CRIMINAL LIABILITY FOR DIGITAL CORRUPTION: UZBEKISTAN IN COMPARATIVE PERSPECTIVE

Abstract

Digital transformation has significantly altered state operations while simultaneously reshaping the landscape of corruption. New schemes, inherently tied to emerging technologies, are increasingly categorized as “digital corruption.” This paper examines how criminal liability for such acts is regulated across several jurisdictions, focusing on the United States, Germany, and Singapore. These international approaches are subsequently compared with the legislative framework of the Republic of Uzbekistan using a comparative legal methodology to identify both commonalities and regulatory gaps. The analysis encompasses legal definitions, enforcement mechanisms, and practical experiences regarding corruption linked to digital assets, e-government platforms, and cyber-related misconduct. A key finding is the efficacy of flexible legal language in leading jurisdictions; terms such as “anything of value,” “benefit,” or “gratification” provide the necessary breadth to encompass modern forms of bribery, including cryptocurrency transfers and intangible advantages. While Uzbekistan’s Criminal Code remains robust, its reliance on the traditional formulation of “tangible valuables or pecuniary benefit” may be insufficiently broad to capture non-material digital advantages. Consequently, the paper concludes that Uzbekistan would benefit from updating its legal terminology to reflect international standards. Furthermore, the development of specialized expertise in digital evidence and the deepening of international cooperation are presented as essential requirements for the legal system to effectively mitigate contemporary corruption risks in the digital age.