The bankruptcy of Megabank JSC Ukraine: a case of resolution under Martial Law by Decision No. 362 of 21 July 2022, alleged embezzlement worth 30 million Euros, Prozorro Sale lot No. GL19N1025527 and a controversial sale to "Spectrum UA Credit LLC"/"Spectrum Assets" in potential breach of sanctions

Disclaimer: This article does not constitute investment advice. 
Attention: This article has been drafted from June 2022 onwards, additions have been made in June 2026 as well as a review on whether the documented information is still accurate. Information has been stored with utmost accuracy, yet several sources are no longer publicly available. Claims regarding these sources were made at the time of consultation and hold true based on the information available at the relevant sources at the time. Information from referenced sources is still accurate. Moreover, in case of fraud or suspicions thereof and it affects the financial interests of the EU, you are required to report it. 
The following edit has been made: five paragraphs have been added in June 2026, which are as follows:

-  An alleged 30 million Euro embezzlement scheme?  

-  Case No. 520/2120/19, an early warning sign?  

-  Supreme Court ruling in favour of NBU and investigations into embezzlement 

-  A sale of Megabank's assets to "Spectrum Assets"/ Spectrum UA Credit LLC

-  Conclusion

The article itself has been divided in three parts:

i) Background

ii) Megabank's ins, outs and allegations  

iii) A sale of Megabank's assets to "Spectrum Assets"/ "Spectrum UA Credit LLC" 

In 2022, the 24th largest bank in Ukraine, Megabank, has started to show cracks in its financial health, and has been declared insolvent since June 2022. As a regional bank, located in Kharkiv and established in 1991, this puts an end to the company as a going concern after 31 years, following the revocation of its banking license.

Only four years ago (as of 2026), the bank reported record profits of around 5 billion Ukrainian Hryvnia, five times as high as in 2017. During that time, the amount of equity remained unchanged. Its main shareholder is Tecton-Stroy LLC, a private joint stock company with Mr. V.G Subbotin as its Ultimate Beneficiary Owner, having a stake of 60.8% according to the 2019 annual report. Furthermore, p.45 specifies that purchase and sale agreements were conducted on 28, 29 and 30 March 2019 worth UAH 130 million. On 19 December 2019, UAH 46 million of these contributions were refunded, of which UAH 11,600 to Tecton-Stroy, under conditions set out in the unscheduled General meeting of Shareholders. A month after the bankruptcy announcement, the 2021 annual report in English has been removed. The most recent attempt in visiting its website led to a connection error. (Same for the Russian one, with the corporate actions set out at p. 21).

i) Background

Despite record profits in 2018, Megabank JSC Ukraine was declared insolvent on 2 June 2022. The government decision was based on Megabank's failure to comply with the law. Alleged violations included lending to related third parties and inadequate credit risk assessments leading to a build-up of non-core assets on the balance sheet, according to Retail Banker International. Moreover, the regulator stressed that the overall Ukrainian banking sector is stable and solvent, suggesting that Megabank's problems are rather specific. Megabank's 2014 annual report mentions an outstanding balance with 'other related parties' of 885 mln Hryvnia, versus only 638 Hryvnia to the major shareholder. These 'other related parties' are ironically "companies that are considered to be under control of Bank’s ultimate shareholder and Bank’s management" as visible on pp 64-65, suggesting an outstanding balance of 886 mln Hryvnia with the bank's management and UBO. Unfortantely the website of Megabank has recently become inaccessible which makes it impossible to read the annual reports as of the date of this article. These were accessed in June 2022. To read the evidence of the claims made in this paragraph and the above, would require Megabank to fully restore access to its official annual reports. 

When Megabank was declared insolvent, it has denied access to the national deposit guarantee scheme, as demonstrated by an article from Interfax. That scheme requires a financial assessment of the bank before handing out compensation to depositors.

ii) Megabank's ins, outs and allegations 

Ownership structure

In 2021, the bank reported record profits of around 5 times as high as in 2017 according to stockworld.ua, the domain of which is unfortunately no longer available. Another source mentions for 2021 a net income of 114.8 million UAH https://thebanks.eu/banks/19460. During that time, the amount of equity remained unchanged. Its main shareholder is Tecton-Stroy LLC, a private joint stock company with Mr. V.G Subbotin as its Ultimate Beneficiary Owner, having a stake of 60.8% according to the 2019 annual report. Furthermore, p.45 specifies that purchase and sale agreements were conducted on 28, 29 and 30 March 2019 worth UAH 130 million. On 19 December 2019, UAH 46 million of these contributions were refunded, of which UAH 11,600 to Tecton-Stroy, under conditions set out in the unscheduled General meeting of Shareholders. A month after the bankruptcy announcement, the 2021 annual report in English has been removed. As mentioned two paragraphs above, the evidence can be verified if the reports are returned online. 

Outstanding balance in 2014

 Megabank's 2014 annual report mentions an outstanding balance with 'other related parties' of 885 mln Hryvnia, versus only 638 Hryvnia to the major shareholder. These 'other related parties' are ironically "companies that are considered to be under control of Bank’s ultimate shareholder and Bank’s management" as visible on pp 64-65, suggesting an outstanding balance of 886 mln Hryvnia with the bank's management and UBO. Unfortantely the original website of Megabank has recently become inaccessible which makes it impossible to read the annual reports. To read the evidence of this claims also requires Megabank to fully restore access to its official annual reports, which is not the case at the time of writing. 

Now that Megabank is insolvent, it has denied access to the national deposit guarantee scheme, as demonstrated by an article from Interfax. That scheme requires a financial assessment of the bank before handing out compensation to depositors. This is unusual for a bank that has been declared 'problematic' since 3 February 2022 by the National Bank of Ukraine, in accordance with Article 75 of the Law of Ukraine on Banks. Instead, Megabank JSC will be the first Ukrainian bank whose deposits are to be fully compensated under martial law. 

High volume of correspondent accounts
It has become clear that Megabank has had relatively high volumes in correspondent accounts, 1.2 billion UAH from the beginning of the war till May, according to Oleksy Yatsenko, Head of the Supervisory Board and Chairman of the Board at Megabank. Among its depositors was, at least in April 2018, Ihor Rainin, who reportedly claimed to have 2 million UAH worth of assets at the time, of which only 3.3% held in bank deposits. Ihor Rainin was head of the presidential administration under Poroschenko,  according to a Kyiv Post article of 27 November 2019. He was appointed Chairman of the Opposition Platform - Pro Life as of 27 November 2019.

A Cypriot lawyer as director for the UBO’s shell companies?
One name that keeps popping up in the charts of ownership structure is Christodoulos Vasilliades. As of 1 January 2022. He is director at several shell companies that are used to run Melvi Am Limited and Melvi Agri Limited. This Cypriot company register  mentions the legal constructions Mittelmeer Directors Limited and Ionics Directors Limited, and this one (i-cypriot) links them as the respective directorates for Melvi Am and Melvi Agri. This can be seen on the next page (marked in red):

Source: https://i-cyprus.com/company/444097 (Accessed 4 October 2023)

Melvi Agri and Melvi Am in their turn fulfilled an important role in the ownership structure of Megabank since at least 2013. These two limited liability companies have had both a direct form of ownership in the bank as well as an indirect one through another limited liability company called M-Invest Ukraine. This can be seen in the chart on the next page (Source: https://bank.gov.ua/files/Shareholders/351629/351629_20190101.pdf , Accessed 4 October 2023):

The chart below dates from 1 January 2019, just a day after the year in which record profits were made (same source). Based on these statistics, you can calculate that the cumulative amount of ownership thus managed through director Christodoulos Vasiliades through the marked ring of shell companies equaled 0.3710%+0.4149%+(9.9761%+9.9761%)*(39.9197%+74.9908%*4.9936%)+74.7900%*4.9931%= 13.138% of total ownership in Megabank in 2019.

If we turn to the chart from 1 January 2022, we find the following (see next page): (9.976148%+9.976148%)*(30.047642%+74.990754%*3.758720%+74.790052%*3.758286%)+0.312284%+0.279228%= 7.2364%.  

Obviously this amount is far below the amount of 2019, yet still significant. It raises questions why the EBRD on behalf of the EU has maintained its equity investment until 2022 despite the UBO - Mr. Subbotin that is - being reliant on a lawyer who has been sanctioned by the U.S and U.K since 2023 and had before that provided services to oligarchs that align closely with the Kremlin, even though in itself it is not a priori illegal, at least not in 2022. 

Besides the constant involvement of Melvi Agri Limited, Melvi AM Limited and M-Invest, another (near) constant are the rates of ownership: Melvi Agri and Melvi AM both hold just below 10% stake in  M-Invest, and M-Invest in its turn owns just below 75% in 'Tori 2014' and 'Megasoft' respectively. And M-Invest holds just below 40% directly in Megabank. And both Melvi Agri Limited and Melvi AM Limited hold a direct stake of less than 0.5%. It is noteworthy too that both Melvi AM and Melvi Agri are fully owned by Mrs. Subbotina, the wife of the UBO, through intermediaries on Belize, respectively called Winfold Investments Limited and Tesco Investments Limited as seen in both charts.

What the query from 4 October 2023 in the Cypriotic company register shows is that Melvi AM Limited and Melvi Agri Limited are still active, that it to say more than one year after insolvency of Megabank JSC itself. That implies several key components of the investment structures at now defunct Megabank are still alive and managed by Christodoulos Vassilliades if we rely on the public registry i-cypriot. It must be stressed that the remnant of Megabank JSC has evolved into Megabank, with a new website that mentions 21 July 2025 to be the deadline for liquidation of the bank. It is unclear for the time being what transactions are carried out to achieve that, and the developments in below paragraph have sparked controversy (source: telegram.org):

2026 update:

An alleged 30 million Euro embezzlement scheme?

Above snapshot is an excerpt from a Telegram message from 14 September 2023, which  refers to an article by Ukraine Insider, where former MP Oleksandr Chernenko accuses Viktor Subbotin of embezzlement. It is an allegation, and should therefore not a priori count as evidence of fraud. In addition, the statement, which originally appeared on facebook, has been retracted and on the other company of which Mr. Subbotin is owner, namely Ukrenergymachines, a statement has been made denouncing the allegations and announcing preparations of lawsuits against those who spread the rumour. 

And yet, an  article by EUToday from 8 July 2025 confirms that Viktor Subbotin and his wife Olena Subbotina are under investigation for the embezzlement of about 30 million Euros by the State Bureau of Investigation. Furthermore, it is mentioned that criminal proceeding №42019221430000469 was initiated in 2019 yet remained dormant until 2022. (Source: https://eutoday.net/a-e30-million-scheme-how-did-the-subbotins-firms-withdraw-funds-from-the-ministry-of-finance-and-the-ebrd-from-megabank/). It is alleged that the payments took place between 2017 and 2021. During that period, it is reported that the European Investment Bank and the Ukrainian Ministry of Finance provided funds worth 30 million Euros to Megabank through Ukreximbank. Later on, 'internal law officers', as referred to in the article, discovered that once arrived, these funds were provided to related companies controlled by Megabank's owners instead of Small- and Medium Enterprises as intended. One of these companies is called Nonferrous Metal Plant LLC and was alleged to have received 10 million Euros.  A document referred to indicates several tranches of payments between 2017 and 2021, and if proven true, might support the claim made in the Telegram post when assessed in the relevant court. Besides Nonferrous Metal Plant LLC,  entities subjected to investigation included OPTION-Trade LLC, of which Olena Subbotina is 97% owner, as well as TORI 2014 LLC, TUDU CORPORATION LLC, M-Invest PrJSC. You can find those on the chart showing ownership structure in the excerpts from NBU above to see the exact stakes, mind that it is not in English. 

Case No. 520/2120/19, an early warning sign?

An article by Finbalance from 19 September 2019, accessed in October 2023 reported on several highlights from case No. 520/2120/19. Unfortunately the domain is no longer available at the time of update in 2026, yet several findings in the article stood out: A judgement by Ukraine's supreme court of 16 September that year, in which Megabank sought a cassation appeal to contest the restrictions imposed on it from 27 September 2018 till 31 December 2018, with an extension from 28 December 2018 till 31 March 2019. The supreme court ruled in favour of Megabank and cancelled several restrictions that were in place during the described period. 

A remarkable statistic was the maximum amount of credit risk on operations with persons related to the bank, namely 115.79% (as of 1 September 2019). This is about 4.5 times the maximum of 25% as required by the NBU. 

Supreme Court ruling in favour of NBU and investigations into embezzlement 

On 24 June 2025, the Ukrainian Supreme Court has declared the decision by the National Bank of Ukraine to declare Megabank insolvent as legal. This verdict was reached despite earlier objections raised by owner Viktor Subbotin, according to an article by liga.net (Source: https://finance.liga.net/en/bank/news/megabank-has-been-officially-declared-insolvent-the-supreme-court-upheld-the-nbus-decision), which likely strengthens the position of the Ukrainian State in the investigation. 

iii) A sale of Megabank's assets to "Spectrum Assets"/ Spectrum UA Credit LLC

An article from antikor.ua from 18 December 2024 named "Hidden passport and FSB ties: How Spectrum Assets circumvented NBU and Cabinet bans" refers to journalists who discovered the sale of assets by the Ukrainian Deposit Guarantee Fund to a company called Spectrum Assets. The lot was sold for 124 million UAH on debt claims worth around 2.8 billion UAH, of which 90% belonged to Russian Sberbank's Ukrainian branch called MR Bank,  and the other 10% included assets from Russian Prominvestbank and Ukrainian Megabank, meaning that millions of UAH in debt claims from Megabank may have been sold to this company following the tender submitted to Prozorro Sale. 

The article mentions that a requirement by Prozorro Sale is that the participant(s) must have no connection to the Russian Federation, stating that the Ultimate Beneficial Owner of Spectrum Assets, Marina Yevseyeva hid the fact that she holds Russian citizenship besides her American passport. Reference is made to obtained documents which show that she has authorised Michael Trubchik (born in Belarus) since 7 February 2023 to manage both Spectrum UA Credit LLC (US) and its Ukrainian subsidiary Spectrum Assets. It must be said that a query on the NSDC of Ukraine Office on the name “Yevseyeva” does not show any results. However, the fact that Spectrum Assets won the acquisition of the lot indicates potential gaps in Prozorro Sale’s screening procedures as well as Ukraine’s registration of individuals and entities.

A query on megabank.fg.gov.ua leads to a statement of 27 February in which reference is made to a tender no. GFD001-UA-20240123-11291 of 14 February 2024 with lot number GL18N1025468 (https://megabank.fg.gov.ua/articles/57379-povidomlennya-pro-ukladennya-dogovoru.html) as in the snapshot above, however, this does not seem to match with the picture from the antikor article. Instead, a further inquiry on Prozorro leads to another tender with exposures from the same three banks, with the following lot number: GL19N1025527. As far as visible, this is the only other lot that includes a pool of assets from all three banks for which the auction value corresponds exactly to the one as can be seen in the antikor article, meaning it is this one that was likely sold Spectrum Assets.

A detailed look on Prozorro Sale shows that the starting time for accepting bids was 12 January 2024 at 15:59. The closing window for submitting bids was 7 February 2024 at 08:30, and the auction was closed that same day at 15:15. The opening bid to be received was 296,781,679.39 (around 296.8 million) Ukrainian Hryvnia, whereas the sale was ultimately conducted for 124,648,305.34 (around 124.6 million) Hryvnia, which roughly corresponds to the 124 million Hryvnia as mentioned before. When opening the attached NDA pdf, is can be noted that page 11 of 12 requires participants to confirm no affiliation with the Russian Federation in accordance with Decree to the Cabinet of Ministers of Ukraine dated March 3, 2022 No. 187, see below (in Russian) If it is true that indeed this lot was sold to Spectrum Assets, which it likely is based on the mentioned lot value, involved banks and legal requirements - taken into account the information on Spectrum Assets UBO - it can then on credible grounds be alleged that a breach of sanctions has taken place. 

Spectrum Assets is registered in Ukraine as Spectrum Assets LLC, having been established on 10 October 2019, as visible on Ukrainian corporate data register youcontrol.ua (see snapshot below, source: https://youcontrol.com.ua/en/catalog/company_details/43285992/). On 31 March 2026, Spectrum UA Credit LLC, accompanied by natural person Geno Pikulik, filed a complaint at the U.S. District Court for the District of Columbia (case number 1:2026cv01090), against the Ukrainian Deposit Guarantee Fund, National Bank of Ukraine and the Security Service of Ukraine. The complaint involves Statutory Provision 28 U.S.C. § 1330 (https://dockets.justia.com/docket/district-of-columbia/dcdce/1:2026cv01090/290995), which guards a plaintiff against breach of contract by a foreign state. Filing 5, on 9 April 2026 involves a Standing Order. After that, arbitration case (ICSID Case No. ARB/26/17) was filed on 17 April 2026 invoking BIT Ukraine - United States of America 1994. This bilateral treaty may have been used to justify a circumvention of the existing bans imposed by NBU and the Ukrainian government on grounds that the UBO is an American citizen (Maria Yevseyeva) but that remains speculative. 

This leads to an Arbitration case that has been initiated against Ukraine at the ICSID (ICSID CASE NO. ARB/26/17) as of 17 April 2026. https://icsid.worldbank.org/cases/case-database/case-detail?CaseNo=ARB/26/17.

As an article from censor.net (https://censor.net/en/news/3525850/russian-evseeva-bought-up-assets-of-russian-banks-in-ukraine) notes, the Deposit Guarantee Fund verifies client data based on the public register of legal entities, in which Marina Yevseyeva was registered as an American citizen at the time of the tender, which was won in February 2024. Following the fact that the Ukrainian Security Service discovered that she holds Russian citizenship as second nationality, the Deposit Guarantee Fund has ordered a fine equal to the purchased lot, about 124 million UAH. 

Offshore Alert also refers to the case and describes that the complaint is about an alleged $127 million conspiracy. (source: https://www.offshorealert.com/spectrum-ua-credit-llc-et-al-v-ukraine-et-al-complaint-127m-conspiracy/?srsltid=AfmBOopEic1oAiGSYA2ZKanLI6QcalPQ9_ypYP0LAamAJ0Fvzn5VC5Dc). This complaint is likely a response to the decision of the NBU and Ukrainian Security Service to reassess the sale to Spectrum Assets as a result of scrutiny and the fine imposed on Spectrum Assets.

The parent company of "Spectrum Assets LLC" is "Spectrum UA Credit LLC", also registered in October 2019 and can be found in the Corporate register of the state of Delaware and has file number 7551095. Its registered address is 251 Little Falls Drive in Wilmington, 19808, whereas its principal place of business resides in Newport Beach, California. This can be seen in an excerpt from pacer monitor, see below.  

The cases have not been closed yet.