UKRAINE Trends and Developments Contributed by: Denys Bugay, Volodymyr Vashchenko, Denys Shkarovsky and Oleksandr Lukianenko, VB Partners
Combating Corruption and Coercive Methods in Ukraine The year 2025 has been marked by the dynamic development of white-collar crime practice in Ukraine, driven by a combination of domestic reforms, Euro - pean integration processes, and the impact of the full-scale war. Key trends include: • the defence of the procedural independence of anti-corruption bodies; • the “reset” of the Economic Security Bureau of Ukraine and the appointment of new leadership; and • the commencement of reform of the Asset Recov - ery and Management Agency. The legislative process has become significantly more active, in particular with regard to (i) the criminalisation of sanctions evasion, and (ii) the reduction of pressure on businesses from law enforcement authorities. The scope of international co-operation is steadily increasing and mutually beneficial. There has been a marked growth in the exchange of information, both from foreign law enforcement agencies to their Ukrain - ian counterparts and vice versa. Competent authorities in foreign jurisdictions have begun more frequently extraditing suspects to Ukraine, notwithstanding the risks posed by the war. This development has been strongly facilitated by the position taken by the Ukrainian government. Attempt to Restrict the Procedural Independence of Anti-Corruption Bodies Following 2014, anti-corruption institutions were established with institutional independence in order to minimise political influence. These bodies have prov - en their effectiveness – during their operation, dozens of high-ranking officials have been served with notices of suspicion in connection with criminal offences. From their inception, the National Anti-Corruption Bureau of Ukraine (NABU) and the Specialised Anti- Corruption Prosecutor’s Office (SAPO) enjoyed pro -
cedural independence from the General Prosecutor’s Office. In particular, the Criminal Procedure Code of Ukraine provided for rules prohibiting the delegation of inves - tigations of offences falling within the jurisdiction of NABU to other investigative authorities (the State Bureau of Investigation, the Security Service of Ukraine, the National Police, or the Economic Security Bureau of Ukraine). This separation made it possible to minimise the risks of political interference in the work of bodies investi - gating systemic high-level corruption. In July 2025, however, reverse processes began, which curtailed the procedural independence of NABU and SAPO. On 22 July 2025, the Verkhovna Rada of Ukraine adopted a Law that restricted the procedural inde - pendence of NABU and SAPO, effectively subordinat - ing them to the Prosecutor General. In particular, the Prosecutor General was granted the exclusive authority to: • transfer any investigation being conducted by NABU detectives to any other authority – previ - ously, the Criminal Procedure Code of Ukraine expressly prohibited this; • sign notices of suspicion addressed to senior offi - cials, including members of Parliament, members of the cabinet of ministers and others – formerly, this power belonged to the head of SAPO; • independently appoint prosecutors responsible for procedural supervision in cases of high-level cor - ruption; and • issue binding instructions to SAPO prosecutors and NABU detectives. Society perceived the law as a rollback of anti-corrup - tion reform, which sparked widespread protests. This ultimately led to the repeal of the law and the restora - tion of the previous powers of NABU and SAPO. It is expected that, following these developments, the number of proceedings concerning high-level corrup -
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