If your property or business was suddenly transferred to another person, you have a choice - contact the police and sue, or complain to the Anti-Raiding Office at the Ministry of Justice. Every year, this special body reviews several thousand complaints against those who are often called “black notaries” or “black registrars” in the media.
Based on the results of consideration of these complaints to the board, the Ministry of Justice decides to reject or satisfy these complaints, cancel certain registration actions, or even deny access to the registers of such registrars. General statistics show that only 21% of complaints are satisfied.
Journalists from NGL.media collected and analyzed about 22.5 thousand such decisions of the Ministry of Justice, starting from 2016 to July 2024 inclusive. They organized all the data and created a convenient search system where you can find all solutions regarding complaints about the actions of a particular registrar or notary.
In total, almost 6.3 thousand registrars and notaries are included in the database, but most of the complaints are from less than 500 people, against whom 10 or more complaints were filed.
This tool is useful to journalists researching corporate raids, lawyers analyzing practices to prepare their complaints or lawsuits, and anyone who wants to test the virtue of a particular notary or registrar or investigate the purity of the history of a particular property.
Database of complaints against registrars. How it works
Journalists uploaded all decisions for each registrar and notary to the Pinpoint portal, which allows you to flexibly search for names, companies, names or combinations of words among tens of thousands of documents. For example, you can search for all documents mentioning a specific street and registrar (Rybatskaya + Eroshenko streets), and it is important to put search terms consisting of several words in quotation marks. Or you can exclude a certain term from the search results by placing a minus sign in front of it without a space (Rybatskaya St. - Eroshenko). To go to Pinpoint, click here or the image.
More detailed data on registrars and notaries who had 10 or more complaints was visualized.
How they did it
The Ministry of Justice does not publish generalized data* on complaints against registrars and notaries, however, the results of consideration of each complaint are published on the website in PDF format. The journalists wrote a script that goes through the relevant pages on the Ministry of Justice website and saves these PDFs for further analysis. Most of them were simply scanned images, so in order to automatically extract text from them, we had to first recognize it using OCR tools. To do this, we used the Tesseract library, saving data about each complaint and the text of the response to it in a separate dataset. Further analysis of the texts was carried out using the OpenRefine program, looking for similar text patterns in responses to complaints - this was how it was possible to identify and “clean up” the names of the registrars (sometimes their names and surnames were published with typos), as well as determine the result of the consideration of the complaint.
* The Ministry of Justice only allows basic information about complaints scheduled for consideration by the commission (in addition, this information is not available for complaints that were considered before October 2023).
Former registrar of the cultural department of the Chernivtsi Regional State Administration Nikolai Gergelyuk is one of the leaders of this list. In 2022, various religious organizations of the UOC-MP complained about it more than a hundred times. It turned out that Gergelyuk changed their names in the register, adding phrases like “It is not indicated that they belong to the Russian Orthodox Church (Moscow Patriarchate).” Most of these complaints were satisfied by blocking the registrar's access to the register for three months, but such original entries in the registers are still found.
Nikolai Gergelyuk explained his actions in a conversation with NGL.media with a patriotic position. Now he no longer works as a registrar because he is serving in the army.
However, this curious story is an exception, because other cases regarding registrars and notaries look much worse.
Record breakers
In addition to Gergelyuk, at least six more registrars were discovered, each of whom was complained about to the Anti-Raiding Office more than 100 times.
One of these registrars is Sergei Rodzin from the Rivne region. Now he is suing the Ministry of Justice, trying to appeal the blocking of access to the registry. Over the past two years, Rodzin has received 130 complaints. True, most of the complaints concern one case of violations in 2022 when registering lease agreements for agricultural plots in favor of one company. A significant number of complaints are due to the fact that they were filed to cancel state registration separately for each site.
However, even if we count these cases as one, there are still quite a lot of complaints. Today Rodzin continues to work in the Vysotsky Village Council as a state registrar, as evidenced by his declaration, which was filed in March 2024.
The attention of journalists was also attracted by the biography of Sergei Rodzin. The fact is that before becoming a registrar, he was a well-known person in the region - he headed the police in the town of Dubrovitsa, Sarnensky district, Rivne region. In 2016, he was arrested as part of the Yantar special operation, accused of bribery and creating a criminal organization. He was eventually released on bail of UAH 2.7 million, and later entered into a plea agreement, according to which the sentence of 5 years in prison was replaced by three years of probation. In March 2020, he was released from punishment after the expiration of his probation period.
How does the Anti-Raiding Office work?
The Anti-Raiding Office fights unscrupulous registrars and notaries, protecting the rights of property owners and legal entities. Anyone whose rights have been violated may complain about the corresponding registration action no later than one year from the date. If more than two months have passed since the decision of the appeal was made, then the complainant must indicate exactly when he learned about the violation of his rights.
Direct consideration of complaints is carried out by the board for consideration of complaints in the field of state registration. During martial law, meetings are held without the participation of the complainant and the person complained about, as well as interested parties - but they have the right to submit written explanations.
Based on the results of consideration of the complaint, the board makes a decision by voting, formalized by the corresponding conclusion. And on its basis, a decision is made by the Ministry of Justice in the form of an order. The order may have three options: satisfaction of the complaint, refusal, or leaving the complaint without consideration on the merits.
The panel also determines how serious the registrar's or notary's violation is. And he can not only cancel or correct the entries he has made in the registry, but also temporarily block his access to the registry or cancel it altogether.
In addition, the registrar may be subject to disciplinary action, and in relation to the notary, the Office can apply to the Higher Qualification Commission of Notaries with a request to cancel the certificate of the right to engage in notarial activities.
As the editors of NGL.media were informed by the Anti-Raiding Office, no orders from the Ministry of Justice were taken to bring disciplinary action, but notaries were reported to the High Qualification Commission of Notaries - there have been only six such cases since the beginning of 2020.
They can also contact law enforcement agencies. Since the beginning of 2022, the Ministry of Justice has informed about the presence of signs of a criminal offense five times.
Another record holder for the number of complaints was Andrey Yaroshko, registrar of the Nizhechelubyansky village council in the Ternopil region. In total, more than 60 complaints were filed against him, most of which were found to be fair. True, the violations were considered minor, and his access to the registry was not blocked. Despite a significant number of complaints, Yaroshko actually violated the law only once, since the majority of satisfied complaints were from one enterprise - Agro-Ros LLC, and illegal registrations were carried out in favor of the Demetra++ enterprise. In all cases, the registration of lease rights to agricultural land plots was discussed.
It is interesting that Andrei Yaroshko also began his career as a registrar with bribery. While still a 25-year-old young registrar, he, as the judges put it, “received an improper reward in the amount of $400.” Then in 2013, he admitted guilt and was released from the main sentence.
Exiting business from sanctions
In this text it is impossible to tell the stories of all the registrars and notaries whose work was investigated by the Anti-Raiding Office. But trends and innovations should be shown. The head of the Anti-Raiding Office previously spoke about the retraining of some notaries from illegally depriving property to those who help get rid of it. We are talking about those who re-register the property of sanctioned persons, which in the future may become the property of the state.
NGL.media discovered several dozen orders of the Ministry of Justice for 2023-2024, which mention sanctions legislation. Basically, we are talking about removing the names of sanctioned beneficiaries of Ukrainian companies from the register. As Ivan Korodyuk, head of the Anti-Raiding Office, said, a total of 98 legal entities were subject to registration actions in violation of sanctions legislation.
Among the orders, journalists found a story about Vadim Novinsky’s companies. In the spring, the SBU appealed to the Ministry of Justice with a complaint that Novinsky was excluded from the beneficiaries of dozens of companies. As a result of the audit, most of the changes were canceled, and access to the Unified State Register was canceled for two notaries (Alla Smirnova and Alexandra Chernik) and three state registrars (Anna Popadinets, Raisa Khizhka and Alla Shevchuk).
The story is similar with the change of owners of the Osokorki-7 and Academ Club companies, associated with Viktor Medvedchuk and Oksana Marchenko. After the release of the Bihus.info investigation that a number of their assets had been transferred to new owners, the Office of the Prosecutor General contacted the Ministry of Justice and such registration actions were immediately canceled. But registrars and notaries were not punished.
At the same time, there were cases when complaints were filed by registrars and notaries themselves, who claimed that someone had used their access identifiers in the Unified State Register. For example, such complaints came from a private notary from the Poltava region, Lyudmila Rusnyak. One of her complaints concerned the famous businessman Vadim Ermolaev, who is under Ukrainian sanctions, and five companies were transferred to his daughter Sofia Kononenko.
Fewer complaints
It should be noted that the number of complaints is decreasing. However, the main reasons for this are not the increase in the virtue of registrars and notaries, but changes in legislation and the beginning of a full-scale invasion. Then all real estate and business transactions were suspended for a while, so there were no complaints. However, with the resumption of registration activities, other types of complaints appeared - related to the assets of sanctioned persons.
There is another reason for the decrease in the number of complaints, since in 2019, utility registrars made it impossible to perform registration actions. Namely, they, according to the Ministry of Justice, carried out the most illegal changes in the registers. The peak of such activity occurred in 2020-2021.
By the way, the website of the Ministry of Justice previously contained a list of registrars and notaries whose access to state registers was revoked, but now such a section has disappeared from the official website. The Ministry of Justice did not provide journalists with an up-to-date list, but forwarded NGL.media’s request to the State Enterprise “National Information Systems”, which responded that “such information does not exist in ready-made documentary form.”
Persons involved in investigations
One of the most media-rich state registrars in Lviv and the surrounding area is 48-year-old Mikhail Zhivko. His work has been covered by many media outlets, including NGL.media. Either he will help with the dubious registration of land for the Dubnevich family, or the sanctioned ex-customs officer Ivan Bokal.
Previously, he was tried for registering private ownership of a communal land plot in Lviv. Later, Zhiva was officially suspected in the cases of the Bryukhovitsky districts and the house of trade unions in the center of Lvov. Indictments in both cases have already been submitted to court.
A total of 20 complaints were made about the registration actions of Mikhail Zhivko, but only in one case was the complaint satisfied, blocking his access to the registry for three months. The Ministry of Justice rejected the remaining complaints for formal reasons.
How to monitor your own property and business to protect yourself from raiding
It is necessary to constantly monitor the status of your assets using two open state registers: the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Formations and the State Register of Rights to Real Estate.
But since doing this every day and manually is very inefficient, there are several possibilities to do it automatically. True, all of them are not free.
For example, the service for monitoring registration actions for real estate objects of individuals and legal entities “SMS-Mayak” from Liga and the Ministry of Justice, which offers two options priced at 36 UAH and 352.8 UAH per month.
Changes to legal entities can be easily tracked on paid platforms, such as YouControl and Clarity Project (please note that these services provide free access to editorial journalists). By subscribing to specific legal entities in these services, you can receive notifications about changes, including court cases and more.
There were also complaints against registrar Irina Revakovich and Kristina Boyko, who appeared in NGL.media publications. Most of the complaints were rejected, but in the most famous story involving them, the decision of the Ministry of Justice was not in their favor. We are talking about the “privatization” of the Lviv communal markets “Vinnikovsky” and “Pidzamche”.
They tried to cancel this order of the Ministry of Justice in court, but to no avail. However, this did not particularly help, because the Lviv City Council agreed to a settlement agreement, and the criminal investigation continues without any result. Revakovich and Boyko no longer work as state registrars, as their declarations show, but legal battles to cancel some of their registration activities are still ongoing.
Another well-known registrar from the Lviv region, Natalya Lobodinets, is known for entering real estate data into the register based on documents from the future. But judging by the declarations, it is still working. This year there have already been two orders from the Ministry of Justice blocking her access to the real estate register for three months.
The most high-profile case in the history of Lviv is a scam involving dozens of communal premises that the Lviv City Council lost. Several registrars and notaries were involved in this case, including notary Ulyana Pshenichnaya. The board considered two complaints about it, but refused to satisfy them, because in one case there was already a legal dispute, and in the other it was said that the notary acted in accordance with the law.
To see documents related to other registrars, go to the Pinpoint portal.
