What the NACP Missed in Halushchenko’s Asset Declarations?

Could the millions an ex-minister of justice laundered well before NABU opened its investigation, have been spotted? After all, the official filed annual asset declarations that the NACP is supposed to verify.

On February 19, the NABU released new details in its investigation into the Midas case involving Herman Halushchenko, who was recently notified of suspicion for money laundering and participation in a criminal organization. According to NABU’s materials, assets linked to the former minister of justice and energy—whom members of the criminal organization allegedly referred to as “Sigismund”—were registered in the names of his relatives through a complex network of offshore companies and funds.

Once again, the NACP’s role in this situation is hard to ignore. The Agency is authorized to verify public officials’ asset declarations. And yes, the NACP did verify two of Halushchenko’s annual declarations—for 2021 and 2024—through a “full” review that was automated rather than manual. We criticized this NACP innovation back in 2023 because the entire check essentially boils down to cross-referencing a declaration against registries and databases. Real schemes, however, can only be uncovered through manual work by digging deeper and analyzing information. 

Halushchenko’s case looks like yet another confirmation that the NACP must update its approach. So, let’s break down what exactly the Agency overlooked in Halushchenko’s declarations.

The offshore scheme

NABU detectives established that between 2021 and 2025, a total of USD 12 million was laundered for the benefit of “Sigismund” and his family—funds that were largely held in foreign accounts.

Some of this laundered money was spent on the family’s needs, including:

• paying for the children’s expensive education at elite institutions in Switzerland,
• medical services at a clinic owned by one of the scheme’s participants (“Sugarman”),
• buying designer clothing at Kyiv boutiques, and more. 

To launder the funds, Halushchenko built a multi-tiered structure. In particular, three companies were registered via offshore jurisdictions in the Marshall Islands. They became part of a trust registered in Saint Kitts and Nevis and also acted as investors in a fund on the island of Anguilla, which was used to attract and launder money. In this way, the funds were carefully concealed.

Still, the NACP could have noticed certain manipulations from Halushchenko’s declarations. 

Halushchenko listed his former wife and four children as the official beneficial owners of the offshore companies. This is a common concealment scheme: assets are registered in the names of relatives or close associates who do not live with the declarant, allowing their assets to be omitted from the declaration. “Divorces” are also often fictitious for precisely these reasons.

But under the law, minor children must be declared by public officials regardless of whether they live together. Accordingly, in his 2024 declaration, Halushchenko listed his four children as family members. Yet he did not disclose any of his children’s assets—neither in the section on corporate rights nor in the section on beneficial ownership of family members’ assets.

In the 2021 declaration, when Halushchenko was still married and declared his wife’s assets, her corporate rights and beneficial ownership in the architectural bureau Prostir 86 are reported. But there is still no mention whatsoever of beneficial ownership in offshore companies.

If Halushchenko’s declarations had been selected for a manual review not limited to registry cross-checking, Agency staff could at minimum have sent follow-up requests both to the declarant and to national and international authorities.

It is also worth noting that, unlike NABU, the NACP still has weak international cooperation with foreign authorities when it comes to obtaining information on officials’ or family members’ foreign assets. This is an area the NACP clearly needs to strengthen.

Education in Switzerland 

According to an investigation by Schemes, Halushchenko’s son Maksym has been studying for the fourth consecutive year at one of Europe’s most expensive private colleges—College Alpin Beau Soleil in Switzerland—where tuition and boarding can cost up to USD 200,000 per year. Over four years, the total cost could reach roughly USD 700,000, or UAH 26 million—many times more than Herman Halushchenko’s family’s official income and declared savings. Journalists were able to establish this using open-source data.

In court, Halushchenko explained that different people paid for the education—his son’s godparents and family friends. This information requires additional scrutiny by NABU and, ideally, the NACP as well, since the Agency should have examined it much earlier.

NACP guidance indicates that education payments fall under expenses that must be declared. At the same time, only the declarant is required to report such expenses—so if third parties truly paid for the education, this information would not appear in the “expenses” section.

However, the declaration also contains a section on gifts—and that is where information about paying for Halushchenko’s son’s education should have appeared. The NACP has explained that when a third party covers the declarant’s or a family member’s costs for travel (flights, accommodation), treatment, education, and so on, it is considered a non-cash gift. As a general rule, such a gift must be reflected in the declaration with its value indicated.

So if Halushchenko’s son’s education was paid for by godparents and family friends, this should have been shown in Halushchenko’s declaration, unless each of them paid less than the reporting threshold, which is highly unlikely given the tuition figures cited above.

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Once again, we are looking at a situation where the NACP has remained on the sidelines of a high-profile scandal. Once again, most of the facts were uncovered by journalists or by NABU detectives during criminal proceedings. 

We understand that the NACP’s functions and capabilities differ significantly from NABU’s, and we are not comparing them. Still, it appears the NACP had sufficient tools to verify information about Halushchenko’s assets long before he was notified of suspicion.

Two automated “full” reviews of the declarations of the person whom participants in the scheme allegedly called “Sigismund” produced no results at all. Most likely, the former minister’s declarations will now be selected for a repeat, manual full review—just as happened after the Tetiana Krupa scandal. But the effect of such an after-the-fact review is disproportionate to the mandate of a body that is supposed to prevent corruption. 

The facts we cite should be yet another wake-up call for the NACP: it unquestionably and urgently needs to revise its approach to financial control. But will the Agency listen?