In 2026, the question is no longer whether the company has an anti-corruption program. The question is different: can we prove that our decision was legal, transparent and economically justified?
This is exactly what was discussed at the practical webinar “Compliance 2026”.
What has become critically important
Sanctions risk
The check is no longer limited to the counterparty. It is necessary to analyze the ultimate beneficial owners, control, related parties, bank, payment route and end user. Special attention is required for connections with the Russian Federation and the Republic of Belarus and possible schemes for circumventing sanctions.
Integrity of the counterparty
It must be confirmed even before the conclusion of the contract. A sign of risk does not always block the deal, but always requires a documented explanation.
Currency supervision and foreign economic activity
The NBU primarily assesses the economic essence of the transaction. Shell companies are under special attention.
Confidentiality and AI
If a document cannot be sent to a third party, it cannot be uploaded to a public AI service.
Rule of thumb
Every non-standard decision should leave a clear trail:
who conducted the review;
what was discovered;
who approved the decision;
why it was made.
The contract is launched only after the counterparty has been checked, approved by the finance department, and a legal opinion has been obtained. The residual risk is transferred to a higher level of approval.
There is zero tolerance for bribery, kickbacks, and opaque commissions.
Speak Up Algorithm:
STOP → CHECK → DISCLOSE → ASK COMPLIANCE → DOCUMENT
Compliance in 2026 boils down to one key question: can we prove the integrity of our decisions?