IMF Report on Ukraine Asset Declaration System: Wasting enormous resources on low value tasks, spending little on those that matter

No, that is not what the new IMF report on Ukrainian’s asset declaration system says. International organizations are never that blunt. 

But reading the careful, thorough assessment of Ukraine’s most important anticorruption program it is clear that what the authors were thinking given what they found. And what they did say comes awfully close:

  • “The effectiveness of Ukraine’s [Asset Declaration System] is undermined by an overly expansive and highly formalistic framework that overburdens the [National Agency on Corruption Prevention], weakens prioritization, and limits the system’s capacity to support meaningful detection and recovery of illicit assets.”
  • “[Its] expansive scope, which is unmatched by other European nations, strains the NACP by forcing it to manage one of the world’s largest database of public officials’ assets with highly limited resources.”
  • “The conversion of NACP findings into final judicial sanctions remains limited. In 2025, the NACP transmitted 369 reasoned conclusions to law enforcement for criminal prosecution. These resulted in 12 guilty verdicts, a marked improvement from zero verdicts in 2021, but a conversion rate that remains low relative to the volume of referrals and reflects the broader systemic delays in the judicial pipeline for high-level corruption cases.”

More lifestyle audits

Comparing what officials declare they own to their house they live in, the car they drive, the vacations they take, and other properties they own and expenses they incur is the most effective way to spot if they are corrupt (here). The NACP has a unit dedicated to conducting such audits, but as the IMF report found, not only does the Lifestyle Management (LSM) group have a small staff, but the audits do not focus on priority areas such as 

“. . . war-related procurement and expenditure, where the convergence of significant public resources and reduced oversight creates acute corruption vulnerabilities.”  

The recommendation to audit the lifestyle of those involved in procuring military supplies and equipment comes at a critical time. Confidential reviews by the State Audit Service and an internal Ministry of Defense auditing department show war profiteering has reached unconscionable levels. Front-line troops are being supplied with worthless ammunition while military contractors are reaping huge profits (here).

Lifestyle audits are the surest, fastest way to weed out those officials corrupting the military procurement process. NACP staff now conducting routine checks of the accuracy of low-level officials’ declarations should be reassigned to the LSM unit and ordered to scrutinize the lifestyle of every single individual involved in military procurement.

Ukraine’s supporters in the international community have long recognized that an asset declaration program is crucial to curbing corruption and made its establishment a condition of continued financial assistance. The IMF report provides a roadmap for making the program effective. The international community should insist the government follow that map with haste.

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