Online robbery

NGL.media created the first database to search for unfair notaries and registrars
26 October 2024

If your property or business has all of a sudden been signed over to another person, you can choose one of two variants — either go to the police and sue them or register a complaint with the Anti-Raiding Office at the Ministry of Justice. This specific body annually looks into several thousand complaints about the people, called “black notaries” or “black registrars” in the media. Pursuant to the results of the board’s review of these complaints, the Ministry of Justice takes a decision to either dismiss or satisfy these complaints, abolish some registration activities, or deny these registrars any access to the registers. According to the total statistics, only 21% of complaints are satisfied.

NGL.media collected and analysed about 22.5 thousand such decisions of the Ministry of Justice from 2016 till July 2024 inclusive. We have arranged all the data and created a convenient search system where anyone can easily find all the decisions regarding the complaints about a specific registrar or notary.

A total of almost 6.3 thousand registrars and notaries have been entered into the database, but more than half of all complaints refer to a total of under 500 persons featured in 10 or more complaints.

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This instrument may be handy for journalists, investigating forcible takeovers, for lawyers, analysing the practice to prepare their complaints or suits, and anybody who wants to check the fairness of a specific notary or registrar or investigate the purity of some real estate history.

The database of complaints about registrars. How it works

We have downloaded all the decisions regarding all the registrars and notaries to the Pinpoint portal, which ensures a flexible search for names, enterprises, dates, or any combinations of words among dozens of thousands of documents. For instance, you can search for all the documents, mentioning a specific street and registrar (“Rybatska street” + Yeroshenko); it is important to enclose the search terms, consisting of several words, in quotation marks. Or you can exclude a term from the search results by placing a minus sign without a space in front of it (“Rybatska” -Yeroshenko). Click the image to go to the Pinpoint.

We have visualized the more detailed data about the registrars and notaries featured in 10 or more complaints at the end of the text. Start entering the surname in the search line and choose it from the list; there are also references to all the documents related to the selected registrar or notary.

This is how we have done it Hide

The Ministry of Justice does not publish any generalized data* on the complaints about registrars and notaries, but the results of each complaint review are published on the website in PDF format. We have written a script that “crawls” along the relevant pages on the website of the Ministry of Justice and saves these PDFs for further analysis. Most of these were merely scanned images, so to extract the text from them automatically, we had to recognize it using OCR instruments. We used Tesseract engine and kept the data about each complaint and the text of a response thereto in a separate dataset. Our further analysis of texts involved the use of OpenRefine programme and search for similar text patterns in responses to complaints — this is how we managed to determine and “clean” the registrars’ surnames (sometimes their names and surnames were published with misprints) and to define the result of a complaint review.

* The Ministry of Justice allows only for obtaining basic information about the complaints to be considered by the board (besides, this information is not available regarding the complaints considered until October 2023)

A former registrar of the Department of Culture of the Chernivtsi regional state administration, Mykola Herheliuk, is at the top of our list. In 2022, different religious organizations of the Ukrainian Orthodox Church (Moscow Patriarchate) complained about him over one hundred times. It was found that Herheliuk changed their names in the register, adding phrases like “The belonging to the Russian Orthodox Church (Moscow Patriarchate) has not been indicated”. The majority of these complaints were satisfied, and the registrar’s access to the register was blocked for three months, but it is still possible to find such original entries in the registers.

In the conversation with NGL.media, Mykola Herheliuk explained his actions by his patriotic attitude. He doesn’t work as a registrar anymore because he serves in the army.

However, this funny story is an exception since other cases regarding registrars and notaries look much worse.

Record holders

In addition to Herheliuk, we have found at least six registrars, mentioned over 100 times in the complaints filed with the Anti-Raiding Office.

One of these registrars is Serhii Rodzin from the Rivne region. At present, he is pursuing legal action against the Ministry of Justice, trying to appeal his blocked access to the register. There have been 130 complaints about Rodzin in the last two years. It should be noted that most complaints refer to one case of violations in 2022 when the lease agreements for agricultural land plots were registered for the benefit of one company. A considerable number of complaints are caused by the fact that they were filed to abolish the state registration for each separate land plot.

However, even if these files are counted as one case, there are still rather many complaints. Today, Rodzin still works as a state registrar in the Vysotska village council, which is reflected in his income declaration, submitted in March 2024.

Serhii Rodzin’s biography has attracted our attention as well. The matter is that before becoming a registrar, he was rather a well-known person in the region — he headed the police department in the town of Dubrovytsia in Sarne district, Rivne region. In 2016, he was arrested within the special operation “Amber” and accused of bribery and founding an illegal organization. Finally, he was released on bail of UAH 2.7 million and later signed a plea deal, according to which his punishment of five years of imprisonment was changed to a suspended three-year sentence. In March 2020, he was free from his punishment due to the completion of the probation term.

How does the Anti-Raiding Office work Hide

The Anti-Raiding Office fights unfair registrars and notaries, protecting the rights of real estate owners and legal entities. A person, whose rights have been infringed, can complain about the relevant registration activity no later than within one year from its date. If more than two months have passed since the day of taking the appealed decision, the complainant has to obligatorily specify exactly when he or she found out about the infringement of his/her rights.

The immediate review of complaints is within the scope of the board, reviewing the complaints in the sphere of state registration. During martial law, hearings are held without the participation of the complainant and the person being complained about, as well as interested parties, but they have the right to submit their explanations in writing.

Following the result of the complaint review, the board makes a decision by voting, which is then documented as a relevant opinion. It is then used as a basis for the Ministry of Justice to make a decision in the form of an order. There may be three variants in the order: satisfying a complaint, dismissing, or leaving the complaint without a review on the merits.

The board also determines how grave the registrar’s or notary’s violation is. It can both abolish or correct their entries in the register and temporarily block or even revoke their access to the register.

In addition, the registrar may face disciplinary responsibility, and as for the notary, the Office may address the Higher Qualification Commission of Notaries with a request to revoke the certificate on the right to practice notary.

The Anti-Raiding Office has informed the editorial office of NGL.media that there has been no order from the Ministry of Justice to bring anyone to disciplinary responsibility. However, they have filed requests to the Higher Qualification Commission of Notaries regarding some notaries — there have been only six such cases since early 2020.  

They may also contact the law enforcement bodies. Since early 2022, there have been five times when the Ministry of Justice has informed law enforcement bodies about the signs of criminal activities.  

Another record holder in terms of the number of complaints is Andrii Yaroshko, the registrar of Nyzhchi Lubianky village council in the Ternopil region. There has been a total of over 60 complaints filed against him, and most of them have been found to be fair. However, his violations have been found insignificant, and his access to the register has not been blocked. Despite a considerable number of complaints, Yaroshko has actually violated the law only once since most addressed complaints were from one enterprise — “Agro-Ros” LLC, and illegal registrations were done for the benefit of “Demetra++” enterprise. All these cases were related to the registration of a right to lease agricultural land plots.

It should be noted that Andrii Yaroshko started his registrar’s career with bribery as well. Being a 25-year-old registrar, he “received an unlawful remuneration in the amount of 400 dollars”, as judges put it. At the time, in 2013, he admitted his guilt and was released from the main punishment.

Business was released from the sanctions

In this text, we cannot tell the stories of all the registrars and notaries whose work was reviewed by the Anti-Raiding Office. Yet, some tendencies and innovations should be demonstrated. Previously, the head of the Anti-Raiding Office talked about the occupational retraining of some notaries when those, who unlawfully deprive people of their property, become the ones who help get rid of it. This goes about the notaries who re-register the property of people under sanctions, which may pass into the ownership of the state in the future.

NGL.media found several dozens of the Ministry of Justice’s orders for 2023–2024, which mentioned the sanctions legislation. They are mostly related to removing the names of sanctioned beneficiaries of Ukrainian companies from the register. As per Ivan Korodiuk, the head of the Anti-Raiding Office, the registration activities conducted with the violation of the sanctions legislation were detected regarding a total of 98 legal entities.

Among these orders, we found the story about Vadym Novynskyi’s companies. In spring, the Security Service of Ukraine filed a complaint with the Ministry of Justice about the removal of Novynskyi from the list of beneficiaries of dozens of companies. After the inspection, most of these changes were abolished, and access to the Unified State Register was denied to two notaries (Alla Smirnova and Oleksandra Chernyk) and three state registrars (Anna Popadynets, Raisa Khyzhka, and Alla Shevchuk). 

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There is a similar story about the change of owners of “Osokorky-7” and “Akadem-club” companies, which is related to Viktor Medvedchuk and Oksana Marchenko. After the release of the investigation of Bihus.info, demonstrating that a number of their assets were signed over to other owners, the Prosecutor General’s Office addressed the Ministry of Justice, and these registrations were abolished immediately. However, the registrars and notaries were not punished.

At the same time, there were cases when complaints were filed by registrars and notaries, claiming that someone used their identifiers to get access to the Unified State Register. For instance, such complaints were filed by Liudmyla Rusniak, a private notary from the Poltava region. One of her complaints was related to Vadym Yermolayev, a well-known businessman who is under Ukrainian sanctions and whose five companies were signed over to his daughter, Sofia Kononenko.

There are fewer complaints

It is noteworthy that the number of complaints is decreasing. However, the main reason behind it is not better integrity of registrars and notaries but the changes in the legislation and the beginning of the full-scale invasion. That was the time when all the activities related to real estate and business were suspended, so there were no complaints either. Yet, when the registration activities were renewed, other types of complaints emerged too. These were related to the assets of the persons under sanctions.

There is one more reason for the decrease in the number of complaints — in 2019, the registrars of municipal enterprises were deprived of the possibility to do any registration. According to the data of the Ministry of Justice, they were the ones to make the most unlawful changes in the registers. The peak of this activity was in 2020–2021.

By the way, previously, there was a list of registrars and notaries whose access to state registers had been cancelled, but this section has disappeared from the official website. The Ministry of Justice has not provided us with the current list and sent the inquiry of NGL.media to ST “Natsionalni Informatsiini Systemy” [National Information Systems], which replied that “this information does not exist in the ready documented form”.

The persons in our investigations

One of the most high-profile state registrars in Lviv and its suburbs is 48-year-old Mykhailo Zhyvko. His work was highlighted in many media outlets, including NGL.media. He was the one to help the Dubnevych family with dubious land registration or to assist the sanctioned ex-employee of the customs, Ivan Bokal

Previously, he was sued for registering the private ownership right regarding a municipal land plot in Lviv. Later, Zhyvko received a notice of suspicion in cases about the land plots in Briukhovychi and the Trade Unions Building in the centre of Lviv. The indictments in both cases have already been transferred to the court. 

There were a total of 20 complaints regarding Mykhailo Zhyvko’s registration activities, but only one complaint was addressed, and his access to the register was blocked for three months. All the other complaints were dismissed by the Ministry of Justice due to formal reasons.

How can you monitor your own property and business to protect yourself from forcible takeover Hide

You should monitor the status of your assets constantly using two open state registers: the Unified Register of Legal Entities, Sole Entrepreneurs, and Public Organizations and the State Register of Real Estate Rights.

Yet, since it is very inefficient to do it manually every day, there are several possibilities to do it automatically. However, all of them are not free to use.

For instance, the service of monitoring the registration activities regarding the real estate property of private individuals and legal entities, “SMS-Mayak” by Liga and the Ministry of Justice, suggests two variants, which cost UAH 36 and UAH 352.8 per month.

The changes regarding legal entities can be easily traced on paid platforms, for example, YouControl and Clarity Project (we would like to note that these services provide free access for the journalists of the editorial office). Subscribing to specific legal entities in these services, you can receive notifications about some changes, including litigations, etc.

There were complaints about the registrars, Iryna Revakovych and Khrystyna Boiko, featured in previous publications of NGL.media. Most complaints were dismissed, but in the most high-profile story with their involvement, the decision of the Ministry of Justice was not in their favour. The case was related to the “privatization” of the Lviv municipal markets, “Vynnykivskyi” and “Pidzamche” in the interests of a businessman and ex-deputy, Hryhorii Kozlovskyi

There was an attempt to appeal this decision of the Ministry of Justice in court, but it failed. Yet, it didn’t help much because the Lviv city council came to an agreement, and the criminal investigation is still ongoing without any result. The tax declarations of Revakovych and Boiko demonstrate that they don’t work as state registrars anymore, but court proceedings regarding the cancellation of some of their registration activities are still underway.

Another registrar from the Lviv region, known to us, Natalia Lobodynets, is famous for entering data about real estate into the register based on the documents from the future. Yet, judging by her income declarations, she is still working. This year, there have been two orders of the Ministry of Justice on blocking her access to the register of real estate for three months.

The most high-profile case in the history of Lviv is the fraud involving dozens of municipal premises lost by the Lviv city council. This case featured several registrars and notaries, including Uliana Pshenychna, a notary. The board reviewed two complaints regarding her but refused to satisfy them because there was ongoing litigation in one case, and the other stated that the notary had acted according to the legislation.


Check your registrar


We have visualized data on registrars and notaries who received 10 or more complaints. Start typing a surname in the search bar and select it from the list; there are also references to all the documents related to the selected registrar or notary. To see documents related to other registrars, go to Pinpoint.


This material was prepared with the financial support from the European Union. The EU4IM project, funded by the European Union, is solely responsible for its content. The content of the material is the sole responsibility of NGL.media and does not necessarily reflect the views of the European Union.