In the Croatian legal system, “financial crime” is not legally defined. It is a descriptive term used to denote offences affecting property, financial or economic interests, often involving complex transactions or abuse of trust. It particularly includes:

• property offences (eg, fraud – Article 236; abuse of trust in business – Article 246);
• corruption offences (eg, bribery – Articles 293–294);
• money laundering (Article 265);
• offences against the economy and financial system (Chapter XXIV);
• tax offences (eg, tax evasion – Article 256);
• capital market offences (eg, market abuse – Article 260 in conjunction with the Capital Market Act/EU Market Abuse Regulation (MAR));
• violations of international sanctions; and
• cyber-enabled property offences (Chapter XXV; eg, computer fraud – Article 271).

A financial crime exists where the following elements are met:

• an act or omission;
• unlawfulness;
• culpability; and
• statutory definition.

Typical elements include:

• conduct (eg, deception, concealment);
• consequence (pecuniary damage or unlawful gain);
• causation; and
• subjective element (fault).

Liability generally requires intent (direct/indirect) or negligence; most financial crimes require intent, while negligent offences are rarer.

Attempts are punishable if the offence carries more than five years’ imprisonment or where law expressly allows. Attempt liability exists for serious financial crimes. Participation includes incitement and aiding/abetting (Articles 37–39). Criminal association (Article 328) addresses organised crime; Croatia does not recognise Anglo-Saxon “conspiracy”, but similar functions are served.

Legal persons may be criminally liable under the Criminal Liability of Legal Persons Act (CLPA), which governs conditions, penalties, confiscation, seizure, publication of judgments, limitation periods and procedure.

The presumption of innocence and the burden of proof are governed by the Criminal Procedure Act (CPA) and the Constitution of the Republic of Croatia. Every person is presumed innocent until proven guilty by a final judgment.

Under Article 3(2) CPA/08, the burden of proving guilt lies with the prosecutor. The suspect or accused is not required to prove their innocence and has the right to remain silent.

The standard of proof for conviction is “beyond reasonable doubt”, and in case of doubt, in dubio pro reo applies. Limited presumptions exist in specific contexts, such as confiscation of criminal proceeds or money laundering, but the prosecutor must always prove the offence and guilt. Liability requires fault (intent or negligence), while strict liability is generally limited to misdemeanours.

Under the Criminal Code, a person may be held criminally liable as a participant if they knowingly take part in the commission of an offence by another perpetrator. Participation includes, in particular:

• co-perpetration (Article 36 of the Criminal Code), where a person commits an offence alone or through another person;
• incitement (Article 37) – ie, inducing another person to commit an offence; and
• aiding and abetting (Article 38) – ie, facilitating the commission of an offence by providing advice, means, removing obstacles or otherwise assisting.

Aiding and abetting and incitement are punishable within the limits of the participant’s intent, and their liability is generally accessory, meaning it is linked to the existence of the principal offence, although it is not necessary for the principal offender to be convicted.

Pursuant to Article 39(3) of the Criminal Code, special personal circumstances that justify exemption from punishment, mitigation or qualification of the offence are taken into account only in respect of the co-perpetrator or participant to whom they relate.

Furthermore, for organised forms of financial crime, the concept of a criminal association (Article 328 of the Criminal Code) is particularly relevant, as it criminalises the mere act of association for the purpose of committing offences, and often qualifies the underlying offences when committed within such an association.

The statute of limitations for criminal prosecution is prescribed in Article 81 of the Criminal Code currently in force. Criminal prosecution becomes time-barred after:

• 40 years for offences punishable by long-term imprisonment or imprisonment exceeding 15 years;
• 25 years for offences punishable by imprisonment exceeding ten years; 20 years for offences punishable by imprisonment exceeding five years;
• 15 years for offences punishable by imprisonment exceeding three years;
• ten years for offences punishable by imprisonment exceeding one year; and
• six years for other criminal offences.

For certain offences, no limitation periods apply. Criminal prosecution does not become time-barred for offences such as genocide, the crime of aggression, crimes against humanity, war crimes, terrorism, human trafficking, aggravated murder, aggravated murder of a female person, serious criminal offences of sexual abuse and exploitation of a child, murder of a person under international protection and other offences that are not subject to limitation under the Constitution of the Republic of Croatia or international law.

In general, the limitation period begins on the day the offence is committed, or when its consequence occurs if this is later. It does not run during periods when prosecution is legally impossible. For offences against children, it starts when the victim reaches majority.

The Criminal Code also regulates limitation periods for the enforcement of penalties, which depend on the severity of the offence and the sentence imposed. Although there is no specific statutory regime for concealed or continuing offences, legal doctrine recognises exceptions regarding the starting point of limitation periods in certain cases.

In related civil matters, if criminal proceedings are discontinued or charges dismissed, the injured party may bring a civil claim, with the limitation period deemed interrupted if filed within three months of the final decision. Otherwise, general civil limitation periods apply.

Where a final judgment is quashed, the limitation period for damages is suspended until a new final decision. If the damage results from a criminal offence with a longer limitation period, the civil claim follows that extended period, including any suspension or interruption.

Chapter II of the Criminal Code governs the application of Croatian criminal law. Article 14 provides that Croatian law applies to nationals and residents committing offences abroad if punishable in that jurisdiction, including when citizenship is acquired after the offence. Article 18a restricts proceedings where acts have been finally judged in Schengen states, provided sanctions are executed or cannot be executed. Croatian nationals or companies acting abroad may be prosecuted in Croatia.

International legal assistance is governed by the Act on Mutual Legal Assistance in Criminal Matters (MLAA) and the Act on Judicial Cooperation with EU states, covering the European Arrest Warrant (EAW), European Investigation Order (EIO), asset freezing/confiscation, extradition and transfer of proceedings.

Croatia co-operates through Eurojust, Europol and European Public Prosecutor’s Office (EPPO), particularly in cross-border economic and corruption cases, and has bilateral treaties for judicial co-operation.

Extradition within the EU uses the EAW based on mutual recognition; for third countries, treaties and domestic law apply, with judicial control and respect for fundamental rights. The system emphasises mutual recognition, rapid information exchange and co-ordination between authorities, essential for complex cross-border financial crime.

Specialised bodies/networks play a key role:

• police – Europol, Interpol
• judicial – Eurojust;financial intelligence –the Anti-Money Laundering Office (Financial Intelligence Unit – FIU), Egmont Group, EU FIU network; and
• regulatory co-operation – the Croatian Financial Services Supervisory Agency (Hrvatska agencija za nadzor financijskih usluga – HANFA) within EU supervisory frameworks.

Article 9 of the Constitution of the Republic of Croatia provides that a Croatian national may not be expelled, deprived of citizenship or extradited, except where required by an international treaty or EU law. In practice, extradition of suspects in financial crime cases operates under a dual regime:

• within the EU, the EAW applies pursuant to the Act on Judicial Cooperation in Criminal Matters with EU Member States; and
• in relation to third countries, the Act on International Legal Assistance in Criminal Matters, international treaties and the principle of reciprocity apply.

Extradition of Croatian nationals to third countries is generally not permitted unless provided by treaty, in line with aut dedere aut judicare (extradite or prosecute domestically). Articles 35–37 of the Act on International Legal Assistance set strict grounds for refusal. Extradition will not be permitted if:

• the person is a Croatian national (outside the EU);
• the offence was committed in Croatia or against its interests;
• dual criminality is not met;
• prosecution is time-barred;
• a final domestic judgment exists or proceedings are pending;
• the person’s identity is not established; or
• there is insufficient evidence for reasonable suspicion.

Extradition may also be refused where Croatia can prosecute or enforce the sentence. The principle of speciality applies: the requesting state may not prosecute for other offences or restrict rights beyond the extradition scope.

Croatia does not maintain a formal prohibited list, but extradition may be refused where fundamental rights could be violated. Historically, Croatia did not extradite nationals, but the 2010 constitutional amendment allows it where international agreements or EU law provide.

The main authorities responsible for investigating and prosecuting financial crime in Croatia are the State Attorney’s Office (Državno odvjetništvo Republike Hrvatske – DORH), including municipal and county offices, and the specialised Office for the Suppression of Corruption and Organised Crime (Ured za suzbijanje korupcije i organiziranog kriminaliteta – USKOK).

Since 1 June 2021, the EPPO has also operated in Croatia, handling offences affecting the EU’s financial interests.

Investigations are conducted by the Ministry of the Interior, particularly through specialised police units such as the Police National Office for the Suppression of Corruption and Organised Crime (Policijski nacionalni ured za suzbijanje korupcije i organiziranog kriminaliteta – PNUSKOK), in close co-operation with USKOK. At early stages, the Tax Administration and the Anti-Money Laundering Office also play a role by monitoring tax compliance and analysing suspicious transactions.

In addition to criminal proceedings, financial crime may also give rise to civil and administrative actions. Injured parties may seek damages or restitution in civil courts, while regulatory bodies may impose administrative or misdemeanour sanctions independently.

Although there is no formal conflict of jurisdiction, overlap between criminal, civil and administrative proceedings requires co-ordination in practice. Criminal prosecution does not exclude other proceedings, nor do administrative sanctions preclude criminal liability.

Jurisdictional issues between criminal and misdemeanour proceedings are resolved based on legal classification.

Financial crime investigations most commonly begin with a criminal complaint filed by the police, supervisory authorities – ie, the Croatian Financial Services Supervisory Agency (HANFA), Croatian National Bank (CNB; Hrvatska narodna banka – HNB), the Tax Administration or the Croatian Competition Agency (Agencija za zaštitu tržišnog natjecanja – AZTN) – injured parties or private individuals, as well as on the basis of official knowledge obtained by the state attorney (eg, media, audit or internal reports). Upon receipt, the state attorney orders preliminary inquiries. If reasonable suspicion is established, an investigation is opened, or a direct indictment is filed.

Accordingly, proceedings may be initiated on the basis of a criminal complaint, other information on a criminal offence or ex officio.

The purpose of the investigation is to collect the evidence necessary to decide whether to bring an indictment or discontinue proceedings, as well as to secure evidence that may not be repeatable at trial. The investigation is conducted by the state attorney, who issues a decision to open it where there are grounds for suspicion.

Under the CPA, investigations are generally conducted for offences punishable by more than five years’ imprisonment, and are mandatory for the most serious offences (eg, punishable by more than 15 years or long-term imprisonment, or where the offender acted while insane).

The state attorney opens an investigation against a specific person where reasonable suspicion exists and no legal impediments are present.

Croatian criminal procedure is governed by the principle of legality, meaning the state attorney must initiate prosecution where statutory conditions are met. While some assessment exists – particularly at the pre-investigation stage – and limited exceptions apply (eg, dismissal of complaints or the principle of opportunity), prosecutorial discretion remains constrained by the duty to prosecute.

Under the CPA (CPA/08, Articles 216–340), competent authorities (state attorney, police, courts) hold broad investigative powers.

Regarding documents and information, the state attorney and police may require natural and legal persons to provide data, records and documents relevant to criminal proceedings, including banking and financial information, with the possibility of issuing orders and measures to secure evidence.

For searches and seizures, the court, upon the state attorney’s motion, issues warrants to search homes, premises, persons and objects, and to temporarily seize items serving as evidence or originating from criminal offences. In urgent cases, police may act without a prior warrant, subject to judicial review.

Suspects must be questioned after being informed of their rights, including the right to counsel and to remain silent, while witnesses are summoned to testify truthfully, with coercive measures applicable in case of unjustified absence or refusal (with statutory exceptions).

Regarding tracing, freezing and confiscating assets, the court may order interim measures (eg, disposal prohibition, account freezing, temporary property seizure) to secure confiscation of unlawful gain, including digital assets such as crypto-assets, using special evidentiary measures under judicial supervision. Permanent confiscation follows final judgment. All powers are subject to legality, proportionality and judicial control.

In the context of cryptocurrencies, criminal activity involving digital assets has grown alongside their widespread use. Croatian law permits temporary seizure and preservation of electronic evidence, tracing and freezing of property suspected to derive from criminal offences. The first court case involving crypto-asset freezing occurred in 2021. General rules on temporary seizure and confiscation of proceeds apply to digital records and assets.

Permanent confiscation aligns with the principle that no one may retain unlawful pecuniary gain (Criminal Code, Article 5), applicable to offenders and third parties who received the benefit, including digital currencies.

Croatian competent authorities use technology and digital data sources in financial crime investigations, but it is important to distinguish between what is expressly regulated and publicly confirmed, and areas with insufficient public information.

Public sources confirm the use of operational and financial intelligence analysis, access to bank account and financial flow information, and special technical equipment under special evidentiary measures. The Anti-Money Laundering Office independently analyses and forwards relevant data to authorities, while a 2022 law facilitates access to bank account information for serious criminal offences. Ministry of the Interior documents confirm the use of International Mobile Subscriber Identity (IMSI) Catchers and surveillance system upgrades.

Automated surveillance in criminal matters is legally based on the CPA (CPA/08) via special evidentiary measures, including covert surveillance, subject to judicial supervision. The Constitutional Court has upheld this framework due to prompt judicial review and short deadlines for warrant confirmation. Technology is therefore used within strict procedural limits.

Regarding blockchain and crypto-assets, the Croatian regulatory framework presupposes technologically assisted supervision, especially under the Markets in Crypto-Assets Regulation (MiCA) regime. HANFA publishes European Securities and Markets Authority (ESMA) guidelines and technical standards for preventing and detecting market abuse in crypto-assets, showing reliance on analytical and technological tools for regulatory supervision.

However, no public evidence confirms routine use of AI tools or commercial blockchain forensics by the Ministry of the Interior (Ministarstvo unutarnjih poslova – MUP), DORH or USKOK, so this cannot be stated categorically.

AI use in law enforcement is legally restricted. Croatian data protection law governs automated processing for criminal investigations, requiring impact assessments, supervisory consultations, data protection officers, security measures and Croatian Personal Data Protection Agency (Agencija za zaštitu osobnih podataka – AZOP) supervision. AZOP guidance confirms that real-time biometric identification in public spaces is generally prohibited, except in narrowly defined cases with additional approvals. AI use is not banned but strictly limited by necessity, proportionality, legality and fundamental rights protections.

In conclusion, Croatian authorities use data analysis, access to financial information, digital registers and technical surveillance tools in financial crime matters, as well as regulatory tools for crypto-asset supervision. However, there is insufficient public evidence of broad, standardised use of AI or specialised blockchain forensics in operational investigations. Legal limits arise from the CPA, personal data laws, access to financial information and the AI Act framework.

Internal investigations are not generally mandated by law, but they are practically necessary in financial institutions for obliged entities under the Anti-Money Laundering and Terrorist Financing Act, listed companies and entities with developed compliance systems. The Anti-Money Laundering and Terrorist Financing Act requires the establishment of internal controls, risk assessments, transaction monitoring and reporting, which also includes internal investigations of suspicious transactions.

As regards confidentiality, internal investigations must comply with the GDPR and the Act on the Implementation of the General Data Protection Regulation (principles of processing, legitimate interest, informing data subjects), as well as the Labour Act (limitations on employee monitoring, prohibition of discrimination and retaliation). Obliged entities under the Anti-Money Laundering and Terrorist Financing Act must report suspicious transactions to the Anti-Money Laundering Office, and breaches of certain reporting duties may constitute a criminal offence. Lawyer-client communications are protected by legal professional privilege, which also extends to internal investigations conducted by lawyers.

Accordingly, in the Croatian system, internal investigations do not have a formally prescribed status under the CPA (CPA/08), but in practice they play an important role in detecting and clarifying financial crime, especially in the corporate environment. The results of internal investigations may serve as the basis for filing a criminal complaint or as a source of information for DORH, but they do not in themselves have evidentiary value unless lawfully introduced into the proceedings (eg, through witness testimony or the obtaining of documents by means of procedural actions).

As regards voluntary disclosure and co-operation, Croatian law does not recognise formal mechanisms such as deferred prosecution agreements, but the competent authorities (primarily DORH and the courts) may take such conduct into account. Co-operation with prosecuting authorities, voluntary submission of information or remediation of harmful consequences may influence the decision whether to prosecute (eg, the application of the principle of opportunity in limited cases) or may mitigate punishment as a mitigating circumstance.

In financial crime investigations in Croatia, all measures under criminal procedure may be applied, including arrest and questioning, if statutory conditions are met (grounds for suspicion and detention), in line with the CPA. Suspects are questioned only after being informed of their rights, including legal counsel and the right of defence.

The key document informing the accused of their rights is the “Notice of Rights”, served together with search warrants, summonses, detention or identification orders, or expert examination orders (Article 239(2) CPA/08).

Accused persons have the fundamental right not to co-operate or present a defence – ie, the right to remain silent and protected against self-incrimination (nemo tenetur se ipsum accusare), as guaranteed by the CPA, the Constitution and the European Convention on Human Rights. Exercise of this right cannot be held against the suspect.

However, some situations allow limited compulsory co-operation, subject to clear limits. Natural and legal persons may be required to produce documents, including financial records, based on court or state attorney orders. Searches, temporary seizure and special evidentiary measures are allowed under strict judicial supervision. Witnesses must testify unless exempted by law.

Refusal of lawful co-operation has consequences depending on the person’s status:

• a suspect may not be sanctioned for remaining silent;
• a witness may be fined or compelled if failing to appear or testify without justification;
• natural and legal persons may face fines or other measures for failing to produce ordered data; and
• giving false testimony or obstructing evidence may constitute a separate criminal offence.

The system balances protection of procedural rights with prosecutorial powers to obtain evidence from other persons or independent sources, under judicial supervision and the principle of proportionality.

Croatian law provides for restrictive measures prior to indictment to secure confiscation of unlawful gain or prevent disposal of a suspect’s assets (interim measures). These measures are governed primarily by the CPA, while the Criminal Code provides the substantive basis for confiscation. In cross-border cases, the Act on Judicial Cooperation in Criminal Matters with EU Member States applies.

The types of measures include, in particular:

• temporary seizure of objects and assets;
• prohibition on the disposal of assets;
• freezing of bank accounts; and
• other security measures aimed at future confiscation of unlawful gain.

The legal conditions and thresholds for imposing such measures are:

• the existence of reasonable suspicion that a criminal offence has been committed;
• a likelihood that the property derives from, or is connected with, the criminal offence;
• a risk that the property will be concealed, alienated or otherwise made unavailable (necessity); and
• proportionality of the measure in relation to the aim pursued.

As a rule, measures are imposed upon the motion of the state attorney, subject to a court decision and judicial supervision. Injured parties may seek the freezing of assets to secure a civil claim under Article 160(1) CPA/08.

Cross-border effect is achieved through European freezing and confiscation orders within the EU, and mutual legal assistance with third countries. Measures may also apply to third parties where property is suspected to be:

• transferred to avoid confiscation;
• formally registered in another person’s name; or
• held by related persons or companies but connected with the offence.

International legal assistance is governed by the Act on International Legal Assistance in Criminal Matters and the Act on Judicial Cooperation in Criminal Matters with EU Member States. These cover the EAW, EIO, freezing and confiscation of unlawfully acquired assets, extradition and transfer of proceedings. Croatian authorities co-operate through Eurojust, Europol, and the EPPO, especially in cross-border economic and corruption cases.

Under the Criminal Code of the Republic of Croatia (CC/11), offences often grouped under the notion of fraudulent conduct are not a single category, but consist of separate offences linked by the common purpose of obtaining unlawful pecuniary gain to the detriment of another through deception, abuse of trust, abuse of position or misappropriation of property.

The basic offence is fraud (Article 236), committed when a perpetrator, intending to gain unlawfully, misleads another person by false representation, conceals facts or keeps the person in error, causing action to the detriment of their or another’s property. Essential is active or passive deception causing mistaken belief and resulting in pecuniary damage. Basic fraud carries up to five years’ imprisonment, while aggravated forms, particularly involving substantial damage or multiple perpetrators, carry one to eight years.

Specific forms include fraud in business operations (Article 247), punishable by six months to ten years if substantial damage occurs, and computer fraud (Article 271), involving unauthorised interference with data or systems for unlawful gain, punishable up to five years.

Abuse of trust and position are significant: abuse of trust in business operations (Article 246) covers situations where a person entrusted with managing another’s property or representing a legal entity misuses their powers or fails to fulfil duties, causing damage. Basic forms are punishable up to five years, rising to ten for major damage. Embezzlement (Article 233) relates to unlawful retention or appropriation of entrusted movable property, without deception at the time of obtaining it, punishable up to three years, with harsher penalties for serious cases. Abuse of position and authority (Article 291) applies to officials or responsible persons exploiting their role, exceeding authority or neglecting duties for gain or to harm others, with aggravated cases punishable up to 12 years.

Forgery, particularly of documents (Article 278), frequently facilitates fraud by creating the appearance of legality. While Croatian law does not recognise “conspiracy” in the Anglo-Saxon sense, criminal association (Article 328) covers organised groups committing offences, including fraud, and the organised structure and common purpose act as aggravating factors.

In conclusion, Croatian law distinguishes fraudulent conduct by method, perpetrator status and the type of legal interest infringed, but all involve intent to obtain unlawful pecuniary gain while causing damage through deception, abuse of trust, misuse of position or unlawful appropriation of entrusted property.

In the public sector, the core bribery offences are receiving a bribe (Article 293 CC) and giving a bribe (Article 294 CC). Receiving a bribe is committed by an official or responsible person who requests or accepts a bribe, or the promise of one, to perform or omit an act, including lawful acts. Key elements are the perpetrator’s status, the bribe as quid pro quo and its link to the official act. Penalties range from one to ten years’ imprisonment. Giving a bribe is committed by any person offering, promising or giving a bribe to influence an official, with penalties up to several years’ imprisonment.

The Criminal Code also criminalises trading in influence (Article 295 CC) and giving a bribe for trading in influence (Article 296 CC), covering situations where a person uses actual or supposed influence over an official to mediate decision-making for a benefit.

In the private sector, the offences of receiving a bribe in business operations (Article 252 CC) and giving a bribe in business operations (Article 253 CC) apply. Receiving a bribe occurs when a person requests or accepts a bribe to favour another in a transaction, causing damage to the represented entity; mere acceptance is punishable in a lesser form. Penalties range from six months to eight years. Giving a bribe in business operations requires a connection between the bribe and the business decision, with penalties up to five years. Bribery in bankruptcy proceedings (Article 251 CC) is also punishable, with penalties up to eight years.

The Croatian Criminal Code expressly covers foreign public officials, including members of the Croatian Parliament, local and regional councillors, European Parliament members, and representatives in foreign states or international organisations (Article 339 CC), implementing international anti-corruption standards.

Croatian law does not contain a separate offence of “failure to prevent”, as in some Anglo-Saxon systems. Liability is based on active participation (receiving, giving, mediating a bribe), while supervision or prevention failures may be sanctioned under other offences or through corporate liability statutes, but not as a standalone offence.

The Criminal Code of the Republic of Croatia regulates money laundering primarily through the offence under Article 265 CC, covering acts aimed at concealing the unlawful origin of property. The offence is committed by any person who invests, takes over, converts, transfers or exchanges property known to be obtained through a criminal offence, with the aim of concealing or misrepresenting its origin, or who conceals or misrepresents its nature, source, location, disposition or ownership. It also includes acquiring, possessing or using such property, and assisting the perpetrator of the predicate offence. Essential elements are property derived from a criminal offence, knowledge of its unlawful origin and acts to conceal or integrate it. Basic forms carry six months to five years’ imprisonment; aggravated forms, especially involving large value or criminal associations, carry one to eight years.

Predicate offences are not limited to a closed list; any offence generating pecuniary gain may serve as a basis. Common examples include fraud (Article 236), embezzlement (Article 233), robbery, abuse of trust in business operations (Article 246), corruption (Articles 293–294), tax evasion and organised crime (Article 328). Conviction of the predicate offence is not required; it suffices that the property derives from a criminal offence.

AML compliance obligations are governed by special legislation, primarily the Anti-Money Laundering and Terrorist Financing Act. The Criminal Code supports this system through the criminalisation of money laundering and related offences, such as abuse of position or assisting an offender. Non-compliance is generally enforced through administrative sanctions, but criminal liability arises when non-compliance involves knowingly concealing unlawful assets or assisting in money laundering under Article 265 CC, with imprisonment and other criminal measures possible.

The Criminal Code of the Republic of Croatia expressly criminalises abuses in the capital market through offences designed to protect market integrity, investor confidence and information transparency. Key offences include insider dealing, market manipulation, and false or misleading disclosure of information.

Misuse of inside information (Article 259) occurs when a person with non-public information uses it to trade financial instruments or obtain other pecuniary benefits, for themselves or others. Unauthorised disclosure or advising others to trade on the basis of such information is also punishable. Basic forms carry up to five years’ imprisonment, with harsher penalties for serious cases.

Market abuse (Article 260) covers conduct that falsely or misleadingly influences financial instrument prices, such as fictitious transactions, orders creating false impressions of supply or demand, or disseminating false information, aiming to disrupt market functioning and obtain unlawful gain. Basic penalties are up to five years, with more severe punishment for aggravated cases. Misleading disclosure of information is also criminalised, protecting transparency and truthfulness in the capital market.

The unauthorised provision of financial services is not a separate criminal offence but is generally regulated under special legislation governing the capital market, credit institutions and investment services, usually as misdemeanours or administrative offences. However, if linked to fraud, investor deception or other criminal conduct, such activities may fall under general criminal offences, including fraud (Articles 236, 247) or abuse of trust (Article 246).

Therefore, the Criminal Code directly regulates serious capital market abuses through misuse of inside information, market manipulation, and misleading disclosure, while unauthorised financial services are primarily addressed outside criminal law unless they constitute general criminal offences.

The Criminal Code of the Republic of Croatia provides for several offences relating to tax abuse, false financial reporting and manipulation of business records, the central offence being tax or customs evasion under Article 256 CC. This offence is committed by any person who, intending to wholly or partly avoid payment of taxes or levies, provides inaccurate or incomplete information, or fails to report relevant facts, causing a reduction or avoidance of a tax liability. Essential elements are the intention to avoid public levies and the existence of actual tax loss. Basic forms carry up to five years’ imprisonment, while more serious cases carry stricter penalties.

The Criminal Code also covers offences regarding business books and financial records, particularly breach of the obligation to keep commercial and business books under Article 248 CC. This occurs when a responsible person fails to keep books, keeps them irregularly, or destroys, damages or conceals documentation, thereby hindering review of business operations. The essence is the endangerment of transparency, not necessarily pecuniary gain. Basic forms carry up to three years’ imprisonment. False accounting may also fall under fraud (Article 236), abuse of trust in business operations (Article 246) or forgery of a document (Article 278), depending on the purpose of the conduct.

Regarding legal persons and “failure to prevent” tax evasion, Croatian law does not create a separate offence for mere failure to prevent. Liability of legal persons is regulated by the Act on the Liability of Legal Persons for Criminal Offences, allowing punishment if a criminal offence was committed in the name, on behalf or for the benefit of the legal person, including as a result of insufficient supervision. Sanctions include fines, prohibitions on activities and other measures prescribed by the statute.

In the Croatian legal system, competition law infringements, including cartel conduct, are primarily regulated by administrative law, while criminal protection exists only indirectly through general offences under the Criminal Code.

Cartel conduct is mainly governed by the Competition Act (Zakon o zaštiti tržišnog natjecanja – ZZTN), which prohibits agreements that prevent, restrict or distort competition, including price-fixing, market-sharing, output limitation and exchange of sensitive information. Such conduct is not a criminal offence but an administrative infringement, sanctioned by fines imposed by the AZTN, which may reach up to 10% of annual turnover. Administrative law also covers abuse of a dominant position (eg, unfair pricing, discrimination, tying) and unauthorised concentrations. These are likewise subject to fines and corrective measures.

The Criminal Code does not provide a specific cartel offence, but certain anti-competitive practices may, depending on the circumstances, fall within general criminal offences.

The Criminal Code of the Republic of Croatia contains a broad range of counterfeiting offences that should be precisely covered, and which are distributed across several chapters of the Criminal Code depending on the protected legal interest (authenticity of documents, security of payment transactions, public health, etc).

In the area of payment transactions and the financial system, these include:

• forgery of a document (Article 278 of the Criminal Code) – making a false document or altering a genuine document and using it as genuine;
• forgery of an official or business document (Articles 279 and 281 of the Criminal Code) – entering false data into official or business documents;
• certification of untrue content (Articles 281/282 of the Criminal Code) – misleading an authority into certifying untrue content;
• counterfeiting of money (Article 274 of the Criminal Code) – making counterfeit money or altering genuine money and putting it into circulation;
• counterfeiting of securities (Article 276 of the Criminal Code) – making or altering securities with the intention of using them as genuine; counterfeiting of value signs (Article 277 of the Criminal Code) – relating to stamps, tax stamps and similar indicia of value; and
• misuse of a non-cash payment instrument and related offences, including the making, procuring, possessing or making available means for the misuse of non-cash payment instruments (Article 244a and related provisions of the Criminal Code).

In the area of documents and identity, these include:

• misuse of an identity document (Article 280 of the Criminal Code) – using another person’s or an invalid identity document as one’s own; and
• making, procuring, possessing or making available means for counterfeiting (Article 283 of the Criminal Code) – criminalising preparatory acts for counterfeiting, which demonstrates a high level of protection of legal transactions.

In the area of cybercrime, there is computer forgery (Article 270 of the Criminal Code) – ie, entering, altering or deleting computer data with the intention that such data be used as authentic, thereby effectively simulating a “digital document”.

In the area of protection of health and safety, there is counterfeiting of medicines or medical products (Article 185 of the Criminal Code) – ie, manufacturing or placing on the market counterfeit medicines or medical products, which constitutes a particularly serious offence because of the danger posed to human health.

As regards criminal offences against intellectual property, the Criminal Code regulates them in a separate chapter (Chapter XXVII), with the most important being:

• infringement of copyright and related rights – unauthorised reproduction, distribution or use of copyrighted works (so-called piracy);
• infringement of industrial property rights – unauthorised use of a patent, trade mark, industrial design or designation of origin;
• unauthorised use of another’s company name or designation; and
• unauthorised manufacture and placing on the market of counterfeit products (counterfeits).

These offences cover typical forms of infringement such as counterfeiting of goods and piracy – ie, unauthorised use of protected rights for the purpose of obtaining gain.

In the legal order of the Republic of Croatia, it is necessary to distinguish between greenwashing as a form of misleading business conduct and environmental criminal offences, expressly regulated in Chapter XX of the Criminal Code. Greenwashing is not a separate criminal offence, but giving false or misleading information about environmental characteristics may be relevant under consumer protection, competition, advertising and corporate reporting rules, and in certain cases may constitute fraud under Article 236 CC if deception, intent and pecuniary damage are present.

By contrast, the Criminal Code prescribes environmental offences, with the basic offence being environmental pollution under Article 193, covering discharge of substances or radiation capable of endangering air, soil, water or human health. Penalties range from six months to five years, or one to eight years in serious cases. Other related offences include:

• discharge from vessels (Article 194);
• endangering the ozone layer (Article 195); and
• environmental harm from waste (Article 196), plants or facilities (Article 197), and radioactive substances (Article 198).

These offences involve conduct contrary to regulations with potentially serious consequences.

The Criminal Code also protects nature and biodiversity in relation to destruction of protected parts of nature (Article 200), destruction of habitats (Article 201), trade in wild species (Article 202) and unlawful introduction of genetically modified organisms (GMOs) or alien species (Article 203). Other covered conduct includes unlawful hunting and fishing, forest devastation, alteration of water regimes, unlawful mineral exploitation and construction in protected areas. Aggravated offences under Article 214 carry penalties up to 15 years, including imprisonment and confiscation of objects or unlawful gain, with possible mitigation in cases of effective remorse.

Almost all offences are framed “contrary to regulations”, meaning criminal liability relies on special environmental legislation and EU law, including with respect to permits, environmental impact assessments, waste, water, air and nature protection. Greenwashing is instead addressed through consumer protection, advertising and financial disclosure, supervised by regulatory authorities.

Enforcement is in the form of criminal proceedings for environmental offences by DORH and the police, administrative sanctions for regulatory breaches including misleading claims, and civil claims for damages. Croatian law thus separates criminal liability for actual environmental harm from regulatory and civil liability for misleading environmental representations, with the two regimes complementing each other, thereby ensuring comprehensive criminal-law protection of the environment.

For criminal offences prosecuted ex officio, including most offences in the field of financial crime, the State Attorney has exclusive authority to prosecute, applying the relevant provisions of the Criminal Code and the CPA (CPA/08).

On the basis of the results of preliminary inquiries and the investigation, the State Attorney may dismiss the criminal report or discontinue the prosecution, file an indictment, propose the issuance of a penal order or enter into a plea agreement. The discretion involved in such decision-making is normally regulated by the CPA, but is applied restrictively in serious economic crime and corruption cases.

Pursuant to Article 17(1) CPA/08, criminal proceedings commence:

• when the decision opening the investigation becomes final;
• upon confirmation of the indictment if no investigation has been conducted;
• when a hearing is scheduled on the basis of a private prosecution; or
• upon the rendering of a judgment issuing a penal order (Article 541(1)).

Under Croatian law, criminal proceedings are initiated based on the principle of legality of prosecution (Article 2 CPA), meaning prosecution must start where there are grounds for suspicion that an offence prosecuted ex officio has occurred, and the State Attorney generally cannot choose not to prosecute.

In practice, some procedural discretion exists, as the State Attorney assesses whether conditions are met for taking steps, particularly during preliminary inquiries, and decides whether to open an investigation or if the evidence is insufficient. This discretion is limited by the principle of legality and supervised within DORH.

Regarding legal persons, the Act on the Liability of Legal Persons allows the State Attorney to initiate proceedings where an offence was committed in the interest of, on behalf of or for the benefit of the legal person, in line with statutory requirements. Discretion exists for procedural direction, but there is no formal right to refrain from prosecution without legal grounds.

The court has no discretion to initiate prosecution; it acts only after an indictment is filed, assessing whether statutory requirements for confirmation are met, but not whether prosecution should occur.

In conclusion, prosecution is initiated ex officio by DORH (or USKOK) under the CPA and the principle of legality. Professional assessment occurs during preliminary inquiries and decisions under the Act on Legal Persons, but it is constrained by statutory rules and hierarchical supervision, not free discretion.

Proceedings for financial crime generally last longer than other criminal cases due to complex evidence, including numerous financial transactions, extensive documentation and expert examinations. An international element often requires mutual legal assistance, further prolonging proceedings. These cases also typically involve multiple defendants and complex legal classifications.

There is no single rule for securing the defendant’s presence. Pre-trial detention may be ordered where statutory grounds exist (eg, flight risk, interference, reoffending), but less severe measures such as bail, precautionary measures or residence restrictions are often used, especially where the defendant is available. In practice, combinations of bail and precautionary measures are common, while detention is not automatic.

CPA/08 sets strict time limits for detention (Articles 130–134). Detention is initially ordered for 30 days, with possible extensions. After indictment, courts must regularly review its justification, and the total duration depends on the offence and procedural stage.

Statutory maximum periods before judgment apply, with possible extensions in complex cases, always subject to judicial review. For detained defendants, the principle of urgency applies, requiring faster court action and shorter intervals between hearings.

In the Republic of Croatia, public funding of defence is available under general rules of the Criminal Code and the CPA, not linked specifically to the type of offence.

A defendant has the right to court-appointed counsel in cases of mandatory defence, such as pre-trial detention, serious criminal charges or where the interests of justice require it. The state initially bears the costs. Outside mandatory defence, counsel may be appointed at state expense if the defendant proves insufficient means and the case requires professional legal assistance.

Criteria for granting defence are based on financial circumstances and the complexity or seriousness of the case. The court assesses income, assets and overall circumstances. Although the state initially pays, the defendant may be required to reimburse costs if convicted and financially able. If acquitted or proceedings are discontinued, costs are generally borne by the state.

In conclusion, public funding of defence ensures the right to a fair trial but is conditional on financial circumstances and the outcome of the proceedings.

In the Republic of Croatia, financial, economic and corruption cases are heard by courts of general jurisdiction according to subject-matter and territorial rules; there are no separate “white-collar” courts. Specialisation exists mainly through specialised divisions and institutions rather than separate courts.

USKOK plays a key role in prosecution, while investigations are conducted by PNUSKOK, specialised police units. Since 2009, USKOK divisions have operated within county courts in Zagreb, Split, Rijeka and Osijek, staffed by judges vetted and trained for complex corruption and organised crime cases, creating functional specialisation.

Cases are generally assigned to experienced judges, so despite no formal separate court, there is de facto judicial specialisation. Recent legislative proposals aim to strengthen this by establishing special judicial divisions for corruption and organised crime at certain courts.

Suspects cannot choose the court or type of procedure; jurisdiction is determined by law based on offence seriousness and other criteria, and proceedings follow the CPA. Defendants may exercise procedural rights, such as seeking judge recusal, but cannot influence court assignment.

In conclusion, Croatia does not have special courts for financial crime, but USKOK, PNUSKOK and USKOK divisions provide institutional and personnel specialisation, with cases assigned to judges experienced in complex economic and corruption offences.

In Croatia, criminal proceedings, including financial crime cases, are conducted without a jury in the Anglo-Saxon sense, but before professional judges and, in some cases, lay judges. There is no system where citizens independently decide on guilt.

In more serious cases before county courts, panels consist of a professional judge and lay judges who decide jointly on guilt and sentence, while less serious cases are heard by a single judge. The same applies to financial crime cases, with no special jury regime.

Defendants cannot choose to be tried by a jury or influence the court’s composition, which is determined by law. They may only request recusal of a specific judge or lay judge. Lay judges are appointed for fixed terms by representative bodies and are not selected for individual cases, nor subject to procedures like voir dire.

There are no reforms aimed at abolishing jury trials in financial crime cases, as such a system does not exist; discussions focus instead on judicial specialisation.

In conclusion, financial crime cases are decided by professional judges, with possible lay participation, without a classic jury system, and without defendant influence over the court’s composition. In Croatia, criminal proceedings, including financial crime cases, are conducted without a jury in the Anglo-Saxon sense, but before professional judges and, in some cases, lay judges. There is no system where citizens independently decide on guilt.

In the Croatian legal system, both a legal person and a natural person can be prosecuted simultaneously, which is standard in financial and economic crime cases. Under the Act on the Liability of Legal Persons for Criminal Offences, a legal person is liable if the offence was committed by a responsible natural person in its name, on its behalf or for its benefit, or due to a failure in supervision or organisation.

Proceedings against the legal person and the natural person are generally conducted jointly, allowing a single judgment and comprehensive assessment of liability, though proceedings against the legal person alone are possible if the natural person is unavailable.

Liability within corporate structures is determined by the conduct of managers or entrusted persons, or by failures in supervision, control or business organisation. This functional model corresponds in practice to “failure to prevent”, though is not expressly named as such.

In corporate groups, parent company liability may arise from actual control, benefit from the offence or inadequate supervision. Legal successors also inherit liability, so mergers or acquisitions do not exclude responsibility for prior offences.

In conclusion, the Croatian system applies cumulative liability for legal and natural persons, assessing individual responsibility alongside corporate liability, with a focus on control, benefit and organisational failures.

In the Croatian legal system, there is no general statutory obligation for all legal persons to implement formal compliance programmes for preventing financial crime, though such programmes are required or strongly expected in certain sectors. The framework is fragmented and sector-specific: the Anti-Money Laundering and Terrorist Financing Act mandates internal controls, risk assessments, procedures, appointment of responsible persons, and supervisory systems for financial institutions and other obliged entities, while whistle-blower protection legislation requires internal reporting channels for employers of a certain size.

In the public and para-public sectors, compliance functions are expressly required, for example in state-majority-owned companies, whereas in the private sector such obligations are not general but encouraged through regulatory, supervisory and market expectations.

Croatian law does not criminalise the mere absence of a compliance programme, nor provide a formal “failure to prevent” model. However, organisational failings or ineffective internal controls may be relevant in establishing a legal person’s liability when a criminal offence results from such deficiencies.

Croatian criminal law does not provide special defences exclusively for financial or economic crime; general substantive and procedural defences under the Criminal Code and CPA apply. These include challenging elements of the offence (absence of pecuniary damage, unlawful gain or breach of duty), culpability (lack of intent, mistake, reliance on professional advice), and grounds excluding unlawfulness (lawful conduct, self-defence, necessity). Procedural objections, such as illegality of evidence or breaches of defence rights, are also common.

Croatian law does not recognise general de minimis exceptions for financial offences, though the concept of an insignificant act (Article 33) exists. It applies restrictively: a criminal offence does not exist if harm is negligible, culpability minor and punishment unnecessary. This is rarely invoked in economic and financial crime due to market impact.

There are no general safe harbours for financial crime. Limited procedural mitigations, such as the principle of opportunity or plea agreements, do not exempt from substantive liability. Sector-specific exceptions exist indirectly through regulatory regimes (tax, financial, AML), affecting unlawfulness, culpability or sanctions, but not eliminating liability if offence elements are met.

In conclusion, Croatian criminal law provides general defences without special privileges for financial crime, and exceptions like the insignificant act are narrow and rarely applied.

In the Republic of Croatia, whistle-blower protection for reporting financial crime is governed primarily by the Act on the Protection of Persons Reporting Irregularities, implementing EU Directive 2019/1937.

A whistle-blower is any natural person who, in a work-related context, reports irregularities such as financial crime, corruption or abuse. The Act provides protection of identity and confidentiality, prohibition of retaliation (dismissal, demotion, harassment), judicial protection and compensation for damage, free legal aid and institutional support. Protection extends to related persons (colleagues, family) and persons processing reports.

Unlike some Anglo-Saxon systems, Croatia does not provide financial rewards, but strong legal and institutional incentives encourage reporting. A multi-channel reporting system exists: internal channels within the employer, external channels to competent authorities and, under certain conditions, public disclosure. Employers with 50 or more employees must establish internal reporting systems, appoint confidential persons and define procedures for handling reports.

Anonymous reporting is allowed, and employers must act on reports with sufficient information. Confidentiality of the whistle-blower’s identity is maintained, except in statutory exceptions. Protection is conditional on good faith; knowingly false reports may incur misdemeanour liability.

In conclusion, while financial rewards are not offered, the Croatian system provides broad legal protections, institutional mechanisms, and anonymous reporting options to encourage disclosure of financial crime while protecting whistle-blowers from retaliation.

Under Croatian criminal law, financial crime offences are generally prosecuted ex officio and fall under the exclusive competence of the State Attorney, following the principle of legality (Article 2, CPA). Proceedings commence upon the final decision opening an investigation, confirmation of an indictment if no investigation occurred, scheduling a hearing in private prosecution or issuance of a penal order (Article 17(1) and 541(1) CPA/08).

Based on preliminary inquiries and investigations, the State Attorney decides whether to dismiss the complaint, discontinue prosecution, file an indictment, propose a penal order or conclude a plea agreement. While discretion exists, it is applied restrictively, particularly in serious economic crime and corruption cases. During preliminary inquiries, the State Attorney exercises procedural autonomy in assessing whether conditions for action are met, but this is constrained by the principle of legality and internal supervision.

For legal persons, corporate criminal liability under the Act on the Liability of Legal Persons applies where the offence was committed in the interest of or on behalf of the entity. The State Attorney decides whether to initiate proceedings once statutory conditions are satisfied, so discretion exists in procedural direction but not in omitting prosecution without grounds.

At sentencing, courts have broad discretion within statutory ranges and must consider all relevant factors, including seriousness, personal circumstances, and aggravating or mitigating factors. Decisions must be reasoned and are subject to appeal.

DORH holds discretion mainly in prosecutorial decisions, including initiating, continuing or discontinuing proceedings, and in plea negotiations. This discretion is bounded by law, the principle of legality and the public interest.

Under Croatian criminal law, natural persons may be sentenced to imprisonment, fines, suspended sentences, judicial admonition, security measures (eg, prohibition on certain activities or supervision) and confiscation of unlawful gain. Legal persons may face fines, confiscation, prohibitions, security measures, publication of the judgment and, in exceptional cases, dissolution. Sentencing and mitigation consider the seriousness of the offence, damage or gain, manner and duration of conduct, culpability, previous convictions, post-offence behaviour (confession, co-operation, compensation) and, for legal persons, organisational failings, supervision and remedial measures.

Sentencing follows the general rules of the Criminal Code, the Special Part prescribing ranges, and the Act on the Liability of Legal Persons. After establishing guilt, the court individualises the sentence within statutory ranges, assessing aggravating and mitigating factors. For legal persons, organisational shortcomings, deficient supervision and benefits obtained are particularly considered.

Croatia does not formally recognise deferred or non-prosecution agreements, but plea agreements allow negotiation of sanctions, including suspended sentences, protective supervision, confiscation and costs. The court confirms the agreement, while the State Attorney can negotiate guilt, sentence and measures, or discontinue prosecution for opportunistic reasons, especially for legal persons without assets or in bankruptcy.

Courts may consider remedial measures, such as compliance improvements or replacement of responsible persons, and legal persons can be exempt if they self-report before discovery. While Croatian law does not formally use a “failure to prevent” concept, liability for organisational failings has a similar effect, allowing sentencing to reflect institutional context, corporate culture, and circumstances to individualise punishment and encourage prevention.

In the Croatian legal system, mechanisms for the confiscation of property obtained through criminal offences are regulated primarily through the Criminal Code and the CPA, with management of confiscated property governed by special legislation. Confiscation is generally ordered within the conviction judgment, but extended confiscation is possible where there is a clear disproportion between lawful income and the person’s property. The scope includes the directly obtained benefit, converted or transferred property, substitute property and any income or profits derived from it.

Confiscation is usually decided within criminal proceedings, with the criminal court applying the standard of beyond reasonable doubt for criminal liability and a lower standard for establishing unlawful gain. Interim measures, such as prohibitions on disposal or account freezing, may secure future confiscation, and third parties may participate to prove lawful origin. If direct confiscation is impossible, the court may order payment of a sum equivalent to the property’s value, with enforcement measures including execution or substitute imprisonment.

Civil proceedings may run in parallel, allowing injured parties to claim damages or restitution, formally separate but potentially overlapping with criminal proceedings.

Overall, the Croatian system provides a broad framework for confiscating unlawfully acquired property, including its transformations and returns, while safeguarding procedural guarantees and third-party rights.

Under Croatian criminal law, no one may retain property benefits obtained through a criminal offence, and such benefits are confiscated from the offender or third parties who did not acquire them in good faith. Confiscation primarily serves the state, but the law simultaneously protects the interests of the injured party through a civil claim within criminal proceedings (Articles 153–162 CPA/08), allowing the victim to seek damages, restitution of property or restoration of the previous state. The court may decide on such claims in the criminal judgment if the facts are clear, avoiding separate proceedings.

This dual criminal-civil system enables the victim to assert rights effectively. Filing a civil claim within criminal proceedings interrupts limitation periods and is legally equivalent to filing a civil action. If the court cannot resolve the claim or there is no conviction, the victim may pursue civil litigation under the Civil Obligations Act or the Act on Ownership and Other Real Rights, ensuring continuous protection.

Victim protection extends to the misappropriated property and all its transformations. Restitution can cover the original item, its value if alienated or destroyed, or claims based on unjust enrichment if retained without legal basis. Confiscation also includes substitute property, mixed assets and any income or profits derived, effectively enabling tracing, although the term is not expressly used. Interim protective measures, such as freezing accounts or prohibiting disposal, may be applied during preliminary inquiries or investigations to secure property for eventual confiscation or satisfaction of the victim’s claims.

In the Republic of Croatia, enforcement priorities in financial crime are shaped by national needs and international obligations, particularly within the EU, Organisation for Economic Co-operation and Development (OECD), Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL) and Financial Action Task Force (FATF) frameworks, with an increasing focus on operational effectiveness rather than formal compliance.

Key priorities include:

• strengthening anti-corruption measures, particularly in relation to high-level and foreign bribery; improving efficiency of prosecutions and financial investigations; and
• enhancing procedural frameworks to increase convictions and expand confiscation of assets.

Asset recovery remains central, with an emphasis on extended confiscation and alignment with EU rules to ensure that crime does not pay.

AML/CFT enforcement is also a priority, focusing on supervision of obliged entities, risk-based approaches and strengthening private-sector compliance systems. Increasing attention is given to digital finance and crypto-assets, particularly under the EU MiCA Regulation, as well as to cybercrime and technology-enabled offences, including proposed regulation of AI misuse.

International co-operation, especially with EU bodies such as the EPPO, plays a key role, particularly in cases involving EU funds and cross-border financial flows. Overall, Croatia is shifting towards a more results-oriented system focused on effective enforcement, asset recovery and addressing emerging risks specialised units in DORH and police, as well as proposed Criminal Code amendments, such as criminalising misuse of AI systems.

In the Republic of Croatia, developments in white-collar crime show a clear trend towards normative modernisation and stronger enforcement, shaped both by international obligations (OECD, EU, MONEYVAL) and lessons from recent complex corruption and economic crime cases. Legislative reforms focus on strengthening the anti-corruption criminal-law framework, particularly in line with OECD instruments.

Following Croatia’s ratification of the Convention on Combating Bribery of Foreign Public Officials and participation in the OECD Working Group, the Criminal Code has been amended to expand bribery offences (especially involving representatives), introduce stricter sanctions and criminalise conduct preceding formal decision-making, such as influencing votes or abstention. These reforms reflect a materially broader understanding of corruption, aligned with OECD standards.

Enforcement practice shows intensified activity by USKOK, DORH and the EPPO, with growing numbers of complex investigations involving EU funds, cross-border elements and sophisticated financial structures. Recent high-profile cases illustrate this trend:

• Darko Horvat, former Minister of Economy, Entrepreneurship and Crafts, and later Minister of Physical Planning, was arrested in February 2022 for abuse of office in allocating non-repayable budget funds to connected entities that did not meet grant conditions;
• Gabrijela Žalac, former Minister of Regional Development and EU Funds, was investigated by the EPPO and Croatian authorities for misuse of EU and public funds, ultimately resulting in a conviction via guilty plea;
• Tomislav Tolušić, former Deputy Prime Minister and Minister, was accused of misrepresenting vineyards and secured funds to obtain approximately HRK7 million in EU subsidies; and
• Vili Beroš, Minister of Health (2020–24), was arrested in November 2024 in connection with manipulation of public procurement in state hospitals to secure benefits for a medical equipment distributor, illustrating the challenges of cross-border and institutional co-ordination, as seen in the conflict of jurisdiction between USKOK and the EPPO in this case.