The report – “Political Graft in Europe on the Loose: Anti-Corruption Legal Frameworks in Comparative Historical Perspective” – was prepared as part of the EU-funded RESPOND project.
In it, the authors conduct a comparative analysis of the legislation of Sweden, the Netherlands, the United Kingdom, France, Italy, Hungary, Bulgaria, Serbia, and Ukraine.
These countries represent two major macro-regions of Europe – Western and Central-Eastern Europe – which differ in their historical experience of democracy, the structure of bureaucracy, and the depth of their anti-corruption traditions. According to the document, Western Europe’s anti-corruption systems evolved bottom-up, through the cultural consolidation of fairness and accountability, whereas in Central and Eastern Europe they tend to develop top-down, driven by external obligations and integration processes. In Southern and post-Soviet countries, legal reforms face persistent clientelist practices, where personal ties and informal agreements often remain stronger than formal institutions.
Assessing the regulation of political corruption in these regions, IGA experts note that the approach focusing mainly on the existence or absence of laws and their degree of enforcement — typical of the positivist-institutionalist theory commonly used to evaluate anti-corruption effectiveness – may be incomplete. It must be complemented by an analysis of a broad range of national contextual factors: cultural-historical, social, and political. Consequently, a regulatory model effective in one jurisdiction cannot simply be transplanted to another, even within the shared institutional space of the EU; both the content and implementation of norms must take into account the socio-political dynamics of each state.
Therefore, the authors frame their analysis of (anti)corruption in the region within a social-constructivist perspective, focusing on two main directions:
- examining long-term cultural and historical processes shaping a country’s anti-corruption environment;
- understanding contemporary legal regimes through the reconstruction of legal norms governing political financing, lobbying, revolving doors, and the media.
This approach allowed the experts to formulate a definition of political corruption that goes beyond the simple “legal–illegal” dichotomy typical of the positivist-institutionalist approach. According to the document, political corruption encompasses actions and behaviors that often occupy “grey zones” of legality but distort decision-making processes and exclude certain groups from political participation. In other words, political corruption includes forms of influence that may not be illegal or criminally punishable but nonetheless undermine public trust and equal participation in democratic politics, damaging the values, goals, and mission of public institutions.
The report identifies four main domains through which political corruption manifests itself: political financing, lobbying, the revolving door, and the media. These forms of corrupt behavior are described as components of “legal corruption,” where the law is not formally violated, yet the actual effects of undue influence are equivalent to bribery, reflecting the close interconnection between wealth and power. Such practices are particularly characteristic of advanced industrial democracies, where legislative systems may deliberately avoid regulating these areas – unlike the clear prohibitions applied to bribery.
The main part of the report contains country profiles of the nine states mentioned above, describing the evolution of their national legal regimes in areas related to political corruption, as well as the influence of cultural and political factors on enforcement effectiveness.
At the first stage of the study, researchers reviewed national laws and strategies regarding the four identified forms of political influence, compiling catalogues for each country describing legislation, oversight bodies, and sanctions for violations. At the second stage, the authors analyzed how these laws are shaped and function within specific political contexts, examining examples of legislative reforms and government inaction, the impact of journalistic investigations, civil society pressure, and international standards, as well as cases where political elites deliberately distort or obstruct legal mechanisms.
*The Institute for Global Analytics (IGA) is a Bulgarian non-governmental organization engaged in research on democracy, media freedom, propaganda and strategic communication, models of public opinion in a pan-European context, and political corruption in digital societies.