Ukraine’s 5th audit by the Organisation for Economic Co-operation and Development (OECD) reveals steady progress in enhancing whistleblower protection efforts. This audit is a sub-regional peer-review that takes place under the Istanbul Anti-Corruption Action Plan (IAP), in which Ukraine is one of the 10 participating countries.
Since 2023, some of Ukraine’s notable achievements include securing the independence of the Specialized Anti-Corruption Prosecutor’s Office (SAPO), strengthening whistleblower protection, and reforming corporate liability frameworks to accede to the OECD Anti-Bribery Convention.
(Infographic. Overview of Ukraine’s anti-corruption performance. Ukraine’s Fifth Round of Anti-Corruption Monitoring Follow-up Report, p. 13).
This restoration of power to Ukraine’s anti-corruption agencies follows the Ukrainian parliament’s decision to grant the SAPO independent oversight of the National Anti-Corruption Bureau (NABU) investigations. Before the decision, this power resided with the Prosecutor General (PG). This highly political position that has historically been prone to corruption.
Viktor Shokin, the PG of Ukraine from 2015 to 2016, was fired over speculation of corruption. His successor until 2018, Yuriy Lutsenko, was caught in a backchannel campaign with Rudy Giuliani, one of U.S. President Trump’s previous attorneys. Similarly, Iryna Venediktova served as the PG from 2020 to July 2022, until she was removed due to alleged collaborations with Russian officials. Andriy Kistin, the PG from 2022 to 2024, also resigned during a corruption scandal.
To ensure transparency moving forward, the Security Service of Ukraine will conduct background checks on NABU and SAPO employees. Additionally, using an approved methodology by the Security Service of Ukraine, the staff of these agencies will undergo internal polygraph testing every two years.
Ukraine’s efforts also involved the creation of a Unified Whistleblower Reporting Portal on September 6, 2023, which allowed users to efficiently submit a corruption report and easily monitor its review status. Acting as a central electronic platform available 24/7 for filing reports, including anonymously, the OECD reviewed the portal as a major achievement. However, by the end of 2024, the OECD audit found that fewer than 8,000 institutions were linked to the portal, falling well short of the original goal. In addition to the efficacy concerns, there is now a lack of systematic enforcement of rights, including protection from reprisal. Confidentiality violations have occurred without remedial action, making whistleblowers more vulnerable to potential retaliation.
The success of these efforts is demonstrated by the first Ukrainian whistleblower award of UAH 1.68 million, which was paid in 2024 by the National Agency on Corruption Prevention (NACP). In 2019, the idea of compensating whistleblowers was introduced in the Law of Ukraine “On Prevention of Corruption.” According to Article 53-7 of the Law, with a maximum compensation of $500,000 (UAH 21,023,380), a whistleblower can collect 10% of the monetary value of the case. Previously, awards were not possible due to a lack of court decision enforcement and regulated payment procedures; however, a state budget now provides the funds.
Per the OECD follow-up report, “over 61% of measures planned for 2024 have been fully implemented, with a significant number of measures to be fully implemented before the end of the cycle at the end of 2025 ” (14). Accordingly, Ukraine ranks at 91.9% for its anti-corruption policy, with a performance level baseline of 53%.
Despite imperfection, if other countries had even a shred of Ukraine’s initiative and receptive feedback to the OECD’s suggestions, anti-corruption efforts would thrive worldwide.