This is a situation when former civil servants move to work in private companies with which they previously interacted, or vice versa – business representatives take key positions in the authorities. According to GRECO assessment, in Moldova this area remains poorly regulated and creates direct corruption risks. This is especially true for law enforcement officials.
Recommendations not implemented
GRECO Recommendation XXIV notes that the previous report requested the Moldovan authorities to establish an effective oversight mechanism for the implementation of the rules on post-employment restrictions for law enforcement officers and to empower the oversight mechanism to impose adequate sanctions in case of violations of the rules on post-employment restrictions.
The report notesthat the Moldovan authorities refer to Law No. 82/2017 on Integrity, which provides for the enforcement of the regime of restrictions and limits with regard to the termination of service, labor or employment relationships and the transfer of public servants to the private sector.
However, GRECO notes that although the authority is formally competent to initiate proceedings for violations of restrictions after termination of employment, the lack of an effective oversight mechanism, systematic monitoring or statistical data on the application of measures in practice leads to the conclusion that the authority to impose sanctions is neither efficient nor effective. Therefore, this part of the recommendation has not been implemented, the report concludes.
“Revolving doors” as a systemic risk
What does this mean in practice? The report emphasizes: “Restrictions applied after leaving public service remain insufficient and require further development.” In fact, this means that former officials can use the connections, access to information and influence gained in public service to benefit private entities.
The organization’s experts recommend introducing clear rules for a “cooling-off period” during which former officials cannot work in sectors related to their former activities.
GRECO considers this very important and points out that the “revolving door” problem is considered one of the key issues in EU anti-corruption practice, as it is difficult to detect but has a systemic impact on decision-making.
In the Moldovan context, the risks are exacerbated by the weakness of control institutions and the limited resources of the supervisory authorities.
In this regard, GRECO emphasizes the need:
– Establish clear restrictions on employment after civil service;
– ensure monitoring of such transitions;
– introduce sanctions for breach of the rules.
In the final conclusion, the experts make it clear: without solving this problem, even increased control and transparency within the system may not be enough.
In other words, corruption risks do not disappear when an official leaves office – they simply change form.
