Ukraine is fighting on the frontlines while tackling entrenched issues like financial crime, making the reform process both demanding and complex. As the country moves towards EU accession, it is gradually implementing necessary measures.

Notably, Ukraine has a strong understanding of money laundering and terrorist financing risks, as recognised by MONEYVAL evaluators. However, due to its geopolitical location, political challenges, and the ongoing full-scale invasion, the country remains vulnerable. Despite legislative improvements and efforts to enhance system effectiveness, some issues persist.

This policy brief highlights two types of challenges: those associated with the EU accession process; and those that must be addressed to enhance Ukraine’s response to financial crime and strengthen the resilience of its financial system. The brief then provides recommendations for improvement. 

The research identified six key areas that require attention in Ukraine: the low level of PPP in combating financial crime; lack of regulation of virtual assets; insufficient supervision of designated non-financial businesses and professions (DNFBPs); limited financial investigations capacity; the growing prevalence of money mules; and weak targeted financial sanctions (TFS).