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Fulfillment of the requirements of Ukraine's Memorandum with the IMF: NACP prioritizes financial control on top officials and high-risk areas

01.10.2026

The National Agency on Corruption Prevention (NACP) has fulfilled the requirements of Ukraine's Memorandum of Economic and Financial Policies with the International Monetary Fund (IMF). This concerns the requirements regarding the development of regulatory legal acts that determine the priority and measures of financial control for high-ranking officials working in high-risk sectors.

Thus, the NACP approved the order "On Amendments to Certain Regulatory Legal Acts of the National Agency on Corruption Prevention," one of the key changes of which is a new version of the Procedure for Selecting Declarations of Persons Authorized to Perform State or Local Self-Government Functions for Full Verification and the Priority of Such Verification Based on Risk Assessment. The state registration of the order was carried out by the Ministry of Justice of Ukraine on September 29, 2026. It will enter into force on October 2, 2026.

The changes provide for the improvement of the risk-based approach in selecting declarations for full verification. Particular attention will be paid to declarations submitted by officials operating in areas with increased corruption risks and high-ranking officials subject to the investigative jurisdiction of the National Anti-Corruption Bureau of Ukraine. This recommendation was also provided by IMF experts in their Technical Assistance Report "Improving the Asset Declaration System for Public Servants."

In addition, Head of the NACP Viktor Pavliushyk signed the order "On Determining Priority Areas for Financial Control Measures." The document defines that for the period from October 2, 2026, to May 31, 2027, the priority areas for selective lifestyle monitoring of declarants and selecting declarations for full verification are: taxation; customs; energy; public procurement.

The definition of these areas complies with IMF recommendations regarding strengthening the risk-based approach and focusing financial control measures on declarants working in areas with an increased level of corruption risks.

Furthermore, to ensure maximum transparency, starting from the end of September 2026, the NACP will publish key performance indicators for financial control measures recommended by the IMF twice a year. These reports have already been published and reflect the results of verifications conducted based on the risk-based approach, as well as the lifestyle monitoring of officials carried out.

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