When it’s not clients who come, but NABU, ESB and CID

In Ukrainian realities, the question “will law‑enforcement come” has long turned into “when and in what status you will meet them”. Businesses and ordinary citizens are increasingly becoming subjects of criminal proceedings – both as real beneficiaries of schemes and as “accidental” links in the chain. It is enough to be the owner of an LLC, a sole proprietor, the director of an “old” company, the chief accountant, an officer of a counterparty or simply a person through whose account a large sum once passed – to end up mentioned in an investigating judge’s ruling.

Who is in the highest‑risk zone today

Law‑enforcement officers look not at the sign on the door, but at a person’s role in processes and cash flows.

• Owners of sole proprietorships and LLCs are the first candidates for suspect status in cases of tax evasion, sham entrepreneurship, misappropriation of assets, and cash‑out schemes.
• Directors and beneficiaries are held liable for “organising the scheme”, even if they were not actually involved in day‑to‑day operations.
• Chief accountants and CFOs are the technical centre of any case: reports, acts and payment orders bear their signatures.
• Officers of counterparties (especially state entities) easily become co‑participants in corruption episodes.
• Ordinary citizens – those who agreed to “lend a passport to register a company”, “become a director for 5 000 UAH” or “let a payment pass through their card”.

One and the same case may cover both the business and specific individuals – with personal liability, seizure of assets and restriction of freedom.

NABU, ESB, CID: how they enter your business and your life

Anti‑corruption bodies and economic crime units work in their own niches, but for the client the outcome looks the same – searches, seizures, freezes and interrogations.

• NABU focuses on high‑level corruption, public procurement and large budgets, but businesses appear in these cases as contractors, counterparties or beneficiaries. Searches, seizures and freezing of accounts and assets can effectively stop a company’s work long before a court verdict.
• The Economic Security Bureau (ESB) specialises in taxes, sham transactions, excisable goods, paper‑only deals and misappropriation of property. This is where most tax evasion cases against sole proprietors and LLCs are born, along with parallel proceedings against owners, directors and accountants.
• National Police units (including the Criminal Investigation Department, CID) enter under the pretext of fighting “conversion centres”, “shell companies” and “organised groups”. This also affects entirely lawful businesses – because of cash operations, complex chains of counterparties and old contracts or deals.

Typical tools of pressure on businesses and citizens

In cases against businesses and individuals, the same scenario almost always repeats.

• Searches: office, warehouse, production site, apartment, garage, country house – anywhere documents, equipment, cash or data carriers may be stored.
• Seizures: laptops, phones, servers, primary documents, company stamps – things without which neither the company nor personal life can function.
• Asset freezes: corporate rights, bank accounts, deposits, cars, real estate, consignments of goods, equipment.
• Personal pressure: interrogations, covert investigative actions, preventive measures – from personal undertakings and bail to house arrest.
• Information background: being mentioned in a “high‑profile case”, public statements and media leaks that create a toxic image for banks, partners and employers.

Officially, all this is called “ensuring the investigation”. In practice, such actions often become a lever of influence – to force you to negotiate, give up the business, withdraw claims or accept conditions that are “convenient” for the investigators.

Risks for the business and personally for you

For sole proprietors and LLCs:

• Paralysis of operations due to frozen accounts, seized goods and equipment.
• Loss of documents and data, breakdown of settlements with counterparties, penalties from banks and partners.
• Destruction of reputation with investors, the tax authority, financial monitoring and partners.

For individuals:

• Personal criminal liability – even if a person “just signed what they were told to”.
• Risk of arrest, bail, travel restrictions and loss of access to their own funds.
• Freezing of personal assets (apartments, cars, deposits) that were acquired over years and have no relation to the “scheme”.
• A toxic mark in one’s biography: refusals from banks, lost career opportunities, problems with travel and visas.

The worst part is that most businesses and people start thinking about protection only after the first search or summons. At that stage a lot can still be fixed, but the cost of a mistake is much higher.

How WINNER protects businesses and citizens from criminal prosecution

The law firm WINNER protects two dimensions at once – the business (sole proprietors, LLCs, groups of companies) and individuals: owners, directors, accountants, officers of counterparties and “ordinary” citizens.

1. Prevention
   • Audit of the business model and personal roles: where law‑enforcement can “enter” and whom they can turn into a suspect.
   • Building internal protocols: what to do during a search, when an investigator calls, or when documents are requested.
   • Training for the team and owners: how to answer questions, what to sign, and what must never be done under any circumstances.
2. Crisis response
   • Immediate dispatch of defence lawyers to a search – both to the company and to the homes of owners and managers.
   • Monitoring investigators’ actions, recording violations, minimising seizure of critical assets and information.
   • Defence during interrogations and when preventive measures are chosen, counteracting pressure and attempts to “settle things” off the record.
3. Long‑term defence
   • Defence strategy in the criminal case simultaneously for the business and specific individuals.
   • Working with asset and account freezes – cancelling, modifying and unblocking them.
   • Supporting public communications so that the case does not destroy your business reputation.

When you should contact us

The best time to take care of your protection is before an investigator from NABU, ESB or CID rings your doorbell.

If you want to:

• assess the real risks for your business and personally for you;
• have a clear action plan in case of a search;
• get a team of lawyers ready to come “here and now” and take over all communication with the investigators,

leave a request via the form on our website or contact us in any convenient way – the WINNER team will prepare an individual defence strategy for you.

Author: Ihor Yasko, Managing Partner at WINNER Law Firm, PhD in Law.