If Ukraine wants to attract international investment and secure long-term support for its reconstruction, it must demonstrate the integrity of its financial system. Investors need confidence that the country’s anti-money laundering and counter-terrorist financing (AML/CFT) framework is effective, and that confidence can only come from an independent international assessment.

While the European Union assesses elements of Ukraine’s AML/CFT framework as part of the accession process under the «Fundamentals» cluster, that process may be influenced by broader political considerations and cannot, on its own, provide the reassurance sought by international investors. Fortunately, there is an independent benchmark against which all jurisdictions are measured: the MONEYVAL mutual evaluation.

In simple terms, MONEYVAL is an independent international review of whether a country’s anti-money laundering system actually works in practice. It assesses how effectively countries implement the global AML/CFT standards developed by the Financial Action Task Force (FATF), the international standard-setter in this field. As Ukraine is not a direct FATF member, it is evaluated by MONEYVAL, the Council of Europe’s FATF-style regional body.

The stakes are high. Countries with serious weaknesses in their AML systems risk being placed on the FATF’s grey or black lists. Grey-listed countries come under enhanced monitoring, while the black list is reserved for the highest-risk jurisdictions. For both, the consequences are significant: lower investor confidence, more expensive international financial transactions, and lasting reputational damage. Every country works hard to avoid being grey- or black-listed. Ukraine should do the same.

Ukraine’s last mutual evaluation took place almost a decade ago, in 2017. Many of the vulnerabilities identified then remain relevant today, including corruption and tipping-off within law enforcement agencies, the lack of regulation of virtual assets, and insufficient supervision of designated non-financial businesses and professions (DNFBPs).

FATF has recently launched a new round of mutual evaluations, and it is in Ukraine’s strategic interest to undergo its assessment rather than postpone it because of the war. A successful evaluation would strengthen international confidence in Ukraine’s financial system and send a powerful signal to investors. Achieving this, however, will require political leadership to prioritise AML/CFT reforms and allocate the necessary resources to strengthen the system before the evaluators arrive.

The FATF’s methodology has evolved significantly over the past decade. Countries are no longer assessed primarily on whether they have adopted the right legislation, but on whether their systems produce real results: successful investigations, prosecutions, confiscation of criminal assets, and effective risk reduction.

One of the clearest ways to demonstrate this effectiveness is through information sharing between public and private sector, known as public-private partnerships (PPPs). Financial institutions often possess the information needed to identify suspicious financial activity, while law enforcement has the powers to investigate and disrupt criminal networks. Bringing these two sides together through structured information sharing enables faster, better-informed responses to financial crime. Such cooperation can only succeed if the public and private sectors trust one another. Establishing that trust should be Ukraine’s first priority.

Although FATF does not require countries to establish formal PPPs, it has placed increasing emphasis on collaborative approaches in recent years. Its latest report encourages jurisdictions to strengthen public-private cooperation to combat illicit finance, while FATF President Giles Thomson has repeatedly highlighted PPPs as an important tool for improving AML/CFT effectiveness. The newly established Anti-Money Laundering Authority (AMLA), the EU’s new central AML supervisor and coordinator, is going even further by encouraging information sharing between private-sector institutions where appropriate.

For Ukraine, this discussion is particularly timely. Momentum behind a national public-private partnership has grown considerably over the past two years. The Ministry of Finance, the National Bank of Ukraine, financial institutions, and international partners are already working towards a more structured framework for information sharing and joint action. The challenge now is to transform this momentum into a trusted and operational partnership before Ukraine’s next MONEYVAL evaluation.

Ukraine does not need to reinvent the wheel. Successful models already exist. One example is the Lithuanian Centre of Excellence in Anti-Money Laundering, established after a series of major money laundering scandals exposed reputational risks across the Baltic region. Lithuania recognised that protecting confidence in its financial system required closer cooperation between government and the private sector rather than isolated institutional efforts. Ukraine can draw valuable lessons from this experience.

Ukraine has been given something that few countries receive before a mutual evaluation: additional time. The question is no longer whether an integrity of the financial system is desirable, but whether Ukraine will use this opportunity to demonstrate that its AML/CFT system is genuinely effective. If it does, the benefits will extend well beyond a successful MONEYVAL evaluation—to stronger investor confidence, progress towards EU accession, and a more resilient financial system. Ukraine can ill afford the alternative.