How do things stand now?

Most articles in the CPC section devoted to international cooperation have not been amended since the Code was adopted in 2012. At that time, digitalization was not a global priority, and the practice of international cooperation had not become widespread enough to reveal the weaknesses in its legal regulation. 

As a result, the provisions currently in force lag in many respects behind technological progress and the new legal approaches to mutual legal assistance — particularly when it comes to confiscating assets located in foreign states and dealing with participants in criminal proceedings who are abroad.

The exchange of materials in international cooperation. Current legislation permits requests and case materials to be exchanged in paper form during international cooperation. This significantly slows down Ukraine’s interaction with partner states in the fight against crime, since it requires a considerable amount of time.

The protection of information in international cooperation. Information processed within such cooperation currently has no clear safeguards against disclosure — especially where the cooperation does not require opening criminal proceedings in Ukraine.

The international wanted list. The CPC does not expressly define the moment from which a person is considered to be on the international wanted list.

The enforcement of HACC judgments. Although the HACC hears high-level corruption cases as a specialized court, certain matters arising in the enforcement of its judgments — such as a convicted person’s parole or the replacement of the unserved part of a sentence with a more lenient one — still go before local courts under the rules of Article 539 of the CPC, rather than before the HACC.

The confiscation and special confiscation of property abroad. The CPC does not contain a sufficiently detailed mechanism for establishing the location abroad of property subject to confiscation or special confiscation. The engagement of ARMA to trace and seize property abroad when enforcing confiscation decisions is also currently unregulated.

Questioning from abroad. Witnesses or victims located abroad can be questioned only from the premises of a court at their place of residence, which means that a corresponding request must be sent each time to the competent authorities of the foreign state through mutual legal assistance. Only for the duration of martial law or a state of emergency has it become possible to question a witness or victim directly by videoconference from any location.

What does the draft law propose?

Draft Law No. 14292 proposes a fairly broad package of changes. Among the key positive updates:

• permission to make wider use of electronic communications for international cooperation requests;
• regulation of the protection of information and materials in international cooperation;
• a more detailed set of grounds for refusing or postponing mutual legal assistance requests, and of the procedure for executing them;
• improvement of the procedure for recognizing and enforcing judgments, as well as for confiscating property abroad;
• the introduction of the ability to question persons located abroad by videoconference or from the premises of a Ukrainian diplomatic mission, regardless of whether martial law or a state of emergency has been declared in the country.

Which provisions need refining?

Despite its generally positive thrust, the document contains a number of procedural gaps, legal ambiguities, and risks that could negate the intended effect in practice.

For the mechanisms it establishes to work smoothly, the document should be refined in the respects described below.

Confiscation of property abroad: the right direction, but a weak procedural design

The amendments to Articles 535 and 568 of the CPC are intended to ensure the enforcement of judgments insofar as they concern the confiscation or special confiscation of property located abroad. This is an important step, particularly in countering organized crime, and corruption in particular. There are two problematic points whose resolution could improve this process.

In the proposed wording of Article 535(7) of the CPC, the drafters would require the court to draw up a petition for the recognition and enforcement, in a foreign state, of a Ukrainian court’s conviction insofar as it concerns the confiscation or special confiscation of property. However, the drafters failed to take into account that special confiscation may be imposed not only by a court’s verdict but also, under Article 96-1(2) and (3) of the CC, by rulings on release from criminal liability, on the closure of criminal proceedings, on extended confiscation, on the imposition of coercive measures of a medical or educational nature, and on the imposition of criminal-law measures on a legal entity. The aforementioned provision of Article 535(7) of the CPC should therefore also include a reference to the rulings listed in Article 96-1(2) of the CC.

In addition, the draft law would require those enforcing the judgment (chiefly the State Enforcement Service) to notify the court of any property discovered abroad that is subject to confiscation or special confiscation.

This innovation is consistent with EU Directive 2024/1260, under which the tracing and identification of property subject to freezing and confiscation must be possible even after a final court decision. Yet, although the draft law offers such an option, the point at which criminal property — or property subject to confiscation — is discovered should not be deferred all the way until the court’s final decision. 

The reason is that state enforcement officers cannot match law enforcement agencies or ARMA in detecting and tracing property, especially abroad — they lack sufficient powers and resources for this. 

As noted earlier, it is law enforcement agencies during the pre-trial investigation, and ARMA, that have the most tools for tracing and identifying assets subject to confiscation. Even they, however, do so fairly rarely, and the reason is that Article 91 of the current CPC in no way requires the location of property subject to confiscation or special confiscation to be proved within criminal proceedings. Largely because of this, in most cases such property ultimately goes unnoticed by the enforcement service.

Therefore, to adapt the provisions of EU Directive 2024/1260 to Ukrainian realities, it would be sensible, first, to supplement Article 91 of the CPC with provisions requiring the prosecution to prove the location of assets subject to confiscation or special confiscation. Second, to establish that, when enforcing court decisions on confiscation for the laundering of criminal property or for corruption, ARMA may be engaged to identify property that may be confiscated. Article 535(7) of the CPC should also include a reference to the rulings listed in Article 96-1(2) of the CC.

2. The international wanted list, the digitalization of summonses, and the removal of procedural obstacles for persons abroad

One of the draft law’s provisions concerns placing a suspect on the international wanted list. In Article 291 of the CPC, the drafters propose to draw a clear distinction between a domestic search within Ukraine and an international one, and to establish that a suspect is deemed wanted precisely from the moment the investigator or prosecutor issues a decision to that effect.

This will help settle long-standing debates about the moment from which a person is considered placed on the international wanted list and will allow courts to follow a single line of application. 

At the same time, the amendments to this article will not resolve another, more acute problem. It concerns cases where suspects or the defendants are abroad and the defense, invoking Article 135(7) of the CPC, argues that they may be reached solely through the diplomatic-channel procedure. Currently, under this provision, a summons for a person residing abroad is served through international cooperation mechanisms.

HACC case law reasonably explains that a person’s mere presence abroad does not require summoning them through diplomatic channels, since such channels should be used only if the person has formally arranged permanent residence, registered with a consulate, deregistered their residence, and the like. If no such facts are established during the criminal proceedings, the person is summoned in the ordinary manner.

 Even so, the debate over this issue continues, owing to lawyers’ inconsistent reading of the said Article 135(7) of the CPC. This is precisely why the measure under the State Anti-Corruption Program to simplify the procedure for summoning, in criminal proceedings, persons who reside abroad and are citizens of Ukraine has not yet been implemented.

It would therefore be best to specify clearly in Article 135(7) of the CPC that a person located abroad may also be summoned through electronic means of communication — official email addresses, messengers, and social media (provided that the person’s use of them is documented).

3. Matters concerning the enforcement of HACC judgments should remain within that court’s jurisdiction 

The draft law also proposes amendments to Article 539 of the CPC. In this article, the drafters seek to clarify that the question of parole, or of replacing the unserved part of the sentence of a convicted person who has been transferred to serve their sentence abroad, is decided by the Ukrainian court that delivered the verdict. 

This provision carries no risks; however, while amending this article of the CPC, the legislator could also resolve the problem of matters relating to the enforcement of HACC judgments being decided by courts other than the HACC. Thus, by amending Article 539 of the CPC, the legislator could solve two problems at once.

The HACC has special subject-matter jurisdiction over corruption-related criminal proceedings. Yet most matters relating to the enforcement of its judgments are decided by local courts — in particular, at the person’s place of serving the sentence or place of residence. 

Local courts are entitled to grant parole to persons convicted by HACC judgments, to substitute their punishment, and to release them from it altogether. Such situations are not uncommon. For example, in 2024 the Shevchenkivskyi District Court of Kyiv granted parole to a person convicted by the HACC — an accomplice in the bribery case involving the director of the Rzhyshchiv Military Forestry State Enterprise — so that he could serve in the military. And in 2025 the Voznesensk City-District Court released from punishment the head of a private company who had been convicted of misappropriating UAH 787 million of an NBU loan and of participating in the Yanukovych–Kurchenko criminal organization.

Matters relating to the enforcement of HACC judgments should be decided by that very court, since they can substantially affect the actual extent of the punishment imposed on those convicted of corruption-related criminal offenses — and therefore its deterrent, punitive, and rehabilitative effect.

Article 539 of the CPC should therefore be supplemented with a separate clause under which matters relating to the enforcement of a HACC judgment will be decided by the HACC alone. 

4. Eliminating the risks associated with the extradition procedure 

The draft law’s amendments also touch on extradition. The drafters spell out the procedure for submitting extradition requests, the handling of situations where several states request a person’s extradition, the application of preventive measures to such persons, and so on. Some of the proposed innovations require clarification.

The draft law adds to Article 575 of the CPC a mechanism for confirming that an extradition request remains valid. Under it, the court must respond to the Ministry of Justice on whether the request remains valid, and a failure to provide such a response becomes grounds for withdrawing it. Yet the drafters set no deadline at all for providing this response.

This creates a risk that, because the response deadline is undefined, the Ministry of Justice may mistakenly treat such an extradition request as withdrawn — even though the court has provided no response at all.

It is therefore important to add to the new Article 575(7) and (8) of the CPC clear deadlines for the court’s response, and to provide that it is a negative response from the court — not the absence of one — that constitutes grounds for withdrawing such a request.

In addition, to align the rules on simultaneous requests for a person’s surrender, the new clause 5-2 of Article 589(1) of the CPC should be supplemented with a further ground for refusing extradition: the surrender of the extradited person to one of the requesting states.

Thus it is necessary, first, to add to the proposed Article 575(7) and (8) of the CPC clear deadlines for courts to respond to the Ministry of Justice, and to provide that it is a negative response from the courts — not the absence of one — that constitutes grounds for withdrawing an extradition request. Second, the new clause 5-2 of Article 589(1) of the CPC should be supplemented with the following ground for refusing extradition: the surrender of the extradited person to one of the requesting states.

Conclusions

Transparency International Ukraine recommends adopting Draft Law No. 14292 in the first reading as a basis, with refinement ahead of the second reading, since adopting it in its current wording would leave gaps that would diminish the effect of the changes made.

In our view, the following recommendations should be taken into account during this refinement:

• Supplement Article 91 of the CPC with provisions requiring the prosecution to prove the location of assets subject to confiscation or special confiscation. 
• Establish that state enforcement officers may engage ARMA to identify property that may be confiscated when enforcing judgments or rulings for the laundering of criminal property (Article 209 of the CC) or for corruption (Note 1 to Article 45 of the CC). 
• Add to Article 535(7) of the CPC a reference to the rulings listed in Article 96-1(2) of the CC.
• Specify clearly in Article 135(7) of the CPC that a person located abroad may also be summoned through electronic means of communication — official email addresses, messengers, and social media (provided that the person’s use of them is documented).
• Add to Article 539 of the CPC a separate clause under which matters relating to the enforcement of a HACC judgment will be decided by the HACC alone. 
• Add to the proposed Article 575(7) and (8) of the CPC clear deadlines for courts to respond to the Ministry of Justice, and provide that it is a negative response from the courts — not the absence of one — that will constitute grounds for withdrawing an extradition request. 
• Supplement the new clause 5-2 of Article 589(1) of the CPC with the following ground for refusing extradition: the surrender of the extradited person to one of the requesting states.

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.”

How do sanctions work?

Yurii Ivaniushchenko, also known as “Yura from Yenakiieve,” is a former Party of Regions MP of the 6th and 7th convocations and one of Viktor Yanukovych’s closest associates. After the Revolution of Dignity, he fled the country and has since lived primarily in Monaco. But despite all the cases opened against him, Ivaniushchenko is still not under sanctions.

A reminder here: sanctions in Ukraine are governed by the dedicated Law on Sanctions. Under this law, proposals to apply such restrictions to a specific individual, company, or state can be submitted to the NSDC by parliament, the president, the Cabinet of Ministers, the National Bank, or the Security Service. And although the SSU is not the only body that can propose sanctions against someone, it is entirely logical that the NABU turned to it as a law enforcement agency.

The grounds for applying sanctions, while described fairly broadly in the law, form an exhaustive list, and all of them relate to protecting the state’s national interests or the rights of its citizens. That said, we cannot know for certain why sanctions are imposed on any specific person, since such reasoning is not made public.

By way of example, we can recall the rapid imposition of NSDC sanctions on Timur Mindich and Oleksandr Tsukerman following NABU’s release of materials from the Midas case.

At the time, the tapes published by NABU referred, among other things, to “two [million] to Moscow.” And although we cannot assert that this was precisely what underpinned the sanctions, it is clear that, unlike in the Ivaniushchenko case, there was enough evidence of activity threatening national security to impose on Mindich and Tsukerman more than half of all available restrictions. The package even included deprivation of state awards — which Mindich and Tsukerman do not hold — and a ban on foreign non-military vessels and warships entering Ukraine’s territorial waters, although that sanction also has little bearing on these particular figures in NABU’s case.

At the same time, we do not know the reasoning behind the sanctions imposed on Mindich, Tsukerman, or other figures on such sanctions lists. The general problem with Ukrainian sanctions is that we cannot find out which specific actions and supporting evidence underpin the application of such measures to any given person. This is because sanctions are often based on the materials of criminal cases in which the sanctioned individuals are involved, and that information cannot be disclosed. That said, under the EU standard, the NSDC’s decision should at least include a general statement of reasons for sanctioning a person.

In Ivaniushchenko’s case, once again, we can rely on the materials the NABU has published, the contents of court rulings, and the SSU’s own public statement — all of which refer to his ties to Russia. Despite this, it is impossible to understand why the NSDC applied sanctions against Mindich and Tsukerman but the SSU refused to take the same approach with Ivaniushchenko, because the law does not require the reasoning behind such decisions to be made public.

How does Ivaniushchenko’s citizenship affect the application of sanctions?

There is one more contested aspect to the “Yura from Yenakiieve” case — his Ukrainian citizenship. The practice of states imposing sanctions on their own citizens is generally very rare, since it runs counter to the very logic of such measures. For its own citizens, the state has internal means of influence — chief among them criminal liability for offenses against national security and the like.

Under the law, all sanctions other than deprivation of state awards may be applied to Ukrainian citizens only if those individuals engage in terrorist activity. But there is room for maneuver when it comes to people who hold dual citizenship, have been stripped of Ukrainian citizenship, or hold only a residence permit. In particular, the Law on Citizenship of Ukraine sets out, as a ground for termination of citizenship, the voluntary acquisition by a person of citizenship of a state recognized by the Verkhovna Rada of Ukraine as an aggressor state or occupying state.

The European Convention on Nationality likewise allows a state to deprive a person of citizenship if they have voluntarily acquired the citizenship of another country or if their conduct seriously harms the state’s interests.

 

Many sanctioned Ukrainian citizens have also held Russian citizenship — Viktor Yanukovych, for example. As for other cases, Ihor Kolomoiskyi was stripped of Ukrainian citizenship by a presidential decree, and Hennadii Boholiubov holds only a permanent residence permit in Ukraine (although the sanctions register lists him as a Ukrainian citizen). 

In the cases of Petro Poroshenko, Kostiantyn Zhevaho, and, more recently, Andrii Bohdan, however, the NSDC must have evidence of their terrorist activity, since these individuals do not hold any citizenship other than Ukrainian and have not been stripped of it.

As for Yurii Ivaniushchenko, according to Radio Liberty, back in 2004 he obtained a passport of a citizen of the Russian Federation in Rostov-on-Don. In the same investigation, journalists indicate that the former MP held at least two Russian international passports and used them to travel to Russia. In particular, since the start of the full-scale invasion, he has flown there at least ten times. 

Thus, Ivaniushchenko’s citizenship should not stand in the way of applying NSDC sanctions against him — given the now-established practice of sanctioning even Ukrainian citizens who hold no other passport.

*** 

The Ivaniushchenko story is yet another piece of evidence that Ukraine’s sanctions policy has shifted from confronting Russia to using such measures as a substitute for justice or a tool of selective political pressure.

A situation in which the SSU itself publicly labels someone an “FSB resident in the ‘DPR’” and then does not find sufficient grounds to impose sanctions on that person amounts, at the very least, to institutional inconsistency that requires a better explanation than the one NABU received in response to its petition.

As long as the reasoning behind sanctions remains opaque and their application remains situational and reactive, this instrument will continue to be perceived not as part of the national security system, but as a lever whose use depends on the political climate.

1. New evidence of improper influence over the government 

The tapes document specific instances where Timur Mindich gave direct instructions to then-Defense Minister Rustem Umerov. In particular, he asks Umerov to “sign off on the acceptance” of body armor that the state had refused to accept, and lobbies for the appointment of certain people to positions. The tapes also reference potential “summoning” of NBU Governor Andrii Pyshnyi to resolve matters required by those under NABU investigation.

All this points to preferential treatment for certain businesses because they have powerful patrons. It has limited the potential growth and development of Ukraine’s defense sector and once again exposed an institutional gap in which state bodies remain vulnerable to interference by outside actors. 

2. The tapes indicate Mindich’s direct involvement in defense company Fire Point

The released materials show that former Defense Minister Umerov considers Timur Mindich to be the actual owner of Fire Point — and Mindich is evidently one of the firm’s beneficiaries. 

As the Public Anti-Corruption Council under the Ministry of Defense has stated, if this fact is confirmed, Fire Point will completely lose the ability to supply its products to Ukraine’s Defense Forces, because Mindich is under sanctions. It can therefore be assumed that Fire Point disclosed knowingly false information about its beneficiaries, and so, in the PACC’s view, may face a fine and be classified as a risky supplier.

This creates additional difficulties for Ukraine’s defense capabilities during wartime.

3. Questions raised again about the Dynasty cooperative and the President’s inner circle 

The released recordings have given us still more detail about the cottage complex being built in Kozyn, previously reported on by investigative journalists. It is now known that mansions in this complex were being prepared for, among others, former Deputy Prime Minister Oleksii Chernyshov, “Vova,” “Andrii,” and Timur Mindich. These facts have once again revived discussion of the Dynasty cooperative and renewed questions about the origin of funds for its construction.

These challenges reveal a deep distortion of the governance system and demand an immediate change of approach to prevent abuses. Despite the President’s public support for the investigation into the “Mindich case” and the dismissal of the Head of the Office of the President, the new data point to the suspect’s likely influence over NSDC Secretary Rustem Umerov. 

Transparency International Ukraine calls on the President to remove from office all those involved in the scheme and to ensure transparency of decisions. The Office of the President’s selective reactions to the investigation not only strike at the state’s reputation but also undermine Ukraine’s internal capacity in wartime.

How does register access work?

The USRCD operates under two access tiers. 

General access is open to the public via the official web portal. All published decisions are depersonalized — names, addresses, and other sensitive data are stripped out. 

Full access is a restricted, service-use instrument available exclusively to judges, court staff, and authorized personnel of law enforcement and state bodies (NABU, SAPO, SSU, SBI, ARMA, etc.). This tier displays unredacted documents in their entirety. Authorization requires login through the Electronic Court system using personal digital keys or tokens.

Under the USRCD Maintenance Procedure, the administrator — state enterprise Judicial Information Systems — is required to track and log all actions by authorized users. In other words: there’s a paper trail for who searched what, and when.

What’s the problem?

Debate over the unauthorized dissemination of information obtained through full register access intensified following several NABU cases, most notably the Borzykh case. More recently, the Midas operation disclosure revealed officials from multiple agencies browsing sealed rulings without legitimate cause. And during HACC judicial selection interviews, it emerged that candidates — themselves authorized registry users — had conducted searches impossible to justify on professional grounds. 

As we can see, last year alone saw no shortage of unjustified searches in the USRCD. The mechanisms enabling these leaks fall into three categories.

Use of others’ credentials. Various authorities have confirmed cases where third parties (typically lawyers) accessed the sealed register using judges’ login credentials. In one case from the Kyiv Region, a lawyer allegedly logged in under a judge’s credentials to retrieve rulings concerning his clients (operators of fraudulent call centers) and tipped them off about planned investigative actions. This was prosecuted as unauthorized interference with automated systems under Article 361(5) of the Criminal Code.

Court staff acting as insiders. Schemes have also been uncovered where court employees systematically supply information to outside clients. In Dnipro, a judge’s assistant allegedly conducted targeted searches twice a week on behalf of criminal actors and lawyers, printed search warrants (including those in money-laundering cases) and handed them over for payment.

Unjustified searches under full access. Log analysis during HACC selection interviews revealed widespread misuse of service-level credentials for personal purposes. It was established that candidates (sitting judges) had run hundreds of queries on former family members, their businesses, or their own cases. One candidate’s login was linked to 240 queries unrelated to their caseload, including 75 searches on their sister’s ex-husband, who was under investigation. System logs show recurring searches by name on prominent figures in anti-corruption investigations (Alperin, for example), conducted by individuals with no procedural connection to those cases whatsoever. Candidates routinely explain this away as “general professional curiosity,” but for investigators it creates a real risk of prematurely exposing prosecutorial strategy.

Technical logging can trace activity tied to a specific digital key over years. Yet users frequently claim no knowledge of the individuals searched or simply can’t explain the queries — strongly suggesting either credential-sharing or deliberate concealment.

What’s the current legal framework?

The Law of Ukraine on Access to Court Decisions, the primary statute governing the USRCD, specifies when general access may be restricted — but says nothing about restricting full access to particular categories of decisions. 

The assumption, apparently, was that all authorized users would handle the information responsibly. The record shows otherwise.

In response, the High Council of Justice adopted amendments in July 2023, at NABU’s request, permitting investigators and prosecutors to restrict (or delay) general access to certain rulings. The Supreme Court struck those amendments down.

On top of all preventive measures, criminal liability applies to unauthorized actions involving register data. The relevant offenses include: unauthorized interference with the operation of information and communication systems and networks (Article 361 of the Criminal Code); illegal sale or distribution of restricted-access information stored in computer systems (Article 361-2); deliberate entry of false information or failure to timely enter data into judicial automated systems (the UJITC, etc.), as well as unauthorized actions involving data in such systems — whether committed by authorized users or outsiders (Article 376-1).

But criminal liability is reactive — it responds to leaks that have already occurred. It does not deter effectively, nor does it protect ongoing investigations.

The USRCD Maintenance Procedure does authorize Judicial Information Systems to revoke full access from users who violate the law, including by disclosing register information. 

Tellingly, the gaps in USRCD access regulation are acknowledged by the expert community as well. The draft Anti-Corruption Strategy 2026–2030 lists as an expected result the establishment of effective mechanisms to prevent, detect, and respond to abuse in automated case distribution and register access — including audit and automated monitoring of full-access user activity (para. 2.1.5.4). It also requires that any restriction on access to court decisions be justified, proportionate, and based on legally established procedures (para. 2.1.5.5). The message is clear: the current framework is inadequate and the need for changes is already overdue.

What needs to change?

One step has already been taken: as of March 1, 2025, USRCD authorization requires tokens through the Electronic Court system, eliminating simple username-and-password logins. This makes it possible to establish that full access was obtained from a specific judge — not as a result of negligence.

Legislative reform is the other piece of the puzzle. Earlier attempts to amend the law on access to court decisions, including to prevent unauthorized disclosure of information available under full access, have already been made. Last year, MPs actively pushed Draft Law No. 7033-d, which drew public criticism for proposals that would have restricted general access to the USRCD as well — a disproportionate and unacceptable overreach. A revised version is now back before the relevant committee. 

There have also been calls to close off all pre-trial decisions from the register entirely. But it bears repeating: unauthorized dissemination occurs precisely through full access — the tier that is, by design, limited to a narrow circle of users. Moreover, many pre-trial rulings are issued in open hearings, some of which are even broadcast. Blanket restriction on general access to such rulings would undermine public oversight — and that is unacceptable.

It is also worth acknowledging that full access to the register can, in certain cases, be a genuinely effective tool. Quick access to information helps resolve conflicts of interest, prevent attempts to resell assets after a freeze, and address other operational needs. But calibrating the scope of accessible rulings to the actual mandate of the official holding full access would go a long way toward eliminating the risks of unauthorized disclosure.

To protect particularly sensitive pre-trial information, we support legislative proposals to restrict full access as well, so that officials would be unable to retrieve information on search warrants, covert investigative measures, asset freezes, and temporary access orders. Critically, these restrictions should apply specifically to decisions issued in closed hearings. 

The closed-hearing mechanism under Article 27 of the Criminal Procedure Code allows for the publication of rulings with targeted redaction of information whose disclosure could harm either individual rights or the interests of the pre-trial investigation. Blanket restriction on general access to decisions issued in open proceedings, such as pre-trial detention rulings or extensions of investigation periods, would erode accountability and public monitoring, including the ability to track the progress of corruption investigations. Post-indictment asset freeze decisions, reviewed with the participation of property owners, allow the public to monitor whether confiscation actually follows conviction. That oversight function must be preserved.

Even now, a troubling pattern is visible: access to certain plea agreement verdicts is being restricted from general view, despite judges having the tools to redact only the sensitive portions. However important the interests of an investigation may be, the mechanisms of accountability and transparency must not be sacrificed — they are among Ukraine’s hard-won achievements on the road to democratic law enforcement.

Finally, having reviewed the recordings of joint PCIE and HJCJ qualification sessions on HACC judicial selection, we can confirm that the technical capacity to monitor USRCD activity already exists. What is now needed is a legal obligation to use it: regular audits of search activity, with clear and enforceable consequences — disciplinary action for unjustified queries, and criminal liability where the elements of an offense are present.

***

Unauthorized access to the court register has become a systemic problem — and criminal liability alone will not solve it. Addressing it requires a comprehensive approach combining technical, legislative, and organizational measures.

First, the scope of full register access must be reviewed against the actual mandate of each official who holds it. Where clear criteria can be established, that access should be narrowed accordingly.

Second, legislation must restrict full access to specific categories of decisions: search warrants, asset freezes, and other rulings issued in closed hearings. These should be unavailable in full mode for a defined period, or until a specified trigger — such as the delivery of a verdict in the case.

The closed-hearing mechanism under Article 27 of the Criminal Procedure Code should in turn be applied consistently — with targeted redaction of sensitive information, not wholesale closure of entire decisions.

Third, the existing technical logging capacity must become the foundation for regular audits of search activity, with clear consequences for unjustified queries — disciplinary or criminal, depending on whether the elements of an offense are present.

Throughout all of this, any restrictions must leave the principle of open justice intact. Unjustifiably closing off access to plea agreement verdicts or pre-trial rulings, such as detention decisions, would undermine the democratic oversight of law enforcement that Ukraine has been building.

How quickly NABU investigates cases and SAPO sends indictments to court

The data presented in February point to a certain decline in the number of people notified of suspicion in corruption cases in 2025, but overall, they indicate intensified work targeting top officials. 

While in 2024 notices of suspicion were served on 231 people in total, in 2025 that number was 218. 

So how did these figures change across categories of officials?

• The number of the highest-ranking officials notified of suspicion (ministers, heads of central executive authorities, and their deputies) doubled, from 6 people in 2024 to 12 in 2025.

For example, in 2024 former Minister of Agrarian Policy Mykola Solskyi was notified of suspicion in a land seizure case in Sumy region; former Deputy Head of the Office of the President Andrii Smyrnov was notified of suspicion for laundering illicitly obtained funds and accepting an offer of a bribe; and former Deputy Energy Minister Oleksandr Kheilo was notified of suspicion for offering a bribe. In 2025, those notified of suspicion included Antimonopoly Committee Head Pavlo Kyrylenko in a new episode of failure to declare assets and illicit enrichment; former Deputy Prime Minister and Minister of National Unity of Ukraine Oleksii Chernyshov for alleged abuse of office and accepting an undue benefit; and former Deputy Minister of Agrarian Policy and Food Volodymyr Topchii for alleged abuse of office.

• Representatives of the judiciary: 10 people received notices of suspicion in 2025, compared with 5 in 2024.

Among the NABU-SAPO proceedings in 2024, notable cases included the bribery case involving economic court judges in Lviv region and the case involving judges of the Bilhorod-Dnistrovskyi court in Odesa region, who allegedly accepted bribes for rulings that became grounds for draft deferments. In 2025, suspects in NABU bribery cases included a judge of a city district court in Dnipropetrovsk region, a judge of one of Odesa’s district courts, and a judge of the Volovets district court.

• Members of Parliament and local councils, as well as other local senior officials: the figure remained at roughly the same level—21 people in 2025 versus 22 in 2024. 

In this category, those notified of suspicion in 2024 included MP Mykola Zadorozhnii, who, according to the prosecution, together with accomplices solicited a bribe from the head of a village council in Sumy region and organized its transfer. Notices of suspicion were also served on Iryna Kormyshkina in a case involving illicit enrichment and false declarations, and on Mukachevo Mayor Andrii Baloha for allegedly ensuring the adoption of a decision to sell a municipally owned land plot at an understated price. In 2025, NABU and SAPO notified MP Viktor Bondar of suspicion for organizing a scheme to supply products to Ukrzaliznytsia at inflated prices. In another case, as many as four sitting MPs—Yevhen Pyvovarov, Ihor Nehulevskyi, Olha Savchenko, and Yurii Kisiel—were named as suspects for, according to the investigation, systematically receiving undue benefits in exchange for voting in Parliament.

• The number of suspected officials of state agencies and state-owned companies decreased: there were 23 such individuals in 2025, compared with 37 in 2024.

This can be explained, among other things, by the implementation of a policy of prioritizing investigations into high-level corruption.

The process of sending cases to court has also changed. The number of people in respect of whom indictments were prepared increased. In 2024, indictments were drawn up against 243 people (131 in the first half of the year and 112 in the second half), while in 2025 that number rose to 280 (154 in the first half and 126 in the second half).

In 2025, the largest number of SAPO indictments concerned:

• heads of other state agencies and state-owned companies—56 people. Among them were four defendants in the case about the embezzlement of funds from Ukrzaliznytsia; officials and their accomplices in the case concerning abuse at the Odesa Portside Plant; and officials charged in connection with laundering funds belonging to state-owned enterprises that were part of the Ukroboronprom concern.
• Members of Parliament and local councils, as well as other local senior officials—23 people. In 2025, cases sent to court included those against two former members of the Odesa Regional Council, who together with other accomplices seized 32 vessels, converted them into 12 barges, and unlawfully appropriated them. Also sent to court with an indictment was the case against MP Zadorozhnii, who, with the assistance of National Police officials, demanded a bribe in exchange for not obstructing infrastructure repair works in Sumy region. A former member of the Kharkiv Regional Council also became a defendant after allegedly organizing a criminal group whose actions in electricity sales during wartime caused losses of more than UAH 58 million to Ukrenergo.
• Law enforcement officials—26 people. Defendants in NABU and SAPO cases in this category included an ex-detective of the central office of the Bureau of Economic Security and a senior investigator of the Main Department of the National Police in Kyiv region for demanding an undue benefit of $150,000; the head of a sector within the SSU Department for the Protection of National Statehood and two other individuals exposed for demanding an undue benefit of $300,000; and a former head of a department of the Cherkasy Regional Prosecutor’s Office and a civilian who were exposed while receiving $41,000.

This trend shows that NABU and SAPO are not only opening more proceedings but are also more effectively bringing pretrial investigations to completion. This dispels the myth that NABU merely announces suspicions while the number of indictments remains low. Of course, once a person has been notified of suspicion, completing the pretrial investigation takes time, especially where mutual legal assistance measures are involved or suspects are being sought. 

Even so, for analytical purposes it would be appropriate for the statistics to include the average duration of pretrial investigations of criminal offenses, with a breakdown of the number of criminal proceedings in which the investigation has been suspended and an indication of the reasons for that, as well as the duration of the defense’s review of the case materials under Article 290 of the Criminal Procedure Code of Ukraine. At present, these aggregate indicators, which significantly affect the understanding of the timeline of top-level corruption cases, are unfortunately unavailable.

In addition, NABU’s statistics do not publish information on terminated criminal proceedings, including a breakdown showing whether these are cases with identified suspects or cases without suspects. That would make it possible to take a broader view of the pretrial investigation body’s work, including whether criminal proceedings remain pending there for long periods without notices of suspicion being issued.

It is also worth noting that Parliament still has not passed the changes that would strengthen NABU’s work and that international auditors have stressed are necessary. These include, in particular, abolishing the automatic closure of cases once investigation time limits expire, as well as resolving jurisdiction-related issues. This would allow the NABU and the SAPO to demonstrate an even higher level of effectiveness in investigating cases. In addition, unresolved issues remain with access to wiretapping without SSU involvement, as well as other matters affecting the efficient handling of state secrets and access to independent forensic examination.

The HACC’s effectiveness in court proceedings

The HACC’s annual report shows that its performance in court proceedings improved markedly across key indicators in 2024–2025: from the volume of cases reviewed to the speed of decision-making and the value of confiscated assets.

The HACC significantly increased the pace at which it completed criminal cases. In 2025, the court reviewed 114 cases (concerning 180 individuals), compared with 88 cases involving 137 individuals in 2024.

The number of judgments also rose, from 77 in 2024 (including 38 plea-based judgments) to 109 in 2025 (including 72 plea-based judgments). Overall, 154 individuals were convicted last year, substantially more than in 2024, when the figure was 112. We also see a decline in the number of acquittals, from 10 in 2024 to 8 in 2025. This, too, shows that most of the cases SAPO sends to court are built on a solid evidentiary foundation.

For example, in 2024 the HACC Appeals Chamber sentenced ex-MP Ruslan Solvar to three years in prison for unlawfully receiving compensation for housing rent. The HACC sentenced former SSU investigator Serhii Hlivinskyi to nine years in prison for soliciting and accepting a bribe, and MP Andrii Odarchenko also received his sentence—eight years in prison for attempting to bribe the former head of the State Agency for Recovery with bitcoin. 

Then, in 2025, the HACC sentenced ex-MP Dmytro Kriuchkov in absentia to 15 years in prison for embezzling more than UAH 1.5 billion from the companies Cherkasyoblenergo and Zaporizhzhiaoblenergo; former head of the State Judicial Administration Salnikov to three years for abuse of influence; and, finally, former head of the State Fiscal Service Roman Nasirov received his sentence—six years of imprisonment for abuse of office.

We also see a rise in the number of plea-based judgments. For example, in 2025, based on plea agreements, the HACC sentenced former head of the Western Economic Court of Appeal Borys Plotnytskyi to eight years of imprisonment, barred him from holding senior civil service positions for three years, and imposed a fine of UAH 85,000. Former Prosecutor General’s Office prosecutor Volodymyr Derhunov was sentenced to one year of actual imprisonment; in addition, he was banned from holding office for three years, and his residential house, together with a KIA Sportage, was confiscated. A plea agreement was also concluded with businessman Tyshchenko, a defendant in the case involving the embezzlement of the “Kurchenko oil products.” At the same time, for example, the texts of the judgments in the Plotnytskyi and Tyshchenko cases are sealed, and public communication on these cases does not make it possible to determine what exactly the state received in exchange for mitigating their punishment.

So although the increase in the number of cases reviewed is positive in itself, the growing number of plea-based judgments—especially when access to them is limited—may undermine trust in both the HACC and SAPO. In this regard, it would be advisable to use classification only for specific parts of a judgment and to improve SAPO’s communication regarding its policies on plea agreements in high-level corruption cases.

Despite the increase in the number of cases, the HACC managed to improve the efficiency of its use of time in court proceedings. While in 2024 one criminal case took an average of 618 days from receipt to final judgment, in 2025 that average fell to 405 days. This may have been aided, among other things, by the introduction of single-judge proceedings, as well as by the increased number of plea-based judgments, since such cases take significantly less time to review.

Even so, the number of unresolved proceedings is growing. While there were 287 such proceedings in 2024, involving 749 individuals, in 2025 there were already 327, involving 862 individuals. This shows the need for both legislative and organizational measures aimed at improving the efficiency of criminal case review. 

For example, in the course of monitoring HACC cases, we recorded instances of abuse and delay, including in the case involving the criminal organization at the District Administrative Court of Kyiv, in former State Fiscal Service head Roman Nasirov’s case within Onyshchenko’s “gas scheme,” and in the case of the so-called “king of smuggling,” Vadym Alperin. All of this could be addressed through amendments to the Criminal Procedure Code of Ukraine aimed at countering abuse of procedural rights.

Cassation review of HACC and HACC Appeals Chamber decisions by the Supreme Court also shows positive trends. In 2025, the cassation court reviewed a larger number of appeals filed by parties—164 in total, including 41 reviewed on the merits. By comparison, in 2024 there were 150 such appeals, and only 28 were reviewed on the merits. Overall, the number of HACC decisions left unchanged upon review also increased: in 2025, there were 27 such decisions, or 65.9% of those reviewed on the merits, whereas in 2024 there were 16, or 57%.

It is also encouraging that the court’s effectiveness in asset recovery improved in 2025. Last year, the total value of assets subject to special confiscation exceeded UAH 673 million across 13 proceedings. By comparison, in 2024 this figure stood at UAH 158.8 million in 11 proceedings. Meanwhile, the value of confiscated assets in money laundering cases increased almost tenfold—from UAH 50.6 million in 2024 across 4 judgments to UAH 470.3 million in 2025 across 7 judgments.

Even so, the HACC’s and NABU’s reports contain no information on the enforcement of asset confiscation decisions, which means it is impossible to track how much of this money has actually reached the state budget. Still, if provided by other state bodies, this information could be highly illustrative from the standpoint of public communication quality.

***

The effectiveness of NABU, SAPO, and the HACC is no longer just about the figures in their reports. These are already indicators that stakeholders in Ukraine and abroad look to. 

Indeed, the visible uptick in these institutions’ work was the main reason Ukraine’s score in the 2025 Corruption Perceptions Index improved by 1 point. In that study, the Bertelsmann Foundation gave Ukraine 5 points, primarily taking into account the extent to which officials who abuse their office are held accountable or punished. And the figures above speak directly to that. The Corruption Perceptions Index is an international study that takes into account a whole range of factors affecting the state of anti-corruption efforts.

So the increase in the number of notices of suspicion issued to top officials, indictments, and judgments is a positive trend not only for the work of NABU, SAPO, and the HACC, but for the entire field overall. At the same time, real trust in the anti-corruption system requires more than just bigger numbers. It also requires transparency: publishing more aggregated information, opening up plea-based judgments to the extent possible, and reporting on the actual enforcement of confiscation decisions. 

We have no doubt that NABU, SAPO, and the HACC are indeed working, but systemic work also means addressing the shortcomings that still exist. That is what will determine whether quantitative growth in the indicators turns into a qualitative result.

Open Letter to the Verkhovna Rada of Ukraine Regarding the Termination of the Unlawful Actions of the Temporary Investigative Commission on Investigating Corruption in Law Enforcement Agencies, Courts, and Judicial Authorities 

On June 19, 2025, the Parliament established the Temporary Investigative Commission of the Verkhovna Rada of Ukraine to investigate possible facts of corruption or corruption-related offenses in law enforcement agencies, courts, and bodies of judicial governance (the TIC), chaired by Members of Parliament Serhii Vlasenko and Maksym Buzhanskyi.

Despite its declared purpose, the TIC threatens the independence of anti-corruption bodies and judicial authorities. In particular, the TIC committed the following violations:

• reviewed the activities of the HCJ, the HQCJ, and the PIC, although the Parliament did not assign it this task in Article 1(2)(1) of the resolution establishing the TIC;
• attempted to compel the appearance of HQCJ member Serhii Chumak, despite the fact that Article 49(3) of the Law of Ukraine on the Judiciary and the Status of Judges prohibits compulsory appearance for judges; 
• established an expert group not provided by law, the members of which bear no personal liability for knowingly false findings.

 

The following institutions have already stated that the TIC exceeded its mandate and is being used as an instrument of pressure on anti-corruption bodies and interference with the independence of the judiciary: the National Anti-Corruption Bureau of Ukraine (NABU), the Specialized Anti-Corruption Prosecutor’s Office (SAPO), the High Anti-Corruption Court (HACC), the High Council of Justice (HCJ), the High Qualification Commission of Judges of Ukraine (HQCJ), and the Public Integrity Council (PIC).

In its 2025 report on Ukraine, the European Commission noted that the TIC “should not erode public trust in anticorruption institutions through unwarranted public statements nor overstep the limitations stemming from the separation of powers.”

In its opinion, the Parliamentary Rules Committee stated that the TIC submitted its activity report without complying with the requirements of Article 21 of the Law of Ukraine on Temporary Investigative Commissions and Temporary Special Commissions of the Verkhovna Rada of Ukraine—the deadline for the TIC’s next report is missing; there is no information on voting on each established circumstance; and the report contains no proposals. Despite the fact that the Parliament did not consider the TIC’s report and did not instruct it to continue its work, the TIC approved a plan for the coming months and is planning meetings.

The actions of the Members of Parliament on the TIC discredit parliamentary oversight, have nothing to do with a genuine fight against corruption, and create risks for fulfilling Ukraine’s commitments to the EU.

In light of these facts, we demand that the Verkhovna Rada of Ukraine:

1. Immediately include on the agenda of the next plenary session the issue of hearing the TIC’s report, conclusions, and proposals.
2. Following consideration of the TIC’s report, adopt a decision to terminate the TIC’s mandate.

Civil society organizations:

• DEJURE Foundation
• ZMINA Human Rights Center 
• CHESNO movement
• Center for Economic Strategy
• Bihus.Info
• StateWatch
• Human Rights Group SICH
• Detector Media
• Transparency International Ukraine
• Center for Civil Liberties

What needs to change in corruption investigations

In its report, the European Commission noted an increase in the number of indictments in NABU cases. This has clearly caused concern among certain representatives of the Ukrainian authorities who, instead of fulfilling Ukraine’s international commitments to enhance the capacity for effective investigations, are promoting harmful legislative initiatives designed to undermine the effectiveness of the NABU and the SAPO. This refers to the events of July 21–22, 2025, when Parliament, in fast-track mode, adopted, and the President signed, a law that restricted the independence of the anti-corruption bodies.

Although most of its provisions harmful to the Bureau and the anti-corruption prosecutor’s office were later repealed by another law, some Members of Parliament have not abandoned these efforts. Disregarding the warnings of EU commissioners and the clearly articulated demand of society, they continue to insert into various draft laws provisions that would allow influential suspects to evade criminal liability or even establish the lawfulness of their actions. For example, where they acted based on explanations issued by certain state bodies, as proposed in Draft Law No. 12439. The European Commission explicitly referenced such legislative initiatives in its report. 

At the same time, the authorities largely ignore recommendations that would genuinely improve NABU’s operational effectiveness. These include granting the Bureau the ability to conduct wiretapping autonomously (without involvement of the Security Service of Ukraine). For interested parties, it is extremely convenient to know in advance whose communications NABU intends to intercept, making it possible to warn “their” person ahead of time. 

Court examinations also remain a systemic problem. Corruption cases often have an economic dimension — they involve the proper valuation of works performed under state contracts or the determination of the amount of damage caused. Overburdened expert institutions, pressure on experts, or their bribery negatively affect both the quality and speed of evidence collection in corruption cases.

The European Commission also noted that the possibility of closing cases due to the expiry of pre-trial investigation time limits has still not been abolished. This provision allows suspects to avoid criminal prosecution simply because an indictment was submitted to the court with a delay of two or three days. The NABU cases were most often closed on this ground due to confusion stemming from shifting positions of the Supreme Court — when judges could not agree on which authority was responsible for extending investigation time limits or on how such time limits should be calculated.

The Commission further noted a decline in the number of corruption indictments initiated by the National Police and the State Bureau of Investigation. This alarming trend was also highlighted in our Shadow Report. It indicates a substantial decrease in the number of mid- and low-level corruption investigations that successfully reach the courts. Addressing this issue requires strengthening the analytical capacity of the Prosecutor General’s Office, which should analyze the reasons for case closures, assess the lawfulness of investigations, and determine whether corruption factors influenced the final decisions. 

The NABU also received specific “homework” from the European Commission. The audit report published in May 2025 contains a number of recommendations aimed at strengthening the Bureau’s performance. In particular, European partners emphasized the need to improve the effectiveness of internal control management and to enhance safeguards against the unlawful disclosure of pre-trial investigation information. The latter recommendation is clearly relevant not only for the NABU but also for the SAPO.

Fair adjudication within a reasonable time

Completion of the investigation and transfer of a case with an indictment to the HACC is by no means the end of criminal prosecution. The case must still be examined with full respect for procedural guarantees, without abuse of those guarantees, and within a reasonable time.

In some cases, this becomes an exceptionally difficult task, with which, regrettably, the HACC cannot always cope. The number of cases closed due to the expiry of limitation periods is increasing, and not primarily because of flaws within HACC itself. 

The tactic of deliberate delay is usually chosen by those suspects who see the approaching prospect of release from criminal liability and therefore use every possible procedural opportunity to prolong the proceedings until the case is closed. This includes unfounded recusals, marathon speeches lasting up to 40 hours during debates and final statements, repeated failures of participants to appear, holidays, sick leave, and hours-long deliberations over matters that are clear. In some instances, such cases had no real chance of being considered at all — they were referred to the HACC with only a few months remaining before the expiration of limitation periods.

For this reason, the European Commission devoted considerable attention to improving the statute of limitations framework and counteracting procedural delays — in other words, combating abuse of procedural rights. In addition, the report expresses expectations regarding HACC itself, which should develop a strategy to ensure the effectiveness of judicial proceedings. On November 28, the HACC published the corresponding strategy.

It is also important not to lose sight of the ongoing competition to fill 23 vacant judicial positions at the HACC. It is crucial that this process take place with the participation of the Public Council of International Experts, which together with the High Qualification Commission of Judges must ensure the selection of professional and ethically sound candidates. 

Without a high-quality selection of judges, it will be impossible to improve the effectiveness of adjudicating top-level corruption cases. However, this appears to run counter to the intentions of certain Members of Parliament, who have established a Temporary Investigative Commission whose activities have prompted serious concerns from the European Commission regarding respect for the balance between branches of power. In our view, these concerns are fully justified — the Commission’s representatives have taken decisions that indicate serious interference in the functioning of the judiciary.

What usually escapes broader public attention is how HACC verdicts are actually enforced. The European Commission did not focus on this issue separately in its report but did note general problems with the enforcement of court decisions across the board. We, in turn, recall that Ukraine still lacks a proper data collection system on the enforcement of HACC sentences. This makes it impossible to assess the real state of implementation of verdicts, including the confiscation of assets from convicted persons and the enforcement of other penalties.

Incidentally, the European Commission quite rightly drew attention to asset confiscation, more precisely, to the insufficient number of such cases. It pointed out that current legislation lacks mechanisms for seizure in the context of extended confiscation and that the grounds for applying special confiscation need to be improved. This fully aligns with the recommendations of our research, the implementation of which would prevent all kinds of ‘Midas figures’ from retaining their illicit wealth.

***

As we can see, the European Commission has formulated specific requirements that Ukraine must fulfill in order to continue moving toward the EU. In essence, this is a list of systemic problems that have for years been blocking the effective fight against corruption and now require urgent resolution.

Ukraine has already covered a significant part of the path toward the EU. Specialized anti-corruption institutions have been established, many necessary laws have been adopted, and there have been convictions in high-profile cases. However, the moment has now come when Europe is no longer looking at the mere creation of institutions but at their real effectiveness. 

Recent investigations by the NABU and the SAPO give hope that both the level of such effectiveness and public awareness of it will continue to grow. At the same time, the efforts by certain representatives of the authorities to suppress the independence of anti-corruption bodies and the regular obstruction of their work indicate that these institutions are becoming increasingly dangerous for the most entrenched and institutionalized corruption. 

Yet the creation of NABU, SAPO, and HACC is not a clause in international agreements — it is a response to a clear demand from Ukrainian society after the Revolution of Dignity. That is why further strengthening their capacities and preserving best practices will make it possible to ensure the inevitability of criminal liability for those who, at a time of existential threat to the very existence of the Ukrainian state, continue to devise new schemes. So that no one will any longer question whether protective structures should be built for electricity generation facilities, or how financial flows should be structured so that law enforcement cannot reach them. Because they will reach them anyway.

Investigations and suspicions are good things

The first point worth emphasizing is that the investigation (and its expected outcomes) is definitely positive. Despite the scandal and intense media attention, including internationally, the key takeaway is that the scheme will stop, and the money will no longer be stolen. This is precisely why we fought to safeguard the independence of the NABU and the SAPO this summer. 

Of course, beyond the investigation and suspicion notices, we expect concrete verdicts and accountability for those involved. That will not happen overnight. We live in a rule-of-law state, where pre-trial investigations and court proceedings must run their course. But accountability for corruption is essential and expected.

The Government’s response

The President initially voiced only general support for the investigation and the need to hold the guilty accountable. Two days later, he finally called for the dismissal of the ministers named in the case and spoke of sanctions against the suspects. These were minimal steps — and delayed ones. The Government first suspended only the Justice Minister, Herman Halushchenko, and sent the State Audit Service to inspect Energoatom’s procurement transactions, mentioned in the investigation. This clearly looked like an attempt to shield “close friends and family.” 

As for the State Audit Service’s inspections, we doubt auditors can do much. They can verify whether the physical state of the construction sites matches the paperwork — whether what was declared was actually built. That may assist investigators. But auditors have no authority to trace or confirm kickbacks. They cannot even formally identify overpayments. Their role is limited to ensuring procurement procedures comply with the law.

Are procurement rules to blame?

A natural first reaction is to assume the problem lies in procurement itself. The leaked recordings reference procurement of protective structures for energy facilities. They are allowed to bypass Prozorro and be made directly — a wartime exception introduced to speed up the fortification of critical infrastructure. Yet, according to the recordings, the criminal organization actively slowed construction to extract kickbacks.

Still, an identical scheme could have worked through competitive tenders. Prozorro is not an anti-corruption system. It is an e-procurement platform that makes procurement more efficient and transparent. Transparency, in turn, means a higher chance of spotting corruption. But what we typically see are indirect signs: discriminatory conditions, inflated prices concealing margins for kickbacks. Criminal organizations, unfortunately, do not send their kickbacks through the e-procurement system.

Would there have been a greater chance of spotting the problem if these procurements had gone through Prozorro? Yes. Would it have allowed us to detect kickbacks with certainty? No. 

System and people 

Corruption arises where imperfect systems meet individuals willing to exploit them. There are no perfect systems, no matter how detailed or well-designed the rules. Rules cannot absolve people of responsibility. Ultimately, decisions are made by specific individuals.

To reduce these risks, meritocracy must guide appointments to public office. People should receive positions because of their qualifications and achievements, especially in managerial roles. Unfortunately, what we see now more closely resembles nepotism. 

We must accept that the war will not end soon and stop using it as an excuse to avoid necessary decisions. Leadership positions in state institutions should be filled through open competitions, not direct appointments. We see the results of this approach in the NABU and the SAPO — institutions that have demonstrated capacity largely because their leadership was selected through transparent competitions. The same competitive approach should be used to choose heads of state-owned enterprises and oversight bodies like the State Audit Service and the Accounting Chamber. And these competitions must be not only open, but rigorous, with realistic criteria and proper assessment of qualifications and skills. 

These positions must also come with competitive market level salaries. Otherwise, attracting qualified professionals will remain impossible. A senior public-sector position is a job comparable to management roles in the private sector — only with higher responsibility and risk. It must be compensated accordingly.

Most government positions, however, are still filled by direct appointment, and public-sector pay remains far below market standards. This must change.

Ministerial appointments, of course, are inherently political; open competitions cannot apply. But we must recognize that “moving the deckchairs” is not a real government reset in critical moments. The responsibility for appointing capable, ethical ministers lies with the Parliament — and indirectly with the Prime Minister and the President. This choice, too, must be rooted in meritocracy, not personal loyalty. 

Uncovering corruption is only the first step

The exposure of the Energoatom kickback scheme unleashed a torrent of emotions. The story dominates media and social networks, with headlines appearing in international outlets.

But once the emotions recede, we must think clearly about what this actually means — and what must happen next. 

Yes, the first steps after exposing corruption are investigations, suspicion notices, convictions, and accountability. But such cases always point to the need for systemic change. The “eggs for 17” scandal brought about defense procurement reform. Was that reform perfect? No. Did it improve the situation? Absolutely. 

This scandal should be seen as a signal: we can no longer tolerate nepotism. Public service, especially in key leadership positions, requires political and economic independence. Without it, efficiency is impossible. 

Should this investigation prompt reconsideration of the wartime exceptions that allow direct procurement of protective structures for critical infrastructure? Or do national-security considerations still justify them?

Could stronger internal or external oversight have prevented the scheme? We are left with many questions that require serious, deliberate reflection.

The case of Ruslan Mahamedrasulov: were there ties to Russia?

Ruslan Mahamedrasulov served as Head of NABU’s Interregional Directorate of Detectives based in Dnipro. He was detained by the Prosecutor General’s Office and the Security Service of Ukraine on suspicion of aiding the aggressor state under Article 111-2 of the Criminal Code of Ukraine. This article establishes criminal liability for intentional actions aimed at assisting the aggressor state in causing harm to Ukraine, either through support for enemy decisions or the transfer of material resources.

The charges are based on claims that Mahamedrasulov allegedly acted as an intermediary in selling technical hemp to the Republic of Dagestan, while the illicit cultivation of this crop was allegedly organized by his father, a private entrepreneur. The prosecution asserts that by facilitating this trade with Russia, the senior NABU official assisted his father in unlawful activity and caused harm to Ukraine. However, the public record lacks details on how exactly such harm is substantiated or whether the alleged hemp sales could indeed qualify as aiding the aggressor state.

What we did see is that law enforcement focused heavily on the NABU official’s family background. The SSU publicized information unrelated to the essence of the suspicion — such as his parents’ citizenship, sources of their income, and his vacation destinations — clearly aimed at eliciting an emotional reaction from the audience.

Evidently, these details were intended to shape a strong emotional perception of NABU detectives as deeply entangled in Russian connections and indifferent to the realities of war in Ukraine, holidaying abroad instead — a tactic that closely resembles manipulation.

The Mahamedrasulov case also raised serious concerns about the quality of the evidence base. Civil society experts have already analyzed discrepancies in the materials released by the SSU. Attention was drawn to the apparent confusion between Dagestan and Uzbekistan in relation to a state program supporting hemp cultivation. In fact, such a program exists in Uzbekistan, not in Russia’s Dagestan. 

As “evidence,” the SSU cited a Russian government resolution providing subsidies only for crops grown on Russian territory and listed in the state register, without any mention of imported products. The Dagestan government’s own resolution makes no reference to hemp as an eligible subsidized crop. Moreover, procurement from abroad could not have been justified under that decree: by the time the alleged “correspondence” began — on July 10, the same day the SSU claims the exchange took place — the application deadline for subsidies had already expired. That correspondence also referenced Agroprime, which has been under criminal investigation in Russia since 2023 for unlawfully obtaining a 22.2-million-ruble subsidy. No firm under investigation could, even in theory, qualify for a subsidy in Dagestan.

Despite all these inconsistencies, on July 22, 2025, the Pechersk District Court ordered Mahamedrasulov into pretrial detention without the option of bail until September 16, 2025, later extended to October 21.

The key issue in the Mahamedrasulov case remains the discrepancy between the seriousness of the charges and the quality of the evidence presented. The SSU relied on selective and emotionally charged communication, emphasizing the detective’s family background — from his father’s citizenship to his vacation in Tenerife — which unmistakably suggests an attempt to create an emotional image of collaboration with the enemy. At the same time, there appear to be critical gaps in the evidence base, ranging from confusion over foreign subsidy programs to the use of information about a company already under investigation for financial violations.

What does the connection to MP Fedir Khrystenko have to do with it?

A central element in how the SSU and the PGO communicated about the Mahamedrasulov case was his alleged connection to MP Fedir Khrystenko, formerly of the now-banned Opposition Platform – For Life party. On July 20, the day before the NABU searches, the SSU and PGO charged Khrystenko in absentia with high treason, claiming that he was a resident (senior agent) of Russia’s FSB and worked to strengthen Russian influence within the NABU.

According to the investigation, the FSB recruited Khrystenko during the presidency of Viktor Yanukovych, and the MP actively carried out tasks assigned by the Russian intelligence service during the Revolution of Dignity. Following the full-scale invasion, he fled abroad and continued his unlawful activities from there. 

The SSU alleges that Khrystenko had known Mahamedrasulov since their time studying together at Donetsk University. The SSU also disclosed details of supposed links between the two. Additional investigative materials allegedly showed that Mahamedrasulov’s father corresponded with Khrystenko, and in one exchange, they agreed to meet in the European Union. Moreover, in that correspondence, Khrystenko supposedly wrote to the father that he could not reach Mahamedrasulov Jr. (using only the first initial for secrecy) and asked for help in establishing contact.

Interestingly, the official communication contains no explanation of how Khrystenko actually exerted influence on the NABU, raising questions about whether the SSU and PGO truly possess a sufficient evidentiary base to substantiate the criminal charges against the MP.

Khrystenko himself was detained in Ukraine on September 6, 2025, and placed in pre-trial detention. However, he was not returned under a formal extradition procedure, but through political arrangements with the authorities of the country where he had been staying.

Communication surrounding Khrystenko’s suspicion included further examples of manipulation. The PGO released information about his alleged contacts with other NABU officials, explicitly naming them. At the same time, authorities circulated claims that NABU detectives had helped oligarch Hennadii Boholiubov cross the border. 

These claims were based on the fact that the wife of Oleksandr Skomarov, head of a NABU detective unit, left Ukraine in 2022 in a car registered to the family of fugitive MP Khrystenko. However, Skomarov explained to Ukrainska Pravda that on February 25, 2022, he obtained official permission from his management to evacuate his wife and their two-year-old child to the western border. There, he met an elderly man (over 60) who transported vehicles abroad for payment and agreed to take his family. On February 26, from the town of Berehove, Skomarov’s family was taken out of Ukraine. It appears most likely that this man was transporting Khrystenko’s vehicle and agreed to take passengers for an additional fee.

This leads to the question: if the SSU and PGO were confident enough of Skomarov’s ties to Khrystenko to mention him publicly, why was he not formally notified of suspicion of any crime?

Another “information dump” by law enforcement claimed that detectives under Skomarov’s supervision had, at Khrystenko’s request, helped Hennadii Boholiubov cross the border. Specifically, it was alleged that two NABU employees accompanied the fugitive oligarch on a train during his escape. 

The NABU, however, explained in its official communication that the detectives were in fact on a work assignment at the invitation of the Stolen Asset Recovery Initiative (StAR) — a joint program of the World Bank and the UN Office on Drugs and Crime. The trip had been official, approved in advance, and undertaken to participate in a series of bilateral meetings at the Global Forum on Asset Recovery held in Vienna on June 25–27. It was purely coincidental that Boholiubov happened to be in the same train car.

The alleged connection between oligarch Ihor Kolomoiskyi and Oleksandr Skomarov, supposedly regarding the “resolution” of Kolomoiskyi’s criminal cases if Skomarov were to win a position at the ESBU, also appears extremely tenuous. This conclusion was drawn from a screenshot containing Kolomoiskyi’s remark: “Looks like there will be a second NABU.” How law enforcement interpreted this phrase in such a way is unclear. It appears they sought to use a single piece of information to plug multiple holes in the government’s problems at the time.

Thus, this case also lacks sufficient detail to assess the validity of the accusations but certainly not a shortage of manipulative communication tactics from the SSU, which is, of course, deeply concerning.

Suspicion of trading in influence

On September 16, the Prosecutor General’s Office announced that Ruslan Mahamedrasulov had been served an amended notice of suspicion. According to the investigation, the NABU official accepted an offer of unlawful benefit for himself and third parties in exchange for influencing decisions made by public officials — an offense under Article 369-2(2) of the Criminal Code of Ukraine.

Investigators allegedly discovered this information on the suspect’s phone. He had reportedly received an offer from one of his contacts to help resolve tax-related issues for several Ukrainian companies. The matter involved illegal decisions by the State Tax Service to remove about ten companies from its list of “risky” entities, allowing them to conduct financial transactions worth around UAH 30 million. The PGO stated that analysis of the companies’ activities indicated signs of affiliation with a “conversion center.” The cost of such “services” was reportedly UAH 900,000, roughly 3% of the total amount of blocked funds. 

According to investigators, the NABU officer accepted this offer and attempted to resolve the issue through a former high-ranking tax official, at a time when the current Prosecutor General, Ruslan Kravchenko, headed the State Tax Service. Mahamedrasulov also allegedly sought assistance from a former law enforcement colleague with whom he had previously worked at the NABU. During interrogations, the individuals in question confirmed that the NABU official had indeed contacted them with such a request.

It is important to note that as of the date the suspicion was served to Mahamedrasulov, investigators were only considering whether to charge the individual who had offered him the bribe, and there is no public record confirming that such a notice of suspicion has been served to that person. Nevertheless, the media reported that the individual who corresponded with Mahamedrasulov during the time Kravchenko led the Tax Service is currently listed as an assistant to the Prosecutor General.

Following an analysis of the published information, questions remain as to whether the investigators truly possess all the evidence required to prove the alleged offense. The available data do not demonstrate that the NABU official accepted a proposal to influence anyone for unlawful gain, nor is it clear which specific official Mahamedrasulov was allegedly supposed to influence, according to the PGO’s version.

The case of Viktor Husarov

Viktor Husarov worked in the “D-2” unit of NABU’s Central Office. He was detained by the PGO and the SSU on suspicion of high treason and unauthorized actions with information.

According to investigators, Husarov committed more than 60 episodes of transmitting restricted information to Dmytro Ivantsov, a former deputy head of Yanukovych’s security. The SSU claims that in February 2014 Ivantsov helped the fugitive president escape to Russia, after which he stayed in Crimea and joined the occupying forces.

The SSU further alleged that Husarov was part of a large enemy agent network run by FSB officer Igor Yegorov. This network allegedly also included SSU Major General Valerii Shaitanov (convicted in 2020 and sentenced to 12 years in prison) and a serviceman of the National Guard.

A particular feature of Husarov’s case is that his cooperation with Ivantsov allegedly began as early as 2012, when he worked at the Ministry of Internal Affairs, not at the NABU. Publicly available information contains no indication that this cooperation continued during his employment at the NABU. 

The NABU, for its part, presented a version of events that differs from that of the SSU. According to the Bureau’s leadership, in August 2023 it received information from the SSU about possible risks associated with Husarov. The claim was that during his service at the MIA (2012–2015), he had emailed information about Ukrainian citizens to a staff member of the State Guard Directorate. The NABU immediately became involved in clarifying the circumstances and organized an additional check together with NABU officers and SSU unit heads. However, during this joint inspection, no evidence was found to suggest that Husarov was aware of the State Guard official’s ties to Russian intelligence services. This was confirmed by an SSU representative during in-person meetings.

The NABU also initiated an interview of the employee, but the SSU strongly recommended refraining from any action so as not to interfere with operational work. The special service further mentioned that the identified connections did not concern the NABU employee, and no contacts between them had been recorded.

On August 1, 2024, a search was conducted at Husarov’s residence on the basis of a court order, after which he was summoned for questioning. In August 2024, the SSU orally informed the NABU that during the investigation of the high treason case, no evidence of the NABU employee’s involvement had been found, and no proof of participation in anti-state activities existed.

Since then, the NABU has repeatedly requested documentary confirmation of the check results from the SSU but has received no official response.

Husarov’s defense lawyer stated in court that her client had indeed transmitted data in 2015 but believed that Ivantsov was still employed at the State Guard and did not know about his flight to Crimea or his cooperation with the Russians. She also reported that during Husarov’s detention on July 21, SSU officers beat him to force disclosure of his phone password.

On July 22, the Shevchenkivskyi District Court ordered Husarov to be held in custody for 60 days without bail. On September 8, the appellate court upheld the decision.

For us, the Husarov case raises the greatest number of questions concerning the motivation for his detention specifically in July 2025. If the SSU had information about his contacts with Ivantsov since 2023, conducted checks in 2024, and even orally informed the NABU that no evidence of anti-state activity existed, then why was the arrest carried out precisely on the eve of the parliamentary vote on dismantling NABU’s independence? The defense’s claim that Husarov was unaware of Ivantsov’s shift to the Russian side, along with reports of beatings during his detention, add further doubts regarding the legality of the procedural actions.

The case of false asset declaration

On September 10, 2025, the SSU announced that it had exposed NABU detective Vitalii Tiebiekin for false asset declaration (Article 366-2(1) of the Criminal Code of Ukraine). He was accused of attempting to conceal the purchase of a two-room apartment in Uzhhorod worth $100,000. According to the SSU, the detective allegedly registered the property under the name of his close acquaintance’s mother. Despite the family residing in the apartment, Tiebiekin failed to declare the property in his 2023 asset declaration and, in his 2024 declaration, listed it as rented. However, investigators reportedly obtained evidence showing that the individual registered as the owner did not receive any payment for its use.

Interestingly, although the overall tone of SSU statements on this case was rather restrained (in stark contrast to the earlier, more aggressive communication in previous cases), the agency still decided to add that the detective’s parents hold Russian passports and live in temporarily occupied territory — information that Tiebiekin allegedly failed to disclose when applying for security clearance to access state secrets, thereby violating the law.

By doing so, the SSU continued to shape a narrative of NABU’s alleged “pro-Russian infiltration.” Moreover, its actions undermine the understanding of forced passportization as a violation of international humanitarian law, and cast doubt on the Russian Federation’s deliberate policy of creating conditions that discriminate against residents who refuse Russian citizenship, depriving them of basic rights and services.

Another concerning element is the prosecutor’s request for bail in the amount of over UAH 4 million and a personal recognizance for the suspect to report any change of residence and to appear when summoned by the prosecutor. Ultimately, the court imposed bail of over UAH 2.9 million and placed additional procedural obligations on the NABU detective. Yet the Criminal Procedure Code of Ukraine clearly sets the maximum bail for non-serious crimes at 20 subsistence minimums for employable persons — just over UAH 60,000. A higher amount cannot legally be applied because the alleged offense is neither serious nor especially serious. The HACC, for example, routinely imposes bail consistent with this standard for similar cases.

Road traffic accident cases

In parallel with the detentions over the alleged “Russian trace,” the State Bureau of Investigations announced suspicions against NABU employees in cases related to road traffic accidents that resulted in injuries to victims.

All three accidents occurred earlier — two in 2021 and one in 2023. The first accident took place in Kyiv when a law enforcement officer, exiting from a secondary road, collided with a vehicle traveling on the main road. The second accident occurred at the 61st kilometer of the Kyiv–Odesa highway, where an officer, while overtaking another vehicle, failed to maintain a safe speed, veered off the road, and overturned the car, which subsequently hit a gas station building. The third accident involved an officer driving a service vehicle at a regulated intersection in Kyiv; he struck a pedestrian crossing the road on a green light. The pedestrian sustained injuries classified as moderate.

The NABU made public its position on these cases. In each incident, the employees immediately provided first aid to the victims, called an ambulance and the police, and reported the incidents to the relevant authorities. These actions were properly recorded and confirmed by the findings of NABU’s Internal Control Department.

The employees did not use their official positions for personal advantage, nor did they attempt to avoid liability. On the contrary, they fully cooperated in establishing the circumstances of the incidents. One of the detectives even provided financial assistance to a victim for medical treatment.

The NABU expressed surprise at the decision to conduct mass searches over events that occurred several years ago, as well as the initiation of motions for interim measures in the form of unconditional detention. At the same time, the SBI filed motions to suspend all three employees from their positions, despite the absence of risks of interference in the investigation.

On July 22, the court imposed interim measures on all three suspects. The first detective was suspended from duty until September 21 and ordered to notify authorities of any change of residence and not to leave Kyiv. The second was placed under personal obligations for 60 days and also suspended from work. The third was placed under nighttime house arrest for 60 days.

Particularly puzzling is the suspension from duty of these NABU detectives. Such an interim measure requires establishing circumstances that justify the belief that the suspect’s continued service contributed to the commission of the crime, or that while in office, the suspect might destroy or falsify evidence, unlawfully influence witnesses or other participants in the proceedings, or otherwise obstruct the investigation. Based on the publicly available facts, it is unclear how such risks could have been proved.

Thus, the road accident cases raise questions about the proportionality of the measures applied and their synchronization with other proceedings against the NABU. The suspension of detectives over traffic accidents is especially questionable, since the law requires substantiated grounds showing that remaining in office contributed to the crime or poses risks to the investigation.

Instead of conclusions: questions that require answers

An analysis of the events of July 21, 2025, and the subsequent investigation into NABU employees raises a series of fundamental questions that concern not only these specific cases but also the overall adherence to the rule of law in Ukraine.

Why did all actions by different law enforcement bodies take place simultaneously on the same day, just before the parliamentary vote on dismantling the independence of the NABU and the SAPO? Why did cases of entirely different jurisdiction — from traffic accidents to high treason — advance at the same time? Why were searches conducted without court warrants, and why were appellate reviews delayed?

Particular concern arises over the quality of the evidence base in cases qualified as treason and aiding the aggressor. In Mahamedrasulov’s case, analysis revealed inconsistencies regarding an apparent confusion of countries in relation to subsidy programs. In Husarov’s case, the SSU initially informed the NABU that no evidence of anti-state activity had been found, but a year later suddenly detained the employee without providing further documentary confirmation.

Why did law enforcement communication rely so heavily on manipulative tactics — from emphasizing family ties to unlawfully disclosing the names of suspects? Why was the evacuation of a detective’s family in February 2022 interpreted as a “connection with a Russian agent,” and why was an oligarch’s remark “looks like there will be a second NABU” presented as an attempt to “settle criminal cases”?

Any criminal proceedings, regardless of the seriousness of the charges, must be conducted in strict compliance with the rule of law, the presumption of innocence, and procedural guarantees. However, the published facts, including reports of beatings during detentions, excessive pre-trial measures in traffic accident and false declaration cases, the coordinated actions of multiple law enforcement bodies, and public communication that undermines the presumption of innocence, point to systemic violations.

These circumstances suggest that the criminal prosecutions of NABU employees have become one of the key elements in attempts to dismantle independent anti-corruption institutions. The synchronization with the parliamentary vote, the scale of the operation, and the nature of the communication all indicate a political motivation behind these actions.

If, however, genuine evidence emerges proving that employees of anti-corruption bodies acted in the interests of the aggressor state, such matters must be resolved within the framework of existing disciplinary and criminal procedures in full compliance with procedural guarantees.