Depending on the status of relevant person, subject to anticorruption regulations and type of violation disciplinary, administrative and criminal liability may apply.

Disciplinary actions that may be  imposed on Public Officials are:

• notice;
• reprimand;
• warning of partial professional incompliance;
• demotion of class of Public Official up to 6 months;
• dismissal¹.

Disciplinary action may be imposed by executives of relevant state body where a Public Official is employed and the level of action depends on the character of the offence, prior record and behavior of the Public Official. 

The anticorruption Law provides a comprehensive list of corrupt practices comprising anticorruption violations. However, liability for each particular violation is found either in Administrative Offences Code or in Criminal Code as outlined below. Where respective offence is described in the anticorruption Law but liability is not provided in either Code, it would constitute the basis for disciplinary liability as discussed above.

4.1. Criminal offences and liability

Crimes which entail criminal liability include²:

• abuse of power or official position;
• official's inaction;
• misuse of authority or exceeding official powers;
• forgery;
• negligence; 
• illegal participation in entrepreneurial activity;
• accepting a bribe;
• offering or giving a bribe;
• bribery brokerage;
• illegal enrichment. 

Types of punishment to be imposed for the above crimes depend on gravity and scope of material damage and the nature of crime. The penalties include:

• arrest;
• fine;
• disciplinary labour;
• ban to hold specific positions for the term of up to 3 years;
• seizure of property;
• deprivation of freedom (i.e. imprisonment) for the maximum term of up to 15 years.

Criminal liability may only be imposed on individuals.

4.2. Administrative offences and liability

Administrative liability provided by the Code of Administrative Offences now is envisaged for rather specific offences that do not explicitly qualify for crimes, e.g. unlawful rejection to provide information, failure to comply with mandatory instructions of competition authority, record of false data on credit history etc.

Unlike criminal liability, a legal entity may be held liable for administrative offences when specifically provided by the Code of Administrative Offences, in the event an officer of such entity is imposed with administrative liability the legal entity itself is not exempt from the liability, and vice versa³,

Foreign individuals and foreign legal entities could be held liable for administrative offences.

Administrative penalties include:

• fines;
• official warning (binding cease-and-decease instruction);
• administrative arrest up to 15 days;
• community work;
• prohibition to engage in certain activities or to hold certain positions for specific period of time;
• confiscation of assets;
• recovery of the value of the object of administrative offence (i.e. damages, value of stolen property etc.).

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