White-Collar Crime 2025 Comparisons

In Ukraine, criminal offences are divided into two main categories: crimes and misdemeanours.

Crimes are further classified by severity into minor, serious, and particularly serious offences, with the classification determined by the punishment prescribed in law.

Every crime must contain certain essential elements:

• subject;
• object;
• objective aspect (an act or omission); and
• subjective aspect (intent and culpability).

The presence of a specific purpose or motive within the subjective aspect is not necessary for an act to be recognised as a crime.

Importantly, criminal liability is not limited to completed offences. Attempts to commit a crime – whether successful or not – and, in certain circumstances, preparations for committing a crime are also punishable under Ukrainian law.

In all criminal proceedings, including those concerning white-collar offences, the burden of proof rests exclusively with the prosecution.

This principle is enshrined in Article 62 of the Constitution of Ukraine, which affirms that every person is presumed innocent until proven guilty by a court of law. No individual may be subjected to criminal penalties unless their guilt is established through due legal process, and the accused bears no obligation to prove their innocence.

While Ukrainian criminal procedure legislation does not expressly define the standard of proof in criminal cases, established judicial practice applies the “beyond a reasonable doubt” standard. This requires that the evidence presented must eliminate all reasonable alternative explanations, leaving only the conclusion that the accused committed the alleged offence.

Ukrainian legislation allows for the prosecution of individuals for criminal offences, and provides for the application of criminal law measures to legal entities.

The Criminal Code of Ukraine outlines statutes of limitations both for individuals (Article 49) and for legal entities regarding criminal liability.

Statute of Limitations for Prosecution of Individuals

The statute of limitations varies according to the severity of the offence:

• two years for a misdemeanour where the punishment is less severe than restriction of liberty;
• three years for a misdemeanour where restriction of liberty is prescribed;
• three years for a minor crime punishable by no more than two years of imprisonment;
• five years for a minor crime, except for the above exception;
• ten years for a serious crime; and
• fifteen years for an especially serious crime.

The statute of limitations begins from the date the offence is completed and continues until a court sentence enters into force. Notably, there are no special provisions regarding ongoing offences in relation to the statute of limitations.

Additionally, certain offences are exempt from the statute of limitations entirely. These include:

• crimes against national security;
• acts of torture; and
• certain crimes against peace and humanity – eg:
1. planning and waging aggressive war;
2. violations of the laws of war;
3. use of weapons of mass destruction; and
4. genocide.

Statute of Limitations for Applying Criminal Law Measures to Legal Entities

The statute of limitations for legal entities also depends on the gravity of the offence, as follows:

• three years for a misdemeanour;
• five years for a minor crime;
• ten years for a serious crime; and
• fifteen years for an especially serious crime.

This period begins from the date the authorised person committed the offence that serves as the basis for applying measures to the legal entity.

Extraterritorial Reach

In addition to its domestic applicability, Ukrainian criminal legislation extends to actions committed outside Ukraine under the following conditions:

• Crimes committed abroad by Ukrainian citizens or stateless persons permanently residing in Ukraine are subject to prosecution under the Criminal Code of Ukraine, unless international treaties specify otherwise.
• Foreigners or stateless persons who do not permanently reside in Ukraine may be held criminally liable in Ukraine for serious or especially serious crimes committed outside Ukraine, if these crimes are against Ukrainian citizens’ rights and freedoms or against Ukraine’s interests.
• Foreigners or stateless persons who do not permanently reside in Ukraine and who commit crimes abroad are subject to Ukrainian jurisdiction if such jurisdiction is stipulated by international treaties.
• If foreigners or stateless persons outside Ukraine commit offences related to abuse of influence, or offer, promise or provide unlawful benefits to Ukrainian officials or accept such benefits, they may be prosecuted under Ukrainian law.

Cross-Border Co-Operation

Ukraine participates in approximately 100 bilateral and multilateral treaties that address mutual legal assistance in criminal matters and extradition. Key multilateral treaties include:

• the UN Convention against Transnational Organized Crime (2000);
• the UN Convention against Corruption (2003);
• the European Convention on Mutual Assistance in Criminal Matters (1959);
• the European Convention on the Extradition of Offenders (1957);
• the European Convention on Combating Terrorism (1977);
• the Council of Europe Convention on Laundering, Search, Seizure and Confiscation of Proceeds of Crime (1990);
• the Inter-American Convention on Mutual Assistance in Criminal Matters (1992); and
• the Convention on Extradition (1933).

These treaties facilitate co-operation and mutual legal assistance in criminal investigations and proceedings, enhancing Ukraine’s ability to address cross-border crime effectively.

Involvement in International Task Forces

• Ukraine is in the process of acceding to the OECD Anti-Bribery Convention: in 2022 Ukraine officially submitted an application to join the OECD and in 2023 was granted participant status in the Working Group on Bribery.
• Ukraine is an active member of INTERPOL (since 1992). The National Central Bureau (NCB) of INTERPOL in Ukraine is the Department of International Police Cooperation of the National Police of Ukraine.
• Within the framework of European integration, Ukraine has strengthened its co-operation with Europol and Eurojust. Although not yet a full member, Ukraine exchanges information and co-ordinates actions in cases with a cross-border element.
• Ukrainian law enforcement agencies also interact with international financial institutions, including the World Bank and regional development banks, in matters concerning the recovery of illicitly removed assets.
• Ukraine is not a member state of the Financial Action Task Force.

Criminal Law Measures

Ukrainian legislation employs the term “criminal law measures” rather than “criminal liability” in relation to legal entities. This distinction arises because legal entities are not defined as subjects of crime per se; however, certain measures can be applied to them in specific circumstances.

The criminal law measures applicable to legal entities include:

• fines – as of 2025, the maximum fine amounts to UAH127.5 million (EUR2.6 million);
• confiscation of property; and
• liquidation.

These measures may be imposed under the following conditions.

Criminal acts committed by authorised persons

When committed by authorised persons on behalf, and in the interests, of a legal entity, crimes included are:

• money laundering;
• use of funds from illegal narcotics;
• bribery of officials (regardless of ownership type);
• bribery of public service providers; and
• abuse of influence.

Failure to prevent corruption

This occurs where authorised persons fail to fulfil their duties regarding corruption prevention, resulting in the commission of any of the aforementioned crimes.

Crimes against national and public security

These include certain crimes committed by authorised persons on behalf of a legal entity that affect national security, public security or international legal order, or that involve terrorist activities.

Crimes against sexual integrity and public morality

These include crimes committed by authorised persons related to a minor, concerning sexual freedom, public order and morality, when done in the interests of the legal entity.

Crimes are deemed to be committed in the interests of a legal entity if they:

• result in an unlawful benefit to the entity;
• create conditions for such a benefit; or
• aim to evade legal liability.

Importantly, the imposition of criminal law measures does not preclude the direct criminal liability of the authorised persons within the legal entity.

In cases of reorganisation, criminal law measures may also be applied to the legal successors who inherit the property, rights and obligations related to the criminal offences.

Liability of parent, subsidiary and group companies

In Ukraine, a legal entity bears liability only for those criminal offences committed by its authorised representatives on its behalf and in its interests.

Liability of a parent company for the actions of its subsidiary, or of a subsidiary for the actions of its parent company, is not provided for under national legislation and may only be established within internal policies and corporate governance rules.

In Ukraine, there are no distinct sentencing guidelines specifically for white-collar crimes. Judges follow general sentencing principles as outlined in the Criminal Code of Ukraine.

Under Ukrainian law, the court imposes sentences within the range established by the legal provisions applicable to the offence committed. The court considers several factors when determining the appropriate sentence, including:

• the severity of the offence;
• the offender’s identity; and
• any mitigating or aggravating circumstances.

Legislation allows both for less severe and more severe sentences than those prescribed by the standard sanction for a crime:

• less severe sentences – these may be imposed if there are significant mitigating circumstances and a substantial reduction in the crime’s gravity; and
• more severe sentences – these may be applied in cases involving multiple offences or cumulative sentencing.

Additionally, if the court approves a reconciliation agreement (between the accused and the victim) or a plea agreement (between the accused and the prosecutor), it will impose a sentence that reflects the terms agreed upon by the parties involved.

Mitigating Factors

The factors considered for the mitigation of punishment are listed in Article 66 of the Criminal Code. This list is not exhaustive. In the sphere of white-collar crime, the following may apply.

• Personal conduct and efforts towards redress:
1. confession, genuine remorse, or active co-operation in the detection of the offence; and
2. voluntary compensation for damages caused or rectification of the harm inflicted.

• Personal circumstances of the defendant:
1. state of health; and
2. absence of previous convictions, and good character.

• Motives and degree of guilt – commission of the offence as a result of severe personal, family, or other circumstances:
1. under threat, coercion, or due to material, professional, or other dependency; or
2. under the influence of strong emotional distress.

In addition, the court may take into account other circumstances that mitigate punishment, depending on the specific facts of the case.

In Ukraine, a civil claim for damages arising from a crime may be brought in one of two forums:

• civil court – by initiating proceedings within the civil justice system; or
• criminal court – by submitting the claim to the court handling the related criminal case, provided it is filed before the start of the trial.

If a civil court dismisses the claim, the claimant may not subsequently pursue the same claim within the criminal proceedings. Likewise, if a criminal court rejects the claim, the claimant loses the right to seek compensation in civil proceedings.

However, if no civil claim is filed during the criminal proceedings, or if such a claim remains unresolved, the claimant retains the right to bring the matter before a civil court.

Where multiple individuals suffer damage from the same crime, each must file a separate civil claim, as Ukrainian law does not provide for collective actions in these circumstances.

Ukrainian legislation does not specifically categorise crimes as “white-collar”. Instead, such offences are generally classified under economic crimes, corruption offences and crimes committed by officials.

Corruption Crimes

Corruption crimes and those related to corruption hold a significant position within this category. Ukraine has established a specialised anti-corruption framework to address these crimes.

The National Anti-Corruption Bureau (NABU) is responsible for investigating corruption offences and related crimes. NABU detectives investigate cases involving:

• embezzlement;
• unlawful seizure of property;
• money laundering;
• misappropriation of budget funds;
• issuance of illegal regulatory acts; and
• bribery of employees within public legal entities.

They also handle crimes associated with the provision of public services.

The Specialised Anti-Corruption Prosecutor’s Office (SAPO) works alongside NABU in prosecuting corruption-related cases.

The High Anti-Corruption Court handles first-instance trials for corruption crimes. The Appellate Chamber of the High Anti-Corruption Court addresses appeals in corruption cases.

Other Law Enforcement Agencies

The Economic Security Bureau (ESB) investigates economic crimes including embezzlement and misuse of budget funds, particularly when involving budgetary compensation or regulatory acts that unlawfully affect budget revenues or expenditures. The ESB also handles bribery of employees in non-public legal entities and abuse of power in specific cases.

The State Bureau of Investigation (SBI) investigates crimes committed by high-ranking officials, including former presidents, prime ministers, government members, people’s deputies and high-ranking prosecutors. The SBI also addresses crimes against the military service order, except for state secrets-related disclosures.

The National Police of Ukraine investigates crimes not under the jurisdiction of NABU, the ESB, the SBI or the Security Service of Ukraine.

Procedural Oversight

Prosecutors of the Prosecutor General’s Office oversee pre-trial investigations and public indictments for cases handled by the ESB, SBI and National Police.

Prosecutors of the Specialised Anti-Corruption Prosecutor’s Office manage cases investigated by NABU.

Court Proceedings

The High Anti-Corruption Court prosecutes corruption and related crimes.

Courts of general jurisdiction handle other white-collar crimes not specifically related to corruption.

Institutional Developments in 2025

In 2025, no global changes occurred that would affect enforcement. Although attempts were made to limit the powers of NABU and SAPO, public pressure led to the reversal of these changes, and the authorities regained their full scope of functions. At the same time, a new Prosecutor General was appointed in 2025, who now co-ordinates the activities of prosecutors.

State policy and political pressure may influence investigative priorities and the timing of enforcement, as well as affect the allocation of resources and prioritisation of cases. Nevertheless, the authorities continue to exercise their powers in accordance with the law.

Ukrainian criminal procedural law provides several grounds for initiating an investigation.

• Victim or informant request – most investigations begin following a complaint from a victim or a report from any individual who becomes aware of a crime.
• Independent discovery – proceedings may also be initiated when the prosecution independently uncovers evidence suggesting the commission of a criminal offence. This often occurs through reports, acts, or official documents from regulatory or supervisory bodies revealing violations (for example, tax irregularities or unlawful banking operations) that result in financial losses to the state or other entities.

Any information indicating the possible commission of a crime must be entered into the Unified State Register of Pretrial Investigations within 24 hours of receiving the application or discovering the evidence.

Law enforcement agencies, operating under the procedural oversight of the Prosecutor General’s Office or the Specialised Anti-Corruption Prosecutor’s Office, are authorised to undertake a range of actions necessary for crime investigation. Their powers include the following.

Demanding Evidence

Agencies can request documents and items essential for the investigation from individuals, legal entities, state authorities and other entities. Such requests (made by detectives) do not require prior approval from a prosecutor or investigating judge.

Interrogating Witnesses

Agencies are empowered to interrogate witnesses, with legal limitations on the duration of interrogation (no more than two hours at a time and eight hours per day). There is no limit on the number of times a person can be interrogated. Witnesses have the right to refuse to testify against themselves, their close relatives or family members, and the right to withhold legally protected secrets (eg, confessions, medical records, notarial and lawyer–client communications). Providing false testimony may result in criminal liability.

Conducting Searches

Searches of individuals or legal entities require a permit from an investigating judge. The judge’s order must specify the investigators authorised to conduct the search and the items or documents that can be seized. The prosecution must demonstrate that the items or documents are crucial for the investigation and are located at the premises, and that the search is the most effective course of action. Search permits are valid for up to one month and can be used only once. A new permit is required for any subsequent searches.

Performing Secret Investigative Actions

These actions may include monitoring private communications, overseeing criminal activities and real-time surveillance of bank accounts. Such measures are carried out based on decisions made by investigators, prosecutors or investigating judges, depending on the type of action.

Tracing, Freezing and Seizure of Digital Assets

Ukraine does not have specific legislative regulation for the tracing, freezing, and seizure of digital assets.

At the same time, law enforcement authorities actively trace, arrest (freeze), and seize cryptocurrencies, tokens, and other digital assets, relying on general provisions, in particular the Criminal Procedure Code (CPC) and the Laws on Prevention and Counteraction to Legalisation (Laundering) of the Proceeds of Crime and on Financial Monitoring. Such measures are applied where digital assets constitute physical evidence, have been obtained unlawfully, or are subject to confiscation.

• Arrest and seizure (confiscation) – carried out on the basis of an investigating judge’s ruling, in accordance with the CPC requirements.
• Freezing (suspension of transactions) – legally possible under the above-mentioned Laws on Anti-Money Laundering and Financial Monitoring. In practice, however, this directly depends on the jurisdiction and willingness or unwillingness of cryptocurrency exchanges to co-operate with law enforcement authorities.

Ukrainian legislation does not currently regulate the use of artificial intelligence by law enforcement authorities, nor does it prohibit it. Accordingly, the application of such technologies in the investigation of economic or “white-collar” crimes remains at the discretion of law enforcement and state authorities.

Reports from law enforcement bodies do not provide information on whether artificial intelligence is used or not.

The practice of conducting internal investigations is evolving in Ukraine. Currently, there is no specific legislative framework governing internal investigations within private companies. However, it is increasingly common for companies, particularly international ones operating in Ukraine, to establish their own internal policies and procedures for managing these investigations.

These internal policies typically address the protocols and procedures for conducting investigations, reflecting a growing trend towards formalising investigative practices within the corporate sector.

In Ukraine, internal corporate investigations are primarily influenced by data protection and labour legislation.

• The Law on Personal Data Protection regulates the collection, processing, and storage of employees’ personal information. Companies are obliged to ensure confidentiality and restrict access to such data.
• Internal investigations are often linked to disciplinary matters; therefore, when conducting such investigations, companies must comply with procedures established by labour law so as not to infringe employees’ rights.
• Furthermore, an internal investigation must not violate the right to privacy. In Ukraine, unlawful collection, use, or disclosure of private information – including personal data – constitutes a criminal offence.

With regards to interaction with law enforcement authorities, companies are not legally obliged to provide the results of their internal investigations.

The pre-trial investigation concludes with the investigator preparing an indictment, which must be approved by the prosecutor before being submitted to the court. In exceptional cases, the prosecutor may prepare the indictment if they disagree with the version submitted by the investigator.

Once the indictment is filed, the prosecutor represents the public prosecution in court. For corruption-related crimes, the prosecution is led by a prosecutor from the Specialised Anti-Corruption Prosecutor’s Office. For other white-collar crimes not involving corruption, the Prosecutor General’s Office handles the prosecution. The role of the prosecutor is to present and substantiate the charges in court to secure the criminal liability of the accused.

If, during the trial, the prosecutor determines that the evidence does not support the indictment, they are obligated (in consultation with a higher-level prosecutor) to withdraw the indictment.

The court is responsible for deciding whether an individual will be held criminally liable or whether criminal law measures will be applied to a legal entity, based on the merits of the case.

Deferred prosecution agreements do not currently exist under Ukrainian law, and their introduction into Ukraine in the near future seems unlikely.

Ukrainian legislation does not specifically address corporate fraud offences separately from general criminal law. However, within the corporate context, the following general offences are commonly encountered.

Fraud (Article 190 of the Criminal Code of Ukraine)

Fraud involves deceitfully taking someone else’s property or acquiring property rights through deception or breach of trust.

Aggravating circumstances include:

• commission by a group of individuals or an organised group;
• during a state of war or emergency;
• in large or especially large amounts; and
• using electronic computing equipment unlawfully.

Depending on the existence of aggravating circumstances, the punishment for fraud ranges from three to 12 years’ imprisonment, or a fine from UAH34,000 (EUR700) to UAH136,000 (EUR2,800).

Depending on the presence of aggravating factors, the penalty for fraud is three to 12 years of imprisonment or a fine of between UAH3.028 million (EUR66,400) and UAH12.112 million (EUR265,800).

Misappropriation, Embezzlement or Seizure of Property (Article 191 of the Criminal Code of Ukraine)

Misappropriation

This involves illegally retaining or withholding property that was lawfully possessed by another, intending to use it for personal gain or the benefit of others.

Embezzlement

This involves unlawfully spending or transferring property entrusted to or managed by the offender.

Appropriation

This involves illegally transferring property for personal use that was not originally entrusted to the offender but that was managed owing to their official position.

Aggravating factors include:

• repeated offences;
• commission by a group of persons or an organised group;
• during a state of war or emergency;
• in large or especially large amounts; and
• abuse of official position.

The punishment for these offences ranges from three to 12 years’ imprisonment, or fines from UAH34,000 (EUR700) to UAH85,000 (EUR1,700).

Forgery (Article 366 of the Criminal Code of Ukraine)

Forgery involves:

• the issuance of false official documents;
• entering false information into official documents; or
• otherwise falsifying documents.

Aggravating circumstances include grave consequences resulting from the forgery.

Sanctions for forgery include a fine of up to UAH68,000 (EUR1,400) or imprisonment for up to five years, together with an additional prohibition on engaging in certain activities for a period of up to three years.

Ukrainian criminal procedural legislation addresses active and passive bribery, applicable in both the public and private sectors.

Public Sector Bribery

Bribery in the public sector involves:

• offering or promising an unlawful benefit to an official or a third party;
• providing such a benefit; or
• requesting that an official accept such an offer or demand in exchange for performing or refraining from certain actions in favour of the person making the offer or a third party.

This applies to officials of state or local self-government bodies in Ukraine, as well as to officials of foreign states, international organisations and foreign judges.

The offence also involves offering or promising an unlawful benefit to auditors, notaries, appraisers or other professionals engaged in public services, including:

• experts;
• arbitration managers;
• private executors;
• independent mediators;
• labour arbitration members; or
• arbitrators during their official functions.

Criminal liability arises for offering, promising or providing such benefits, or for the acceptance of such offers or benefits by these professionals.

Private Sector Bribery

In the private sector, criminal liability arises for:

• offering or promising an unlawful benefit to an official of a private legal entity;
• providing such a benefit; or
• requesting or accepting such a benefit in return for performing or refraining from specific actions.

Abuse of Influence

Criminal liability extends to both active and passive forms of abuse of influence. This includes offering, promising or providing an improper benefit to a person with the intent to influence decisions made by individuals authorised to perform state or local self-government functions. Acceptance of such offers or benefits also constitutes grounds for criminal liability.

In summary, Ukrainian legislation criminalises both the act of offering or promising unlawful benefits and the acceptance of such benefits, encompassing both public and private sectors and extending to various forms of influence abuse.

There are no legislative requirements obliging private individuals or employees of private companies to report corruption. For them, it is a right rather than an obligation. At the same time, if a person conceals information in a situation where they are themselves a participant in a corruption scheme, such behaviour may be regarded as complicity in the offence.

The situation differs for public officials: the Law on Prevention of Corruption obliges them to report an offer of unlawful benefit (Article 24) and conflicts of interest (Article 28). Failure to do so entails disciplinary sanctions, up to and including dismissal.

Consequences of failure to report:

• for private citizens and employees of private companies – none; and
• for public officials – disciplinary liability, which may include dismissal from office.

Criminal liability in Ukraine arises only for active concealment of a serious crime; mere failure to report is not treated as such.

Insider Dealing

Under Article 232-1 of the Criminal Code of Ukraine, criminal liability for insider dealing arises in the following cases.

• Unlawful use of insider information – the misuse of insider information results in:
1. unjust profit – receipt of undue profit by the individual or a third party;
2. avoidance of losses – evading significant financial losses; and
3. harm to interests – substantial damage to individuals, legal entities or public interests.

• Transactions based on insider information – engaging in transactions using insider information leads to:
1. significant unjust profit – acquisition of substantial undue profit;
2. avoidance of losses – preventing significant losses by market participants or others; and
3. damage to interests – notable harm to individuals, legal entities or public interests.

The maximum penalty for such actions is a fine of up to UAH170,000 (EUR3,500), as well as disqualification from holding certain positions or engaging in specific activities for up to three years.

Market Abuse

Articles 222-1 and 222-2 of the Criminal Code of Ukraine address criminal liability for market manipulation.

For manipulation on organised markets, criminal liability arises if manipulative actions result in:

• significant profits – receipt of considerable profits by the individual or others;
• avoidance of losses – preventing significant financial losses; and
• damage to interests – significant harm to individuals, legal entities or public interests.

The maximum penalty for market manipulation on organised markets includes a fine of up to UAH170,000 (EUR3,500) and a prohibition on holding certain positions or engaging in specified activities for up to three years.

For manipulations in the energy market, the sanctions are stricter, with a maximum fine of up to UAH1.4 million (EUR29,000).

Criminal Banking Law

Criminal offences related to banking activities include:

• insolvency of banks – bringing a bank to insolvency (Article 218-1);
• misuse of bank secrecy – unlawful use of confidential banking information (Article 231);
• disclosure of banking secrets – intentional disclosure of banking secrets on capital and commodity markets (Article 232);
• database and reporting violations – violations related to maintaining depositor databases or forming reports (Article 220-1); and
• falsification and concealment – falsification of financial documents and reports, or concealing insolvency or grounds for revoking a licence (Article 220-2).

These offences carry significant legal consequences aimed at maintaining the integrity of banking and financial systems in Ukraine.

Tax Evasion (Article 212 of the Criminal Code of Ukraine)

Article 212 of the Criminal Code of Ukraine addresses criminal liability for intentional tax evasion, specifically for evading taxes, fees, or mandatory payments within the taxation system. Criminal liability arises where such actions result in significant non-payment to state budgets or special-purpose funds, defined as amounts exceeding UAH4.5 million (EUR93,000).

Aggravating circumstances include:

• Group conspiracy – where the offence is committed by a group of individuals acting in concert;
• Scale of non-payment – where the unpaid amount qualifies as large (UAH7.5 million/EUR155,000) or especially large (UAH10.5 million/EUR217,000).

The maximum sanction includes a fine of up to UAH425,000 (EUR8,700) and disqualification from holding certain positions or engaging in specific activities for up to three years. Confiscation of property is also possible. Notably, imprisonment is not prescribed as a sanction for this offence.

Relief from liability – a person may be exempted from criminal liability if, before being formally notified of suspicion, they pay the outstanding taxes and compensate for any damages caused to the state.

Obligations to Prevent Tax Evasion

The Tax Code of Ukraine explicitly requires taxpayers to pay taxes fully and on time, maintain proper records, file returns, and retain primary documentation.

Legal entities have additional internal obligations, including ensuring accurate accounting and maintaining internal controls.

Reporting Requirements

• Tax returns and calculations – regular filing of tax reports in accordance with the Tax Code.
• Financial statements – required from enterprises under the Law on Accounting and Financial Reporting.
• Special reports – including transfer pricing documentation (controlled transactions), ultimate beneficial ownership disclosures, and financial monitoring reports for banks and companies.

Failure to Prevent Tax Evasion

• Criminal liability – not applicable; only intentional evasion is punishable.
• Administrative and financial liability – possible, eg, for failure by directors or accountants to submit reports, improper bookkeeping, or lack of adequate financial control.
• Civil liability – may arise where shareholders, investors, or creditors suffer damages due to a company’s tax violations.

Sanctions

• Administrative – fines for failure to submit or late submission of reports, or for accounting irregularities.
• Financial – penalties and surcharges for late payment of tax, or suspension of tax invoices.
• Civil liability – recovery of damages caused to the state or counterparties through falsification of tax documents.
• Criminal liability – in cases of intentional tax evasion or falsification.

In Ukraine, companies are required to maintain accurate accounting records and financial statements that reflect their financial condition and operational results. However, direct criminal liability for improper accounting or inaccurate financial statements is generally not established.

Exceptions for Financial Institutions

Falsification of financial documents

For financial institutions, criminal liability arises under Article 220-2 of the Criminal Code of Ukraine in cases of:

• falsifying financial documents;
• concealing insolvency; or
• misrepresenting the grounds for revocation of a financial institution’s licence.

Constituent elements of the offence

• Object – the statutory procedure for conducting financial activities and financial reporting of institutions.
• Objective aspect:
1. falsification of financial documents;
2. concealment of insolvency; or
3. misrepresentation of grounds for licence revocation.
• Subject – an official of a financial institution (director, chief accountant, or other person responsible for financial reporting).
• Subjective aspect – direct intent (awareness of the unlawful nature of the act and desire to achieve the result).

Sanctions

The maximum penalty is restriction of liberty for up to four years, together with disqualification from holding certain positions or engaging in specific activities for up to three years.

Liability for Non-Financial Entities

Officials of non-financial legal entities may incur criminal liability under the following provisions.

Official negligence (Article 367 of the Criminal Code of Ukraine)

Liability arises for failure to perform, or improper performance of, official duties due to negligence, resulting in significant damage to protected rights, freedoms, public or state interests, or the interests of legal entities.

Constituent elements of the offence

• Object – legally protected interests of state authorities and legal entities, the violation of which may result from the negligence of an official.
• Objective aspect – failure to perform, or improper performance of, official duties due to careless or negligent attitude, causing material damage to the rights and interests of individuals, state or public interests, or legally protected interests of legal entities.
• Subject – a special subject: an official.
• Subjective aspect – most commonly manifested as negligence with respect to both the act itself and its consequences.

The maximum penalty is imprisonment for up to eight years, along with disqualification from holding certain positions or engaging in specific activities for up to three years.

Official forgery (Article 366 of the Criminal Code of Ukraine)

This encompasses preparing and issuing knowingly false official documents, or entering knowingly false information into official records.

Constituent elements of the offence

• Object – legally protected relations in the sphere of official activity, as well as the rights and lawful interests of the state, legal entities, and individuals.
• Objective aspect – issuing knowingly false official documents, inserting knowingly false information into such documents, or otherwise falsifying them.
• Subject – a special subject: an official (director, officer, or accountant).
• Subjective aspect – direct intent (the official is aware of the unlawful nature of their actions and intends to cause the result).

The maximum penalty is imprisonment for up to five years, together with disqualification from holding certain positions or engaging in specific activities for up to three years.

In Ukraine, criminal liability is not specifically established for breaches of economic competition law. However, the Law of Ukraine on Protection of Economic Competition provides for a range of penalties for non-compliance, including the following.

1. Anti-competitive concerted practices – these include:

• fixing prices or other conditions for the purchase or sale of goods;
• distorting the outcome of auctions; or
• significantly restricting competition.

The constituent elements of the offence may be defined as follows.

• Subject – a legal entity or its officers acting on behalf of the undertaking.
• Object – economic relations within the market that ensure free competition.
• Objective element:
1. concerted actions with other market participants relating to prices, terms of sale, allocation of markets or customers;
2. restricting participation in auctions; or
3. creating barriers for other market participants.
• Subjective element – intent to achieve an anti-competitive effect and to obtain economic benefit.

2. Abuse of a dominant position – engaging in practices that exploit a monopoly position in the market.

The constituent elements of the offence are as follows.

• Subject – a legal entity holding a dominant position in the market (market share as defined by law or by the Antimonopoly Committee of Ukraine (AMCU)).
• Object – market competition and access to the market for other participants.
• Objective element – deliberately creating obstacles for competitors, setting discriminatory prices, refusal to sell goods, limiting supply volumes, or other conduct that distorts the market.
• Subjective element – intent to secure economic gain through the use of a monopoly position.

3. Failure to comply with AMCU decisions – non-implementation or partial implementation of decisions issued by the Antimonopoly Committee of Ukraine.

The constituent elements of the offence are as follows.

• Subject – a legal entity subject to an AMCU decision.
• Object – fulfilment of the requirements of the Antimonopoly Committee.
• Objective element – failure, or only partial fulfilment, of the Committee’s decisions.
• Subjective element – intent or conscious disregard of the obligation to comply with the decision.

4. Unauthorised concentration – mergers or acquisitions requiring AMCU approval but carried out without such approval.

The constituent elements of the offence are as follows.

• Subject – legal entities carrying out mergers or acquisitions.
• Object – market structure and competition between undertakings.
• Objective element:
1. implementation of a concentration without notification or approval by the AMCU; or
2. acquisition of control over competitors in breach of the law.
• Subjective element – intent to obtain advantages by unlawfully consolidating market power.

5. Submission of false information – providing incorrect or misleading information to the AMCU or other authorities.

The constituent elements of the offence are as follows.

• Subject – a legal entity or its representatives.
• Object – the AMCU’s activities in monitoring the market and ensuring competition.
• Objective element – deliberate provision to the AMCU or other authorities of false data regarding prices, transactions, market shares, or production volumes.
• Subjective element – intent to mislead public authorities with a view to evading oversight or liability.

Sanctions for Violations

Fines

The maximum fine is 10% of the revenue from product sales in the year preceding the fine’s imposition. If the unlawful profit exceeds 10% of this revenue, the fine can be up to three times the amount of the illicit profit.

Forced division

This sanction is applied in cases of monopoly abuse, requiring the division of the business entity. However, it is not applicable if organisational or territorial separation is impossible, or if there are significant technological interconnections between the enterprises or their divisions.

Damage compensation

Individuals or entities harmed by violations of competition laws can seek compensation through commercial courts.

These measures aim to enforce compliance and address anti-competitive practices effectively.

Ukrainian criminal legislation prescribes liability for various offences relating to the protection of consumer rights. These include the following.

Introduction of Dangerous Products

This offence involves the intentional placing on the Ukrainian market of products which do not comply with established safety standards. Such products may be either foodstuffs or non-food items.

Criminal liability arises where the total value of the dangerous products exceeds UAH757,000 (EUR15,670).

Constituent elements of the offence

• Object – the protection of human life and health, public health and the environment.
• Objective element – the placing on the market of products (the first availability of a product on the market of Ukraine, whether by sale or otherwise, for the purposes of distribution, consumption or use in the course of business activity) which do not meet established safety standards and which may pose a risk to life, health or the environment.
• Subject – any natural person capable of liability who manufactures or places such products on the market (in the case of a legal entity – directors, representatives or other officials who took or authorised the relevant actions).
• Subjective element – intent (awareness of the product’s danger and potential for harm).

The penalty for this offence may include a fine of up to UAH136,000 (approximately EUR2,800), as well as a prohibition on holding certain positions or engaging in certain activities for up to three years.

Sale of Radioactively Contaminated Products

This offence covers the procurement, processing, transportation or sale of foodstuffs or other products contaminated with radioactive substances beyond permissible levels, which pose a risk of death or injury, or which have in fact caused death or injury.

Constituent elements of the offence

• Object – human life and health, and public safety.
• Objective element – the procurement, processing, transportation or sale of foodstuffs or other products contaminated with radioactive substances which may pose a threat to life or health.
• Subject – any natural person capable of liability who carries out such actions (in the case of a legal entity – directors, representatives or other officials who took or authorised the relevant actions).
• Subjective element – intent (awareness of the contamination and the associated danger).

The maximum penalty for this crime is imprisonment for up to five years.

Falsification of Medicinal Products

This offence includes the manufacture, acquisition, transportation, transfer, storage for the purpose of sale, or sale of counterfeit medicinal products.

Constituent elements of the offence

• Object – human health, and the safety of medicinal products.
• Objective element – the manufacture, acquisition, transportation, transfer, storage for the purpose of sale, or sale of medicinal products which are falsified (ie, do not comply with standards of quality, composition or labelling).
• Subject – any natural person capable of liability (in the case of a legal entity – directors, representatives or other officials who took or authorised the relevant actions).
• Subjective element – intent (awareness of the falsification and its potential harmful effect).

The maximum sanction for this crime is imprisonment from ten to 15 years, or life imprisonment if the falsified products result in death or serious consequences, or if they involve particularly large quantities.

Ukrainian criminal law addresses various offences related to cybersecurity, including the following.

Unauthorised Interference in Computers and Networks (Article 361 of the Criminal Code)

This crime involves unauthorised actions affecting computers, computer systems and telecommunications networks.

Aggravating factors include:

• repeated offences;
• actions by a group in conspiracy;
• information leakage, loss, forgery or distortion;
• significant damage or risk of serious technological accidents, environmental disasters or mass harm; and
• commission during martial law.

The maximum penalty is 15 years of imprisonment, with an additional ban on holding certain positions or engaging in specific activities for up to three years.

Creation and Distribution of Malicious Software (Article 361-1 of the Criminal Code)

This covers the development, distribution or sale of malware and other harmful technical means.

Aggravating factors include:

• repeated offences;
• actions by a group in conspiracy; and
• significant damage caused.

The maximum penalty is five years of imprisonment.

Unlawful Sale or Distribution of Restricted-Access Information (Article 361-2 of the Criminal Code)

This involves the unauthorised sale or distribution of restricted information stored in computers or other media.

Aggravating factors include:

• repeated offences;
• actions by a group in conspiracy; and
• significant damage caused.

The maximum penalty is five years of imprisonment.

Unlawful Actions With Information (Article 362 of the Criminal Code)

This includes unauthorised alteration, blocking, destruction, interception or copying of information processed or stored in computers and networks.

Aggravating factors include:

• repeated offences;
• actions by a group in conspiracy; and
• significant damage caused.

The maximum penalty is six years of imprisonment, with an additional ban on holding certain positions or engaging in specific activities for up to three years.

Violation of Computer Operation Rules (Article 363 of the Criminal Code)

This covers violations of rules for operating computers, systems and networks, or for protecting information processed by them.

Mandatory conditions include causing significant damage and the perpetrator being responsible for the exploitation of the systems.

The maximum penalty is three years of restriction of freedom, with an additional ban on holding certain positions or engaging in specific activities for the same period.

Intentional Mass Distribution of Unsolicited Messages (Article 363-1 of the Criminal Code)

This involves sending mass unsolicited messages that disrupt or terminate the operation of computers, networks or telecommunications systems.

Aggravating factors include:

• repeated offences;
• actions by a group in conspiracy; and
• significant damage caused.

The maximum penalty is five years of imprisonment, with an additional ban on holding certain positions or engaging in specific activities for up to three years.

Ukrainian legislation does not currently provide for any liability, whether administrative or criminal, for the violation or circumvention of sanctions. However, Ukraine is expected to introduce criminal liability for such acts in the near future.

Under Ukrainian law, criminal liability arises for the concealment of serious or especially serious crimes that were not prearranged (Article 396 of the Criminal Code).

Such concealment includes:

• hiding the perpetrator, traces of the crime, or the instruments and means used to commit the offence;
• concealing the acquisition or sale of property obtained through criminal activity; and
• legalising (laundering) money or other assets derived from criminal activity.

The constituent elements of the offence are as follows.

• Object – the administration of justice and the legality of the investigation.
• Objective element – active conduct aimed at deliberately concealing a crime, thereby hindering its detection or preventing the perpetrator from being held accountable.
• Subject – any person capable of liability.
• Subjective element – intent (awareness of the criminal act and conscious concealment).

The maximum penalty for such concealment is imprisonment for up to three years.

Where an individual has pre-emptively agreed to conceal a crime – regardless of its severity – they are considered an accomplice. In such cases, the penalty is determined in accordance with the nature of the underlying offence.

Under Ukrainian criminal law, liability extends beyond the direct perpetrator of an offence to include individuals who “direct” or “facilitate” the commission of a crime. Such individuals are considered accomplices and are subject to the same penalties as the principal offender or instigator of the offence. This principle also applies to offences for which legal entities may incur criminal liability.

As these persons are regarded as accomplices and subject to the same sanctions as the primary perpetrator or instigator, the constituent elements of the offence are determined by the specific type of criminal act in which they participated.

Under Article 209 of the Criminal Code of Ukraine, the legalisation of property obtained through criminal means constitutes a criminal offence. This encompasses the following.

• The acquisition, possession, use or disposal of property where the circumstances indicate that it was obtained through criminal activities. This includes financial transactions involving such property, as well as its movement or alteration.
• Actions aimed at concealing or disguising the origin, ownership, rights, sources or location of such property.

A key requirement is that the individual knew, or ought to have known, that the property was obtained directly or indirectly through criminal means.

The constituent elements of the offence of legalisation (money laundering) are as follows.

• Object – the established order of circulation of funds and property, and economic security.
• Objective element – financial transactions or other actions with property knowingly obtained through criminal means, undertaken to confer a lawful appearance.
• Subject – a competent (sane) person.
• Subjective element – direct intent, with the specific purpose of concealing the illicit origin of the property or giving it a lawful appearance.

The maximum penalty for this offence is imprisonment for up to 12 years, together with deprivation of the right to hold certain positions or engage in specific activities for up to three years, and confiscation of the property.

Additionally, intentional breaches of anti-money laundering regulations – such as failure to submit, late submission, or submission of false information regarding financial transactions subject to monitoring – are also criminalised. Penalties for such breaches include:

• fines of up to UAH85,000 (approximately EUR1,700);
• probation supervision for up to three years; and
• deprivation of the right to hold certain positions or engage in specific activities for up to three years.

In Ukraine, criminal offences exist that may be classified as environmental, social and governance (ESG) violations, although there is no direct ESG classification in legislation. The main categories are as follows.

Environmental Offences

Violations of environmental safety rules and duties to prevent environmental harm

Criminal Code Articles: 236, 237, 253 and 254.

Constituent elements

Object: environmental safety, natural resources, and public health.

Objective element: breach of environmental safety rules, failure to take measures to eliminate damage, design or operation of facilities without environmental protection, and mismanagement of land.

Subject: natural and legal persons.

Subjective element: intent or negligence.

Sanctions: fines of up to UAH170,000 (approximately EUR3,500) and restriction or imprisonment for up to ten years, with disqualification from holding certain positions or engaging in certain activities for up to three years.

Pollution and degradation of natural resources

Criminal Code Articles: 239, 241 and 243.

Constituent elements

Object: land, water, and air resources; the environment.

Objective element: pollution or degradation of resources causing substantial harm to ecology or public health.

Subject: natural and legal persons.

Subjective element: intent or negligence.

Sanctions: fines of up to UAH85,000 (approximately EUR1,800) and restriction or imprisonment for up to five years, with disqualification for up to three years.

Illegal appropriation or use of natural resources

Criminal Code Articles: 239-2, 240, 240-1, 242 and 244.

Constituent elements

Object: land, water, subsoil resources, and continental shelf.

Objective element: illegal acquisition, extraction, sale or use of natural resources, and breach of protection rules.

Subject: natural and legal persons.

Subjective element: intent.

Sanctions: fines of up to UAH170,000 (approximately EUR3,500) and restriction or imprisonment for up to eight years, with disqualification for up to three years.

Violations of plant and animal protection rules

Criminal Code Articles: 245–252.

Constituent elements

Object: flora, fauna, protected areas, fish and wildlife resources.

Objective element: illegal logging, hunting, fishing, destruction or damage to protected territories, breach of veterinary rules, and unauthorised use of explosives.

Subject: natural and legal persons.

Subjective element: intent or negligence.

Sanctions: fines of up to UAH153,000 (approximately EUR3,200) and restriction or imprisonment for up to ten years.

Additionally, the Criminal Code provides penalties for crimes against peace, human security, and international order, including ecocide (Article 441) – encompassing mass destruction of flora or fauna, poisoning of the atmosphere or water resources, or other acts potentially causing ecological catastrophe.

Sanction: unconditional imprisonment for up to 15 years.

Social Offences

Human trafficking and forced labour

Criminal Code Articles: 149, 150 and 150-1.

Constituent elements

Object: human rights and freedoms, dignity, labour freedom, and child protection.

Objective element: recruitment, transportation, retention or coercion into work or services, or use of children for begging.

Subject: natural persons.

Subjective element: intent.

Sanctions: imprisonment for up to 15 years.

Violations of personal rights and violent acts

Criminal Code Articles: 146, 151 and 151-2.

Constituent elements

Object: personal integrity, freedom, marital rights, and protection from unlawful deprivation of liberty.

Objective element:

• unlawful detention or abduction;
• unlawful placement in psychiatric facilities; or
• coercion into marriage.

Subject: natural persons.

Subjective element: intent.

Sanctions: imprisonment for up to ten years, with disqualification for up to three years.

Violation of labour rights

Criminal Code Articles: 172 and 175.

Constituent elements

Object: labour rights, lawful interests of employees, and social payments.

Objective element: gross violation of labour laws, or non-payment of wages, pensions, or other legally established payments.

Subject: natural persons – employers or officials.

Subjective element: intent or negligence.

Sanctions: fines of up to UAH85,000 (approximately EUR1,800), and restriction or imprisonment for up to five years, with disqualification for up to three years.

Serious crimes against humanity

Criminal Code Articles: 442 and 442-1.

Constituent elements

Object: life, health, dignity, and international human rights.

Objective element:

• genocide; or
• crimes against humanity (murders, persecution based on nationality, ethnicity or religion, or forced displacement).

Subject: natural persons.

Subjective element: intent.

Sanctions: imprisonment for up to 15 years or life imprisonment.

Governance/Corporate Offences

In Ukraine, these may manifest as:

• abuse of power or official position (Article 364 of the Criminal Code (CC)) – misuse of authority contrary to company or state interests;
• corrupt or fraudulent official actions (Articles 366, 367, 368 and 369 of the CC) – including illegal receipt or provision of benefits, falsification of documentation, and official negligence; and
• violations of accounting or financial reporting rules (Articles 212-1 and 220-2 of the CC) – falsification of financial documents misleading shareholders, investors, or regulatory authorities.

The constituent elements of governance offences are as follows.

Object:

• rights and lawful interests of legal entities, the state, and third parties;
• ensuring transparent corporate governance; and
• financial discipline.

Objective element:

• intentional acts or omissions causing harm to the interests of the company, the state, or third parties; or
• includes falsification, embezzlement, abuse of powers, or corrupt actions.

Subject: natural or legal persons holding official functions or controlling the company.

Subjective element: intent, often motivated by personal gain or hidden benefit.

Sanctions: fines (up to UAH425,000 – approximately EUR8,800), restriction or imprisonment for up to 12 years, disqualification for up to three years, and often confiscation of property.

Companies in Ukraine are not obliged to monitor their suppliers in case of criminality, but they are expected to implement ESG policies, auditing, and supply chain monitoring to minimise risks of labour, environmental, and governance violations, as well as to avoid administrative, civil, or reputational liability.

Currently, Ukrainian legislation does not establish any distinct criminal or administrative offences related to the misuse of artificial intelligence, algorithmic trading, or automated decision-making in financial or commercial contexts.

Classification of Crypto-Assets

In Ukraine, crypto-assets are not recognised as legal tender, but they are considered property or financial assets. Depending on their characteristics, they may be classified as securities, property, or goods, which determines the applicable law and potential sanctions.

Although crypto-assets are currently not recognised as legal tender in Ukraine and are not directly regulated as currency or securities, this does not preclude liability for unlawful activities involving them. Specific criminal offences have not yet been established, but violations may take the following forms.

Fraud involving crypto-assets (criminal liability – Article 190 of the Criminal Code)

Object: property rights.

Objective element: obtaining crypto-assets through deception or abuse of trust.

Subject: a legally competent individual.

Subjective element: direct intent, with a motive for personal gain.

Penalties for this offence may include a fine of up to UAH136,000 (approximately EUR2,800), as well as restriction or imprisonment for up to 12 years.

Legalisation (money laundering) of criminally obtained income (if crypto-assets are used for the circulation of criminal proceeds – Article 209 of the Criminal Code)

Object: economic security and the legally established order of income circulation.

Objective element: use of crypto-assets to conceal, legalise, or circulate income obtained through criminal means.

Subject: a legally competent individual (including officials).

Subjective element: direct intent.

Sanctions may include imprisonment for up to 12 years, deprivation of the right to hold certain positions or engage in specific activities for up to three years, and potential confiscation of property.

In Ukraine, there are no specific defences tailored for white-collar offences. As a result, the standard defence strategy typically involves arguing that the essential elements of the alleged offence have not been established.

The Criminal Code of Ukraine provides that an act or omission may – despite formally meeting the criteria for a crime or misdemeanour – not constitute a criminal offence if it does not present a significant public danger. This means that if the act causes no substantial harm or risk to individuals, legal entities, society or the state, it is considered insignificant and therefore not punishable. This principle applies universally, without restrictions to specific industries or sectors.

Under Ukrainian criminal procedural legislation, suspects and accused individuals have the option to enter into a plea bargain with the investigation. The plea bargain typically includes:

• the obligations of the suspect or accused to co-operate in uncovering crimes committed by others (if applicable);
• the agreed-upon punishment;
• conditions for potential partial relief from civil liability, such as compensation for damages to the state; and
• terms regarding special confiscation and other relevant conditions.

For a plea bargain to be valid, the following criteria must be met:

• an unconditional admission of guilt;
• if the plea bargain involves a particularly serious crime investigated by NABU, the suspect must provide evidence implicating another individual in the crime;
• disclosure of the criminal actions of accomplices or other crimes committed by a criminal group, if the bargain involves a non-organiser of such a group; and
• consent from all victims, if any.

Under the Law of Ukraine “On Prevention of Corruption”, whistle-blowers and their relatives are entitled to state protection. This protection includes the following.

• Safety measures – if there is a threat to the life, health, property or housing of whistle-blowers or their close relatives owing to the disclosure of corruption-related information, law enforcement agencies are required to ensure their safety.
• Anonymity – whistle-blowers can report corruption anonymously. If personal details are disclosed, confidentiality and anonymity are guaranteed.
• Legal assistance – whistle-blowers are entitled to free legal assistance for protecting their rights or to reimbursement of the attorney’s fees.
• Employment protection – whistle-blowers and their close relatives cannot be dismissed, disciplined or subjected to negative employment actions (such as suspension, demotion or salary reduction) owing to their reporting. If such actions occur, whistle-blowers are entitled to reinstatement and compensation for lost income.
• No legal liability – whistle-blowers are not legally liable for reporting corruption, even if their report violates their official, civil, labour or other obligations.

Regarding incentives, whistle-blowers may receive a financial reward if the value of the reported corruption offence or the related losses exceeds UAH7.5 million (approximately EUR155,000). The reward amounts to 10% of the monetary value of the crime or the damage caused, but shall not exceed UAH24 million (approximately EUR496,000) as of 2025.

An anonymous report of an offence can be submitted electronically via forms available on the official web portals of all law enforcement agencies, the Prosecutor’s Office, and the National Agency for Corruption Prevention (NACP). These forms ensure and guarantee the confidentiality of the whistle-blower and protection of their identity.

Impact of Different Jurisdictions on Defence Strategy

• Divergent approaches to evidence, standards of proof, and the rights of the accused may require adaptation of the strategy in each country.
• Disclosure requirements vary across jurisdictions. This increases the risk that evidence provided in one jurisdiction could be used against the client in another, or conversely, that evidence may not be accepted.
• International requests from law enforcement authorities or asset freezes often require co-ordination with lawyers in the countries where the investigation is ongoing.
• Co-ordinated Defence Mechanisms – mutual collaboration among defence counsel within a network of international lawyers to exchange information and harmonise defence positions.

Limitations of International Co-Operation

Some jurisdictions do not fully, or only partially, recognise evidence obtained abroad, particularly if it was collected in breach of local procedural rules.

Political or diplomatic factors may delay or restrict inter-state co-operation (eg, delays in providing information or refusals due to domestic political interests or strained relations with another country).

Over the coming year, Ukraine is not expected to implement large-scale reforms or experience high-profile political events specifically in the area of white-collar crime. At the same time, a series of legal and institutional updates are anticipated, aimed at strengthening the response to economic offences and white-collar crime.

Overhaul of Key Anti-Corruption and Economic Institutions

• ARMA (Asset Management Agency) – ongoing reform includes a transparent leadership selection process, external evaluation of activities, and improved mechanisms for managing confiscated assets.
• BEB (Bureau of Economic Security) – effectively undergoing a “restart” with the appointment of a new head, updates to HR policies, and the setting of investigative priorities.
• State Customs Service – appointment of a new head is expected, which should strengthen anti-corruption measures and efforts against smuggling.

Implementation of Procedural Reforms

A series of amendments to the Criminal Procedure Code adopted in 2024–2025 will take full effect in 2025–2026. Notably, the High Anti-Corruption Court (HACC) is already hearing cases with a single judge rather than a three-judge panel, expediting proceedings. An expansion of the HACC judicial staff is also anticipated to reduce the burden on individual judges.

Reforms in the Office of the Prosecutor General

The new Prosecutor General, R. Kravchenko, has initiated structural changes: new commissions are being established, the functions of existing units are being reviewed, and oversight of business rights compliance is being strengthened. A policy direction has been declared to reduce pressure on business, including a moratorium on unlawful inspections, closure of groundless criminal proceedings, and enhanced transparency of processes.

Law Enforcement Priorities

• Combating tax evasion, financial fraud, and abuses in public procurement.
• Addressing violations of the sanctions regime (with the anticipated adoption of Bill No 12406, introducing criminal liability for sanctions circumvention).
• Strengthening co-operation with European and international bodies in financial monitoring, anti-money laundering, and transnational economic crime.