Preventing and Combating Corruption in Wartime Ukraine: Legal Framework and Current Challenges

Legal Framework

Fighting corruption remains one of Ukraine’s top state priorities — even under martial law. The fundamental legal basis includes the Law of Ukraine On Prevention of Corruption, Criminal Code of Ukraine, and regulations governing the work of key institutions such as the National Anti-Corruption Bureau of Ukraine (NABU), the Specialised Anti-Corruption Prosecutor’s Office (SAPO), and the National Agency on Corruption Prevention (NACP).

In 2023, the Cabinet of Ministers of Ukraine adopted Resolution No. 220 On Approval of the State Anti-Corruption Programme for 2023–2025, aimed at identifying weaknesses in the anti-corruption infrastructure and offering reforms to strengthen enforcement and transparency.

Key Provisions and Institutions

Ukraine’s anti-corruption infrastructure consists of several independent bodies:

• NABU investigates top-level corruption crimes;
• SAPO, recently restructured for greater independence, oversees NABU’s investigations;
• NACP focuses on compliance, asset declarations, and corruption risk analysis.

Recent legislative reforms have increased NABU’s staff to up to 1,000 employees, enhancing its operational capacity.

In December 2023, the Verkhovna Rada adopted amendments making SAPO institutionally independent from the Prosecutor-General’s Office — a major step forward in ensuring prosecutorial autonomy.

Legal Remedies and Enforcement Measures

Victims and whistleblowers can report corruption through multiple channels: NABU’s online portal, NACP’s whistleblower system, or directly to the prosecutor’s office. Ukrainian law also provides for protection of whistleblowers and offers reduced penalties for those who voluntarily report corruption.

Amendments to the Law of Ukraine On State Secrets now regulate transparency in defence procurement, requiring public disclosure of certain contract details — unless such information is classified for national security reasons.

Additionally, a legislative initiative proposes the establishment of an electronic register of participants in state defence contracts to eliminate fictitious suppliers and enhance oversight.

Recent Developments

1. Procurement Transparency
   Parliament amended Article 8 of the Law On State Secrets to allow partial disclosure of defence procurement data. This was done in response to high-profile scandals and public demand for accountability during wartime.
2. Criminal Proceedings
   As of early 2025, NABU is investigating over 60 criminal proceedings regarding corruption in the defence sector. A major case from January 2024 revealed an attempt to embezzle UAH 1.5 billion (approx. USD 40 million) intended for mortar shell procurement.
3. Corruption in Military Conscription
   Prosecutors reported multiple cases of bribes offered to avoid mobilisation or re-register military vehicles. For example, in March 2024, a Kyiv territorial recruitment officer was accused of soliciting USD 900 to keep vehicles off mobilization rosters.
4. Economic Mobilization
   In May 2024, the Economic Development Committee proposed a mechanism allowing companies to “book” strategically-important employees by paying UAH 20,000 per month — a measure designed to balance economic stability with military needs.

Illustrative Cases

• Case 1:
  In January 2024, a senior Defence Ministry official, along with private contractors, was charged with attempting to embezzle funds during a large-scale arms procurement deal. The case highlights the risks of non-transparent defence spending.
• Case 2:
  In July 2023, military and local government officials in Volyn Region were caught accepting bribes to avoid conscription. The amount received was close to UAH 37,000.

These cases reflect a broader trend: wartime corruption is shifting into new spheres — primarily defence logistics and mobilisation.

Challenges and Future Outlook

While Ukraine has made progress (e.g., improving its Corruption Perceptions Index score to 36/100 in 2023, ranking 104th out of 180 countries), real challenges remain. Enforcement is improving, but systemic issues persist — especially in defence procurement and mobilisation procedures.

Further reforms are expected in 2025, particularly in:

• Criminal liability enhancement for wartime corruption;
• Digital registers of procurement and personnel to ensure accountability;
• Improved whistleblower protections to encourage reporting within the military sector.

Executive Summary

Corruption in wartime Ukraine has become more sophisticated, with new risks emerging in defence procurement and mobilisation. In response, Ukraine has adopted stronger anti-corruption legislation, restructured key institutions, and improved transparency mechanisms. Still, enforcement remains inconsistent, and further reforms — especially in the areas of criminal liability and procurement oversight — are urgently needed. For foreign businesses, understanding these legal dynamics is critical to mitigating compliance risks and building sustainable operations in Ukraine.