Review of Lithuania’s National Agenda on the Prevention of Corruption

2. The 2022-2033 NAPC: Towards overcoming institutional and co-ordination challenges in integrity policies

Abstract

This chapter considers the Lithuanian 2022-2033 NAPC in relation to international good practice in the construction of integrity strategies. It provides insights on the Lithuanian strategy by making several recommendations addressed at the 2022-2033 NAPC’s theory of change, as well as on strengthening the institutional capacity of the STT. Furthermore, the potential for broadening the scope of the NAPC, developing targets and problem analysis are considered. These recommendations may help to inform current and ongoing efforts to strengthen the institutional anti-corruption in Lithuania.

Taking the lesson learned from the previous implementation period, the following section briefly assesses the process of developing the 2022-2033 NAPC against key international benchmarks and provides recommendations to be considered in the process. Furthermore, it includes recommendations regarding standards that help guide the design of strategies and action plans, including:

• The OECD Public Integrity Handbook (OECD, 2020[1]) and the assessment according to the OECD Public Integrity Indicator on Principle 3 of the OECD Recommendation on Public Integrity (OECD, 2017[2]).

• UNODC’s National Anti-Corruption Strategies: A Practical Guide for Development and Implementation (UN, 2015[3]).

• UNDP’s Anti-Corruption Strategies: understanding what works, what does not and why (UNDP, 2017[4]).

• The G20 High-Level Principles for the Development and Implementation of National Anti-Corruption Strategies (UNODC, 2020[5]).

When drafting a strategy that involves several bodies, one option is to assign to a small committee the primary responsibility for drafting the strategy document and granting it a reasonable degree of autonomy in developing the draft; the committee would be composed of representatives from the relevant public bodies (OECD, 2020[1]) (UN, 2015[3]). The drafting body should have sufficient stature and legitimacy to act as an effective “champion” for the drafting body, and ultimately for the strategy itself. Furthermore, a strategic approach requires high-level commitment during the strategy design process, as well as ensuring that the approach avoids overly rigid compliance objectives and places emphasis on promoting cultural change within organisations (OECD, 2020[1]). It is also key to ensure the continued support and involvement of senior political leaders as well as diagnostic analysis, appropriate governance, and political support (UN, 2015[3]; G20, 2021[6]). A successful anti-corruption strategy must not only lay out a comprehensive set of substantive reforms but also indicate the means for ensuring co-ordinated implementation. For this co-ordination, the STT is well positioned, as it covers both prevention and sanctioning of corruption. Indeed, this is confirmed by the findings of the OECD 2022 survey that showed an overall satisfaction with the leadership and methodological assistance provided by the agency and some areas of improvement that will be discussed in following sections.

Strengthening the STT and its preventive role

Lithuania could consider strengthening the role of the STT, both as a preventive agency and as a co-ordination agency, while mainstreaming integrity policies through the entire public administration

The STT has a unique role in Lithuania combining both preventive and enforcement functions. With regards to corruption prevention specifically, the STT carries out corruption risk analysis in certain areas of the public administration, municipal activities or processes, examining anti-corruption activities of one or more public entities involved. At the same time, the STT is also responsible for determining the level of resilience to corruption within public entities after being determined by the public sector entity itself. According to Article 12 of the Law on Corruption Prevention, the STT assesses the number and types of measures implemented in public sector entities to create an anti-corruption environment. Similarly, it has been very successful in the areas of improving legislation (Box ‎2.1). However, when consulting institutional actors (Table ‎2.1), it became clear that the role of the STT on its preventive and co-ordinating role could be further strengthened.

Table ‎2.1. Satisfaction with the work and support of the Special Investigation Service (STT)

Please rate your satisfaction with the work and support of the Special Investigation Service (STT) in its function as the Technical Secretariat of NAPC 2015-2025 in the following areas (N = 13)*	Net satisfied	neither satisfied nor dissatisfied	Net dissatisfied
Conducting evaluations of public institutions	8	4	1
Developing and co-ordinating a robust monitoring framework (indicators, baselines, targets) to monitor the implementation of NAPC	10	3	0
Disseminating best practices	9	3	1
Organising regular consultation of the implementing institutions	11	1	1
Providing counselling and ad hoc guidance to support implementing institutions	11	1	1
Providing methodological support to implementing institutions	9	3	1
Providing training to implementing institutions	11	2	0

Source: OECD 2015-2025 NAPC Stakeholders Survey, 2022.

Box ‎2.1. Corruption proofing – a good practice from Lithuania

In Lithuania, the STT has proofed draft legislation to check for any potential impact the proposed law could have on corruption since 2002. The process follows an internal assessment by drafting institutions and general guidelines enacted by the Ministry of Justice. Furthermore, an ex post evaluation of the impact of such legal regulation can be carried out by the entities.

In 2015, for instance, the STT examined the draft Law on Physical Culture and Sport. It concluded that the Law’s proposed criteria to appoint experts to a council tasked with awarding grants were too vague, which created risks of corruption that government funds would be misused. In another example, the STT reviewed a draft legal amendment to the Law of Public Procurement. Again, the STT recommended revising criteria according to which unreliable suppliers must be excluded by contracting authorities to safeguard public funds.

In 2020, 194 laws and 191 draft laws were subject to an anti-corruption assessment. GRECO reports have praised co-operation between Lithuanian authorities when analysing anti-corruption legislation from an anti-corruption perspective. Moreover, the STT occasionally engages civil society and experts to assist in the assessment. While the recommendations from the STT are not binding on the entity drafting the law, in practice it seems that its recommendations are adopted in about 90% of cases. The use of STT expertise to identify and close legislative loopholes that entail corruption risks is commendable. Indeed, the 2021 STT Performance Report shows that, during the year 2021, 70.7% of proposals for critical anti-corruption remarks and 57.4% of proposals for other anti-corruption remarks were ongoing or fully or partially implementing.

Source: (STT, 2015[7]) ; (STT, 2021[8]); (GRECO, 2021[9]); (Hoppe, 2020[10]).

First, a comprehensive strategic framework for integrity should cut across various policy sectors involving different government institutions, i.e. law enforcement, regulatory, civil, and administrative authorities. In Lithuania, amendments to the 2021 Law on the Prevention of Corruption introduced the “principle of subsidiarity”. The amendments established obligations for public sector entities to actively assess, identify and mitigate corruption risks. The results of these assessments are to be public to allow comparison between institutions, including over time (GRECO, 2022[11]). At the same time, public bodies are obliged to establish a dedicated internal anti-corruption unit or appoint an anti-corruption specialist (“ethics officer”) to carry out these risk management functions (Seimas of the Republic of Lithuania, 2021[12]). Stipulations are also included that seek to guarantee the independence of these units and lay out their expected duties, such as reporting data on detected infringements, corruption risks, and proposed mitigation measures (HSE University Anti-Corruption Center, 2021[13]). These measures align perfectly with the “principle of subsidiarity” and assure a real transfer of capacities and ownership in public institutions across the board. However, the implementation of this principle has remained challenging. According to Lithuanian authorities, this is due to the lack of ownership and political will by managers and leadership within the institutions as well as a limited capacity by ethics officers when it comes to trickling down integrity policies through the institution and sector.

Second, an effective integrity strategy should go beyond policy reforms and, provide channels to ensure co-ordinated implementation of these reforms. The interaction of various actors ensures mutual accountability and peer control when it comes to the implementation of the integrity strategy. At the same time, there is also need for co-ordination mechanisms at the operational level that allow for the efficient interactions of the various institutions that are required to exchange information, agree commitments and co-ordinate their efforts to ensure policy coherence. In Lithuania, ethics officer does not have formal co-ordinating mechanisms between themselves. Providing further guidance to both ethics officers and managers and a baseline of what is expected of them, might help increase ownership of their role within public institutions. Furthermore, as mentioned previously, Lithuania could consider including the in the upcoming Action Plans a network of ethics officers with regular meetings to discuss common challenges. This could be co-ordinated by the executive branch as well as the COEC and the STT. A similar practice is implemented in the Slovak Republic and Argentina (Box ‎2.2), where each line ministry is required to appoint an anti-corruption co-ordinator, who participates in the “Board of Anti-Corruption Co-ordinators” (OECD, 2022[14]).

Box ‎2.2. Network of Public Integrity Areas and Liaisons

The Argentine Anti-Corruption Office (Oficina Anticorrupción, OA) has developed the Network of Public Integrity Areas and Liaisons (Red de Áreas y Enlaces de Integridad Pública). The purpose of this institutionalised arrangement is to advance the development of a comprehensive transparency policy, generating multiple channels of contact to raise awareness and disseminate the principles and guidelines for the ethical behaviour of public officials. This creates a collaborative process between the main co-ordinator and the areas/sectors in which integrity policies are being implemented.

Source: https://www.argentina.gob.ar/anticorrupcion/enlaces-integridad

Furthermore, to increase co-ordination efforts, Lithuania could consider fine tuning the roles of all the actors involved in the 2022-2033 Action Plans and strengthening the roles of both the STT and the Ministry of Justice to be able to fulfil their roles. According to Lithuanian authorities, high-level commitment and continued support of senior political leaders is ensured through the approval of the NAPC by a resolution of the Seimas. Since the NAPC does not clarify the role of the STT’s and how it is distinguished from the role of the Ministry of Justice or the Commission for the Fight against Corruption, the Actions Plans could specify concrete measures and institutions directly or indirectly responsible for their implementation with defined stakeholders, concrete measures, and terms for their implementation. Furthermore, it would be useful to mention the role of other organisations, e.g. line ministries and the Seimas, and more specifically, how these are expected to co-operate with STT in the overall co-ordination. For example, if some sort of co-operating platforms is envisaged or if working groups would help in co-ordinating activities specifically for the development of the Action Plans.

Lithuania may consider strengthening guidelines provided by the STT on integrity management systems for public sector institutions

As stated, several legislative changes made during the NAPC implementation period were intended to compel public bodies to strengthen their internal integrity management systems to ensure that general anti-corruption preventive measures were introduced in the public sector, but also to encourage the adoption of specific measures relevant to each body. To this end, a handbook on the development of integrity management systems in the public sector was produced and updated in 2018 (STT, 2020[15]). According to information collected during the consultation for this report, the obligation to establish internal integrity management functions at institutions remains low and there is a lack of publicly available information about steps taken by public entities to prevent corruption.

In the interviews conducted for this report, officials stated that the corruption risk analysis and the determination of the level of resilience to corruption could be further strengthened, as a way to inform integrity management systems. The STT, as a law enforcement agency, can access data and information for investigation purposes, according to Article 8 of Law VIII-1649 of 2000 to identify patters. Nevertheless, the State Personal Data Protection Service has issued directives that prevent the STT from using big data analysis for the prevention of corruption. The key argument is built on the basis that despite the STT’s access and processing rights, this access is subject to the decision of the data controller (or also referred to as “data provider” or “register owner”), namely the agency that handles the data and who will eventually assess the lawfulness of the request (State Data Protection Inspectorate, 2021[16]). The State Data Protection Inspectorate points out that the anti-corruption intelligence can only be justified for individual data requests and not for the entire public information system or register. This approach leaves wide discretionary powers to register owners. However, the EU Regulation 2016/679 does not preclude law enforcement agencies from accessing big data for the prevention of criminal offences (European Parliament, 2016[17]). On the contrary, it notes that the free flow of personal data between competent authorities for the purposes of the prevention of criminal offences should be facilitated while ensuring protection of the data. At the national level, the Constitutional Court of Lithuania also asserts that preventive measures aimed at limiting and reducing crime cannot in themselves be considered a constitutionally unjustified restriction of the right to privacy (Constitutional Court of Lithuania, 2019[18]). To facilitate the collection and analysis of data, Lithuania could consider strengthening the collaboration between the STT and register operators through the establishment of a robust legal framework for such collaboration and exchange of information.

Paving the way for the 2022-2033 Action Plans: overcoming challenges and lessons learned in the design of the NAPCs

Lithuania could further develop the vision of the 2022-2033 NAPC and build on it in the upcoming Action Plans, including its alignment with a coherent theory of change and expected outcomes

Strategies should articulate a clear vision, explaining envisaged outcomes, objectives and how planned activities will contribute to the achievement of that vision. A coherent and overarching theory of change is increasingly recognised as pivotal to anti-corruption interventions and becomes fundamental to asses outcomes within monitoring and evaluation (OECD, 2020[1]; G20, 2021[6]). A good theory of change requires a clear vision and goals, a strong problem identification, the interventions and the outcomes that are needed to effect change and the underlying assumptions that are necessary for these outcomes to materialise (UNDG, 2017[19]).

The 2022-2033 NAPC attempts to establish a core and guiding theory of change in paragraph 1 (describing the aims of the NAPC):

“1. The National Anti-Corruption Agenda 2022-2033 (hereinafter referred to as the "Agenda") is being developed with the aim of achieving substantial changes in the reduction of corruption, a coherent and integrated state-building environment that is resilient to corruption. Processes related to progress in the fight against corruption, which have an impact on the maturity of society, the economy, state governance and justice, will also help to safeguard national security interests”

Chapter 1 in Section 1 describes the legal basis for the NAPC’s development. The section, using the above objective as a starting point, references the European Commission’s EU-wide Rule of Law Report to underline the importance of fighting corruption and provides a definition of corruption. The 202-2033 NAPC also lists a series of European and international initiatives in the field of corruption prevention and describes Lithuania’s institutional and legal framework related to anti-corruption. Even though there is a brief analysis of the main issues to be covered by the Agenda, the analysis stays in the descriptive and does not explain the relevance of these thematic areas, the problems identified, or how they link to the expected outcomes. This is why, the upcoming Action Plans would benefit from a previous process of defining and creating a more stringent “theory of change”, that could help explain how planned activities will contribute to the achievement of that vision.

Furthermore, the Action Plans could include a broader diagnosis in thematic areas, explaining why certain priorities were selected or the importance of addressing dormant reforms. International standards emphasise that a key to the success of any anti-corruption strategy is a robust diagnostic stage, which can involve political economy analysis, stakeholder mapping, corruption risk assessments and other evidence gathering. Establishing a solid understanding of corruption’s drivers and enabling factors, as well as core vulnerabilities, is indispensable (OECD, 2020[1]; G20, 2021[6]) (UN, 2015[3]). The OECD Public Integrity Indicator 1.3.2 “Evidence-based problem analysis and use of diagnostic tools” reflects this international good practice and asks countries to develop an evidence-based problem analysis and use diagnostic tools to build upon such diagnosis. In the case of the 2022-2033 NAPC, there are many outstanding issues as it relates to the strength of the problem analysis, perhaps correlated to the “theory of change” challenges. For example, it relies heavily on the decay on international indicators but fails to explain the root causes of such a decay in its problem analysis. To address these weaknesses, Lithuania could deepen the problem analysis in the upcoming Action Plans, to present the interlinkages between the progress targets, the data referenced, the problem root causes and potential areas of improvement.

In principle, it could even use some of the information from Chapter 2 of the 2022-2033 NAPC to create an initial diagnosis that could help inform and refine future activities. Some issues to be considered are (Box ‎2.3):

Box ‎2.3. Key Recommendations for defining the core ideas guiding the NAPC and subsequent Action Plans

• Detailing what are the substantial changes desired to achieve

• Set a distinction between what will be directly attributed to this new NAPC and what is part of on-going processes or reforms.

• The Agenda will benefit from stating a principle of flexibility and adjustment that will allow it to be adapted over time, both in terms of priorities and activities.

• For the Action Plans, consider articulating the interlinkages between the Agenda’s overall objective, problem identification and envisaged outcomes in the Action Plan.

• Consolidate a broader approach in the Action Plans, which goes beyond anti-corruption and focuses more on preventive policies, such as the strengthening of an integrity system, internal control mechanisms, integrity units, sub-national policies and sector specific policies.

Lithuania could also consider a clearer identification of targets and envisaged outcomes in the Action Plans, all aligned with the desired results of a previously established “theory of change”. Although dedicated sections in the 2022-2033 NAPC propose a few targets and explain their link to national and international studies, it is not explained how achieving these targets is expected to address the problems identified. Furthermore, it is unclear how the targets support the implementation of the three directions set out in the 2022-2033 NAPC and the agenda’s overall strategic objective. Therefore, the Action Plans would benefit from an enhanced analysis which would establish priority areas, as in other OECD countries (Box ‎2.4) and link the challenges with the agenda’s progress targets and envisaged outcomes. Similarly, several progress targets might require further analysis, e.g. the progress target on conflict of interest only does an assessment of nepotism. This analysis could be further strengthened, or an explanation provided as to why is this the only issue worth raising. Additionally, in many instances, each progress target includes a checklist of laws, regulations and instruments enacted, as well as some references to national and international surveys, but these do not correlate or try to address the problems identified in the previous chapters.

Box ‎2.4. Setting a strategic approach to integrity and anti-corruption in the United Kingdom

The United Kingdom Anti-Corruption Strategy 2017-2022 seeks to provide a long-term framework for ensuring a safer, more prosperous and more confident future based on concerted UK action against corruption. The strategy is informed by a detailed analysis of key corruption risk areas, based on data from the following sources:

1. Data of sociological surveys, such as the Ipsos MORI Veracity Index, 1993-2016, the Control Risk 2015 International business attitudes towards corruption, and the PWC 2016 Annual Global CEO Survey.

2. Results of the implementation of the 2014 UK Anti-Corruption Plan.\

3. Analysis of the impact of anti-corruption laws in the public and private sectors, based on the results of the London Anti-corruption Summit of 2016.

4. Political and legal factors, such as the effects of Brexit or the leading role of the United Kingdom on pushing for a beneficial ownership transparency agenda, which details the efforts of the United Kingdom to implement international standards on anti-corruption.

Based on this situation analysis, the Strategy identifies priority areas for anti-corruption, including strengthening the integrity of the United Kingdom as an international financial centre; reducing the insider threat in high-risk domestic sectors; promoting integrity across the public and private sectors; reducing corruption in public procurement and grants; improving the business environment globally; and working with other countries to combat corruption.

Source: (HM Government, 2017[20])

Building on recent efforts, Lithuania could further systematise the process of the NAPC, enhance transparency and ensure the continuous engagement of stakeholders across the policy cycle

International good practice emphasises that a strategy development process should ensure the appropriate inclusion and participation of actors responsible for carrying out any part of the strategy (OECD, 2020[1]; G20, 2021[6]) (UN, 2015[3]). This offers transparency to the process as it allows a multi-stakeholder approach to the strategy. In particular, consultations should extend not only to the political leadership of the various implementing agencies but also to the technical staff or career civil servants who will play a key role in implementing the strategy’s recommendations and external experts (i.e. academics, civil society organisations, citizen representatives, etc.). High levels of transparency and public participation benefit from the inputs of stakeholders. A good example is that of Latvia (Box ‎2.5), where a minimum 2-week consultation period is established by Law.

Box ‎2.5. The public consultation procedure in Latvia

The Rules of Procedures of the Cabinet (as updated by Regulation No. 606 in September 2021) foresees notifications regarding the participation process on the Unified Portal for the Development and Agreement of Draft Legal Acts (hereinafter the TAP Portal) no later than 14 days before submitting the planning document to the decision-making body (this means before start of inter-governmental consultation or before announcement at the State Secretaries meeting).

The public consultation procedure starts with the submission of a draft strategy to the TAP Portal, where it is made public. Then, the inter-governmental consultation takes place (it is called “Agreement of Drafts and Provision of Opinions”) with the involvement of ministries and other government authorities, which are determined in the Rules of Procedures. According to point 55 of the Rules of Procedures, there are ten working days for comments to be submitted. If there are objections, further meetings are organised, and inter-governmental consultation continues until there are no objections or until the strategy goes to the Cabinet of Ministers with some objections left.

Source: Rules of Procedures of the Cabinet, https://likumi.lv/ta/en/en/id/325944-rules-of-procedures-of-the-cabinet

According to the interviews conducted for this review, Lithuania’s consultation process for the 2015-2025 NAPC encountered several difficulties. In particular, and in accordance with civil society organisations and private sector representatives at the virtual fact-finding mission, there were many difficulties accessing information during the implementation period. Furthermore, the involvement of the sub-national level was very limited and according to public officials, the consultation took place only after the main objectives and activities had been already decided. As stated above, these systemic shortcomings in the consultation process were reflected in Lithuania’s low score in the OECD Public Integrity Indicator (PII).

Recently, there seems to be an understanding of the need to strengthen consultation practices in Lithuania. Decision making based on consultations is one of the priorities of the Government (Government of Lithuania, 2020[21]). As a result, Lithuania invested efforts in improving and systematising its consultation process for the development of the 2022-2033 NAPC. The consultation process for the 2022-2033 NAPC lasted four months from May to September 2021. The draft agenda was made publicly available online and all interested parties (i.e. law enforcement authorities, ministries, local government, private sector entities) were invited to submit their comments to it. Albeit, in accordance with the interviews conducted during the virtual fact-finding mission, citizens and civil society organisations were of the view that consultation was merely formal and that many of their comments were not taken into consideration and no explanation was provided to support the inclusion or not of certain issues. Furthermore, even though Lithuanian authorities stressed that discussion panels were organised with various stakeholders, including academia and non-governmental actors, civils society organisations at the on-site visit mentioned that only a few were present and that a wider group of stakeholders could be considered for the next cycle. At the sub-national level, local government entities were encouraged to identify their priorities and develop their own anti-corruption plans. However, feedback was not provided on whether their priorities were included in the final drafts. Therefore, Lithuania will benefit from i) having a wider group of stakeholders consulted for the 2022-2033 Action Plans; ii) provide feedback to civil society organisations and other non-governmental stakeholders on the inclusion of their suggestions and iii) include this same group of actors in the implementation and monitoring of the 2022-2033 Action Plans.

Indeed, the consultation process for the development of the 2022-2033 NAPC shows significant progress. Building on these efforts, Lithuania should further systematise this process, enhance transparency and ensure the continuous engagement of stakeholders across the policy cycle. As a matter of fact, there are some requirements of the PII benchmark, which remain unfulfilled. The PII requires that a minimum duration of at least 2 weeks for inter-governmental and public consultation period is established in legislation. This does not seem to be the case in Lithuania, where there is no mandatory minimum consultation period ensuring that stakeholders have sufficient time to provide meaningful inputs (OECD, 2021[22]). As described above, despite considerable efforts to exchange feedback on the draft agenda, it is not clear whether the stakeholders engaged in the process were informed as to how their inputs were addressed. Lithuania could consider publishing a summary sheet with responses to all submitted comments provided during the public consultation. In alignment with the PII standards, the summary sheet should be made publicly available online. Additionally, the public consultation could take the form of a continuous engagement with stakeholders allowing them not only to provide opinions upon request, but to also have a permanent channel to raise concerns and give suggestions on improvements. It appears that feedback was sought from stakeholders at a later stage of the policy-making process, when a draft agenda had already been prepared. Instead, Lithuania could consider involving stakeholders in early stages of the development of the NAPC to enable them to identify and evaluate different options. This approach ensures democratic legitimacy, as it sets the tone that, beyond a mere formality, the consultation process is a meaningful stage of the agenda preparation.

Additionally, while the 2022-2033 NAPC mentions that citizens, non-governmental organisations, public interest groups, businesses, journalists, and public information producers and disseminators are encouraged to contribute to the implementation of the Agenda, the agenda does not clarify how this will be achieved. In fact, the NAPC does not mention the public consultation that took place in accordance with the Law on Legislative Framework, the summaries of the comments received or the participating stakeholders. In so far, Lithuanian authorities may consider including a section that describes the consultation process for the setting up of the NAPC and especially, in upcoming steps. This would ensure that all stakeholders are informed about the possibility and ways of contributing to the development and implementation of the agenda.

Finally, to ensure the upcoming Action Plans contain a whole of society vision, Lithuania could consider strengthening ownership of the 2022-2033 NAPC and the Action Plans at the sub-national level. Recognisably, the changes put forward in an anti-corruption strategy document often put additional burdens on government agencies, making it more difficult for them to carry out their missions and thus creating resistance. Differences in maturity level, especially at the local level, should be considered when drafting integrity strategies. Furthermore, recognising the individual role of public entities in managing their own responsibilities in relation to integrity is key to facilitate synergies. Lithuania could consider standardised and more regular guidance to local government for conducting corruption risk assessment, through the Ministry of Interior and the Association of Municipalities. Furthermore, these actors could encourage them to eventually develop their own anti-corruption plans following the identified problematic issues in the 2022-2033 NAPC. This is an approach already implemented in certain municipalities, like the Vilnius City Municipality, but implementation is not uniform across the country (OECD, 2021[23]). Indeed, documentation provided by the Municipal Association indicates that the translation of tasks and functions described in the Resolution proves challenging for local government entities. Finally, standardised guidance could include, for example, the development and publication of rules or manuals for drafting integrity plans, complemented by regular trainings for local officers. Recent experience from Estonia, as shown in Box ‎2.6 could provide a good example in this area. Relevant efforts could be co-ordinated with the support from the Ministry of Interior in accordance with their legal mandate on the issue.

Box ‎2.6. Integrity guidance for Municipalities in Estonia

Estonia has adopted the guidance on “Internal Control and Prevention of Corruption in Local Authorities”. The guidance includes recommendations to:

• Mapping of officials, procedures, and activities with corruption risks

• Mapping activities to prevent and resolve conflicts of interest

• Designating a position or structural unit responsible for identifying corruption risks and activities for their mitigation

• Ensuring documentation of processes and activities in the institutions so that they are transparent and can be verified later

• Establishing consistent procedures for the prevention of conflicts of interest

• Strengthen the audit committee to ensure stronger political control from the council

The guidance contains examples of corruption risks and problems as well as examples of countermeasures. For example, a risk is that a public official will engage in an outside business activity. One proposed countermeasure is to establish a procedure for the notification of outside activities, indicating to whom and in what form the notification should be provided (for example, the name of the legal entity and a brief description of the outside activities should be included in the notification).

Source: (OECD, 2021[23]).

Based on the experience of the previous NAPC, Lithuania could consider broadening the scope of the next Action Plans to include more current challenges and issues left behind in the previous strategy

Several important policy issues related to the enforcement and sanctioning of corruption seem to have been left out of the 2015-2025 NAPC. Perhaps the most notable of these relates to money laundering, which was a topic intentionally treated in isolation from the NAPC. Similarly, while the NAPC made a commitment to accede to the OECD Anti-Bribery Convention, there appears to have been limited attention given to foreign bribery in the Inter-institutional Action Plan. Finally, although asset recovery has been a constants concern in Lithuania (both at the national and international level) no efforts have been made to centralised and compile the different regimes. This is not to say that authorities in Lithuania did not take relevant steps in this area, simply that these efforts fell outside of the purview of the NAPC itself. Nonetheless, some progress has been made with the development of recommendations for Lithuanian businesses operating abroad on how to identify corruption and foreign bribery (STT, 2022[24]). However, this compartmentalised approach in which money-laundering, foreign bribery and asset recovery were seen solely as law enforcement issues and addressed via a separate strategy resulted in missed opportunities for coherence and co-ordination on the preventive side.

Money laundering

Anti-money laundering reviews conducted under the Financial Action Task Force (FATF) standards1 during the initial few years of the NAPC pointed to significant shortcomings in Lithuania’s approach to money laundering, particularly related to risk-based supervision and the resourcing of supervisory bodies. In response to these recommendations, the Bank of Lithuania reported increasing resources to ensure more robust supervision of financial entities (Martini, 2019[25]). In 2021, a separate division for the anti-money laundering/counter terrorist financing supervision of financial institutions and Designated Non-Financial Businesses and Professions (DNFBPs) was established. Lithuania has also transposed the 4th and 5th EU Anti-Money Laundering Directives into national legislation, and these legal changes have instituted a risk-based approach as well as extended the definition of beneficial owner (Walless, 2020[26]). Nonetheless, the European Commission concluded in January 2019 that gaps remained, while civil society observers have also remained critical of the country’s efforts (European Commission, 2019[27]).

Media reporting has uncovered how Lithuanian banks have been used to facilitate money laundering and transnational corruption. A Swedish outlet published a story in 2019 alleging that former Ukrainian President Yanukovych used the Lithuanian branch of a Swedish Bank to launder huge sums of money received in bribes or misappropriated from public coffers (SVT, 2019[28]). This appears to have been confirmed in an investigation conducted by Clifford Chance into the bank’s activities (Clifford Chance, 2020[29]). Another investigation in 2019 by the Organised Crime and Corruption Reporting Project reported that a Lithuanian bank, played a role in the Troika Laundromat case (Anti-Money Laundering Centre: The Netherlands, 2019[30]). Reportedly, at least 35 offshore shell companies with accounts at this bank were used to move more than four (4) billion US dollars generated through organised crime, corruption and tax evasion (OCCRP, 2019[31]). In the aftermath of these bank scandals, Lithuanian authorities took further steps to improve the country’s anti-money laundering supervision (Sytas, 2019[32]).

However, progress in implementing further reforms is still necessary. As of the latest MONEYVAL follow up report from November 2022, Lithuania is only deemed to be fully compliant on eight (8) of the 40 FATF recommendations (Council of Europe MONEYVAL, 2022[33]). Particular weaknesses remain in relation to five (5) areas in which Lithuania is viewed to be only partially compliant. One of the most significant shortcomings related to the lack of beneficial ownership transparency, which impedes the ability of law enforcement and investigative journalists to detect conflicts of interest that could lead to corruption (OGP, 2022[34]). The VMI also reports that the lack of a beneficial ownership register had hindered tax-related investigations in Lithuania (OGP, 2022[34]).

Amendments in 2019 to the Law on the Prevention of Money Laundering and Terrorist Financing provided a legal basis for a central register of beneficial ownership being set up as a subsystem of the Information System on Members of Legal Entities (JADIS) (Transparency International Lithuania, 2019[35]). However, as no budget was allocated to implement this requirement. Lithuania has been one of the three (3) slowest EU countries to establish a publicly available beneficial ownership register in compliance with the 5th Anti-Money Laundering Directive (Transparency International, 2021[36]). Finally, in August 2022, the sub-system of Beneficial Owners (JANGIS) of JADIS was launched, successfully completing this activity. The OGP has recommended making the data available in open data format, free of charge and without barriers to access. Importantly, it will also be crucial to introduce mechanisms to verify the accuracy of information provided by corporate entities and apply tough sanctions for those who do not provide accurate information in a timely fashion (OGP, 2022[37]).

Overall, not explicitly making a link between the national anti-corruption programme and anti-money laundering efforts was a shortcoming, and this appears to be acknowledged by the 2021 Implementation Review, which concedes that Lithuania exhibits poor resilience to money laundering and that creates conditions for corruption that were not addressed by the NAPC (STT, 2021[8]). Furthermore, during the virtual fact-finding mission, it became apparent that there is a need to improve the exchange of information between the Financial Crime and Investigation Service (Finansinių nusikaltimų tyrimo tarnyba, FNTT) and the STT. In 2019, the STT submitted 0 requests for information related to the identification of beneficial owners of bank accounts held by financial institutions, 2 in 2020 and only 1 in 2021 (Financial Crime Investigation Service, 2020[38]), despite a rapid rise in the number of Suspicious Transaction Reports (STRs) submitted to the Money Laundering Prevention Board at the FNTT, from 541 in 2016 to 3 526 in 2020 (Financial Crime Investigation Service, 2020[38]). The FNTT conducted inspections of 23 companies to assess their anti-money laundering framework in 2020, an area of seeming relevance also to the work of the STT given their mandate to oversee foreign bribery (Financial Crime Investigation Service, 2020[38]). Therefore, the Action Plans could consider including specific measures to improve the co-operation and exchange of information between FNTT and the STT. To do so, bodies that played only a marginal role in the 2015-2025 NAPC, such as the FNTT and the Bank of Lithuania, should be more involved in the implementation. For example, Lithuania could consider how to facilitate greater information sharing and cooperation between the STT and the FNTT, including to facilitate the identification of beneficial owners, especially in cases of suspicious transactions. Finally, in 2022 the FNTT launched an internal project aimed to identify and register politically exposed natural persons and cross reference such information with the list of beneficial owners. Lithuania could further enhance these efforts during the next implementation period.

Foreign Bribery

Lithuania included in its 2015-2025 NAPC acceding to the OECD Anti-Bribery Convention (Seimas of the Republic of Lithuania, 2015[39]) as one of its priorities. This was finally achieved in 2017 (Government of the Republic of Lithuania, 2021[40]). Amendments to the Criminal Code and the Code of Criminal Procedure followed to align legislation with the requirements of the OECD Foreign Bribery Convention (Government of the Republic of Lithuania, 2021[40]). A 2019 evaluation by the OECD Working Group on Bribery (WGB) found that, although the country had made improvements to the legal framework, more attention was needed to ensure effective enforcement of anti-bribery laws with regard to corporate liability and imposing sanctions for foreign bribery, including confiscation. Recent assessments show that enforcement of the OECD Anti-Bribery Convention is still very limited. Notably, as of 2019, no cases have ended in prosecution or sanctions (OECD, 2019[41]). The Organised Crime and Corruption Reporting Project has brought to light cases of Lithuanian companies implicated in foreign bribery cases, that were never investigated nor prosecuted (OCCRP, 2019[42]). Lithuania could therefore increase its enforcement efforts by including in the NAPC and its action plans activities towards ensuring that STT investigators are in an open and constant dialogue with the supervising prosecutor in all foreign bribery cases, as previously recommended by the OECD WGB (OECD, 2017[43]).

Asset recovery

Lithuania’s approach to asset recovery is still rather nascent. In 2010, Lithuania introduced two partially concurring measures, namely criminal liability for illicit enrichment and extended confiscation into the Criminal Code. Since then, the application of extended confiscations in practice is still at an early stage. Lithuania also invested efforts in establishing civil law sanctions. A Civil Asset Confiscation Act entered force in 2020 to allow for the seizing the proceeds of crime, but as yet, efforts to confiscate assets using civil procedures are in their infancy and capacity to conduct the necessary financial investigations to locate criminal assets seems limited (Government of the Republic of Lithuania, 2021[40]). There have been few instances in which property has been confiscated in relation to illicit enrichment and it seems that data on the assets recouped through judicial decisions is not systematically collected (Government of the Republic of Lithuania, 2021[40]). The STT has observed that more progress is needed to improve the effectiveness of the Civil Asset Forfeiture Institute to strengthen the capacity of law enforcement authorities to seize the proceeds of corruption (STT, 2021[8]).

The Lithuanian authorities could therefore consider establishing a unified system to enhance the efficacy of asset recovery. Unexplained wealth orders might be a useful legal instrument in this regard. Lithuanian authorities could additionally strengthen the use of civil forfeiture tools, including non-conviction-based confiscation and extended confiscation in criminal proceedings. To that end, specialised training on illicit enrichment and asset recovery could be developed for investigation officers and members of the judiciary.

Proposals for action

This chapter provides input primarily in the form of recommendations targeting the National Anti-Corruption Agenda’s theory of change, as well as in strengthening the institutional capacity and co-ordinating role of stakeholders involved. Furthermore, the potential for broadening the scope of the NAPC, developing targets and problem analysis are considered. These recommendations may help to inform current and ongoing efforts to strengthen the institutional anti-corruption response in Lithuania.

1. Firstly, Lithuania could strengthen the role of the STT both as a preventive agency and as a co-ordination agency, while mainstreaming integrity policies through the entire public administration, by:

• Following up on the Law on Prevention of Corruption, public institutions and their leadership must increase ownership of integrity measures and mainstream these through their sectors and entities.

• Increase communications and providing feedback to ethics officers in key agencies and line ministries, as it refers to the implementation of the NAPC. This would allow the mainstreaming of policies and the integrity agenda.

• Allowing the STT to use the information gathered for monitoring and evaluation to provide feedback and inform discussions and decision making at the strategic level. As a next step, the co-ordination mechanisms could aim to become automated, for example through standardised forms for the exchange of information.

• Fine tuning the roles of all the actors involved in the 2022-2033 Action Plans, clearly defining the responsibilities, and assigning responsibilities for the implementation of specific actions. For example, by developing a guide to inform implementing actors of the steps for monitoring and the filling of progress reports.

• Strengthening the collaboration between the STT and data register owners by providing a legal framework for such collaboration and exchange of information.

• Ensuring ownership of the NAPC and its forthcoming Action Plans by the implementing entities.

• Developing further awareness raising activities with implementing institutions to assure the necessary institutional ownership over time.

• Continuing and strengthening successful on-going initiatives such as the Integrity Academy.

• Including in the 2022-2033 NAPC and its subsequent plans information on the anti-corruption activity of each public body and publish data on the incidences of corruption identified the outcome of these investigations and the corrective measures taken.

2. Secondly, Lithuania could further develop the vision contained in the 2022-2033 NAPC and build on it in the upcoming Action Plans, including its alignment with a coherent theory of change and expected outcomes, by:

• Defining and creating a more stringent “theory of change”, that could help explain how planned activities will contribute to the achievement of that vision.

• Including a broader diagnosis in thematic areas, explaining why certain priorities were selected or the importance of addressing dormant reforms.

• Deepen the problem analysis in the upcoming Action Plans, to present the interlinkages between the progress targets, the data referenced, the problem root causes and potential areas of improvement.

• Clearly identifying targets and envisaged outcomes in the Action Plans, all aligned with the desired results of a previously established “theory of change”.

• Enhancing the analysis of strategic priorities and linking the challenges with the agenda’s progress targets and envisaged outcomes.

3. Thirdly, Lithuania could further systematise the process of the NAPC, enhance transparency and ensure the continuous engagement of stakeholders across the policy cycle, by:

• Having a wider group of stakeholders consulted for the 2022-2033 Action Plans.

• Provide feedback to civil society organisations and other non-governmental stakeholders on the inclusion of their suggestions.

• Include this same group of actors in the implementation and monitoring of the 2022-2033 Action Plans.

• Providing standardised and more regular guidance to local government for conducting corruption risk assessment.

4. Finally, Lithuania could consider broadening the scope of the 2022-2033 NAPC and Action Plans to include issues not discussed in previous strategies, such as money laundering, foreign bribery, and asset recovery. This could be achieved by:

• Include in the 2022-2033 NAPC and its subsequent Action Plans, specific measures to facilitate greater information-sharing and co-operation between FNTT and the STT.

• Ensure that STT investigators are in an open and constant dialogue with the supervising prosecutor in all foreign bribery cases.

• Facilitating direct access by procurement authorities to corruption convictions of natural and legal persons and ensure effective exclusion from procurement in accordance with the provisions of the Law on Public Procurement.

• Establishing a unified system to enhance the efficacy of asset recovery.

• Strengthening the use of civil forfeiture tools, including non-conviction-based confiscation and extended confiscation in criminal proceedings.

• Developing specialised training on illicit enrichment and asset recovery for investigation officers and members of the judiciary.

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Note

← 1.  Lithuania is a member of MONEYVAL, a FATF-style regional body. MONEYVAL’s fifth round mutual evaluation of Lithuania was adopted on 6 December 2018.