Combating Corruption and Money Laundering (September 2025 – August 2026)

Key findings on combating corruption and money laundering from the sections of the Shadow Report for the European Commission prepared by Transparency International Ukraine.

This is the third Shadow Report that TI Ukraine has prepared in coalition with partners. This year, the scope of independent monitoring was significantly expanded . In addition to Chapters 23 ‘Judiciary and Fundamental Rights’ and 24 ‘Justice, Freedom and Security’, the experts conducted, for the first time, a comprehensive analysis of another component of the ‘Fundamentals’ cluster: the ‘Functioning of Democratic Institutions’.

The report consists of two volumes. It covers:

• the rule of law (courts, the prosecution service, the Bar and legal education);
• the fight against corruption and organised crime;
• the protection of fundamental human rights and freedoms;
• visa policy and migration;
• European integration matters;
• the work of the Verkhovna Rada and the Government;
• multi-level governance, elections and civil society.

Below, we present the key findings from the sections on the fight against corruption and organised crime prepared by TI Ukraine.

Key achievements

During the reporting period, progress in combating corruption was mostly piecemeal and depended on the internal efforts of individual institutions.

The main positive developments:

• Better performance by the HACC, NABU, and SAPO. The number of indictments sent to court and the number of verdicts both increased. The HACC and the HACC Appeals Chamber gained 17 new judges, and the HACC reduced its average case-processing time in 2025.
• More special confiscation. The amount of funds confiscated by court decision rose from UAH 158.8 million in 2024 to more than UAH 673 million in 2025.
•  Preparation of a new Anti-Corruption Strategy. The relevant parliamentary committee endorsed the consolidated draft Anti-Corruption Strategy for 2026–2030 (No. 15230-d).
• Inventory at the ARMA. The Agency completed a full inventory of property and identified more than 102,000 assets.

Institutional capacity of anti-corruption bodies

The development and independence of anti-corruption bodies continue to run up against political interference, pressure, and restrictions on the exercise of their powers.

International experts and selection procedures

• Published materials from NABU and SAPO investigations pointed to attempts by top officials of the Office of the President and the Cabinet of Ministers to influence the formation of selection commissions (for the NACP and the ESBU). These facts confirm that the participation of independent international experts with a decisive vote is a critical safeguard against the politicization of selection processes.
• The loss, in June 2025, of international experts’ right to take part in forming the Selection Commission for members of the HQCJ set a dangerous precedent, and the issue has still not been resolved in legislation.

Audits of the agencies

• NABU. The NABU is implementing the recommendations of its first audit (which rated it “moderately effective”), but there is a risk that international experts will be removed when the evaluation moves to a two-year cycle.
• SAPO. An audit has yet to begin, even though the legal grounds for it arose in March 2026.
• NACP. An external assessment has been blocked for more than four years because the Ministry of Justice has delayed approving its criteria and methodology. The Agency itself implements the recommendations of past audits only formally or refuses to implement them altogether.

Pressure on the NABU and SAPO and their functional independence 

Pressure on the NABU did not ease throughout the year:

• The SSU and the PGO detained NABU detectives and searched their premises.
• In February and June 2026, covert surveillance devices were found at the premises of heads of NABU units.
• Civil society organizations publicly called the Verkhovna Rada’s temporary investigative commission an instrument of pressure.

Several structural problems remain unresolved:

• Wiretapping. The NABU still depends on the SSU to intercept communications.
• Forensic examinations. There is no independent forensic institution for sensitive cases: state institutions are prone to data leaks, while private experts come under pressure.
• Investigative jurisdiction. Extending NABU’s jurisdiction to the leadership of the Office of the President, the SBI, and the ESBU has still not been addressed in legislation.
• Cases involving MPs. The powers of the SAPO head in proceedings against MPs remain unregulated, so all required procedural actions must be approved by the Prosecutor General.
• Single-judge hearings. Legislation has still not introduced single-judge consideration of civil and administrative cases at the HACC, which significantly overloads judicial panels and drags out proceedings. 

Although funding for the NABU, SAPO, and the HACC has increased, it still does not cover these institutions’ actual needs. For example, HACC judges’ salaries have been “frozen” since 2020.

Criminal justice

Law enforcement and the judiciary face procedural problems and legislative gaps.

Workload and deadlines at the HACC. In 2025, the average length of case consideration fell to 405 days, but in the first half of 2026 it rose again to 689 days. The backlog of pending cases is growing. 

Procedural “traps.” Automatic closure of cases upon expiry of the pre-trial investigation time limits (the “Lozovyi amendments”) has still not been repealed by law. For example, it was for this very reason that in May 2026 the HACC closed the high-profile proceedings concerning alleged embezzlement at Ukrzaliznytsia.

Measures against delaying tactics also need improvement. The President vetoed the law on higher fines for contempt of court, and the new draft law No. 15333 does not provide for monetary penalties for defense lawyers who fail to appear.

Plea agreements. A growing number of HACC cases end in plea agreements rather than full trials. In 2025, 72 of the 109 verdicts, or two-thirds, were delivered on this basis. 

This instrument speeds up justice and helps recover losses. However, public perception of such agreements remains a problem. The terms of some of them are opaque, which raises questions about why the defendant received the particular sentence specified in the verdict. The authors of the report believe that most of these questions can be addressed through better communication: the court and the prosecution should clearly explain the terms on which an agreement was concluded and what the state received in return.

Other agencies and investigative jurisdiction. The quality of corruption investigations by other law enforcement agencies (the NPU and the SBI) needs improvement. Of the 4,714 indictments filed in 2025, 3,935 were sent to court by the police, mostly for less serious offenses. Acquittals and revoked notices of suspicion call into question the quality of the SBI’s complex investigations. The SSU and other agencies continue to investigate cases that by law fall under NABU’s jurisdiction, and no liability is provided for this.

Criminal Code. Amendments to the elements of certain corruption offenses and to the rules for calculating limitation periods have still not been adopted, even though the new EU Directive on combating corruption, adopted in March 2026, requires them.

Financial control (NACP)

The Agency’s work in financial control and corruption prevention shows systemic shortcomings.

Low effectiveness of automated checks. In 2025, more than 244,000 declarations (40%) underwent automated verification, yet this tool fails to detect illicit enrichment, which is precisely what it is meant to target. For example, all declarations of former official Olha Stefanishyna passed automated verification, although the NABU and SAPO later served her with a notice of suspicion of illicit enrichment amounting to UAH 13.9 million. The same happened in the case of former minister Herman Halushchenko. 

Moreover, the IMF structural benchmark requiring an update of the risk-based verification system by the end of June 2026 has not been met. 

Lack of transparency and communication. The NACP still does not publish its logical and arithmetic control (LAC) rules and has not ensured transparent communication on the verification of declarations of certain senior officials (notably the former Head of the Office of the President, Andrii Yermak).

Lifestyle monitoring. This mechanism produces better results (unlawful assets worth more than UAH 1.1 billion were identified in 2025), but the procedure lacks automated case allocation and clear guarantees of objectivity.

Conflict of interest. The number of administrative offense reports drawn up by the NACP fell significantly, from 27 in 2024 to 11 in 2025. The Agency has no right to take part in court hearings or to appeal decisions on its own reports.

Party financing. More than 110 political parties systematically fail to submit financial reports. Fines for this are disproportionately low, and oversight of whether budget funds are spent appropriately is limited.

Assets (recovery, special confiscation, and ARMA reform)

The management of seized and confiscated property needs proper record-keeping and workable practical mechanisms.

Lack of records on special confiscation. Despite the growing volume of special confiscation ordered by courts, the state keeps no record of how such decisions are enforced, which makes it impossible to track actual revenue to the budget.

ARMA reform and inventory. The adoption of Law No. 4503-IX laid the groundwork for reforming the Agency. The full inventory has been completed: it identified 102,569 assets under court rulings, whereas the state register of seized assets lists only 44,815.

Problems in managing seized property:

• As of July 2026, the Prozorro module for selecting managers of simple assets had not been launched due to a lack of funding.
• Most of ARMA’s requests concerning the impossibility of effectively managing assets go unanswered by prosecutors.
• The selection commission failed to choose an ARMA head, so a new selection procedure has been announced.

Short version of the Shadow Report

How we prepared the report

In addition to TI Ukraine, experts from the Agency for Legislative Initiatives, the ZMINA Human Rights Centre, Tomorrow’s Lawyer, Europe Without Barriers, the Ukrainian Bar Association, the Civil Network OPORA, and the Centre for Democracy and Rule of Law worked on the report, and European Pravda provided informational support. 

In preparing our section on combating corruption and organized crime, Transparency International Ukraine experts:

• conducted 17 interviews with various experts, representatives of international partners, civil society experts, and public officials;
• sent 12 requests to state bodies to clarify statistical information;
• analyzed 73 measures of the Rule of Law Roadmap in the area of fighting corruption and countering money laundering;
• examined legislation and its application in practice;
• analyzed international standards, including EU regulatory documents;
• reviewed official and statistical data and, based on these, identified trends in the activities of the state bodies covered by the report.

Chapter 23 on Justice and Fundamental Rights and Chapter 24 on Justice, Freedom, and Security, examined in the Shadow Report, are part of Cluster 1, Fundamentals. This cluster is key to the entire negotiation process: it was the first to open and will be the last to close, at the final stage of negotiations, once all EU member states give their consent.

Full version of the Shadow Report