SEMEN KRYVONOS
NABU Director

The first half of 2025 was a period of trials, challenges, and key victories for NABU that opened new horizons and strengthened the institution’s independence.

For the first time in its history, NABU and SAPO came under unprecedented legislative pressure that restricted our powers and threatened the ability to investigate high-level corruption effectively. The law, which significantly curtailed our autonomy, was passed without public debate and in defiance of the position of civil society and international partners. This was accompanied by public searches targeting NABU staff, as well as a large-scale information campaign aimed at discrediting the Bureau and its employees.

However, due to strong public backlash, a new law restoring the independence of NABU and SAPO was adopted within days. Notably, during the first half of 2025, for the first time in Ukraine’s history, the highest-ranking government official was held criminally liable, confirming our ability to independently and effectively investigate corruption — even at the highest levels.

A former Deputy Head of the Presidential Office was also served with a notice of suspicion for bribery and money laundering. A unique operation called “Clean City” was conducted to neutralize a criminal organization that controlled land-related decisions in Kyiv. Two major corruption schemes were uncovered at the Ministry of Defense: a price inflation scheme for military food supplies that caused losses of UAH 733 million, and the embezzlement of UAH 246 million during the development of the Armed Forces’ automated control system “DZVIN.”

During this period, NABU also underwent an independent international audit — the first comprehensive external review of the Bureau’s activities in ten years. The results confirmed the Bureau’s effectiveness, particularly in pre-trial investigations, and affirmed its institutional independence and resilience.

Despite pressure and challenges, NABU continues to fulfill its core mission: holding top officials accountable for grand corruption. In the first half of 2025, based on NABU and SAPO materials, 115 individuals were served with notices of suspicion, including high-ranking officials, such as the Deputy Prime Minister. The economic impact of our work exceeds UAH 16.8 billion, with UAH 2.8 billion allocated to support the Armed Forces of Ukraine.

We remain focused on improving internal processes and overcoming external limitations to enhance the effectiveness of investigations in key sectors — defense, energy, reconstruction, customs, and the tax system.

Thank you to all employees, partners, and members of the public for your continued support.

OLEKSANDR KLYMENKO
SAPO Head

The first half of 2025 has become one of the most pivotal periods in the history of SAPO and NABU. It was a time of serious challenges, significant achievements, and decisions that have influenced not only our institutions, but the entire anti-corruption system in Ukraine.

Over the course of six months, SAPO prosecutors together with NABU detectives issued 115 notices of suspicion in cases involving individuals from the highest levels of power – including in the defence sector, the judiciary, and state-owned enterprises – and submitted 69 indictments to court against 154 persons. We are sending a clear message: the rule of law allows for no exceptions, and those guilty of high-level corruption will be held accountable, regardless of their position.

There have also been new results in the application of civil forfeiture mechanisms. During this period, SAPO prosecutors filed 24 claims for the recovery of unjustified assets in favour of the state, amounting to over UAH 135 million – more than in all previous years combined.

Approximately UAH 2.7 billion has been transferred to support Ukraine’s Defence Forces, derived from forfeited bail, fines under plea agreements, and other procedural instruments.

One of the most significant milestones was the announcement of an open competition for the position of SAPO prosecutors. This is the first competition held since SAPO became a separate legal entity, distinct from the Prosecutor General’s Office. As a result, the SAPO team will be joined by new qualified prosecutors. I firmly believe that a professional and purpose-driven team is the foundation of SAPO’s institutional capacity, and that strengthening it is an investment in future effectiveness.

Alongside these achievements, we must also acknowledge a deeply troubling event that shook not only the anti-corruption institutions, but Ukrainian society as a whole – the adoption of Draft Law No. 12414 by the Verkhovna Rada of Ukraine, which dismantled the legal guarantees of independence for SAPO and NABU. Its adoption represented a direct attack on the anti-corruption infrastructure that has been built over more than a decade of determined effort. This move called into question our shared European future and sent a powerful signal to both Ukrainians and international partners: the fight for anti-corruption reform in Ukraine remains very much alive.

At the same time, we witnessed the strength of a genuine civil society in Ukraine – one that is prepared to defend its values of justice, European choice, and institutional independence through democratic means. This is a powerful force that inspires us and distinguishes Ukraine civilisationally from the morally bankrupt aggressor state.

We are deeply grateful to Ukrainian society for its steadfast support for an independent anti-corruption infrastructure, and to our international partners for their trust and for standing up in defence of the principles we all share. We also bow in deep respect to Ukraine’s defenders, who – at the cost of immense personal sacrifice – continue to protect the country from a deadly invader.

The SAPO and NABU teams are acutely aware of the great trust that has been placed in us, and we are fully committed to honouring that trust. We know that our work is not a one-off campaign, but a daily, principled endeavour. We will not stop.

The fight against high-level corruption will not be easy. But it is precisely this fight that is a necessary condition for Ukraine’s long-awaited European future.

AUDIT

For the first time in its 10 years of operation, the National Anti-Corruption Bureau of Ukraine (NABU) underwent an external independent assessment of its effectiveness, conducted by international experts. The audit was not only a snapshot of where we stand, but also a guide for the institution’s future development. Its conduct is mandated by law and is part of Ukraine’s international obligations in the field of anti-corruption reform.

INVESTIGATION

The first half of 2025 saw a series of high-profile exposures by NABU and SAPO, particularly in the defense, land, and healthcare sectors. As in previous reporting periods, the focus remained on uncovering high-level corruption amid the ongoing full-scale aggression by the russian federation.

ICD

In the first half of 2025, the activities of the NABU Internal Control Department (ICD) focused on monitoring employees’ compliance with legal requirements, conducting integrity checks, responding to possible violations, evaluating candidates, and taking measures to prevent the leakage of official information.

INTERACTION

NABU: Institutional Development, Digitalization, and Engagement with Society

During the reporting period, the National Anti-Corruption Bureau of Ukraine (NABU) continued to strengthen its institutional capacity, expand international cooperation, and actively involve the public in shaping a new anti-corruption culture. The focus of its activities included digital transformation of investigations, engagement of veterans in service, development of youth initiatives, and partnerships with international partners and anti-corruption bodies in other countries.

CHALLENGES

NABU continues to operate under significant external pressure and high public demand for anti-corruption efforts, Maintaining independence, transparency, and effectiveness requires overcoming a range of both internal and external challenges. These include interference in operations, information attacks, and the need to protect Bureau employees.

APPENDICES

These appendices contain statistical information on the NABU activities in the first half of 2025 as required by Article 26 of the Law of Ukraine “On the National Anti-Corruption Bureau of Ukraine”