WP4
Building the EU Anti-Corruption Framework
Watch the full recording of our Erasmus+ seminar hosted by UNWE, featuring experts from across Europe. Learn how anti-corruption policy is evolving within the EU—and how education plays a key role in shaping a more transparent future.
Full transcription below.
Chief Assist. Prof. Dr. Atanas Dimitrov:
Good morning everyone. I’m more than happy to welcome everybody here. We are now starting this webinar under the Erasmus+ project: “Analysis of the Open Access Anti-Corruption Education Landscape and National, EU, and International Anti-Corruption Frameworks.”
We have guests from Italy, Croatia, and Greece. Without any further ado, I would like to give the floor to the Rector of the University of National and World Economy, Professor Dr. Dimitrov, for his welcome speech.
Prof. Dr. Dimitar Dimitrov:
Dear participants in this seminar, I hope our infrastructure will cope with the online airing of this webinar. Welcome, both virtually and in person, to the University of National and World Economy.
The topic of anti-corruption is very important and has been developing significantly in recent years. We would like to continue this work together with our partners under the Erasmus+ framework, with participation from Bulgaria, Croatia, Italy, and Greece. These are local partners, but the most important thing is that they are also EU partners.
Efforts directed toward anti-corruption initiatives should be continuous. For many years, there has been the view that anti-corruption efforts should be implemented in legislation and studied by students in law departments. But as you know, this is a complex issue. It requires combined efforts from judicial, economic, sociological, psychological, and other disciplines in order to prevent and fight corruption effectively.
At our university, we began such initiatives in 2016 through agreements with national anti-corruption agencies, including the Parliamentary Anti-Corruption Commission. We created an Anti-Corruption Academy and presented lectures with leading experts from the Ministry of Interior, anti-corruption agencies, and the prosecutor’s office.
However, this is not enough. Although we launched a master’s program on anti-corruption, it did not continue successfully. This is a long-term process, and we need sustainable efforts in this field. I’m happy that we are renewing these efforts. Maybe we can even discuss the establishment of a local or regional anti-corruption academy with the joint efforts of our Southeastern European partners.
This is important: to include training, education, and a common curriculum directed toward anti-corruption and the dissemination of its results. This issue is crucial. Sometimes it seems like there are only minor violations or bad practices, but in many cases—as a popular slogan says—“corruption kills.”
Corruption kills when roads are built poorly, when bribes are paid to police or politicians, and when buildings collapse during earthquakes due to poor construction. We all suffer from these things.
I wish success to this very timely and interesting webinar. With the presence of our guest Professor Teresa Russo, I hope there will be fruitful results. Thank you for your attention.
Chief Assist. Prof. Dr. Atanas Dimitrov:
Thank you, Professor Dimitrov. I would now like to give the floor to Professor Spasov, the international project leader.
Assoc. Prof. Dr. Svetoslav Spassov:
Thank you, Professor Dimitrov.
We welcome our colleague, Professor Teresa Russo. You were muted—do you hear me now?
Yes? Perfect.
I would like to welcome Professor Teresa Russo to the University of National and World Economy. As our Rector, Professor Dimitrov, mentioned, our university has experience in anti-corruption education. We began our cooperation with the UNODC in Vienna back in 2016.
From those early years, we also built partnerships with colleagues from Greece and Croatia. I would now like to briefly present our master’s program in anti-corruption. We were the first university in Bulgaria to implement such a pilot program.
We signed a memorandum of cooperation in the field of anti-corruption. The memorandum was signed between the UNODC and the National Council for Anti-Corruption Policies of the Republic of Bulgaria. We officially started the program on March 1st, 2018.
Here you can see some photos from the launch. Professor Dimitrov and I attended the official ceremony in December 2015. The Deputy Prime Minister also supported our program.
There were many activities at the beginning of the program—public lectures, high-level speakers, and institutional support from the prosecutor’s office, the agency for confiscation of illegal assets, the State Financial Inspection Agency, and the Audit Office.
Our curriculum is quite comprehensive. I won’t go into detail, but we set up a national academy at the university. Its aim is to promote the fight against corruption through lectures, events, conferences, and practical training.
However, we faced difficulties—especially during the COVID period and the political crisis in Bulgaria from 2021 to 2024. Many governments changed during that time, and this made it hard for the academy to continue growing.
Since 2018, more than 50 students have graduated from our master’s program. With our new Erasmus+ project—“Development and Implementation of Anti-Corruption Education Programs for Universities in Bulgaria, Greece, and Croatia”—we want to go one step further. We want to create an international master’s program for Southeastern Europe.
Why not even go beyond Bulgaria, Greece, and Croatia? Let’s include Italy, Serbia, North Macedonia, Albania, and others. Professor Russo has strong expertise in this region and is already developing educational programs across Balkan countries. So, even though Italy is not part of the Balkans geographically, your participation is very welcome and very logical.
Thank you very much.
I would now like to give the floor to Professor Teresa Russo from the Department of Legal Sciences at the University of Salerno.
Professor Teresa Russo:
Good morning.
Thank you very much. I’d like to express my gratitude to the Rector of the University of National and World Economy, Professor Dimitrov, and to Professor Spasov, as well as to Professor Atanas Dimitrov, Professor Anamaria Musa from Croatia, and Professor Dimitris Ziouvas from Greece for inviting me to participate in this very interesting project.
This project aligns with the topics I work on through my Jean Monnet Chair, which focuses on promoting public awareness on EU enlargement policy, values, and the Western Balkans.
Thank you also for the proposal from Professor Spasov. I welcome this type of initiative—one that promotes education and EU values simultaneously.
Thank you again. I’ll now share some thoughts, along with a few slides, on the anti-corruption framework of the European Union (EU), the need for its update, and a more systemic approach.
As many of you know, the EU came relatively late to defining its own anti-corruption strategy compared to other international organizations. In fact, it’s still defining it—hence the title of today’s seminar: “EU Anti-Corruption Framework in the Making.”
This delay is mainly due to the nature of the EU’s supranational legal system, which initially didn’t grant it explicit competence over anti-corruption matters.
[Legal Background and Evolution]
The legal basis for EU anti-corruption efforts began with the Treaty of Maastricht. It was part of the so-called Third Pillar on Justice and Home Affairs and treated corruption as a matter of common interest among member states. The approach was intergovernmental in nature, using framework decisions.
We saw the first EU policy against corruption in a 1997 communication from the European Commission. It wasn’t until the Treaty of Lisbon that the EU gained clear legislative power in this area.
According to Article 67(3) of the Treaty on the Functioning of the European Union (TFEU), the EU shall work to ensure a high level of security by preventing and combating crime and by approximating criminal laws. Article 83(1) includes corruption among the serious cross-border crimes for which the EU can legislate.
[Current Framework]
The current EU anti-corruption framework is complex and fragmented. It includes two main legislative instruments:
The 1997 Convention on the fight against corruption involving EU or national officials.
The 2003 Framework Decision on combating corruption in the private sector.
In addition, there are other directives and legal tools dealing with public procurement, money laundering, fraud against the EU budget, asset freezing and confiscation, and whistleblower protection.
We also have supporting bodies such as OLAF (the anti-fraud office), Europol, Eurojust, the European Public Prosecutor’s Office (EPPO), and several non-legislative strategies—like the Security Strategy and the Rule of Law Reports.
[Why We Need an Update]
This fragmented situation led the European Commission to propose a new anti-corruption strategy in May 2023. The aim is to make EU anti-corruption efforts more coherent and effective.
Organized crime often uses corruption to infiltrate public and private sectors. The Commission identified high-risk sectors like health, transport, construction, defense, agriculture, food, and social services.
The new strategy emphasizes prevention and education. For example, it promotes:
Transparency
Ethics and integrity
Regulation of lobbying and revolving doors
Risk mapping
Anti-corruption networks
National reforms and external EU actions
[Proposed EU Anti-Corruption Directive]
The most important element of the package is the proposed directive that:
Harmonizes definitions and sanctions across EU countries
Updates older instruments like the 1997 and 2003 measures
Aligns with international standards (especially the UN Convention against Corruption)
It also cross-links with other laws—on fraud, money laundering, and whistleblower protection—and seeks to reduce inconsistencies among national definitions that hinder cross-border cooperation.
The directive includes provisions for preventive bodies in each member state and a minimum level of penalties. It respects subsidiarity and proportionality under EU law, aiming to add value without overstepping national traditions.
[Parliament and Council Positions]
In February 2024, the European Parliament adopted its position, pushing for:
More emphasis on democratic protection and transparency
Reparations for victims of corruption
Broader definitions of offenses (like political misconduct)
Stronger rights for civil society to participate in cases
The Council, however, took a more conservative stance in June 2024. It:
Limited certain offenses
Weakened language from “shall” to “may”
Lowered penalties
Extended transposition deadlines from 18 to 36 months
Softened the obligation to lift immunities
So, the Parliament and Council positions differ, and this affects final negotiations.
[Concerns from Member States]
Member states expressed concerns about:
Broad or vague definitions like “undue advantage” or “public interest”
Potential conflicts with national legal traditions
Bureaucratic burden on companies
Political misuse of the law
Lack of resources for implementation
On the other hand, the European Parliament is concerned about:
Weak preventive measures
No common standards for lobbying or revolving doors
No guaranteed resources for enforcement
That’s why, earlier this month, Transparency International and other civil society groups issued an open letter urging the Council and Parliament to support stronger rules in line with Parliament’s position.
To conclude, the proposed EU anti-corruption directive represents the first truly comprehensive approach to the issue within the Union. That alone makes it worthy of support.
Some key benefits include:
Legal consistency across borders, making it easier to investigate and prosecute corruption.
Stronger deterrence, with harmonized sanctions to reduce loopholes.
Improved public trust, by demonstrating EU-level commitment to transparency.
Better protection of the EU budget, ensuring fair competition and more effective use of funds.
What’s new and especially important is the recognition of “strategic corruption”—where personal gain is not the main goal. Instead, it’s used to destabilize states and shape foreign policy outcomes. This is a serious threat to EU internal and external security.
That’s why the 2023 Anti-Corruption Package also includes a proposal for a Council decision on restrictive measures against serious acts of corruption that harm the EU’s interests or foreign policy goals. This is part of a growing trend to address corruption not just internally but globally.
In April 2024, the Commission presented a new internal security strategy: “Protect the EU.” It calls for cooperation between citizens, businesses, civil society, and law enforcement to prevent corruption and organized crime.
Importantly, the EU is also linking anti-corruption with enlargement policy. Candidate countries must meet strict rule-of-law and anti-corruption standards to progress toward membership. The Commission monitors these through annual Rule of Law and Enlargement Reports.
Countries like Albania, Serbia, Montenegro, and North Macedonia are now included in these evaluations. The Commission wants to see alignment with Chapters 23 and 24 of the acquis (Judiciary and Fundamental Rights; Justice, Freedom, and Security).
Additionally, the EU’s €800 billion defense spending initiative now faces pressure to integrate anti-corruption standards, especially in procurement.
To wrap up: The fight against corruption must be embedded in both internal reforms and foreign policy, using law enforcement, education, and civic engagement. That’s how we build a more transparent, fair, and secure Europe.
Thank you very much for your attention. I’ve also shared my academic contact details and links to my publications, should anyone want to stay in touch.
[Q&A and Panel Discussion]
The floor is now open for questions. Online participants are invited to raise their hands or write in the chat.
A few questions are directed to Professor Russo:
On the Southeastern European Anti-Corruption Academy:
She supports the idea and emphasizes the importance of a multidisciplinary, regional effort. Such an academy could serve both candidate countries and EU members and would be particularly useful for promoting shared standards.
On deeper cooperation between countries:
She highlights the enthusiasm of students and institutions in the Balkans to work with Western partners and stresses the need for education, communication, and civil society engagement.
[Professor Anamaria Musa – University of Zagreb]
Professor Musa takes the floor to speak on the role of preventive mechanisms.
She argues that most of the proposed directive focuses on criminal law, while prevention mechanisms are underdeveloped.
She splits preventive tools into two categories:
Soft mechanisms: e.g., conflict of interest, access to information, lobbying regulation, asset declarations.
These lack strong EU enforcement mechanisms. Member states are left to regulate them independently.
Harder mechanisms: e.g., whistleblower protection, public procurement transparency, anti-money laundering rules.
The EU has taken a firmer stance here, requiring national laws and networks.
She points out the uneven quality of legislation across countries, and the lack of political commitment to transparency in many states. Even in countries with laws on paper, public awareness and enforcement are often low.
For example, it took over 10 years for the Council of Europe’s convention on access to documents to come into force. This shows just how slowly political will can move.
[Professor Dimitris Ziouvas – Panteion University, Athens]
Thank you very much.
I’ll focus on one specific topic: illicit enrichment, and whether it is (or should be) criminalized in EU member states. This is a revealing case study of how fragmented the EU’s anti-corruption framework remains.
Illicit enrichment is defined by the UN Convention Against Corruption (Article 20) as a “significant increase in the assets of a public official that cannot be reasonably explained in relation to their lawful income.”
The issue here is proof: with illicit enrichment, the burden is partially shifted to the accused. The prosecution only has to show a disproportionate increase in wealth. The defendant must then explain where it came from. This conflicts with some core EU legal principles—especially the presumption of innocence and the right to remain silent.
So, although the UN convention allows states to criminalize illicit enrichment, it leaves it optional—and many EU countries have opted not to.
Out of 27 EU member states:
Only 18 have a criminal offense for illicit enrichment.
9 member states (including Greece) do not criminalize it at all.
Greece adopted it briefly in 2010 with a penalty of up to 5 years (or 10 years for amounts above €73,000), but it was abolished just 4 years later, in 2014. Today, there have been no final convictions in Greece for illicit enrichment.
Why is this important? Because in practice, illicit enrichment laws are extremely useful. They help law enforcement target corrupt officials even if they can’t prove the exact original crime (e.g., bribery). They are a powerful shortcut—which also makes them controversial.
Now, let’s look at Article 13 of the proposed EU directive, which is titled “Enrichment from Corruption Offenses.” Does it criminalize illicit enrichment?
Not quite.
It criminalizes the “acquisition, possession, or use of property by a public official who knows it comes from corruption.” But that’s essentially a subset of money laundering. The key difference: it still requires proof of the property’s corrupt origin.
Therefore, the proposed directive does not include true illicit enrichment, where no link to a specific offense needs to be proven.
To conclude: if we want real harmonization, we need to bravely address illicit enrichment. It’s not easy. But it would close major gaps in EU enforcement, especially in countries where asset recovery has failed.
[Audience comment from University of Zagreb]
A colleague comments: prosecutors would love to have illicit enrichment laws—it makes their job easier. But many judges and lawyers oppose them for good reasons. Without safeguards, these laws could undermine due process.
[Professor Sunčana Roksandić – University of Zagreb]
Thank you. I’d like to offer a broader reflection.
What do we want to achieve with the directive?
If we are serious about tackling grand corruption, we should treat it as something closer to an international crime. In 2018, the UN Security Council even recognized corruption as a threat to international peace and security—citing Venezuela.
Let’s not forget: corruption during war, during transition periods, or in defense sectors has severe consequences. It can destabilize entire regions.
Some have argued for a special international anti-corruption court. I’m not necessarily saying that’s the best path, but we need to think bigger.
Croatia is a good example. After the war and privatization period, we passed a law to prosecute economic crimes from the 1990s. But it came too late—and produced almost no convictions. This shows the importance of acting quickly, and having the right legal tools in place.
We also need to align our definitions and sanctions across the EU, particularly for crimes like:
Abuse of function
Influence trading
Illicit enrichment
Some of these are optional under UN law, but we have a chance to make them mandatory under EU law.
We’ll soon publish a special issue in the International Criminal Law Review with ten articles on grand corruption. I hope it helps push the conversation forward.
[Dr. Emanuele Vanata – University of Salerno]
Thank you. I’d like to connect anti-corruption to two other urgent EU policy areas: environmental sustainability and energy policy.
Corruption directly undermines both. It:
Distorts environmental impact assessments
Enables illegal waste dumping and toxic emissions
Inflates renewable energy subsidies
Increases household energy costs
Undermines climate resilience and disaster relief
For example, after the 2023 floods in Emilia-Romagna, Italy, anti-corruption controls were critical in preventing the misallocation of reconstruction funds.
EU treaties already link these areas:
Article 2: values of democracy and rule of law
Article 3: sustainable development and well-being
Article 191: environmental protection
Article 194: energy policy
Article 325: protection of EU financial interests
The EU has recently updated its Environmental Crime Directive, passed a new Anti-Money Laundering Regulation, and proposed the anti-corruption directive we’ve discussed today.
But implementation is key. We need:
Digital traceability systems for public spending
Cross-border alerts for suspicious investments
Open public procurement platforms
Citizen participation and whistleblower protection
The green transition must be fair and transparent, not captured by corrupt interests.
[Closing Q&A and Final Contributions]
Following the expert presentations, the moderator invites any final questions or comments from participants, especially those online.
A participant from the University of Zagreb adds:
“Corruption is often seen as just a governance problem, but it directly impacts human rights, democratic institutions, and even peace and security. We need to broaden our thinking—this is no longer just about small-scale misuse of power. The EU has a historic opportunity to lead.”
[Professor Spasov – Final Remarks]
Thank you to all our speakers and partners.
I’d like to extend special thanks once again to:
Professor Teresa Russo and her team from the University of Salerno
Professor Dimitris Ziouvas, Professor Anamaria Musa, and Professor Sunčana Roksandić for their thoughtful presentations
Dr. Emanuele Vanata, whose reflections on the environmental and energy link added another vital dimension
Your participation has made this seminar extremely meaningful and constructive.
We are currently working under Work Package 3 of our Erasmus+ project, which focuses on developing open-access digital anti-corruption education materials for universities in Bulgaria, Greece, and Croatia.
We have already completed:
Work Package 2 – A full comparative legal analysis of national, EU, and international anti-corruption frameworks, delivered collaboratively by our academic partners
And now we are launching Work Package 4, which involves:
Producing expert interviews and podcasts
Engaging with practitioners, professors, and legal experts across Southeastern Europe
Disseminating knowledge to both students and the wider public
As Professor Russo suggested earlier, we now have the momentum—and perhaps even the basis—to establish a Southeastern European Anti-Corruption Academy.
This academy could provide:
Joint curriculum development
Faculty exchange
Policy coordination
Long-term research into corruption prevention and prosecution
Let’s make this happen.
[Final Note and Group Photo]
Before we close, we’d like to invite all participants to turn on their cameras so we can take a group photo to mark this successful online meeting.
Thank you again for being part of this event. We look forward to working together as we continue developing and implementing anti-corruption education programs across Southeastern Europe.
Have a wonderful day, and see you at the next seminar.
Goodbye!