The National Bank of Ukraine has published the results of its review of the report on supervisory actions concerning Sense Bank for the 2022–2026 period. The regulator confirmed that in recent years the bank has been under enhanced supervision, particularly following its nationalization. According to the NBU, the authority regularly checked the bank's compliance with financial monitoring requirements, as well as banking, currency, and sanctions legislation, and applied enforcement measures — fines and written observations. The NBU Board separately endorsed the actions of independent anti-corruption bodies and stated its interest in the full and impartial establishment of all the circumstances of the case, emphasizing that a necessary condition for this is maximum openness and transparency on the part of all participants.
Four years of enhanced supervision: what exactly the regulator checked
Over the period from late 2022 to 2026, the NBU Committee adopted more than 100 decisions concerning Sense Bank. As a result of supervisory activities, the regulator sent 21 notifications to law enforcement agencies, the State Tax Service, and the State Financial Monitoring Service. By topic, the NBU conducted three inspection checks on compliance with banking legislation requirements, six checks in the area of financial monitoring, and a further three on compliance with sanctions and currency legislation. Thus, the supervisory perimeter around the bank remained active throughout the period under review and was not limited to isolated measures.
Secret protocols of collegial bodies
The key episode highlighted by the regulator was the second inspection check under banking legislation, completed in April 2025. It was during this check that a significant body of previously unknown confidential or secret protocols of Sense Bank's collegial bodies was discovered. The NBU also informed law enforcement agencies of this fact. The discovery of hidden protocols effectively became one of the grounds for further tightening of scrutiny of the bank's internal procedures and the actions of its governing bodies.
"Forrest Gump" and Hladyshchenko's communications
On 28 May 2026, the regulator informed the bank's owner, represented by the Ministry of Finance of Ukraine, and the members of the Temporary Investigative Commission about the progress of administrative proceedings concerning the chairman of the board of directors of Sense Bank, Oleksiy Stupak, and the chairman of the supervisory board, Mykola Hladyshchenko. The situation changed significantly on 19 August, when NABU published new materials of the pre-trial investigation within the framework of the "Forrest Gump" operation. According to the NBU, these materials contained directly recorded communications of Hladyshchenko with a third party. This became the basis for an urgent decision by the Committee on the assessment of the supervisory board chair, as well as for the launch of unscheduled inspections of the bank to examine facts of possible interference with the operation of the automated banking system.
Decision on the supervisory board chair and internal investigation
On 19 August 2026, the Committee decided that Mykola Hladyshchenko did not meet the qualification requirements on independence. Following this, the NBU published a demand that the government immediately terminate his powers as chair of the supervisory board of Sense Bank. On 24 August, in response to the regulator's request, the bank launched an internal investigation involving specialists in information technology, financial monitoring, compliance, and internal audit. Earlier, the bank's supervisory board was joined by a state representative — the financier Natalya Degtyareva, appointed by the Cabinet of Ministers. In parallel, NABU and the SAP published fragments of conversations within the "Forrest Gump" operation, in which possible influence over the nationalized bank was mentioned.
Contradictory data
Here it is necessary to honestly note a discrepancy in wording between the regulator's position and a number of media sources. In its own statement, the NBU links the unscheduled inspections of the bank to the recorded communications of Hladyshchenko and possible facts of interference with the operation of the automated banking system, while the decision on the supervisory board chair is derived from an assessment of compliance with the qualification requirements on independence. At the same time, several sources (including ura-inform, finance.rambler.ru, and life.ru) present the latest bank inspections as initiated in connection with the case over the pledge for German Halushchenko. It is important that these are different surnames (Hladyshchenko and Halushchenko) and, most likely, parallel tracks: the published NBU text does not link the decision on Hladyshchenko with the case over the pledge for Halushchenko. Readers should bear in mind that two versions of the "trigger" for the latest inspections coexist in the public domain, and the regulatory position attributes the primary cause to Hladyshchenko's communications and possible interference with the banking system.
Context: the state in the supervisory board and a bet on transparency
Against the backdrop of nationalization and enhanced supervision, the state's presence in the bank's management is strengthening: Natalya Degtyareva has been included in the supervisory board on behalf of the Cabinet of Ministers. At the same time, the NBU consistently emphasizes that it is interested in the impartial establishment of all the circumstances of the case and regards maximum openness of all parties as a necessary condition for such work. The combination of more than one hundred committee decisions, 21 referrals to law enforcement and regulatory bodies, the discovery of secret protocols, and the unscheduled inspections following the publication of the "Forrest Gump" materials forms a picture of one of the most intensive supervisory cycles that the regulator has conducted with respect to a national bank during the period under review.