Country projects: Ukraine

In 2024, with funding from the United States, ACN launched a two-year project focused on supporting Ukraine in its participant status and further capacity-building. This project aims to identify deficiencies in Ukraine’s legislative and enforcement framework to combat the bribery of foreign public officials and will provide recommendations to rectify these shortcomings. It will also help Ukraine build the law-enforcement capacities necessary to implement the convention and that are key to succeeding in its accession aspirations. The work is intended as technical assistance; findings and recommendations will not be binding for the OECD Working Group on Bribery, which will formally assess Ukraine’s accession request. Nevertheless, the proposed activities will allow Ukraine to begin addressing its deficiencies immediately, increasing the likelihood of meeting the accession criteria when the formal assessment begins.

This project provides technical assistance to fill gaps and align Ukrainian legislation with the requirements of the Anti-Bribery Convention beyond the immediate accession criteria. The project will also assist Ukraine in building its capacity to prevent, detect, investigate and prosecute foreign bribery, with a focus on detection by stakeholders from the public and private sectors. It will include a set of activities aimed at strengthening business integrity, particularly on implementing the 2021 Anti-Bribery Recommendation. In addition, it will provide law enforcers with additional sources of detection and help prevent foreign bribery and broader corruption.

The integrity and anti-corruption review will help Ukraine design and implement comprehensive integrity and anti-corruption strategies and policies. ACN’s role in the review will be to assess the business integrity framework in Ukraine against its compliance with the 2021 Recommendation for Further Combating Bribery of Foreign Public Officials in International Business Transactions and ACN's Regional Recommendations on Business Integrity. This will provide a strong tool to incentivise anti-corruption compliance in the private sector that is key to ensuring integrity in the reconstruction of Ukraine, with the involvement of the private sector. It will also help the Ukrainian government in developing future anti-corruption policies and practical measures on business integrity.

Funded by the Government of Sweden, this project was implemented in 2023, contributing to the education of the business community on the OECD Anti-Bribery standards. It also helped involve businesses in Ukraine’s process of reform to align with the standards of the OECD Working Group on Bribery.

Through two workshops and a joint consultation event between the business community and the government, ACN raised awareness of OECD standards and initiated a dialogue on the changes that businesses will face with the upcoming reforms. The focus of discussions was on the reform of the corporate liability for corruption, a major reform initiated by the government in 2022. As a result, the business community put forward its proposals to the draft legislation and proposed joint government-business actions on business integrity to better align with OECD standards. The training package used at the workshops was shared with the National Agency on Corruption Prevention and the Ukrainian Network of Compliance and Integrity to help future efforts to raise awareness and build capacity.

Funded by the Government of Norway, this project was implemented under the OECD-Ukraine Memorandum of Understanding from 2019-21. The project helped state-owned enterprises in the energy sector with their ability to build efficient anti-corruption internal control mechanisms. It also delved into the energy sector of Ukraine, analysing corruption risks inherent to the sector and the government’s countermeasures and provided a set of recommendations for the way forward. The reports below also cover the investigation and prosecution of corruption in this sector, as well as common challenges faced by law enforcement and recommendations for anti-corruption agencies.

Funded by the United States, this project was implemented in 2020-22 and involved training detectives from Ukraine’s National Anti-Corruption Bureau and the Specialised Anti-Corruption Prosecutor’s Office. The training focused on investigating sophisticated corruption and money-laundering schemes using modern financial and IT tools, different types of companies and complex asset structures, and adjudication. It was conducted as a simulated investigation and trial involving judges of the High Anti-Corruption Court. The project built on many years of simulated investigation training conducted by ACN with US funding.