150 million hryvnias in bail for former Energy Minister Herman Halushchenko did not appear out of nowhere — it passed through 80-100 legal entities, one shell company and four banks before settling in accounts of the High Anti-Corruption Court. This was revealed at a session of a temporary investigative commission of the Verkhovna Rada by Dmytro Oliynyk, First Deputy Governor of the National Bank of Ukraine.
The key detail: the NBU was not looking for money, but for the logic of the scheme. "Analysis to the fourth degree of separation" is when a regulator traces not only who paid for HACC, but also who paid the person who paid the person who paid for HACC. And so on four times. No cash was found at any of these four steps.
A company that did nothing for two years
According to Oliynyk's version, the scheme worked like this: dozens of companies with "excess liquidity" sold this liquidity — in other words, actually converted cash into non-cash form through third parties. Then everything was "laundered" through a single legal entity that had conducted no activity for two years. This transit company scattered funds across four different banks, and from there the money went to the court's accounts.
"My modest hypothesis: cash was not deposited into the system, cash was sold to those companies that had excess liquidity... And then this company scattered it across four different banks, and then transferred it to HACC. This is a hypothesis, the team is working on it now," Oliynyk said.
The very term "hypothesis" is key here: the NBU is not claiming to know the exact scheme, but rather describing the most probable reconstruction based on what was traced. Final evidence is not yet available.
Banks under suspicion, not just Sense
A public scandal erupted around Sense Bank after NABU released recordings on August 19 in which the bank's chairman allegedly proposed creating artificial "windows" — periods when the financial monitoring system would officially be put on "maintenance" so that payments would pass without verification.
However, Oliynyk suggested that Sense Bank is not the only one and possibly not the worst example in this story. "In these four degrees of separation, we found banks that have no fewer questions than Sense, and to some even more," he said. At the same time, the NBU has not yet found any "windows" in the financial monitoring system itself — this remains a separate line of investigation.
Another nuance: payments to HACC accounts are by default not considered high-risk, meaning they do not automatically trigger heightened attention from control systems. This is precisely the weakness that the scheme's organizers likely exploited — the money looked like a routine payment to the state court account.
Why this is more than bail
The story with 150 million has already grown into a separate large-scale case called "Forrest Gump". NABU and SAP established that the funds to free Halushchenko had criminal origins. In August 2026, as part of this case, a suspicion was announced against Irina Mudria, Deputy Head of the Presidential Office — after which Zelenskyy removed her from her position.
If the NBU's hypothesis is confirmed, it would mean that the bail system in high-profile corruption cases has a structural flaw: money can be "laundered" through dozens of transit firms and several banks so that formally no individual payment looks suspicious. The question now facing the NBU and NABU is whether they can prove not only the scheme of money movement, but also the specific people who managed it at each of the four banks.
