Compliance Under Fire: Building Ukraine’s Integrity Amid War

Tomasz Kruk
Sep 30, 2024
11 min read

Updated: Dec 3, 2024

Amid the war, Ukraine faces two critical tasks: defending its borders and planning for the nation’s recovery. Now is the time to intensify efforts in transparency and anti-corruption, leveraging proven, verified methods to lay the groundwork for a stable and resilient post-war future. This is also the moment to consider bold, innovative approaches—ones that have not been tested.

Introduction: Setting the Stage for Ukraine's Recovery

All wars eventually end, and as Ukraine’s conflict nears its conclusion, planning for the future becomes critical. This phase is about more than rebuilding physical structures; it’s about redefining Ukraine’s national identity, securing independence, and strengthening ties with the European Union.

However, reconstruction faces a major hurdle: entrenched corruption, or systema, which has long impeded progress. Transparency and integrity are essential—not just to gain international trust but to meet the high standards expected by Ukraine’s Western allies.

With the influx of aid, successful rebuilding will hinge on compliance frameworks aligned with global standards. These programs provide not only ethical safeguards but also a strategic advantage, enabling Ukraine’s integration into Western economies. Adherence to these compliance standards goes beyond a corporate requirement—it is vital for Ukraine’s future, impacting all public, local, and regional institutions.

A unique opportunity also exists to reintegrate veterans—those who defended Ukraine—back into society. Veterans bring discipline, resilience, and a strong sense of duty, qualities that are invaluable in enforcing compliance and countering corruption. Their presence in these roles not only honors their service but strengthens Ukraine’s defenses against systemic corruption.

This reconstruction phase offers Ukraine a rare chance for lasting reform. By empowering veterans to lead in compliance roles, Ukraine can instill a zero-tolerance culture for corruption. This requires a robust, independent compliance infrastructure, led by individuals unwavering in their commitment to transparency. Veterans and their families, with their deep investment in the nation’s future, may be the ideal leaders to drive this transformation.

I am not a politician, strategist, diplomat, or engineer—I’m a compliance professional. With 20 years of experience across Eastern and Central Europe, including Ukraine, Russia, and the Balkans, I aim to share my insights on compliance in challenging environments. My goal is to contribute to Ukraine’s rebuilding by sharing what I’ve learned from regions that balance reform and regression.

Ukraine’s Window of Opportunity for Lasting Reform

Snow fell softly outside, covering Switzerland in a quiet, white stillness. Inside, my home was filled with warmth—laughter, friendship, and the deep crimson of good wine. It was December 13th, and my friend, a French lawyer, had arrived bearing a bottle of Georgian wine, a dark and promising gift—a gentle nod to our recent travels through Tusheti.

We opened the bottle and poured, the crimson liquid swirling in our glasses. We laughed, the conversation flowing as easily as the wine, covering everything from politics to the beauty of Georgia’s mountains. The second bottle was uncorked, and with a quiet curiosity, I asked, “Do you know why today is so important for Poland?”

He paused, eyes narrowing slightly, as if searching the archives of his mind. Then, with a confident nod, he leaned back and spoke. "Of course. The military junta, Jaruzelski, dictatorship, Soviets." He listed them with the precision of a man who knew his history well. There was no hesitation, no uncertainty in his voice.

He paused, taking a sip before continuing. “We French stood with Solidarnosc, stood with the Polish people, but then…” He sighed, the room falling quiet, “by February, we were already looking somewhere else—Ethiopia, the African food crisis.” His words hung between us, a reminder of the fleeting nature of global attention, of how quickly solidarity fades when the next crisis calls.

I understood; that’s how it often goes. The West moves from one crisis to the next, and Ukraine must be prepared for the same. Once the war ends, all eyes will be on Ukraine—but only for a short time. There will inevitably be another crisis, somewhere else. Ukraine will have one window—one opportunity to secure the funds, aid, and support necessary for real change. There won’t be a second chance.

Navigating Ukraine’s Post-War Transformation

Ukraine's post-war recovery promises significant Western support, akin to the Marshall Plan after World War II. While no program of that scale is yet official, Ukraine is expected to receive extensive financial aid, investments, and partnerships. This support will likely include financial credits for reconstruction, managerial aid for institutional rebuilding, and insurance to attract foreign investors. Such efforts are vital to integrating Ukraine’s economy into the Western landscape. However, these investments hinge on establishing robust governance and compliance frameworks aligned with international standards.

The challenge is clear: Ukraine must enforce effective anti-corruption measures to dismantle its entrenched systema of crony capitalism. International donors demand zero tolerance for corruption and concrete reforms —not only in government but across all sectors. Ukraine’s credibility, long tarnished by the influence of oligarchs, now rests on demonstrable reform, as donor nations expect concrete, lasting change. Additionally, sustainable reconstruction requires not only anti-corruption but also heightened security to attract foreign businesses to participate in recovery.

This moment presents both a challenge and an opportunity for Ukraine to overcome decades of stagnation. Implementing the 2023-2025 anti-corruption program, empowering bodies like NABU and SAPO, and securing their autonomy are essential steps. Donors will look for a strong record of prosecutions and asset seizures in high-level cases. By meeting these expectations, Ukraine can build not only a stable economy but a foundation for a transparent and prosperous future.

Global Anti-Corruption and Anti-Bribery Standards in Compliance Programs

Over the past 30 years, compliance programs have become a structured and essential tool for ensuring that corruption and fraud remain anomalies rather than systemic issues. These programs are anchored in international regulations, such as the U.S. Foreign Corrupt Practices Act (FCPA), UK Bribery Act, Sapin II (France), OECD Anti-Bribery Convention, United Nations Convention against Corruption (UNCAC). Compliance is even addressed by ISO 37001 (Anti-Bribery Management System). These frameworks work by establishing clear rules, monitoring adherence, and addressing violations swiftly.

Tested and refined by businesses and regulatory authorities worldwide, including highly regarded U.S. professionals, compliance programs not only reduce unethical behavior but can also mitigate penalties when violations occur. In fact, companies with strong compliance systems may see penalties reduced or avoided entirely in cases of non-compliance.

A successful compliance program is built on strong leadership, often referred to as the "tone at the top," which ensures the senior management commit to ethical behavior. A successful program involves also establishing clear standards, providing regular training, and conducting ongoing monitoring and audits to identify and mitigate risks. At the heart of any compliance structure is the compliance officer, who is responsible for the program's success, from implementation to enforcement.

Beyond protecting businesses from legal consequences, robust compliance programs are crucial for international operations. Without them, local companies face significant challenges—they may be barred from contracting with multinational corporations based in the U.S., Europe, Japan, or Australia; struggle to expand internationally; or fail to secure Western financial support. Increasingly, compliance frameworks are also being adopted beyond the corporate world, benefiting NGOs and government agencies by fostering transparency and accountability.

In today’s global business environment, compliance is no longer just a regulatory obligation—it’s a strategic advantage. A well-functioning compliance program not only facilitates international growth and partnerships but also safeguards organizations from reputational and financial damage.

Lessons from the Region: Enforcement and Cultural Challenges

The challenge for Ukraine will not be in the initial adoption of compliance frameworks, but in their rigorous, sustained enforcement over time. Experience implementing compliance programs across countries has highlighted distinct cultural differences. In Switzerland, there is often initial resistance due to a reliance on long-standing processes, but once compliance programs are accepted, adherence tends to be consistent. In Eastern Europe, including Ukraine, new rules are frequently adopted with speed, but the challenge lies in enforcing established rules consistently and enduringly after implementation. This is where the resilience of compliance officers will be pivotal.

Ukraine must learn from these regional experiences and prioritize enforcement, ensuring that compliance does not lapse into formality after the initial rollout. Given Ukraine’s cultural and institutional landscape, this requires placing individuals who can withstand pressure and uphold compliance firmly in the face of non-compliance at the forefront of these efforts.

Empowered Compliance Officers: Authority, Autonomy, and Resources

The effectiveness of a compliance program relies on the compliance officer. Ideally, this role should embody three core elements: appropriate authority within the organization, sufficient autonomy from management, and adequate resources to implement the program effectively. According to the FCPA Guide, an effective compliance program should ensure that compliance officers have access to all organizational information, direct lines to senior management, and sufficient autonomy to operate without undue influence.

From my experience hiring compliance officers across Western and Eastern Europe, the best candidates often stand out due to their intelligence, strong interpersonal skills, knowledge of local problems, and most importantly, the courage to resist pressure—a critical trait, especially in a high-stakes environment like Ukraine. In such environments, compliance is not simply about setting standards; it is about enforcing them without compromise, even when it means confronting powerful individuals.

Leveraging Veterans: A Unique Opportunity for Ukraine

Over the last two decades, I have observed a significant increase in veterans from the U.S., UK, Israel, and Switzerland transitioning into compliance roles across various industries. You can easily spot them at conferences—standing tall, with sharp haircuts and firm handshakes, exuding an air of discipline. In countries like Switzerland and Israel, this trend is partly due to compulsory military service, but in other nations, the reasons are more nuanced. While still products of their society, military service often instills in veterans a heightened sense of responsibility and integrity, making them particularly effective in enforcing ethical standards.

Veterans possess key qualities that make them natural fits for compliance roles. Their military service instills a strong sense of order, discipline, and an unwavering commitment to ethical standards. This heightened sense of responsibility, combined with their ability to enforce rules under pressure, equips them with the resilience required to navigate high-stakes compliance situations. Their ability to stand firm in the face of challenges, especially when dealing with powerful figures within organizations, is a critical asset that resonates well within corporate environments.

In Ukraine, veterans—both men and women—are uniquely positioned to play a transformative role in shaping compliance practices. Women, in particular, have been a significant presence in Ukraine’s armed forces, with many serving in combat roles. These women veterans are every bit as resilient as their male counterparts, and in some cases, even tougher. The traits developed in military service—discipline, respect for hierarchy, and the ability to perform under immense stress—are directly transferable to civilian compliance roles.

Ukrainian veterans, having faced life-or-death decisions on the frontlines, bring a unique moral courage and credibility to their roles in enforcing compliance. This experience makes them exceptionally well-suited to handle sensitive situations, including dealing with high-ranking officials or making difficult decisions such as dismissing employees who compromise organizational integrity. When a veteran speaks about the importance of adhering to rules, people listen.

As Ukraine rebuilds its institutions and combats corruption, veterans represent an underutilized but powerful resource. Their military-honed sense of ethics and resilience positions them perfectly to lead Ukraine’s efforts in fostering a zero-tolerance compliance culture. Alongside these veterans, their spouses—who have demonstrated equal resilience throughout the war—can play an essential role in supporting and driving forward compliance reforms in Ukraine.

Veterans’ Spouses: An Untapped Resource for Integrity

Equally compelling is the untapped potential of the spouses of veterans. These individuals have not been passive spectators during the war; they have been on their own battlefront—keeping families together, dealing with shortages, and holding everything in place while their partners were fighting. Their strength, resilience, and ability to navigate incredibly difficult circumstances have forged qualities that are invaluable in any leadership role. Just like their partners, they bring a moral authority and charisma that commands respect. They, too, have a powerful stake in the future integrity of the country and are uniquely positioned to enforce compliance from a place of genuine commitment to national values.

Veterans in Compliance: A Win-Win Strategy?

One of the harsh realities we must confront is that veterans returning from war often struggle to find meaningful employment. In other countries, such as Iraq and Kosovo, veterans who were once celebrated as national heroes found themselves unemployed, marginalized, and even mocked by those who stayed behind. Many were reduced to begging, labeled "suckers" or "losers"—a cruel reminder of society's fleeting gratitude.

Ukraine must avoid this outcome at all costs. Veterans and their families deserve roles that honor their sacrifices and channel their skills into meaningful work. Compliance offers an ideal fit—a position where veterans can continue to protect and serve by defending institutional integrity and ensuring corruption has no place in Ukraine’s rebuilding. If we fail to provide these opportunities, we risk not only letting down the individuals who served but also missing out on one of the most powerful resources for genuine institutional transformation.

I firmly believe veterans possess a strong moral compass, an exceptional ability to withstand pressure, and the charisma to inspire others to uphold ethical standards, even when it is difficult. Veterans and their spouses embody these qualities, having navigated life-or-death situations where the stakes were far higher than any corporate compliance challenge. This resilience uniquely qualifies them for the demanding role of enforcing compliance.

The question for Ukraine is straightforward: Should compliance officers be drawn from those who stayed home while others risked everything, or from those who waited abroad for safer times? Or should we entrust these roles to those who have already proven their courage, resilience, and unwavering commitment to the nation’s future?

Uncharted Territory: The Risks and Rewards

There are legitimate concerns when it comes to embedding veterans in Ukraine’s compliance movement. No institution is immune to corruption, and every organization, reflects the broader society. However, certain challenges may be more manageable within the military. The strict obedience, limited tolerance for dissent, and swift, severe penalties typical of military operations might offer a unique advantage in enforcing compliance compared to the more flexible civilian sector.

The next question is how to balance veterans and representatives from civil society in compliance roles. Should veterans make up 5%, 50%, or even 95% of compliance officers?

Yet, even a well-intentioned structure can be vulnerable to corruption—power can corrupt, and absolute power can corrupt absolutely. This gamble carries risks. Consider Georgia’s experience from 90’s or recent Estonia’s: through strong political will, bold actions, strategic technology, and savvy public relations, they achieved a remarkable turnaround, reducing corruption and delivering tangible benefits to citizens. It worked for Georgia, it is working in Estonia —why not try a similar approach in Ukraine?

Post-Graduate Programs for Compliance Officers: Veteran Preference?

The answer is yes, but building such programs requires careful planning. Becoming an effective compliance officer isn’t rocket science, nor does it demand decades of specialized education or intricate technical skills. What it does require is focused, high-quality training led by seasoned Western professionals who have run compliance programs for multinational companies based in the U.S. or Europe. These practitioners—who understand the practicalities of compliance from A to Z—offer the most valuable guidance.

To prepare compliance officers for Ukraine’s specific needs, trainers must have a deep understanding of the country’s unique institutional and cultural landscape. This grounding ensures the training isn’t just theoretical but addresses the real-world challenges Ukraine faces. Without this tailored approach, even the best-structured compliance programs may fall short in tackling the deeply rooted issues Ukraine seeks to overcome.

For future compliance officers, training should cover a range of hard and soft skills. For veterans, some additional, specialized classes may be needed to address the risks of militarizing the anti-corruption effort. While veterans bring valuable discipline and leadership to compliance, there is a delicate balance. Over-militarizing could lead to unintended consequences, potentially limiting openness, infringing on human rights, and affecting democratic growth. Military structures operate with rigid hierarchies and emphasize obedience—traits that don’t naturally align with an open society.

Effective compliance training must maintain this distinction, ensuring that democratic values are upheld and that Ukraine’s compliance officers are prepared to foster transparency within the principles of an open, democratic society.

Look Who’s Against It

Before pushing veterans to the forefront of Ukraine's compliance movement, consider who the opponents are. Often, they’re the same people who left when things got dangerous, or those now sneering from the sidelines, calling veterans "suckers" for staying and fighting. It’s a badge of honor when resistance comes from those who’ve sacrificed nothing. Veterans, with their proven commitment, resilience, and integrity, are precisely the kind of people the critics fear—because they won’t flinch and won’t bend to corruption.

Conclusion: Establishing Compliance Before the War Ends

Ukraine’s post-war recovery presents a unique opportunity to address its long-standing issue of corruption. By leveraging veterans and their families in compliance roles, Ukraine can build a future founded on transparency and integrity. Strong anti-corruption programs, backed by dedicated individuals, will help Ukraine secure international trust, attract investment, and rebuild stronger than ever.

The question is simple: Will Ukraine use its war-forged heroes to lead the charge against corruption and build a prosperous future?

Join the Conversation!

What are your experiences with compliance in transitional environments? Share your thoughts on how Ukraine can navigate this complex transformation.

Acknowledgments: I would like to extend my sincere gratitude to Tom, Borys and Elena for their invaluable feedback and insights, which helped shape and improve this article.