Civil Forfeiture in 2025: From Isolated Cases to a Systemic Anti-Corruption Tool

In 2025, the SAPO filed 45 civil forfeiture claims—three times more than in the previous five years combined. 

This trend shows that the mechanism for recovering unjustified assets has evolved into a powerful system targeting public officials at every level, from members of parliament to customs officers and local government representatives. We previously reviewed and analyzed the specific features of this mechanism in a separate article.

Indeed, HACC’s 2025 case law has finally shattered the myth that assets can be safely concealed through relatives. It also points to a significant expansion in the range of defendants, from local self-government representatives to top officials, including members of parliament and deputy ministers. An analysis of SAPO’s work confirms that virtually all branches of government and oversight bodies have come under scrutiny, with particular focus on abuses in the customs and border services, as well as in executive and local authorities.

A key development in 2025 was SAPO’s shift from analyzing formal legal ownership to examining actual control over assets. Prosecutors began successfully proving in court that even if an asset is registered in the name of a distant relative or business partner, it is still subject to forfeiture if the official in fact uses it—for example, by paying utility bills, keeping personal belongings there, or regularly parking a car there. This approach has effectively closed the “nominee owner” loophole that for years allowed wealth to be hidden outside official asset declarations.

The appeals process in 2025 also became longer and more complex: defendants increasingly tried to delay proceedings as much as possible or find grounds to overturn forfeiture rulings. To do so, they challenged HACC decisions first before the HACC Appeals Chamber and then before the Civil Cassation Court.

Ukraine’s EU integration commitments also include the introduction of single-judge consideration of these cases, and the relevant draft law has already been registered in parliament. We therefore expect MPs to contribute to making this instrument more effective. 

Why are these precedents so important for combating corruption in public service? How did the asset value thresholds for claims change in 2026? And which luxury cars and “land empires” were ultimately returned to the public? Read the full breakdown of the year’s most high-profile cases on the HACC Decided platform.