Law enforcement officers have resumed the investigation into the embezzlement of funds allocated by donors for the reform of the prosecutor's office

Law enforcement agencies have resumed investigative actions in criminal proceedings investigating the embezzlement of funds allocated by American donors for the reform of the prosecutor's office. As reported by the Judicial and Legal Gazette, it concerns $4.4 million. Part of the funds may have been funneled through the Anti-Corruption Action Center (CPK) to individual entrepreneurs (FOPs), writes UNN.

The publication notes that movement in the criminal proceedings began after the recent visit of the Prosecutor General of Ukraine to the United States. It concerns criminal proceedings No. 42016000000000688, which relate to the use of international technical assistance funds for prosecutor's office reform. The criminal proceedings were opened back in March 2016.

"The history of the proceedings has a clear political and legal turning point. The proceedings were opened back in March 2016 on the grounds of possible misappropriation of international technical assistance funds allocated for criminal justice reform in Ukraine. However, in May of the same year, after the appointment of Yuriy Lutsenko as Prosecutor General, investigative actions suddenly ceased. The prosecutor publicly called the case one that disgraces the GPU," the publication states.

However, as the Judicial and Legal Gazette indicates, in March 2026, an investigating judge of the Pechersk Court considered the prosecutor's motion for temporary access to items and documents. By a ruling dated 12.03.2026, the Pechersk District Court of Kyiv granted the motion of the prosecutor of the Office of the Prosecutor General and authorized temporary access to documents of the U.S. Department of State and the INL Bureau regarding international technical assistance project No. 3313. The investigation is seeking reports on project implementation results, acts of completed work, invoices, and payment orders to verify the legality of the use of $4.4 million.

The essence of the criminal proceedings

During the period 2014–2016, Project No. 3313 "Support for Criminal Justice Reform in Ukraine" was implemented in Ukraine, with a total cost of $4.4 million.

The main donors of the project were the U.S. Government and the Bureau of International Narcotics and Law Enforcement Affairs (INL) of the U.S. Department of State.

The official beneficiary and recipient of assistance on behalf of the state was the General Prosecutor's Office of Ukraine, where Davit Sakvarelidze was designated as the responsible beneficiary person, and Hennadiy Kachibaya as the project contact person. The Academy of the Prosecutor's Office of Ukraine was also involved in the process of reviewing tests for prosecutors. At the same time, non-governmental organizations, in particular the NGO "Anti-Corruption Action Center" (CPK), played an important role in implementing related tasks.

The criminal proceedings were initiated on March 16, 2016, on the grounds of Part 5 of Article 191 of the Criminal Code of Ukraine — misappropriation or embezzlement of property through abuse of official position on an especially large scale. The reason for opening the case was an official parliamentary request from People's Deputy Ihor Suslov.

According to the investigation's version, project funds were used through a mechanism involving NGOs and individual entrepreneurs (FOPs).

In March 2016, the Pechersk Court of Kyiv granted investigators of the GPU access to the bank accounts of the NGO "Anti-Corruption Action Center." The justification stated that the GPU, as the beneficiary, did not receive funds and did not enter into contracts, and the assistance was allegedly used for purposes other than intended.

In total, in March and May 2016, investigators obtained over 27 authorizations for access to documents in the Treasury, the NBU, and commercial banks.

The scheme of fund movement and the position of investigative bodies

According to the inspection materials analyzed by law enforcement, the financial model of interaction between donors and implementers was as follows:

U.S. Government/INL — Project No. 3313 — NGO "CPK" — Individual Entrepreneurs (FOPs)

Analytical reports of law enforcement agencies stated that:

• approximately 80% of the funds received by the NGO "CPK" were transferred to the accounts of individual entrepreneurs (FOPs) based on civil law agreements for the performance of various services (expert research, analytics, development of IT solutions, etc.);
• separately, the materials mention the co-founder of the NGO "CPK," Vitaliy Shabunin, who, according to the report, as an individual entrepreneur (FOP), received approximately UAH 800,000 for the performance of work/services. The mere fact of receiving funds does not indicate a violation of the law and is subject to assessment by law enforcement agencies.

For its part, the involved expert group, as the publication states, relying on investigation materials, provided purely scientific and methodological support for the project, in particular the creation and validation of testing tools for the personnel renewal of the prosecutor's office.

Position of the parties and further progress in the case

The publication indicates that official Washington previously reported that there are no claims regarding the use of the allocated funds.

"Thus, a serious legal conflict arises: can embezzlement or misappropriation of property be charged if the owner (donor) himself declares the absence of losses and full fulfillment of the contract terms, and did international partners influence the course of the investigation into the case of grants for prosecutor's office reform?" the article states.

The publication notes that if the investigation has objective, proper, and sufficient evidence of possible violations of national legislation in the transfer of funds to individual entrepreneurs (FOPs), society and the legal community have the right to expect appropriate procedural decisions, such as the announcement of suspicions or referral of the case to court. If such evidence is insufficient or the position of the U.S. Embassy negates the elements of the crime, society has a legitimate right to know the reasons why this criminal proceeding has remained open for over ten years.

The analysis of criminal proceedings No. 42016000000000688 demonstrates a complex balance between the state's internal jurisdiction and international obligations in the field of technical assistance.

"Sources suggest that the activation or, conversely, the potential closure of this case after international visits by the leadership of the Office of the Prosecutor General may indicate a search for legal consensus. However, from a legal standpoint, only the court should put an end to this case. Any political interpretations must give way to a legal analysis of the evidence. It is absolute transparency, adherence to reasonable timeframes, and the completion of the process that can eliminate the numerous assumptions that have accumulated around this case," the article emphasizes.

The Judicial and Legal Gazette noted that at the time of publication, in the mentioned criminal proceedings, no person has been served with a notice of suspicion, and there is no information about a court conviction. The circumstances presented in the material are at the stage of pre-trial investigation and require a final legal assessment by the authorized bodies.