To the President of Ukraine 

Volodymyr Zelenskyy

To the Prosecutor General of Ukraine 

Ruslan Kravchenko

To the Director of the State Bureau of Investigation 

Oleksii Sukhachov

 

 

STATEMENT

On 11 July 2025, the State Bureau of Investigation (SBI) conducted searches at the home of the co-founder of the non-governmental organisation Anti-Corruption Action Centre, Vitaliy Shabunin.

At the time of the investigative actions, Shabunin is a sergeant serving in the 43rd Separate Mechanised Brigade of the Armed Forces of Ukraine. According to his lawyer, Olena Shcherban, the searches were conducted by the SBI at several addresses: at his place of registration in Kyiv, where Vitaliy’s family with young children currently lives, and at his place of service in the Chuhuiv district of the Kharkiv region. The searches were preceded by a prolonged and systematic smear campaign against Shabunin via anonymous Telegram channels.

According to the Anti-Corruption Action Centre, the investigative actions were conducted with numerous violations by the SBI, which were recorded by lawyers who arrived at the scene after the fact: the absence of court orders, the organisation of searches in such a way that lawyers were unable to arrive on time and take measures to ensure that rights were respected, the absence of video recording of the process of seizing equipment and items that could be used in the future for further discrediting, the seizure of items unrelated to the subject of the criminal proceeding, etc. Mobile phones were taken from Vitaliy Shabunin and his relatives, and even children’s tablets were seized.

The SBI served Shabunin with a notice of suspicion for “evasion of military service” and “fraud” (under Part 4 of Article 409 and Part 2 of Article 190 of the Criminal Code).

It should be recalled that Vitaliy Shabunin voluntarily enlisted in the Armed Forces of Ukraine from the first days of the full-scale invasion. He served in various regions of Ukraine, stationed with his military unit in accordance with official orders issued by the command. The SBI’s accusations of his alleged evasion of service are based on the period when Shabunin was on official assignment to the National Agency on Corruption Prevention (NACP) in accordance with an official order from the command. Such assignments of military personnel to state authorities and institutions are not unique. During his assignment to the NACP, Shabunin received standard financial support as a military serviceman in accordance with the applicable legislation, without any “combat” payments.

The legislation did not require Shabunin to undertake any special actions in the event of an assignment: his task was to go on the assignment in accordance with the order. The issue of whether or not a serviceman receives payments does not depend on his personal will, nor is he responsible for processing such payments. These matters are regulated by the state, and if it considers that an unjustified payment has been made, there is a civil law institution through which a claim for the return of funds may be filed.

Therefore, Vitaliy Shabunin is being suspected of committing actions that were carried out by state bodies, because a military serviceman does not decide how much he should be paid and by whom; he is a subordinate who, while in service, is in the “hands” of the state and dependents on it.

The official press release of the SBI also contains a manipulative reference to the use of a volunteer car. However, according to the Anti-Corruption Action Centre, this claim was not included in the notice of suspicion, as this practice is legal and widely used in the Defence Forces. Moreover, private donors had previously given a public explanation that the purchase was made with funds from the CEO Club and that the car was transferred specifically for the needs of military serviceman Shabunin. Since the donors who financed the purchase of the car do not believe that their rights have been violated and have not appealed to any law enforcement agencies to restore their rights, the latter have no legal grounds to accuse the serviceman of using a car that is not owned by a state body or military unit.

Thus, the actions of the pre-trial investigation bodies can be considered either as complete incompetence of officials and unsuitability for their positions, or as a deliberate attack aimed at putting pressure on Vitaliy Shabunin, who continued to criticise the work of state bodies while serving in the military.

This criminal prosecution has signs of being politically motivated and constitutes an abuse of law, i.e. it has been carried out in violation of Ukraine’s obligations under Article 18 (Limitation on use of restrictions on rights) of the Convention for the Protection of Human Rights and Fundamental Freedoms, in conjunction with Article 6 (Right to a fair trial) and Article 10 (Freedom of expression) of the said Convention.

This prosecution is yet another episode in a long history of attacks against Vitaliy Shabunin personally and against the Anti-Corruption Action Centre he heads, which have been ongoing since 2016.

We, the undersigned representatives of human rights, anti-corruption organisations and other civil society groups, appeal to the President of Ukraine, the Prosecutor General and the Director of the SBI to prevent the justice system from being used for political reprisals and persecution of government critics.

We call upon:

  • The President of Ukraine – to publicly state the inadmissibility of politically motivated persecution of civil activists.
  • The Director of the SBI – in accordance with paragraph 2 of Article 39 of the Criminal Procedure Code, to suspend the investigators who conducted the pre-trial investigation of this case and initiate disciplinary proceedings against them; in accordance with paragraph 4 of Article 39 of the Criminal Procedure Code, to rectify violations of the law committed by the investigators; to assume personal responsibility and, in accordance with paragraph 5 of Article 39 of the Criminal Procedure Code, personally conduct a full pre-trial investigation, exercising the powers of an investigator.
  • The Prosecutor General – to ensure impartial procedural management of the pre-trial investigation and conduct an internal investigation of the investigators in the event of gross violations of criminal procedure law; if no elements of a criminal offence are found, to close the criminal case against Vitaliy Shabunin.

Pressure on civil activists is unacceptable in a democratic country such as Ukraine.

  1. Human Rights Centre ZMINA
  2. Institute of Mass Information
  3. Anti-corruption center “MEZHA”
  4. The Anti-Corruption Headquarters
  5. “Holka” (NGO “The Needle”)
  6. Centre for Economic Strategy 
  7. NGO “Human rights platform”
  8. Kharkiv Anti-Corruption Centre
  9. Media Initiative for Human Rights
  10. DEJURE Foundation
  11. National NGO “Institute Of Political Education”
  12. All-Ukrainian Association “Automaidan”
  13. NGO “Women’s Anticorruption Movement”
  14. International Centre for Ukrainian Victory (ICUV)
  15. The Center for Democracy and Rule of Law (CEDEM)
  16. Ukrainian Center for Independent Political Research
  17. NGO “Zaporizhzhia Investigations Centre”
  18. Centre of Investigative Reporting “The Power of Truth”
  19. Public Control Platform 
  20. ANTS – National Interests Advocacy Network 
  21. Civil Network OPORA
  22. Bihus.Info
  23. The CHESNO movement
  24. CASE Ukraine – Center for Social and Economic Research
  25. NGO “MINZMIN”
  26. Anti-corruption Research and Education Centre (ACREC)
  27. Human rights initiative “Pravotvorets”
  28. Transparency International Ukraine
  29. NGO “Crimean Process”
  30.  NGO “Zero Waste Lviv”
  31. NGL.media
  32. NGO “Ukrainian LGBT+ Military and Veterans for Equal Rights”
  33. NGO “Local Development and Reforms Center”
  34. NGO “Social Capital”
  35. NGO “Rivne Social Partnership Centre” (Initiative “For Fair Tenders”)
  36. Information and Analytical Centre “Civic Space” 
  37. NGO “Proactive Community”
  38. NGO “Civic Control Coordination Centre”
  39. Civic Union “Human Rights House Crimea”
  40. Open Data Association
  41. National Charitable Organisation “Ukrainian Legal Aid Foundation”
  42. NGO “Centre of Law Enforcement Activities Research”
  43. StateWatch Analytical Centre
  44. NGO “Genealogical Community “Arkhisovist”
  45. NGO “People’s Will” (“Volia Hromady”)
  46. NGO “Institute of Legislative Ideas”
  47. NGO “Civil holding “GROUP OF INFLUENCE”
  48. NGO “Centre of Policy and Legal Reform”
  49. Kremenchuk Anti-corruption Centre
  50. NGO “ZORAX”
  51. NGO “Ecosphere”
  52. NGO “Green Leaf”
  53. NGO “RIPO Patriot”
  54. NGO “Coalition of Culture Actors”
  55. International Renaissance Foundation
  56. NGO “BCD”
  57. Educational Human Rights House Chernihiv
  58. Recruiting platform Lobby X
  59. Ukrainian Legal Advisory Group (ULAG)
  60. NGO “Youth organization ”Interaction”
  61. NGO “Kod 21” 
  62. Detector Media
  63. NGO “Cherkasy Information Agency ”18000″
  64. NGO “Horizon of changes”
  65. The German Marshall Fund of the United States
  66. NGO Cherkasy Information Agency “18000”
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The actions of the pre-trial investigation bodies can be considered either as complete incompetence of officials and unsuitability for their positions, or as a deliberate attack aimed at putting pressure on Vitaliy Shabunin, who continued to criticise the work of state bodies while serving in the military.