Deputy, 315,000 dollars and “forgotten” millions in the declaration

In Zakarpattia, law enforcement officers have notified a deputy of the Uzhhorod City Council of suspicion on counts of legalization of property obtained by criminal means and intentional inclusion of false information in the annual declaration.  According to the investigation, the official attempted to give illegal funds the appearance of lawful assets through formal execution of a loan and the use of relevant documents within criminal proceedings in which he appeared as a victim.

The amount of funds allegedly provided as a loan was 315 thousand US dollars, which, at the NBU exchange rate for the relevant period, exceeded 11.5 million UAH.  Subsequently, the deputy submitted a notarized statement of no claims, indicating that the mentioned funds had been returned to him, which was intended to create the impression of the lawful origin of the assets.

False information in the declaration amounting to millions of hryvnias

In parallel, law enforcement officers established that the deputy failed to reflect a number of significant assets and income in his annual declaration.  In particular, this concerns a residential house with an area of over 350 m² and a land plot in Uzhhorod, as well as a house in Kyiv, information about which the declarant was obliged to indicate in accordance with the Law of Ukraine “On Prevention of Corruption”.

In addition to real estate, the declaration did not reflect salary, monetary assets in the form of loans to third parties, funds in a deposit account, and balances of funds as a sole proprietor.  In total, according to estimates of law enforcement agencies and the NACP, the amount of falsely declared information exceeded 13.8 million UAH, which significantly surpasses the threshold of 2,500 subsistence minimums for able-bodied persons established for criminal liability.

Criminal-law qualification: Art. 209 and Art. 366-2 of the Criminal Code of Ukraine

The deputy is charged with committing criminal offenses under Part 2 of Article 209 and Part 2 of Article 366-2 of the Criminal Code of Ukraine.  Article 209 of the Criminal Code of Ukraine provides for liability for the legalization (money laundering) of property obtained by criminal means, in particular by concluding transactions or carrying out financial operations with such assets in order to give them the appearance of lawfully acquired property.

Article 366-2 of the Criminal Code of Ukraine establishes criminal liability for the intentional inclusion by a declarant of knowingly false information in a declaration, if the discrepancy between the real state of affairs and the declared data exceeds a significant threshold defined by law.  For local self-government officials, as well as for civil servants, the obligation of annual declaration of property, income and financial liabilities directly follows from the Law of Ukraine “On Prevention of Corruption” and the relevant clarifications of the NACP.

At present, the pre-trial investigation is ongoing, and the issue of choosing a measure of restraint for the suspect is under consideration by the court under the procedural guidance of the regional prosecutor’s office.

Why declaration cases are a “time bomb” for officials

The practice of the NACP and law enforcement agencies shows that issues of declaration and financial transparency are one of the most sensitive risk areas for local council deputies, heads of municipal enterprises, high-ranking officials and their families.  Incorrectly qualified income, improperly valued property or a banal “forgetting” about certain assets can turn an administrative mistake into criminal proceedings with real sanctions.

In addition, with the strengthening of anti-corruption control and the digitalization of registers, the likelihood of detecting inconsistencies between the declaration, banking data, and information from real estate or corporate rights registers is increasing significantly.  In such conditions, systematic work with legal advisers becomes not an option, but a necessity for all declarants.

How JSC “Law Firm WINNER” helps

JSC “Law Firm WINNER” provides comprehensive support to officials, local council deputies, heads of state-owned enterprises and business owners on issues of declaration, financial transparency and criminal-law risks.  In particular, the firm’s lawyers help to:

• conduct a preventive audit of annual declarations before submission, identify and eliminate potential risks;
• structure asset and financial flows taking into account the requirements of anti-corruption legislation;
• prepare clients for NACP inspections, develop legal positions and document packages for explanations;
• build a defense strategy in criminal proceedings under Art. 209, 366-2 of the Criminal Code of Ukraine and related offenses.

Practical experience with cases involving legalization of property and false declaration enables the WINNER team not only to respond to already initiated proceedings, but also to build preventive protection in order to reduce the likelihood of criminal risks arising in the future.

Webinar in mid-March: how not to become a suspect in a criminal case because of a declaration

In mid-March 2026, JSC “Law Firm WINNER” will hold a practical webinar dedicated to declaration risks, issues of proving the origin of assets, and protection from criminal liability for financial operations.  During the event, the firm’s experts will analyze typical declarants’ mistakes, current case law under Art. 209 and 366-2 of the Criminal Code of Ukraine, and provide practical recommendations on building an effective compliance system for officials and businesses.

You can follow announcements and registration for the webinar on the official website of JSC “Law Firm WINNER” and on the firm’s social media pages.

Author: Yevhenii Murchenko, Head of the Criminal Law and Procedure Practice of the law firm “WINNER”.