Overview
Welcome to Secretariat’s third edition of Rebuilding Ukraine, where we explore the evolving landscape of Ukraine’s reconstruction, the challenges ahead, and the opportunities emerging. Stay informed with our insights on Ukraine’s Emerging Risks, Funding and International Support, and Sanctions & Export Controls.
- Emerging Risks: In this edition, we provide updates from the National Agency on Corruption Prevention (NACP), the National Corruption Bureau of Ukraine (NABU), and the Specialized Anti-Corruption Prosecutors office (SAPO) in Ukraine.
- Funding & International Funding: The EU and UK have increased and extended financial support to Ukraine, including loans and grants for defense, infrastructure, civil society, and independent media. Meanwhile, US military funding to Ukraine is currently paused.
- Sanctions & Export Controls: The US and Europe are taking divergent approaches to sanctions on Russia. While the US is considering the potential lifting of some sanctions, Europe is intensifying its measures with the 17th Sanctions package currently underway.
Emerging Risks
Businesses and investors/funders in Ukraine will face many challenges common to conflict zones, such as corruption, regulatory uncertainties, and infrastructure deficiencies. These factors, along with the constantly evolving sanctions and international relations, contribute to a complex risk profile for governments, NGOs, and businesses operating in or considering investment in Ukraine. We explore the multifaceted nature of these business risks, offering insights into the challenges in this volatile region.
This month, the combined actions of the NACP, NABU, and SAPO against individuals, government officials, and businesses have heightened concerns about risk in areas such as bribery and corruption, contractual risks, money laundering, organized crime, and governance. Notably, these agencies have identified significant risks and vulnerabilities in public procurement and defense fortifications. The NACP has also initiated lifestyle monitoring of state tax officials to detect unjust enrichment. Additionally, NABU and SAPO have uncovered high-profile corruption and bribery schemes in key sectors such as defense, construction, procurement and energy, as well as illicit enrichment leading to state revenue loss.
The unified whistleblower reporting portal, established by the NACP, has received over 5,000 complaints of corruption. Of these, 68% pertain to corruption-related administrative offenses defined in Chapter 13-A of the Code of Administrative Offenses, 24% involve corruption-related criminal offenses defined in the note to Article 45 of the Criminal Code of Ukraine, and a further 8% concern other corruption-related violations of the law. The NACP’s whistleblower initiative highlights its crucial role in raising awareness and improving transparency and accountability in Ukraine.
The investigation status reported by the NACP
Source: https://whistleblowers.nazk.gov.ua/#/
Procurement
March 2025
- The NACP launches analysis of corruption risks in procurement of defense and warfare equipment for the Ukrainian Armed Forces. Read the full article.
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Bribery & Corruption
March 2025
- The NACP has identified vulnerabilities in the construction of defense fortifications and public procurement. They are currently studying corruption risks in reconstruction efforts, particularly in the Zaporizhzhia region. Read the full article.
- A lifestyle monitoring exercise conducted by the NACP and the State Bureau of Investigation (SBI), along with evidence from independent sources, revealed that a state tax official had unjustly acquired assets beyond their regular means. Prosecutors are seeking to recover these assets for the state. Read the full article.
- NABU and SAPO have uncovered a bribery scheme involving a State Border Guard Service officer who used an intermediary to bribe a law enforcer with USD 355k in USDT cryptocurrency to avoid exposure of his illegal activities. Read the full article.
- NABU and SAPO charged the former deputy minister of agrarian policy and a district state administration deputy head with abuse of office and forgery, causing millions in state damages. In 2018, they illegally secured UAH 27 million (USD 0.6 million) in state aid for a plant-growing enterprise, falsely claiming it was for planting material. In fact, the funds were used as contribution to the company’s charter capital to be paid up by the founder. Read the full article.
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Conflict of Interest
March 2025
- The National Agency on Corruption Prevention (NACP) has reported an administrative offense by the former head of the Vasylkiv City District Court of Kyiv Region for failing to disclose a conflict of interest. The Supreme Court upheld a decision to confiscate part of the ex-judge’s apartment, valued at over UAH 3.6 million (USD 0.09 million), recognizing it as an unjustified asset. Read the full article.
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