Specialized Anti-Corruption Prosecutor’s Office

Specialized Anti-Corruption Prosecutor’s Office (Спеціялізована антикорупційна прокуратура or САП; Spetsializovana antykoruptsiina prokuratura or SAP). One of three anti-corruption agencies introduced in 2015 to fight political corruption in Ukraine. It was established by the administration of President of Ukraine Petro Poroshenko following a directive from the European Union (EU) as a condition for Ukraine to acquire visa-free travel into the Schengen Area as well as to make progress towards EU membership. A unit within the Office of the Prosecutor General of Ukraine, it was meant to be politically independent but this did not happen in practice neither under Poroshenko nor his successor, Volodymyr Zelensky. It prosecutes in the courts criminal cases investigated and prepared by the National Anti-Corruption Bureau of Ukraine (NABU), its sister agency.

The first head of SAP was Nazar Kholodnytsky, appointed in December 2015. He resigned in August 2020, complaining about interference from his superior, Prosecutor General Iryna Venediktova, and denying suspicion of wrongdoing. A search for his replacement began in January 2021 with the creation of an eleven-member commission whose membership tilted in favor of promoting a candidate acceptable (i.e., loyal) to President Volodymyr Zelensky. When the commission narrowed the competition to two candidates not to the executive’s liking, the process was paused. The EU and the United States criticized the delay. In the meantime, SAP came directly under Venediktova, a client of Zelensky. During this interval several cases into senior politicians and oligarchs were reportedly stalled. Further delays were engineered by the president’s representatives on the commission.

The commission selected Oleksandr Klymenko to be head of SAP in July 2022, while Zelensky dismissed Venediktova, and despite the president’s preference for a third candidate Klymenko was formally appointed. A lawyer, Klymenko worked previously as an investigator of the National Police of Ukraine and was most recently head of a NABU department. His appointment came about as a result of pressure from the EU in connection with granting Ukraine candidate status prior to membership.

Under his predecessors the work of SAP had been undermined by the Prosecutor General of Ukraine (acting for the president) and courts (acting for the accused) taking cases away from it or closing them down altogether. In September 2022, however, Klymenko managed to cancel the illegal and unwarranted closure of an infamous case, Rotterdam+, thus reopening it for prosecution. He also dismissed the prosecutors associated with that case.

As required by the EU, in December 2023 the Ukrainian government passed new laws strengthening its anti-corruption agencies. To improve its effectiveness the SAP was separated from the Office of the Prosecutor General of Ukraine operating as a distinct legal entity. Procedures for the competitive selection of prosecutors and management were improved, and new means of disciplinary control and external auditing were introduced. The EU’s requirements were not fully met insofar as the new law did not entirely repeal the so-called Lozovy amendments which allowed corruption suspects to avoid responsibility.

Reasons for the reluctance of Volodymyr Zelensky’s government to comply fully with EU directives and to give up its control of the anti-corruption agencies were revealed in 2024 when SAP and NABU exposed the Ukrzaliznytsia scandal. This involved the embezzlement of 94.7 million hryvni ($2.4 million USD) and the detention of a former advisor to the President’s Office. The suspect advised the deputy head of Zelensky’s office, a notoriously corrupt figure himself but protected by the presidential entourage.

In July 2025, the Supreme Council of Ukraine with uncharacteristic speed passed a law depriving NABU and SAP of their independence. It authorized the Prosecutor General to access all NABU cases and to transfer or cancel them at will. The previous day, the Security Service of Ukraine (SBU) had raided NABU and SAP offices looking for Russian spies. Justified on that basis, the new law would reduce the head of SAP to a nominal status with no real independent power. Zelensky signed the law into effect, despite the fact that this brought people into the streets and elicited protests from the G7 and EU. Within days, under pressure from the unprecedented public demonstrations—dubbed the ‘cardboard revolution’—Zelensky reversed his decision and restored the procedural powers and guarantees of independence of the agencies.

In the fall of 2025 the Operation Midas, conducted by NABU and SAP, exposed high-level criminal activity in the energy and defence sectors involving corruption, money laundering, and illegal enrichment. It implicated present and past energy ministers as well as a former business partner of Zelensky. However, no charges were laid in the next six months. Anyone close to the centre of power in Ukraine still seems to be untouchable and immune from prosecution by the SAP.

BIBLIOGRAPHY
Kalitenko, O. ‘Anti-Corruption Reform in Ukraine After Russia’s Full-Scale Invasion,’ SCEEUS (Stockholm Centre for East European Studies) Report Series on Ukrainian Domestic Affairs, No. 9 (13 June 2023)

Bohdan Harasymiw

[This article was written in 2026.]