Special Project: A Conversation with the Head of NACP, Viktor Pavlushchyk
A series of high-profile scandals this year involving Medical and Social Expert Commission and Military Medical Board doctors, Territorial Center of Recruitment and Social Support leaders, and prosecutors with disabilities has shaken society. These cases have exposed both the cynicism of the situation and the extent to which corruption has infiltrated the state apparatus and how many people and levels are involved in creating schemes of abuse of power. According to a study initiated by the National Agency on Corruption Prevention (NACP), 73% of Ukrainians consider corruption the biggest problem in the country after Russia’s armed aggression. At the same time, it is worth noting another figure: only 19% of the population has directly encountered corruption in their daily lives.
How does one of the state bodies specifically created to detect and respond to abuse of power by civil servants operate? Where does corruption begin, where is the line of crime, how can an honest society be fostered, why does access to state resources blind officials, and can Ukraine handle these challenges on its own?
We discussed these questions with Viktor Pavlushchyk, Head of NACP, during the Re:Open Zakarpattia 2024 forum.
Viktor Pavlushchyk at the Re:Open Zakarpattia 2024 forum
What does the concept of “integrity” personally mean to you? Where does it start?
Obviously, it is about moral and ethical principles in actions and individual perception of situations. Integrity means doing the right thing even when no one is watching. By adopting this approach, we will eventually break the inherited mindset from past generations that power is an opportunity to steal or otherwise exploit one’s official position. Instead, we will set an example for future generations on how to act conscientiously. Integrity starts with each citizen—at any moment, in any situation in life. Because wrongdoing is not only committed by those who abuse their position and accept bribes—it is also committed by those who offer them.
The age-old question: Is it ethical to give a doctor a chocolate bar or a small gift as a token of appreciation for good service?
I wouldn’t focus on specific cases like this. A professional should do their job well simply because it is their responsibility. When it comes to doctors, patients should be able to receive quality care without worrying that they will be treated differently After all, doctors take the Hippocratic Oath, which commits them to providing care regardless of personal gain. Beyond that, we need to foster a culture where neither patients nor professionals feel the need to exchange gifts as compensation. In my view, a simple “thank you” should be enough.
Given the numerous corruption scandals involving government officials this year, is it even ethical to talk about integrity in Ukraine? How does the system allow this? And how did we let corruption infiltrate state institutions so deeply?
The fact that these scandals are being exposed is actually a sign of growing transparency in Ukraine. It shows that law enforcement—particularly anti-corruption agencies—is doing its job by uncovering these issues. Moreover, public officials are now required to maintain transparency by submitting annual asset declarations, allowing society to scrutinize their financial status. In the past, such information was not readily accessible. That’s why it’s more important than ever to emphasize integrity—to show people the difference between right and wrong and encourage them to uphold high ethical standards in their own lives.
You often state in various interviews that, compared to other countries, Ukraine holds fairly good positions in terms of anti-corruption efforts. On what basis are these data and statements formed?
It’s true. Ukraine was the first non-member country of the Organization for Economic Co-operation and Development (OECD) to join the “Public Integrity Indicators” initiative. This initiative measures how effectively governments promote integrity in public administration, and I can confidently say that Ukraine is among the leaders—even compared to OECD member states. This is something we should be proud of. A new study will soon be released, highlighting Ukraine’s exceptional openness in many areas. For instance, when it comes to publishing open data, we rank third in the world. That is a significant achievement. No other country has an asset declaration registry as comprehensive as ours, nor such a vast amount of publicly available information on government officials. These are clear signs of progress, and over time, they will help reduce corruption in our society.
Ukraine has numerous agencies dedicated to fighting the abuse of power. How are responsibilities divided among them— National Agency on Corruption Prevention, National Anti-Corruption Bureau of Ukraine, Specialized Anti-Corruption Prosecutor’s Office, State Bureau of Investigation? And ultimately, who do we have to thank for uncovering the biggest corruption scandals we’ve discussed?
The National Agency on Corruption Prevention (NACP) is not a law enforcement body but a central executive authority with special status. Its role is to develop and implement anti-corruption policy. When it comes to criminal investigations, that’s the responsibility of law enforcement agencies. However, NACP does have certain inspection functions, such as conducting full audits of public officials’ asset declarations and monitoring their lifestyles. In the course of our work, we may also identify signs of criminal and other corruption-related offenses and take appropriate measures. If we identify potential signs of corruption-related offenses, we immediately forward the materials to law enforcement agencies. As for administrative offenses—such as unjustified wealth accumulation by public officials—these cases are referred to specialized agencies and prosecutors, who then submit claims to the High Anti-Corruption Court for confiscation of illicit assets.
Each organization has its own area of responsibility and defined functions, but in many aspects, we intersect, collaborate, and engage all relevant parties in the process. Notably, the implementation of the State Anti-Corruption Program for 2023–2025 involves 109 government agencies across Ukraine. This is truly a comprehensive effort.
Viktor Pavlushchyk
NACP has been operating for nine years. What do you consider the agency’s greatest achievement?
There are quite a few accomplishments. In September, we had the opportunity to present them during a negotiation process with the European Commission, where Ukraine received positive feedback on its progress in preventing and combating corruption. This is an important step toward EU membership. The European Commission recognized the strengthening of the anti-corruption institutional framework, the increased independence and capacity of SAPO (Specialized Anti-Corruption Prosecutor’s Office), NABU (National Anti-Corruption Bureau), and NACP (National Agency on Corruption Prevention), as well as improvements in pre-trial investigations, court proceedings, and decisions on high-level corruption cases. I can confidently say that there are many examples demonstrating maximum transparency and openness in the Ukrainian government. One of the most notable is the electronic declaration system, which was introduced and is continually modernized and improved. Today, we have over 700,000 public officials who are required to submit annual declarations. This is an extraordinary figure—no other country in the world has such a system with this level of transparency. I also want to highlight the Whistleblower Reporting Portal, which Ukraine has implemented. This system could serve as a model for other countries to adopt.
There are reports that some individuals have officially received financial rewards for exposing bribery. What amounts are we talking about?
Yes, for the first time in Ukraine’s history, NACP issued financial rewards to two whistleblowers this year. One whistleblower received 1.68 million UAH for reporting a bribe offer, while another was awarded 13.3 million UAH. I want to remind everyone that, under Ukrainian law, a whistleblower is entitled to up to 10% of the monetary value of the corruption crime or the damage caused to the state after a court delivers a guilty verdict. This is a landmark event that will give momentum to the further development of the whistleblowing system in Ukraine.
It is clear that reviewing and verifying all 700,000 electronic declarations submitted to NACP annually is impossible. That is why you introduced a risk-based approach. How does it work?
Indeed, compared to 2021, we now apply a risk-based approach when selecting and verifying declarations. Each declaration undergoes an automated verification process. The data provided is cross-checked with interoperable state registers. If all the information matches, the declarant receives confirmation of a successfully completed automated check. If discrepancies are found, it may indicate either violations or, in some cases, the inability to verify certain details within the declaration. Based on this automated review, each declaration is assigned a risk rating. Those with the highest risk scores are selected for a comprehensive review, where income, acquisition feasibility, and expenses are closely examined. If an individual could not have legitimately acquired a certain asset within a given period, we flag this for further investigation. Additionally, full-scale audits may be triggered by public reports, journalistic investigations, or requests from law enforcement agencies. Even declarations that previously passed an automated or full review can be re-examined if new facts emerge.
Conversation with Viktor Pavlushchyk
How strict are the penalties for incorrectly filed declarations? After all, mistakes can happen accidentally.
There are criminal, administrative, and disciplinary penalties, depending on the amount of the discrepancy found. If the sum is significant and it is not just a minor mistake—it suggests at least negligence or even deliberate intent to provide false information. Rest assured, no one is punished for an error of 100 or even 1,000 UAH. The penalties apply to far more serious violations. That said, we firmly believe that the majority of public officials in Ukraine act with integrity.
Your work is divided into two parts: detecting violations and preventing them. What measures are most effective in preventing corruption?
Preventing corruption requires a comprehensive approach. The National Agency on Corruption Prevention (NACP) is a policy-forming body. We conduct research on corruption risks, provide recommendations for their elimination, and perform anti-corruption examinations of legislation. Our work also includes developing key documents like the Anti-Corruption Strategy and the State Anti-Corruption Program, which aim to prevent corruption in all sectors of life. By the way, when drafting the State Anti-Corruption Program and Strategy, we focus on the 15 most vulnerable sectors. These are selected based on research that indicates their level of corruption or high levels of corruption risks. We regularly publish various data on corruption risks, for example, regarding citizens leaving the country during martial law, public procurement, the activities of Medical and Social Expert Commissions (MSECs), and many others. Education is also an essential preventive measure. Additionally, we run youth education projects, like “Transparent Schools” and “Transparent Universities”, because, as we discussed earlier, integrity is something that should be fostered from childhood.
Can Ukraine tackle corruption on its own without external assistance?
We do a lot independently, but we also learn from our partners’ experience. This is especially important in the EU accession negotiation process, where experts and representatives of the European Commission conduct analyses, screenings, and provide recommendations. Ukraine, as a country at war, also receives substantial material support, as it cannot allocate its own resources to certain initiatives. No country can tackle corruption entirely alone, and it is beneficial to adopt the best global practices. That is why we move in both directions: we implement international experience while also developing innovations that others want to adopt. Let me remind you that the electronic asset declaration register, the whistleblower portal, and the information system for monitoring and implementing the National Anti-Corruption Program—these have no equivalent anywhere in the world. Many countries have already approached us, requesting presentations and access to these innovations for implementation in their own systems.
Investigative journalism has often played a key role in bringing cases to public attention. At times, it seemed that relevant authorities only responded under societal pressure.
We greatly rely on and appreciate the work of investigative journalists, as we cannot thoroughly monitor the entire country on our own. Media reports are among the most crucial sources of information, alongside the work of our agency, law enforcement bodies, and an active civil society. Journalistic materials have repeatedly served as a basis for launching full-scale lifestyle audits of officials and for law enforcement intervention when necessary.
You have been leading the agency for almost nine months. Before that, according to your biography, you worked as a detective for a long time. Does your previous experience help, or is your current role mostly administrative?
I applied through an open competition, and, of course, this position is a major achievement for me. However, my primary goal is to use my expertise to drive meaningful change in the country and improve society. My past experience provides valuable insight into the field, which significantly aids me in my current role.
Larysa Lypkan, Varosh
Photo: Natalia Radchenko
This material has been prepared within the framework of the Dutch-Slovak-Ukrainian project ‘Strengthening the Rule of Law at the Local/Regional Level in Ukraine: The Case of Zakarpattia Region’, which is implemented with the support of the Government of the Kingdom of the Netherlands under the MATRA program, a leading Dutch initiative for social transformation support.
The project is being implemented by the Institute for Central European Strategy (ICES) in collaboration with the Dutch organization Foundation of Justice, Integrity and Anti-Corruption (FJIAC) and Transparency International Slovensko (TI SK), in partnership with the Zakarpattia Regional State Administration and the Regional Council.
Important: The content of this material does not reflect the official position or opinions of the project’s implementers or donors. The content of the publications is the sole responsibility of Varosh.
