Government officials and business representatives are asking the IMF not to demand the repeal of the changes regarding PEPs
27 July 12:48
A group of former officials, experts, and representatives of the business community and civil society has called on the International Monetary Fund (IMF) not to make the repeal of the amendment regarding politically exposed persons (PEPs)—which was adopted by the Verkhovna Rada—a condition for providing support to Ukraine. The text of the open letter was published on Facebook by Svitlana Panaotiidi, former Deputy Minister of Economic Development, Environment, and Agriculture, according to "Komersant Ukrainian".
“We are writing this open letter as citizens of Ukraine who have held various government and public offices and who, in accordance with current legislation, are classified for life—along with our family members—as politically exposed persons (PEPs). We are joined by experts, representatives of civil society, and the business community who are committed to the effective implementation of anti-money laundering and counter-terrorism financing (AML/CFT) standards in Ukraine,” the letter states.
The authors of the letter disagree with the IMF’s concern that the amendment weakens the effectiveness of the PEP regime and moves Ukraine’s anti-money laundering and counter-terrorism financing (AML/CFT) system further away from FATF standards.
“Our request: Refrain from withholding support or making it contingent on the repeal of this well-founded, risk-based adjustment until a proper, evidence-based assessment has been completed. Ukraine needs effective, not merely symbolic, AML/CFT regulation. A system that imposes a burden on law-abiding citizens and businesses but fails to identify actual criminals serves neither the goals of transparency nor the interests of the Ukrainian people,” the statement reads.
It is noted that on June 9, 2026, the Verkhovna Rada adopted in the second reading and as a whole draft law No. 15111-d on the taxation of income from digital platforms, with an amendment limiting the period of mandatory enhanced financial monitoring to 12 months after a person ceases to perform the functions of a PEP.
Upon completion of this period, banks and other entities responsible for primary financial monitoring must reassess the client’s risks. If relevant risks exist, they retain the right and obligation to continue enhanced monitoring.
According to the signatories, the amendment is consistent with the FATF’s risk-based approach and does not eliminate enhanced monitoring of former officials. According to them, FATF standards do not require the lifelong application of enhanced measures regardless of the time that has elapsed since the person’s departure from office.
“The amendment does not contradict any FATF recommendation or standard. FATF Recommendation 12 and its related interpretive notes emphasize precisely a risk-based approach to PEPs and do not require lifelong enhanced monitoring regardless of the time that has elapsed. We have the relevant FATF documents and are ready to provide detailed references to them. As of today, neither the IMF nor our Ukrainian counterparts have identified any specific provision, recommendation, or rule that this amendment allegedly violates, nor have they explained the nature of the alleged violation,” the letter states.
The letter also notes that the formal application of enhanced financial monitoring to former officials, their family members, and business partners creates difficulties in opening accounts, making routine payments, and conducting business activities.
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The signatories argue that the current approach also reduces the willingness of qualified professionals to serve in government positions and on the supervisory boards of state-owned companies due to the extension of enhanced financial monitoring to them and their family members without any time limit.
They proposed that the IMF obtain a separate analysis of the amendment from business associations, the public, and independent experts, as well as consult with them regarding the changes’ compliance with FATF standards.
Among the signatories of the appeal are: former deputy ministers Svitlana Panaiotidi, Ihor Dyadyura, Dmytro Zolotukhin, Dmytro Romanovych, and Valeriia Kolomiets; Gleb Vyshlinsky, executive director of the Center for Economic Strategy; his deputy Maria Repko; former head of the National Agency for Civil Service Oleksandr Starodubtsev; and co-founder of the NGO “Technologies of Progress” Maksym Nefyodov.
Copies of the letter were sent to the European Commission, European Commissioner for Enlargement Marta Kos, EU Ambassador to Ukraine Katarina Maternová, and Ukraine’s Deputy Prime Minister for European and Euro-Atlantic Integration Vsevolod Chentsov.
As previously reported, last week IMF staff stated in a report following the first review of the Extended Fund Facility (EFF) program that the 12-month restriction on enhanced due diligence for former PEPs, along with the expansion of the list of such individuals, weakens Ukraine’s anti-money laundering and counter-terrorism financing system and moves it further away from FATF standards.
After the 12-month period ends, enhanced due diligence may continue only if there is documented evidence of high or unacceptably high risk. IMF staff plans to coordinate further steps with reform partners, in particular with the EU.
Who Are Politically Exposed Persons (PEPs)?
Politically Exposed Persons (PEPs) are individuals who hold important public offices. These include heads of state, prime ministers, ministers and their deputies, members of parliament, high-ranking political figures, senior officials in the judiciary, law enforcement, the justice system, and defense, as well as the leadership of the National Bank, among others. A complete list of such positions in Ukraine is provided in the Financial Monitoring Law (“On Preventing and Combating the Legalization (laundering) of Proceeds from Crime, the Financing of Terrorism, and the Financing of the Proliferation of Weapons of Mass Destruction”) in Article 1.
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