I. STRATEGIC DOCUMENTS
Anti-Corruption Strategy and Action Plan
Does the country have a comprehensive anti-corruption strategy and a multi-annual action plan resulting from a wide consultation, including civil society and relevant stakeholders?
MEZHA has been actively involved in monitoring the implementation of the provisions of the Anti-Corruption Strategy for 2021-2025 and the State Anti-Corruption Program for 2023-2025 in the areas of combating corruption and developing Ukraine’s law enforcement, as well as national security institutions.
As of today, according to the information system for monitoring the implementation of the State Anti-Corruption Programme, only 53% of measures have been fully implemented, while 47% have been only partially implemented or not implemented at all. These gaps require further inclusion in the new Anti-Corruption Strategy and the State Anti-Corruption Programme for 2026–2030.
Currently, Ukraine is in the process of developing a new Anti-Corruption Strategy. The Anti-Corruption Strategy for 2026–2030 has not yet been adopted, and the draft law has not even been registered in the Verkhovna Rada of Ukraine.
On 31 December 2025, the Government extended the Anti-Corruption Strategy for 2021-2025 and its implementation programme until a new strategy is adopted, because the process of adopting the new Strategy has been delayed.
The process of developing the Anti-Corruption Strategy is characterized by open participation of all stakeholders and the expert community.
MEZHA also contributed to the development of the Strategy by preparing its own research on the political dependence of the National Police on the Ministry of Internal Affairs and the lack of transparency in the appointment of its leadership. The National Agency on Corruption Prevention (NACP) acknowledged these problems and included measures to address them in the Anti-Corruption Strategy.
Are activities and timelines realistic? Are responsible actors/bodies identified? Is there a budget set aside for the implementation? Are there any result or impact indicators?
MEZHA has been constantly monitoring the process of implementation of the State Anti-Corruption Program for 2023-2025 in the defence sector (see our latest report here). Only 33% of the measures were fully implemented. The low implementation rate of the Program measures was due to several planning, legislative, and political challenges, including:
- unclear or poorly designed measures and mismatched implementing bodies;
- weak coordination among co-implementers;
- lack of funding for certain measures;
- and security risks related to the ongoing armed aggression of russia.
Based on these challenges and the experience of Program implementation over the past three years, we recommended that the new Anti-Corruption Program: carry over unfulfilled and partially fulfilled measures; clearly assign lead implementers in line with their mandates; limit the number of responsible actors to avoid diluted accountability; take into account martial law and related security constraints; and, where possible, seek international technical assistance to ensure adequate funding.
There are already several signs that the Adoption of the Anti-Corruption Strategy for 2026–2030 faces obstacles.
In accordance with the requirements of the Ukraine Facility, Ukraine is required to adopt and publish the Anti-Corruption Strategy and the State Anti-Corruption Programme by the end of the second quarter of 2026.
However, the draft law on the adoption of the Anti-Corruption Strategy is still not available, as by the end of the first quarter of 2026, ministries are still reviewing and coordinating the provisions of the draft Anti-Corruption Strategy for 2026–2030.
Moreover, key ministries have raised objections regarding the content of the Strategy’s measures and identified problems, which could lead to a blockage of its adoption:
- The Ministry of Internal Affairs opposes merit-based selection for senior police leadership positions;
- The Ministry of Finance emphasizes the lack of funds for further institutional strengthening of the NABU;
- The Ministry of Justice proposes to exclude from the Strategy issues related to strengthening NABU and the SAPO.
There is still a risk that even if we assess the draft text positively at this stage, it may still be weakened or altered at the government committee level. Thus, further progress in adopting the Anti-Corruption Strategy depends on the political will of the Cabinet of Ministers of Ukraine as well as the Verkhovna Rada of Ukraine, which is currently in crisis and not passing key legislation.
Are there dedicated activities and/or policy/sectorial action plans for areas particularly at risk of corrupt practices e.g. public procurement 10, privatisation, large budgetary expenditure, construction, land-use planning, health, education, police, customs, justice, taxation, local administration, financing of political parties.
The draft Anti-Corruption Strategy is being aligned with the overall framework of reforms set out in key national strategic documents and European Union recommendations targeting areas that are particularly vulnerable to corruption:
(1) Strengthening Anti-Corruption Infrastructure;
The draft Anti-Corruption Strategy for 2026–2030 provides for strengthening the institutional capacity of NABU, including by ensuring the independence of its jurisdiction, aligning it with EU recommendations, improving access to data and forensic expertise, enhancing analytical capacity, securing adequate resources, and expanding its regional presence.
It also provides for strengthening SAPO by expanding the powers of its leadership, ensuring institutional independence, and providing adequate human and financial resources, supported by an effective internal human resources policy.
(2) National Police and State Bureau of Investigation;
The State Bureau of Investigation (SBI) and the National Police remain highly politically dependent on the government and Presidential Office, which negatively affects their professional functioning as law enforcement bodies. The European Commission has consistently recommended, for several years, the introduction of transparent, merit-based procedures for selecting the leadership of both institutions, based on candidates’ competence and integrity.
As a result of a study on corruption risks in the recruitment of senior management in the National Police of Ukraine, the Anti-Corruption Center “MEZHA” found that all key appointments in the police are made by political actors, the Minister of Internal Affairs or the Cabinet of Ministers, without transparent criteria or clearly defined procedures, creating a risk of inconsistent law enforcement based on hidden motives. In response to a request from the Anti-Corruption Center “MEZHA,” it was recently confirmed that no draft law to reform the institution existed at the end of January, and as of the end of March 2026, no information about such a draft law was publicly available.
Despite this, no progress has been made. The Ministry of Internal Affairs and the National Police openly oppose any changes to the procedure for appointing the Head of the Police.
As for the SBI, the President promised a draft law to reform the institution on 2 January, but as of the end of March 2026, no such draft law has been submitted. In response to a request from MEZHA, it was recently confirmed that no such draft law existed at the end of January, and as of the end of March 2026, there was still no information about it publicly available.
In addition, the Anti-Corruption Center MEZHA is aware of the risks that the Office of the Deputy Prime Minister for European Integration is seeking, in negotiations with the EU, to reduce the role of international experts in the selection of the Director of the SBI, which is unacceptable to civil society.
At the same time, the draft Anti-Corruption Strategy for 2026-2030 provides for a transparent, merit-based, and predictable procedure for selecting the Head of the National Police of Ukraine with the involvement of independent experts delegated by international partners, as well as improvements to the selection procedure for the Director of the SBI in line with European Commission recommendations. However, there are risks that the Government or the Parliament may not adopt the Strategy in this form.
In addition, the Ministry of Internal Affairs, in developing its own Anti-Corruption Program for 2026–2028, ignores the existence of corruption risks in the appointment of senior management positions in the National Police, which also leads to a fragmented anti-corruption policy and reduces the effectiveness of Ukraine’s anti-corruption commitments.
The Anti-Corruption Center “MEZHA” has addressed the Ministry with proposals to revise the 2026–2028 Anti-Corruption Program taking into account the recommendations of the European Commission and the NACP.
(3) Customs Service of Ukraine;
The draft Anti-Corruption Strategy for 2026–2030 provides for comprehensive reforms in customs aimed at reducing discretion, increasing transparency, and strengthening institutional capacity.
Regarding procedures, it introduces standardized decision-making for customs valuation, classification, and control, mandatory electronic recording of decisions, publication of reasoned decisions, review and appeal mechanisms, greater automation for low-risk declarations, risk-based processing, random allocation of cases, post-clearance controls, and upgraded technical verification systems integrated into a centralized database.
Regarding personnel, the Strategy establishes merit-based and transparent recruitment and promotion, a structured staffing reserve, performance indicators (KPIs), functional separation of key duties, and human resources practices aligned with international standards to ensure integrity, professionalism, and continuity in customs administration.
Currently, there is an ongoing competition for the Head of the Customs of Ukraine. It is extremely important to complete it in a lawful manner and appoint a worthy candidate who meets the criteria of integrity and professionalism, since the successful implementation of these measures largely depends on the political will of the leadership. Therefore, we continue to closely monitor the progress of the competition. You may access details on the course of the competition and its candidates via the link to our policy brief.
ІІ. INSTITUTIONAL FRAMEWORK
A. Prevention
Is there a robust anti-corruption agency or body responsible for overseeing corruption prevention and coordinating related activities (including the Strategy/Action Plan)?
The National Agency on Corruption Prevention is responsible for shaping anti-corruption policy in Ukraine through a range of legislative instruments, including public asset declarations, anti-corruption review of draft laws and existing legislation, lifestyle monitoring of public officials, and oversight of political party financing, etc.
The year 2025 was particularly significant for Ukraine’s anti-corruption system due to several serious threats aimed at undermining the NABU and the SAPO, which handle high-profile corruption cases in the country. Following a strong public response that helped preserve the anti-corruption infrastructure, in November 2025 it was revealed by NABU and SAPO that the largest corruption scheme in the energy sector involved individuals from the President of Ukraine’s close circle.
At the same time, these turbulent developments exposed institutional challenges and risks related to the work of the NACP. In particular, civil society has raised concerns regarding the political independence and effectiveness of this preventive authority.
Does it enjoy the necessary independence? Is it protected from political influence? Are there examples indicating that it has been subjected to undue pressure?
Since July 2025 there were several signs and examples indicating that it has been subjected to political pressure:
(1) The lack of a clear and firm opinion by NACP as the key anti-corruption prevention authority on harmful draft laws.
According to the Law of Ukraine “On Prevention of Corruption”, the NACP may suspend the consideration of a draft law for up to 10 days while it conducts an anti-corruption examination of the respective act. However, no such action was taken when Parliament voted in July 2025 on draft law №12414, which undermined the autonomy and institutional independence of the prosecutor’s office from the Office of the Prosecutor General.
This inaction by the NACP persists with regard to other harmful legislative initiatives. For example, in August 2025, the Parliamentary Law Enforcement Committee proposed amendments to draft law №12439 that are detrimental to anti-corruption investigations. These amendments would: allow corruption schemes in customs, taxation, or procurement to be concealed through “explanations” issued by government agencies; permit investigations only where there is “sufficient data” indicating a crime, thereby granting law enforcement broad discretion in deciding whether to initiate a case; restrict urgent searches to a limited list of cases, effectively hindering law enforcement from pursuing suspects in other corruption-related offenses; deprive the ESBU of the authority to initiate cases independently as an investigative body (see details – here)
On 10 March 2026, the Parliamentary Law Enforcement Committee revisited its conclusion on the draft law preserving all these risks. However, there has been no action by the NACP aimed at influencing the substance of the draft law, nor has it expressed any official position on the matter.
(2) Detected ties between members of a criminal organization in the energy sector (NABU “Midas operation”) and representatives of the NACP.
NABU recordings in the “Midas operation” indicated that in May 2025, the Head of the Security Unit at Energoatom, Dmytro Basov, allegedly delivered a bribe to NACP officials for some “document”. There have been concerns in the media that these funds may have been linked either to the special check of Serhiy Pushkar during his appointment as a member of the National Energy Regulatory Commission of Ukraine or to the review of the asset declaration of former Minister of Energy Herman Halushchenko (see details at the link).
However, the NACP stated that it had reviewed more than a thousand documents and reported that no violations were identified, which also raises doubts. No one was held subject to disciplinary liability, and this official may still be working at the NACP.
(3) Selective conduct of full declaration checks and lifestyle monitoring with respect to certain political figures.
Journalists have pointed out that there was no information on the NACP website about the initiation of a full verification of Andriy Yermak declaration, the former Head of the Presidential Office, although such information is usually published for all subjects. The document containing the results appeared only after his dismissal in November 2025, even though the verification had been conducted much earlier. This creates the impression that the process was hidden by the NACP officials at the request of certain individuals, which further undermines trust in the NACP’s independence.
Also, earlier, journalists had repeatedly raised concerns about the selective approach of the NACP in choosing “lower-level officials” instead of political figures for lifestyle monitoring.
One illustrative example is the case of Illia Vitiuk, an official of the Security Service of Ukraine. In 2024, journalists revealed that the official’s wife had purchased an apartment worth over UAH 20 million. Following an appeal to the NACP, the agency reported that it had found no violations during the lifestyle monitoring, which caused public outrage. Moreover, in September 2025, NABU notified Illia Vitiuk of suspicion of illicit enrichment.
Moreover, the declaration of the former Minister of Energy, Herman Halushchenko, was only subjected to full verification on 16 March, 2026 after requests from Member of Parliament – Anastasiia Radina, even though his statements in court had already provided sufficient grounds to initiate such checks independently. Let us recall that, one of the suspects in the “Midas operation” is former Minister of Energy, and later Minister of Justice, Herman Halushchenko. Herman Halushchenko was detained on February 15 while attempting to cross the Ukrainian border. After his arrest, the former minister was transferred to Kyiv. On February 17th, the court imposed a preventive measure in the form of pre-trial detention, with the alternative of bail set at UAH 200 million (approx. USD 4.5 million). See details on this case – here.
Number of disciplinary procedures conducted and sanctions imposed in vulnerable areas, including the police and customs. An assessment of whether these sanctions have a deterrent effect.
In the “Midas” case against the circle surrounding the President of Ukraine, a group of individuals with strong connections to the law enforcement sector was uncovered. Released recordings show that one of the figures, Ihor Myroniuk, visited the SBI. The criminal organization likely maintained ties to the SBI, which may have been acting in its interests. The recordings also mention the involvement of a head of a prosecutorial authority.
However, the response to these serious revelations has been slow and limited. The SBI has opened criminal proceedings and initiated an internal investigation. However, based on its results, the agency has not identified any responsible individuals and reported that the employee in question only had a one-and-a-half-hour meeting with detectives in the lobby as a witness (see details – here).
The Office of the Prosecutor General has not taken any active measures. It has not contacted NABU or SAPO to clarify which head of a prosecution body is implicated, has not launched an internal investigation based on the evidence, and has not opened any criminal proceedings.
The same situation applies to the leadership of the Prosecutor’s Office, most of whom, according to our investigation, have close relatives with Russian passports or have businesses in occupied territories. Namely, we revealed that Prosecutor General Ruslan Kravchenko’s father became a russian citizen during the full-scale war, in 2023. He obtained russian citizenship and made regular trips from the so-called “luhansk people`s republic” (“LPR”) to the Voronezh and Rostov regions of russia. 3 of the 4 Deputy Prosecutors General appointed by Kravchenko (Lohachov, Krym, Vdovychenko) have or business interests in the so-called “LPR”, or pay taxes to the russian federation’s budget, thereby supporting the russian army, or have relatives holding russian citizenship.
It poses great risks considering that these officials have access to the state secret. Moreover, these individuals have access to information on all criminal proceedings, including those in the defense sector, and can hold anyone accountable, from members of parliament to the prime minister.
However, there was no proper reaction to the revealed facts, particularly in the form of an internal investigation – only some public responses in small media outlets.
The team of MEZHA has repeatedly emphasized that the system for enforcing disciplinary accountability in politically dependent and non-transparent bodies is ineffective. Concerns have repeatedly been raised regarding the unjustified assets and integrity of the Police leadership, and the Minister of Internal Affairs of Ukraine has explicitly stated that disciplinary procedures will not be applied following a court conviction. For example, in 2024 journalists revealed that Ivan Vyhivskyi, the Head of the National Police, used property registered in relatives’ names without sufficient declared income, and that his sister had business ties with individuals involved in criminal proceedings. Despite the public outcry, the Minister of Internal Affairs refused to initiate an internal investigation.
We would like to note that on August 29, 2025, draft law №13713 on amendments to the Disciplinary Statute of the National Police of Ukraine was registered. This is a requirement of the State Anti-Corruption Program for 2023-2025, which aims to improve the procedures for conducting internal investigations and forming disciplinary commissions. However, the proposed draft law does not fully comply with the requirements of the Program, in particular:
- the draft law does not include a requirement that at least half of the disciplinary commission members be representatives of civil society, which contradicts the State Anti-Corruption program;
- the draft law lacks a list of offenses for which the disciplinary commission may recommend dismissal from office or service in the police, contrary to the State Anti-Corruption program;
- the draft law grants managers the discretion to determine the format of disciplinary commission meetings (open or closed sessions) that undermine the transparency of their work.
Details on all the risks of this draft law are presented in our anti-corruption examination at the link.
B. Repression
Number of cases where political influence was exerted upon law enforcement and judicial actors handling corruption investigations, including through public statements regarding concrete investigations.
(1) Volodymyr Kudrytskyi case;
In October 2025, the SBI announced suspicions against the former Head of NEC Ukrenergo, Volodymyr Kudrytskyi, regarding a procurement dating back to late 2018.
At the same time, the case is viewed as political persecution, as journalists from Ukraine’s leading media outlet, Ukrayinska Pravda, reported that on 10 October 2025, during a presidential meeting with government officials on the protection of energy facilities, proposals were made to politically persecute former officials through a high-profile prosecution.
At the same time, Kudrytskyi was considered by the President’s team as a dangerous political opponent, and his dismissal in 2024 harmed relations with international partners.
Under these circumstances, the criminal case concerning an episode from seven years ago appears purely as an act of political pressure against a critic of the President’s team. The pre-trial investigation is being conducted by the SBI and the Office of the Prosecutor General, both of which are subject to political influence and whose leadership is appointed not based on transparent criteria of professionalism and integrity, but for political reasons.
(2) The influence of the political context on the case against NABU detectives;
After the searches in the “Midas operation”, the President’s key team member, Head of his Office Andriy Yermak, was dismissed on 28 November.
This single event led to the reconsideration of preventive measures the following week in the politically motivated cases against NABU detectives Viktor Husarov and Ruslan Mahamedrasulov, as well as Mahamedrasulov’s father (see details – here). All of them were released from pre-trial detention.
Moreover, during this period, the Security Service of Ukraine (SSU) distanced itself from the case, stating that the investigations were being conducted by the Office of the Prosecutor General and the SBI.
All three detectives remained in pre-trial detention for four months without an effective judicial review of the necessity of such a measure. As of December, no procedural developments had occurred, while the changes observed were political, indicating a high level of politicization of the judiciary and law enforcement bodies.
(3) An attempt to discredit the Competitive Commission responsible for organizing and conducting the selection process for vacant leadership positions at the SAPO by appointing a member with questionable reputation.
On 28 November 2025, the Council of Prosecutors of Ukraine officially announced the start of the selection process for members of the Competitive Commission responsible for organizing and conducting the selection process for vacant leadership positions at the SAPO (hereinafter – the Commission).
It is extremely important to ensure that the Commission is composed of members with an undisputed reputation and background, as the selection will include the Head of SAPO (following the end of Oleksandr Klymenko’s term in 2027), the First Deputy Head, and the Deputy Head of SAPO – the leadership responsible for setting the vector of the SAPO work.
However, by Order №405 of 23 December 2025, Oleksii Shevchuk, an attorney with a questionable reputation, was appointed as a member of the Commission under the Prosecutor General`s quota.
Oleksiy Shevchuk is the subject of journalistic investigations, has faced disciplinary action as an attorney, has supported unconstitutional laws of a dictator, Viktor Yanukovych, and has worked for pro-Russian individuals). Over 60 civil society organizations and media outlets called to revoke the delegation, but as of early February, it had not been reversed.
Considering Ruslan Kravchenko’s previous background of proactive opposition to the SAPO and NABU in July 2025, his appointment of Shevchuk to the commission represents a deliberate attempt to sabotage the competition.
Moreover, the Prosecutor General is manipulating with the false information in his statement by claiming that he cannot exclude Oleksii Shevchuk from the Competitive Commission responsible for organizing and conducting the selection process for vacant leadership positions at SAPO. The Competitive Commission is not yet considered fully formed, as its complete composition has not been appointed. Therefore, the Prosecutor General is not restricted from replacing a member under their quota if that member does not meet the legal requirements regarding integrity and impeccable reputation.
At the same time, Oleksiy Shevchuk filed a lawsuit against the Head of MEZHA, Martina Boguslavets, over her public statement regarding his appointment as a member of the Commission. We consider this to be pressure in response to a public position, as we did not present any false information about him.
(4) An attempt to discredit anti-corruption activists.
Vitaliy Shabunin, the Chairman of the Board of Anti-Corruption Action Center, informed that the SBI and the Office of the Prosecutor General leaked his intimate photos from his phone, which was confiscated during a search conducted by the SBI. Photos were leaked to anonymous Telegram channels.
This action does not meet the standards expected of the Office of the Prosecutor General and the SBI as law enforcement authorities responsible for protecting their citizens. Moreover, this reflects a pattern of behavior by the Prosecutor General, Ruslan Kravchenko. In December 2025, he even threatened his critics, stating that he would “come after” those who publicly raised questions about his resignation. Civil society has doubts as to whether Ruslan Kravchenko is fit for the position of Prosecutor General (see the policy brief on his six months in office at the link).
Do these specialised departments/bodies in the prosecution office enjoy the necessary independence when conducting investigations? Is their mandate clear and restricted to serious corruption cases? Do they have the necessary resources (financial, staff and material)?
Legal amendments introduced in 2025 by draft law №12414 decreased the independence of prosecutors when conducting investigations.
In July 2025, draft law №12414, aimed at limiting the autonomy and powers of NABU and SAPO, also contained a number of other harmful initiatives that further deepen the institutional problems of the prosecution system, namely increasing the dependence of prosecutors on its leadership.
As a result, since July 2025 it is possible to appoint prosecutors during martial law outside of the competitive selection procedure, including individuals from outside the prosecution system according to para. 5-4 of the Transitional Provisions of the Law of Ukraine “On the Prosecutor’s Office”:
“5-4. During the period of martial law:
- A prosecutor of the Office of the Prosecutor General or of a regional prosecutor’s office may be appointed a prosecutor of a lower-level prosecutor’s office by way of transfer without conducting the competition provided for by Article 38 of this Law, as well as a person who did not hold the position of prosecutor on the day of entry into force of the Law of Ukraine “On Amendments to the Criminal Procedure Code of Ukraine Regarding the Peculiarities of the Pre-Trial Investigation of Criminal Offenses Related to the Disappearance of Persons Missing under Special Circumstances during the Period of Martial Law”.
In practice, this means that individuals may work in the prosecution system without undergoing competitive selection, testing, or integrity checks. Such an approach entrenches favoritism practices, where key positions are occupied not by the most competent candidates but by individuals close to the leadership.
Particularly, such appointments increase dependence on and loyalty to the appointing leadership. Such appointments may create a sense of personal gratitude and encourage individuals to prioritize maintaining the favor of those who appointed them in order to retain their positions. This environment risks fostering favoritism and undermines merit-based decision-making, as professional competence and integrity may become secondary to personal loyalty.
Moreover, this contradicts the principle of merit-based selection for public positions in line with OECD standards, which the EU has also required Ukraine to follow in its most recent Enlargement Reports for 2024 and 2025.
Also, in July 2025, the Prosecutor General received excessive powers to demand any procedural document from any prosecutor regarding any criminal investigation. According to the amended Part 2 of Article 36 of the Criminal Procedural Code of Ukraine: “The Prosecutor General (or a person performing his/her duties), in order to exercise his/her powers, has the right to issue a written instruction to the head of a pre-trial investigation body (except for the detective units and the internal control unit of the National Anti-Corruption Bureau of Ukraine), which is mandatory for execution, regarding the provision to him/her of pre-trial investigation materials, with the establishment of the deadline and the manner of its execution”.
Issuing such instructions regarding any investigation also undermines the independence and autonomy of prosecutors, who are expected to exercise procedural oversight impartially.
No draft law canceling these provisions was registered so far. MEZHA has received from the Ministry of Justice of Ukraine a copy of a draft law amending the Law of Ukraine “On the Prosecutor’s Office” regarding the assessment of prosecutors’ performance and the selection of prosecutors for managerial positions.
The draft law was developed by the Office of the Prosecutor General to fulfill Ukraine’s EU obligations related to the reform of the prosecutor’s office system. It is still being finalized, has not been published for public discussion, and appears to be the only legislative initiative currently addressing this issue.
We have conducted an independent legal and anti-corruption assessment of this draft law and would like to share our findings (please see our conclusion at the link).
The key risks identified are that the draft law fails to take into account international obligations and the requirements of national strategic-level legislation, in particular the recommendations of GRECO, the Rule of Law Roadmap, and the Comprehensive Strategic Plan for the Reform of Law Enforcement Agencies as Part of Ukraine’s Security and Defense Sector for 2023–2027.
Specifically, it does not cancel the amendments introduced in July 2025 regarding the appointment of prosecutors without a competitive selection process; does not establish any regulatory requirements for the procedures for evaluating and selecting prosecutors; does not take into account the special status of the SAPO when forming the commission for evaluating the performance of SAPO prosecutors and others.
Is there a secure platform for communication, and is access to the necessary databases ensured in compliance with data protection rules, or are there alternative arrangements for information exchange? How are the smooth exchange of information and the confidentiality of investigations ensured?
According to information provided by NABU leadership to Members of Parliament, NABU was unable to obtain sufficient information during the investigation of the “Midas” case from the State Financial Monitoring Service due to obstruction by its Head, Filip Pronin, a presidential appointee (see details via the link).
At a temporary investigative commission of the Verkhovna Rada on the “Midas” operation, it was revealed that in 2025, out of 109 requests sent by NABU to the State Financial Monitoring Service, only 50 received responses, with one reply taking as long as 319 days.
Without the involvement of the Service, effective investigation of money laundering, cross-border transfers, and access to information from other jurisdictions is not possible.
III. OTHER
Regarding the institutional capacity of the National Anti-Corruption Bureau to conduct independent forensic expertises
Forensic examinations play a crucial role in proving guilt in criminal proceedings. NABU detectives frequently order forensic examinations, and given their intense workload and the large number of cases they handle, the ability to turn to an independent expert institution is extremely important for proving the guilt of suspects in corruption cases.
The problem is that in cases where expert examinations are ordered, there are issues with the time required to complete expertises, with contradictory conclusions on the same matter due to possible interference, as well as political pressure on the whole process. For this reason, NABU has long been advocating for the creation of a separate independent expert institution for its needs, as it is currently forced to rely on expert institutions under the Security Service of Ukraine, the Ministry of Justice, and the Ministry of Internal Affairs.
In 2024, based on the Resolution of the Cabinet of Ministers of Ukraine of 8 September 2023 No. 798-r “On the Establishment of the Research Center for Independent Forensic Examinations,” the Research Center for Independent Forensic Examinations (hereinafter – the Center) was established as part of Ukraine’s commitment to the IMF to ensure NABU’s access to independent and competent forensic experts, enabling it to effectively exercise its investigative powers.
According to the Ministry of Justice announcements, the Center was intended to include such guarantees of independence as a supervisory board composed with a majority of representatives from international organizations and the appointment of the head of the institution by the supervisory board, among other safeguards.
Nevertheless, since the Center’s registration in January 2024, for two years there has been neither an independent supervisory board nor a head appointed by such an independent supervisory board. Moreover, the head of this Center has been appointed as Andrii Svintsytskyi – the former director of an expert institution under the Security Service of Ukraine, a person close to Andrii Naumov, the former head of the SBU’s Internal Security Department and a state traitor. Furthermore, according to journalists, Andrii Svintsytskyi’s family has acquired real estate and vehicles worth approximately one million dollars over the past few years, despite having no income commensurate with such purchases.
At the same time, NABU emphasizes the need for institutional independence of such an expert institution, in particular its establishment directly under the Cabinet of Ministers without subordination to any specific ministry, including the Ministry of Justice, as well as the introduction of an independent competitive procedure for appointing the head of the expert institution. Achieving this requires amendments to the Law of Ukraine “On Forensic Examinations”.
NABU’s position is that the Center can only serve as a technical base, while institutionally the expert institution must remain separate from the Ministry of Justice and include the necessary guarantees of independence. It was frequently emphasized by the NABU during the nonpublic meetings with us.
Thus, there are currently doubts that the government, in particular the Ministry of Justice, is interested in proactive cooperation with NABU regarding the establishment of an independent expert institution.
Analytical team that worked on the report:
Martina Boguslavets, Olena Kupina, Vladyslava Rudyka, Anatoliy Yarema