Criminalization and Anti-Corruption in Ukraine and Georgia

Alexandre KUKHIANIDZE

Nino KUKHIANIDZE

Abstract: This article compares the development and resilience of anti-corruption institutions in Ukraine and Georgia. Although both states inherited weak post-Soviet institutions, experienced major political transformations, and pursued European Union membership, their reform trajectories have diverged. Ukraine de­veloped a specialized anti-corruption architecture whose investigative, prosecuto­rial, preventive, and adjudicative functions are institutionally dispersed and partly protected by competitive appointments, civil-society oversight, and international conditionality. Georgia achieved a substantial reduction in petty corruption after the 2003 Rose Revolution, but retained centralized political control over law-en­forcement and judicial institutions; its later Anti-Corruption Bureau lacked inde­pendent investigative authority and remained vulnerable to executive influence. Using a qualitative comparative case-study design, the article examines legisla­tion, official assessments, institutional mandates, appointment procedures, and selected enforcement outcomes. It argues that EU conditionality can reinforce anti-corruption reform only when it interacts with domestic political commitment, autonomous institutions, and an active civil society. Formal institutional creation alone does not prevent political capture.

Keywords: Ukraine, Georgia, criminalization, corruption, reforms, democratiza­tion, authoritarianism.  

Introduction

Corruption is treated here not merely as individual bribery but as a mode of institutional capture through which public authority is subordi­nated to private, criminal, oligarchic, or partisan interests. “Criminaliza­tion” therefore refers to the penetra­tion of economic and state institu­tions by criminal networks and in­formal patronage, while “legal crimi­nalization” refers separately to the use of criminal law against desig­nated conduct or status. This distinc­tion is essential to the comparison: Georgia’s post-2003 reforms were highly effective against organized crime and petty corruption, yet did not establish durable safeguards against elite political control; Ukraine’s later model distributed anti-corruption functions across spe­cialized bodies whose autonomy has remained contested but compara­tively resilient.

This study examines why spe­cialized anti-corruption institutions developed greater operational auton­omy and resilience in Ukraine than in Georgia. It traces the post-Soviet criminalization of both states, com­pares the mandates and appointment safeguards of their anti-corruption bodies, and evaluates how EU condi­tionality interacted with domestic political incentives after candidate status was granted.

Key research questions:

1. How did post-Soviet criminali­zation and state capture develop in Ukraine and Georgia?
2. How did the institutional de­sign, appointment procedures, and enforcement powers of the two coun­tries’ anti-corruption systems differ?
3. Under what domestic political and institutional conditions did EU conditionality strengthen – or fail to strengthen – anti-corruption reform?

This study employs a qualitative comparative approach, utilizing a set of methods to analyze the evolution, legal mandates, and political trajecto­ries of anti-corruption bureaus in Ukraine and Georgia. The research focuses on two post-Soviet states that share a similar historical legacy in public administration, key milestones in democratic transformation (the 2003 Rose Revolution and the 2014 Euromaidan), and an aspiration for EU integration.

The study identifies independent and dependent variables and compar­ative operationalization: Ukraine ver­sus Georgia. Operationalized inde­pendent variables include legisla­tively enshrined mandates (criminal investigation powers versus adminis­trative oversight), independence guarantees (international selection commissions versus executive ap­pointments), and external conditions based on EU criteria (high direct conditionality – EU candidate status, seven recommendations, visa liber­alization, independent anti-corruption infrastructure versus high initial and evolving conditionality (radical anti-corruption reforms driven by EU and NATO integration plans, twelve EU candidate status criteria, de-oligarchization and institutional neu­trality). Operationalized dependent variables include institutional resili­ence (high structural autonomy against legislative rollbacks, civil society and international donor influ­ence versus restructuring-prone and portfolio shifts following changes in political dynamics); the capacity to enforce “grand corruption” (high formal output versus low formal out­put on top officials), and vulnerabil­ity to political capture or abolition (legislative attempts to alter selection rules, trim investigative powers, or subordinate prosecutors versus risk of political capture such as the ruling party’s capture of institutional ap­pointment mechanisms which makes bodies vulnerable to political influ­ence.

Data collection methods include an analysis of national legislation, court rulings, and official regulations establishing and governing anti-cor­ruption bodies; a review of official reports, assessments, and compliance findings prepared by international organizations and civil society groups; and the tracking of specific cases and operational outcomes, such as asset declaration audits and initi­ated investigations. Comparative analysis is used to contrast the legal frameworks and procedural auton­omy of the anti-corruption bureaus in Ukraine and Georgia, alongside a method of tracking pivotal events –such as the granting of EU candidate status to both states, and the halting of the European integration process by the ruling “Georgian Dream” party following the 2024 parliamen­tary elections.

Criminalization in Ukraine Following the Collapse of the USSR

The collapse of the Soviet Union in 1991 led not only to a profound crisis but also to a political, eco­nomic, and social transformation in Ukraine¹. On one hand, gaining inde­pendence opened up opportunities for democratization and economic re­forms; on the other hand, the disinte­gration of old state structures and so­cietal demoralization gave rise to a period of instability that fostered widespread criminalization. The weakening of state institutions, ab­sence of the culture and traditions of the rule of law, undemocratic proce­dures for privatizing state property, and economic hardships led to a surge in organized crime and corrup­tion, as well as the consolidation of oligarchic power².

Soviet-style governance structures collapsed rapidly, whereas establish­ing new democratic institutions, tran­sitioning to a market economy, re­forming the judiciary, and addressing widespread poverty alongside en­trenched crime and corruption re­quired significantly more time³. A legal vacuum and weak oversight enabled managers of state enterprises – in league with emerging financial-industrial and criminal groups – to exploit privatization to appropriate assets and capital; meanwhile, ram­pant corruption and moral decay within law enforcement agencies fa­cilitated the growth of organized crime. Consequently, disputes were frequently resolved through informal or criminal means⁴. Thus, privatiza­tion became a means of unfairly ac­quiring material and financial re­sources at minimal cost. Former So­viet and Party officials, as well as new entrepreneurs, engaged in finan­cial schemes and smuggling, while criminal groups helped them elimi­nate competitors, controlled racket­eering operations, or carried out con­tract killings. Violent clashes be­tween gangs became a feature of economic life in the 1990s, particu­larly in major cities⁵.

All of this led to a significant ex­pansion of the shadow economy and the formation of influential informal networks that utilized corruption, vi­olence, and patronage to enrich themselves illegally at the expense of the country’s majority population. Emerging non-governmental organi­zations and independent media out­lets did not yet possess the capacity to exercise effective civic oversight within Ukrainian society.

With the strengthening of new political, state, and civil democratic institutions by the early 2000s, there was a decline in violent crime; how­ever, criminal elements managed to integrate into legitimate business, becoming less visible yet remaining influential through corrupt ties to po­litical structures, via money launder­ing and other schemes. Despite the waning of violent organized crime after the 1990s, forms of corruption such as bribery, kickbacks, theft, em­bezzlement, fraud, and money laun­dering evolved into a systemic and more entrenched form of criminali­zation in Ukraine. Corruption linked organized crime with the authorities, the business sector, and even seg­ments of the population, facilitating the emergence and growing influence of oligarchic capital, which leveraged its political connections and eco­nomic power. This enabled oligarchs to control the media, influence elec­tions, and alter legislation to their own advantage⁶. Corruption and oli­garchic interests flourished even fur­ther after 2014, when Russia’s an­nexation of Crimea and the war it instigated in Ukraine’s Donetsk and Luhansk regions led to a sharp rise in illegal arms trafficking, smuggling, and other forms of criminal enter­prise⁷. According to an analysis pub­lished in the European journal eucrim (The European Law Forum: Preven­tion, Investigation, Prosecution), which is based on Transparency In­ternational’s Global Corruption Ba­rometer study, the proportion of the Ukrainian population reporting pay­ing a bribe to obtain basic govern­ment services increased from 37% in 2011 to 38% in 2017. The report concludes that, despite political changes, corrupt officials continue to use opaque schemes⁸. A comprehen­sive report published by the Centre for Eastern Studies (OSW) details that while older oligarchic factions were temporarily placed on the de­fensive, new political-business groups – explicitly described as “oli­garchic” – emerged around the new Ukrainian political leadership after 2014. The authors found that infor­mal patronage networks persisted because political power remained tied to the control of business assets⁹. “Ukraine has long been a hotspot in the global arms trade, a situation that has intensified since the beginning of Russia-backed conflict in the east in 2014”¹⁰. However, by this time, the geopolitical landscape shifted against Russian influence and domestic cor­rupt networks; the need to ensure na­tional security and the surge in civic engagement among the Ukrainian population fostered the strengthening of state institutions, a dramatic rise in national consciousness and patriot­ism, and the consolidation of Ukrainian society. The struggle for sovereignty and survival evolved into a fight against the two main adver­saries of Ukrainian statehood: Rus­sia’s aggressive policies and domes­tic corruption. Efforts to curb corrup­tion were undertaken following the 2004 Orange Revolution and the tragic events of the 2013-2014 Euromaidan; these included police reorganization, increased transpar­ency in public procurement, and nu­merous other reforms. However, the systematic implementation of anti-corruption reforms and the strength­ening of civil society became a na­tional priority for Ukraine following Russia’s full-scale invasion in 2022 and the country’s designation as an EU candidate.

Ukraine has been making slow but steady progress in combating cor­ruption – although corruption re­mains a critical challenge in its EU integration process. This trajectory is contextualized by Transparency In­ternational’s Corruption Perceptions Index (CPI), which measures percep­tions of public-sector corruption ra­ther than corruption itself:

Source: Transparency International’s CPI, https://www.transparency.org/en/cpi/2025/index/ukr

Criminalization in Georgia Following the Collapse of the USSR

Criminalization in Georgia repre­sents one of the most drastic institu­tional transformations in the post-Soviet space. Post-Soviet Georgian criminalization can be divided into three distinct phases:

• Criminal state capture and a cor­rupt system of public administra­tion (1991-2003): the spread of organized crime and the for­mation of systemic, institutional­ized corruption.
• State reforms to combat crime and corruption (following the 2003 Rose Revolution): radical anti-mafia legislation, sweeping police reform, and harsh penalties for crimes.
• Democratic transfer of power fol­lowing the 2012 parliamentary elections, the antidemocratic backsliding, and formation of the Georgian “mafia state”.

Following the 1991 Soviet col­lapse, Georgia experienced systemic state failure, civil wars, and seces­sionist armed conflicts in Abkhazia and South Ossetia. In this institu­tional vacuum, criminal networks – specifically the organized criminal subculture known as the “Thieves-in-Law” (Kanonieri Kurdebi) – cap­tured core state functions. They con­trolled the shadow economy, man­aged informal trade, smuggling, and commercial disputes, operating as parallel judicial authorities. Institu­tional corruption flourished; law en­forcement agencies and government institutions became deeply compro­mised by petty and elite corruption, relying heavily on informal bribery networks to maintain basic opera­tions.

Following the 2003 Rose Revolu­tion, the administration of President Mikheil Saakashvili instituted radical reforms designed to eradicate orga­nized crime and corruption, and re-establish state capacity¹¹. In 2005, Georgia amended its Criminal Code to introduce unprecedented legisla­tion specifically criminalizing mem­bership in organized crime groups or belonging to the status of a “Thieves-in-Law” (mafia bosses), regardless of whether a specific underlying crimi­nal act was proven. According to Ar­ticle 223 “Membership of the crimi­nal underworld; Thief in Law” of the Criminal Code of Georgia, member­ship in the criminal underworld shall be punished by imprisonment for a term of five to eight years, with or without a fine, and being a “Thief-in-Law” shall be punished by impris­onment for a term of seven to ten years, with or without a fine¹².

In the security sector, the gov­ernment fired thousands of traffic police officers in a single day, re­placing them with a modernized Patrol Police unit to disrupt street-level bribe extraction¹³. Soon, all other police structures were re­formed, and similar measures were taken in the Prosecutor’s office and in the judiciary.

Concerning any crime, the state adopted a zero-tolerance policy, leading to a massive spike in incar­ceration rates during the mid-to-late 2000s, making Georgia one of the most incarcerated nations per capita in Europe at the time. Eradicating street-level corruption required a combination of high salaries, new equipment, and strict central over­sight, as well as the criminalization of informal social networks. Radical eradication of organized crime and corruption caused authoritarian risks. Despite street crime and petty cor­ruption being drastically reduced, the central government’s unchecked ex­ecutive authority led to over-incar­ceration, human rights abuses within the penitentiary system, and concerns regarding elite corruption¹⁴.

Police reform was perceived as successful because efficiency was usually measured through declines in organized crime and corruption and increases in public trust. The Rose Revolution led to revolutionary me­thods of government rather than the rule of law. As a result, the old soviet tradition, when police serve the au­thorities instead of the law and citi­zens, was maintained, and “…technical modernization…” did not “…automatically produce demo­cratic policing,” with the police as an element of an authoritarian moderni­zation¹⁵.

Not only the police but the Prose­cutor’s Office and the Judiciary re­mained under the centralized control of the ruling United National Move­ment (UNM). Ultimately, the con­centration of presidential political power at the expense of the legisla­tive and judiciary caused a lack of democratic development and viola­tions of human rights, especially in prisons. By 2012, the need for a change of government was evident. A prison scandal involving the sexual abuse of male inmates – which broke roughly a month before the 2012 par­liamentary elections – served as the catalyst that secured victory for the new Georgian Dream (GD) party, founded by Bidzina Ivanishvili, a Russian oligarch of Georgian de­scent. Although later controversy surrounded the production, timing, and political use of some recordings, the footage exposed serious abuses within the penitentiary system and decisively affected public opinion before the election.

Following the transfer of power, Georgian Dream gradually consoli­dated influence over state institu­tions. Government rhetoric concern­ing a so-called “deep state” was used to justify personnel and institutional changes that critics described as par­tisan. Key positions across law-en­forcement, security, prosecutorial, and local-government bodies were increasingly filled by politically con­nected officials. The judiciary, which had previously been criticized for its alignment with the UNM govern­ment, proved vulnerable to influence by the succeeding administration as well. This continuity illustrates how institutions lacking structural inde­pendence can be repurposed by suc­cessive governing parties. Criminal proceedings against former President Mikheil Saakashvili and several lead­ing opposition figures have sub­sequently intensified domestic and international concerns about selective justice and democratic pluralism.

Anti-Corruption Reform in Ukraine after EU Candidate Status

Ukraine’s fight against corruption after receiving EU candidate status on June 23, 2022 can be understood as a shift from a largely domestic re­form agenda toward a European integration-driven system of anti-corruption conditionality. Candi­date status created stronger incentives and external monitoring for Ukraine to demonstrate that anti-corruption institutions, judicial independence, transparency, and enforcement were becoming durable features of demo­cratic governance. The European Council, which granted Ukraine the candidate status, linked further pro­gress toward EU membership to ful­fillment of the conditions identified by the European Commission. The EU framework therefore made the fight against corruption part of Ukraine’s broader rule-of-law and democratization process¹⁶.

A central feature of Ukraine’s post-candidate-status trajectory was the further consolidation, operation­alization, and protection of special­ized institutions established during the post-Euromaidan reform period:

• NABU – National Anti-Cor­ruption Bureau of Ukraine, which investigates high-level cor­ruption;
• SAPO – Specialized Anti-Corruption Prosecutor’s Office, which prosecutes corruption cases investigated by NABU;
• HACC – High Anti-Corruption Court, which adju­dicates major corruption cases;
• NACP – National Agency on Corruption Prevention, which focuses primarily on pre­vention, asset declarations, con­flicts of interest, political-finance oversight, and anti-corruption pol­icy.

These steps reduced the ability of political and traditional law enforce­ment structures to control investiga­tions involving powerful political or economic actors. The OECD de­scribed the newly created anti-cor­ruption organizations as among Ukraine’s strongest functioning pub­lic institutions and reports that their performance has improved over time¹⁷.

Especially important post-candi­date-status development was the ap­pointment of the new NABU director and head of SAPO through a com­petitive process involving interna­tional experts. The OECD considered these appointments significant be­cause international involvement helped reinforce transparency and merit-based selection¹⁸.

Before 2022, Ukraine’s anti-cor­ruption reforms were strongly influ­enced by the post-Maidan reform process; however, after candidate status, fighting corruption became directly connected with EU acces­sion negotiations and the rule-of-law requirements for membership.

The Ukrainian experience indi­cates that external conditionality must extend beyond the adoption of anti-corruption legislation to the in­dependent and effective application of that legislation. The central chal­lenge is to preserve institutions capa­ble of investigating ministers, judges, prosecutors, members of parliament, senior law-enforcement officials, and economically powerful actors with­out improper political interference.

Undisclosed assets and finances can undermine public confidence in democratic institutions and electoral competition. This is why another im­portant step was the restoration and strengthening of Ukraine’s electronic asset-declaration system, which re­quires public officials to disclose their assets and financial interests, and allows anti-corruption organiza­tions to identify unexplained wealth and potential conflicts of interest. According to the OECD’s 2025 as­sessment, Ukraine reopened its comprehensive and digitized asset-declaration system and strengthened mechanisms for monitoring declara­tions. The OECD’s 2025 assessment identified strengthened whistleblower protection as one of Ukraine’s sig­nificant achievements. Governmental employees frequently possess infor­mation that is useful for external in­vestigators; therefore, protecting them strengthens institutional ac­countability. This is important be­cause productive anti-corruption pol­icy cannot depend only on prose­cutors and investigators¹⁹.

In a democratic society, political power does not automatically provide immunity from criminal accountabil­ity. There have also been significant efforts aimed at increasing enforce­ment against high-level corruption. NABU and SAPO initiated hun­dreds of new criminal cases, in­volving the defense, energy, law-en­forcement, and oversight sectors, in­cluding former MPs, ministers, tax and customs officials, and other sen­ior actors²⁰.

Despite all efforts, judicial reform and independence remain one of Ukraine’s most difficult anti-cor­ruption problems and major weak­nesses. The OECD’s 2025 monitor­ing rated Ukraine’s performance in judicial independence at 57.4/100, unchanged from its 2023 baseline. By comparison, anti-corruption in­stitutions received a substantially stronger score of 92.7/100 in 2025²¹. New anti-corruption institutions appeared more efficient than the older judicial system in Ukraine.

Events in 2025 demonstrated that reform is neither linear nor irreversi­ble. Legislative measures supported by the presidential majority threat­ened the independence of NABU and SAPO, prompting strong protests from civil society and international partners. Subsequent legislation re­stored key guarantees of their inde­pendence. The episode revealed con­tinuing risks of political interference, but also demonstrated the resilience produced by domestic mobilization, institutional pluralism, and interna­tional scrutiny. It therefore compli­cates any characterization of Ukraine as an unqualified anti-corruption suc­cess.

Ukraine is in a particularly com­plicated situation because of the Rus­sian military invasion, and wartime conditions make transparency and accountability more difficult. This is why anti-corruption policy has be­come increasingly connected to de­fense procurement, reconstruction, public procurement, and manage­ment of international financial as­sistance. The OECD’s assessment indicates that Ukraine has made im­portant progress but continues to face risks in public procurement, en­forcement, asset recovery, and judi­cial independence²².

By 2026, the overall assessment of Ukraine’s anti-corruption efforts suggests a significant improvement. The OECD’s 2025 monitoring gave Ukraine particularly strong results in anti-corruption policy, whistleblower protection, and anti-corruption insti­tutions. Its anti-corruption-policy score increased from 53.0 in 2023 to 91.9 in 2025, while the score for spe­cialized anti-corruption institutions rose from 78.6 to 92.7. Enforcement of corruption offences also increased, though only from 34.2 to 39.1²³.

The key OECD publications that directly assess Ukraine’s national anti-corruption framework are the OECD Integrity and Anti-Corruption Review of Ukraine (2025) and its accompanying country profile in the OECD Anti-Corruption and Integrity Outlook (2026). The OECD explic­itly states that Ukraine has success­fully built and maintained an anti-corruption framework that aligns closely with international standards and its EU integration goals²⁴.

Anti-Corruption Reform in Georgia after EU Candidate Status

Georgia’s fight against corruption after receiving EU candidate status is more complicated than Ukraine’s experience. Georgia had already de­veloped a relatively sophisticated anti-corruption system before candi­date status, particularly in combating petty and administrative corruption. But this system was created before Georgian Dream came to power in 2012. However, by the time Georgia received EU candidate status, the main problems remained high-level corruption, political influence on law enforcement, conflicts of interest, judicial independence, and the auton­omy of anti-corruption bodies. Ordi­nary citizens of Georgia no longer felt the direct pressure of corrupt po­lice officers and officials, and the ruling Georgian Dream party saw no political incentive to dismantle this system or spark public discontent. The ruling party accepted the system unchanged, and during the entire pe­riod of its rule did not take any sig­nificant steps to increase the effi­ciency of combating high-level cor­ruption, except for some actions to simulate this fight in the first year after Georgia was granted EU candi­date status.

Georgia applied for European Union membership on March 3, 2022 following the outbreak of war in Ukraine, and on December 14, 2023, the European Council granted Georgia  candidate status, on the un­derstanding that the relevant reforms associated with the nine steps of the Commission’s recommendations of 8 November 2023 were imple­mented²⁵. The Commission’s rec­ommendations (November 8, 2023) required Georgia to: Ensure a free, fair and competitive electoral pro­cess, notably in 2024; Implement a judicial reform, including reform of the High Council of Justice and the Prosecutor’s Office; Further address the effectiveness and ensure the in­stitutional independence and impar­tiality of the Anti-Corruption Bureau, the Special Investigative Service and the Personal Data Protection Service; Establish a strong track record in in­vestigating corruption and organised crime cases; Improve the protection of human rights, ensuring freedom of assembly and expression; Consult and engage with civil society, allow­ing for their meaningful involvement in legislative and policymaking pro­cesses and ensure they can operate freely²⁶.The Georgian Dream Gov­ernment not only failed to implement the above recommendations, but also suspended the very process of Georgia’s admission to the EU, soon after the parliamentary elections in Georgia of October, 2024. This deci­sion caused a great wave of indigna­tion in Georgian society, especially among young people, and led to mas­sive and prolonged meetings, demon­strations, and clashes with police and state security forces throughout Georgia. The result of these clashes was a brutal campaign launched by the Georgian Dream to persecute pro­testers, mass arrests, torture, sub­stantial financial penalties, and the detention of political opponents, pri­marily among civil activists and stu­dent youth. Georgian Dream initiated the adoption of a number of anti-democratic laws aimed at destroying civil society and the political opposi­tion, and also began reforms aimed at establishing full party control over the entire education system in the country, primarily in universities²⁷. This kind of policy is accompanied by disinformation in the style of Rus­sian propaganda and ideological at­tacks on the EU and diplomatic rep­resentations of Western countries in Georgia to undermine confidence in Western values ​​and the very idea of ​​Georgia’s membership in the EU.

An important institutional devel­opment preceding candidate status was that the Parliament of Georgia adopted legislation establishing the Anti-Corruption Bureau (ACB) in November 2022. The ACB mandate included coordinating anti-corruption policy, monitoring implementation, and developing recommendations. The EU welcomed this establishment as significant, but the key question was whether the institution could op­erate independently of political influ­ence. The problem was that the Prime Minister of Georgia appointed the ACB Director. This decision by the ruling Georgian Dream party ignored demands of the parliamentary oppo­sition to appoint the Director based on parliamentary consensus. As a result, the ACB of Georgia aligned its actions with the ruling party. In September 2024, one month before the parliamentary election of 2024, the ACB issued decisions against the leading civil society organizations, “Transparency International – Georgia” (TIG) and “Choose Europe” which prevented them from registering as observers of the 2024 elections, monitoring the electoral campaign, and other activities relat­ing to the electoral process²⁸. The decision was so odious, and the civil society protest so strong, that the government cancelled it soon. An­other case was the ACB’s attempt to check asset declarations of three hundred top politicians and govern­ment officials of Georgia, including judges. The four top judges who had earlier been sanctioned by the US government because of corruption applied to the court against the ACB, demanding to investigate why they were included in the list and putting under question the qualifications of the commission members who se­lected and included them in the list. As a result, the process was effec­tively blocked, and all four judges successfully avoided verification of their asset declarations. On June 12, 2025, Tbilisi City Court granted the Anti-Corruption Bureau the right to demand from five civil society or­ganizations vast amounts of pro­grammatic, administrative, financial and personal information, including on all their contractors and individual beneficiaries, from 1 January 2024 to 10 June 2025. The order invokes the Law on Grants, the Law on Political Associations of Citizens and the Law on Combating Corruption, all re­cently amended by the ruling Geor­gian Dream party in its campaign aimed at curtailing the rights to free­dom of association and expression and other human rights. The ruling party Georgian Dream weaponized the country’s justice system and the Anti-Corruption Bureau to suppress human rights activities and civil soci­ety organizations²⁹.

In 2025, the parliamentary Speak­er announced the abolition of the ACB, stating that the bureau’s func­tions will be transferred to the State Audit Office by 2 March 2026. ‘As a result of consultations with the gov­ernment, a common view was formed that this function better fits the State Audit Office within the con­stitutional framework of public gov­ernance, as a higher and more inde­pendent consti­tutional body’, he said³⁰.

The ACB’s appointment struc­ture, limited mandate, and record generated substantial concerns about its political dependence and its ca­pacity to investigate high-level cor­ruption. The Georgian case demon­strates that institutional creation does not necessarily produce institutional independence, impartiality, or effec­tive enforcement

.

Source: Transparency International’s CPI, https://www.transparency.org/en/cpi/2025/index/geo

The European Commission’s 2025 assessment concluded that Georgia’s democratic backsliding had become so serious that the coun­try was effectively a “candidate country in name only”. Anti-corrup­tion reform became increasingly in­tertwined with the deterioration of democratic checks and balances³¹.

Conclusions

In the 1990s, Ukraine and Georgia underwent similar processes of criminalization; however, in the subsequent fight against corruption, they chose two distinct approaches and anti-corruption models for insti­tutional reform.

Amidst a gradual improvement in the effectiveness of anti-corruption efforts, Ukraine has continued to de­velop democratic governance princi­ples and strengthen civil society and anti-corruption bodies as part of its EU integration process. Despite Rus­sia’s horrific aggression against it, Ukraine is successfully advancing along the path of European integra­tion and the fight against corruption, particularly at the highest levels.

Ukraine’s experience demon­strates that anti-corruption reform is simultaneously a rule-of-law reform and a democratization process. The post-2022 experience illustrates a strong relationship between EU can­didate status, strengthening of anti-corruption institutions, increased in­vestigative, prosecutorial, and judi­cial independence and accountability of political elites, and finally, con­solidation of democratic institutions.

Following the post-Euromaidan reform process, Ukraine established a new, specialized anti-corruption in­stitutional framework: the National Anti-Corruption Bureau to conduct pre-trial investigations, the Special­ized Anti-Corruption Prosecutor’s Office to handle prosecutions, and the High Anti-Corruption Court to adjudicate cases. Bolstered by West­ern assistance and requirements linked to EU accession, this institu­tional system has demonstrated sub­stantial resilience and improved per­formance, despite the war with Rus­sia.

A contrasting trajectory is evident in Georgia. The primary shortcoming in Georgia’s anti-corruption efforts in 2003-2012 was not a failure to im­plement radical anti-crime and anti-corruption reforms, but rather the ex­cessive centralization of presidential power and the retention of political control over the entire law enforce­ment apparatus, including the judici­ary. Consequently, reforms were not synchronized with democratization processes and failed to safeguard human rights – particularly political rights and the rights of prisoners. The revolution ushered in revolutionary methods of governance rather than the rule of law. For this reason, the ruling UNM was defeated in the 2012 parliamentary elections. The opposition GD, led by Russian oli­garch Bidzina Ivanishvili, came to power, followed by a gradual yet ac­celerating democratic backslide. Anti-corruption efforts remained con­fined to the grassroots level, leaving political and elite corruption un­touched. By 2025, corruption per­ception indicators had fallen below 2012 levels, demonstrating that Georgia’s greatest success in com­bating corruption occurred between 2004 and 2012, whereas the period from 2012 to 2025 has been marked by stagnation and even regression in this struggle.

The Anti-Corruption Bureau, es­tablished in late 2022 to meet condi­tions for EU candidate status, was not granted the authority to conduct in­dependent pre-trial criminal investi­gations; instead, it became dependent on the ruling party’s political will and an instrument for exerting pressure on civil society. However, after “Georgian Dream” unilaterally halted the European integration process and effectively abandoned Western sup­port, the Georgian parliament de­cided to abolish the agency and trans­fer its functions to the State Audit Office. The dismantling of Georgia’s Anti-Corruption Bureau –- a move that sharply contradicts the condi­tions for EU integration – further ev­idences Georgian Dream’s aban­donment of the fight against high-level corruption, and, at the same time, the use of the low-level corrup­tion control mechanisms inherited from the UNM.

Georgia’s democratic and rule-of-law deterioration has coincided with the weakening of external reform in­centives and persistent concerns about elite corruption. The compari­son suggests that EU conditionality can reinforce democratic and anti-corruption institutions when it is sup­ported by domestic political com­mitment, institutional autonomy, and civil-society oversight. When gov­erning elites reject or evade that con­ditionality, however, formal compli­ance may give way to political cap­ture and institutional dismantling.

Notes

• Kuzio, Ukraine: State and Nation Building, Routledge, London, 1998.
• Kerstin, The Capture of the State by Organized Crime in Ukraine. Or­ganised Crime in Europe, Springer, 2004, pp. 271–298.
• Aslund, How Ukraine Became a Market Economy and Democracy, Peterson Institute for International Economics, Washington D.C., 2009.
• Volkov, Violent Entrepreneurs: The Use of Force in the Making of Russian and Post-Soviet Capitalism, Cornell University Press, 2002.
• Kerstin, op.cit.
• Rosaria, The Rise of the Ukrainian Oligarchs, The Soviet and Post-Soviet Review, 30, no. 3, 2003, pp. 293-323.
• Lucan, Pluralism by Default: Weak States and the Rise of Competitive Authoritarianism, Johns Hopkins University Press, 2015.
• Kos, War and Corruption in Ukraine, 2022, Vol. 17(2), eucrim, pp. 152–157. DOI: https://doi.org/ 10.30709/eucrim-2022-007.
• Kononczuk, Keystone of the system: Old and New Oligarchs in Ukraine. Centre for Eastern Studies. Number 59, Warsaw, August 2016, https://www.osw.waw.pl/sites/default/files/pw_59_ang_keystone_system_net_0.pdf#:~:text=1.%20The%20’old’%20oligarchs%20(temporarily)%20on%20the,the%20key%20mechanisms%20safeguarding%20the%20specifically%20Ukrainian.
• Ukraine Sees Jump In Illegal Weapons Sales. Organized Crime and Corruption Reporting Project (OCCRP) (October 23, 2018). https://www.occrp.org/en/news/ukraine-sees-jump-in-illegal-weapons-sales
• O’Shea, Democratic police reform, security sector reform, anti-corruption and spoilers: lessons from Georgia, Conflict, Security & Development, 22(5), 2022, pp. 387-409.
• Criminal Code of Georgia, https://matsne.gov.ge/en/document/download/16426/157/en/pdf.
• Lili di Puppo, Police reform in Georgia. Cracks in an anti-corruption success story. U4 Anticorruption Resource Center, 2010, https://cdn.sanity.io/files/1f1-lcoov/production/bd4b26c6f3ff367ba87e3fe28169cdcfa9c4f249.pdf
• O’Shea, op.cit.
• Meladze and T. Gamkrelidze, The Fatal Flaws in Georgia’s National Police Modernization. Just Security, April 22, 2026, https://www.justsecurity.org/136827/georgia-national-police-modernizat-ion-flaws/
• European Council, Conclusions on Ukraine, the membership applications of Ukraine, the Republic of Moldova and Georgia, Western Balkans and external relations. Ukraine, Council of the EU, 23 June 2022, https://www.consilium.europa.eu/en/press/press-releases/2022/06/23/ eur-opean-council-conclusions-on-ukrai-ne-the-membership-applications-of-ukraine-the-republic-of-moldova-an-d-georgia-western-balkans-and-external-relations-23-june-2022/pdf.
• OECD, OECD Integrity and Anti-Corruption Review of Ukraine, OECD Public Governance Reviews, OECD Publishing, Paris, 2025, https://doi.org/10.1; OECD Anti-Corruption and Integrity Outlook 2026: Harnessing the Integrity Advantage, OECD Publishing, Paris, March 24, 2006, https://doi.org/ 10.1787/16708b78-en.787/7dbe965b-en.
• Idem, Review of Anti-Corruption Reforms in Ukraine under the Fifth Round of Monitoring: The Istanbul Anti-Corruption Action Plan, OECD Publishing, Paris, 2024, https://doi.org/1787/9e03ebb6-en.
• Idem, Ukraine Fifth Round of Anti-Corruption Monitoring Follow-Up Report. The Istanbul Anti-Corruption Action Plan. Revised version, September 2025. https://www.oecd.org/content/dam/oecd/en/publications/reports/2025/09/ukraine-fifth-round-of-anti-corruption-monitoring-follow-up-report_218cb aa8/097f0a38-en.pdf.
• Idem, OECD Integrity and Anti-Corruption Review of Ukraine, cit.
• Idem, Ukraine Fifth Round of Anti-Corruption Monitoring Follow-Up Report. The Istanbul Anti-Corruption Action Plan, cit.
• See: OECD Integrity and Anti‑Corruption Review of Ukraine. Organisation for Economic Co-operation and Development, May 6, 2025, https://www.oecd.org/en/pub-lications/oecd-integrity-and-anti-corr-uption-review-of-ukraine_7dbe965b-en.html; Anti‑Corruption and Integrity Outlook 2026: Ukraine. Organisation for Economic Co-operation and Development (OECD), May 7, 2026, https://www.oecd.org/ en/publications/anti-corruption-and-integrity-outlook-2026_0c8910f8-en/ukraine_3b2dc8e9-en.html.
• European Commission, Membership status: candidate country. Enlargement and Eastern Neighbourhood, 2024, https://enlargement.ec.europa.eu/countries/georgia_en )
• European Commission, Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions. Communication on EU, Enlargement Policy, Brussels, November 8, 2023, https://enlargement.ec.europa.eu/document/download/cc71d42b-6c07-4d-eb-9069-5ca2082d166d_en?filena-me=COM_2023_690%20Communication%20on%20EU%20Enlargement%20Policy_and_Annex.pdf ).
• Chanturia, Georgia’s University Reform Is Not a Neutral Initiative. It’s a Political Act. Civil Georgia, January 28, 2026, https://civil.ge/archives/718654
• ACB of Georgia, Decision No. 03/029-24 of the Director, September 24, 2024, regarding the restriction of the powers of non-governmental organizations in the 2024 parli-am-entary electios, https://acb.gov.ge/ files/biuro/%E1%83%A1%E1%83%98%E1%83%90%E1%83%AE%E1%83%9A%E1%83%94%E1%83%94%E1%83%91%E1%83%98/antikorufciuli%20biuros%20ufrosis%20gadawyvetileba_029.pdf ).
• Amnesty International, Georgia: Court order on five independent NGOs a blow to freedom of association, London, June 19, 2025, https://www.amnesty.org/en/latest/news/2025/06/georgia-court-order-on-five-independent-ngos-a-blow-to-freedom-of-association/
• Bardouka, „Georgia confirms dissolution of Anti-Corruption Bureau”, OC Media, November 17, 2025, https://oc-media.org/georgia-confirms-dissolution-of-anti-corrupt-ion-bureau/.
• European Commission, Enlargement Package shows progress towards EU membership for key enlargement partners. Directorate-General for Enlargement and Eastern Neighbourhood, November 4, 2025, https://enlargement.ec.europa.eu/news/2025-enlargement-package-shows-progress-towards-eu-membership-k-ey-enlargement-partners-2025-11-04_en )

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KUZIO, T., Ukraine: State and Nation Building, Routledge, London, 1998.

KERSTIN, Z., The Capture of the State by Organized Crime in Ukraine. Organised Crime in Europe, Springer, 2004, pp. 271-298.

ASLUND, A., How Ukraine Became a Market Economy and Democracy, Peterson Institute for International Economics, Washington D.C., 2009.

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Articles and studies

O’SHEA, L., „Democratic police reform, security sector reform, anti-corruption and spoilers: lessons from Georgia”, Conflict, Security & Development, 22(5), 2022, pp.387-409.

ROSARIA, P., „The Rise of the Ukrainian Oligarchs”, The Soviet and Post-Soviet Review, 30, no. 3, 2003, pp. 293-323.

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BARDOUKA, Y., “Georgia confirms dissolution of Anti-Corruption Bureau”, OC Media, November 17, 2025, https://oc-media.org/georgia-confirms-dissolution-of-anti-corruption-bureau/.

CHANTURIA, R., “Georgia’s University Reform Is Not a Neutral Initiative. It’s a Political Act”, Civil Georgia, January 28, 2026, https://civil.ge/arch-ives/ 718654

Criminal Code of Georgia, https://matsne.gov.ge/en/document/download/16426/157/en/pdf.

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di PUPPO, L., “Police reform in Georgia. Cracks in an anti-corruption success story”, U4 Anticorruption Resource Center, 2010, https://cdn.sanity.io/ files/1f1lcoov/production/bd4b26c6f3ff367ba87e3fe28169cdcfa9c4f249.pdf

MELADZE, G. and GAMKRELIDZE, T., The Fatal Flaws in Georgia’s National Police Modernization. Just Security, April 22, 2026, https://www.justsecurity.org/136827/georgia-national-police-modernization-flaws/

Documents

ACB of Georgia, Decision No. 03/029-24 of the Director, dated September 24, 2024, regarding the restriction of the powers of non-governmental organizations in the 2024 parliamentary elections, https://acb.gov.ge/files/biuro/%E1%83%A1%E1%83%98%E1%83%90%E1%83%AE%E1%83%9A%E1%83%94%E1%83%94%E1%83%91%E1%83%98/antikorufciuli%20biuros%20ufrosis%20gadawyvetileba_029.pdf.

Amnesty International, Georgia: Court order on five independent NGOs a blow to freedom of association, London, June 19, 2025,  https://www.amnesty.org/en/latest/news/2025/06/georgia-court-order-on-five-independent-ngos-a-blow-to-freedom-of-association/

European Council, Conclusions on Ukraine, the membership applications of Ukraine, the Republic of Moldova and Georgia, Western Balkans and external relations. II.Ukraine. Council of the EU, 23 June 2022, https://www.consilium.europa.eu/en/press/press-releases/2022/06/23/european-council-conclusions-on-ukraine-the-membership-applications-of-ukraine-the-republic-of-moldova-and-georgia-western-balkans-and-external-relations-23-june-2022/pdf.

European Commission, Georgia. Membership status: candidate country. Enlargement and Eastern Neighbourhood, 2024, https://enlargement.ec.europa.eu/countries/georgia_en

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Idem, Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions. Communication on EU Enlargement Policy, Brussels, November 8, 2023. https://enlargement.ec.europa.eu/document/download/cc71d42b-6c07-4deb-9069-5ca2082d166d_en?filename= COM_2023_690%20Communication%20on%20EU%20Enlargement%20Policy_and_Annex.pdf

OECD, Integrity and Anti-Corruption Review of Ukraine, OECD Public Governance Reviews, OECD Publishing, Paris, May 6, 2025, https://doi.org/10.1787/7dbe965b-en.

OECD, Anti‑Corruption and Integrity Outlook 2026: Ukraine. Organisation for Economic Co-operation and Development (OECD), May 7, 2026, https://www.oecd.org/en/publications/anti-corruption-and-integrity-outlook-2026_0c8910f8-en/ukraine_3b2dc8e9-en.html

OECD, Anti-Corruption and Integrity Outlook 2026: Harnessing the Integrity Advantage, OECD Publishing, Paris, March 24, 2006, https://doi.org/10.1787/16708b78-en

IDEM, Review of Anti-Corruption Reforms in Ukraine under the Fifth Round of Monitoring: The Istanbul Anti-Corruption Action Plan, OECD Publishing, Paris, 2024, https://doi.org/10.1787/9e03ebb6-en.

IDEM, Ukraine Fifth Round of Anticorruption Monitoring Follow-Up Report. The Istanbul Anti-Corruption Action Plan. Revised version, Sep-tember 2025. https://www.oecd.org/ content/dam/oecd/en/publications/reports/2025/09/ukraine-fifth-round-of-anti-corruption-monitoring-follow-up-report_218cb-aa8/097f0a38-en.pdf

IDEM, Anti-Corruption and Integrity Outlook 2026 Harnessing the Integrity Advantage, 2026,  https://www.oecd.org/ content/dam/oecd/en/publications/reports/2026/03/anti-corruption-and-in-te-grity-outlook-2026-country-note-s_b1-df9263/ukraine_904c61de/3b2dc8e9-en.pdf

Ukraine Sees Jump in Illegal Weapons Sales. Organized Crime and Corruption Reporting Project (OCCRP), October 23, 2018, https://www.occrp.org/en/news/ ukraine-sees-jump-in-illegal-weapons-sales