Law enforcement officials have resumed investigative actions in a case involving the alleged embezzlement of $4.4 million allocated by the United States for prosecutorial reform. The resumption of inquiries follows the Prosecutor General’s visit to the U.S.
Law enforcement agencies have restarted their investigative work on a criminal case concerning the alleged misappropriation of funds provided by American donors for the reform of the prosecutor’s office. As reported by Sudovo-yurydychna Hazeta, the sum in question is $4.4 million. A portion of these funds might have been channeled through the Anti-Corruption Action Center (ACAC) to private entrepreneurs, reports UNN.
The publication notes that progress in the criminal proceedings began following a recent visit of the Prosecutor General of Ukraine to the United States. This case pertains to criminal proceedings No. 42016000000000688, which deals with the utilization of international technical assistance funds for the reform of the prosecutor’s office. The criminal proceedings were initiated back in March 2016.
“The history of the proceedings shows a clear political-legal turning point. The case was opened in March 2016 based on signs of possible appropriation of international technical assistance funds allocated for the reform of criminal justice in Ukraine. However, in May of the same year, after Yuriy Lutsenko’s appointment as Prosecutor General, investigative actions were abruptly halted. The prosecutor publicly declared the case as one that disgraced the Prosecutor General’s Office,” the publication points out.
However, as highlighted by Sudovo-yurydychna Hazeta, in March 2026, an investigative judge of the Pechersk Court considered a prosecutor’s motion for temporary access to items and documents. By a ruling dated March 12, 2026, the Pechersk District Court of Kyiv granted the prosecutor’s request from the Office of the Prosecutor General and authorized temporary access to documents from the U.S. Department of State and the Bureau of International Narcotics and Law Enforcement Affairs (INL) concerning international technical assistance project No. 3313. The investigation is seeking reports on the project’s implementation outcomes, completion certificates, invoices, and payment orders to verify the legality of the $4.4 million expenditure.
Essence of the Criminal Proceedings
During the period of 2014–2016, Project No. 3313, “Support for Criminal Justice Reform in Ukraine,” was implemented in Ukraine, with a total value of $4.4 million.
The primary donors for the project were the U.S. Government and the Bureau of International Narcotics and Law Enforcement Affairs of the U.S. Department of State (INL).
The General Prosecutor’s Office of Ukraine acted as the official beneficiary and recipient of the aid from the state. Davyd Sakvarelidze was designated as the responsible person for the beneficiary, and Hennadiy Kachibai as the project’s contact person. The National Prosecution Academy of Ukraine was also involved in the process of reviewing tests for prosecutors. Concurrently, non-governmental organizations, particularly the Anti-Corruption Action Center (ACAC), played a significant role in executing related tasks.
The criminal proceedings were initiated on March 16, 2016, under Article 191, Part 5 of the Criminal Code of Ukraine – appropriation or embezzlement of property through abuse of office on a particularly large scale. The impetus for opening the case was an official parliamentary inquiry from Member of Parliament Ihor Suslov.
According to the investigation’s version, project funds were utilized through a mechanism involving non-governmental organizations and private entrepreneurs.
In March 2016, the Pechersk Court of Kyiv granted the Prosecutor General’s Office investigators access to the bank accounts of the ACAC. The justification stated that the Prosecutor General’s Office, as the beneficiary, had not received funds nor entered into contracts, and the aid might have been used improperly.
In total, during March and May 2016, investigators obtained over 27 permits for access to documents held by the Treasury, the National Bank of Ukraine, and commercial banks.
Fund Flow Scheme and Position of Investigative Bodies
Based on the review materials analyzed by law enforcement officers, the financial model of interaction between donors and implementers was as follows:
U.S. Government/INL — Project No. 3313 — ACAC — Private Entrepreneurs
Analytical reports from law enforcement agencies indicated that:
- approximately 80% of the funds received by ACAC were transferred to the accounts of private entrepreneurs based on civil law agreements for the performance of various services (expert research, analytics, IT solution development, etc.);
- Vitaliy Shabunin, a co-founder of ACAC, is specifically mentioned in the materials as having received approximately 800,000 UAH as a private entrepreneur for work/services rendered. The mere fact of receiving funds does not indicate a violation of legislation and is subject to assessment by law enforcement agencies.
For their part, the engaged expert group, as indicated by the publication citing investigation materials, provided purely scientific and methodological support for the project, including the creation and validation of testing tools for the personnel renewal of the prosecutor’s office.
Positions of Parties and Further Developments in the Case
The publication notes that official Washington had previously stated that there were no claims regarding the use of allocated funds.
“Consequently, a serious legal conflict arises: can embezzlement or misappropriation of property be charged if the owner (donor) themselves declares no damages and full fulfillment of contractual terms, and did international partners influence the investigation of the grants for prosecutorial reform?” – the article states.
The publication points out that if the investigation possesses objective, admissible, and sufficient evidence of possible violations of national legislation in the transfer of funds to private entrepreneurs, society and the legal community have the right to expect appropriate procedural decisions, such as the announcement of suspicion or the referral of the case to court. If such evidence is insufficient or the U.S. Embassy’s position negates the elements of the crime, society has a legitimate right to know the reasons why this criminal proceeding has remained open for over a decade.
An analysis of criminal proceedings No. 42016000000000688 demonstrates a complex balance between the internal jurisdiction of the state and international obligations in the sphere of technical assistance.
“Sources suggest that the intensification or, conversely, the potential closure of this case following 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 a court can bring finality to this case. Any political interpretations must give way to a legal analysis of the evidence. Absolute transparency, adherence to reasonable timeframes, and the completion of the process are essential to dispel the numerous assumptions that have accumulated around this matter,” the article emphasizes.
Sudovo-yurydychna Hazeta noted that at the time of publication, no individual had been served with a notice of suspicion in the mentioned criminal proceedings, and there is no information regarding a court conviction. The circumstances presented in the material are at the pre-trial investigation stage and require a final legal assessment by authorized bodies.