The tapes released as part of Ukrainska Pravda’s investigation contain new evidence of Timur Mindich’s influence over the government and point to signs of corruption that undermine trust in the entire decision-making system, particularly in the defense sector.

Mykhailo Tkach’s report shows that, after the first notices of suspicion were served in this investigation, the authorities underestimated the damage done by the scheme’s participants. And they did not do enough to remove those under investigation from their posts.

Below are the key challenges that, in our view, change the overall context of the entire investigation and the related government processes.

The Prosecutor General has appointed lawyer Oleksii Shevchuk to the SAPO Selection Commission, despite his already questionable reputation. This step is unacceptable, as commission members must meet the highest integrity standards: their work determines trust in the selection process, SAPO’s future independence, and the effectiveness of the anti-corruption system.

The Law of Ukraine on the Prosecutor’s Office sets clear requirements for members of the Selection Commission for SAPO leadership. They must be individuals with an impeccable professional reputation, high professional and moral qualities, public authority, and integrity. These are not merely declarative requirements — they must be confirmed both formally and in light of candidates’ public reputation.

On December 23, 2025, Prosecutor General Ruslan Kravchenko filled the “prosecutor’s quota” for appointing members of the Selection Commission that will select candidates for leadership positions in the Specialized Anti-Corruption Prosecutor’s Office. Those appointed include lawyer Oleksii Shevchuk. Transparency International Ukraine draws attention to circumstances that reasonably cast doubt on whether this individual meets the legal requirements of an impeccable professional reputation, high moral qualities, and public authority.

Open sources contain information indicating that Shevchuk does not meet these criteria.

1. Negative assessment by the Ethics Council in the competition for the High Council of Justice. In 2023, this independent body with the participation of international experts found that Oleksii Shevchuk did not meet the criteria of professional ethics and integrity for a member of the High Council of Justice. These criteria are also relevant for members of the SAPO Selection Commission.

2. Disciplinary proceedings during his legal practice. Open sources contain information about at least two disciplinary cases concerning Oleksii Shevchuk as a lawyer. One involved insulting the honor and dignity of another lawyer, which resulted in a three-month suspension of Shevchuk’s right to practice law. Another concerned a Facebook post in which the lawyer used offensive language toward certain individuals and threatened them with “draft notices to hot zones” as punishment — the Qualification and Disciplinary Commission of the Bar considered this to undermine the authority of the legal profession and show disrespect for military service. As a result, Shevchuk was stripped of his right to practice law; however, the Higher Qualification Commission of the Bar overturned that decision due to procedural violations.

3. Mentions in investigative journalism with negative public resonance. Oleksii Shevchuk has repeatedly appeared in investigations by NGL.media. In particular, regarding the disappearance in Lviv of 10,000 U.S.-supplied military first-aid kits, and the misuse by certain civic organizations of the Shliakh system. At that time, lawyer Shevchuk held the position of head of the coordination headquarters on humanitarian assistance at the Lviv Regional Military Administration and served as an adviser to the head of the Lviv Regional State Administration, Maksym Kozytskyi.

Even in the absence of convictions, the nature and scale of public doubts matter when assessing the integrity of a member of a selection commission, especially in the field of criminal justice. Any reputational risks associated with an individual commission member jeopardize the legitimacy of the entire selection process.

We also note that the selection of SAPO leadership is taking place amid heightened risks of political pressure on anti-corruption bodies. In such circumstances, the quality and impeccable integrity of the Selection Commission’s composition become especially important.

In light of these concerns, Transparency International Ukraine calls on the Prosecutor General to reconsider the decision on the personal composition of the SAPO Selection Commission and replace Oleksii Shevchuk with a person who unequivocally meets the requirements of the Law of Ukraine on the Prosecutor’s Office and the highest integrity standards.

Trust in the leadership of the Specialized Anti-Corruption Prosecutor’s Office begins with trust in the selection process for its leadership positions. That is precisely why the composition of the Selection Commission must be unquestionably authoritative and beyond doubt.

Transparency International Ukraine supports the joint statement by civil society organizations calling for an end to the unlawful actions of the Temporary Investigative Commission on investigating corruption in law enforcement agencies, courts, and judicial authorities (the TIC). 

We believe it is important to emphasize that the activities of this TIC have been discredited from the very outset. In particular, independent investigative journalists and reputable media outlets have publicly reported that the ТІС was established with the aim of preparing political ground for narrowing the powers and undermining the institutional independence of the National Anti-Corruption Bureau of Ukraine (NABU) and the Specialized Anti-Corruption Prosecutor’s Office (SAPO).

Members of Parliament who have led the work of the Commission or taken an active part in its activities largely do not inspire public trust and are associated with a questionable reputation. Notably, the Head of the TIC, Serhii Vlasenko, is closely associated with the leader of the parliamentary faction, Yuliia Tymoshenko, in relation to whom the NABU and the SAPO are conducting criminal proceedings and who has been served with a notice of suspicion this morning. Moreover, Mr. Vlasenko himself is also known for harmful legislative initiatives and for his active opposition to the involvement of international experts in selection commissions. The Deputy Head of the TIC, Mr. Buzhanskyi, was the author of legislative amendments that posed a direct threat to the independence of the anti-corruption infrastructure.

Furthermore, the activities of the TIC have been marked by systematic pressure on members of the High Qualification Commission of Judges, members of the High Council of Justice, and members of the Public Integrity Council, as well as on other individuals involved in judicial reform.

At the end of last year, in accordance with the statutory parliamentary timeline, the TIC published its report. We see a serious risk in that document. In particular, its provisions reflect a significant deviation from Ukraine’s commitments under the rule-of-law agenda, its European integration obligations in the field of anti-corruption, the approved anti-corruption strategy, and the relevant reform roadmaps.

In view of all the arguments above, TI Ukraine considers it necessary to terminate the work of this TIC and supports the joint statement by civil society organizations, which we give below. 

On September 21, Members of Parliament registered Draft Law No. 14057, which proposes comprehensive amendments to the regulation of an individual’s personal non-property rights. Among other things, it contains provisions that, under current conditions, could adversely affect the media and civil society organizations by significantly restricting their ability to report on matters of public interest.

Such provisions would have a chilling effect and may hinder the democratic development of the state. The following proposed norms are of particular concern:

1. Automatic recognition of information violating the presumption of innocence as false.

The authors propose to automatically consider as false any information that violates the presumption of innocence until a person’s guilt is proven and established by a final and binding court conviction.

While respect for and adherence to the presumption of innocence is an essential element of a democratic order, it cannot automatically negate the right to freedom of expression. Without a clear and advance delineation of what constitutes compliance with the presumption of innocence, such an initiative could negatively affect the work of those engaged in investigative journalism as well as those monitoring high-profile corruption cases in the courts.

2. Interference in selection procedures through demands for retraction

The draft law could enable candidates for top positions to demand the retraction of information regarding their assets or personal history published by competition commissions or advisory groups as part of the vetting process. Moreover, if such bodies refuse to retract the information voluntarily, a court could order them to withdraw or annul such decisions, destroy them, or issue new ones without the contested information.

This would undermine the integrity of competitive selection procedures by allowing judicial interference in their conduct and restricting the independence of competition commissions through court assessments of the accuracy of information about candidates. Such provisions could compromise the quality of virtually all competitive appointments to top positions in Ukraine, including judges of the High Anti-Corruption Court, the Constitutional Court, and others.

3. Removal of subjectively “irrelevant” information (right to be forgotten)

The proposal to enshrine in law an individual’s right to demand the deletion of information from publicly available sources is based on vague categories — such as “irrelevance of information” or “loss of public interest.” This could allow courts to uphold claims from individuals seeking to remove negative information about themselves, even if it was disseminated long ago. This would negatively affect selection procedures, as candidates would be able to “clean up” their information landscape in advance, substantially limiting the public’s ability to obtain a full picture of such individuals.

In addition, especially in today’s context, it is vital for Ukrainians to remember those who have spread pro-Russian narratives. The implementation of a “right to be forgotten” could enable precisely those individuals to erase certain chapters of their past from public access.

Despite the extensive package of legal reforms proposed by Draft Law No. 14057, certain provisions could trigger hundreds of lawsuits by interested parties against media outlets and civil society organizations working on anti-corruption issues.

This would undoubtedly undermine the quality of anti-corruption efforts. The authors of the draft law should not restrict freedom of expression by justifying questionable provisions under the pretext of adapting Ukrainian legislation to European standards.

Therefore, Transparency International Ukraine calls on Members of Parliament to revise the provisions of Draft Law No. 14057 after broader consultations with all stakeholders.

The unlawful adoption and hasty signing of Draft Law No. 12414 on July 22 marked a “black” day for the Verkhovna Rada of the IX convocation and President Volodymyr Zelenskyy.

This decision undermined the independence of the anti-corruption infrastructure, yet it failed to shake the strength and unity of Ukrainian society, which once again demonstrated its maturity, agency, and determination in defending democratic values. The adoption of these provisions represented a clear step backward on Ukraine’s path toward European integration and democratic development. In order to resume movement in the right direction, the authorities must return to the initial position and repeal the changes that obstruct the opening of the fundamental reform cluster and contradict the Roadmaps adopted by the Government.

Civil society has repeatedly called on the authorities to engage in constructive dialogue. Today, we call for concrete action — to repeal the provisions of Law No. 4555 through a vote in the parliamentary session on July 31.

We, representatives of civil society organizations and participants in the peaceful protest that spread across Ukraine, call on the Verkhovna Rada to adopt, as a whole, one of the draft laws aimed at restoring the institutional capacity of NABU and SAPO:

• No. 13533, “On Amendments to the Criminal Procedure Code of Ukraine and Certain Legislative Acts of Ukraine Regarding the Strengthening of Powers of the National Anti-Corruption Bureau of Ukraine and the Specialized Anti-Corruption Prosecutor’s Office”, or
• No. 13531, “On Amendments to the Criminal Procedure Code of Ukraine and the Law of Ukraine ‘On the Prosecutor’s Office’ Regarding the Restoration of Institutional Independence of the Bodies Conducting Pre-Trial Investigation and Procedural Oversight in Corruption Cases.”

After the law is adopted in full, we urge the Verkhovna Rada to vote for its immediate signing by the Chairperson of Parliament, and we call on the Speaker and the President of Ukraine to sign it without delay.

We emphasize that passing one of these draft laws is necessary not only for NABU and SAPO, or for our international partners such as the EU and OECD, or for protesters and civic organizations. It is equally needed by the President, the Government, and all Members of Parliament. This is an opportunity to correct a mistake — the only effective and honest way to say to the Ukrainian people: “We are sorry. We were wrong.”

We remind the authorities that they are obligated to strictly adhere to the Constitution of Ukraine, which defines the country’s strategic course toward full membership in the European Union and NATO.

Based on this, and to reaffirm commitment to the European integration path, we call on:

• The President of Ukraine and the Verkhovna Rada of Ukraine — to appoint judges to the Constitutional Court of Ukraine from among the competition-selected candidates.
• The President of Ukraine — to sign the Law of Ukraine “On Amendments to Certain Laws of Ukraine Regarding the Strengthening of Certain Guarantees for Media, Journalists, and Citizens in Access to Information” (draft law No. 11321), which includes, in particular, live streaming of parliamentary committee meetings.
• The President of Ukraine — to stop the systematic violation of the 15-day deadline for signing laws established by Article 94 of the Constitution and to comply with the legal obligation to sign laws in the event of delay.
• The Verkhovna Rada of Ukraine — to preserve the decisive role of international experts in competitive selection procedures, particularly in the selection of members of the High Qualification Commission of Judges of Ukraine by adopting draft law No. 13382.
• The Verkhovna Rada of Ukraine — to initiate amendments to the Law of Ukraine “On Public Consultations” to extend the obligation for Members of Parliament to conduct public consultations during the drafting of legislation.
• The Cabinet of Ministers of Ukraine — to appoint the competitively selected Director of the Bureau of Economic Security (BES).

We appeal to all representatives of the authorities: draw the right conclusions and preserve the unity of Ukrainian society — this is our most vital resource in confronting Russian aggression and building a democratic, European state.

Dear Prime Minister and Members of the Cabinet of Ministers of Ukraine,

We, the representatives of civil society organizations, business associations, and public opinion leaders, call on you to appoint Oleksandr Tsyvinskyi, the winner of a transparent competition, as Director of the Economic Security Bureau of Ukraine (ESBU).

Ukrainian society, the business community, and international partners have high expectations for the reboot of the ESBU. The effective, depoliticized, and professional functioning of this agency is key to creating a favorable investment climate, reducing the shadow economy, and strengthening trust in public institutions. A successful reform of the ESBU is not only a core requirement of our international partners but also a vital necessity for Ukraine’s economic resilience during the war and throughout the post-war recovery.

We remind you that the Competition Commission, which included international experts, held a transparent competition and identified Oleksandr Tsyvinskyi as the winning candidate for the position of ESBU Director. We urge you not to repeat the mistakes of the previous government and to make a historic decision that demonstrates genuine political will for change. Appoint Oleksandr Tsyvinskyi as Director of the Economic Security Bureau and launch the much-needed institutional reset that the entire country is waiting for.

We trust in your wisdom and sense of responsibility to the public and the state.

To the President of Ukraine 

Volodymyr Zelenskyy

To the Prosecutor General of Ukraine 

Ruslan Kravchenko

To the Director of the State Bureau of Investigation 

Oleksii Sukhachov

 

 

STATEMENT

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

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

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

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

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

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

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

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

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

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

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

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

We call upon:

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

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

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

On June 1, 2025, the mandate of the international experts serving on the Competition Commission for selecting members of the High Qualification Commission of Judges (HQCJ) expired. Their seats are to be taken by representatives of the unreformed Council of Judges and the Bar Council of Ukraine. Following this, in November, the mandates of international experts in the Public Council of International Experts (PCIE) under the High Anti-Corruption Court (HACC) and other similar commissions are also set to expire. Therefore, unless the involvement of international experts is extended without interruption, Ukraine will lose a key safeguard for the independence of the HQCJ, and with it, the prospect of genuine rule of law for years to come.

Two years after its relaunch, the HQCJ has raised the transparency of selection processes and has already begun recruiting over two thousand new judges for local and appellate courts. Under its new composition, every fifth judge interviewed receives a recommendation for dismissal — from “Maidan judges” like Olena Izotova-Vakim to DACK judges such as Tetiana Sheiko.

These achievements would not have been possible without the EU integration process and the decisive voting power of international experts. The reform of the HQCJ and the High Council of Justice (HCJ) was the second of the seven requirements that earned Ukraine candidate status and opened accession talks with the EU. The involvement of international experts ensured that political or corporate interests of vested parties would not influence the final list of candidates for these institutions.

Now the HQCJ faces even greater challenges: to fill 2,350 vacancies in local and appellate courts, form the benches of two new administrative courts, conduct another selection for the HACC, and renew the Supreme Court.

However, the independence of the HQCJ is under threat. The institution is under systematic pressure from the SBI, and the expiration of the international experts’ mandate opens the door to puppet candidates being nominated to the Competition Commission by Ukrainian institutions. For example, Lidiia Izovitova, the head of the Bar, known for her closeness to Viktor Medvedchuk, will be involved in nominating Ukrainian experts to the Competition Commission. With such delegates, the Commission will consist of representatives of the old corrupt elite seeking a return to the Yanukovych era. As a result, the HQCJ risks once again becoming a recruitment center for dependent judges, and all the efforts of the current composition of the Qualification Commission will be devalued.

The experience of post-2014 reforms has shown that out of all models for selecting judges and other officials, only those involving international experts have proven effective. The most telling examples come from the work of new institutions and their commissions: in five years, the HACC has delivered over two hundred verdicts against top-level corrupt officials; the Ethics Council has blocked the appointment of notorious candidates to HCJ; and the NACP, after a selection process involving international experts, has improved the formation of national anti-corruption policy. Where there was no external voice, as in the Council of Judges, the system continues to reproduce itself.

The model of giving decisive voting power to external experts has already become the “gold standard” beyond the judiciary as well, and it enjoys broad public support: 56% of Ukrainians believe that international professionals should have the dominant say in the selection of judges.

We firmly believe that preserving the decisive vote of international experts is not a matter of procedural formality, but a strategic choice: either an independent HQCJ and fair selection processes today — or a return to mutual cover-ups for many years to come. We choose the former and call on:

1. The Verkhovna Rada and the President of Ukraine — to urgently adopt legislation extending the mandate of international experts on the Competition Commission until the completion of key selections
2. The European Union — to ensure that documents governing Ukraine’s path to EU membership include clear provisions on the decisive vote of international experts in commissions supporting the formation of rule of law institutions
3. Ukraine’s international partners and donors — to provide sufficient financial and organizational support for the functioning of such commissions to ensure their continued independence and capacity to fulfill their crucial mission.

This statement is open for endorsement by civil society organizations: join us.

The RISE Ukraine Coalition calls on Members of Ukrainian Parliament to urgently support Draft Law No. 12374-d, aimed at a comprehensive reform of the Asset Recovery and Management Agency (ARMA).

This draft law is a critically important step toward ensuring transparent and effective management of seized assets, which directly affects Ukraine’s recovery processes.

Recovery and remediation of the consequences of war require significant financial resources. The Fund for the Elimination of the Consequences of Armed Aggression, intended to be filled through sanctioned assets, has already become one of the key instruments for financing reconstruction. However, the current system for managing seized sanctioned assets creates room for manipulation, in particular due to poorly designed public policy in the area of ensuring confiscation through criminal seizures.

Draft Law No. 12374-d effectively addresses these issues by establishing a clear mechanism for transferring sanctioned assets seized in criminal proceedings to the SPFU, enabling further allocation of funds for recovery.

Draft Law No. 12374-d is the most robust ARMA reform proposal among all those submitted to Parliament. It comprehensively incorporates previously registered legislative initiatives. This draft law:

1. Standardizes asset identification procedures — introduces a clear mechanism for analysis and planning before the transfer of assets into management.
   
2. Improves the system for managing different types of assets — introduces a differentiated approach for simple and complex assets, and establishes clear deadlines for management procedures.
   
3. Increases transparency — expands ARMA’s public reporting obligations and requires the disclosure of more information on the status of assets, income from their management, and the Agency’s performance.
   
4. Unblocks the management of corporate rights of enterprises linked to the aggressor state.
   
5. Regulates the issue of sanctioned assets — clearly establishes that assets seized in criminal proceedings and confiscated under sanctions will be transferred to the SPFU to enforce the relevant decision and contribute to the Fund for the Elimination of the Consequences of Armed Aggression.

The adoption of Draft Law No. 12374-d is an important step toward implementing effective and well-defined asset management mechanisms, as well as ensuring transparent and high-quality oversight of these processes.

Therefore, the RISE Ukraine Coalition urges the Verkhovna Rada of Ukraine to promptly consider and support Draft Law No. 12374-d.