The last four years, the country did not have an anti-corruption strategy, with the previous document of this kind spanning the period between 2015 and 2019. The adoption of a new anti-corruption strategy and its implementation plan is a condition for Bosnia and Herzegovina’s joining the European Union.

The Strategy stresses that the anti-corruption activities are being considerably undermined by such factors as:

• Fragmentation of the anti-corruption institutional system;
• Insufficient compliance of the domestic legislations with international standards, including the lack of a number of necessary legal acts/provisions in the existing legal acts;
• Inadequate policy for countering corruption crimes;
• Lack of assessment of the actual effect of public anti-corruption policy;
• Lack of transparency in public decision-making;
• Lack of monitoring of law enforcement against corruption.

The measures formulated in the Strategy are aimed at addressing the challenges identified, also by developing, adopting and introducing anti-corruption instruments, coordinating the activities of public bodies and organisations of the public and private sectors to prevent corruption, effectively detecting and prosecuting corruption crimes, and implementing good practices and international standards.

The Strategy saw the contributions of representatives of both public bodies and international and civil society organisations.

It is based on such principles as:

• Political will to combat corruption;
• Zero tolerance for corruption;
• Systemic reaction to corruption in line with good practices;
• Rule of law;
• Interagency, public-private and international cooperation;
• Responsible implementation of the measures included in the Strategy;
• Continuous systemic measures for combating corruption;
• Transparent activities of the public sector actors;
• Use of the limited resources in the most effective manner;
• Lack of discrimination and respect for the rights and freedoms of citizens.

The document includes the measures for countering corruption distributed over three key areas:

1. Enhanced measures to prevent corruption

This line of action of the Strategy envisages such goals and objectives as:

1.1. Improvement of the legal framework:

• Make amendments to Law of 30 December 2009 No. 103/09 “On Agency for Corruption Prevention and Coordination of the Fight against Corruption” (Zakon o Agenciji za prevenciju korupcije i koordinaciju borbe protiv korupcije) regarding, in particular, improved accountability system and resourcing, as well as enhanced independence of the body;
• Make amendments to Law of 16 December 2013 No. 100/13 “On Protection of Persons Reporting Corruption” (Zakon №100/13 о zaštiti lica koja prijavljuju korupciju u institucijama bosne i hercegovine) taking into account the provisions of Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law and the OECD Recommendation for Further Combating Bribery of Foreign Public Officials in International Business Transactions;
• Make amendments to Law of 19 September 2001 No. 23/01 “On Elections” (Izborni zakon);
• Make amendments to the legal act regulating investigations of financial crimes;
• Put the legal framework on conflicts of interest in line with the recommendations of international organisations, in particular, GRECO, the Venetian Commission, the United Nations and EU standards;
• Adopt legal acts concerning other aspects of corruption prevention: (1) on lobbying, (2) on political parties organisation, in particular, on oversight of political financing and subsequent spending of the funds received, (3) on confiscation and management of confiscated property, including the establishment of the bodies authorised to undertake relevant activities, (4) on transparency of ownership of the media, (5) on the updated Law “On High Council of Judges and Prosecutors”;
• Promote the principles of integrity in public bodies, in particular, by improving codes of conduct for policemen.

1.2. Conflict-of-interest management:

• Prior to amending the legislation on conflicts of interest with the aim to put it in line with the recommendations of international organisations and EU standards, ensure efficient enforcement of existing legal acts, in particular, by establishing a Commission on dismissal due to conflicts of interest and providing it with the necessary administrative and financial independence, as well as creating and improving the functional software for detecting conflicts of interest;
• Develop guidance on managing conflicts of interest for officials;
• Strengthen interagency cooperation in investigation of potential conflicts of interest;
• Publishing asset declarations and Gifts Register and providing open access to them.

1.3. Compliance:

• Promote the principles of integrity in the private sector also by organising training, developing codes of conduct and appointing compliance officers.

1.4. Management of public finances:

• Implement financial management in the administration of public finances and ensure control over expenditure of public finances;
• Define precise criteria for allocating public funds;
• Detect corruption risks in public procurement and adopt mitigation measures;
• Raise awareness of the heads of public bodies and organisations about their personal responsibility for the decisions taken with regard to the expenditure of public funds;
• Establish an authority responsible for protecting the financial interests of the country and the EU;
• Publish information on expenditures of the public budget funds and provide open access to it.

1.5. Participation of society:

• Enhance transparency of activities of the public sector actors by introducing digital technologies, in particular, by creating an open Register of corruption risks;
• Undertake measures for raising public awareness about corruption, including workshops, conferences etc.;
• Provide open access to the information on public financing of the media;
• Assess the effectiveness of enforcement of Law of 30 August 2023 No. 61/23 “On Freedom of Access to Information at the Institutional Level” (Zakon o slobodi pristupa informacijama na nivou institucija Bosne i Hercegovine).

1.6. Anti-corruption education:

• Undertake educational measures for promoting the principles of integrity and countering corruption for officials, children and the youth, also under the Global Resource for Anti-Corruption Education and Youth Empowerment (GRACE Initiative);
• Organise regular training on ethics and integrity for judges.

2. Improved mechanisms for detecting and proving corruption crimes and liability for their commission

In this area, the document outlines the following objectives:

2.1. Build the potential of courts, law enforcement and other bodies:

• Conduct training on detecting and proving corruption crimes with the focus on using special investigative techniques, on investigation of financial crimes and confiscation of property;
• Improve ethical requirements for law enforcement officers and court servants;
• Enhance the efficiency of processing auditors reports;
• Improve the provision of resources to the divisions for investigation of corruption crimes and control of compliance with ethical requirements;
• Improve the reporting system for monitoring of effectiveness of investigation of corruption crimes, from indictment to the conclusion of criminal procedures;
• Analyse the case law on corruption-related cases and performance of the authorities responsible for investigating “grand corruption”;
• Establish a Department for corrective action based on the reports of the High Council of Judges and Prosecutors;
• Improve the exchange of information among the police, tax bodies, courts and other public bodies, as well as interoperability of the police with the prosecution authorities and other entities;
• Improve the mechanism for managing confiscated assets, in particular, by creating electronic databases of such property and its use in public interest.

3. Enhanced interagency, regional and international cooperation

In this area, the Strategy sets such objectives as:

3.1. Interagency cooperation:

• Create an authority responsible for implementing corruption prevention measures, including coordination of interagency interaction;
• Strengthen interagency cooperation also by concluding agreements and memoranda;
• Adopt plans to promote the principles of integrity and countering corruption in public bodies in line with the Strategy;
• Create a team of trainers consisting of representatives of the bodies responsible for preventing corruption;
• Analyse experience and challenges in implementing strategic anti-corruption documents and establish single standards for strategic planning based on the findings;
• Monitor and assess the effectiveness of implementation of the Strategy and draft the next strategy.

3.2. Regional and international cooperation:

• Strengthen international and regional cooperation with the organisations active in combating corruption and investigating corruption crimes;
• Join the Global Operational Network of Anti-Corruption Law Enforcement Authorities (GlobE Network);
• Enhance participation in the European Partners against Corruption (EPAC) and the Anti-Corruption Network for Eastern Europe and Central Asia.

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Monitoring and assessment of effectiveness of implementation of the Strategy will rest with the Agency for Corruption Prevention and Coordination of the Fight against Corruption (Agencija za prevenciju korupcije i koordinaciju borbe protiv korupcije).