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.

Via Polish organization Ordo Iuris:

• BioTexCom, a Ukrainian firm, has announced a September conference in Warsaw promoting surrogacy and offering the “purchase” of a child for 65,000 euros; the case is now with prosecutors

• Since 2023, Ordo Iuris has submitted opinions to UN and EU bodies arguing that surrogacy constitutes human trafficking and the sale of children under international law.

• The Ordo Iuris Institute cooperates with UN Special Rapporteur Reem Alsalem, whose report on violence against mothers cited its position; Alsalem was a guest at a conference organized in June 2026.

• Ordo Iuris advocates a new Optional Protocol to the Convention on the Rights of the Child banning surrogacy and has prepared Polish translations of two UN reports on the issue.

• The Ordo Iuris Institute is petitioning Poland’s Minister of Justice, Waldemar Żurek, to block the event organized in Warsaw by BioTexCom as a promotion of human trafficking; the appeal is available at niedlasurogacji.pl.

On September 12–13, the Ukrainian company BioTexCom plans to hold a conference in Warsaw aimed at promoting programs offering surrogate motherhood and in vitro fertilization. The company is inviting interested parties to individual meetings with its representatives, offering surrogacy packages worth nearly 65,000 euros. Under Polish law—unlike Ukrainian law—surrogacy may be classified as a criminal offense. The matter of the Warsaw conference has already been referred to the prosecutor’s office.

This event is not an isolated episode but another manifestation of a broader phenomenon: Poland, alongside other Western and Central European countries that lack their own surrogacy regulations, has for years been becoming a market for foreign so-called reproductive companies. In this context, it is worth recalling that the issue of surrogacy has for years been a central concern of the Ordo Iuris Center for International Law—both at the domestic level and in the most important international forums.

Opinions and positions at the UN and the European Union

Since 2023, the Institute has regularly submitted opinions and positions to bodies of the United Nations (UN) and institutions of the European Union (EU), consistently arguing that surrogacy meets the definition of human trafficking and the sale of children under international law. In February 2023, Ordo Iuris experts published an analysis showing that European Union law does not require member states to legalize surrogacy. When, in December 2024, the Third Committee of the UN General Assembly adopted a resolution on trafficking in women and girls that for the first time explicitly addressed the phenomenon of surrogacy, the Ordo Iuris Institute described it as a significant precedent.

This activity intensified significantly in 2025. In April, Ordo Iuris submitted an opinion contributing to a UN thematic report on surrogacy, in July it joined the organizations supporting a position presented to the UN Human Rights Council against the legalization of this practice, and in October and November it submitted further positions—including an extensive opinion, “Surrogacy as a Form of Sale of Children and Violation of Women’s Rights”—addressed directly to the UN Special Rapporteur. The year 2026 brought further action: in January, an opinion for the European Commission calling for every form of surrogacy to be recognized as human trafficking, in March, participation in the session of the Commission on the Status of Women, and in July, a commentary summarizing the UN Human Rights Council’s 62nd session, at which the report on violence against mothers was presented.

Cooperation with the UN Special Rapporteur

A special place in these efforts is occupied by the cooperation with Reem Alsalem, the UN Special Rapporteur on violence against women and girls, who consistently defends the biological understanding of sex and motherhood in her reports. Ordo Iuris took part in informal expert consultations conducted by Alsalem for both of her key documents—the report on violence against women in the context of surrogacy, submitted to the UN General Assembly in October 2025, and the report on violence against mothers, presented to the Human Rights Council in July 2026. Importantly, the Ordo Iuris Institute’s position was explicitly cited in the latter document, in the section addressing the devaluation of motherhood in contemporary public and institutional discourse.

This cooperation also took a direct form: on June 3, 2026, Reem Alsalem personally took part—as a special guest—in the international academic conference “Motherhood in the 21st Century” organized by Ordo Iuris at Cardinal Stefan Wyszyński University. During the panel devoted to surrogacy, she presented the findings of her report, outlining the profile of women who become surrogates—almost exclusively poor women, often single mothers or immigrants—and calling for a model of surrogacy abolition modeled on the abolition of prostitution. She was accompanied by Olivia Maurel, spokeswoman for the international Casablanca Declaration—a coalition of more than 150 experts from 75 countries advocating a universal ban on surrogacy—who was herself born through the procedure and shared a moving personal testimony.

Cooperation with the initiators of the Casablanca Declaration

This is not the first time the paths of Ordo Iuris and the circle surrounding the Casablanca Declaration have crossed. As early as April 2024, the Ordo Iuris Institute took part in an international conference in Rome organized by the Declaration’s initiators, devoted entirely to the issue of surrogacy, and addressed its findings in the commentary “The Right to a Child, or the Rights of the Child?” The participation of the Declaration’s spokeswoman in the Warsaw conference in June 2026 is thus a continuation of many years of ongoing cooperation with this coalition, not an isolated episode.

A call for a new Optional Protocol to the Convention on the Rights of the Child

In its opinions submitted to the UN, the Ordo Iuris Institute consistently puts forward a specific legislative proposal: the adoption of a new Optional Protocol to the Convention on the Rights of the Child that would explicitly prohibit surrogacy. The legal argumentation, developed in particular in the November opinion for the Special Rapporteur, invokes Article 35 of the Convention on the Rights of the Child and Article 2(a) of the existing 2000 Optional Protocol on the Sale of Children, whose definition of “the sale of children”—in the assessment of Ordo Iuris experts—also covers surrogacy agreements under which a child is transferred in exchange for remuneration or another benefit.

Polish translations of UN reports

The latest element of this activity is a publication that took place just a few days ago. On August 25, 2026, the Office of the UN High Commissioner for Human Rights published on its official website Polish translations of both of Reem Alsalem’s reports mentioned above—on violence against women in the context of surrogacy and on violence against mothers. Both translations were prepared by the Ordo Iuris Institute. Thanks to this, Polish-speaking lawyers, journalists, public administration officials, and NGOs have gained direct access to the full content of both documents—without relying on the fragmentary quotations and secondary media coverage through which UN reports had until now been known in Polish public discourse.

The actions outlined above—more than a dozen opinions and positions submitted to the UN and the EU, participation in the UN Special Rapporteur’s expert consultations, its own international academic conference in Warsaw, cooperation with the initiators of the Casablanca Declaration, the call for a new international treaty, and the preparation of official translations of UN reports—together form a picture of Ordo Iuris’s systematic, years-long engagement in the fight against surrogacy at both the domestic and international levels. It is against this backdrop that the Ordo Iuris Institute’s opposition to the BioTexCom conference planned for September 12–13 in Warsaw should be understood. The Ordo Iuris Institute has prepared a petition to Poland’s Minister of Justice, Waldemar Żurek, calling for the event to be blocked.

“The conference that the Ukrainian company is planning for September in Warsaw is not a neutral informational event, but a promotional campaign for a commercial reproductive business that treats a woman’s body as a means of production and a child as a product tailored to the client’s expectations.

Polish law does not explicitly criminalize surrogacy, but that does not mean a legal vacuum. An agreement under which a child is handed over in exchange for payment may meet the definition of human trafficking, and organizing and promoting such practices on the territory of the Republic of Poland should meet with a response from the relevant authorities. Ordo Iuris has for years documented the mechanisms of exploitation built into commercial surrogacy: from Colombia, through Ukraine, to the United States—and consistently works to ensure that this problem is no longer treated as the private affair of ‘commissioning parents,’ but is recognized for what it truly is: a form of economic exploitation of women in difficult life circumstances and a violation of a child’s fundamental right to identity and to a bond with the mother who gave birth to them,” notes Julia Książek of the Ordo Iuris Center for International Law.

The post Children for sale: A Ukrainian firm plans to promote surrogacy in the heart of Poland, case referred to prosecutors appeared first on Remix News.

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