Vitalina Harkava, Head of the Public Procurement Sector, Executive Committee of Boiarka City Council 

When the legal department asked her to review every contract with additional agreements signed since 2021, Vitalina knew right away this wouldn’t be easy. The task covered 300–400 contracts. Before the training, she had already used the analytics module for price monitoring and looking up procurement information, but by her own admission, her knowledge of the tool was fairly superficial. The legal department’s request pushed her to look for a new approach. Reviewing several hundred contracts by hand, finding every additional agreement, and analyzing the changes would have taken at least two to three weeks.

The solution came during the training itself. At one of the webinars, Vitalina described her task and asked whether BI Prozorro could handle it. The answer turned out to be surprisingly simple: yes.

“Iryna showed me in literally 10-15 minutes how to do it in BI Prozorro. Honestly, I was amazed. Work I’d mentally set aside two-three weeks for suddenly became so much simpler. All I had left to do was the analysis itself and writing up the results,” she recalls. 

That was the moment Vitalina truly grasped BI Prozorro’s practical value. 

Still, she admits it took some time to get comfortable with the tool. The filters gave her the most trouble — one wrong step and the data she needed would disappear. So she kept going back to the recorded sessions, working through each step again from the start. That’s how she gradually built up an understanding of how the module works.

But the biggest discovery for her wasn’t the time savings — it was the ability to see how other communities operate. That’s exactly what she chose to explore for her homework assignment: what other communities procure, how many contracts they sign, how often they amend them, and which procurements they cancel. 

“I learned a lot about how other communities work and the mistakes they’ve made. That’s useful, because it means I don’t have to repeat the same mistakes in my own work,” Vitalina says. 

Since then, she’s started looking at other communities’ procurement in a new light. She believes, procurement data can reveal more about a community than any report. All it takes is a look at where the money goes to understand its priorities — road repairs, infrastructure development, or other projects.

Vitalina also uses the tool to spot risk in procurement. With Ukraine’s State Audit Service and other oversight bodies conducting regular checks, she says contracting authorities need to work proactively — analyzing their own contracts and flagging anything that might raise questions during a monitoring review.

“We need to check ourselves before an external monitoring review comes to us. We have to see our own risks and fix them ahead of time,” Vitalina says.

Oksana Karakai, Chief Specialist, Accounting and Finance Department, Kamianske City Council

“I wouldn’t even have noticed that.” That thought crosses Oksana Karakai’s mind more often than she’d like when she reviews State Audit Service monitoring reports and reads through auditors’ findings on other contracting authorities’ procurement.

Working at Kamianske City Council, Oksana regularly tracks procurement not just for her own community but for other organizations as well. She’s especially drawn to monitoring reports — which procurements get flagged, what violations auditors find, and what catches their attention when they review documents. After the BI Prozorro training, Oksana started paying much closer attention to these reports. Now she treats many auditors’ findings as pointers for her own work — a chance to catch risks before they become problems. 

“When I see a comment or a question from an auditor, I immediately check whether something similar could happen in our case,” she says.

Just a few months ago, Oksana only had a passing familiarity with BI Prozorro. She first encountered the module at a training session on price analysis, where she only managed to get comfortable with one section — but it was enough to realize the system had far more to offer. That’s what led her to sign up for TI Ukraine’s training. She says the practical exercises helped the most; working through them was how she gradually got a handle on the interface and the logic behind the module.

Oksana felt the practical benefit almost immediately. She needed to put together a list of contracts for the year. In the past, that meant gathering the information by hand, cross-checking it against her own spreadsheets, and making sure nothing had been missed. In BI Prozorro, the task went far faster.

“It took a bit of figuring out at first, but once I understood how it worked, I had a ready-made table right away. It’s incredibly fast — I mean, super fast,” Oksana recalls.

She says the whole task took about twenty minutes. Previously, putting together a sample like that could easily take half a day.

“You had to gather everything, check it, and format it properly. Here, in a few clicks, I got a full summary of every contract for the entire year,” she says.

Oksana believes the ability to work with open data and analytical tools is becoming increasingly important for local governments. However, she’s noticed that not everyone is ready to pick up new tools and change familiar ways of working.

She sums up BI Prozorro’s main advantage simply: it’s a large body of information that’s already organized and gathered in one place. Instead of spending hours hunting for data by hand, you can find it — and analyze it — in the same tool, in a fraction of the time.

Not long ago, she used to search for procurement records on the Prozorro portal herself, scrolling through dozens of pages and losing a lot of time in the process. Today, most of those tasks get done much faster. That’s why Oksana’s advice to anyone just starting out with BI Prozorro is not to be afraid of investing time in learning it — it’s nothing compared to the time it will end up saving.

Nataliia Kostenko, Chief Specialist, Department of Digital Transformation, Information Policy and Transparency, Sheptytskyi City Council

For Nataliia Kostenko, the BI Prozorro training wasn’t an introduction from scratch. She’s worked with BI modules for a long time and regularly uses them to analyze her community’s work. Even so, the training gave her a fresh perspective on what the analytics could do. 

“The main benefit is that we see the whole picture at once,” Nataliia says. 

She explains that an authorized procurement officer typically looks at one procurement or tender at a time. BI Prozorro makes it possible to see procurement across the entire community — from the executive committee down to municipal enterprises. That kind of overview helps not just with analysis, but with spotting risks and making decisions based on them.

When Nataliia showed the BI tools to staff in Sheptytskyi City Council’s land department, their reaction was strikingly emotional. Within minutes, the system generated a data sample that used to take hours to prepare.

“They were amazed that we could pull a complete sample for any given period in a single minute,” Nataliia recalls. 

Since the training, Nataliia has been using the module more actively to analyze the community’s biggest suppliers. It gives her a quick view of which companies work most often with the municipal enterprises and the executive committee. 

“This way we can see the scale of procurement, the scale of company participation in it, and draw our own conclusions,” Nataliia explains.

In her view, the real value of analytical tools lies in helping communities work more transparently, make decisions faster, and use limited staff resources more effectively.

“We used to have to collect a lot of information manually. Now we can see the whole system at a glance and make decisions based on data,” Nataliia says. 

That’s why she’s convinced analytical tools have long stopped being a nice-to-have for communities. Today, they’re one of the key tools of local governance.

The three communities’ stories are different. For one, BI Prozorro became a faster way to work with contracts; for another, a tool for finding risk; for a third, a way to see the whole procurement system at once. But all the training participants agree on one thing: data analysis is no longer a nice extra skill — it’s steadily becoming an essential part of how local governments do their work.

For city council staff or other local government representatives looking to get started with BI Prozorro, we recommend beginning with the video lecture series How to Manage Procurement.

This material was made possible with the support of the MATRA program of the Embassy of the Kingdom of the Netherlands in Ukraine.

What happened: a timeline of events

At the center of events is a criminal proceeding against Olena Lukash, former Minister of Justice of Ukraine, charged with misappropriation of budget funds and official forgery. Here is how the HCJ decision regarding HACC Appeals Chamber judges came about.

2014 — Proceeding entered into the Unified Register of Pre-Trial Investigations; investigation conducted by the Prosecutor General’s Office. 

October 17, 2019 — Deputy Prosecutor General Chumak serves Lukash with a revised notice of suspicion.

October 21, 2019 — Prosecutor General Riaboshapka transfers the investigation to the NABU; the HACC was henceforth to exercise judicial oversight in the case.

March 2020 — Lukash’s defense counsel files a complaint against the notice of suspicion with the Pecherskyi District Court; the SAPO prosecutor requests the Supreme Court transfer the case to the HACC.

October 12, 2020 — The Supreme Court declines: because the notice was not signed by the SAPO prosecutor, the case supposedly falls outside the HACC’s jurisdiction; the investigating judge of the Pecherskyi District Court grants the defense counsel’s complaint and cancels the suspicion.

November 2020 — The Kyiv Court of Appeal leaves the defense counsel’s complaint against the Pecherskyi District Court’s decision without granting it.

January 2021 — The HACC Appeals Chamber, following the SAPO prosecutor’s complaint, cancels the Pecherskyi District Court’s ruling and closes the proceeding on the complaint.

January 22 and 25, 2021 — Olena Lukash files complaints with the HCJ against the actions of the HACC Appeals Chamber judges. In her complaint, she argued that the HACC Appeals Chamber judges had no authority to review the case.

November 2025 — The Third Disciplinary Chamber of the HCJ refuses to hold the HACC Appeals Chamber judges liable.

May 2026 — The HCJ sitting in plenary session sets aside this decision and issues warnings to judges Kaluhina, Semennykov, and Mykhailenko.

The complaint against the disciplinary chamber’s decision was filed by attorney Ivashchenko—Lukash’s defense counsel, who is himself a defendant in the same criminal proceeding. It is also worth noting that the Supreme Court’s October 2020 decision, on which the HCJ relies, was based on a specific criterion—who signed the notice of suspicion—a criterion that does not actually appear in the Criminal Procedure Code’s provisions on HACC jurisdiction.

The “case dumping” scheme through the Pecherskyi District Court

From 2020 onward, subjects of NABU investigations began exploiting investigating judges, predominantly from the Pecherskyi District Court in Kyiv, as a tool to remove their cases from anti-corruption proceedings. 

The scheme is straightforward: a complaint is filed with the Pecherskyi District Court alleging inaction by the Prosecutor General’s Office concerning the Prosecutor General’s failure to review a defense motion within a NABU criminal proceeding—despite the fact that formally such a court lacks authority to review complaints in NABU cases. Yet the complainants argue that because the Prosecutor General’s Office is located within the territorial jurisdiction of the Pecherskyi District Court, that court is authorized to hear such complaints. The court then issues a ruling favorable to the suspect—for example, ordering the transfer of the case to another investigative body or canceling the suspicion. Subsequently, the Prosecutor General’s Office complies with this ruling, and the case is effectively removed from the system.

This is precisely what happened in the Ukrbud case, involving Oleh Tatarov, then Deputy Head of the Presidential Office. There, the Pecherskyi District Court unlawfully ordered the removal of the case from NABU’s investigative authority. The Prosecutor General’s Office complied, and later Office prosecutors blocked all efforts to return the proceeding to the Bureau by withdrawing an appeal filed with the HACC Appeals Chamber. Similar situations arose in the cases of Zlochevskyi, VAB Bank, and the Dubnevych thermal power plant—matters we will discuss further.

The response to this was as follows: SAPO prosecutors, and sometimes PGO prosecutors, filed appellate complaints with the HACC Appeals Chamber. That court repeatedly reviewed and cancelled rulings issued by the Pecherskyi and other district courts, consistently holding: appellate review of any decisions in cases falling within the HACC’s jurisdiction may be conducted exclusively by the HACC’s Appeal Chamber. 

Yet the Supreme Court, in several decisions concerning the Zlochevskyi case in March 2021 and August 2021, as well as in the case of DACK judges from August 2020, held that when a decision was formally issued by a court of general jurisdiction, it must be appealed to the appellate court of general jurisdiction, not the HACC Appeals Chamber. Interestingly, this position conflicted to some degree with other similar situations.

In light of this, the HACC Appeals Chamber was sometimes compelled to dismiss appeals of district court rulings. This occurred in the Zlochevskyi case and in the VAB Bank case.

The problem of jurisdiction over NABU cases in courts of general jurisdiction was so serious that it appeared in the National Anti-Corruption Strategy for 2023–2025 as a separate priority. This means that the state, at the level of a government document, acknowledged that judicial review of NABU cases by other courts represents a systemic problem that must be addressed. The state should therefore adopt specific legislation to prevent such practices. Yet by holding accountable the judges who resisted this practice, the HCJ is moving in the opposite direction.

Against this backdrop, the disciplinary case concerning three HACC Appeals Chamber judges developed—judges whom the High Council of Justice warned in May 2026.

Why HACC Appeals Chamber judges had grounds to act as they did

The January 12, 2021 ruling of the HACC Appeals Chamber in the case of Lukash’s complaint against the notice of suspicion contains detailed and coherent legal reasoning.

The judges proceeded from the premise that Article 33-1 of the Criminal Procedure Code establishes subject-matter jurisdiction of the HACC, which takes priority over territorial jurisdiction. This means: if a criminal proceeding, by its characteristics, falls within the HACC’s jurisdiction, no other court—neither at the trial level nor at the appellate level—may hear it. Jurisdiction is determined by the properties of the proceeding itself, not by which court actually issued a particular decision.

At the time of appellate review, investigative authority in this case had been assigned to the NABU, and the case materials had been transferred to that agency. Thus, the condition set out in Section 20-2 of the Transitional Provisions of Ukraine’s Criminal Procedure Code—that pre-trial investigation is conducted by NABU—was satisfied. Consequently, subject-matter jurisdiction of the HACC applied, meaning that appellate review fell within the competence of the HACC Appeals Chamber.

Regarding the Supreme Court’s October 12, 2020 ruling, which denied the prosecutor’s request to transfer the case from the Pecherskyi District Court to the HACC, the HACC Appeals Chamber judges offered a clear explanation: the Supreme Court was deciding only the question of transfer of the proceeding from one trial court to another—and only within the scope of arguments the prosecutor had raised in the motion. The Supreme Court neither decided nor could have decided the question of appellate jurisdiction for the prosecutor’s later filed appeal.

Beyond this, the HACC Appeals Chamber judges’ position on jurisdiction was neither novel nor isolated—it reflected established practice that had developed both before and after the January 12, 2021 ruling.

The HACC Appeals Chamber had repeatedly reviewed rulings of investigating judges of the Pecherskyi District Court in NABU cases, and the Supreme Court did not challenge this:

• In the VAB Bank case, the HACC Appeals Chamber in July 2020 cancelled a Pecherskyi District Court ruling and closed the proceeding on the complaint. The Cassation Criminal Court within the Supreme Court three times—in September, October, and November 2020—refused to open cassation proceedings on appeals challenging this HACC ruling, finding arguments about unlawful action by the anti-corruption court to be unsubstantiated.
•  In the Dubnevych thermal power plant case, in March 2021, the HACC Appeals Chamber cancelled a Pecherskyi District Court ruling, and the Supreme Court twice—in April and May 2021—refused cassation review, stating that the HACC ruling was not subject to appeal. 

Moreover, judges of the Kyiv Court of Appeal themselves directed appeals from district court decisions to the HACC Appeals Chamber:

• In the case of the former head of the Chernihiv RSA, in December 2020, the Kyiv Court of Appeal independently transferred an appeal to the HACC Appeals Chamber, determining that the anti-corruption court was the proper appellate court in proceedings falling within the HACC’s jurisdiction—regardless of which trial court issued the challenged decision.
• In the Dubnevych thermal power plant case mentioned above, the Kyiv Court of Appeal in March 2021 transferred the case for review by the HACC Appeals Chamber.

Furthermore, in September 2023, the Supreme Court confirmed the lawfulness of the HACC Appeals Chamber’s actions in another instructive episode: the head of the Pecherskyi District Court for more than two years ignored fourteen requests from the HACC Appeals Chamber for case materials relating to an appeal filed in the Zlochevskyi case, claiming that the anti-corruption court supposedly was not the proper appellate court. The HACC Appeals Chamber submitted a separate ruling to the HCJ concerning the head of court’s violation of Criminal Procedure Code requirements. In September 2023, the Supreme Court left the Pecherskyi District Court head’s cassation appeal without granting it, confirming that determining the question of jurisdiction does not fall within the authority of a trial court head and cannot serve as grounds for refusing to comply with lawful requests from an appellate court.

And in December 2024, the Supreme Court itself granted a motion and transferred an appeal from the Kyiv Court of Appeal to the HACC Appeals Chamber, citing a violation of jurisdictional rules.

Thus, the legal position for which the judges received a warning was not a departure from practice but part of it—consistently supported by both the Kyiv Court of Appeal and the Supreme Court itself, albeit with certain exceptions in specific proceedings.

What is wrong with the HCJ decision

In May 2026, the High Council of Justice characterized as “obvious” a violation of what, by July 2021, had already been established as settled practice.

The HACC Appeals Chamber had been reviewing Pecherskyi District Court rulings in NABU cases since 2020—and the Supreme Court did not recognize this as unlawful. Conversely, in refusing to open cassation proceedings, the Supreme Court effectively confirmed the lawfulness of the HACC’s actions. Under such circumstances, the HCJ’s assertion about the “obviousness” of the violation is at best unconvincing.

Moreover, the HCJ overlooked the fact that the Supreme Court in December 2024 did precisely what the judges did in 2021. 

The judges, both in their decision and during HCJ proceedings, consistently explained that the Supreme Court in October 2020 was addressing only the transfer of proceedings from one trial court to another. In our view, that same Supreme Court decision contained rather peculiar reasoning regarding the determination of jurisdiction based on who served the notice of suspicion—conditions for such a criterion do not exist in Ukraine’s Criminal Procedure Code.

The HCJ further contends that two conflicting appellate court decisions arose concerning the same ruling. This does not correspond to what actually occurred. The Kyiv Court of Appeal reviewed a complaint filed by the defense counsel of the suspected person, counsel who presented no substantive arguments about any illegality or lack of evidentiary basis for the ruling in their favor. The court emphasized this point in its decision. By contrast, the HACC Appeals Chamber reviewed a complaint filed by the prosecutor, who sought to set aside the same ruling and close the proceeding for substantive violations. Different appellants, different legal requests, different legal positions on review. The HACC Appeals Chamber did not review the Kyiv Court of Appeal’s decision and raised no challenge to it.

Furthermore, at HCJ proceedings, the HACC Appeals Chamber judges pointed out that the HCJ had already declined to open disciplinary proceedings in instances where a HACC Appeals Chamber judge had suspended execution of a Pecherskyi District Court ruling, and subsequently a panel of judges cancelled the corresponding district court ruling.

Under these circumstances, to speak of intentional violation means to contend that the judges acted unlawfully while possessing genuine legal grounds for their position. We found no basis for such a conclusion.

Conclusions and open questions

Following this analysis, several questions remain.

Will the legislature close this gap? The Criminal Procedure Code’s provisions governing jurisdiction over NABU cases in courts of general jurisdiction still contain no clear answer to a situation where a local court, contrary to law, issues a decision in a NABU case. 

What does this mean for NABU and SAPO cases in practice? The problem arose because, during a period when the SAPO leadership post was vacant, certain of its powers were exercised by the Prosecutor General. Attorneys, disregarding rules of subject-matter jurisdiction, challenged actions or inaction of the Prosecutor General before the Pecherskyi District Court. The judges of that court ruled on such complaints. If the term of the SAPO leadership ends and stable leadership of the specialized prosecution service is not ensured by then, the problems will return.

Why did the HCJ not notice contradictions in its own practice? During HCJ proceedings, the HACC Appeals Chamber judges pointed out that the HCJ had previously declined to open disciplinary cases in similar circumstances. How can the same actions in one case constitute no disciplinary breach, while in another they do? The HCJ decision offers no answer.

The Prosecutor General’s Monopoly Over MP Cases

A parliamentarian should be protected from pressure for their political position, voting, statements, and general representative activities. Without such protection, an MP could become dependent on executive power. However, Article 482-2 of the Criminal Procedure Code “protects” MPs from a far broader range of situations. It applies not only to politically motivated prosecution for parliamentary activity but extends to corruption offenses that have nothing to do with protecting the parliamentary mandate.

As far back as 2017, GRECO (Group of States Against Corruption) recommended implementing clear and effective measures to ensure that the removal of immunity from parliamentarians would not prevent criminal prosecution of those suspected of committing corruption offenses. In particular, it proposed adopting clarifications on this matter with clear and objective criteria.

Interestingly, in 2020, after immunity was removed, GRECO concluded that this recommendation had been implemented only “satisfactory.” According to the Council of Europe’s monitoring body, this assessment was apparently linked to the fact that the new law can only be effectively implemented in the absence of abuses and political bias. And this is something Ukraine cannot yet hope for—even the Prosecutor General remains a politically interested party. He is appointed by the President of Ukraine with the consent of MPs, without formalized competitive procedures assessing competence and integrity.

From nearly the beginning, the expert community noted that such a construction effectively creates a modified form of immunity from criminal prosecution. Moreover, the Criminal Procedure Code does not provide analogous special procedures for initiating criminal proceedings against judges, who also enjoy certain immunity. 

During the discussion of the relevant draft laws themselves, some MPs emphasized that making investigations dependent on the will of a single person—the Prosecutor General—creates corruption risks and may result in the impossibility of prosecuting an MP criminally.

The practice already demonstrates the problem 

One of the first prominent examples involving an MP was the case of Oleksandr Yurchenko. In September 2020, the NABU publicly announced that it had submitted materials and a draft suspicion notice to Prosecutor General Iryna Venediktova for registering proceedings and notifying the MP of suspicion. However, the Prosecutor General’s Office replied that it saw insufficient grounds for registering proceedings. 

The NABU was effectively forced to publicly call on the Prosecutor General to sign the suspicion notice. Eventually this did happen, but the episode itself demonstrated the key point: a corruption case against an MP can be stalled in this manner.

We observed numerous examples where journalists uncovered suspected corruption by MPs, yet the Prosecutor General refused to open proceedings. And the most recent and telling such case is the matter against Iryna Kormyshkina. In early 2025, she and her husband admitted guilt and, based on a plea agreement, received a sentence for illicit enrichment and money laundering. However, as far back as 2022, the Prosecutor General Andrii Kostin had stalled the initiation of the case, first refusing to register the crime report, before a court eventually ordered him to launch an investigation. 

These cases are not isolated, and from time to time they become a genuine obstacle to NABU and SAPO investigations of high-profile corruption within parliament.

Why comparison with other countries works against the Ukrainian model

In democratic states, parliamentary immunities typically follow a different logic, designed to protect the parliamentary function rather than create a blanket barrier to criminal process. The Venice Commission has drawn attention to this dangerous paradox: in young democracies, immunity can simultaneously protect MPs from state abuse and become an obstacle to fighting corruption.

This is deeply important for Ukraine. We are not an established democracy with a substantial legacy of political traditions and unconditional confidence in the prosecution service, law enforcement agencies, and political institutions—Ukrainian institutions are still earning such trust from society. For this very reason, a model in which corruption proceedings against an MP depend on one politically appointed official cannot be considered optimal.

Moreover, even developed democracies, while granting their parliamentarians immunity similar to what we abandoned in 2019, do not erect barriers to initiating pre-trial investigations. And certainly, do not afford protection to MPs from all categories of criminal offenses, including corruption—the Venice Commission considers this unacceptable.

In many European approaches, immunity often applies only to arrest, detention, or prosecution (formal suspicion)—as in Belgium, France, Italy, and Portugal. 

Several of these countries conducted constitutional reforms as far back as the 1990s, whereby opening an investigation against a parliamentarian requires no separate authorization. In France, for example, following constitutional reform, Chamber consent to opening criminal proceedings is not mandatory—it is required only for detention, arrest, and other judicial control measures. In Italy, Constitutional Law No. 3 of October 29, 1993 removed the requirement for prior Chamber consent to open proceedings against MPs.

The Ukrainian model moved in the opposite direction, placing even the submission of information to the Unified Register of Pre-Trial Investigations (URPI) under special control.

Why the SAPO head should receive such powers

Ukraine deliberately created a separate anti-corruption system in which the NABU investigates high-profile corruption, the SAPO provides prosecutorial supervision, and the HACC ensures judicial control and adjudication of such cases. This model was meant to reduce the dependence of investigations on any political influences. Yet the Criminal Procedure Code has long recognized the special role of the SAPO head regarding MPs, giving him the authority to independently sign notices of suspicion to them. 

However, that same Article 482-2 does not grant the SAPO head an analogous role regarding submission of information to the URPI or approval of key investigative applications during pre-trial investigation. This creates a contradiction: the head of the Specialized Anti-Corruption Prosecutor’s Office can notify an MP of suspicion, but lacks direct authority to independently launch proceedings or approve a search or other investigative measure. And this is all the more significant because ultimate control over searches, arrests, interception of communications, and preventive measures must still be exercised by an investigating judge.

Furthermore, when addressing the legislative removal of parliamentary immunity, an alternative draft law had proposed authorizing the SAPO head to perform the same functions regarding prosecution of MPs as the Prosecutor General. In its explanatory memorandum, the authors specifically noted that concentrating powers solely in the Prosecutor General creates risks that material evidence and traces of crime could be destroyed, and that it may become impossible to conduct investigative measures swiftly.

Beyond this, granting such powers to the SAPO head benefits not only the efficiency of anti-corruption investigations, but the MPs themselves. In cases involving parliamentarians, there is always a risk that any decision by the Prosecutor General will be perceived as political pressure, especially when it concerns opposition cases. Involving the SAPO head in NABU cases reduces this risk by shifting decisions to a more specialized and institutionally removed plane—recall that our Prosecutor General is appointed by specific officials. 

For honest MPs, such powers in the SAPO head mean greater protection from selective political prosecution; for society, it means less reason to believe that anti-corruption cases are blocked or initiated based on political expediency.

***

The cancellation of parliamentary immunity in Ukraine was an important political decision, but it did not resolve the problem of MP privileges in criminal procedure. Ukraine should not have replaced old parliamentary immunity with new prosecutorial immunity.

As practice has shown, such an approach is especially dangerous in corruption cases against MPs, as it creates a risk that investigations may be delayed or blocked not through weakness of evidence, but through the lack of political will of a single official—the Prosecutor General.

Granting such powers to the SAPO head in proceedings within NABU’s investigative jurisdiction will strengthen guarantees for parliamentarians and make it impossible to use such cases as a hidden form of immunity. And this benefits both MPs and anti-corruption law enforcement agencies.

What was Kniaziev’s role in the case, and why does this agreement matter so much? 

For a time, Kniaziev was charged with creating an organized group, but in the indictment and the verdict his actions were classified as those of a principal — an official who had accepted an unlawful benefit for himself and others. According to investigators, the scheme was built by the intermediaries, Horetskyi and Horburov, while Kniaziev secured the outcome in court. 

A key condition of the agreement was incriminating testimony against the other participants in the scheme. On its basis, notices of suspicion were served on four Grand Chamber judges: Zhanna Yelenina, Iryna Hryhorieva, Ihor Zhelieznyi, and retired judge Oleksandr Prokopenko. Kniaziev confirmed that he had coordinated the payment of the “reward” between the intermediaries and the judges. In particular, after the ruling was adopted, he personally handed Prokopenko a black folder containing $50,000 — even though Prokopenko had prepared a dissenting opinion, ostensibly disagreeing with the decision. Kniaziev explained the money simply: “people are grateful to all the judges” who had delivered the result. 

As the verdict notes, a corruption crime committed by the chairman of the country’s highest judicial body undermined trust in the justice system and damaged Ukraine’s international standing. An important argument in favor of the agreement was the public interest in swift justice. Over the course of more than 50 hearings, the HACC had not even examined all of the prosecution’s evidence; the agreement made it possible to avoid a years-long trial. Kniaziev’s testimony opened an investigation into the other Grand Chamber judges — without his cooperation, proving their involvement would have been extremely difficult.

For international partners, the EU in particular, the verdict is a signal that the inevitability of punishment has worked even at the highest level of the judicial system. Five years of actual imprisonment with confiscation of property will, in the court’s view, also serve as a warning to others.

Kniaziev’s return to the bench: is it even possible, and if so, when?

Kniaziev had lost his judgeship even before the verdict, and not because of the criminal case. In 2023, he was found guilty of a corruption-related administrative offense: during a search, investigators found a lease for a four-room Kyiv apartment at a symbolic UAH 1,000. The UAH 906,000 by which the rent fell short of the market value was deemed by the court an unlawful gift and confiscated, and Kniaziev was additionally fined UAH 2,550. The NACP then applied to the High Council of Justice, which opened disciplinary proceedings and removed Kniaziev from office. The Grand Chamber of the Supreme Court subsequently upheld that decision.

Now comes the verdict in the criminal case. The three-year ban on holding positions in judicial and law enforcement bodies takes effect only after the principal sentence has been served. Taking into account time spent in custody, the actual term of imprisonment will be about 4.3 years. This means a return to the judicial system is impossible for at least seven years.

But even after that, the path back into the justice system is effectively closed. A criminal record for a particularly grave crime is expunged only eight years after the sentence has been served. And a conviction for a corruption crime, together with dismissal from judicial office, will remain weighty considerations in any judicial selection competition — the HQCJ and the Public Council of Integrity are unlikely to overlook this episode in his biography.

***

This case has become one of the most high-profile in the HACC’s practice — the first time in Ukraine that a sitting chairman of the Supreme Court was caught taking a bribe. And the verdict, with its actual imprisonment and confiscation, has become the subject of active debate. Although it may still be appealed within 30 days, the grounds for doing so are limited.

Like any convicted person, Kniaziev has the right to petition the President of Ukraine for a pardon, but here too there are very few grounds. And if he fails to comply with the agreement, the prosecutor may move to have the verdict overturned.

Detection and tracing: more requests, fewer assets found

In 2025, ARMA received 9,468 requests to detect and trace assets — a 20% increase over 2024 (7,865). 

The number of assets actually found, however, fell across several categories. ARMA located 29,049 land plots, down from 107,066 in 2024 — a figure we flagged at the time as an anomaly. Other categories rose: detected funds reached UAH 36.5 billion against UAH 8.3 billion, corporate rights UAH 58.5 billion against UAH 35.9 billion, and virtual assets stood out most of all — 1.29 million USDT against 2,400 USDT, a roughly 530-fold increase.

One section is genuinely new: ARMA publicly acknowledges the structural gap between assets traced and assets seized. Only 2% of the property ARMA traces is later seized. The report explains, among other things, that the information ARMA compiles on traced assets cannot be used as evidence in criminal proceedings.

The Agency separately notes that some tracing requests come in proceedings where confiscation — or even the option of special confiscation — is not envisaged at all. The information on traced assets is then used by the prosecution under Article 93 of the Criminal Procedure Code of Ukraine, which governs the rules for gathering evidence and nothing more. In other words, in certain cases ARMA functions as a property-records service for law enforcement.

ARMA also sent 639 international requests in 2025, against 383 in 2024 (up 66%). The numbers are striking, but they raise questions about the quality of each request and the effectiveness of the institution’s foreign track as a whole. The report does detail what was found abroad: 366 properties, 88 vehicles, $5.9 million, and corporate rights worth the equivalent of UAH 924.86 million. How much of this was seized, and which of these decisions foreign competent authorities recognized, remains unknown. 

Such decisions by foreign actors do not depend on ARMA alone, of course. But to analyze the state of asset recovery — a function the Agency does hold — the missing piece is information on whether those assets were actually seized abroad.

Asset management: more new agreements, but the revenue still comes from the old ones

Last year we noted that ARMA had concluded only 7 management agreements against 33 announced competitions. In 2025, there are already 40 management agreements under 38 rulings. On paper this is a breakthrough — yet 27 agreements carried over from previous years remain the main source of revenue for the state budget.

A single agreement — with Ukrnafta over the assets of Ukrnaftoburinnia, signed back in June 2023 — brought UAH 1.074 billion to the budget out of UAH 1.54 billion from management agreements overall. That is roughly 70% of the year’s revenue from one asset. All 38 new agreements signed in 2025, by contrast, account for just 2.5% of revenue (UAH 38.7 million).

The figures on asset sales in 2025 are also contradictory. The Agency organized 184 auctions, of which only 41 succeeded (about 22%). Nearly four out of five auctions produced no result. This calls for a separate explanation — on how the lots were assembled, and on starting prices and the appeal of the assets. 

The key thing left out of the report: as of its publication, the new mechanisms for selecting managers through Prozorro still had not been launched, even though they were supposed to be operating by January 30, 2026. This means that, overall, the transfer of assets to managers under the new rules is significantly delayed.

Oversight of managers: more activity, but the quality questions remain

In 2024, ARMA carried out only 10 on-site inspections of managers — one of the key figures we criticized. In 2025, there are already 38 on-site inspections and 348 desk reviews, for 386 oversight actions in total. These produced 27 orders to managers and 5 established instances of mismanagement.

In terms of trend, this is a marked improvement. In absolute terms, though, 38 on-site inspections against the 34,062 assets ARMA has placed under management, worth UAH 10.7 billion, is still a modest figure. 

The report also fails to show how the inspection results were interpreted: how many orders led to an actual change in a manager’s conduct, and how many agreements were terminated for ineffectiveness. And the scandalous case of KAMparytet, which subleased shopping centers at prices three times higher than its declared income, is not mentioned in the report at all, even though the case was discussed separately at the parliamentary Anti-Corruption Committee, and in 2026 the Agency confirmed the violations and announced its intention to terminate the agreements with the company. 

Inventory: ARMA finally has a definitive count of the assets it manages 

The transitional provisions of the new ARMA law required the body to identify, within six months, all assets placed under its management before the law took effect. The Agency reports that, following a full inventory, its records now cover 60,274 assets, of which 20,753 have high management potential. This figure also includes assets being prepared for competitive procedures or already identified as attractive for management and sale.

Even so, the Agency still does not use the term “asset pool,” which would make it possible to see how many units of property actually form part of an operating business that can be grouped under that concept. In practice, this makes it quite hard to tell from the report how many economically attractive businesses lie behind the figure of 20,753 assets. 

In 2025, 1,703 assets were handed to managers under agreements, while across all years ARMA has transferred 34,062 assets in total. These 1,703 assets are valued at UAH 5,354.31 million, against UAH 10,737.53 million for all assets combined. So nearly 5% of the assets placed under management in 2025 account for roughly 50% of the total value. One hypothesis here is that in earlier years the assets transferred for management were largely low-value.

In all, the body of assets ARMA is empowered to act on amounts to 94,336 units. Of these, 34,062 have already been transferred to managers under agreements (1,703 in 2025), and 60,274 have not (20,753 of them with high management potential). 

Handling “complicated” assets proved a separate problem: of 100 appeals ARMA made to prosecutors about its inability to manage such assets effectively, only 32 received a reply, and just 5 of those were resolved favorably. In other words, 95% of the cases where ARMA has already deemed an asset problematic to manage remain unresolved once the prosecution is brought in. And this problem should be resolved by amending the Criminal Procedure Code of Ukraine, as we have stressed before.

***

Over the past year, the volume of activity inside ARMA has grown substantially. The Agency is drafting secondary legislation, running asset inventories, tracing assets, and shaping recovery policy. Not every task has been completed, but the progress is visible. 

Even so, in watching ARMA’s performance, we would like to see real results in the effectiveness of asset recovery. That can be traced, in particular, by comparing the outcomes of tracing, seizure, effective management, and confiscation. Beyond that, the data available in the report does not make clear how the new system for selecting managers actually works, since not a single auction of that kind has taken place since the law was adopted. And in any case, the management agreements covered in the report were all concluded under the old procedures. 

That is why we see the key task for ARMA today as changing the very logic of how it traces and manages property. In our opinion, the next report should demonstrate not just the volume of work done, but concrete achievements across the system as a whole. All the more so since invoking the old rules will no longer make any sense. 

Background: why Rodovid Bank fell into crisis

Rodovid Bank grew rapidly in 2005–2006 — and fell just as rapidly during the 2008 crisis. As of early 2009, it was the 19th largest Ukrainian bank by assets. But behind that outward scale lay a far less rosy picture: roughly 80% of corporate loans were unrecoverable, and the share of non-performing loans to individuals reached 47%. In other words, the bank had effectively ceased to exist as a functioning financial institution — its fall was only a matter of time.

Investigators never fully established who siphoned off assets in the pre-crisis period, or when. The bank’s owners hid behind a chain of shell companies. 

One well-known episode illustrates the logic of what was happening, even though it does not directly relate to this criminal case. In 2008, Firtash’s UkrGazEnergo placed roughly half a billion hryvnias on deposit at 9% per annum. A year later, three days before temporary administration was introduced, the rate was raised to 48% — three times the market rate. Later, once the bank was already state-owned, the Firtash structure received UAH 284 million in accrued interest. A court subsequently declared the agreement void, but no one was ever held criminally liable for this episode.

Nationalization and another round of plunder

Rodovid’s bankruptcy was among the most high-profile of all such cases at the time. The government of Yulia Tymoshenko decided to rescue it, recapitalizing the bank with an injection of UAH 8.4 billion — almost $1 billion at the time. As a result of this “rescue” operation, 99.97% of the bank’s shares passed into state ownership. But the plunder continued even after the bank became state-owned, as we describe in more detail below.

Lines outside Rodovid Bank during its collapse

Formally, the bank was taken over by temporary administrator Serhii Shcherbyna. But in practice, according to investigators, everything was run by Oleksandr Shepelev — a former MP of the fifth and sixth convocations and, in the past, a member of the Yulia Tymoshenko Bloc faction, which he left in 2007 to join the Party of Regions faction. He is the one charged with organizing the embezzlement scheme. Yehorenko was an accessory in it — the man with signing authority who knew the bank’s internal paperwork.

Oleksandr Shepelev

At the time of these events, Shepelev was an MP and held positions on the Verkhovna Rada’s Committee on Finance and Banking, as well as on the privatization commission. According to investigators, he declared himself the bank’s unofficial overseer on behalf of the Cabinet of Ministers, took a separate office at the premises on Sahaidachnoho Street, and began running the institution with no signing authority but through verbal instructions. He installed his own people in key positions.

The fictitious documents were signed by Dmytro Yehorenko, who before temporary administration was introduced had served as acting chairman of the board and, from 2009, as full chairman without the “acting” prefix. He did not organize the scheme or draw up the documents — the papers were simply brought to him ready-made. But he signed them, aware that there were no grounds for transferring the funds. The court qualified his role as aiding and abetting and noted separately that Yehorenko gained no personal financial benefit.

According to the verdict, the scheme was simple. Shepelev’s wife, Halyna, acquired ownership of an administrative building in central Kyiv through a relative linked to the same circle, who had purchased it from EBRF CJSC, a company controlled by that same group. Next came a fictitious lease: the bank supposedly rented this building. Contracts, acceptance certificates, and supplementary agreements were all backdated, marked February 2009 — that is, before temporary administration was introduced — and some documents were dated as far back as 2006. The aim was to disguise the crime as a business relationship that had supposedly existed long before the bank became state-owned.

The building on Sahaidachnoho Street near the funicular in Kyiv that once housed Rodovid Bank’s head office 

On the basis of these documents, between September 2009 and March 2010 Shcherbyna made nine payments totaling almost UAH 18.5 million to Halyna Shepeleva’s account. More than UAH 17 million of this was withdrawn in cash through the bank’s teller and used by the couple as they saw fit.

The court established that the bank did not actually use the building. No relocation, no furniture, no utility payments — nothing to confirm a genuine tenancy. In April 2010, an audit commission inspected the premises and found only renovation work underway.

In 2014, Ekonomichna Pravda described Rodovid’s collapse as “the dirtiest banking scam of the independence era” and asked: where did the money go, and would anyone be held to account? There are now some answers.

The losses in the Yehorenko case, confirmed by forensic economic examination, amount to almost UAH 18.5 million. No civil claim for compensation was filed, since a separate ruling in a civil case had already ordered UAH 18 million recovered from Halyna Shepeleva in the bank’s favor.

What the court decided in the Yehorenko case

The HACC received the indictment on January 31, 2024, and within a month and a half moved to consideration on the merits, ruling to hold special judicial proceedings in absentia against Yehorenko, who had been wanted since 2018 and, as of February 7, 2019, under arrest in absentia imposed by the Pechersk District Court of Kyiv. 

The wanted notice for Dmytro Yehorenko on the Interior Ministry website

Once the case reached trial, however, Yehorenko did express a wish to take part in the hearings remotely. 

Over two years, the court examined thousands of pages of documents, questioned witnesses, and ruled on dozens of defense motions. He did not plead guilty. His reasoning ran that, as the owner of 34% of the bank’s authorized capital who had served first as acting chairman of the board and then as chairman, he knew the institution well from the inside. Yehorenko insisted that the building was genuinely leased and that some of the bank’s units had moved in there — security, programmers, and the regional directorate. He denied signing any fictitious documents, claimed the bank had no “overseer” at all, and said Shepelev had no workplace there and only occasionally dropped by to see Shcherbyna. In the end, the court rejected all these arguments.

On April 9, 2026, a panel of HACC judges found Yehorenko guilty under two articles: aiding and abetting the misappropriation of property through abuse of official position (Article 27(5) and Article 191(5) of the Criminal Code of Ukraine) and forgery in office by prior conspiracy (Article 28(2) and Article 366(1) of the Criminal Code of Ukraine). The court sentenced him to 10 years’ imprisonment with confiscation of property and immediately released him from serving it. The reason: the statute of limitations on the more serious offense expired on March 4, 2025, and on the forgery charge back in 2013. 

Notably, Yehorenko himself had objected to closing the proceedings on limitation grounds and had insisted on a trial on the merits. 

Yehorenko’s defense filed an appeal against the trial court’s verdict. On the basis of these appeals, on May 22, 2026, the HACC Appeals Chamber opened appellate proceedings. 

Where the other defendants are now

The Rodovid case is not a single verdict over UAH 18 million siphoned off through a fake lease, but a sprawling network of proceedings moving at different speeds. The total losses inflicted on the bank after nationalization run into the hundreds of millions of hryvnias, and the central episode still awaits resolution.

The bank’s temporary administrator, Serhii Shcherbyna, entered a plea agreement back in 2017 — as the perpetrator of the same crime in which Yehorenko was found to be an accessory. By available accounts, as of 2025 he is in prison.

Halyna Shepeleva

Halyna Shepeleva was convicted by a verdict of the Shevchenkivskyi District Court of Kyiv on December 18, 2024, and sentenced to 7 years’ imprisonment, a 3-year ban on holding certain positions, and confiscation of property. She did not plead guilty, claiming she had signed documents without going into the details because she was busy with the family rather than the bank’s affairs. The verdict has not yet taken legal effect — the defense has filed an appeal. 

The main defendant in the case remains Oleksandr Shepelev, a former member of both the Yulia Tymoshenko Bloc and the Party of Regions. Investigators regard him as the architect of the entire scheme, which contains far more episodes than the ones Yehorenko was tried for. The NABU and the SAPO accuse Shepelev of organizing a scheme to misappropriate over UAH 300 million of Rodovid’s funds. According to investigators, this money went to pay for fictitious services from a firm close to Shepelev, and another UAH 40 million, as Shcherbyna stated, went to renovate a building leased from Shepelev himself. Shcherbyna, the bank’s temporary administrator, supposedly had to certify the allocation of this money with his signature under pressure, but on the record he later called those decisions criminal.

The indictment over the UAH 300 million that Shepelev is charged with embezzling reached the HACC in January 2022. Consideration on the merits began that October and continues to this day. 

But Shepelev’s record extends far beyond Rodovid. In 2013 he was detained in Budapest: Ukraine suspected him of organizing the murders of an Interior Ministry colonel and a banker, the attempted murder of another banker, and the embezzlement of state funds earmarked for the rescue of the recently nationalized bank. In March 2014 he was extradited to Ukraine and taken into custody. Soon afterward, Shepelev faked an illness and was transferred to an emergency hospital, from which he escaped that July by bribing a guard. He went into hiding in Russia, where he was granted refuge in exchange for testimony against a number of Ukrainian politicians and cooperation with the FSB — which became the basis for opening a high treason case against him. However, after a falling-out with Russian law enforcement over an attempted bribe, he returned to Ukraine, and in February 2018 he was detained near Kyiv carrying the ID of a lieutenant colonel of the “MGB” of the so-called “DPR.”

In 2020, the Desnianskyi District Court of Kyiv sentenced Shepelev to 7 years for escaping custody and bribing a guard. The court established that, while in custody at a Kyiv hospital, Shepelev passed money to the head guard three times — twice UAH 500 and once $100 — so that the guard would ignore his having a phone. On July 6, 2014, he left the hospital through the utility rooms and illegally crossed out of Ukraine. Shepelev did not plead guilty, claiming the entire prosecution was Yanukovych’s personal revenge — supposedly because Shepelev had gone against him. The Court of Appeal upheld the verdict.

In 2022, the Obolonskyi District Court of Kyiv, on top of the earlier verdict, sentenced Shepelev to 15 years for organizing the murder of Serhii Kyrychenko, chairman of the supervisory board of the Donetsk-based AvtoKrAZBank. According to the prosecution, Shepelev eliminated him as a competitor: he hired a hitman for $40,000, who stabbed the victim at least 14 times in the entrance hall of a building in Donetsk. This happened back in January 2003. The court partially granted the civil claim brought by the victim’s daughter for UAH 2.5 million in moral damages. The appeal largely upheld the verdict but credited his prior time in detention. The cassation court, in turn, also counted the sentence for escaping custody toward this term — and found that Shepelev had fully served his sentence for this murder. 

Beyond these two convictions, the Solomianskyi District Court of Kyiv is currently hearing another case involving Shepelev — over the contract killing of Roman Yerokhin, a colonel in the Interior Ministry’s organized crime directorate (UBOZ), in 2006. 

As of May 2026, the case of the “Rodovid millions” before the HACC is at the stage of examining evidence — the defense is currently presenting its materials. At a hearing on May 4, defense counsel tried to add to the case file the testimony of the bank’s temporary administrator, Serhii Shcherbyna, and other witnesses — testimony they had given in another criminal proceeding. The panel of judges denied the motion: if the defense wants these witnesses’ testimony, it can question them directly in this case. The defense lawyers agreed with the ruling. So, in the near future, the Shepelev case will likely see the questioning of witnesses and defendants from the Rodovid Bank case. 

Defense counsel also maintains that much of the evidence he has submitted points, in his view, to the political persecution of his client. The defense argues that the charges against Shepelev were fabricated because of the change of power after the Revolution of Dignity and his client’s political ties to the Yanukovych regime, against which he had supposedly turned. In effect, the defense is trying to portray Shepelev as a victim of political reprisals — despite the fact that he has several convictions for crimes unrelated to this case. 

Shepelev himself is currently in a pretrial detention facility. He takes part in hearings by videoconference. In the proceedings he communicates exclusively in Russian. 

Although the case has dragged on for years, Shepelev himself has done everything to give the court a chance to get through it in time — inadvertently extending the limitation periods through his own crimes. 

The Criminal Code of Ukraine provides that the statute of limitations is suspended if a person evades the investigation or the court. Shepelev fled Ukrainian law enforcement twice: first to Hungary and then, after he was handed over to Ukraine, once more — this time to Russia, and with yet another crime to his name. There he cooperated with hostile intelligence services, as well as with Russian gauleiters in the so-called “DPR.”

***

The running of the limitation period can also be interrupted if the defendant commits a new crime before the previous period expires. In that case, the period starts over from the commission of the latest crime. 

Shepelev “made use” of this too: after the Rodovid case began, he committed new serious crimes — escaping custody and bribing a guard. It is from the date of the escape, July 6, 2014, that the 15-year limitation period begins to run, expiring in July 2029. 

If a verdict in the case over the embezzlement of Rodovid’s funds is not handed down before that date, the case may be closed on limitation grounds. So Yehorenko’s fate — convicted, but walking free — is not yet what threatens Shepelev. But that depends on the court finishing the trial in time. 

The Rodovid case vividly illustrates the systemic problem of complex cases being investigated too slowly. Yehorenko received a verdict but served no punishment. Only a small fraction of the losses has been recovered for the state. Another defendant is still waiting for the court to rule on his case. Whether society’s demand for justice in this case will be satisfied remains an open question.

Background

It should be noted at the outset that the brief plan described here is not the beginning of the Dynasty story but an intermediate stage in it. 

According to data made public in the court register, the acquisition of the land plot for the cottage development in 2019 became the subject of a separate NABU investigation — due to indications of probable corrupt actions by local officials. The Kozyn territorial community sold the land — with cadastral number 3223155400:04:006:0028 and an area of 4.2491 hectares — for UAH 9,008,092, based on an expert appraisal of UAH 8,758,275. Yet the investigation estimates the land’s minimum market value at the time at UAH 43,246,120 (i.e., five times higher), and its maximum at UAH 180,193,690 (twenty times higher). 

On the level of hypotheses, then, the Dynasty scheme can be traced through three sequential stages:

1. the corrupt acquisition of the land plot in 2018–2019 at an undervalued appraisal 
2. the laundering of criminally obtained funds through real estate construction in 2019–2025
3. an attempt in 2025 to “cleanse” the asset of the risk of seizure and confiscation through a series of transactions with unrelated legal entities. 

This resembles a complete cycle of obtaining proceeds from crime and removing them beyond the state’s reach. It is precisely this that the modernization of confiscation mechanisms — required by Directive (EU) 2024/1260 — is meant to prevent. As noted in another document important for EU integration — the Rule of Law Roadmap — Ukraine is required to integrate its provisions into national legislation by Q2 2027. 

What happened with the assets

Imagine that you own a house worth $2 million. Formally, however, it isn’t yours — it’s registered to a chain of individuals and companies that, on the surface, appear independent of one another. Something similar was happening with Dynasty, as we can see from materials in the court register. 

• 2012. The Sunny recreation facility in Kozyn is purchased through Bloom Development LLC for UAH 2.47 million. The land under the facility is leased from the village council.
• 2018. The Sunny Shore Housing Cooperative is established, ostensibly for the construction of housing. There are three founders: two nominees, with the third becoming chair. Oleksii Chernyshov — recently served with another notice of suspicion by the NABU, which regards him as the organizer of this scheme — does not appear among them. The cooperative obtains the land on sublease.
• 2019. Oleksii Chernyshov briefly appears in documents as a co-founder of Bloom Development LLC, but quickly “exits” — transferring his share to his wife. That same year, the land is purchased outright from the village council by Bloom Development for UAH 9 million.
• 2019. Chernyshov personally extends a loan of UAH 3.6 million to the cooperative (as recorded in an HACC ruling). Formally, then, he is not the owner, but in reality he is financing the project.
• 2020-2025. Active construction of Dynasty. Chernyshov’s wife is effectively running the process. Through nominees and six powers of attorney issued, Chernyshov retains control.
• August 29, 2023. His wife also “exits” the list of Bloom Development’s participants. The sole owner remaining is a nominee.

Accordingly, by the time the NABU starts taking an interest in Oleksii Chernyshov personally, the houses and the land belonged to a company whose registered owner was an individual with no connection to him. Between the actual beneficiary and the asset were a number of legal “layers.”

What the “asset cleansing” plan proposes

Owning the unfinished mansions through a chain of legal entities turned out to be insufficient. After the publicity generated by the Bihus.info investigation and the start of the NABU probe, the real owners faced the task of protecting the asset from seizure and subsequent confiscation. The action plan — proposed by specialists who remain unknown — even bears a title that leaves no doubt as to its purpose.

And here is how the plan was to be carried out.

Step 1: “Sell the land to insiders through a loan”

The authors of the brief proposed creating a new company. It is provisionally designated as the “Investor” and is to appear entirely unconnected to Chernyshov (in contrast to the already exposed Bloom Development LLC). This “Investor” buys the land from Bloom Development LLC, but not with its own money — with a loan extended to it by another “friendly” company or bank. And the land is immediately encumbered by a mortgage in favor of the lender.

This structure serves several purposes: 

• the purchase for money looks like an ordinary commercial transaction rather than an attempt to conceal property
• the mortgage creates additional obstacles to recovering the asset: if the prosecutor seeks to challenge the sale and reclaim the land, the state will face a “competitor” in the person of the lender. 

Step 2: Understate the value of the houses

The plan’s authors do not even hide the fact that there are problems with the real value of the unfinished estate. The document states outright: “bring the real value of the unfinished construction facility closer to the documented financing.” For the actual value of a single house, according to the NABU and the SAPO, is nearly $2 million, while what officially passed through the Sunny Shore Housing Cooperative was far less — approximately 10% of the real costs. 

If an independent appraiser writes the real value in the report, the obvious question arises: where did the money come from? That is why a “right” appraiser is needed — one who will record the official value of the house at roughly the level of the documented financing.

Then, if in a year or two someone tries to challenge the sale, they will see contracts in which the price matches the appraisal. Legally, everything is clean.

Step 3: Sell the houses as a pile of materials

If a house is registered in the real estate register, it can be placed under seizure. But if it physically exists yet has not been registered, it is legally almost “invisible” for purposes of reflection in the encumbrance register. The plan envisages this: at the time of the transactions, the Kozyn houses are not formally registered as completed real estate — they exist as construction in progress. This means they can be sold to the “Investor” simply as a set of construction materials — at the reduced value from Step 2 — and the transaction will leave no trace in the state registers.

So, by the time the NABU finally obtains a seizure ruling against the previous owner, there will be nothing left to seize. The houses are not in the register, and the materials have already been recorded in the “Investor’s” books. Additional steps would then be required to locate and identify the new owner and seize their property — which would take additional time.

Step 4: Register the property to the “Investor” as its own

The “Investor” now registers the same houses in its own name in the State Register of Real Property Rights — as a new real estate object. As a legitimate owner who purchased the land under a contract, it has now “built” a house on the land using the purchased materials. Legally, then, this is a different asset from the one that could have been seized earlier, because it was registered after these transactions were carried out. The owner is a company with no connection to Chernyshov. Its origin is documented through a chain of contracts.

Step 5: Sell again — this time openly

The final step: the “Investor” sells the entire complex (the land and the registered real estate) through an electronic trading platform (such as SETAM) to yet another company, provisionally named the “Developer.” This company, too, has no connection to Chernyshov.

Why an auction? Because it creates a presumption of market price and of good-faith acquisition. Bought at an open auction through a transparent procedure — therefore, a bona fide acquirer. And under the requirements of Article 96-2 of the Criminal Code of Ukraine, special confiscation does not apply to a bona fide acquirer. Period.

From there, the “Developer” calmly finishes the mansions, commissions them, and sells them to end buyers. The end buyers will hold completely clean title. Even if, several years later, a verdict is reached against the suspects in the case, there will be nothing left to confiscate.

In lieu of conclusions: which vulnerabilities of the confiscation regime this plan exploits

As we can see, the “asset cleansing” plan is built on a detailed knowledge of current legislation, and each of its steps targets a specific loophole. A mortgage in favor of a “friendly” lender, an undervalued appraisal, the sale of the mansions as construction materials, the resale through an electronic auction — together, all of this aims to create a legal status in which confiscation becomes impossible even when a verdict exists. Article 96-2 of the Criminal Code of Ukraine permits the confiscation of property from a third party only when it is proven that the party “knew or could have known” about its criminal origin. Yet the plan is specifically constructed so that this awareness cannot be proven.

It is precisely against such a model that Directive (EU) 2024/1260, mentioned at the outset, is directed. It permits courts to confiscate property based on its disproportion to lawful income and the absence of a plausible lawful source. Consequently, there is no longer a need to prove a third party’s subjective awareness in every case. Protection for the bona fide acquirer is preserved through procedural safeguards — the right to counsel, access to case materials, the right to be heard in court, and the right to appeal the confiscation decision, as provided in Article 24 of the Directive.

In the Rule of Law Roadmap, Ukraine has committed to implementing the Directive by Q2 2027. The case of the Dynasty mansions is the best illustration of why this commitment must be fulfilled in substance, not just in form.

As for the fate of these mansions, if it can be proven that they were built with funds of criminal origin, that will be decided by the courts. But without legislative improvements, there remain many ways to shield assets from the “line of fire.”

What happened and what the Cabinet should do

In early April 2026, the NACP completed inter-agency clearance of the draft Anti-Corruption Strategy and submitted it for the Cabinet’s consideration. The Agency had developed the Strategy with the help of expert working groups that conducted sectoral studies, which then formed the basis of the document. The NACP has published all the relevant materials on its website — the draft of the final document and a table showing which public comments had been incorporated and which had not.

Although the Law on Corruption Prevention does not require the Cabinet to process the anti-corruption strategy and register it in parliament as a government draft law, this has been the established practice in Ukraine, and it was the expectation of everyone involved — government officials, international partners, and experts alike. And indeed, anti-corruption strategic documents have always been adopted through government legislative initiative in the past.

Moreover, the law provides that the next step after the anti-corruption strategy is adopted is the approval of a State Anti-Corruption Program to implement it. These next steps will have to be carried out by the government — so it would be logical for it to be involved in shaping the first document as well.

However, because the strategy sat with the Cabinet for over a month without being adopted, and there emerged a real threat that deadlines would be missed (along with potential financial losses for Ukraine — more on that below), Anastasiia Radina, Chair of the Verkhovna Rada Committee on Anti-Corruption Policy, decided on May 13, 2026 to break with tradition and register the draft law on the Principles of State Anti-Corruption Policy for 2026–2030 herself.

This is not “Radina’s own draft,” though. Its content has been agreed upon — it simply lacks the government’s “sign-off.”

The version of the draft law that has been registered matches the version the NACP sent to the Cabinet in April, after coordination with the relevant stakeholders.

The urgency on the part of the anti-corruption committee’s chair is entirely justified. Adoption of the anti-corruption strategy is one of Ukraine’s international commitments. It is required, in particular, by the Ukraine Facility plan (an EU initiative in which each reform Ukraine carries out or each decision it adopts unlocks specific financial assistance), the Rule of Law Roadmap, and the so-called “Kachka-Kos 10-point plan,” which gathers together the most important reforms in the areas of rule of law and anti-corruption.

Under the Ukraine Facility plan, the deadline for adopting the strategy and the anti-corruption program to implement it is the end of June 2026 — and given parliamentary procedure, there is already very little time left.

But the registration of the draft law by Anastasiia Radina does not mean the government can now forget about this document — quite the opposite. If the Cabinet of Ministers has views of its own on the document, it should still review the NACP’s version of the anti-corruption strategy as quickly as possible and convey its position to parliament. The Committee on Anti-Corruption Policy will then be able to take the government’s comments on board and, where it agrees with them, introduce “government” changes to the draft law that has already been registered.

The Verkhovna Rada’s Rules of Procedure do allow subjects of legislative initiative — including the government — to submit amendments and proposals to draft laws during preparation for the second reading (Articles 89 and 116 of the Law on the Rules of Procedure of the Verkhovna Rada of Ukraine).

If the government ignores this opportunity, it will deprive itself of any say in the content of the strategy — and end up in a situation where it has to develop the SAP on the basis of a document finalized without it.

What the new strategy is about

The current strategy will be Ukraine’s third.

The first covered 2014–2017 and was primarily aimed at setting up new anti-corruption institutions. After it expired, Ukraine went five years without an anti-corruption strategy. A new one was adopted with considerable delay only in June 2022 — and even then not really by choice, but to fulfill EU requirements: Kyiv needed this step in order to obtain candidate-country status. But that strategy, which covered 2022–2025, had largely declarative goals. And — most importantly — it did not take into account the problems associated with Russia’s full-scale invasion at all, since it had been drafted before 2022.

The new document is fundamentally different.

The Strategy for 2026–2030 is considerably more detailed and covers a broader range of areas than its predecessor, in line with the challenges of the moment. In particular, for the first time, a document of this kind includes a dedicated section on recovery.

Structurally, the document the NACP sent to the Cabinet in early April consists of three sections. The first covers the general system of corruption prevention and counteraction. The second covers corruption prevention in priority sectors. The third, added after public consultations, governs the procedural aspects of implementing, monitoring, and evaluating the Strategy and the SAP.

The NACP approached the preparation of the new strategy more inclusively than it had during the previous cycle. External expert groups conducting thematic studies were brought in to work on individual subsections, public consultations were held on each subsection, and the recordings, presentations, and tables showing how comments had been incorporated were made public. This is good practice and improves the document’s transparency and quality.

Transparency International Ukraine was also involved in developing the strategy at several levels. Our DOZORRO experts worked directly on the public procurement section, and we also took part in public consultations on other subsections and submitted written comments on them to the NACP.

The strategy covers most of the key problems in the relevant areas and shows substantial progress in how thoroughly the strategic outcomes have been worked out, compared with the previous cycle.

In particular, several important additions emerged between the first public draft and the text sent to the government. One of the key changes concerns an indicator that now provides for revising pre-trial investigation timeframes and abolishing the automatic closure of criminal proceedings when those timeframes expire. TI Ukraine has long flagged this issue as one of the most acute practical problems.

Other gains include a “strategic pause” between anti-corruption policy cycles, a mechanism to incentivize those who implement the SAP, and the NACP’s right to issue prescriptions to government bodies. The whistleblower protection subsection is better prepared and provides for bringing legislation in line with EU Directive 2019/1937, standardizing the definition of “whistleblower,” and modernizing the Unified Whistleblower Portal.

In the anti-corruption segment of criminal justice (interaction among NABU, SAPO, and HACC), the document matches the European Commission’s technical recommendations — in particular on autonomous wiretapping authority for the NABU, expanded powers for the SAPO Head, and Prosecutor General appointment procedures.

However, the document does have its shortcomings.

We hope to see some of them corrected during parliamentary consideration.

In particular, the effectiveness of the mechanism for verifying e-declarations and for combating money laundering still needs to be addressed — areas whose continued relevance is confirmed by the European Commission’s recommendations as well.

That said, it is already known that some important aspects of the strategy — such as the competitive selection of the Prosecutor General — were ones the government had planned to remove from the document. But because of the Cabinet’s delay, the most ambitious version of the document is the one that has gone to parliament.

Going forward, the important thing is not to weaken the strategy in parliament, but to strengthen it further still.

What’s next?

It is now critical that the government quickly process the draft Anti-Corruption Strategy submitted by the NACP, and that parliament quickly review the comments of the government and the public and — once the document has been refined — vote as soon as possible on the new Law on the Principles of Anti-Corruption Policy for 2026–2030. Above all, this is an international commitment, and failure to meet it directly affects the European integration process.

Parliament’s overall pace of voting on draft laws has slowed considerably as of late, but Ukraine cannot afford to find itself once again in a situation where the state goes for several years without an up-to-date anti-corruption policy cycle.

All the more so given that we have already been in this situation before — and back in 2022, the strategy still had to be adopted in order to meet EU criteria. And by including this document in the “Kachka-Kos plan,” the European Commission has once again reminded us that, for the European Union, this document matters.

What is more, the previous cycle’s experience showed that the belated adoption of the anti-corruption strategy and SAP rendered part of their content outdated, which directly affected the effectiveness of anti-corruption policy. This time around, then, the government and parliament should do everything they can to avoid delaying the adoption of these strategic documents any further than has already happened.

What do these new details from the Mindich tapes mean? 

Andrii Syniuk resigned from the SAPO at his own request back in November last year, right after NABU released the first “Mindich tapes.” As a result, the question of his disciplinary liability as a prosecutor is off the table — a person who has been dismissed cannot be held to disciplinary account within the prosecutorial system.

This resignation, however, in no way closes the question of a criminal-law assessment of Syniuk’s actions. The published materials raise a fundamental question: did Andrii Syniuk disclose pre-trial investigation data he could access by virtue of his position as Deputy Head of the SAPO?

The Criminal Code provides for liability for precisely such conduct. Article 387 specifically addresses cases in which a prosecutor discloses such data, regardless of whether they were directly involved in specific pre-trial investigation. 

We understand why, for tactical reasons and to safeguard the main operation, the SAPO chose not to actively investigate the criminal proceedings opened over the leaks. But following the May 8 journalistic disclosures concerning Operation Midas, we — now as outside observers — see substantial grounds for a criminal-law assessment of Andrii Syniuk’s actions. 

We therefore expect the NABU and the SAPO, in the course of the criminal proceedings, to establish whether Andrii Syniuk did in fact pass case information to the suspects — including data he obtained through the anti-corruption agencies’ internal systems. Given the public interest, we also expect those findings to be made public as soon as doing so no longer risks the investigation.

A study in contrasts: systemic improvement vs. opaque scoring

Last year, only 7 candidates reached the interview stage. This time, 73 made it through to the PCIE and HQCJ. And the reason is not luck — it is systemic improvement of the competition procedures, a process TI Ukraine also contributed to.

The overall elimination rate at each stage of the qualification exam dropped from 43.3% to 13% in the repeat competition. 

The main driver was the new rules introduced under Draft Law No. 12331-2. It reopened the competition to those who had previously failed, missed, or refused the qualification exam — 82 of 205 applicants, or 40% of the total.

The impact of these changes is clearest in the numbers: without the updated rules, we would have had 6 finalists instead of 22, since 16 of those who successfully completed interviews with the PCIE this year had already taken part in prior judicial competitions.

At the same time, the HQCJ chose not to lower the minimum thresholds for the Ukrainian statehood test and the cognitive ability (IQ) test below 75%. In the previous HACC selection round, it was precisely the difficult IQ tests at that high threshold that produced the heaviest attrition — eliminating 79 of 123 participants.

Instead of adjusting the threshold, the HQCJ changed the IQ test provider and, judging by the results, reduced the difficulty of the tests. The Commission apparently took a similar approach with the Ukrainian statehood test — the elimination rate there was the lowest at just 2.5%.

The most dramatic contrast, however, is at the practical assignment stage: only 14.1% failed this time, versus 84% in the 2025 competition. And we have no answer as to why, because the HQCJ ignored calls from civil society to publish the candidates’ written judgments from the practical assignment, along with criterion-by-criterion scoring by members of the examination board.

None of this would matter if HQCJ members had not then squandered the interview opportunity to ask candidates — at least 8 times — about serious errors in their practical assignments. For example, Olena Roik was asked why her judgment convicted the defendant of a more serious offense than the one charged, and Ihor Omelian was asked why his sentence in a false declaration case ordered the convicted person to file an amended declaration. Equally puzzling were the questions about why Yevhen Didenko and Ivan Posokhov ordered special confiscation of laptops used to submit knowingly false declarations, or why Andrii Dudikov mistakenly applied a law that was not in force at the time the offense was committed. 

Judging by the questioning, candidate Olha Pevna — one of the “22” — also made an error in her practical. HQCJ member Serhii Chumak pointed out that her judgment mistakenly imposed a fine above the statutory maximum, and that was not the only concern about Pevna.

We would be able to make sense of these questions if we had access to the completed practical assignments. This once again shows that opaque scoring of practicals only undermines trust in the competition process.

What came up in the PCIE and HQCJ interviews?

As mentioned, the interviews ran for over a month, and despite the punishing schedule and workload, the PCIE and HQCJ genuinely worked hard to keep the bar high. Civil society organizations supported that effort — Transparency International Ukraine, among others, submitted concerns about individual candidates to the Commission and the international experts.

None of this productive work would have been possible without new legal conditions. Draft Law No. 11426, in force since November 2024, gave the PCIE full access to the dossiers of both candidates and sitting judges applying for HACC positions, and extended the interview window from 30 to 45 days.

The longer window proved especially valuable: experts analyzed all available information and conducted interviews with 69 candidates in just 42 days.

As usual, the PCIE and HQCJ focused on assets, ethical conduct, and professionalism. 

Questioning about assets, wealth, and lifestyle was sharp. Candidates often claimed they had managed to live on incomes below the subsistence minimum thanks to tight budgeting and food from their parents. Particular attention went to cases closed under Article 130 of the Code of Administrative Offenses (driving under the influence) — relevant because drawn-out handling of such cases often signals compromised adjudication.

An entirely new line of questioning concerned candidate-judges’ use of the Unified State Register of Court Decisions under full access. Full access, as a reminder, allows users to check whether assets are under arrest, whether a search or other investigative action is being planned, and to look up full names, addresses, and other highly sensitive information. As it turned out, questionable USRCD searches were common among the candidates, and any instance of baseless lookups on relatives and friends seriously damaged their credibility.

The Commission found cases where judges and their assistants had searched for information about themselves, relatives, or other people unrelated to their cases. Judge Tetiana Troian, for example, admitted she used USRCD to watch for a possible bank lawsuit over a debt. Vita Matolych searched for court decisions involving relatives by name or phone number. Candidate Dmytro Movchan looked up one of his relatives in the register more than 100 times.

Separate attention went to candidates’ visits to Russian territory or occupied parts of Ukraine after 2015 — which they described as tourism, personal, or business trips. Explanations like “I saw the occupation as temporary” or references to trips to Kursk Region in 2019 were met with skepticism.

The PCIE and HQCJ also monitored social media — including relatives’ TikTok accounts — to identify undeclared businesses, as happened with candidate Syvokin. He maintained that his wife had no business of any kind, but PCIE members produced what appeared to be her TikTok account, where she presented herself as a beauty professional.

A trail of uncertainty

The challenges of the HACC competition do not end here. Three sitting HACC judges appear set to move up to the Appeals Chamber. This will not create a serious personnel gap in the first instance, but it will significantly affect cases in which these judges served as presiding judges or panel members — their withdrawal means those cases will have to be heard from the start. That includes cases against Hladkovskyi, the Kyrylenko spouses, Mykytas, and others.

On another front, the court will expand its headcount by nearly one and a half times, which creates an urgent need for suitable new premises. On March 25, the HACC even issued an open letter to the President of Ukraine on this.

The 4-judge shortfall at the HACC also means another HACC competition — the fourth — may lie ahead. Replicating the same selection procedure will be extremely difficult, since the PCIE’s mandate expires this May. For the PCIE to take part in the next round, Parliament will need the political will to extend its participation in HACC selection — so that every HACC judge is chosen under the same procedure.