经合组织《反贿赂公约》第三阶段立陶宛后续报告：执行《公约》和相关法律文书

Implementing the Conventionand Related Legal Instruments Disclaimers This work was approved and declassified by the Working Group on Bribery in International Business Transactions on9December2025. This document and any map included herein are without prejudice to the status of or sovereignty over any territory, to thedelimitation ofinternational frontiers and boundaries and to the name of any territory, city or area. Photo credits:© Epitavi / iStock / Getty Images Plus. © OECD 2025. Attribution4.0 International (CCBY4.0) This work is made availableunder the Creative Commons Attribution4.0 International licence. By using this work, you accept to be bound by the terms of this licence(https://creativecommons.org/licenses/by/4.0/). Attribution–you must cite the work. Translations–you must cite the original work, identify changes to the original and add the following text:In the event of any discrepancy between the original work and thetranslation, only the text of original work should be considered valid. Adaptations–you must cite the original work and add the following text:This is an adaptation of an original work by the OECD. The opinions expressed and arguments employedin this adaptation should not be reported as representing the official views of the OECD or of its Member countries. Third-party material–the licence does not apply to third-party material in the work. If using such material, you are responsible for obtaining permission from the third party andfor any claims of infringement. Any dispute arising under this licence shall be settled by arbitration in accordance with the Permanent Court of Arbitration(PCA) Arbitration Rules2012. The seat of arbitrationshall be Paris (France). The number of arbitrators shall be one. Table of contents Summary and ConclusionsSummary of findingsConclusions of the Working Group on Bribery 412 Annex A. Follow-Up Report by Lithuania13 Notes72 Summary and Conclusions Summary of findings1 1.In September 2025, Lithuania submitted its Phase3 written follow-up report to the OECD WorkingGroup on Bribery in International Business Transactions (Working Group). The report described Lithuania’sefforts to implement the 49 recommendations and to address the follow-up issues identified during itsPhase3 evaluation of December 2023. In sum, Lithuania has fully implemented27recommendations,partially implemented14and not implemented8. 2.Lithuania is commended for its efforts to address a number of issues.Recommendations to remindprosecutorsregarding confiscation and to monitor the media for foreign bribery allegations have been fullyimplemented.Guidance onpenalorders have beenissued, and allpenal ordersare publicly available.Prosecutor salaries have been increased.The Seimas has been reminded to exercise restraint incompellingthe attendance of theProsecutorGeneralandSTT, and inasking questions aboutspecificinvestigations.The latest national money laundering risk assessment specifically addresses foreignbribery.Several recommendations on detecting foreign bribery through suspicious money launderingtransactionsandthroughaccounting and auditing have also been implemented.The STT, Ministry ofForeign Affairs and Ministry of Justice have disseminated the Phase3 Report. A number of capacity-buildingand awareness-raisingactivities have been held. 3.Nevertheless, theWorking Groupcontinues to have someremainingconcerns.Lithuaniahas takensome steps but stillhas not implementeda priority recommendationtorepealthe requirement that acourtconsider whether a company’s shareholder is culpable before holding the company liable for a crime.Someforeign bribery investigationscontinue toprogress too slowly.An aggrieved whistleblower must still pursuemultiple avenues of redress under theWhistleblower Protection Lawto obtain all the remedies that he/shemay need. Injunctions and interim relief remain unavailable in some cases.Penaltiesforreprisalsagainstwhistleblowerswould remain insufficient even if legislative amendments that have been drafted areenacted. Regarding corporate liability, sanctions and detection 4.Recommendation 1–Not implemented:The Phase3 Report found that a legal person can be heldliable for foreign bribery only if its shareholders are culpable by knowing, encouraging, or tolerating thecommission of the crime. The Working Group thus recommended that Lithuania “urgently enact legislation”to rectify this serious deficiency. Lithuania has since consulted “certain concerned institutions” whichexpressed“some sceptical views”.Nevertheless,a legislative amendment to implement therecommendation has been drafted and was expected to be enactedin2025. This is positive, buttheWorking Group onlyconsiders enacted legislationwhen assessing the implementation of the Convention.The Working Group also urges Lithuania to emphasise to its stakeholders that currentLithuanianlaw oncorporate liabilityas interpreted by the judiciary does not conform to the Convention, and departssignificantly