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A cadre of former officials, experts, and representatives from business and civil society have urged the International Monetary Fund (IMF) not to make the repeal of a parliamentary amendment concerning Politically Exposed Persons (PEP) a prerequisite for supporting Ukraine.
The text of the open letter was published on Facebook by the former Deputy Minister of Economic Development, Environment, and Agriculture, Svitlana Panaiotidi.
The authors of the letter disagree with the IMF’s concern that the amendment weakens the effectiveness of the PEP regime and distances Ukraine’s Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) system from FATF standards.
“Our request is (…) to refrain from blocking support or conditioning it on the repeal of this justified, risk-based adjustment until a proper, evidence-based assessment is completed,” the appeal states.
It is noted that on June 9, 2026, the Verkhovna Rada adopted, in its second reading and as a whole, draft law No. 15111-d on the taxation of digital platform income with an amendment that limits to 12 months the period of mandatory enhanced financial monitoring after an individual ceases to perform PEP functions.
Upon completion of this period, banks and other entities of primary financial monitoring are required to re-evaluate the client’s risks. If relevant risks exist, they retain the right and obligation to continue enhanced due diligence.
According to the signatories, the amendment aligns with the FATF’s risk-based approach and does not abolish enhanced monitoring for former officials. They assert that FATF standards do not mandate lifelong application of enhanced measures regardless of the time elapsed since an individual’s departure from their position.
The letter also highlights that the formal application of enhanced financial monitoring to former officials, their family members, and business partners creates difficulties in opening accounts, conducting ordinary transactions, and carrying out economic activities.
The signatories claim that the current approach also reduces the willingness of qualified professionals to serve in public office and on supervisory boards of state-owned companies due to the extension of enhanced financial monitoring to them and their family members without time limitations.
They have proposed that the IMF obtain a separate analysis of the amendment from business associations, civil society, and independent experts, and also consult with them regarding the conformity of the changes with FATF standards.
Among the signatories of the appeal are former deputy ministers Svitlana Panaiotidi; Ihor Diadiura; Dmytro Zoloteukhin; Dmytro Romanovych; Valeria Kolomiets; Executive Director of the Center for Economic Strategy, Hlib Vyshlinskyi; his deputy, Mariia Repko; former Head of the National Agency for Civil Service, Oleksandr Starodubtsev; co-founder of the NGO “Technologies of Progress,” Maksym Nefiodov.
Copies of the letter have been sent to the European Commission, the European Commissioner for Neighbourhood and Enlargement, Jutta Urpilainen, the EU Ambassador to Ukraine, Katarína Mathernová, and the Deputy Prime Minister for European and Euro-Atlantic Integration of Ukraine, Oleh Nemchinov.
As previously reported, last week IMF staff, in a report following the first review of the Extended Fund Facility (EFF) program, stated that the 12-month limit on enhanced due diligence for former PEPs, introduced by the parliament, along with an expanded scope of such individuals, weakens Ukraine’s AML/CFT system and moves it further away from FATF standards.
After the expiry of the 12-month period, enhanced due diligence can only continue if there is documented high or unacceptably high risk. IMF staff plan to coordinate further steps with reform participants, including the EU.