3.3. Criminal liability

problems 4

expected strategic
results 22

measures 75

Progress in the implementation of measures as of 18.02.2026

All measures of the SACP

measures, the implementation of which as of 31.12.2025

is about to begin to be completed

32 11 20 12

Implemented Partially implemented Not implemented Not started

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the diagrams above show the share (%) of completed measures (fully and partially)

Problems

% of measures implemented — % of measures partially implemented — evaluation of achievement of ESR, % —

3.3.1. Certain provisions of criminal law relating to criminal liability for corruption-related criminal offenses contradict international standards in this field, are not coordinated with each other and with the provisions of the criminal procedure legislation and the Law of Ukraine On Prevention of Corruption. As a result, in a significant number of cases, perpetrators of corruption-related criminal offenses are relieved of criminal liability and/or punishment

3.3.2. Poor efficiency and quality of pretrial investigation of corruption and corruption-related criminal offenses (a significant number of such proceedings last for years) is due to excessive complexity of certain procedural formalities

3.3.3. The legislation governing the activity of the ARMA contains numerous gaps and corruption risks. Low effectiveness of the processes of transferring assets to ARMA for management to preserve their economic value, as well as the processes of combating and preventing money laundering

<ul class="tooltip_ul"><div class="tooltip_border_bottom">Number of measures: 1</div><li><div class="dot dot_status_1"></div><div class="tooltip_text">Not started: <span>1 | 100%</span></div></li><div class="tooltip_border_bottom"> </div><li><div class="tooltip_text">Оцінка досягнення ОСР: 0.0% (рівень - <span class='achivements-text-color'><span class="bg-low">low</span></span>)</div></li></ul>'>

ESR 3.3.3.10.

ESR 3.3.3.11.

66.7%

3.3.4. The overall progress of court hearings involving corruption and corruption-related criminal offenses is slow. There is no established practice of consideration of criminal proceedings in this category. There are numerous cases of abuse of procedural rights by litigants