White-Collar Crime 2025

UKRAINE Law and Practice Contributed by: Denys Bugay, Volodymyr Vashchenko, Denys Shkarovsky and Oleksandr Lukianenko, VB Partners

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 han - dles 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, includ - ing former presidents, prime ministers, government members, people’s deputies and high-ranking pros - ecutors. 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 over - see pre-trial investigations and public indictments for cases handled by the ESB, SBI and National Police. Prosecutors of the Specialised Anti-Corruption Pros - ecutor’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 pros - ecutors. State policy and political pressure may influence investigative priorities and the timing of enforcement,

as well as affect the allocation of resources and prior - itisation of cases. Nevertheless, the authorities con - tinue to exercise their powers in accordance with the law. 2.2 Initiating an Investigation 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 exam - ple, tax irregularities or unlawful banking opera - tions) 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 Regis - ter of Pretrial Investigations within 24 hours of receiv - ing the application or discovering the evidence. 2.3 Powers of Investigation Law enforcement agencies, operating under the pro - cedural oversight of the Prosecutor General’s Office or the Specialised Anti-Corruption Prosecutor’s Office, are authorised to undertake a range of actions neces - sary for crime investigation. Their powers include the following. Demanding Evidence Agencies can request documents and items essen - tial for the investigation from individuals, legal enti - ties, 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

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