Case description
The NABU and the SAPO suspect former officials of the state-owned Polygraph Combine “Ukraina” of misappropriating over UAH 450 million in the production of biometric documents. Among the suspects is former Minister of Health Maksym Stepanov, who served as Director of the Polygraph Combine during the years when the scheme operated.
The essence of the crime:
According to investigators, the corruption scheme involved artificially inflating prices for components of international passports, ID cards, driver’s licenses, seafarers’ identity documents, and other documents. The inflated pricing became possible because the procurement was conducted through an Estonian intermediary company controlled by Stepanov. A separate episode of the scheme involved monopolizing intellectual property over the holographic security images. This created a mechanism for collecting royalties from each issued document. The copyright to these protective images was registered to the same Estonian company.
It is worth noting that even after Stepanov’s dismissal and the enterprise’s shift to direct procurement from the manufacturer, a contract was concluded between a French company and the Estonian firm. Under this agreement, the Estonian company continued receiving royalty payments for the design. The royalty fees were incorporated into the price of the products supplied to the Polygraph Combine. According to investigators, the total amount misappropriated in this way exceeded UAH 450 million, with the scheme operating from 2013 to 2016 and royalty payments continuing until 2021.
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In addition to Stepanov, the suspects include:
- the former head of a department of the Polygraph Combine;
- an individual close to Stepanov;
- the head of the Estonian company.
The NABU reports that as of September 2025, there are eight suspects in the case. At least two of them are wanted.
The origins of the case date back to 2013, when Ukraine was actively introducing biometric documents to meet European standards. The state-owned Polygraph Combine “Ukraina” was responsible for their production, purchasing materials abroad, including card forms and protective elements, because these products are not manufactured in Ukraine.
According to NABU detectives, Director of the Polygraph Combine Maksym Stepanov acquired the Estonian “shell” company through proxies and required foreign partners to supply products exclusively through it. The intermediary purchased materials at market price and resold them to the Polygraph Combine with a 400–600% markup. This inflated the enterprise’s expenses, while the surplus was transferred to the intermediary’s accounts. Detectives established that funds were transferred from Ukraine to Estonia and then distributed among offshore companies under Stepanov’s control — thereby amounting to the legalization of proceeds of corruption.
Another aspect of the scheme was the appropriation of intellectual property rights to document elements. According to investigators, Stepanov pressured the French company to re-register copyright over the design of protective elements (editor’s note: stylized images of the trident, the map of Ukraine, the flag, and the emblem of the Ministry of Internal Affairs) to the Estonian firm he controlled. As a result, royalties for each issued biometric document — national passport, international passport, driver’s license, etc. — were added to their production cost. The scheme continued generating profit. From 2018 to 2021, the Estonian company received approximately EUR 7 million. Part of these funds was then transferred to the account of Stepanov’s daughter through offshore structures for legalization.
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This scheme not only caused budget losses but also forced Ukrainians to overpay for public services because the royalty for using the “intellectual work product” of Stepanov’s company was built into the official cost of document issuance. Only in 2022 did the Cabinet of Ministers amend technical requirements for documents to eliminate dependence on the Estonian firm’s “intellectual property.”
The investigation was conducted with extensive international support. A joint investigative team was created with Estonia and France under the auspices of Eurojust. Estonia provided key evidence, including data on financial transactions, which made it possible to expose the scheme. In July 2023, Stepanov was notified in absentia of suspicion under Article 191(5) and Article 209(3) of the Criminal Code of Ukraine. In September 2023, the HACC ordered his arrest in absentia. In May 2025, new suspicions of bribery and the legalization of income derived from copyright exploitation were added. In June 2025, detectives completed the pretrial investigation. Once the defense reviews the case materials, the case will be referred to the HACC for trial. In September 2025, the NABU reported recovering more than EUR 3.3 million previously transferred abroad by scheme participants. In November 2025, the French company SURYS transferred EUR 3.37 million (equivalent to UAH 163.38 million) in compensation to the State Budget of Ukraine — the first such compensation in the history of Ukraine’s anti-corruption bodies from a foreign company.
