On April 29, 2026, a working meeting was held between Ukraine’s Deputy Prosecutor General Maksym Krym and the head of the relevant department, Ashot Gevorkyan, and the leaders of more than 30 leading business associations in Ukraine. The event was organized by the UBA, EBA, and ACC with the support of the Center for International Private Enterprise (CIPE).

Participants discussed the results of the STOP_PRESSURE platform, the audit of criminal proceedings against businesses, draft law No. 12439, “gray schemes” in the excise, automotive, and security sectors, as well as the BEB initiative on pre-trial settlement of tax violations.

Maksym Krym, Deputy Prosecutor General of Ukraine, opened the meeting, emphasizing that communication with the business community remains a priority for the Office of the Prosecutor General. He reported on the results of the STOP_PRESSURE platform’s work: in a relatively short time, over 235 reports were processed, and more than 80 million hryvnias were returned to businesses. He also reported on the results of a large-scale audit of criminal proceedings related to business: 9,300 unfounded cases have been closed, and approximately 25,500 remain pending.

The Deputy Prosecutor General also noted certain difficulties the prosecutor’s office faces in enforcing its own directives regarding investigators: “Legally, a prosecutor’s directives are binding. But if you don’t follow them, nothing will happen. A prosecutor can appeal to the head of the investigative body, but that’s as far as it goes.”

At the same time, he reported on specific anti-corruption results: two prosecutors who had extorted money from a business representative were recently detained.

Daria Svistula, Chair of the Committee on Business Protection and Property Rights of the Federation of Employers of Ukraine (FEU), presented the Federation’s position on draft law No. 12439, initiated by the business community. The document significantly strengthens business protection: it regulates the procedure for registering criminal proceedings for economic crimes, conducting urgent searches, and imposing and appealing property seizures. Svistula noted that a partial consensus was reached during the latest review in the Committee on Law Enforcement, but a number of amendments—in particular, the provisions regarding the procedure for urgent searches—remain contentious.

M. Krym supported the need to adopt the law in its main part but noted that certain provisions in the current draft are unacceptable, particularly those that contradict the Constitution.

Yosyp Buchynskyi, vice president of the Ukrainian Taxpayers Association, focused on the systemic problem of investigations under Article 212 of the Criminal Code (tax evasion) and criticized the Economic Security Bureau’s approach to documenting tax violations exclusively through “analytical products,” bypassing tax audit mechanisms. In his view, this deprives taxpayers of the right to appeal tax assessment notices and offers no real prospect of judicial review: only about 10% of cases under Article 212 reach court, and only 1% result in an indictment. He called for a discussion on the need to involve the State Tax Service in documenting tax crimes, noting that such an approach by law enforcement is a source of pressure on businesses, and the cited statistics bear this out, since every criminal proceeding opened against a taxpayer, if it is not referred to court after interrogations and other measures have been conducted, is perceived by the business community as pressure. On the other hand, if the law enforcement agency has sufficient procedural evidence of intentional tax evasion, the criminal proceeding has a prospect of going to court in accordance with the requirements of the Resolution of the Plenum of the Supreme Court of Ukraine dated October 8, 2004, On the Application of Legislation on Tax Evasion.

Oksana Shvets, a representative of the American Chamber of Commerce, highlighted the systematic nature of the ACC’s cooperation with the Office of the Prosecutor General: since May 2020, 71 individual complaints have been filed with the Office by member companies, of which 47 concerned pressure on businesses, and 24 involved situations where companies had suffered harm and were seeking justice. In 37 cases, investor rights were protected, and in 19, significant progress was made. She also emphasized the importance of jointly combating the illicit trade in excise goods, particularly in the tobacco market, and expressed her willingness to continue cooperation, particularly through the ACC platform.

Andriy Solomin, chairman of the All-Ukrainian Association of the E-Cigarette Market, presented the dynamics of budget revenues from the e-cigarette market and demonstrated a direct correlation between legislative changes and the market’s shift into the shadow economy. Following six consecutive legislative changes in 2024, tax revenues to the budget plummeted compared to the record 673 million hryvnias in 2023. He praised the work of the BEB and the Prosecutor General’s Office on high-profile cases in the industry—specifically, the closure of 70 illegal retail outlets—but complained about systemic issues with other law enforcement agencies, particularly the National Police, which lack economic expertise and seize legal excise goods by checking them against the wrong registries.

Georgiy Tupchiy, the controlling shareholder of the security company Venbest, spoke about an initiative by the security industry that led to the passage on December 3, 2025, of a law eliminating the parallel existence of two taxation systems in the security sector—the simplified and the general systems. He noted that the law is already yielding results: most market players have switched to the general taxation system. However, according to him, some companies are resorting to “migration”—formally changing their KVED codes without altering their activities and without paying either VAT or income tax. Mr. Tupchiy drew attention to approximately 600 such companies and asked the Prosecutor General’s Office to monitor this issue.

Vitaliy Matselyukh, attorney and managing partner of Artus Law Firm, a representative of the Association of Security Companies of Ukraine, reported on the association’s initiative to combat dumping in public procurement. Last year, complaints were filed against the 50 largest dumping participants in public procurement with all relevant authorities. Of all the agencies, only the Chernivtsi Regional Prosecutor’s Office responded to one case, and the Dnipropetrovsk Regional Police responded to another. The rest of the complaints, he said, “disappeared without a trace.” In the first quarter of 2026, the number of dumping offenders in public procurement dropped to 78, and he asked the Prosecutor General’s Office to take action on these cases, since the BEB handles only the largest cases and lacks the resources to deal with numerous small-scale violators.

Andriy Antoniuk, Chairman of the Board of the Ukrainian Taxi Association, drew attention to a large-scale scheme to evade customs duties on the import of used cars using forged Eur.1 certificates. According to data from the State Customs Service presented to the Verkhovna Rada’s Temporary Investigation Commission—out of more than 150,000 cars imported over three years with preferential customs clearance without paying duties based on Eur.1 certificates—93% of the Eur.1 certificates checked turned out to be counterfeit or inauthentic, and approximately 110,000 vehicles were cleared without paying duties, likely without being entitled to preferential customs clearance based on counterfeit Eur.1 certificates. Experts estimate the state’s total losses from this scheme alone at 11 billion hryvnias. Antonyuk reported that public sources revealed that on April 22, 2026, human rights activist Vadim Khabibullin filed a criminal complaint with the Office of the Prosecutor General exposing the scheme involving counterfeit EUR 1 certificates. The scheme, involving 11 billion hryvnias, could become one of the most high-profile anti-corruption cases in recent years, and he submitted the collected materials. Deputy Prosecutor General M. Krym assured that this matter would be investigated and properly reviewed.

Mykhailo Sokolov, deputy chairman of the All-Ukrainian Agrarian Council, raised the issue of controversial enforcement practices regarding the requirement to obtain an environmental impact assessment (EIA) for irrigation systems: in the Odesa region, the prosecutor’s office is demanding that an EIA be obtained annually for systems that have existed since Soviet times and have not changed their design boundaries. According to him, obtaining an EIA costs about 500,000 hryvnias and takes at least six months, which is a disproportionate burden for farmers who are just resuming operations after a hiatus caused by the war.

Yevhen Riako, a representative of the Ukrainian Bar Association, raised the issue of introducing “red flags”—a set of clear guidelines for businesses on how to conduct themselves during government tenders, compliance with which would minimize the risk of criminal prosecution under Article 191 (misappropriation of state funds). He noted that currently the only advice lawyers give to clients is not to participate in public procurement at all, as this is the “only guarantee” against criminal risk.

M. Krym noted that the Prosecutor General’s Office is open to dialogue but expressed skepticism about the idea of formalized “red flags,” emphasizing that law enforcement agencies should not discuss their priorities with business associations. He emphasized that the only reliable guideline is compliance with the law, and any expert opinion from the defense will be taken into account in the proceedings.

Rostislav Korobka, vice president of the Ukrainian Chamber of Commerce and Industry, noted that overpricing in government contracts is often a necessity rather than deliberate fraud: the estimated wage in the construction industry is set at 12,000 hryvnias, while the actual market rate starts at 40,000 hryvnias and higher. In such a situation, contractors are forced to “cover up” actual expenses by inflating the cost of materials, which subsequently becomes grounds for criminal prosecution. Mr. Korobka called for this discussion to take place not only at the level of the prosecutor’s office but also with the participation of relevant ministries, as it involves hundreds of billions of hryvnias in contracts and a systemic problem of state regulation.

Serhiy Klyutsa, a partner at Crowe Mikhailenko, cited several categories of cases illustrating the complexities in the interaction between business and law enforcement. The first involves the prosecution of a company executive for management decisions (inventory, charitable contributions to the Armed Forces of Ukraine) at the behest of a minority shareholder: despite the court’s dismissal of the notice of suspicion, the criminal proceedings continue. The second concerns the failure to comply with ECHR rulings that find pre-trial investigations to be excessively lengthy. The Crowe partner cited an example where a motion to dismiss the case was rejected five times with the same justification. He asked the Office of the Prosecutor General to develop a clear protocol for responding to such ECHR rulings.

Yevhen Artyukhov, co-founder of Club100, raised a systemic issue regarding the failure to comply with pretrial judges’ rulings on the return of property: does the Office keep statistics on such cases, and how does it plan to improve the mechanism for monitoring compliance?

M. Krym noted that there are currently no relevant statistics, but assured that every complaint submitted via Stop_Tisk regarding non-compliance with court decisions will be investigated.

Mykola Shcherbina, Executive Director of the Ukrainian Air Transport Association, described the situation that arose in 2024 when the tax service changed its interpretation of the law and equated aircraft leasing with royalties, and the aircraft themselves with industrial equipment. Based on this new interpretation, the BEB launched criminal proceedings against air carriers and their officials for alleged tax evasion—regarding transactions from seven years ago, even though the legislation had not changed during that period.

According to Shcherbina, this situation poses a threat not only to the airlines themselves but also to their relationships with foreign lessors, who may refuse to cooperate with Ukrainian carriers. He appealed to the Office of the Prosecutor General for help in sorting out the situation, since the aviation industry has received no clear explanation from either the tax authorities, the Ministry of Finance, or the State Bureau of Investigation.

Tetyana Lysovets, Vice President of the Ukrainian Bar Association, emphasized the fundamental difference between obvious tax evasion and situations where the law itself allows for dual interpretation. She noted that the Tax Code explicitly states: in the event of conflicting interpretations of the law, the taxpayer is presumed to be correct until the tax authority proves otherwise. Accordingly, until a court has ruled in favor of the tax authority, there is no criminal offense by definition. Lysovets asked the Office of the Prosecutor General to initiate an internal discussion on exactly which cases warrant the opening of criminal proceedings, and to refrain from conducting searches and seizing property where there is no intent.

Yuriy Peroganych, director of the Association of Information Technology Enterprises, raised the issue of a high-profile case from 2020: customs violations amounting to 96 million hryvnias and non-payment of VAT totaling 19 million hryvnias in connection with the import of IT goods and electronics. Despite two parliamentary inquiries to the Prosecutor General, a court ruling finding the driver guilty and imposing a fine of 96 million hryvnias, and the opening of a criminal case—the enforcement proceedings were closed without stating a reason, and the criminal case was closed without charges being filed, even though the owner of the goods is known. He submitted an inquiry regarding the future prospects of the case—whether the statute of limitations has already expired or whether there is still hope for a resolution.

Natalia Artemchuk, a representative of the European Business Association, asked about the official position of the Office of the Prosecutor General regarding the BEB’s initiative on pre-trial settlement of tax violations, specifically regarding the initiation of proceedings based on analytical reports without conducting audits. She also asked how the prosecutor’s office would respond to the BEB’s registration of proceedings in situations where the tax authority had already audited the relevant period and found no violations.

M. Krym replied that he personally does not agree with the idea of pre-trial settlement in the proposed form and had informed the BEB director of this personally, noting that real mediation between law enforcement and business already effectively exists in the form of a current procedural mechanism.

Artem Krykun-Trush, a representative of the Ukrainian Bar Association, confirmed the effectiveness of meetings with representatives of the Prosecutor General’s Office and cited two specific cases. In one case, following the Office’s intervention, the Security Service of Ukraine ceased its unlawful pressure on the director of an international company; in the other, a long-running de facto investigation was finally closed after a thorough review of the case materials. He proposed two systemic changes: first, to allow lawyers to submit appeals through Stop_Tisk on behalf of clients with confirmation of their authority, since the quality of appeals is currently declining because businesspeople without legal training are filling them out on their own. Second, he asked the Office to publish the general criteria used to evaluate complaints—a sort of checklist that would help businesses and lawyers submit higher-quality and better-reasoned complaints.

Ashot Gevorkyan, head of the Department for Oversight of Law Enforcement by Agencies Combating Organized Crime and Protecting Investments, confirmed that he personally reviews all complaints submitted through the Stop_Pressure platform. According to him, 90% of requests for the return of temporarily seized property—especially electronic equipment and documents—are resolved in favor of the business. He acknowledged a systemic problem: the prosecutor does not physically hold the seized property, so he cannot compel investigators to return it quickly. However, Mr. Ashot is personally communicating with relevant parties to expedite this process. A. Gevorkyan urged associations to describe specific illegal actions in their appeals—in particular, the existence of a court order for the return of property—and to refrain from general complaints about pressure during interrogations, since it is precisely these specifics that allow for the fastest possible response.

Following the discussion, the participants reached agreement on nearly all the issues discussed and agreed on systematic cooperation and follow-up meetings at regular intervals.