9 candidates for the post of the SAPO head sent Transparency International Ukraine, the Anti-Corruption Action Centre, the DEJURE Foundation, and Automaidan additional explanations on questions which raised reasonable doubts about their integrity. In particular, we are talking about Oleksii Heiko, Viktor Kutsyi, Andrii Syniuk, Volodymyr Hulkevych, Maksym Hryshchuk, Andrii Kasian, Oleh Borysenko, Oleksandr Formahei, and Oleksii Semeniuk.

Experts of civic organizations have analyzed the information provided by candidates. The publication provides explanations of what candidates sent to our official email addresses and the conclusions of analysts regarding them. Five candidates gave full consent to the publication of their explanations.

You can find the analysis of the explanations of the candidates Volodymyr Hulkevych, Maksym Hryshchuk, and Andrii Kasian below.


Volodymyr Hulkevych, head of the Department of the Ivano-Frankivsk Regional Prosecutor’s Office.

You can get acquainted with the candidate’s explanations here.


  • Possible non-declaration
  • The candidate’s declaration for 2015 implies an inconsistency between his income and expenses. This year, the candidate bought a car in the name of his son for UAH 530,000 and saved money in foreign currency equivalent to UAH 700,000.  In total, this is almost half a million hryvnias more than the amount of income and previous savings of the family.


Candidate’s explanation: the candidate claims that together with his wife from 2000 to 2015 they received at least UAH 3,417,975 or USD 421,408 in salary and pension. This allowed them to save the money indicated in the declaration and buy a car for their son. The candidate provided documentary evidence of this to the selection commission.

Analyst’s comment: since the candidate did not provide documents confirming the above, here and further we present candidate’s explanation with his consent, no changes. The candidate noted that he had submitted supporting documents directly to the selection commission. In general, if the candidate indeed provides documents confirming the facts indicated by him, then his explanations are satisfactory.

  • In 2014, the candidate did not declare housing in Ivano-Frankivsk, where he worked as deputy prosecutor of the region, only his wife’s apartment in Lviv, a garage, and the right to use an apartment in Ternopil. The cost of two cars used by the candidate and his family also remained undeclared.

Candidate’s explanation: the candidate notes that during 2014 he did not live in any housing in Ivano-Frankivsk for more than 1 month (stayed with friends, relatives, hotels, sometimes commuted). Since 2015, the candidate has been renting housing in Ivano-Frankivsk and has been declaring it ever since. In the same written declaration for 2014, the candidate indicated two cars owned by him and his wife: a 2000 Subaru Forester and a 2008 Mitsubishi Outlander. According to the then written declaration, in section IV, it was necessary to indicate the amount of expenses for the procurement of a car in the year for which income and expenses were declared. Since in 2014 he did not purchase any car belonging to him, and therefore he did not indicate the cost of procurement. For a family member, the declaration at that time did not envisage the obligation and possibility of indicating the cost of the purchased car at all. The wife also didn’t buy any car in 2014. In the electronic declarations of a person authorized to perform the functions of the state or local self-government, introduced in 2016, it is necessary to indicate the cost of the vehicle as of the date of acquisition, possession or use, which the candidate did, starting with the electronic declaration for 2015.

  • Since 2015 and until now, the candidate has not declared his wife’s mortgage in the amount of USD 88,000, issued before September 2022.

Candidate’s explanation: the indicated mortgage was paid ahead of schedule in 2012. The Bank Forum PJSC promptly sent an application for the withdrawal of encumbrances of the real estate object and a notification about the exclusion of an entry in the State Mortgage Register to the notary, so the candidate’s wife was sure that the indicated apartment was excluded from this register. However, it has recently turned out that the notary did not perform the necessary actions due to being on parental leave. The candidate’s wife is taking measures to remove the encumbrance of the apartment and exclude it from the State Register of Mortgages.


  • Possible violation of integrity requirements


Doubts about the moral and ethical qualities of the candidate arise due to an accident involving him in 2020: he hit a parked car and left the scene.

Candidate’s explanation: the candidate claims that at the time of the accident, he was on outpatient treatment for coronavirus disease. Besides, the case file indicates someone else’s car number, and the testimony was provided by an unknown witness. This was the reason for closing the proceedings in an administrative case due to the absence of elements of an administrative offense in the candidate’s actions.


  • Possible inconsistency between income and lifestyle


The candidate’s son is studying at an American law college, where a year of study costs about USD 44,000, and the son himself, according to information from his Facebook page, travels a lot.  This raises the question of the family’s ability to pay for tuition and travel.

Candidate’s explanation: the candidate’s son attended an American college for two semesters and graduated in 2014. The cost of it was USD 19,250 (a discount is provided to Ukrainian students). The candidate notes that the son and family had sufficient incomes to provide such studying.

Maksym Hryshchuk, acting head of the SAPO

The candidate did not grant permission to publish the text of the explanations.

  • Doubts about integrity

In July 2018, Maksym Hryshchuk came to a meeting of the Qualification and Disciplinary Commission of Prosecutors to consider the complaint of the NABU against his senior Nazar Kholodnytskyi (the so-called “Kholodnytsky aquarium films”). Such an appearance was perceived as support for Kholodnytskyi when considering a complaint against him.

Candidate’s explanation: not provided

  • Possible non-declaration 
  • Until 2020, the candidate did not declare an apartment in Ternopil, which has been owned by him on the right of common ownership since 1996.

Candidate’s explanation: not provided

  • In the declaration for 2019, he allegedly underestimated the cost of a second-hand car Land Rover Discovery Sport of the 2016 manufacture year. According to the declaration, it cost UAH 368,500 — this is twice as cheap as the initial price of a second-hand car of the same brand today, according to specialized sites. Given this, in 2019 the price of such a second-hand car was higher, since the car was newer.

Candidate’s explanation: the candidate explained that he had bought a car in the United States at an auction and transported it to Ukraine. In the declaration, he indicated the price at which he purchased the car, in hryvnia equivalent.

Analyst’s comment: the candidate’s explanations are sufficient.

Andrii Kasian, SAPO prosecutor.

The candidate did not grant full permission to publish the text of the explanations.

  • Possible improper declaration 
  • The candidate’s declaration for 2020 states that the candidate’s wife has been registered and uses an apartment of 26 square meters in Kyiv since 2007.  However, there is no information about this apartment in the declarations for 2017-2019.

Candidate’s explanation: the candidate explained that he had not declared his wife’s apartment because she did not provide him with information, and neither does she use the indicated housing. In addition, the candidate refers to the absence in the legislation of a direct indication of the need to declare such information: “the current version of Article 46, part 1, clause 1 of the Law of Ukraine “On Prevention of Corruption” envisages the need to declare a “registered place of residence” in relation to “the declaration entity and members of their family,” while the previous version envisaged the obligation to declare a “registered place of residence” only in relation to the declaration entity.

Analyst’s comment: information about real estate objects that are the registered place of residence of the declaration entity or their family members must be indicated in the declaration, even if the person does not actually live there. The mention of the place of registration in Article 46, part 1, clause 1 of the Law of Ukraine “On Prevention of Corruption” concerns only the address of such a place itself, which does not affect the need to indicate the real estate object in the declaration.  Moreover, providing information about real estate objects that are under the right of use of the declarant or their family members is important not only from the point of view of assessing the property status and identifying possible signs of illegal enrichment, but also for identifying private interests that may lead to a conflict of interests. When a certain object belongs to a third party, and an official or a member of their family uses or has the right to use the property of such a third party, the declaration must identify such third parties.

  • The declaration for 2018 does not include the previously declared car of his wife Nissan Qashqai 2013, but there is no information about the income from the sale.  The same declaration contains information about the wife’s income from an unknown source without specifying the amount of this income.

Candidate’s explanation: the candidate’s wife sold the car in 2018, but did not provide the candidate with information about the transaction amount.

  • For 2020, the candidate only once in early April reported significant changes in the property status of UAH 181,000.  At the same time, the candidate’s salary for the year amounted to UAH 1.5 mln.

Candidate’s explanation: since the salary was paid to the candidate twice a month, the amount of each payment did not exceed 50 subsistence minimums that are to be declared. UAH 181,000 was paid to the candidate in a lump sum when going on vacation, so, the amount was declared.

Analyst’s comment: the candidate’s explanations are sufficient.

  • Inconsistency between income and lifestyle 
  • The candidate’s parents work in the judicial system and the public sector. They own two land plots: the mother’s house, which the candidate uses, the father’s house and apartment — all in Kyiv. According to the declaration of the candidate’s father, both houses in the capital were purchased in 2013. In the same year, the candidate’s father bought a new executive car Mercedes ML 350, and three years later replaced it with another car — Mercedes C 220 worth USD 30,000.

Candidate’s explanation of the mother’s home: the candidate notes that the construction of one of the houses began back in 2006. The house was built at the expense of funds from the salary of parents, funds received from the sale of apartments in Poltava and Kyiv, as well as financial assistance from their parents. In 2013, the house was put into operation.

Analyst’s comment: the candidate did not provide any financial documents that would confirm the origin of funds for the construction and arrangement of the house, except for the property declaration of his father for 2011, as well as the grounds for purchasing the mentioned apartments in Poltava and Kyiv. In the indicated declaration, the area of the mentioned house is 196.4 sq. m, and later it was rebuilt to 234 sq. m.

Candidate’s explanation of other real estate: the apartment and garden house with a total area of 184 sq. m were inherited by the father after the death of his parents (father May 11, 2005, mother February 3, 2010). Ownership of the garden house was also registered only in 2013.

Candidate’s explanation regarding the cars: at the expense of funds from the sale of cars previously owned by parents, a second-hand Mercedes ML 350 executive car was purchased in 2013. Then it was sold in 2016 and for these funds they purchased a Mercedes C 220 car, which does not belong to executive cars.

Analyst’s comment: according to the candidate’s father’s declaration for 2011, the family owned only one car at that time — a 2007 Honda. At the same time, the declared value of the purchased Mercedes ML 350 of the year 2012 of manufacture amounted to UAH 245,000 (about USD 30,000 for 2013).

  • The candidate’s retired grandmother bought an apartment in Kyiv with an area of 92.7 sq.m in 2009.

Candidate’s explanation: the candidate’s grandmother purchased an apartment with the money obtained from the sale of her property — an apartment in Kyiv, purchased in 2004 at the expense of the money obtained from the sale of a two-room apartment in the center of  Sverdlovsk, Russia, a country site with construction in progress, and other property in 2003 and 2004 for a total amount of USD 87,000.

Analyst’s comment: the candidate’s explanations are sufficient.