Legal Landscapes: Croatia – White Collar Crime

Ivan Gržić

Attorney-at-law, founder and partner, Tus & Gržic


1. What is the current legal landscape for White Collar Crime in your jurisdiction?

The legal framework for so-called “white collar” criminal offences in the Republic of Croatia is primarily based on the Criminal Code of the Republic of Croatia (Official Gazette Nos. 125/11, 144/12, 56/15, 61/15, 101/17, 118/18, 126/19, 84/21, 114/22, 114/23, 36/24; hereinafter – the Criminal Code*). This fundamental piece of legislation prescribes criminal offences encompassing economic crime, corruption, abuse of office and authority, fraud, money laundering, and offences against the economy and official duty.

With regard to the criminal liability of legal persons, reference should be made to the Act on the Liability of Legal Persons for Criminal Offences (Official Gazette Nos. 151/2003, 110/2007, 45/2011, 143/2012, 114/2022, 114/2023; hereinafter – the ALLPCO*). The ALLPCO defines the prerequisites for liability, types of sanctions, security measures, confiscation of property gains, seizure of objects, public publication of judgments, limitation periods, and the criminal procedure applicable to legal persons.

Criminal proceedings concerning “white collar crime” are governed by the Criminal Procedure Act (Official Gazette Nos. 152/08, 76/09, 80/11, 121/11 – consolidated text, 91/12, 143/12, 56/13, 145/13, 152/14, 70/17, 126/19, 80/22, 36/24, 72/25*).

The aforementioned laws represent the core legal framework used in the prosecution of individuals suspected of economic crimes. However, it is also important to highlight the Act on the Office for the Suppression of Corruption and Organised Crime (USKOK) (Official Gazette Nos. 76/09, 116/10, 145/10, 57/11, 136/12, 148/13, 70/17*), the Police Duties and Powers Act (Official Gazette Nos. 76/09, 92/14, 70/19*), and the Act on the Protection of Natural Persons in Connection with the Processing and Exchange of Personal Data for the Purpose of Preventing, Detecting, Investigating or Prosecuting Criminal Offences or Enforcing Criminal Penalties (Official Gazette No. 68/18*).

A special role in the prosecution of “white collar crime” offences lies with the competent municipal and county State Attorney’s Offices, in particular the Office for the Suppression of Corruption and Organised Crime (USKOK), whose cases are heard before specialised court departments.

In addition, since 1 June 2021, the European Public Prosecutor’s Office (EPPO) has been operating in Croatia as an independent body of the European Union responsible for investigating, prosecuting and bringing to trial criminal offences affecting the EU’s financial interests, including fraud, corruption, money laundering, and cross-border VAT fraud.

The Ministry of the Interior, through specialised police bodies and criminal police departments, is also involved in investigating financial crimes, particularly the National Police Office for the Suppression of Corruption and Organised Crime (PNUSKOK), which monitors and analyses specific forms of corruption, organised crime and terrorism, their trends and methods of commission. PNUSKOK conducts complex national-level investigations in close cooperation with USKOK.

In the initial phases of proceedings, the Tax Administration participates in investigating financial crimes by monitoring tax obligations and cooperating in financial investigations, while the Office for the Prevention of Money Laundering analyses suspicious financial transactions.

In practice, there is an increasing complexity of cases, particularly those involving cross-border transactions and financial instruments, which requires a multidisciplinary approach and close cooperation with financial experts.

2. What three essential pieces of advice would you give to clients involved in White Colar Crime matters?

All advice provided to clients in criminal proceedings is subject to attorney–client privilege, as stipulated in Article 13 of the Law on the Legal Profession (Official Gazette Nos. 9/1994, 117/2008, 50/2009, 75/2009, 18/2011, 126/2021*) and the applicable Code of Legal Ethics.

In general, I would advise clients not to communicate with anyone regarding the ongoing criminal case except their lawyer, as preliminary investigations under Article 206(f) of the Criminal Procedure Act are confidential, and investigations and inquiries are non-public pursuant to Articles 213(3) and 231(1) of the same Act.

If the client is not in custody, they should, after being informed of the charges, conduct a thorough review of all available documentation that could assist in preparing an effective defence. That documentation should be carefully structured so that it can be used to challenge the prosecution’s arguments at the appropriate stage.

Most importantly, at the initial stage of proceedings, the client must remain calm, present their arguments in a reasoned and structured manner, and submit all relevant documentation through their defence counsel to the prosecuting authority. The competent State Attorney’s Office may, even during the investigative stage, discontinue the criminal proceedings.

If an indictment is filed, attention should first be paid to whether it relies on illegally obtained evidence, in which case a motion may be submitted to the court during the indictment review phase to exclude such evidence from the file pursuant to Article 10(2)(2–3) of the Criminal Procedure Act.

Finally, I advise the client to remain composed, calm, and dignified throughout the entire process, respond to all court summonses, and at the conclusion of the proceedings, present their defence arguments in a reasoned and consistent manner.

3. What are the greatest threats and opportunities in White Collar Crime law in the next 12 months?

The main threat arises from increasingly stringent oversight and regulation of financial flows, digital transactions, and public procurement, as well as growing international pressure to combat corruption.

Croatia’s criminal legislation is increasingly shaped by OECD recommendations. Within the project “Raising Awareness and Standards in Combating Bribery in International Business Transactions” (2020–2022), jointly conducted by the Ministry of Justice and Administration, the European Commission, and the OECD, an analysis of Croatia’s legislative and institutional framework was carried out in relation to the OECD Anti-Bribery Convention.

The OECD Report on Croatia (May 2022) found that Croatia’s framework meets many Convention requirements but also provided recommendations for further improvements. After fulfilling formal requirements, in October 2023 the Croatian Parliament ratified the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Official Gazette – International Treaties, No. 10/23*). The Government of the Republic of Croatia also adopted a Decision on Joining the OECD Working Group on Bribery (25 October 2023).

Following OECD recommendations, forthcoming amendments to the Criminal Code aim to strengthen anti-corruption mechanisms, particularly regarding bribery of representatives (Article 339). The amendments, currently in public consultation, will broaden the offence definition so that bribery will include abstaining from voting or making statements induced by bribery, not only changing one’s vote, with potentially harsher penalties.

In June 2025, the Ministry of Justice also confirmed the need to regulate situations involving artificial intelligence (AI), introducing new provisions addressing liability where AI systems cause death, serious injury, or major property damage. These changes respond to rapid technological developments — from autonomous vehicles to weapon systems operating without human control — and introduce preventive liability measures focused on risk management and oversight of high-risk technologies.

Criminal offences committed through AI are expected to receive specific treatment, particularly in the context of traffic safety and endangerment of life, and these legislative changes are likely to extend to financial crime, given AI’s growing influence in business, banking, and political processes.

In conclusion, based on OECD recommendations, Croatia is actively working on legislative amendments relating to corruption investigations, and the next 12 months will be critical in observing how these reforms are implemented and how new offences, based on OECD standards, are prosecuted and sanctioned.

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

The key lies in an individual approach to each case, constant availability, and transparent communication about the course of proceedings.

Mutual trust between lawyer and client is the most important factor — without it, quality representation in criminal proceedings is impossible. Trust is built through timely and realistic risk assessments, professional discretion, and joint decision-making on all key issues.

Continuous education and monitoring of international practice enable modern and effective legal solutions. It is essential to invest in professional development, follow case law trends, and stay updated on legislative changes.

Although success in criminal proceedings can never be guaranteed — due to their inherent unpredictability — clients are always assured of full dedication, engagement, and responsible representation.

5. What technological advancements are reshaping White Collar Crime Law and how can clients benefit from them?

In the past decade, we have witnessed significant technological transformations in how white collar crimes are committed, detected, investigated, and prosecuted. The digitalisation of financial systems, the rise of artificial intelligence (AI), blockchain technology, and advanced data analytics have created new opportunities as well as new risks.

As an EU member state, Croatia adopts and implements European regulatory standards concerning digital forensics, data protection, cybersecurity, and electronic evidence, aligning its framework with those of more developed jurisdictions.

Digital forensics has become a key tool in detecting and proving economic crimes. Croatian law enforcement authorities, USKOK, and the State Attorney’s Office increasingly use specialised software to collect, preserve, and analyse digital traces (e.g. electronic communications, metadata, transaction records, and IT system logs).

Big Data analytics enables investigators to process vast datasets from multiple sources (bank records, business correspondence, accounting systems) and identify behavioural patterns indicative of fraud, corruption, or money laundering.

For clients — particularly legal entities — these tools provide opportunities for internal investigations and prevention. In criminal proceedings, such technologies allow clients to verify the authenticity of electronic evidence used against them.

AI systems are increasingly used to detect irregular transactions, analyse financial reports, and assess the risk of criminal behaviour within organisations. Algorithms can automatically flag unusual activities, such as abrupt changes in payment patterns, transfers to high-risk jurisdictions, or inconsistencies in procurement processes.

For law firms, AI tools enhance the efficiency of evidence review and categorisation, reducing preparation time and increasing analytical precision — directly benefiting clients through lower defence costs, faster case handling, and stronger legal arguments.

Additionally, many software providers now offer AI-based legal research platforms that facilitate access to legislation and case law, significantly improving workflow.

Blockchain technology, as a decentralised record-keeping system, serves as an important instrument in ensuring transaction transparency and data integrity. Since blockchain records cannot be altered retroactively, it can be used as proof of the authenticity of business transactions or contractual relationships.

Although its use in Croatia’s criminal law context is still in early stages, there are initiatives to apply blockchain in public procurement, financial reporting, and asset registries — potentially reducing opportunities for abuse and corruption. Private-sector clients can benefit from safer and more transparent operations, especially in cross-border transactions.

The growing digitalisation of the economy has also led to new offences, such as computer fraud, unauthorised system access, and identity theft. By aligning its legislation with the EU NIS Directive (2016/1148) and adopting the Cybersecurity Act for Operators of Essential Services and Digital Service Providers, Croatia has established a framework for systematic protection of digital infrastructure.

For clients, particularly corporations and financial institutions, investing in cybersecurity and implementing standards such as ISO 27001 or SOC 2 reduces exposure to criminal risks and enhances credibility with regulators and partners.

The Croatian judiciary is also undergoing digital transformation, including e-Communication, electronic case management (e-Spis), and systems for electronic submission and storage of evidence. These improvements facilitate more efficient proceedings and reduce administrative burdens.

In white collar cases, digitalisation strengthens institutional coordination (between DORH, USKOK, MUP, and the Tax Administration) and accelerates access to evidence.

Ultimately, technological advancements are fundamentally reshaping the investigation and prevention of economic crime. In Croatia, their impact is evident in the digitalisation of public institutions, the strengthening of regulatory frameworks for data protection and cybersecurity, and the development of forensic and financial analysis tools.

For clients, the benefits include greater transparency, more effective risk management, lower defence costs, and preventive mechanisms that reduce exposure to criminal liability. Continuous education of legal and economic actors remains essential to ensure proper and timely application of these advancements in line with national and EU regulations.