An anti-corruption investigation reaching from Ukraine's Presidential Office into the management of state-owned Sense Bank has raised questions far beyond the alleged laundering of UAH 150 million. At stake are the governance of nationalised assets, the independence of Ukraine's anti-corruption institutions, a planned bank privatisation, an international arbitration worth more than $1 billion and Kyiv's credibility as it moves deeper into EU accession negotiations.

A week after Ukrainian anti-corruption investigators unveiled an operation carrying the improbable codename “Forrest Gump”, the affair has developed into one of the most consequential governance scandals to hit wartime Ukraine.

At its center is a deceptively simple question: Where did UAH 150 million — approximately $3.4 million — used to secure the release on bail of former Justice and Energy Minister Herman Halushchenko, a centerpiece of the biggest corruption scandal of Zelensky government, actually come from?

The answer alleged by Ukraine's National Anti-Corruption Bureau, NABU, and Specialised Anti-Corruption Prosecutor's Office, SAPO, is extraordinary.

Investigators say criminal proceeds under the supervision and manual management of deputy head of the Office of the president of Ukraine Iryna Mudra were converted into apparently legitimate funds through a series of companies and bank accounts. The source of the money is linked with the main suspect of another corruption scandal Timur Mindich, a close ally of president Zelensky, and the goal was to post bail for a suspect in the Operation Midas investigation into alleged corruption surrounding the state nuclear company Energoatom.

NABU's official account says members of a criminal organisation, acting with representatives and officials of a state-owned bank, arranged the laundering of UAH 150 million during June 2026. The cash was allegedly introduced into the legitimate financial system through accounts belonging to shell companies before being used for bail.

The most revealing evidence released by NABU is not just a bank transfer but Mudra’s own confessions, which give wider picture. In one recorded exchange, a female voice attributed to her says: “Corruption should be systematised and controlled… There is no need to fight it.” A male interlocutor adds: “And lead it.” This is said by one of the highest Ukrainian official in charge of judicial reform. Yet her own words are arguably more disturbing, presenting corruption not as an abuse to be eliminated but as a system to be organised and kept under political management.

Other recordings portray Mudra discussing state owned Sense Bank, where this money-loundering operation took place, as an asset to be under direct political control and used for enrichment. She recounts a proposed arrangement under which political figures politicians from Zelensky party Servant of the People would refrain from attacking the bank while “Sense Bank has to pay them”, and quotes an instruction she received from above to “take over the bank” because it contains “serious flows”. She then describes its managers as compliant figures who would carry money wherever a senior Presidential Office official instructed them, adding that they had “crawled” to her “like kittens” asking to be taken under protection.

NABU’s published recording also appear to show Mudra discussing protection from the institutions supposed to investigate such conduct. She asks how to mobilize votes for “our” candidates to NABU’s Public Oversight Council and describes SAP chief Oleksandr Klymenko as “not one of ours,” warning that if he secured a second term, “we’ll all be fucked.” Taken together, these phrases suggest something broader than participation in a single suspicious transaction: an alleged attempt to control a state-owned bank while influencing the bodies capable of investigating that control. If authenticated and confirmed in context, they would provide unusually direct evidence of political capture and consciousness of wrongdoing. Mudra denies criminal conduct and says the excerpts were released selectively and without their full context.

Taking over the bank  

Revelations are shocking in many dimension and will have influence for years to come. One of the most striking revelation is usage of the state-owned Sense Bank as systemic money-laundering machine.

Sense Bank carries unusual political and legal baggage. Until 2022 it was known as Alfa-Bank Ukraine and was owned through corporate structures associated with ABH Holdings. Among the beneficial shareholders were Russian businessmen including Mikhail Fridman and Petr Aven.

Ukraine subsequently imposed sanctions and, in July 2023, the government took Sense Bank into state ownership. Ukraine's Ministry of Finance says the measure was intended to maintain financial stability and protect depositors after sanctions were imposed on significant shareholders. The state today owns 100% of the bank.

It was therefore no ordinary commercial bank allegedly being exploited. It was an asset that Ukraine had taken into public ownership during wartime, in considerable part because of national-security concerns surrounding its previous ownership.

The source material examined by EU Reporter describes this as a crucial feature of the scandal: after nationalisation, the allegation is not simply that corrupt actors conducted transactions through Sense Bank, but that political influence was progressively established over the institution's governance.

That allegation remains contested and has not been established by a court. But documents released by NABU and widely reported by the Kyiv Independent and other leading Ukrainian media raise questions that are difficult for the Ukrainian authorities to ignore. The Kyiv Independent reported on 22 August that internal Nomination Committee records showed attempts to shape Sense Bank's supervisory board following nationalisation. The paper reported that Iryna Mudra, then deputy head of the Office of the President and chair of the committee involved in selecting supervisory-board members, strongly promoted Mykola Hladyshchenko for a place on the board despite objections concerning competence, potential conflicts of interest and previous employment. Hladyshchenko subsequently became chairman of the supervisory board.

The investigation also cited earlier leaked conversations in which prospective board candidates were allegedly described as “our guys”. Six people reportedly discussed in that context were subsequently appointed. EU Reporter has not independently authenticated those recordings or the leaked committee minutes, so their contents must remain attributed to the publications that obtained them.

However, now the anticorruption agencies established with support and guidance of the EU provide their findings suggesting that the bank was deliberately captured for criminal purposes. NABU says that by early June 2026 the alleged organisers had obtained de facto control of Sense Bank, enabling them to use accounts of controlled businesses in the laundering scheme. That allegation has now triggered action at the highest levels of financial regulation.

Bags of cash, shell companies and a banking bottleneck

The alleged mechanics of the operation read more like a crime thriller than a banking-compliance investigation. According to the investigative material compiled in the source document and subsequent Ukrainian reporting, cash was allegedly concentrated through businesses associated with former MP and developer Maksym Mykytas before being exchanged or routed through companies capable of putting apparently legitimate non-cash funds into the banking system.

The source describes alleged deliveries of cash in bags and boxes, routing through companies including Metrobud and other entities, and discussions about how transactions could pass financial-monitoring controls.

Ukraine's anti-money-laundering regime establishes a UAH 400,000 statutory threshold for certain financial-monitoring obligations, alongside wider risk-based requirements. It would be inaccurate to suggest that every payment above UAH 400,000 is automatically prohibited; rather, banks are expected to identify, scrutinise and where necessary report transactions according to statutory and risk criteria.

The significance of the NABU allegation is therefore not simply the size of the payment. Investigators allege that people involved in the transaction were actively discussing how to overcome or circumvent compliance barriers. Published recordings attributed to members of the alleged group include discussion of a Sense Bank compliance official who could prevent the transaction. Mudra in one recording says that she received demand “from above” to fire a bank official who refuse to clear transaction. The scheme released by NABU paint a shocking picture: to make the transfer the bank's automated monitoring arrangements were temporarily taken out of operation during the transaction.

Those are NABU allegations presented to the court. But the Ukrainian government has already treated them seriously enough to take immediate action. This confirms that NABU accusations are well grounded. 

Saving face

On 19 August, the Cabinet suspended supervisory-board chairman Mykola Hladyshchenko for six months and initiated the suspension of management-board chairman Oleksii Stupak. The Finance Ministry explicitly said that its intervention was designed to address risks including the possible use of Sense Bank for money laundering and inadequate oversight of AML procedures.

The following day, National Bank of Ukraine Governor Andriy Pyshnyi went further. The NBU concluded that Hladyshchenko no longer satisfied the statutory independence requirements for membership of the supervisory board and opened proceedings to examine the collective suitability of the entire board. On 21 August, the government terminated Hladyshchenko's powers altogether.  This regulatory reaction matters because it turns the episode from an allegation concerning individual criminal behaviour into a potential failure of corporate governance and banking supervision.

Sense Bank itself has said it is cooperating with the authorities. Following the NABU searches, the bank said it wanted the circumstances established “fully and objectively” and was providing investigators with the information required under legal procedures.

But the key question is different. There have been already multiple accusations of usage of nationalised Sense bank for allegedly corrupt or shadow schemes. NABU revelation did not come from nowhere and were not a separate incidental case. In previous NABU and journalistic investigations shocking facts of how bank has been used were presented. How was it possible that in time of war after nationalisation of one of the biggest banks  it could turn into money-laundering machine?

The Presidential Office role

The highest-profile suspect is Iryna Mudra. Mudra served as deputy head of the Office of the President and held responsibility for major legal and judicial-policy issues, including international mechanisms concerning Russian aggression and frozen Russian assets. President Volodymyr Zelenskyy dismissed her on 19 August. Presidential Decree No. 734/2026 confirms the dismissal but does not give a reason.  NABU and SAPO served Mudra with a notice of suspicion. On 25 August, Ukraine's High Anti-Corruption Court ordered her held in custody for 60 days while allowing release if UAH 20 million bail is posted. Prosecutors had requested considerably higher bail.

Mudra denies criminal wrongdoing. She has argued that the published recordings have been presented selectively and out of context. Through her lawyers, she has said that she is cooperating with investigators and is prepared to answer their questions through the proper legal process. The underlying source document expressly records those objections and cautions concerning the provenance and quality of some recordings.

On 24 August President Zelenskyy said the anti-corruption bodies had “no questions” for him regarding the investigation.

The billion-dollar shadow over Sense Bank

There is another legal dimension. Former shareholder ABH Holdings commenced ICSID arbitration against Ukraine after the 2023 nationalisation, seeking more than $1 billion and alleging unlawful expropriation. UNCTAD records the dispute as ABH v Ukraine, ICSID Case No. ARB/24/1, concerning the former ownership of Alfa-Bank/Sense Bank. A separate proceeding, EMIS v Ukraine, also concerns alleged unlawful expropriation of Sense Bank.

The government's 2023 decision was taken in the context of sanctions and financial-stability considerations. Whether it complied with the relevant investment treaties is a matter for international tribunals, not for a criminal investigation conducted three years later. Nevertheless, evidence about how the asset was governed after nationalisation could become relevant contextual material in those proceedings.

ABH's case alleges that the taking of Sense Bank was unlawful. Ukraine will defend the nationalisation on its own legal and national-security grounds. A subsequent allegation that politically connected actors exploited the nationalised institution does not answer that legal dispute, but it could make the factual history of the asset considerably more uncomfortable for Kyiv. The source analysis supplied to EU Reporter correctly identifies this potential intersection. Forrest Gump can raise a question about bad faith in the original nationalisation and the consequences might go much further than a bail for one allegedly corrupt official.

And the cherry on the top: Mudra was also one of the officials responsible for formulating and publicly defending Ukraine’s position against ABH Holdings, the former owner of Sense Bank, in its more than $1 billion ICSID claim over the bank’s nationalisation; she later chaired Ukraine’s delegation in other major international proceedings. This creates a particularly damaging contradiction: an official who defended the takeover as a lawful national-security and financial-stability measure is now accused of helping place the same bank under political control and use it to launder criminal proceeds. The allegations do not by themselves prove that the 2023 nationalisation was unlawful, but they seriously undermine the factual and moral credibility of Ukraine’s case and offer ABH a powerful argument that the bank was not transferred into genuinely independent state management, but into a system vulnerable to political capture.

Why Brussels should be watching

Forrest Gump is not an isolated investigation. Its roots reach into Operation Midas, NABU's investigation into alleged large-scale corruption at state nuclear operator Energoatom. NABU says Midas uncovered a criminal structure involved in substantial corruption and subsequent money laundering. Later investigative developments have continued into 2026.

The Forest Gump allegations concern money ultimately used as bail for an individual implicated in that wider investigation. This changes the character of the alleged conduct. If prosecutors prove their case, it would mean that money generated through criminal activity was not merely hidden or spent. It was allegedly recycled back into the criminal-justice system itself to secure the liberty of another suspect.

And here we come to the point vitally important for Brussels.

Ukraine formally opened negotiations on the EU's Fundamentals cluster on 15 June 2026. That cluster includes the judiciary, fundamental rights, justice and security, public procurement and financial control. Crucially, it is the first cluster opened and the last to close, and the European Commission has made clear that progress under it determines the overall pace of accession negotiations.

Ukraine is simultaneously receiving extraordinary financial support from the European Union. The Ukraine Facility provides up to €50 billion between 2024 and 2027, and support is tied to democratic mechanisms, the rule of law, sound financial management, anti-corruption safeguards and reform commitments.

The issue for Brussels is therefore not whether corruption exists in Ukraine. No serious accession process operates on the assumption that candidate countries are free of corruption.

The more important test is whether institutions can discover it, investigate it, prosecute it and correct the governance failures that allowed it without political obstruction. Viewed from that perspective, Forrest Gump presents two competing narratives. The negative interpretation is obvious: people occupying some of the highest positions in the Ukrainian state are alleged to have manipulated a nationalised bank and circumvented controls to launder criminal proceeds.

The more positive institutional interpretation is that Ukraine's own anti-corruption agencies investigated them, published evidence, served suspicion notices, triggered removals at a state bank and brought one of the country's most senior former presidential officials before an independent anti-corruption court.

Which narrative ultimately prevails will depend heavily on what happens next.

The US Food and Drug Administration’s (FDA) decision to allow 20 ZYN nicotine pouch products to carry a specific reduced-risk claim has created a striking contrast with the direction of European Union policy, as Brussels prepares new product rules and proposes EU-wide taxation of nicotine pouches.

The United States Food and Drug Administration has authorised 20 ZYN nicotine pouch products to be marketed with a statement informing adult smokers that completely replacing cigarettes with the pouches can reduce the risk of several serious diseases.

The decision, issued on 30 June 2026, represents the first time that the FDA has granted Modified Risk Tobacco Product orders to nicotine pouches.

The authorised wording states:

“Using ZYN instead of cigarettes puts you at a lower risk of mouth cancer, heart disease, lung cancer, stroke, emphysema, and chronic bronchitis.”

The orders cover ten varieties of ZYN, each sold in nicotine strengths of 3mg and 6mg. The products include Chill, Cinnamon, Citrus, Coffee, Cool Mint, Menthol, Peppermint, Smooth, Spearmint and Wintergreen.

The manufacturer, Swedish Match USA, is owned by Philip Morris International. The products had already received FDA authorisation to remain on the US market in January 2025, but the new decision goes considerably further by permitting a specific comparative health claim.

The FDA said its decision followed an extensive scientific review and was intended to give adult tobacco users accurate information about differences in risk between products.

“FDA’s review of modified risk products is intended to ensure that adult users have clear, science-based information about the relative harms of tobacco products, so they can make informed choices,” said Bret Koplow, acting director of the FDA’s Centre for Tobacco Products.

The ruling does not mean that ZYN is harmless, nor does it approve the products as medicines or smoking-cessation treatments. Nicotine is addictive, and the FDA continues to advise people who do not currently use tobacco or nicotine not to begin.

The significance of the decision lies instead in the regulator’s formal recognition that nicotine products can present very different levels of risk.

Switching, rather than dual use

A crucial qualification is contained in the phrase “instead of cigarettes”. The authorised claim applies to smokers who replace cigarettes with ZYN. It does not promise the same reduction in risk to consumers who use nicotine pouches while continuing to smoke.

Cigarettes burn tobacco, creating smoke containing toxic substances responsible for most smoking-related cancers, cardiovascular disease and respiratory illness. Nicotine pouches deliver nicotine through the lining of the mouth without burning tobacco or producing smoke.

This difference is central to the principle of tobacco harm reduction: smokers who cannot or do not wish to stop using nicotine may nevertheless reduce their health risks by moving away from combustible products.

The FDA’s decision therefore recognises an important distinction that is frequently blurred in political debate. A product can be addictive and unsuitable for non-users while still being substantially less dangerous than smoking.

UK-based public health commentator Clive Bates, a former director of Action on Smoking and Health, has argued that nicotine pouches could deliver benefits comparable to those associated with the use of Swedish snus in Scandinavia.

“Tobacco-free nicotine pouches with a consumer acceptable nicotine content have the potential to benefit public health in the same way that is documented for Swedish snus in Scandinavia, that is, by serving as a low-risk alternative to cigarettes”, Bates said.

“The European Commission should pay close attention to FDA’s exhaustive process and extensive reasoning. It’s unusual to have anything good to say about the Federal government these days, but this is an important exception, where the right answer has been reached for the right reasons”, he added.

Bates has also argued that poorly designed regulation, including excessively low nicotine limits, could make pouches less effective as substitutes for cigarettes and unintentionally protect the market for combustible tobacco.

Why the FDA decision matters for Europe

The American ruling comes at a particularly important moment for the European Union.

The European Commission is simultaneously advancing a formal proposal to overhaul tobacco taxation (TED) and preparing a broader revision of the EU legislation governing tobacco and nicotine products, their presentation, sale, advertising and promotion.

Nicotine pouches are not comprehensively regulated at EU level under the current Tobacco Products Directive (TPD). Because they contain nicotine but no tobacco, they fall outside many of the harmonised provisions that apply to cigarettes, roll-your-own tobacco, heated tobacco and electronic cigarettes. The result is a fragmented European market.

Some member states permit nicotine pouches subject to national restrictions. Others have introduced nicotine limits, packaging and warning requirements or advertising controls, while France has pursued a prohibition.

Different national rules create uncertainty for consumers and manufacturers and complicate enforcement across the EU’s internal market.

The Commission’s April 2026 evaluation of the European tobacco-control framework identified the rapid growth of nicotine pouches, electronic cigarettes and heated tobacco products as one of the main challenges that existing EU legislation is no longer adequately equipped to address.

The evaluation concluded that EU rules had contributed to falling smoking rates and smoking-related deaths but were failing to keep pace with changes in products, marketing practices and consumer behaviour.

The EC is particularly concerned about the use of novel nicotine products among children, adolescents and young adults. However, the FDA decision introduces an additional issue that EU policymakers will now find difficult to avoid: whether new EU rules should recognise differences in risk between combustible cigarettes and smoke-free nicotine products.

Two contrasting regulatory philosophies

The emerging difference between Washington and Brussels is not simply that one jurisdiction is permissive and the other restrictive.

The FDA subjects nicotine products to an exceptionally demanding premarket review. Products must receive authorisation before they can legally be marketed, and separate evidence is required before a manufacturer may make a modified-risk claim.

The FDA can impose marketing conditions, require post-market surveillance and withdraw an order if later evidence shows that the product no longer benefits public health.

Its approach nevertheless accepts that consumers should be told when credible evidence shows that completely switching from one product to another reduces disease risk.

The Commission’s current approach places greater emphasis on reducing the overall attractiveness and consumption of tobacco-related and nicotine products. Its taxation proposal explicitly presents nicotine pouches as products that can prolong addiction or act as substitutes for cigarettes, especially among young people.

These positions are not necessarily irreconcilable.

The EU could impose age controls, marketing restrictions, ingredient standards and proportionate nicotine limits while still recognising that adult smokers may benefit from switching completely away from cigarettes.

It could also prohibit unsubstantiated commercial claims while creating an evidence-based process through which manufacturers could apply for permission to communicate verified differences in risk.

The alternative would be to impose increasingly similar taxation, warnings and advertising rules on products with significantly different health consequences.

A test for evidence-based policymaking

The EC ran a public consultation on revisions to both the Tobacco Products Directive (TPD) and the Tobacco Advertising Directive (TAD) from 22 May to 14 August this year. The consultation, is intended to inform a revision of the legislative framework planned before the end of 2026.

It creates an opportunity to consider evidence that was not available when the current Tobacco Products Directive was adopted in 2014.

Nicotine pouches were then a marginal product. They now represent a rapidly expanding category, and national governments are adopting increasingly divergent responses.

The FDA decision does not compel Europe to follow the US model. The EU has different legal structures, public-health priorities and attitudes towards commercial nicotine.

It does, however, establish a significant regulatory precedent.

One of the world’s most influential public-health authorities has concluded that there is sufficient evidence to tell adult smokers that completely switching to specified nicotine pouches reduces their risk of mouth cancer, heart disease, lung cancer, stroke, emphysema and chronic bronchitis.

That finding sits uneasily with any policy or public communication suggesting that cigarettes and smoke-free nicotine products are essentially equivalent.

The issue is particularly relevant to the Commission’s tax proposal. Taxation affects consumer behaviour partly by changing the relative prices of products. If pouches are taxed so heavily that the economic advantage over cigarettes is substantially reduced, smokers may have less incentive to switch.

Conversely, setting taxes too low could increase affordability and use among young people who have never smoked.

The task for EU legislators is therefore not simply to choose between regulation and deregulation. It is to develop a framework that calibrates restrictions, taxation and consumer information according to evidence about risk, behaviour and population-level effects.

Europe’s choice

While Washington is recognising that adults deserve accurate information about lower-risk alternatives, Brussels is looking for ways to restrict, tax or ban them.

Meanwhile, the EU is failing to control illegal disposable vapes, banned flavours, excessive nicotine levels and unauthorised devices moving through black-market channels. Regulated products are demonised, while illegal and unregulated products keep reaching consumers, including young people.

The forthcoming EU debate will test whether Brussels can reconcile its tobacco-free objective with the potential role of lower-risk alternatives.

The FDA decision makes three points that are likely to shape that discussion.

First, nicotine pouches are not harmless and should not be promoted to children or people who do not use nicotine.

Second, the absence of combustion means that their risks can differ substantially from those associated with cigarettes.

Third, the greatest potential benefit arises when smokers switch completely rather than using pouches alongside continued smoking.

The Commission is right to address gaps in the existing legislation and fragmentation between member states. Common product standards, youth protections and enforcement rules may be necessary for the Single Market to function properly.

But regulation that fails to acknowledge relative risk could also have unintended consequences.

Clive Bates and other harm-reduction advocates argue that treating all nicotine products as though they are similarly dangerous can preserve smoking by discouraging consumers from moving to safer alternatives. European health campaigners respond that the growth of commercially marketed nicotine products could create a new generation of dependent users.

The revised Tobacco Products Directive (TPD) will need to address both concerns.

As the EC completes its consultation and develops its legislative proposal, the American decision gives European policymakers a concrete case study rather than a theoretical argument.

The question is no longer whether a regulator could authorise a carefully limited reduced-risk claim for a nicotine pouch. The FDA has now done so.

The question for Europe is whether its forthcoming legislation will allow comparable scientific evidence to influence regulation, taxation and communication — or whether nicotine pouches will be treated principally as another product to be restricted, irrespective of their potential role in moving smokers away from cigarettes.