Bitcoins Worth ₴2 Billion and Over 10,000 Tokens: Cryptocurrencies Declared by Ukrainian Officials in 2023
On March 31, the deadline for submitting declarations for Ukrainian officials for 2023 expired. In addition to their real estate, salaries, and other income, they reported on their cryptocurrency savings.
Incrypted analyzed declarations from the Unified State Register for 2023, which include cryptocurrencies, and identified the largest bitcoin holders, the most popular digital currencies, and platforms where officials store their assets.
Declaration Features
Since Russia invaded Ukraine, the National Agency on Corruption Prevention (NACP) limited access to the Declaration Register. The agency also stated declarants “should not waste time filling out and submitting declarations or notifying of property changes” until martial law is lifted.
In October 2023, the law on the restoration of electronic declaration came into force. In December, the NACP opened public access to the Register.
Officials had to submit reports for 2021-2022 by January 31 and for 2023 by March 31, 2024.
During a conversation with Incrypted, Oleksandr Melnyk, a lawyer at Juscutum’s Business Security practice, said that people authorized to work for the government must declare their property, including cryptocurrency. It’s important to note they must also report their family members’ assets in their declarations.
The NACP’s Knowledge Base gives clear instructions on reporting cryptocurrencies.
Key Figures
Incrypted analyzed documents listing 10,163 different tokens across 1834 declarations.
The most popular assets listed in the declarations include Bitcoin, Ethereum, Tether, Polkadot, BNB, Cardano, Ripple, Solana, and the Shiba Inu and Dogecoin memecoins.
The declarants indicated a total of 834 BTC, which is valued at over $55.7 million or approximately 2.1 billion hryvnias at the time of the count. Additionally, they declared about 3964 ETH, which is worth almost $13 million and 505 million hryvnias, respectively. They also declared USDT for more than $4.1 million (almost 160 million hryvnias).
Memecoins, such as Dogecoin and Shiba Inu, are also popular among declarants. It is worth noting that when calculating the total number, Incrypted did not take into account 204,357,574,000,000 SHIB listed in the declaration of Oleksiy Klimov, an employee of the Main Department of the State Service of Ukraine on Food Safety and Consumer Protection in Odesa Oblast.
The declarant might have given the wrong number of Shiba Inu assets on the form. This is because the stated amount would represent nearly half of the total number of coins in circulation at the time of writing.
Top 10 Bitcoin Holders
In all 2023 declarations mentioning crypto assets, 792 people listed the bitcoin.
Mykyta Kuzkevych, a deputy of the Odesa Regional Council, is the leader in the number of declared bitcoins. He declared 121 BTC (over $8.2 million at the time of writing) with 88 BTC belonging to Kuzkevych and 33 BTC belonging to his wife. The couple acquired the bitcoins in 2012.
It’s important to note that three other declarants in the top 10 Bitcoin holders were early adopters. These include Oleh Bondarenko, who heads The Committee on Environmental Policy and Nature Management of the Verkhovna Rada’s Office of Affairs, Oleksiy Kucher, head of The State Regulatory Service, and Eduard Solovyov, deputy head of the Mykolaiv Oblast Police Department. Each of them reported receiving bitcoins in 2013.
Oleksandr Kizliar, a member of the Khmelnytsky Regional Council, holds the second-largest amount of Bitcoin among the declarants with 100 BTC (over $6.7 million at the time of writing). He is also among the top 10 officials regarding Ethereum holdings. Additionally, in 2023, Kizliar acquired 6.5 billion PEPE and 1500 SOL.
MP Dmytro Gurin, another participant in the rating, stated that his wife owned 42 BTC ($2.8 million) on the Opendime wallet. However, according to the declaration, the funds were stolen.
Top 10 Tether Holders
Tether’s USDT stablecoin has become the second most popular digital asset in 2023 declarations.
Maksym Kyselov, Director of the State Enforcement Service Department of the Ministry of Justice, owns the most USDT. His declaration shows he has over 647,000. In 2023, he received approximately 2.6 million UAH from the sale of cryptocurrency.
Vitalii Brovko, head of the department at the Prosecutor General’s Office, has the second-largest amount of Tether stablecoins. According to the declaration, his wife owns over 619,000 USDT. It’s worth noting that in 2023 she got about 8.3 million UAH from selling cryptocurrencies.
Also, it’s important to mention that Ivan Ivanov, the first deputy head of the Polissia customs office, has USDT worth over $84,700. In his 2023 declaration, he also mentions owning bitcoin on the FTX exchange in the ‘monetary assets’ section. However, he didn’t specify the amount; only the value in hryvnias (about 61,000 UAH) is given. But the 2022 declaration shows the same amount with the number of coins specified as 102 BTC.
Top 10 Ethereum Holders
In 2023, a total of 606 declarations mentioned Ethereum.
The primary owner is Ihor Osipov, who is a deputy of the Podil District Council of Odesa Oblast. In his declaration, he listed 1800 ETH (over $6 million) but noted that he lost access to all assets. Additionally, Osipov reported owning 1.5 million XRP.
Oleksandr Kizliar, a deputy of the Khmelnytskyi District Council, holds the second place in the ranking. He owns 1000 ETH ($3.3 million). Next is Kristina Pavlova, the chief specialist of the Municipal Services of the City Improvement Department of the Dnipro City Council. Her husband owns 130 ETH, according to her declaration.
Where Do Declarants Keep Cryptocurrencies?
In over half of the 2023 declarations, officials picked Binance as their preferred exchange.
WhiteBIT and Bybit rank as the second and third most popular exchanges, in that order.
Additionally, 2.5% of the analyzed declarations showed the use of cold wallets.
Conclusions
The use of cryptocurrencies in declarations increases every year. For instance, in 2022, they were mentioned in 1428 reports filed in the Unified State Register.
Given Ukraine’s consistent ranking among the top countries in digital asset adoption and Ukrainian investors earning $850 million in cryptocurrency profit in 2023, this trend will likely continue.
However, Ukraine has not yet finalized the regulation of cryptocurrencies and their taxation. Currently, there are two draft laws on the implementation of relevant legislation. According to MPs and representatives of the NBU, neither of these laws will be adopted in their current form.
