Digital blindness of NACP: How automatic checks allowed Halushchenko to "legalize" 12 million dollars of offshore assets

Digital blindness of NACP: How automatic checks allowed Halushchenko to "legalize" 12 million dollars of offshore assets

The public dispute between the National Agency on Corruption Prevention (NACP) and experts from Transparency International Ukraine (TI Ukraine) has highlighted a critical issue in Ukraine’s anti-corruption system: the transition from thorough manual checks to automated algorithms.

According to materials from TI Ukraine.

While the Agency insists on the effectiveness of its methods, the case of former minister Herman Halushchenko proves the opposite.

The official’s declarations for 2021 and 2024 passed through the automated filter without any remarks, despite the fact that, according to the National Anti-Corruption Bureau (NABU), during the same period, 12 million dollars were laundered through an offshore network in favor of his family.

The main criticism from experts concerns the introduction of the term «automated verification», which is effectively absent from the relevant law. The NACP independently added this concept to its Verification Procedure in December 2023.

This has created a dangerous precedent: if the declaration of a high-ranking official holding a «particularly responsible position» passes such automated control and receives the corresponding certificate, it is automatically exempt from a full manual check by a live inspector.

This is exactly what happened with Halushchenko — the algorithms simply compared the data with Ukrainian registries, where foreign offshore accounts in the Marshall Islands or bank accounts in Switzerland could not possibly be registered by default.

Criticism of the NACP’s approaches comes not only from Ukrainian civil society organizations but also from reputable international institutions. The European Commission, in its enlargement report, directly pointed out the «practical and legal shortcomings» of the automated process, which fails to effectively detect unjustified assets.

The OECD (Organisation for Economic Co-operation and Development) in its 2025 report also emphasized the significant gap between legislative requirements and reality: out of half a million high-risk declarations, only a small fraction undergoes truly in-depth scrutiny. The Independent Evaluation Commission of the NACP expressed doubts several years ago about whether a full verification could be effective in automated mode at all.

Transparency International Ukraine stresses that administrative verification is a preventive measure that should precede criminal proceedings. The NACP has sufficient tools for international cooperation, such as the Europol SIENA platform or the UN Convention against Corruption, to request data on foreign assets.

However, instead of using these opportunities for «manual» investigations, the Agency has focused on statistical indicators of the speed of automated checks. In Halushchenko’s case, this led to the fact that evidence of his family’s luxurious lifestyle, including his son’s education in Switzerland costing 200,000 dollars per year, was uncovered by journalists and detectives, not by the relevant control body.

Disclaimer of Responsibility Under the Guise of Digitalization

Suspect in the “Midas” case, former Minister of Energy Herman Halushchenko, during a court hearing at the High Anti-Corruption Court (HACC), February 17, 2026. Suspilne News/Ivan Antypenko

The NACP’s statement that criticism from TI Ukraine «undermines trust in the anti-corruption system» appears to be an attempt to defend a flawed procedure instead of correcting it.

Experts point out that even the mechanism of logical and arithmetic control (LAC) has been weakened: declarations marked as risky can still avoid detailed examination if they have passed an automated «full» check.

The rules of these algorithms remain closed to the public, creating room for manipulation and selective approaches to declarants. In fact, the NACP has created a system where a «checkmark» from a computer becomes an indulgence for top officials.

The situation with Halushchenko, whom partners in the scheme referred to as «Sigismund,» forced the NACP to eventually order a repeat manual check of his assets, but this only happened after NABU issued a suspicion notice. Such a «post-factum» approach negates the very essence of corruption prevention.

If an agency created to detect illicit enrichment only reacts after detectives have already gathered all evidence of money laundering, a logical question arises about the relevance of its current working methods. This supports the argument that automation without intellectual analysis and international cooperation turns financial control into an illusion of security.