Head of NACP Viktor Pavlushchyk: "There is sense that no real demand for justice exists. There are two kinds of demand: for betrayal and for retribution"
How do civil servants and law enforcement officers hide their wealth while submitting declarations every year? Are the declarations of the heads of the Territorial Centre of Recruitment and Social Support (TCR & SS), who are being searched by law enforcement officers, verified? Why are NACP (National Agency on Corruption Prevention) findings used in high-profile court proceedings, and do they carry any weight? Viktor Pavlushchyk, head of the National Agency on Corruption Prevention, answered these and other questions in an interview with Censor.NET.
"WE DO NOT HAVE THE RESOURCES TO CONDUCT VERIFICATIONS SOLELY BASED ON PUBLIC DEMAND"
– The NACP reported violations amounting to over UAH 1 billion following full verifications of declarations in the first three months of 2026. What are the most typical asset concealment schemes you see right now?
– The most common, if we are talking specifically about concealing property, is still registering it in the names of third parties. We have identified specific cases that have already resulted in court rulings. Most often, this concerns the civil forfeiture mechanism, where such identified property can be forfeited in favor of the state through civil proceedings.
– For example, you see some property that a person bought and transferred to a third party. Do you verify where they got the money for it, or do you immediately pass these materials to the NABU?
– NABU subjects are approximately 10,000 out of 700,000 people who submit declarations. Everyone else falls under the jurisdiction of the State Bureau of Investigation (SBI) and the National Police. The NACP's jurisdiction includes not only the subjects subsequently investigated by the NABU. We send a lot of cases to the NABU, to the State Bureau of Investigation, and even more to the National Police. And this is logical.
– And does the NACP currently have enough tools to verify not only the Ukrainian property of officials but also assets abroad?
– This also depends on the procedure and qualification. If signs of illicit enrichment are revealed during the verification, and the difference between lawful income and the value of assets exceeds UAH 9 million, the NACP draws up its conclusion and submits the materials to law enforcement agencies for further investigation within criminal proceedings. It is the law enforcement agencies that subsequently establish all the circumstances of the case. However, if the value of the assets exceeds UAH 1.5 million but does not reach the threshold of criminal liability for illicit enrichment, such assets can be recognized as unjustified. In this case, the NACP sends the materials to the Specialized Anti-Corruption Prosecutor's Office, which files a lawsuit in court for the civil forfeiture of such assets. Thus, the role of the NACP is to identify the relevant signs, prepare the materials, and transfer them to the competent authorities for further response.
– You say that people mainly register property to third parties. How do you link this to the specific person who submitted the declaration? How is this found?
– Through the right of use and the right of disposal. Essentially, there are people who directly manage the acquisition of this property but register it to third parties. This can be done via powers of attorney or verbal agreements. But this is clearly traceable. One person selects and searches, while another formalizes the paperwork. Officials directly participate in these actions, while other people merely register the property under their names and have no relation to the further maintenance, repair, and use of this property. For example, like a car bought by a third party, which a civil servant starts using from the very first day. You could consider this a coincidence, but it is hard to believe.
– But they do not always indicate their actual residential address?
– Not always.
– How do you see such property if you have to deal with such a chain?
– Usually, there are two options. Either from the declaration, if the property is listed there and registered in the names of third parties, or, if the person does not list it in the declaration, from other sources. Most often, and most commonly, these are reports submitted to the National Agency stating that a person is using property that is not listed in their declaration.
– Who sends these reports?
– Citizens, public organizations, law enforcement agencies, and media reports. It can be anything.
– For a specific person, when you conduct a verification, do you do such monitoring, or do you take the report as a starting point?
– Yes, from the received or independently discovered information.
– How many criminal proceedings did the NABU open in the first quarter based on the results of the materials you transferred to them?
– NABU is not the main beneficiary of our work. And it cannot be. However, in terms of figures, since the start of 2026, following full checks of asset declarations, 17 materials have been sent specifically to NABU, with investigations launched into nine of them. One of the latest cases is a notice of suspicion served on a deputy of Odesa Regional Council over false declarations worth more than UAH 58 million. As for lifestyle monitoring, three materials have been referred, investigations have not been launched, but proceedings are ongoing based on 11 of our materials. Again, however, given the narrow range of persons falling under NABU’s jurisdiction, mainly top officials, our figures are lower compared with those of other law enforcement agencies.
– When you talk about the SBI, do you mean law enforcement officers?
– As for NABU’s jurisdiction, this covers category A civil servants, top officials of relevant ministries and agencies who do not have the status of civil servants but fall under the jurisdiction of the National Anti-Corruption Bureau of Ukraine. The largest group here is probably all categories of judges that exist.
As for the jurisdiction of the State Bureau of Investigation, this is mainly law enforcement officers, military personnel, and a number of officials who fall under its jurisdiction. Everyone else falls under the jurisdiction of the National Police.
– When scandals break out - like the recent one with porn offices...
– We have nothing to do with porn offices.
– I will ask anyway. When such high-profile detentions take place and expensive property and cash are found on law enforcement officers, do investigators then come to the NACP with requests to check these people’s declarations and conduct lifestyle monitoring? Or do you perhaps look at their declarations yourself to see what he or she had listed there?
– There has to be specific information that can be verified. If someone simply writes on a fence that someone is corrupt, that is not grounds for action.
– When such stories happen, do law enforcement agencies send requests to the NACP?
– Sometimes they do, sometimes they do not. That is entirely at the discretion of the investigative unit. And they draw conclusions based on the information they have. And they have more of it than what has been published in the media.
– In his post about this special operation, the Prosecutor General said that during searches of the leadership of regional National Police departments, for example, a fleet of six vehicles was seized, along with cash in various currencies totalling more than UAH 22.6 million. But these are law enforcement officers who filed declarations! That is why I am asking.
– That is all well and good, but there is no information there that specifies the things mentioned by the Prosecutor General’s Office. If the materials are sent to the National Agency, we will analyse whether there are grounds for action. There must be specific information. Published information is not an automatic reproach to the NACP, as in: let’s check the whole of Ivano-Frankivsk Oblast or the whole of Ternopil Oblast because yesterday a regional police chief was caught taking a bribe. That is not how it works.
– Do you have tools to detect property located abroad?
– We have tools to check available information, but they are not sufficient. As for detecting such a property, we have very few.
– So you do not see anything there if it is not listed in the declaration?
– The very important question is: what do you mean by "see"? If we are conducting a full check of this declaration, we have methods by which we can verify the relevant information about this property or the official. We have very productive cooperation with the Asset Recovery and Management Agency (ARMA), which receives information from abroad, and somewhat poorer cooperation in communication with foreign counterparts of the NACP. Because we ourselves are limited exclusively to an administrative procedure. The National Agency does not have requests such as, for example, requests for international legal assistance, which are sent by specific law enforcement agencies. If the goal is to find property first and then start a check, we have almost no such tools. These are different things.
– Would you like to have such a right?
– The right to send requests for international legal assistance? Law enforcement agencies may have such a right. We are not a law enforcement agency. I may want a lot of things that could help our work, but I believe changing the agency’s status would be completely wrong. There is a core oversight function, and it is administrative. If the Convention on Combating Corruption provides for the possibility of exchanging information within criminal procedure, and it is effective, then OK. But if another article of the Convention provides for exchanges within an administrative procedure and it is not mandatory for foreign institutions, then I would rather raise the issue (as I am doing) of making it mandatory between Ukrainian bodies and foreign bodies. That would be more important. But an ad hoc expansion of powers for an administrative body? You know, I worked in the law enforcement system for more than 15 years, and I believe every agency should do its own job.
– What grounds do you need to be able to contact ARMA and have them start searching for an official’s property?
– Conducting an administrative procedure, such as a full verification or lifestyle monitoring.
– If a full check is underway, do you contact them regarding every person?
– Not necessarily. We cannot demand: go and find all the property for us in 50 countries. We act where we have additional information that allows us to identify at least the countries where the property may be located. This can very often be detected.
– So earlier you could track who frequently travelled where and look there?
– Yes, it used to be easier. But there are other ways as well. For example, if a person spends money in a certain country. We can contact ARMA on the basis of that information.
– Recently, the National Police reported on 44 searches at the residences, offices, and vehicles of current and former officials from the leadership of the Territorial Centres of Recruitment and Social Support in 16 regions of Ukraine. It was also reported that the materials obtained during the searches will be transferred to the National Agency on Corruption Prevention to conduct a verification and form conclusions regarding possible signs of offenses. Have these materials been transferred to you? How do you plan to respond?
– Here, too, it is very important to understand one simple truth: the National Agency should not play the role of the final instance that will determine: this is legal, and this is not; this is right, and that is not. This role is played exclusively by the court. There are no restrictions on law enforcement agencies discovering information about undeclared assets, illicit enrichment, etc., investigating, and submitting appropriate conclusions to the court. The Law "On Corruption Prevention" clearly stipulates that if signs of corruption or a corruption-related offense are detected, the National Agency prepares a reasoned conclusion. I very often have a question, even in the context of requests from law enforcement agencies, where we communicate and cooperate, as well as in journalistic investigations: why should the NACP do something in a specific case if the signs of a violation have already been identified? Our materials, if they relate to a criminal procedure, become the grounds for law enforcement agencies to register a criminal proceeding and investigate it. If law enforcement agencies have already identified a violation and initiated an investigation, the NACP should not duplicate their work and also verify the exact same facts. Especially when comparing the NACP's resources and capabilities with those of law enforcement agencies.
The issue is that there are always very different expectations, and consequently, criticism. If someone is found – oh! The NACP didn't find this. Okay, the NACP starts dealing with those who were found – and then they say: you are not finding others! And here the question arises: so what exactly is expected of the NACP?
You see, what is important to me is not the criticism, but the perception of the goal, for example, of the register of declarations, the perception of the National Agency's work. Because right now, this perception is maximally associated exclusively with punishment. Very few people perceive the very fact of submitting a declaration by a civil servant as a positive thing. But it shouldn't be like this, because submitting a declaration cannot in any way be associated with the punishment of officials.
– And do you obligatorily verify the declarations of the heads of the TCR & SS?
– It cannot be obligatory. The day before yesterday, it was Medical and Social Expert Commissions (MSECs), yesterday - TCR & SS, today – customs, tomorrow – the tax authority. Every day, there can be a demand to verify a new category of officials, and often non-declarants. We do not have the resources to conduct verifications solely based on public demand. First and foremost, the NACP operates on a risk-oriented approach. We analyze everyone and verify those who have the highest risk indicator, which means potentially significant violations.
– The issue of the TCR & SS is very sensitive for society. When we see how much and what kind of property law enforcement officers discover among the heads, it raises a lot of questions.
– Every issue is sensitive. I can tell you with confidence: every category of people who communicate within their own circle, in their own bubble, will have their own priorities. Taken together, those priorities are many times greater than the National Agency’s capacity to conduct checks.
– When a case of yet another TCR & SS head who has enriched himself by a very large sum of money and possesses valuable property appears in public reports from law enforcement agencies. And you already had their declarations at the Agency. Do you think to yourself, "We missed him, how?!" Or do you not? Do you react emotionally to such things at all?
– For two years, I did not react; now I have started to react a little bit more, but not in this context. I react more emotionally to the distorted perception of the National Agency's overall functionality; the distorted perception of the register of declarations; unjustified expectations from functional duties, the purpose of which I see differently. For instance, individual MPs often like to propose: let's exclude village council heads from the list of declarants! And let's increase (or decrease) the number of declarants!
– Yes, there is an abundance of such ideas in the information space.
– Never in my life have I confirmed to anyone that it is necessary to increase or decrease the circle of declarants. It is necessary to objectively understand how and why financial control systems function in Ukraine. Why is such a comprehensive system, like the one in Ukraine, not needed in European countries? By the way, this issue is raised in European countries in the same way: let's do it like in Ukraine! But no one will implement this there. And they do not need to. Armenia has a similar system. Georgia had a similar one, but it underwent changes. In Romania, there was also a Constitutional Court decision that abolished the obligation to declare the assets of declarants' family members. They consider that for Romania, this is too great a restriction. And why do European countries not need it? Because there is another element of control over the wealth and assets, not only of the civil service there: the tax system. By the way, we also have tax legislation — and it is not bad; perhaps not worse than in many European countries. But there is no control like in European countries.
Regarding the categories of declarants. Take, for instance, the category of village council heads, for example, in the Kyiv region, where land is more expensive, and there are greater opportunities for abuse — questions may arise, as well as for frontline regions. So how do you differentiate each official? Some will not declare, while others will?
– Indeed — how? Do you have your own view on resolving this dilemma?
– I do. The question arises here that the system operates within the clear boundaries and limitations that exist. If there are no abuses exceeding 150 minimums (In 2026, this is UAH 499,200 – ed.) for the threshold of administrative liability, then this issue will never become an object of investigation by either the National Agency or law enforcement agencies. But here the question of that grandmother who lives in that village arises. She will ask the village council head every day about the inaccurate UAH 10,000 in his declaration. Therefore, the goal is, essentially, declaring, ensuring control by citizens, and ensuring the integrity of officials, rather than running around, verifying, and punishing every official at someone's whim. Every minister must be verified, etc. In our country, a question arises exclusively after yet another scandal in some sphere.
– And what should this control be like?
– If a person in our country can buy a car for $200,000 in a car dealership without having any asset backing for this... I mean any individual, not an official. These issues should be controlled. Therefore, the system of declaring officials that exists in Ukraine is important and necessary in the exact form in which it exists. But not in the context of punishments, but in the context of transparency, openness, and the ability of everyone to look at information about their neighbor, a civil servant, if he declares a "Lanos" but drives a "BMW". Such legislative requirements are important precisely for this openness.
– But according to your logic, all corrupt officials can live peacefully until one of their neighbors envies their property.
– No. Here, the question arises of the full verifications of declarations that are being carried out. The National Agency applies a risk-oriented approach to selecting declarations and conducting their verifications. Therefore, no one can feel peaceful except the honest ones. Because if people's math adds up, their assets correspond to their incomes, and they live honestly, they can continue to live peacefully. This is a new approach of the NACP, where verifications are based not on the position, but on the highest indicator of probable violations. Briefly: under the risk-oriented approach, every declaration is analyzed, assigned a risk rating, and those that receive the highest indicator are verified. Thus, we focus not on the position, and every declaration of every official can fall under full verification. Therefore, the honest ones can sleep peacefully – there are no problems there. Because no one will invent violations for them, and even if verifications are conducted, the fact that their property corresponds to the data in their declarations will be revealed. And the dishonest ones physically cannot sleep peacefully, because they will always have to think: did I indicate it correctly? Did I enter it correctly? Did it add up correctly for me? Will they verify me? Will the NABU come for me?
– If this system were effective, would the NABU have less work?
– This is a logical result. In the future, there should be less work. But over time, not in a year and not in two. And not even in five.
– When will that happen?
– Let's do the math. I can clearly tell you that the level of quality and compliance of what is filled out in the declarations of the highest category of officials, who fell under obligatory verifications year after year until 2021, is many times higher than that of all other declarants, for whom, until 2021, there were not even grounds to be verified. Until 2021, only the declarations of the top tier were verified for compliance – the President, the Cabinet of Ministers, the Supreme Court, at best — heads of appellate courts, etc. That's it, full stop. That is, the middle and lower tiers never in their lives thought that their declaration would ever undergo a verification.
In 2023, the legislation was amended, and a risk-oriented approach to the verification of declarations was implemented. This happened even before I joined the NACP, and I am grateful that these changes were adopted. Now, declarations of all categories of declarants can be subject to full verification. People began to realize that every declaration can potentially be verified, and already in 2024 – after the resumption of declaring – we see a significantly more responsible attitude toward filling them out. In fact, in 2024, we began to see the effect of the declaring system that has been operating since 2016. A similar effect will gradually manifest itself regarding other categories of declarants as well – precisely due to the preventive mechanism, when there is an understanding that any declaration can be verified. This will gradually increase the quality of declaring. The results of such changes become noticeable only over time; therefore, it is difficult to accurately predict the timeframes. At the same time, verifications were resumed in 2024, and the first materials after the legislative changes began to be submitted to court as early as April 2024. That is, the system has actually been operating for a little over two years.
– For what percentage of declarations is the risk criterion triggered?
– Violations are found in 62% of the declarations selected based on the risk-oriented approach.
– Is this a high percentage?
– Very high. Until 2021, it was 27% — when everything was verified simply based on the position category.
– What do these risk indicators most often flag?
– Most often, the numbers simply do not add up. Everything hidden eventually comes to light. When people try to invent something, it will still be uncovered. There are all sorts of cases.
– For example?
– We were verifying one declarant, the difference was insignificant. He had a discrepancy between income and expenses of approximately UAH 700,000. At the same time, the explanation, we must give credit where it's due, was extraordinary.
– What was it?
– Almost every day he went to a restaurant with his colleagues, always paid with his card, and everyone else paid him back in cash. Well, it happens, you understand. Real-life situation (irony).
– That’s quite something. Were there any similar stories?
– For example, there was the story of USD 653,000 found in an inherited garage after a grandmother’s death. The NACP conducted a full check of the 2024 declaration filed by the acting head of the State Environmental Inspectorate of Ukraine and received exactly that explanation. A spectacular case, which also gained publicity. What is also interesting here is that the court ruled that the money could qualify as treasure. And how is a find supposed to be handled? 25% goes to you, 75% to the state. A costly way to legalise it, as legalisation options go, but it is what it is.
– (With irony — author’s note). So, as I understand it, it is better not to leave a card trail and to pay in cash?
– Other measures are planned for this, including in Ukraine’s roadmap, which provides for limits on the amount of cash a civil servant may declare outside bank accounts.
– But that does not stop a person from using that cash without declaring it...
– Of course it does not. Except that NABU, the SBI, or the National Police may come in with a search, check everything, and it turns out you have a bit more cash than you could have saved.
– It’s not a given that they’ll come, and it’s not a given that they’ll find anything. And it’s not a given that it’ll be at home.
– Nothing is certain. But this "not certain" plays a very important preventive role. Prevention is usually built on the principles people have. Principles make up a certain share of a person’s overall incentives. But another factor also plays a major role: when a person is afraid. Fear of being checked plays an important role in prevention. The main role is played by making it impossible to spend those funds, and so on. There are many factors there.
The same applies to the elements of countering corruption in general. Not fighting it, but countering it. This includes prevention, enforcement, and other tools that are used. We are developing the anti-corruption strategy, and we also monitor the implementation of the previous strategy and the state anti-corruption programme. The implementation rate is quite high, over 75%. For individual bodies, it clearly correlates with survey figures on how often people encounter corruption in specific sectors. It correlates very strongly with measures implemented, for example, by ministries. The Ministry of Health is a very good example for us. It is the only ministry that has implemented the state anti-corruption programme in full. And the rate at which people encounter corruption in healthcare fell threefold between 2015 and 2025.
– What explains that?
– The enormous amount of work that has been done. First, the introduction of the National Health Service of Ukraine (NHSU) and the institution of family doctors. One measure implemented under the state anti-corruption programme that I find very impressive is the publication of medicine stock levels on hospital websites. In other words, no doctor can tell you: we do not have this medicine, go and buy it at a pharmacy. Things like this shut down opportunities for corruption.
– Let us return to violations. If we speak by category, who are the biggest offenders? Law enforcement officers, civil servants?
– It varies. There are no standout categories. The National Police employs up to 140,000 people. And right next to that, there are 1,000 NABU employees. How are we supposed to compare that? There may be one case there and a thousand here. But one out of 1,000 is one percent, while a thousand out of 140,000 is something else. These are the wrong comparisons to make. We cannot say where the manifestations are greater and where they are smaller.
– Are there any offenders among NABU detectives?
– In 2024 and 2025, two full checks of declarations filed by a NABU employee were completed. The violations were minor: in one case, inaccurate information was identified, and in the other, the declaration was filed late. Based on lifestyle monitoring, materials were also referred back in 2023 over the declaration of false information.
– Unfortunately, open sources point to quite a few scandals involving the defence sector. In your view, what are the most common risks there now? What should attention be paid to? And do you discuss this with Fedorov as a minister who is described as more progressive than his predecessors?
– Of course, this sector will always be at the top for one key reason: the amount of money allocated to it. Where there is big money, there are big risks. That is logical, and this money mainly concerns procurement. There are standard risks that apply to all procurement. There are also risks related to specific types of procurement. Last year, we presented our study on drone procurement. We tried to make it as comprehensive as possible, in cooperation with all stakeholders involved in Ukraine. We have many procurement agencies, as well as many agencies that carry out procurement. Nineteen risks were identified. Of course, an important element is balancing the need for transparency in the procedure with the sensitivity of this information. We understand that some information in the defence sector has restricted access. There is no possibility of making it fully transparent. As for our study, it clearly identifies corruption risks that need to be eliminated. The study was prepared in cooperation with our NATO partners and experts from other organisations, including the civil society sector. Now, with the same group of people, we are working out ways to implement our recommendations. Our cooperation with the Ministry of Defence is quite good. They are focused on this and willing to be involved in minimising these corruption risks.
"No one here waits for a final court ruling."
– At a recent hearing of the High Anti-Corruption Court, where a preventive measure was being chosen for Andriy Yermak, his lawyer, Ihor Fomin, referred to the results of the NACP’s check of his declaration. I quote: "The check found no signs of violations, including with regard to asset status." At the same time, the NACP’s March clarification on the situation around Yermak’s declaration said that "materials from law enforcement agencies that could serve as grounds for a repeat full check had not been received by the NACP." My question is: now that Mr Yermak has been served with a notice of suspicion, and given the huge public outcry around this process, do you expect such materials to be sent?
– No. First, what added value would a repeat check of the declaration have for the materials that law enforcement agencies already have? What would the purpose be? The purpose of a full check is to establish facts, compare them, and refer the materials to law enforcement agencies. The information the NACP can obtain comes only from several sources: official registers, banking institutions, and information obtained through requests to individuals or legal entities. If we send a request to the person involved, he will provide us with information. If we send one to law enforcement agencies, they will provide information. What added value would that have? This is, again, a distorted perception of the very purpose and essence of financial control measures. Plus, there is international cooperation. I have already mentioned the problems with obtaining information through that channel. That is why checking any such information is more logical and more productive within criminal proceedings.
As for the argument involving the presentation of a certificate on the results of a full check, the point is that this is an adversarial process. Each side is entitled to use the arguments it has. But no result of a National Agency check, conducted using only these powers, can ever be used like a doctor’s certificate saying you are healthy. Therefore, the fact that the NACP did not detect violations during a full check of a declaration, using the available information and capabilities, cannot be proof that there were no violations at all, especially those that do not fall under the NACP’s jurisdiction, such as money laundering.
– Can the fact that the NACP conducted checks and found nothing be significant evidence?
– No, of course not. The NACP works with a limited pool of information and draws conclusions only on that basis.
– What are such arguments aimed at, then? Are they simply used by the defence to characterise the client?
– It is an adversarial process. The defence is entitled to use whatever it wants. As is the prosecution.
– NABU wiretaps recorded that in May 2025, Tenor, who, according to media reports, is Dmytro Basov, head of Energoatom’s security unit, allegedly brought a USD 20,000 bribe to the NACP. After that, in January, the National Agency on Corruption Prevention said an internal inquiry had found no involvement of NACP employees in the Energoatom corruption case. Could you explain how this inquiry was conducted? What is done in such cases? The public would be interested to hear this.
– Here, it is necessary to distinguish between the powers of law enforcement agencies within a pre-trial investigation and the powers of any agency when conducting a disciplinary (internal) procedure. Any substantiation in criminal proceedings involving bribes or unlawful benefits is mainly carried out in parallel with a controlled commission of a crime… The National Agency cannot check whether someone received a bribe or did not receive one. All we could do as part of the disciplinary procedure was check for possible abuses that could be useful as information for further investigation by law enforcement agencies, in this particular situation, NABU.
As part of the inquiry, we analysed the full range of NACP powers, the actions of employees and work with registers during the relevant period. No abuses that could be linked to this case were found. For me, as head of the Agency, it is extremely important to identify such facts if they exist, and I guarantee that if they are established, we will take appropriate measures.
At the same time, a disciplinary procedure cannot establish whether a criminal offence was or was not committed. Its task is to identify additional circumstances that may be useful for the further pre-trial investigation. Based on media reports and materials provided by NABU, we conducted an inquiry and sent our conclusion to the Verkhovna Rada Anti-Corruption Committee, NABU and the NACP Public Council. We did this for the sake of transparency and openness, providing a detailed description of the verification measures carried out. At the same time, we cannot publish the report itself, as most of the information it contains includes personal data.
– The NACP belongs to the state structures that are called anti-corruption agencies. The fight against corruption in our country is usually associated with the fight for social justice. In your opinion, during the war, does this demand for justice exist in the country? Or do people not have time for that, being focused on surviving?
– I have a feeling that a real demand for justice does not exist. There are two types of demand: a demand for betrayal and a demand for retribution. The demand for betrayal is realized exclusively at the stage when "information was published on the internet". Whether that information is true or not, most often no one cares. The betrayal is realized, such-and-such are scoundrels. Moreover, it is often not even about unjustified assets, illicit enrichment, or failure to declare. Everything can be declared, the money for it is there. But what does it all come down to? That's it, the demand for betrayal is realized. As if to say, you cannot be a civil servant and own any property; it is physically impossible.
And the second demand is for retribution. We do not have a demand to wait for the final result of the court. The court's decision following a notice of suspicion can take 7-10 years, and by that time, everyone will have forgotten that such an official even existed. Let me give an example of one such case.
Do you remember the clash between the Prosecutor General's Office and the NABU on Petliura Street in 2016? When special forces arrived to protect a NABU detective? And before that, two NABU employees were kidnapped...
– We remember, it was a high-profile story.
– Back then, special forces personnel arrived to rescue that one NABU detective. I remember this case very well, because that detective was me. And then, in 2023, the court sentenced the prosecutor to 9 years in prison. The appeal reduced it to 7. Who remembers that case? No one remembers. In our country, no one waits for the final court decision. I personally waited for this decision and remember this incident well.
The same goes for the perception of the final court decision. We were just talking about the adversarial process. So, where in our society is there a normal perception of an acquittal? If a court issues an acquittal, what is it in people's perception? It is a verdict on the judicial system...
"MY CHILDREN, SOME FROM AN OLDER AGE AND SOME FROM BIRTH, ARE AND WILL REMAIN RELATIVES OF A PEP. THE ONLY WAY TO RID THEM OF THAT STATUS IS FOR ME TO DIE."
– Is anyone monitoring your lifestyle?
– The procedure for a full check of the NACP head’s declaration was formalised and set out in the relevant regulations only during my tenure. Before that, it was effectively not provided for in any document.
It is simply that no one conducts this administrative procedure outside the NACP. But any law enforcement agency, within the scope of its powers, which are many times broader than the NACP’s, can do so.
– Does your experience as an operative make you constantly check your office for bugs, pay attention to whether you are being followed, and things like that?
– With my experience, practice shows that as soon as you check, a bug will appear the very next day. Moreover, no check can guarantee that there is none. No matter how confident you are, that confidence will not help in any way. So integrity will always be the only guarantee.
– You mentioned a demand for betrayal and a demand for retribution. Does the situation with the NABU tapes (as presented by MP Zhelezniak) fall under the demand for betrayal? I mean Tsukerman’s phrase that "it is hard to reach an arrangement with NABU; it is better with the NACP; it is the same kind of sh*t, sometimes you can, sometimes you can’t." It seems to me that this conversation should have interested you.
– Of course, it interested me, because I made a gradation and thought: from that phrase, "the same kind of sh*t," it follows that, in principle, we are on the same level as NABU. The question is more for the person who said it: he believes less there and more here. That is his belief. But we were placed on the same rung.
– Did it not bother you that the public would read all this and remember it as, well, the NACP is just like everyone else?
– It did not bother me, because this kind of discussion is nothing new to me. You know, I worked at NABU for more than eight years. From time to time, I heard the same story: "People at your agency take bribes." And I always said I was ready to document it! Not once did anyone come back to me with the idea of pursuing the matter further...
– I want to ask you about the current situation regarding persons with the status of Politically Exposed Persons (PEPs – editor’s note). This is not an NACP issue, but how do you feel about MPs wanting to limit lifelong financial monitoring of PEPs, their family members, and business partners?
– In my opinion, the key problem lies precisely in the lifetime PEP status. Otherwise, the current legislative framework is entirely logical and in line with international standards. In general, when it comes to legislation, it is important to pay attention not only to the rules themselves, but also to how they are implemented in practice. Many of the questions people have about PEP status are not related to the law as such, but to how it is applied by individual entities. For example, this concerns cases where banks refuse to open accounts or automatically classify clients as high-risk because of their PEP status. At the same time, state-owned banks generally do not create such problems. If such practices occur in private banks, the regulator should respond. A discriminatory approach to people simply because of their status cannot be allowed. This is a fairly typical situation: the problem often lies not in the quality of the legislation, but in its incorrect or overly formal implementation.
– Would it be good if it were limited?
– Its lifetime nature definitely needs to be limited. I will give you an example. My children, some from an older age and some from birth, are and will remain relatives of a PEP. The only way to rid them of that status is for me to die. Do you understand? At the very least, this cannot apply to third parties on such a scale.
– According to the latest data from the NACP, over 110 political parties out of 400 registered (including 72 parties that are in the process of termination) have not submitted reports on property, income, expenses, and liabilities of a financial nature to the NACP for this reporting period. I started looking at the list of debtor parties — and saw parties there that I thought had not existed for a long time. The Socialist Party of Ukraine, SDPU(o), the Women's Party of Ukraine, the "Reforms and Order" party, and the Defenders of the Fatherland party. These are just the most high-profile acronyms of the past. Hence the question: are the majority of debtor parties this quarter in a state of termination?
– For the NACP, the legal status of the entity is the only key factor. As long as a party has not been officially removed from the state register, it is obliged to report, regardless of its actual activity or the absence of personnel. A vivid example is the banned OPZZh. Legally, it has not yet ceased to exist as a legal entity, so the state funds previously allocated to it and the accumulated property must be fully monitored by the Agency up to the final stage of liquidation. Equality before the law is absolute for everyone.
– How often, while analyzing party reports, do you find violations at the NACP?
– Regarding verifications, among the recent ones, we can mention the facts where parties were deprived of funding. For example, "Holos," or the termination of funding for "Batkivshchyna." Or a lawsuit filed regarding "European Solidarity" due to its violations. How typical or atypical are they? They are atypical. Because typical issues are contributions that are not supported by citizens' income, or that exceed legislative limits. But they are small, nothing global. We clearly distinguish between typical violations and isolated, atypical cases. Among the latter, there are two legal categories. The first is violations that give the NACP direct grounds for making a decision to suspend or completely terminate state funding for individual parliamentary parties. The second is the identified facts of misuse of these funds, regarding which we have currently filed a lawsuit with the court (which has not even been considered as of today). We react as harshly as possible to such complex abuses. Instead, most daily violations are minor: technical errors or "contributions without income," when citizens' contributions exceed their official earnings according to tax data. We document each of them, as minor violations are the first step to large shadow schemes, especially during elections.
– An interesting piece of news from May: the Supervisory Board of Mykolaiv’s municipal utility company Vodokanal appealed to the NACP with a request to conduct an unscheduled inspection of anti-corruption work at the company. As I understand it, the staff are broadly dissatisfied with the management methods of the new director general. Hence, this initiative. Do you often receive such requests from company staff?
– Each year, the NACP approves a plan for inspections of how work to prevent and detect corruption is organised, and that plan is public. Last year, we inspected the Ministry of Health, the Ministry of Culture, and the Consumer Protection Service. This year’s plan includes the Ministry of Youth and Sports, the State Service for Transport Safety, the State Employment Service, Ukrenergo and others. So you can see that this is the level of central agencies. At the local level, we inspect city councils. Last year, these were Chernivtsi, Kyiv, and Kharkiv regional military administrations, and an inspection of Dnipro is now underway. We do not have the resources for individual municipal enterprises, and that is not necessary, as they are subordinate to cities. We provided a response setting out our position that this inspection can be conducted by the city council. The complaints concern the work of the authorised anti-corruption officer, an employee of that institution. If there are issues related to disciplinary action or work, or the responsibility of bodies, they must make decisions as managers.
– Have the National Police, who have been widely discussed in society recently, been inspected?
– The National Police were inspected in 2023. There is a huge report on that. This also needs to be understood: we inspected all main police directorates, more than 100,000 people. And then, we do not inspect financial and economic activities. We inspect anti-corruption compliance. It is the same as with the inspection of Energoatom: where was the NACP, people ask, why did it not detect anything? The interesting thing is that we did detect things and recorded many violations; some of the violations we identified were sent to NABU in January 2025. But the point is that even at the Temporary Investigative Commission, when the head of the detectives’ unit spoke, he said directly that the scheme they had documented could not have been detected by any inspection. But the question is whether our recommendations could have prevented this Energoatom story. No, of course not, absolutely not. But they would have created slightly more conditions for anti-corruption compliance inside Energoatom, which could have led to better internal work. Perhaps. There is no guarantee, but there would have been chances if they had implemented our recommendations. But it is what it is.
– We have established that the Mykolaivvodokanal case is not your level. But what about the case of Lviv tax officials Ivan Levkin and Nataliia Zholudieva, who forgot to list entire cottages in their declarations? What do other similar cases lack in order to reach court?
– Active work is being done on this. In this case, the matter falls under the civil forfeiture mechanism. This is about cooperation: our full check of the declaration, in cooperation with the SBI, produced a result in the form of a lawsuit filed by SAPO with the High Anti-Corruption Court. More than UAH 4.4 million in unjustified assets may be recovered from the official. This mechanism works fairly quickly; in similar cases, we get results in about six months on average.
– You verify a large number of declarations. Have there been any recorded attempts of pressure or bribery of your employees?
– If there had been any recorded attempts, this information would be with law enforcement agencies — and public at that. If such facts existed, I would not hide this information.
– But there were times when ministers and deputies were worried, and they came...
– Everyone worries, everyone is nervous.
– I remember once in a former life, I spoke with Kholodnytskyi and Sytnyk. I asked them if politicians come, what they complain about, and what issues they are trying to resolve.
– Everyone complains about the complexity of the full verification. That is normal, because it involves the collection of all data. But even if people ask questions, the main thing is to adhere to the rule of law and the procedure, which must be understandable to everyone...
– Has there ever been a situation where someone from the Office of the President called and said: Check this person, but not that one?
– No, there have been no such cases. We work in accordance with the powers and procedures defined by law and are not guided by political conjuncture or public resonance. This is my personal position, which you can see from the change in approaches, including regarding the agency's external communication. We react to the presence of grounds for conducting verifications, and I consider it significant that in a number of cases, our materials were sent to law enforcement agencies even before these issues gained widespread public or media attention.
That is, if there are questions, they will be voiced; if not, they will not. No one will whitewash someone's reputation or destroy it.
– Returning to 2016, when NABU special forces came to rescue you, then a NABU detective, from your "colleagues" at the Prosecutor General’s Office. Did that story affect your nervous system?
– Of course, it did. When you work on such cases, that is inevitable. The consequences of that case alone included threats, the need to move around with security, and serious pressure. But I always focused on the result, not on the surrounding circumstances. Both our team of detectives and society got that result: the individual was sentenced to seven years in prison and is serving the sentence. This is a huge achievement for the detectives who worked on that case. Life moves on, and such cases become part of your life. Does this affect the nervous system? Absolutely. This kind of work also affects your personal life. When you work for years with virtually no days off and live your job, it comes at a price. But for me, it has always been important to see the cases I start through to the end. The result matters to me.
– And what kept you, and still keeps you, in this situation?
– The desire to achieve the final result. At the same time, I understand that prevention, preventing corruption, is about the long term.
I have been in the law enforcement system for more than 15 years, and I can say clearly that the inevitability of punishment plays an important role in countering corruption. However, let us look at the figures. Over the past 18 years, Ukraine has reduced the level of corruption 3.7-fold (from 67 in 2007 to 18.2 in 2025). Studies show that the biggest contributor to Ukraine achieving this result has been systemic sectoral reforms aimed at minimising corruption, followed by the general system of preventing and countering corruption at all levels.
I believe in the strategy we spent two years developing. It is about systemic changes, not isolated punishments. I believe in measures that make corruption itself impossible. And this really works. An example? Healthcare is a good example. Sociological studies record a decline in corruption there. This is the result not of high-profile criminal cases, but of the consistent implementation of anti-corruption measures. In my view, this approach, eliminating the conditions for corruption rather than merely fighting its consequences, produces the most sustainable result. It is not quick, but it is more effective.
– MP Anastasiia Radina said that independent competitions for the leadership positions of the National Police and the State Bureau of Investigation had been removed from the draft Anti-Corruption Strategy that the government is to consider. The MP called on Ukraine’s Prime Minister Yuliia Svyrydenko and members of the government to restore competitions for positions in the National Police and the SBI to the Anti-Corruption Strategy and to keep elements of a competition for the post of Prosecutor General. What is your view on this?
– The Anti-Corruption Strategy must be adopted. This is a matter of Ukraine’s future, one of the important requirements for our progress and for the provision of financial assistance. I want to stress that this is not a document about several competitions for positions. It is a nationwide document covering 26 areas of life and hundreds of measures that citizens may feel in practice. At this point, the ball is in parliament’s court. Every stage of the strategy’s passage is a space for expert discussion. We are ready to provide expert assistance in any scope and hope that the people’s deputies understand the importance of their decisions.
Tetiana Bodnia, Yevhen Kuzmenko, "Censor.NET"
