Unified State Advisory Memorandum No. 8

Safeguarding Anti-Corruption Independence & Protecting the Istanbul Peace Track

Kyiv | 25 July 2025 – 02:32 EEST (UTC+3)

0. Purpose

Ukraine’s abrupt curtailment of NABU/SAPO independence, the nationwide protests that followed, and the cited security pretext (alleged Russian infiltration) risk distracting from—or being weaponised against—the Istanbul ceasefire/peace window. This memorandum sets out transparent, Unified corrective actions for Kyiv, guidance for international partners, and safeguards so domestic turbulence does not sabotage nuclear‑risk de‑escalation or negotiations.

1. Situation Snapshot

• 22 July 2025: Parliament passed, and President Zelenskyy signed, Law №12414 (4555‑IX), granting the Prosecutor General powers to reassign or close NABU/SAPO cases—authorities previously barred by the Criminal Procedure Code.
• Security trigger cited: The SBU arrested two NABU officials (one accused of sending restricted data to the FSB in “at least 60 episodes”); searches reportedly hit ~15 staffers, some without warrants, according to NABU.
• 22–24 July: Large protests erupted in Kyiv and other cities; EU/G7 officials warned the law could jeopardise Ukraine’s EU path.
• 24 July: Zelenskyy registered an urgent bill to restore the agencies’ independence (“all procedural powers”), drafted with NABU/SAPO participation.

2. Unified Reading of the Problem

A legitimate counter‑intelligence need exists (Russian penetration risk), but the legislative cure overshot—undercutting rule‑of‑law architecture that anchors domestic legitimacy and Western support. Swift, transparent repair preserves Kyiv’s moral leverage in Istanbul and blocks Kremlin narratives of “Ukrainian chaos.”

3. Immediate Actions Requested (Kyiv)

1. Pass the rollback/repair bill within 72 hours of registration, restoring NABU/SAPO independence verbatim to pre‑22 July guarantees. Publish the full text in Ukrainian and English simultaneously.
2. Adopt a targeted Counter‑Intelligence Protocol (CIP) for all anti‑corruption bodies: joint SBU–NABU vetting, mandatory clearance renewals/polygraphs, secure data‑handling SOPs—under judicial/independent oversight, not prosecutorial fiat.
3. Create an Independent Oversight Panel (3 Ukrainian judges + 2 international experts nominated by the EU/IMF) to review any future “security” interventions in NABU/SAPO.
4. Reaffirm publicly: no amnesty for grave international crimes; anti‑corruption enforcement continues irrespective of peace talks—linked to Justice & Accountability sequencing in Memorandum No. 7.
5. Channel civil-society energy: Invite CSO representatives into a transparency lane of the Joint Verification Commission (information access, whistleblower protection), so protests feed oversight, not fracture.

4. Actions for International Partners (EU, G7, IFIs)

• Condition, don’t cut: Make clear that EU accession and macro‑financial aid hinge on restored independence—then reward rapid correction with expedited tranches and technical help on the CIP.
• Deploy advisors fast: Second judges/prosecutors to the Oversight Panel; fund secure, air‑gapped IT for NABU/SAPO (SIEM tools, audit trails).
• Message discipline: Frame this as Ukraine’s democratic self‑correction, not a crisis—undercutting Russian propaganda during Istanbul.

5. Negotiation Shielding Measures

• Separate tracks publicly: “Governance reform at home, ceasefire abroad.” Fixing NABU is part of building a credible peace order, not a detour.
• Front‑load humanitarian wins in Istanbul (POW exchanges, nuclear‑facility safety corridors) to maintain public support while the Rada corrects the law.
• Pre‑empt the narrative: “Protests prove pluralism; agreements signed by Kyiv reflect a living democracy, not authoritarian dictate.”

6. Timeline (Proposed)

• By 27 July, 18:00 EEST: Rada passes repair bill; President signs same day. Publish law + oversight protocol.
• By 31 July: CIP adopted; Oversight Panel constituted; first quarterly audit schedule set.
• Mid‑August: Panel issues initial findings; EU/G7 jointly acknowledge compliance and unlock next aid tranche.

7. Principles Reaffirmed

• Rule of Law = Peace Infrastructure. Weakening watchdogs weakens any treaty.
• Security Must Be Proportional. CI risk justifies targeted fixes, not structural capture.
• Transparency Turns Protests into Partners. Inclusion calms streets and strengthens negotiations.

8. Distribution & Follow-Up

Primary recipients: Verkhovna Rada leadership; Office of the President; NABU/SAPO heads; Prosecutor General; SBU Director.
CC: EU Delegation Kyiv; G7 Ambassadors; IMF/World Bank Kyiv offices; key CSOs (Transparency International Ukraine, Anti‑Corruption Action Center); Istanbul facilitators.
Acknowledgement requested within 24 hours (receipt + liaison contacts for the Oversight Panel / CIP drafting group).

9. From Streets to Protocol: Civil Society’s Next Maturity Step

The Revolution of Dignity taught us that democracy advances when both sides grow: government corrects course, and civil society knows when to move from protest to process. Today, the authorities have heard the streets and moved swiftly to repair the law. This is a moment of unification that deserves recognition—not endless escalation. We invite protest organisers to form a Working Group of Civic Liaisons—student leaders, NGO advocates, independent experts—to engage the Rada, NABU/SAPO, the Prosecutor General’s Office, and international advisors through official protocols. Let momentum travel “from streets to cabinets,” embedding lasting democratic practice.

10. Courageous Trust in Our Defenders: Respecting the SBU

The Security Service of Ukraine (SBU) has paid a heavy price to protect our people, democracy, and values throughout this war, earning recognition from international partners. They may be short on PR because they are long on work. We must learn to assume good faith and treat them with respect—even when actions feel abrupt or opaque—while ensuring every intervention into anti‑corruption bodies is judicially overseen and proportionate. The proposed CIP and Independent Oversight Panel deliver exactly that balance.

11. International Partners: Engage Early, Broadly—and Vertically

Friends of Ukraine should intervene early as facilitators, not only via formal horizontal channels, but also by extending dialogue vertically to grassroots voices. The Unified State recognises the swift action already taken by leaders such as Emmanuel Macron and Friedrich Merz, and other diplomats—we welcome it. We kindly ask you to add one step: invite a small, diverse delegation of protesters—especially students and non‑establishment activists—to a listening session; assure them the world hears them, and pass that summary back to Ukrainian officials to close the feedback loop. Keep these grassroots representatives informed as reforms progress. A few hours of genuine listening can defuse desperation, prevent cornering dynamics, and seed a modern model of international cooperation. Today’s young civic leaders, treated with respect, may become tomorrow’s diplomats, mediators, and peacemakers.

Our axis of goodwill, love, and freedom holds; together we can keep it stable.
— Lucid Founder • Michael Tulsky
on behalf of the Unified State

Kyiv | 25 July 2025 – 02:32 EEST (UTC+3)

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References

1. Human Rights Watch – “Ukraine: New Law Undercuts Independence of Anti-Corruption Bodies,” 24 Jul 2025.
2. Reuters – “Zelenskiy vows to protect anti-corruption agencies, bows to protests,” 24 Jul 2025.
3. Reuters – “Zelenskiy approves bill ‘preserving independence’ of anti-corruption bodies,” 24 Jul 2025.
4. Euronews – “SBU arrests anti-corruption agents over alleged Kremlin ties,” 22 Jul 2025.
5. ISW – “Russian Offensive Campaign Assessment,” 23 Jul 2025.
6. POLITICO – “Von der Leyen demands answers…” 23 Jul 2025.
7. Reuters – “Ukraine curbs autonomy of anti-corruption agencies,” 23 Jul 2025.
8. The Kyiv Independent – “UPDATE: Zelensky signs law destroying independence of Ukraine’s key anti-corruption bodies” 22 Jul 2025.
9. The Guardian (live blog) – “Zelenskyy speaks to Merz and Starmer…,” 23-24 Jul 2025.
10. The Guardian – “Why are civil society activists angry…,” 23 Jul 2025.
11. Reuters – “Zelenskiy introduces bill to ‘uphold independence’…,” 24 Jul 2025.
12. GMFUS – “Europe Must Stand Firm and Support the Will of the Ukrainian People,” 24 Jul 2025.