The Cabinet of Ministers of Uzbekistan adopted Resolution No. 44 on February 3, 2026, “On the procedure for preliminary expertise and practical assessment of foreign investment projects for their compliance with anti-corruption standards.” This document is aimed at strengthening control over the transparency of investment project implementation and countering corruption risks at all stages of their development and implementation.

Key Provisions of the New System

The new Regulations introduce a comprehensive system of anti-corruption expertise for foreign investment projects, covering the following main areas:

Mandatory Project Expertise

All foreign investment projects planned for implementation in Uzbekistan are subject to mandatory anti-corruption expertise. The document specifies that a foreign investment project refers to projects with an investment equivalent of at least $50 million, including state investments, foreign loans, and loans from international financial institutions, provided they are implemented in the fields of economic or social modernization, or infrastructure development.

Responsible Authorities

A system of specialized anti-corruption agencies is being established to conduct the expertise of investment projects. The following entities are involved in the process:

• State bodies and organizations

• Public-Private Partnerships (PPP)

• Sectoral ministries

• Investors and representatives of industry and trade

Stages of Expertise

The expertise of investment projects is conducted at three key stages:

1. Primary Stage – Expertise of the feasibility study (FS), procurement agreements, and other basic project documents, including decisions on adoption or PPP partnership terms.

2. Intermediate Stage – Assessment of the procurement process, the work of contractors, investors, and co-executors during the formation of tender conditions.

3. Final Stage – Expertise of project implementation conditions to identify seasonal changes in conditions, possibilities for deviation from contractual norms, and monitoring of procedures for preventing and detecting corrupt actions.

Categories of Expert Assessment

The Regulations provide for three categories of expert assessment:

• Primary Expert Assessment (Early-Stage Case Analysis) – Conducted at the concept and feasibility study stage, during the expertise of project documentation, and during the planning of procurement procedures or PPP partnership terms.

• Intermediate Expert Assessment – Evaluation of the project’s contractual environment, including analysis of recommendations, monitoring, and identification of corruption risks during procurement, the formation of partnership terms, and the reaching of agreements.

• Concluding Expert Assessment – Assessment of the fulfillment of contract obligations to identify deviations from legal norms, and monitoring of anti-corruption mechanisms during project implementation.

Expertise Procedure

The document regulates the anti-corruption expertise procedure in detail:

• Corruption Risk Analysis – Identifying potential corruption factors through a special risk assessment based on internal evaluation methodologies.

• Competitive Environment Assessment – Analyzing competition conditions during tender procedures to exclude the possibility of a monopoly position for individual participants or the creation of preferences for specific entities.

• Due Diligence of Participants – Assessing the reputation, financial stability, and transparency of investors, contractors, and partners to exclude links to corrupt practices.

• Documentation Analysis – Detailed verification of all contractual documents, partnership terms, and licensing agreements to identify vague wording that creates opportunities for abuse.

• Implementation Mechanism Assessment – Reviewing control, audit, monitoring, and reporting procedures used during project implementation to ensure transparency in the expenditure of funds.

Digital Tools and System Integration

The Resolution provides for the creation of a unified digital platform (“Single National Portal”) by March 1, 2026, to integrate investment projects with tracking systems and international control bodies. The platform will provide:

• Online access to information about projects, procurement terms, and partners.

• Electronic processing of applications and documentation.

• Automated checklists and forms for checking compliance with anti-corruption standards.

• Efficiency assessment modules based on public data.

• Integration with international UNCAC platforms regarding project expertise for compliance with anti-corruption requirements.

Specific Requirements for Project Management

The document introduces a number of mandatory requirements for participants:

• For State Bodies: Mandatory submission of materials for expertise, creating conditions for transparency in procurement, and monitoring anti-corruption measures.

• For Investors and Businesses: Compliance with corporate governance standards, public reporting on key project indicators, implementation of internal anti-corruption systems (compliance mechanisms), and adherence to UNCAC, IECT (Economic Integrity and Transparency Initiative), and FATF standards.

• For Contractors: Compliance with tender requirements, price transparency, and the elimination of subcontracting chains that create opacity in the use of funds.

Sanctions and Liability

The Regulations provide for a strict system of liability:

• Cancellation of project implementation permits if corrupt practices are identified.

• Exclusion from tender procedures for up to 20 years for dishonest participants.

• Referral of materials to law enforcement agencies upon discovery of signs of corruption offenses.

• Application of sanctions in accordance with IECT standards for foreign participants.

Monitoring and Control

A permanent monitoring system is being established, including regular audits, the implementation of Key Performance Indicators (KPIs) for anti-corruption measures, annual reporting, and international information exchange.

Practical Implications for Business

The introduction of new standards creates stricter requirements for foreign investors: the need for early preparation of documentation, mandatory corporate compliance, increased transparency of financial flows, and detailed disclosure of beneficial owners.

Source: Lex.uz