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Cash in 90 currencies of the world, real estate abroad, and “gold” reserves of officials: NACP completes risk assessment of declarations submitted for 2025

24.07.2026

The National Agency on Corruption Prevention (NACP) has completed the risk assessment of declarations submitted for 2025 using logical and arithmetic control (LAC) and generated their risk rating.

Based on the results of the LAC, each declaration receives a risk rating, which directly influences its selection for full verification under a risk-based approach.

It should be noted that the LAC analyses the information provided in the declaration and automatically cross-checks it with data from state registries and other information systems. At the same time, it cannot detect assets or property actually used by the declarant or their family members if the corresponding rights are not subject to state registration or are missing from official registries. That is why the LAC is only one component of the NACP's financial control system. For comprehensive verification of declarable information, the NACP employs financial control measures such as full verifications and lifestyle monitoring, which enable detection of violations that cannot be established solely through automated control/verification tools.

Declarations with the highest risk rating scores determined by the LAC are selected for a full verification. Such a verification is conducted in accordance with the Procedure for Conducting a Full Verification of a Declaration and consists of the following stages: verifying the accuracy of the declared information, determining the precision of the valuation of declared assets, checking for potential conflicts of interest, and establishing signs of unjustified assets and illicit enrichment.

Currently, the NACP continues to verify declarations from previous reporting periods. At the same time, full verifications of declarations submitted for 2025 have already commenced. The list of individuals whose declarations are under verification, as well as the results of such verifications, can be found here.

Declarations with a low risk rating score had the opportunity to undergo an automated verification. Of those submitted for 2025, 40.3% of the eligible declarations passed this verification. As a reminder, eligible declarations are those:

  • which contain sufficient data to identify the declarant's family members and declared assets;
  • which contain a volume of data that can be verified by comparing the declaration data with registries and by applying specific formulas, for instance, to identify signs of illicit enrichment or unjustified assets;
  • which were submitted after the 2021 reporting year (this is impossible for previous years as the declaration form was changed in 2021).

Overall, as part of the declaration campaign (from January 1 to March 31, 2026), public servants submitted over 634 thousand declarations to the Unified State Register of Declarations of Persons Authorized to Perform the Functions of the State or Local Self-Government (Register of Declarations).

What interesting things officials declared for the 2025 reporting period:

Geography of declarants' expenses – in figures 

The NACP analysed the expenses of officials incurred abroad in 2025, as reflected in the declarations, and identified the countries where they spent the most money. Turkey topped the ranking with over UAH 1.15 billion. The top three also included Austria (UAH 698.3 million) and the USA (UAH 296.9 million).

Cash and currency “preferences”

The largest amounts of cash are traditionally held by declarants and their family members in the national currency, the hryvnia. Among foreign currencies, the US dollar and the euro remain the undisputed leaders. At the same time, the declarations also contain information on cash in almost 90 currencies of the world. The Hungarian forint and the Japanese yen were also included in the top 5 currencies in terms of cash savings specified in the declarations.

Not by Bitcoin alone

Cryptocurrency is a virtual asset that is subject to declaration. Officials reported holding cryptocurrency worth a total of almost UAH 839 million as of the end of 2025.

The top 5 cryptocurrencies favoured by declarants included: Tether (USDT), with over UAH 278 million declared; followed by Bitcoin, at over UAH 150 million; Ethereum, at over UAH 100 million; Ripple, at over UAH 46 million; and Binance Coin (BNB), at over UAH 9 million.

The largest total value of cryptocurrency—over UAH 623 million—was declared by declarants who selected the "Other" option for their position in the declaration.

The top cryptocurrency holders also included civil servants of the following categories: Category C (over UAH 109 million), Category B (over UAH 52 million), and Category A (over UAH 19 million), as well as the fifth category of positions in local self-government bodies (over UAH 14 million).

Geography of crypto holders. The most valuable crypto assets were declared by officials in the capital—nearly UAH 265 million. Officials from Odesa (over UAH 99 million), Kyiv (over UAH 70 million), Dnipropetrovsk (over UAH 63 million), and Zakarpattia (over UAH 57 million) regions are not far behind.

Square meters abroad

An analysis of declarations for 2025 showed that declarants and their family members declared 3,904 real estate properties outside Ukraine under ownership rights, with a total value of over UAH 4.1 billion.

Top 5 countries by number of declared real estate properties:

  • Germany — 757;
  • Poland — 503;
  • Spain — 282;
  • Bulgaria — 251;
  • United Kingdom — 161.

More than three-quarters of all declared properties are apartments — 3,064. Residential houses are in second place — 362.

More properties are registered to family members of declarants. Specifically, family members of declarants own 2,033 real estate properties abroad worth UAH 2.2 billion, while the declarants themselves own 1,871 properties worth over UAH 1.9 billion.

The most expensive foreign real estate in terms of total declared value is located in Spain, the United Kingdom, Poland, the USA, and Bulgaria.

Precious metals worth one billion hryvnias

The total value of declared precious metals owned by officials and their family members amounts to over UAH 1.2 billion.

Of this amount, declarants themselves reported owning precious metals worth over UAH 952.5 million, while their family members reported over UAH 247.9 million.

Gold in ingots or plates accounts for the highest value among the declared precious assets, totalling over UAH 1.05 billion. This is the main asset in this category for both declarants and their family members.

This is followed by:

  • coins — UAH 139.7 million;
  • silver in ingots or plates — over UAH 4.6 million;
  • gold powder — over UAH 1.6 million;
  • platinum in ingots or plates — over UAH 746 thousand;
  • palladium in ingots or plates — over UAH 286 thousand.

The provided data reflects general trends in asset declarations by public servants and does not indicate the presence of violations. At the same time, the results of logical and arithmetic control are one of the key tools of the risk-based approach for conducting full verifications of declarations, allowing the NACP to focus its attention on declarations with the highest probability of violations. 

 

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