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 Convention 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 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 the 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 and Table of contents Summary and ConclusionsSummary of findingsConclusions of the Working Group on Bribery Notes72 Summary and Conclusions Summary of findings 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 its 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 aboutspecific 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 pursue 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 the 5.Recommendation 2(a)–Fullyimplemented:Art.581has been amended toprovidethat a company’scorporate compliance programmewould be considered at sentencing. Criminal Code (CC) Lithuania statesthat “various institutions and researchers”discussedwhether compliance programmescan be imposed aspart of a sentence or non-trial resolution in foreign bribery casesand decided not to amend the legislation. 6.Recommendation2(b)–Partiallyimplemented:This recommendation asked Lithuania totake stepsto ensure that sanctions for foreign bribery imposed in practice are effective, proportionate and dissuasive.Aletter from theProsecutor General’s Office (PGO)to prosecutors and investigatorsdated10June 2025presentedtherecommendation andcoveredthis matter ina fair amount of detail.For judges, training on28May 2025addressedthePhase3recommendations.But the event was only attended by 14 judges.Lithuania explains that the low level of attendance “likely reflects the very low number of foreign bribery 7.Recommendation 2(c)–Fully implementedand converted to a follow-up issue: The10June 2025Prosecutor Generalletter reminded prosecutors and investigators to “determine the material benefitreceived by thebriber, and during the judicial examination of the case, the prosecutor must seek to havesuch benefit confiscated”. At least nine training coursesforprosecutorsand other staff in the Prosecutor 8.Recommendation 3(a)–Fully implementedand converted to a follow-up issue:Since20February2025, an STT officer has been instructed tousean information technology toolbiweekly to search fornewsportals worldwide in English, Russian, French, German andSpanish.The effectiveness of this initiative in 9.Recommendation 3(b)–Fullyimplemented:The Phase3 Report recommended that Lit