1. What is the current legal landscape for Bribery & Corruption in your jurisdiction?

Croatia has a broadly developed anti-bribery and anti-corruption framework, primarily based on criminal law, specialised prosecutorial institutions and a national preventive anti-corruption strategy. The main legislative instruments are the Criminal Code (Kazneni zakon, Official Gazette “Narodne novine” Nos. 125/2011, 144/2012, 56/2015, 61/2015, 101/2017, 118/2018, 126/2019, 84/2021, 114/2022, 114/2023, 36/2024 and 136/2025), the Criminal Procedure Act (Zakon o kaznenom postupku, Official Gazette Nos. 152/2008, 76/2009, 80/2011, 121/2011, 91/2012, 143/2012, 56/2013, 145/2013, 152/2014, 70/2017, 126/2019, 130/2020 and 13/2026), the Act on the Office for the Suppression of Corruption and Organised Crime (Zakon o Uredu za suzbijanje korupcije i organiziranog kriminaliteta, Official Gazette Nos. 76/2009, 116/2010, 145/2010, 57/2011, 136/2012, 148/2013, 70/2017 and 136/2025) and the Act on the Liability of Legal Persons for Criminal Offences (Zakon o odgovornosti pravnih osoba za kaznena djela, Official Gazette Nos. 151/2003,
110/2007, 45/2011, 143/2012, 114/2022 and 114/2023). The current strategic framework is also shaped by the Anti-Corruption Strategy for 2021–2030 (Strategija sprječavanja korupcije za razdoblje od 2021. do 2030.
godine, Official Gazette No. 120/2021).

The Croatian Criminal Code criminalises a wide range of corruption-related conduct. The core bribery and corruption offences include receiving and giving bribes in bankruptcy proceedings under Article 251, receiving bribes in business transactions under Article 252, giving bribes in business transactions under Article 253, abuse in public procurement procedures under Article 254, money laundering under Article 265, abuse of office and authority under Article 291, unlawful favouritism under Article 292, receiving bribes under Article 293, giving bribes under Article 294, trading in influence under Article 295, giving bribes for trading in influence under Article 296, and bribery of representatives under Article 339. These offences cover both public-sector and private-sector bribery, as well as related conduct in public procurement, bankruptcy, public office, commercial dealings and political representation.

A key feature of the Croatian system is the role of USKOK, the specialised State Attorney’s Office for corruption and organised crime. USKOK has nationwide jurisdiction and is competent for the most relevant corruption offences, including receiving and giving bribes, trading in influence, bribery in commercial transactions, abuse of office by public officials, unlawful favouritism and bribery of representatives. Its institutional framework is complemented by specialised court departments and the police anti-corruption unit, PNUSKOK, forming the so-called “USKOK vertical”.

In addition to national enforcement by USKOK, the European Public Prosecutor’s Office (EPPO) has become an increasingly important actor in Croatian bribery and corruption matters where the financial interests of the European Union are affected. The EPPO has been operational since 1 June 2021 and is competent to investigate, prosecute and bring to judgment offences affecting the EU budget, including fraud, corruption, money laundering linked to EU-fraud proceeds and serious cross-border VAT fraud. In Croatia, this is particularly relevant in cases involving EU-funded projects, public procurement, agricultural subsidies, cohesion funds and other EU financial instruments. The EPPO exercises prosecutorial functions before the competent Croatian courts through European Delegated Prosecutors, while cooperating with Croatian police, tax and other national authorities. Its role has become especially visible in investigations concerning suspected manipulation of public procurement procedures, abuse of office, bribery and subsidy fraud involving EU funds.

Corporate criminal liability is also an important part of the landscape. Under the Act on the Liability of Legal Persons for Criminal Offences, legal persons may be held liable for criminal offences committed by responsible persons if the offence breaches a duty of the legal person or if the legal person obtained, or was intended to obtain, a benefit. The Act also applies to foreign legal persons recognised as legal persons under Croatian law. Sanctions include fines, dissolution of the legal person, security measures, confiscation of proceeds, confiscation of objects and publication of the judgment. Fines may reach up to 10% of the legal person’s total annual revenue where statutory fines would not achieve the purpose of punishment.

Enforcement is supported by extensive procedural powers. In cases falling within USKOK’s jurisdiction, the law provides mechanisms for special evidentiary measures, financial investigations, access to bank account information, temporary freezing measures and securing confiscation of proceeds. The USKOK Act specifically provides for financial investigations aimed at identifying the value and location of criminal proceeds and securing their confiscation.

The preventive framework is set out in the Anti-Corruption Strategy for 2021–2030. The Strategy recognises that Croatian law does not contain a single general statutory definition of corruption, but refers to the commonly used concept of corruption as the abuse of power, position or authority for private gain. It also notes that corruption is broader than criminal-law offences and requires a preventive framework involving public authorities, the business community, civil society, the media and citizens.

Current policy priorities include strengthening the institutional and normative framework, improving transparency and openness of public authorities, enhancing integrity systems and conflict-of-interest rules, strengthening anti-corruption safeguards in public procurement, and raising public awareness of the harmful effects of corruption and the need to report irregularities. Public procurement is treated as one of the most corruptionsensitive areas, particularly due to risks in planning, preparation, selection of bids, simple procurement and potential favouritism.

In practice, the enforcement environment remains active, especially in cases involving public officials, public procurement, local and regional government, healthcare, state-owned and municipally owned companies, EUfunded projects and financial investigations. At the same time, the policy documents recognise continuing challenges, including the need to strengthen integrity at the highest executive and legislative levels, improve conflict-of-interest and lobbying regulation, reinforce oversight in public procurement, and strengthen corporate compliance mechanisms in state-owned and locally owned companies.

Overall, Croatia may be described as having a mature statutory anti-corruption framework, specialised enforcement institutions and broad corporate liability rules. However, the practical effectiveness of the system continues to depend on the speed and consistency of investigations and court proceedings, the effective confiscation of proceeds, the enforcement of corporate liability, coordination between national authorities and the EPPO in EU-funds cases, and the implementation of preventive integrity measures in public procurement, local government and state-owned companies.

2.  What three essential pieces of advice would you give to clients involved in Bribery & Corruption matters?

The first and most important advice is to obtain specialised legal representation immediately and not to speak to investigators, counterparties, employees, the media or any third party about the matter without counsel. In corruption cases, early statements and informal communications can significantly affect the position of both individuals and companies. Legal counsel should be involved from the very beginning to ensure that the rights of suspects, defendants and legal entities are properly protected.

The second is to preserve evidence and avoid any unauthorised deletion, alteration or collection of documents. A controlled document-preservation and internal-review process should be established immediately, preferably under legal supervision. Bribery and corruption investigations often turn on emails, messages, procurement files, accounting records, payment flows and internal communications, so mishandling evidence can create additional exposure.

The third is to look beyond the criminal file and protect assets from the outset. Bribery and corruption matters usually create parallel risks: personal criminal liability, corporate criminal liability, confiscation of proceeds, freezing of bank accounts, registration of encumbrances over real estate, interim measures securing the confiscation of alleged unlawful gain, public procurement consequences, employment issues, reputational damage and, in EU-funds cases, possible EPPO involvement. In practice, prosecutors will often seek temporary asset-freezing measures at an early stage of the proceedings, including land-registry annotations and restrictions over real estate. Clients should therefore immediately assess the proportionality, scope and legal basis of such measures, challenge excessive or unfounded freezes, and document the damage caused by them. If the defendant is ultimately acquitted or the proceedings are discontinued, the State may be liable for damages caused by unjustified provisional measures.

3. What are the greatest threats and opportunities in Bribery & Corruption law in the next 12 months?

The greatest threats in Croatian bribery and corruption matters over the next 12 months are likely to arise from recent and upcoming procedural changes, the increasing complexity of high-profile investigations, and the reputational impact of media-sensitive proceedings.

A key concern is the recent reform of the Criminal Procedure Act, particularly the changes concerning unlawful evidence, the definition of what constitutes unlawful evidence, and the treatment of evidence obtained as a consequence of unlawfully obtained evidence — the so-called “fruit of the poisonous tree” issue. In bribery and corruption cases, where investigations often rely on covert measures, surveillance, communications data, searches, seized documentation and financial intelligence, even small changes to the rules on admissibility of evidence may have significant consequences for both the prosecution and the defence.

Another important threat is the reform of the indictment review stage. The indictment panel is increasingly moving towards an in-camera model, without the presence of the parties. This may reduce the ability of the defence to make immediate oral submissions on key procedural issues, including the admissibility of evidence and the sufficiency of the indictment. There is also legal uncertainty regarding the possibility of appealing decisions on whether unlawful evidence should be excluded, as the availability of appellate review appears to depend more on judicial assessment in individual cases rather than on a clearly prescribed statutory remedy. For defendants and legal entities involved in bribery and corruption proceedings, this creates additional uncertainty at a procedurally critical stage.

A further threat is the public and reputational dimension of corruption investigations. Cases handled by USKOK or the EPPO are frequently high-profile and closely followed by the media. In practice, media coverage may sometimes overlook the presumption of innocence, which is one of the fundamental guarantees under Article 6 of the European Convention on Human Rights. This can create serious reputational damage for individuals and companies long before any final court decision has been reached.

At the same time, these developments also create opportunities. The first opportunity is for earlier and more strategic defence involvement. Given the increasing importance of evidentiary admissibility, asset-freezing measures, indictment review and media exposure, clients will need specialised legal advice from the earliest stage of the investigation, not only after an indictment is filed.

The second opportunity lies in stronger corporate compliance and internal investigation mechanisms. Companies operating in regulated sectors, public procurement, healthcare, construction, infrastructure, EU-funded projects or dealings with public authorities should use the current enforcement environment to review antibribery policies, reporting channels, approval processes, third-party due diligence, documentation of payments and gifts, and internal controls. A robust compliance system may significantly reduce risk and improve the company’s position if an investigation arises.

The third opportunity is the development of more sophisticated asset-protection and damage-mitigation strategies. In bribery and corruption cases, prosecutors often seek freezing of bank accounts, land-registry annotations over real estate and temporary measures securing the confiscation of alleged unlawful gain. Defence teams should therefore act early to test the legal basis, proportionality and scope of such measures, propose narrower alternatives where appropriate, and document losses caused by excessive or unjustified restrictions.

If proceedings end in acquittal or discontinuance, such documentation may become important for later compensation claims against the State.

Overall, the next 12 months are likely to be marked by a stronger focus on procedural safeguards, admissibility of evidence, corporate liability, asset-freezing measures and the public handling of high-profile corruption cases. For clients, the main challenge will be to react quickly and strategically; the main opportunity will be to use early legal advice, compliance measures and asset-protection planning to reduce both criminal and commercial exposure.

4. How do you ensure high client satisfaction levels are maintained by your practice?

This is a particularly delicate question in criminal defence, especially in bribery and corruption matters, because client satisfaction cannot be measured only by the final outcome of the case. These proceedings are often complex, lengthy, stressful and exposed to significant personal, corporate, financial and reputational risks. For that reason, we focus on ensuring that the client feels fully protected, properly informed and actively defended at every stage of the proceedings.

Our approach is to become involved as early as possible and to start building the defence immediately, without waiting for the case to develop passively. From the outset, we analyse the allegations, review the evidence, identify procedural weaknesses, assess possible unlawful evidence, consider asset-freezing risks and define a clear defence strategy. Where appropriate, we actively propose evidence, challenge procedural irregularities, file appeals and use every available procedural mechanism to protect the client’s rights and improve the client’s position.

A key part of maintaining client confidence is close cooperation with the client. A passive client will rarely be in the same position as a client who actively cooperates with defence counsel. This does not mean that the client should act independently or communicate without legal advice, but rather that the client should assist counsel by providing information, documents, context, timelines, potential witnesses and business explanations that may be crucial for the defence. Effective defence in corruption cases is often built through this combination of legal strategy and the client’s detailed factual knowledge.

We also place strong emphasis on clear and realistic communication. Clients are regularly informed about the procedural status of the case, the risks, the available options and the likely next steps. We avoid creating unrealistic expectations, but we ensure that every client understands what is being done, why it is being done and how each step fits into the overall defence strategy.

Ultimately, our goal is to do everything legally and procedurally possible to prevent an indictment where possible, to challenge the prosecution case where proceedings continue, and, where the matter reaches trial, to obtain an acquittal or the best achievable outcome for the client. In this context, client satisfaction is maintained through commitment, preparedness, accessibility, active defence and the client’s trust that no available defence avenue has been left unexplored.

5. What technological advancements are reshaping Bribery & Corruption law and how can clients benefit from them?

The most important technological developments reshaping bribery and corruption law are artificial intelligence, advanced data analytics, digital forensic tools, e-discovery platforms and automated compliance systems. These technologies are changing both how corruption is detected and how clients can defend themselves or reduce risk.

From an enforcement perspective, authorities increasingly rely on large-scale data analysis, financial intelligence, digital communications, procurement databases, bank records, mobile devices and electronic correspondence. In bribery and corruption cases, evidence is often no longer limited to witness statements or physical documents. It may include emails, messaging applications, metadata, payment flows, procurement patterns, company records, land-registry data, tax data and other digital traces. This makes investigations more complex, but also creates opportunities for a more precise and evidence-based defence.

For clients, AI and data analytics can be particularly useful in internal investigations and compliance reviews. Companies can use technology to identify unusual payments, conflicts of interest, high-risk third parties, repeated contract awards, split procurements, suspicious invoice patterns, gifts and hospitality issues, or abnormal approval processes. Used properly, these tools can help detect problems early, before they become criminal investigations.

Clients can also benefit from digital compliance systems. Automated reporting channels, whistleblowing platforms, approval workflows, audit trails and electronic registers of gifts, hospitality, donations and sponsorships can significantly reduce corruption risk. They also help companies demonstrate that they had functioning preventive systems in place, which may be important in assessing corporate liability, reputational exposure and remedial action.

At the same time, technology must be used carefully. AI-generated analysis is not a substitute for legal judgment, and clients must ensure that digital tools comply with data protection, employment, confidentiality and privilege rules. Poorly managed internal investigations or uncontrolled data collection can create additional legal risks.

Overall, technology gives clients the opportunity to move from a reactive to a preventive approach. Instead of waiting for an investigation, companies can use AI, data analytics and compliance platforms to detect risks early, preserve evidence properly, improve internal controls and respond more effectively if a bribery or corruption allegation arises.