Economic Cybernetics Department
ERI of Business, Economics and Management of SumDU

«The EU-integration transformation of Ukraine’s financial monitoring system amid the war: strengthening efforts to combat terrorist financing», state registration number: 0126U000869, 2026-2028

MAIN PROJECT EXECUTORS

Boiko Anton

Head of the topic
Ph.D. in Economics, Professor, Associate Professor in the Department of Economic Cybernetics
a.boiko@uabs.sumdu.edu.ua

Myrhorod Valeriia

Responsible performer
Ph.D. in Law, Associate Professor, Associate Professor in the Department of Administrative, Commercial Law, and Financial and Economic Security
v.myrhorod@yur.sumdu.edu.ua

Yefimenko Alina

Performer
Ph.D., Assistant Professor, Department of Economic Cybernetics
a.yefimenko@uabs.sumdu.edu.ua

Lyvynenko Yevheniia

Performer
Ph.D., Assistant Professor in the Department of Criminal Law and Judicial Proceedings
e.lytvynenko@yur.sumdu.edu.ua

Lytvynenko Viacheslav

Performer
Postgraduate Student, Sumy State University

PROJECT GOAL

The aim is to develop a scientifically grounded hybrid financial monitoring model adapted to the specifics of wartime conditions, which will ensure effective counteraction to terrorism financing through the synthesis of European regulatory standards with mechanisms for rapid response to security threats.

STAGES OF RESEARCH WORK

Stage 1. Comparative analysis of international financial monitoring standards and the national system

1.1. Using the comparative legal method, compare the requirements of EU directives with Ukrainian legislation and analyze these directives regarding the prevention of money laundering and terrorism financing.

1.2. Assess the effectiveness of the implementation of FATF recommendations in Ukraine under martial law and during post-war reconstruction using the mutual evaluation methodology.

1.3. Conduct a comparative analysis of the European (risk-based) and American (comprehensive reporting) models in order to identify the elements of a hybrid financial monitoring model for Ukraine.

1.4. Study institutional models of the financial monitoring system through multicriteria evaluation (regulatory framework, level of transparency, digitalization, etc.).

Stage 2. Development of a methodology for early warning and detection of terrorism financing threats in Ukraine under wartime conditions

2.1. Investigate the relevant factors shaping terrorism financing threats in Ukraine during wartime based on factor and dynamic analyses.

2.2. Determine the role and place of virtual assets in the system of terrorism financing in Ukraine under wartime conditions through econometric modeling.

2.3. Develop a scientific and methodological approach for the early warning and detection of terrorism financing threats in Ukraine during wartime using a Bayesian approach.

2.4. Test the proposed methodology for early warning and detection of terrorism financing threats for resilience to internal and external shocks through scenario analysis.

Stage 3. Development of practical recommendations and legislative proposals for adapting the financial monitoring system

3.1. Identify the main norms and principles for adapting European standards in the field of countering terrorism financing through the prism of the institutional mapping method.

3.2. Establish the institutional prerequisites and directions for integrating the State Financial Monitoring Service of Ukraine into the European financial intelligence area by studying the interaction of national institutions with AMLA.

3.3. Develop a hybrid financial monitoring model for countering terrorism financing under wartime conditions based on Ukraine’s European integration vector.

3.4. Develop a package of legislative amendments to synchronize European integration requirements with Ukraine’s security needs through the application of the formal legal method, the method of legal act modeling, and the method of standards harmonization.

MAIN TASKS OF RESEARCH WORK

  • to compare the requirements of EU directives with Ukrainian legislation using the comparative legal method and to analyze these directives regarding the prevention of money laundering and terrorism financing;
  • to assess the effectiveness of the implementation of FATF recommendations in Ukraine under martial law and during post-war reconstruction using the mutual evaluation methodology;
  • to conduct a comparative analysis of the European and American models in order to identify the elements of a hybrid financial monitoring model in Ukraine (using case study and comparative legal methods);
  • to study institutional models of the financial monitoring system through multicriteria evaluation;
  • to investigate the relevant factors shaping terrorism financing threats in Ukraine under wartime conditions based on factor and dynamic analyses;
  • to determine the role and place of virtual assets in the system of terrorism financing in Ukraine during wartime through econometric modeling;
  • to develop a scientific and methodological approach for the early warning and detection of terrorism financing threats in Ukraine using a Bayesian approach;
  • to test the proposed methodology for early warning and detection of terrorism financing threats in Ukraine under wartime conditions for resilience to internal and external shocks through scenario analysis;
  • to identify the main norms and principles for adapting European standards in the field of countering terrorism financing through the prism of the institutional mapping method;
  • to establish the institutional prerequisites and directions for integrating the State Financial Monitoring Service of Ukraine into the European financial intelligence area by studying the interaction of national institutions with AMLA on the basis of functional and regulatory legal analyses;
  • to develop a hybrid financial monitoring model for countering terrorism financing under wartime conditions based on Ukraine’s European integration vector;
  • to develop a package of legislative amendments aimed at synchronizing European integration requirements with Ukraine’s security needs through the application of the formal legal method, the method of legal act modeling, and the method of standards harmonization.

EXPECTED SCIENTIFIC AND SCIENTIFIC-TECHNICAL RESULTS

The project is aimed at achieving a number of important outcomes in the field of functioning of a financial monitoring system adapted to the specifics of wartime conditions, ensuring effective counteraction to terrorism financing. A key expected result is a ranking of the effectiveness of institutional financial monitoring models in different countries worldwide, the results of which may be used by the State Financial Monitoring Service of Ukraine to select the optimal institutional model for countering terrorism financing. Another expected outcome is a scientific and methodological approach for the early warning and detection of terrorism financing threats in Ukraine under wartime conditions, which may be used by the State Financial Monitoring Service of Ukraine and the Security Service of Ukraine (SBU) to optimize the time required for threat identification and improve the effectiveness of threat detection.

In addition, the project will produce a classification of virtual assets according to their potential use in terrorism financing in Ukraine during wartime, as well as the identification of channels for their use. These results may serve as a basis for maintaining Ukraine’s national security during the implementation by the National Bank of Ukraine of mechanisms for the legalization of cryptocurrency circulation. Another important result is the development of a hybrid financial monitoring model for countering terrorism financing under wartime conditions, which will serve as a foundation for Ukraine’s European integration processes in terms of harmonizing legislation with EU principles, norms, and standards.

Taken together, these results form a new scientific paradigm for the functioning of the financial monitoring system under wartime conditions. The project not only proposes practical solutions but also establishes a theoretical and methodological foundation for further interdisciplinary research in the fields of financial security, public administration, international law, and digital finance. Thus, the expected results are systemic in nature, combining scientific novelty, practical orientation, and strategic importance for ensuring Ukraine’s national and financial security.

At the same time, the economic impact of the project results will be reflected in the optimization of the financial monitoring system through the implementation of a hybrid model, potentially reducing the costs incurred by law enforcement agencies in identifying terrorist threats, as well as the expenses of financial institutions and the state associated with mitigating their consequences. The mechanism of “wartime exemptions” will accelerate the processing of humanitarian aid and the financing of critical infrastructure, thereby increasing the speed of operations. The implementation of recommendations regarding FATF compliance will improve Ukraine’s rating in the Mutual Evaluation process, enhancing access to international financial markets and reducing the cost of attracting capital for Ukrainian companies. A roadmap with an assessment of economic consequences will make it possible to adopt informed decisions regarding the timing of the implementation of EU Directives, avoiding shock therapy for the financial sector, as occurred in Estonia, where 40% of international connections were temporarily suspended due to partners’ non-compliance with GDPR standards.

The social impact of the project results will be multidimensional, primarily manifested through strengthening protection, trust, and civic resilience. The implementation of the proposed solutions will directly enhance the physical security of citizens by making it more difficult to finance terrorist acts and sabotage activities through more effective detection of russian financing schemes. At the same time, public trust will be strengthened through the introduction of transparent mechanisms for monitoring the targeted use of international financial assistance based on a risk-oriented approach, which will reduce corruption risks and increase trust among both international donors and Ukrainian citizens. A critically important social effect will be the protection of civil society functioning under martial law through the introduction of a “wartime exemptions” mechanism, which will preserve the operational capacity of volunteer organizations without risks of disclosing confidential information. Furthermore, public access to anonymized typologies of financial threats will contribute to improving the financial literacy of the population by teaching citizens to recognize fraudulent schemes.

The impact of the project results on security and defense capability will be manifested through strengthening the state’s capacity to detect and block financial flows supporting hostile agent networks, sabotage groups, and russian information operations. The implementation of FATF standards and EU directives will integrate Ukraine into global financial intelligence exchange mechanisms, which is critically important for countering transnational terrorism financing schemes and sanctions evasion. In addition, the “wartime exemptions” mechanism will ensure a balance between control over financial flows and the efficiency of financing defense needs. This will help avoid delays in weapons procurement and payments to military personnel, ensuring the necessary speed of decision-making that directly affects the state’s defense capability.

SCIENTIFIC AND PRACTICAL VALUE OF THE RESULTS

The project results will be implemented through a comprehensive approach combining legislative initiatives, regulatory changes, and practical tools for public institutions. At the final stage of the project, a package of legislative amendments and a roadmap for adapting European standards in the field of countering terrorism financing will be prepared and submitted for consideration to the Committee of the Verkhovna Rada of Ukraine on Ukraine’s Integration into the European Union and the Committee of the Verkhovna Rada of Ukraine on National Security, Defense and Intelligence. These activities will be carried out within the priorities of the State Financial Monitoring Service of Ukraine, particularly in relation to improving interagency cooperation among public authorities.

Cooperation with the State Financial Monitoring Service of Ukraine will take place through joint webinars, round tables, and consultative working meetings aimed at effectively implementing the following three institutional priorities:

  1. Within the framework of the objective of “improving interagency cooperation among public authorities,” it will be proposed to introduce the best practices of leading countries identified through the developed ranking of institutional model effectiveness.
  2. Within the framework of activities related to the analysis of financial transactions, cooperation, interaction, and information exchange with law enforcement, intelligence, and other state authorities, an early warning and detection model for terrorism financing threats in Ukraine under wartime conditions will be developed.
  3. In order to implement the priority area entitled “development of a unified information system in the field of prevention and counteraction to money laundering, terrorism financing, and financing of the proliferation of weapons of mass destruction as a prerequisite for European integration,” a hybrid model of financial monitoring for countering terrorism financing under wartime conditions in Ukraine will be proposed.

In order to improve the activities of the information and analytical group within the Headquarters of the Anti-Terrorist Center under the Security Service of Ukraine (SBU), it will be proposed to establish a joint working group for identifying relevant factors of terrorism financing threats in Ukraine under wartime conditions and for scientifically substantiating the profile of individuals potentially involved in terrorism financing activities.

In the context of modernizing domestic legislation through harmonization with EU legislation, proposals will be submitted to the Financial Monitoring Department of the National Bank of Ukraine regarding the accelerated adaptation of FATF recommendations to the functioning conditions of the Ukrainian financial system during wartime. Representatives of this department will be invited to participate in a webinar presenting the results of the research project. Special attention in disseminating the project results will be devoted to updating the priority measures of the NBU Strategy within Goal 4, “Modern Financial Services,” by expanding the scope of regulation and supervision of virtual assets. This will be based on the obtained results regarding the classification of virtual assets according to their potential use in terrorism financing in Ukraine during wartime and the identification of channels for their use.

To ensure the effective utilization of the project results, targeted work with key stakeholders is planned. State institutions will receive practical tools for improving interagency cooperation and risk analysis. Methodological recommendations will be developed for financial institutions, taking into account the specifics of operating under martial law and the requirements of European legislation.

In the long term, the project results will contribute to strengthening Ukraine’s institutional capacity in the field of financial security, create a foundation for the further development of the national financial monitoring system, and promote deeper international cooperation. The developed methodologies and analytical materials have the potential for further application in the consulting activities of financial intelligence units of countries friendly to Ukraine.

As a result of the project implementation, new fundamental scientific findings will be obtained, forming a new research direction at the intersection of financial law, EU law, and institutional economics. The hybrid financial monitoring model will become a benchmark for further studies of financial monitoring systems in post-Soviet countries. Empirical confirmation of the research hypothesis that a financial monitoring model combining the European risk-based approach with elements of the American comprehensive reporting model provides an optimal balance between effective threat detection and the protection of the confidentiality of legitimate transactions under martial law will serve as a foundation for developing governance models in the security sector. This will have important implications for the theory of institutional design. The typology of terrorism financing schemes based on the analysis of real russian cases will create a unique empirical basis for further criminological research. The fully documented case-study methodology may also be replicated for the study of other conflicts.

INVOLVED EXECUTORS

PUBLICATION ACTIVITY

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