{"text_format":"2","workbook":"xlsx","n_sheets":2,"sheets":["Coversheet","Lex Mundi Global Anti-Corruptio"],"not_rendered":{"charts":0,"images":1,"macros":0,"external_links":0,"defined_names":0,"comments":0,"pivot_tables":0},"unopened":[],"bounds":{"document_bytes":16777216,"sheet_cells":100000,"run_cost":"one","rows_first":2000,"rows_last":500,"rows_between":2000,"halvings":0,"cell_chars":16384,"cell_head_chars":4096},"cells_cut":0,"cells_raw":0,"read":"whole","date_system":"1900"}

{"sheet":"Coversheet","index":0,"n_rows":12,"n_cols":3,"rows_kept":12,"cut":false,"hidden":false,"merged":[]}
[]
[]
[null,"Prepared By:","Contributors:"]
[null,"Ellex Valiunas","Jaunius Gumbis"]
[]
[]
[]
["Lex Mundi Global Anti-Corruption Compliance Guide"]
[]
["Report Generated: 11/19/2025"]
[]
["View your report results on next tab"]

{"sheet":"Lex Mundi Global Anti-Corruptio","index":1,"n_rows":13,"n_cols":2,"rows_kept":13,"cut":false,"hidden":false,"merged":[]}
["Question","Lithuania"]
["Anti-Corruption Compliance"]
["What is the key anti-bribery and corruption legislation in your jurisdiction?"," The key international conventions to which Lithuania has acceded: \n\n \n\t The United Nations Convention Against Corruption (New York, October 31, 2003);   \n\t The United Nations Convention Against Transnational Organised Crime  (New York, November 15, 2000); \n\t The Council of Europe Criminal Law Convention on Corruption (Strasbourg, January 27, 1999); \n\t The Council of Europe Civil Law Convention on Corruption (Strasbourg, November 4, 1999); \n\t The Council of Europe Convention on Laundering, Search, Seizure and Confiscation of the Proceeds from Crime (Strasbourg, November 8, 1990); \n\t The OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Paris, November 21, 1997); \n\t The Convention on the fight against corruption involving officials of the European Communities or officials of Member States of the European Union (Brussels, May 26, 1997). \n \n\n The key national legislative framework in Lithuania first and foremost is based on the Criminal Code of the Republic of Lithuania. Also, this field is regulated by the Law on the Prevention of Corruption, Law on the Adjustment of Public and Private Interests, Law on Funding of Political Parties and Political Campaigns and Control of Funding, Law on Criminal Reconnaissance, Code of Administrative Offenses and Civil Code of the Republic of Lithuania. \n"]
["Has there been a specific anti-bribery and corruption law enacted in your jurisdiction in the last ten years?","Yes, from January 1, 2020, a new wording of the \nLaw on the Adjustment of Public and Private Interests came into effect. The main change – in general, all declarations of public and private interests of all persons who have an obligation to provide such declarations became public (before 2020 only about 40 percent of such declarations, which were provided mainly by high-level officers, were public). Also, an obligation to declare interests was set to a wider range of persons. A new list of requirements that shall be declared was introduced with the main change to declare all transactions above EUR 3,000 that may give rise to conflicts of interest. In general, all these changes are intended to give to the public more opportunities to monitor whether the representatives of civil service appropriately balance between public and private interests and how transparent are decisions adopted by them.\n"]
["Is a bribe payment to domestic government officials prohibited by the legislation?","Yes. According to Article 227 of the \nCriminal Code of the Republic of Lithuania,it is prohibited for a person directly or indirectly, by themselves or through an intermediary, to offer, promise or agree to give a bribe to a public servant (or a person comparable to him), or to a third person for an act or inactivity of a public servant (or a person comparable to him) in the exercise of his powers.\nAccording to \nArticle 230 of the \nCriminal Code, the notion of ‘public servant’ encompasses state officials, politicians, judges and other persons who perform functions of a representative of the government or have administrative powers, as well as official candidates for these duties.\nIn general, Lithuanian legislation provides a large selection of subjects covered by \nArticle 227.\nFor example, the concept of “a person comparable to a public servant” is significantly broader. The definition involves persons who perform functions of a representative of the government (judicial, administrative) or otherwise ensure the implementation of the public interest by working in a foreign state institution or body of the European Union, an international public organization or an international / European Union judicial institution. \nMoreover, “a person comparable to a public servant” in some situations may mean a person who is employed (or in another legal way performs duties) in a public or private legal person or another organization. \n\n\n \n"]
["Is a bribe payment to foreign government officials prohibited by the legislation?","Yes. A foreign official would be considered as a person comparable to a public servant. \nAccording to \nArt. 230 of the \nCriminal Code, civil servants are equated to persons who, regardless of their status in accordance with the legislation of a foreign state or international public organization, perform the functions of a government representative, including the judiciary functions, hold administrative powers or in other ways ensure execution of public interest while working or under different basis being in office in the institution of foreign country or EU, international public organization, international or EU judicial institution, legal entity or any other organization controlled by a foreign country, also official candidates for such office. The foreign state is considered as any foreign territory, despite its legal status, and encompasses levels and areas of management. \n"]
["Is requesting or accepting a bribe prohibited by the legislation?","Yes. The \nCriminal Code of the Republic of Lithuania (\nArticles 225 and \n227) establishes the concept of active corruption (offering a bribe or agreeing to pay a bribe, \nArt. 227) and passive corruption (asking for or accepting a bribe, \nArt. 225). \nPassive corruption. \nArticle 225 of the \nCriminal Code prohibits public servants or equivalent persons, for their own benefit or for the benefit of other persons, by themselves or through an intermediary from directly or indirectly promising or agreeing to accept a bribe, or requesting or provoking to give a bribe, or accepting a bribe for a lawful or unlawful act or omission in the exercise of his power. \nActive corruption. According to \nArticle 227 of the \nCriminal Code, it is prohibited for a person directly or indirectly, by themselves or through an intermediary, to offer, promise or agree to give a bribe to a public servant (or a person comparable to him), or to a third person for an act or inactivity of a public servant (or a person comparable to him) in the exercise of his powers. \n"]
["Who is subject to the legislation?","Natural persons and legal persons are subject to criminal liability for a\nctive corruption (for bribery, corruption, and trading in influence).\nAccording to \nArticle 20 of the \nCriminal Code, a legal person is liable for criminal acts committed by a natural person if the criminal act was committed for the benefit or in the interests of a legal person by a natural person acting individually or on behalf of a legal person, if they were entitled by their managerial position in that legal person to (i) represent a legal entity; (ii) make decisions on behalf of the legal entity, or (iii) control the activities of a legal entity.\nA legal person may be held liable for a criminal offense also if it has been done by an employee of the legal person or an authorized representative for the benefit of that legal person by an order or authorization of a person in a managerial position or due to inadequate supervision or control. \nIn some situations, legal persons may also be liable for criminal offenses committed by their subsidiaries. \nSubjects of the prohibition of passive corruption (asking for or accepting a bribe) are public servants (for a more detailed explanation please see the answer to “\nIs a bribe payment to domestic government officials prohibited by the legislation?”). \nAlso, please note that according to \nArticle 230 of the \nCriminal Code, a person shall be considered as equivalent to a public servant if he/she is an employee in a private body or is engaged in professional activities under different basis and if he/she holds appropriate administrative powers or has the right to act on behalf of this body or provide public services. Therefore, these persons are also subject to criminal liability for passive corruption. \n\n\n \n"]
["Is there criminal liability for corporate entities who have either paid or accepted a bribe payment?","Yes, there is criminal liability for corporate entities who have either paid or accepted a bribe payment, see the answer to \n\"Who is subject to the legislation?\".\n"]
["What is the penalty for individuals violating the law?"," Penalties for individuals vary according to the committed action and the size of the bribe. For the corruption the following penalties may be imposed: (i) arrest – short-term imprisonment for up to 90 days; (ii) monetary penalty; (iii) imprisonment. \n\n All monetary fines may slightly vary from time to time because they are calculated taking indicators based on the country’s economic situation (e.g. minimal standard of living).  \n\n Below please find examples of possible penalties: \n\n \n\t accepting/giving a bribe for a legal action – a fine up to EUR 200,000, arrest or imprisonment up to 4-5 years may be imposed; \n\t accepting/giving a bribe for illegal action – a fine up to EUR 300,000, arrest, or imprisonment up to 5-7 years. \n \n\n Notwithstanding the above listed maximum fines, please note that the fine provided for taking bribes, trading in influence, graft may not be lower than the amount of the material damage caused by the perpetrator or the amount of property received (wanted to be received) by the perpetrator to obtain for himself or another person. \n  \n"]
["Assuming corporate entities are liable for violating the legislation, what is the penalty for corporate entities violating the law?","A fine between EUR 10,000 and EUR 5,000,000 may be imposed on corporate entities. The court can also impose a limitation on the activity of a legal person (in certain areas, e.g. finance or audit) or liquidation of a legal entity.\nNotwithstanding the maximum fines, please note that the fine for corruption activities may not be lower than the amount of the criminal offense, the material damage caused by the perpetrator or the amount of property received (wanted to be received) by the perpetrator to obtain for himself or another person. It means that if a bribe was, for example, EUR 7,000,000 then a fine shall be of the same amount.\nFurthermore, according to legal acts, information about legal entity’s corruption actions shall be published publicly.  \n\n\n \n"]
["Assuming corporate entities are liable for violating the legislation, does having a compliance program designed to prevent bribery constitute a defense?","An anti-corruption program is one of the most effective ways to show the transparency of the organization and zero tolerance to bribery and any other form of corruption. While an anti-bribery program is a strong argument for defense, it is not absolute and does not completely defend the organization from criminal liability.\nHowever, when assessing the liability of a legal person, other factors, such as corruption prevalence or anti-corruption education for employees should be taken into account.\n\n\n \n"]
["Assuming corporate entities are liable for violating the anticorruption law, is it possible for a corporate entity to reach a deferred prosecution agreement or leniency agreement with the enforcement authorities?","Theoretically, it is possible, but practically hardly probable. The majority of rules regarding exemption from criminal responsibility, suspended sentence, and waiver of penalty for legal entities are designed for natural persons. Legal entities could be exempted from criminal responsibility for example when a person or a criminal act has lost its danger (\nArticle 36 of the \nCriminal Code) or when the criminal act is of little significance (\nArticle 37 of the \nCriminal Code).\n"]