,984,000 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 Ligh Anti-Corruption Court (LACC). Up to now, the LACC has issued 30 decisions in civil confiscation cases (13 lawsuits fully satisfied, 12 partially satisfied and five 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 lifestyle monitoring procedures or e-declaration checks 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; (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. A plea agreement in a corruption or corruption-related offence may also stipulate confiscation of property as an additional form of punishment.

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 their 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 fficial or a third party in exchange for the performance or non-performance by such official of actions with the use of their powers or official position in the interests of the briber or a third party (article 369).

In both cases, the term "public official" refers to 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 them 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. Lowever, 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 2026) for failure to take measures provided by law in the event of detecting a corruption offence.

A request of a foreign public official to give a bribe (unlawful benefit) to themself or a third party in exchange for the performance or non-performance by such official of actions with the use of their powers or official position in the interests of the briber or a third party constitutes a criminal offence in Ukraine under article 368 of the CCU.

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 their 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 their 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 their 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:

• 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;
• its authorised person failed to fulfil the duties imposed on them 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;
• 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; and
• 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:

• effective remorse;
• reconciliation between the perpetrator and victim;
• bailment to the staff of a company; and
• 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; (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, in’uence 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 National Agency on Corruption Prevention (NACP).

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

Horeign 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:

• 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;
• its authorised person failed to fulfil the duties imposed on them 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;
• 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; and
• 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 2026) 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 166,400 hryvnas in 2026): 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 332,800 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 (832,000 hryvnas in 2026), 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 2026) or restriction of liberty for two to four years or two to four years' imprisonment.
• Repeated offence: three to six years' imprisonment with a fine of 8,500-17,000 hryvnas (in 2026) 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 that 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, and restricts participation in state procurement procedures. The record stays in the Register for a long time: five years for legal entities, and until the expiry/removal of a criminal record for individuals. The data in the Register is public and may be freely accessed online 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 them.

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.

In Ukraine, there is no separate liability for accounting irregularities directly related to corrupt practices such as bribery . 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 five 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 their 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 their 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 2026) 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 themself or their relatives, in connection with the performance of their 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 6,656 hryvnas for one gift and 13,312 hryvnas for the whole year from one person or group of persons (in 2026). These value restrictions do not apply to gifts from close relatives, publicly available discounts/winnings/prizes/bonuses (eg, 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 their 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 2026) 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 2026), 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:

• from engaging in any other paid activity (except for teaching, scientific and creative activities, medical practice, sports instructing and refereeing) or entrepreneurship; and
• from being 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 2026) and confiscation of income derived from such activities. In the case of a repeated violation during the year, apart from the confiscation and a fine of 8,500-13,600 hryvnas (in 2026), 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 from owning corporate rights (shares) in commercial companies. Lowever, the official is obliged to put such shares under the management of an unrelated third party within 60 days after their 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 their 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 their 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 of and in the interest of that entity. If an authorised person commits bribery or fails to take corruption prevention measures that 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 them or a third party with an unlawful benefit, as well as the provision of such benefit or a re‘uest to provide it for the performance by the said officer of actions or their inaction with the use of powers granted to them 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 themself or a third party for performing actions or inaction with the use of powers granted to them 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:

• effective remorse;
• reconciliation between the perpetrator and victim;
• bailment to the staff of a company; and
• 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; (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; and
• 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 o'cials, control over the observance of various anti-corruption restrictions, development of state anti-corruption 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 the 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 Specialised Anti-Corruption Prosecutorqs Office (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 Prosecutorqs 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.
• Ligh Anti-Corruption Court (LACC) - 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.

In 2025, the following enforcement patterns in corruption offences could be observed:

• Due to continuous full-scale military aggression against Ukraine, public procurement in the defence sector has grown significantly. In 2025, law enforcement bodies were especially active in investigating and prosecuting corruption in the defence sector. Prominent cases include the procurement of drones, electronic warfare devices, personal protective equipment and food for the military at indicated prices from related companies, possible embezzlement during construction of defence fortifications and alleged instances of kickbacks. One of the trends in those cases is the increasing role of economic and appraisal expert examinations to determine the true market value of purchased goods and services.
• The number of civil confiscation cases against public officials has increased drastically. In 2025, the LAAC issued more decisions on civil confiscation of unjustified assets than in 2019-2024 combined. As compared to criminal cases of unjust enrichment, civil confiscation enjoys a lower standard of proof ("balance of probabilities" instead of "beyond reasonable doubt") and is much quicker. Meanwhile, the number of criminal unjust enrichment cases has also grown in 2025. One of the reasons for this is the active work of the NACP within the procedures of lifestyle monitoring and e-declaration audits.
• There was an increase in the number of notices of suspicion and indictments regarding legalisation (laundering) of money from corruption-related offences. Anti-corruption bodies, particularly the NABU, have shown the ability to detect elaborate money laundering schemes. As a result, corruption-related charges for unjust enrichment, wrongful e-declaring or bribery are often paired with additional charges for money laundering.
• Law enforcement agencies continue to invest substantial time and resources in investigating corruption within the mobilisation process. This includes bribery in drafting offices and military command structures to facilitate evasion of military service, bribery in medical expert commissions to obtain favourable diagnoses, and corruption in educational institutions to secure student exemptions from military service.
• Extradition has become more frequent and efficient. Despite the risks posed by military confict, Ukraine has successfully extradited dozens of suspects in white-collar crime cases in 2025. The trend towards extradition is strengthening, with foreign courts increasingly refusing to consider war in Ukraine as an une‘uivocal reason to deny extradition.

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

Lowever, 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 ‘ualification: a fine of 17,000-68,000 hryvnas (in 2026) 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 166,400 hryvnas in 2026): 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 332,800 hryvnas in 2026), 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: 8ve 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 (832,000 hryvnas in 2026), 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 2026) 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 (in 2026) 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 that 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.

Landmark decisions and investigations on corruption crimes of domestic public officials in 2025 include the following:

• One of the most notable white-collar crime investigations in 2025 was "Operation Midas", involving top-level corruption in the Ukrainian energy sector. In November 2025, NABU and SAPO uncovered an organised crime group that orchestrated an extensive kickback scheme at the state nuclear power company Energoatom. According to the investigation, perpetrators demanded 10-15 per cent kickbacks from contractors supplying goods or services, and then laundered payments through layered transactions and offshore companies. Notices of suspicion were served on a well-known Ukrainian businessman, one of Energoatom's senior managers, an adviser to the Minister of Energy and other participants in the scheme. A former Deputy Prime Minister of Ukraine was also notified of suspicion for unjust enrichment linked to this case. In addition, searches were conducted at the premises of the Minister of Energy, Minister of Justice and the Lead of the Office of the President. The pre-trial investigation remains ongoing and new high-profile suspects may emerge.
• The NABU exposed a major corruption scheme involving inflated state procurement contracts for drones and electronic-warfare equipment. Investigators reported that defence contracts had been concluded at deliberately indicated prices, with approximately 30 per cent of the contract value allegedly returned to the perpetrators as unlawful benefit. Current suspects include a sitting Ukrainian MP, heads of regional administrations and senior National Guard officers. The investigation is still ongoing.
• On 31 October 2025, the LACC found the former Lead of the State Hiscal Service of Ukraine guilty of abuse of power for involvement in corrupt gas-related schemes that allegedly inflicted losses on the state of over 2 billion hryvnas. The trial lasted over six years and included more than 200 hearings. Lowever, as of December 2025, the verdict has not yet entered into force: the defence has filed an appeal with the LACC Appellate Chamber.
• In March 2025, the LACC approved a plea agreement under which a Ukrainian MP and her husband, a prominent local businessman, pleaded guilty in a major corruption-related case. The investigation established that in 2021-2022 the MP acquired assets worth over 20 million hryvnas in excess of her lawful income and savings. These funds were later transferred as a loan to her husband and were used to purchase a family residence in Odesa region. The MP was charged with unjust enrichment and false anti-corruption declaring, while her husband was accused of money laundering and complicity in false anti-corruption declaring. Under the plea agreement, both defendants received five-year sentences (with exemption from serving the sentence and a probation period of two years), fines and disqualification from holding public office for two years. The sum of 20 million hryvnas was confiscated.

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

• On 22 July 2025, the Ukrainian Parliament adopted controversial Law No. 4555-IX, which restricted the procedural independence of key anti-corruption bodies - the National Anti-Corruption Bureau of Ukraine (NABU) and the Specialised Anti-Corruption Prosecutorqs Office (SAPO) - by subordinating them to the Prosecutor General. Inter alia, the Prosecutor General was given exclusive powers to reassign any NABU investigations to other law enforcement agencies and issue legally binding instructions to SAPO prosecutors and NABU detectives. Hollowing major public backlash and civil protests, the Parliament restored the independence of NABU and SAPO on 31 July 2025 by passing Law No. 4560-IX.
• In 2025, the institutional restart of the Economic Security Bureau of Ukraine (ESB) was finalised. ESB is an important pre-trial investigation authority specialising in economic crimes. Hollowing the adoption of legislation for ESB's reset, an open competition was held for the position of ESB Lead. An independent commission with international participation selected the winning candidate and submitted him to the Cabinet of Ministers for approval. Although the Cabinet initially re–ected the appointment, the candidate was eventually appointed as ESB Lead. The ESB reset was widely welcomed by Ukrainian civil society and foreign partners as part of Ukrainejs international commitments.
• A public Unified State Register of Corrupt Officials has existed in Ukraine since 2014. All persons held liable for any disciplinary, administrative or criminal corruption and corruption-related offences were inserted into the Register for life. In April 2024, the European Court of Luman Rights (ECLR) delivered a judgment in a landmark case Sytnyk v Ukraine. The applicant in the case, a former NABU Director who was inserted in the Register for a minor administrative offence in 2019, claimed that his indefinite inclusion in the Register violated the European Convention on Luman Rights. The ECLR ruled that the inclusion of the applicant into the Register for an indefinite period violated article 8 of the Convention, in other words, it constituted interference with the right to respect for his private life that was not proportionate to the pursuit of the declared legitimate aim. In response to the judgment, the Ukrainian Parliament adopted Law No. 44/6-IX of 17 June 2025, establishing limited terms for storing information in the Register: one year for individuals brought to civil or administrative liability; five years for legal entities subject to criminal law measures for corruption offences; and a period until the expiry of the criminal record for individuals convicted of corruption or corruption-related offences.
• Since the introduction of martial law in 2022, some defendants in white-collar crime cases sought to suspend their court trials by initiating their own mobilisation to the Ukrainian Armed Forces. In 2025, the Parliament passed amendments prohibiting the mobilisation of individuals accused of serious or particularly serious corruption offences while their cases are pending before the court.
• The Law "On Sanctions" has been in force in Ukraine for over 10 years. Its application has become particularly important after the full-scale Russian invasion in 2022. However, Ukrainian legislation still lacks legal liability for breach of sanctions. In January 2025, the President submitted Draft Law No. 12406, aimed at establishing criminal liability for deliberate breach or evasion of sanctions. As of December 2025, the draft was voted by the Parliament in the first reading and is being prepared for second reading in committees.