Corporate Liability and Compliance Incentives in Uzbekistan: Lessons from the United States, the United Kingdom and the European Union

Abstract

Uzbekistan has developed an extensive anti-corruption framework, including a statutory compliance service introduced in 2026, yet its preventive duties apply almost exclusively to state bodies and state-owned enterprises. Private companies face neither an obligation to maintain anti-corruption compliance programmes nor any legal benefit for doing so, because Uzbek law does not hold legal entities liable for corruption offences. This article compares how the United States, the United Kingdom and the European Union link corporate liability to compliance: through prosecutorial incentives for self-reporting and effective programmes, through a statutory “adequate procedures” defence, and through criminal or administrative liability with compliance as a mitigating factor. Drawing on UNCAC Article 26 and on German and Italian administrative models, it argues that Uzbekistan can create effective incentives for private-sector compliance without introducing corporate criminal liability. It proposes administrative liability of legal entities for failure to prevent corruption, a compliance defence measured against a published standard, a corporate self-reporting exemption, mandatory internal reporting channels and a phased introduction through public procurement.