Ukraine continues to strengthen its anti-corruption framework even amidst a full-scale war, and the electronic declaration system is already one of the key elements of the state’s anti-corruption framework – this is one of the main conclusions reached by experts from the International Monetary Fund (IMF), who, at the request of the National Agency on Corruption Prevention (NACP) as part of an international technical assistance programme, assessed the effectiveness of Ukraine’s asset declaration and financial control measures.
“Ukraine's asset declaration system is a key anchor for the country's transparency and accountability framework. Enhancing risk-based verification, adopting outcome-oriented indicators, and reinforcing support to anti-corruption investigation and prosecution will concentrate limited resources where the vulnerabilities are greatest and sharpen the system's deterrent and preventive effect,” the IMF noted.
“I am sincerely grateful to the IMF team for their high level of professionalism, constructive cooperation and ongoing support for the NACP. I would like to express my hope for the continuation of this fruitful partnership to strengthen integrity, transparency and accountability in Ukraine’s public and private sectors. The recommendations provided will serve as a roadmap for the further development of the financial control system and the minimisation of corruption risks, and the Agency has already drawn up a practical package of measures to address short-term tasks,” said Viktor Pavlushchyk, Head of the NACP.
The Technical Assistance Report ‘Enhancing the Asset Declaration System for Public Officials’ (summary of the report) provides recommendations on improving the declaration system and further enhancing the effectiveness of financial control measures, namely:
- a possible review, at the legislative level, of the list of persons required to submit declarations, or a fundamental change to the very concept of declarations, depending on the declarant’s position and the purpose of submitting the declaration – whether to ensure transparency or to carry out financial control measures (based on a national assessment of corruption risks, with priority given to the vetting of high-ranking officials);
- grant the National Agency on Corruption Prevention (NACP) access to foreign financial information (by amending the Tax Code of Ukraine and the Law of Ukraine ‘On the Prevention of Corruption’);
- close the legislative loophole regarding state-owned enterprises (by amending Article 3 of the Law of Ukraine ‘On the Prevention of Corruption’), establishing clear criteria for classifying enterprises as state-owned and their officials as declarants;
- legislatively designate the NACP as the competent authority in the field of combating the laundering of proceeds of crime, in order to improve cooperation with the State Financial Monitoring Service, and grant access to information on foreign bank accounts by amending the Tax Code of Ukraine and the Law of Ukraine ‘On Preventing Corruption’;
- strengthen the institution of civil forfeiture of unjustified assets; to this end, it is recommended to bring the limitation periods in administrative, civil and criminal cases into line with the practice of EU Member States and to introduce a mechanism for suspending such periods pending decisions in cases of illicit enrichment;
- to strengthen the legal and operational framework for lifestyle monitoring, namely by establishing a baseline duration of at least six months, with transparent grounds for its extension, in particular where it is necessary to utilise instruments of international cooperation and the tracing of overseas assets;
- strengthen risk-based prioritisation during full checks of declarations and lifestyle monitoring, focusing on individuals working in sectors with high corruption risks, in particular taxation, customs, public procurement and the energy sector; improve the relevant processes for selecting declarations for full audit and review the key performance indicators for financial control measures;
- enable independent experts, as part of an external independent audit of the NACP, technical assistance provided to it by international partners, or independent experts from the technical audit working group, to examine the configuration settings for logical and arithmetic controls, the technical aspects of risk assessment and full audit procedures, subject to compliance with confidentiality and non-disclosure requirements, and to make recommendations for their improvement.
IMF experts also carried out a comprehensive assessment of the financial control framework – ranging from the system for assessing the risks associated with declarations through logical and arithmetic checks, automated and comprehensive verification of declarations, and lifestyle monitoring, to the NACP’s cooperation with other state bodies, in particular the State Financial Monitoring Service, the State Tax Service of Ukraine, the Specialised Anti-Corruption Prosecutor’s Office (SAPO) and the National Anti-Corruption Bureau of Ukraine (NABU), as well as international information exchange.
The Report notes, in particular, that Ukraine’s system of financial control over public officials is one of the most comprehensive among countries that have introduced electronic declarations. At the same time, its further development requires moving away from a fixed number of audits in favour of further refining a risk-based approach, which allows the NACP to focus its limited resources on declarants operating in sectors where the likelihood of corruption is highest.
The vast majority of the recommendations relate to legislative changes. Some of them are already reflected in the draft Anti-Corruption Strategy for 2026–2030 and will be implemented as part of the State Anti-Corruption Programme for the relevant period.
In accordance with the recommendations, the NACP has already drafted amendments to the regulatory acts governing the procedures for selecting declarations for full verification and lifestyle monitoring. The draft documents will shortly be put out for public consultation in accordance with current legislation, during which any interested stakeholder will be able to submit proposals and contribute to improving the NACP’s financial control tools.
One of the public discussions, specifically regarding the draft order on amendments to certain regulatory legal acts of the NACP, was held on September 2.
