At a time when Ukraine is fighting for survival on the front lines, the National Agency for Corruption Prevention (NAPC) has become the perfect tool for concealing the ill-gotten gains of high-ranking officials. Thousands of asset declarations have vanished from public access, ostensibly for “security reasons”—but in reality, this is a convenient loophole allowing officials, judges, customs officers, and law enforcement to evade public scrutiny. Journalists from the independent anti-corruption outlet NGL.media gained access to these “secret” documents and discovered: behind the mask of martial law lies a life of luxury, suspicious assets, and classic signs of illicit enrichment.

It all began on February 24, 2022, the day Russia launched its full-scale invasion. The NAPC immediately closed public access to its registers, including the declarations registry. A few days later, Ukraine’s parliament passed a law allowing all officials to stop filing declarations until the end of martial law. The NAPC also halted checks on previously submitted declarations.

“In these difficult times, NAPC officials, along with declarants, are defending the borders of our Motherland—so victory first, then declarations and checks,” explained then-NAPC head Oleksandr Novikov. Initially, everyone hoped the war would end quickly, making the closure of registers and accountability measures seem temporary.

The first attempt to restore declarations came in September 2022, with pressure from European partners. But the NAPC insisted they remain hidden, calling it “a matter of physical security, life and death for Ukrainian citizens.”

Ultimately, mandatory declaration was restored a year later—on October 12, 2023, when parliament passed the relevant law. All officials were required to submit missed declarations within four months. However, the law allowed hiding declarations for certain categories, including relatives: if a spouse, sibling, or child serves in the military while you work as a judge in a peaceful city, your declaration can also be concealed.

Crucially, the NAPC does not hide declarations automatically—only upon request. The head of the official’s agency must submit a special application, which the NAPC reviews and can remove the declaration from public access within 10 days. This applies not only to declarations from 2022 onward but to all previous ones as well.

Declarations of job candidates or former officials who joined the military after leaving office can also be hidden. For example, the declaration of former Luhansk Regional Administration head Artem Lysogor—who joined the separate National Police assault brigade “Lyut” after dismissal—was concealed.

If the grounds for hiding expire (e.g., security risks disappear), the NAPC must restore public access—but only upon a separate request, as the agency does not monitor changes independently.

But are decisions to classify declarations always justified? In response to an NGL.media inquiry, the NAPC admitted it does not verify the validity of grounds: “The NAPC does not check the substantiation of reasons for removing declarations from open access. It only verifies compliance with formal requirements.”

How many declarations are hidden? The NAPC claims it does not track statistics. However, NGL.media found that in 2025 alone, declarations of 5,352 individuals—totaling 6,836 documents—were removed from public view.

Many who use this option hold jobs with little apparent risk: employees of the National Bank, tax service, treasury, archives, Kyiv Zoo, or even the Presidential Orchestra. Officials in similar positions assess “risks” differently—for instance, Kharkiv Regional Administration head Oleh Syniehubov (in office since December 2021, with no public record of military service) hid his declaration. In contrast, Zaporizhzhia Regional Administration head Ivan Fedorov, whose region is also on the front line, keeps his open. An inquiry to Kharkiv administration yielded no clear explanation.

NGL.media has only Syniehubov’s 2025 notice of substantial property changes, showing UAH 155,000 in March salary.

New Head of Odesa Military Administration

Examining some hidden declarations reveals reasonable suspicions of illicit enrichment—discrepancies between expenses, assets, and official income—which the NAPC is supposed to detect.

Take Serhiy Lysak, former head of Dnipropetrovsk Regional Administration, appointed in October 2025 to lead the newly created Odesa City Military Administration.

A former military officer and senior SBU official, Lysak and his wife own no real estate. While in Dnipro, he rented a house in the elite “Golden Keys” cottage community (monthly rent: UAH 60,000–110,000). They own no vehicles but lease four: Mercedes-Benz S 500, Toyota Land Cruiser, Volkswagen Touareg, and Volkswagen Passat (lease costs undisclosed).

Their main 2024 income: nearly UAH 1.1 million from the regional administration, plus UAH 32,000 for Lysak’s teaching and UAH 58,000 for his wife’s postgraduate studies. Savings: USD 10,000 and UAH 15,000.

Lysak declined to comment on the income-expense mismatch when contacted by NGL.media.

Hidden Declarations of Law Enforcement

The list includes far more law enforcement officials—about three times as many as Armed Forces personnel—not just special forces on combat missions. It features State Bureau of Investigation (DBR), Bureau of Economic Security (BEB), National Police strategic investigations, and even a pretrial detention center guard.

For example, the declaration of Roman Mudy—former head of BEB operations in Lviv and subject of a Ukrainian Pravda investigation—was hidden despite his dismissal. After NGL.media contacted the NAPC, it was opened (the agency says Mudy requested this himself).

Ivan Salenkov, deputy director of the DBR territorial office in Poltava, also hid his declaration—unlike his director Denys Mankovskyi and another deputy, Oleh Sorskyi.

Salenkov’s declaration shows why: he rents an apartment in Poltava, but his wife Nataliia Buhaets owns over 1,000 m² of real estate in Kharkiv (four apartments, three garages, large suburban house) plus land. They own four cars: Lexus RX-200T (used by Salenkov), Mercedes-Benz GLC, Toyota RAV4, and Nissan Cefiro.

2024 income: nearly UAH 2.5 million salary for Salenkov, plus UAH 131,000 pension and over UAH 30,000 bank interest. His wife earned UAH 77,000 at Kharkiv Pedagogical University and over UAH 2 million in interest, dividends, and securities sales.

Savings: over UAH 12 million, USD 300,000, EUR 242,000. His wife lent EUR 300,000 to his father Volodymyr Salenkov’s Bulgarian company “DV BUILD EOOD,” which builds in Sofia.

Salenkov and the DBR refused to explain the classification. Previously, the NAPC found over UAH 2.1 million in false information in his 2023 declaration—grounds for criminal charges under Article 366-2. No evidence of punishment was found.

Gifts in a Hidden Declaration

Kyiv Customs post chief Ruslan Maliuha also hid his declaration, citing his wife’s military service. The family owns land and a 228 m² house in Brovary, his wife a 59 m² apartment there, and son a 54 m² Kyiv apartment. In 2024, Maliuha received a gifted 70 m² Kyiv apartment worth UAH 1.7 million. His wife bought a 2022 Volkswagen Tiguan for UAH 1.1 million. Family income: just UAH 1.1 million.

NGL.media has Maliuha’s 2025 property change notices: late February sale of the gifted apartment for UAH 4.2 million; April sale of his 15-year-old Lexus RX350 for UAH 830,000; May purchase of a 2020 Volkswagen Touareg for UAH 1.6 million.

Maliuha said he is “always open to communication” but referred questions to his employer. His wife declined comment. Kyiv Customs insists the hiding “in no way aims to conceal income or avoid transparency” but refused to explain the funds’ origin.

These cases are just the tip of the iceberg. In a warring country, transparency is not a luxury but a necessity. When soldiers die on the front, and officials hide millions behind “security,” it is not just corruption—it is a betrayal of public trust. It is time for the NAPC to stop being an accomplice and start verifying substance, not just forms.

Sources:

• Original investigation by NGL.media (republished on Focus.ua, December 28, 2025): NAPC Classified Thousands of Declarations: Which Officials Hid Their Income
• Law of Ukraine No. 3384-IX of September 20, 2023, on restoration of declaration: explanations on the NAPC website.
• Official NAPC declarations registry: public.nazk.gov.ua
• Information on Serhiy Lysak’s appointment: reports on 24tv.ua and suspilne.media (October 2025).

Author: Maria Horban; data collection and analysis: Maksym Pikho; editor: Oleh Onysko; translation: Neliia Plakhotа (original credits); English translation prepared for publication.