Entrypoint and Deproil announce the launch of a joint subsurface intelligence capability designed to support investment decision-making in natural resources, including oil & gas, minerals, and energy-transition assets. The partnership brings together Entrypoint’s business intelligence and risk-advisory expertise with Deproil’s advanced geological modelling and reserve-estimation capabilities. The combined offering delivers independent, investment-grade subsurface analysis tailored specifically to the needs of investors, lenders, and advisory firms involved in due diligence, valuation, arbitration, and strategic capital allocation. Subsurface Risk as an Investment Issue In many natural-resource transactions, subsurface uncertainty is frequently mispriced or embedded within commercial assumptions. In-place resources are often conflated with recoverable reserves, while optimistic production forecasts may be insufficiently grounded in geological reality. Structural complexity, compartmentalisation, and development constraints are commonly underestimated, exposing investors to material downside risk. The Entrypoint–Deproil capability addresses this gap by reframing subsurface analysis as an investment-critical intelligence function, rather than a purely technical exercise. Independent Geological Modelling for Decision-Grade Outputs The joint approach integrates multiple data types — including gravity, seismic, well-log, petrophysical, and magnetic data — to construct geologically meaningful inhomogeneous density models from surface to deep subsurface levels. These models are translated into clear, transparent outputs relevant to investment decisions, including: • Independent estimates of recoverable reserves • Defined assumptions and uncertainty ranges • Prediction of initial production (IP) rates • Identification of geological sweet spots and downside risks • Early detection of underperforming development concepts The analysis is designed to complement legal, commercial, ESG, and political due diligence, strengthening valuation discipline and negotiation positioning. Designed for Investors, Advisors, and Disputes The capability is structured to fit typical due-diligence timelines and advisory workflows. It can be deployed at multiple stages of the investment lifecycle — from early screening and pre-LOI assessments to transaction support, refinancing, and arbitration or dispute contexts — providing an independent technical perspective where operator-supplied data may be biased or incomplete. About the Partners Entrypoint  is a business intelligence and risk-advisory firm supporting international investors, financial institutions, and professional advisors across emerging and complex markets. The firm combines political, market, ESG, and asset-level intelligence to support informed decision-making in high-risk environments. The International Trade Administration of the U.S. Department of Commerce lists Entrypoint as a Business Service Provider for Ukraine. For further information, please refer to: www.entrypointgroup.com . Deproil  is a geoscience consultancy with more than two decades of experience in subsurface analysis, geological modelling, reserve estimation, and production forecasting. The firm applies advanced analytical methods to translate complex geological data into practical, decision-oriented insights. For further information, please refer to: www.deproil.com . Contact: contact@entrypointgroup.com

U.S. oil giant Chevron and U.S.-linked private equity firm Quantum Capital Group are reportedly collaborating on a $22 billion bid for the international assets of Lukoil, one of Russia’s largest oil companies Chevron is interested in Lukoil’s 5% stake in Kazakhstan’s Tengiz oilfield, which Chevron partially owns and operates, as well as in refining facilities and over 2,000 filling stations across Europe, Asia and the Middle East. Quantum was founded by Texan oil tycoon Wil VanLoh and has already engaged with officials in the Trump administration, arguing that its proposal would consolidate American control over strategically essential energy assets. Other bidders include The Carlyle Group , ExxonMobil , Saudi Arabia’s Midad Holding  Energy, and other suitors that have expressed interest. But any final agreement would require US regulatory approval, effectively giving President Donald Trump a veto over the transaction. Western sanctions tied to the Russian invasion of Ukraine have forced Lukoil into divestment, compelling Russia into a fire sale of prized global assets. Kremlin’s calculus just got harder: sanctions bite, assets are leveraged, and peace doesn’t come cheap — it might be priced in billions. For Vladimir Putin, forced divestments may be the cost of a face-saving way out of the war against Ukraine — and, metaphorically, the price of an Alaska red-carpet welcome. This deal isn’t just corporate M&A — it’s a potential turning point in the economic pressure applied to Moscow and a signal that Western markets are reclaiming influence over energy routes once dominated by Russian state-linked firms. Energy policy isn’t just economics anymore — it’s diplomacy, strategy, and perhaps the real cost of ending a long war. The open question remains: what additional costs would Ukraine be expected to bear to bring the war to an end within this broader geopolitical bargaining framework?

During wartime, governments often face difficult trade-offs between transparency and security. Ukraine is no exception. According to a recent Opendatabot analytical review , 2025 saw a further reduction in the availability of certain open datasets that had previously supported public oversight, business analysis, and market intelligence. While some of these decisions are linked to security considerations, the result is a narrower open-data environment that will require systematic restoration once wartime restrictions are lifted. Current State of Open Data Access Ukraine’s open data transparency level currently stands at approximately 44%, reflecting both datasets closed since the beginning of the full-scale invasion and additional restrictions introduced in 2025. Importantly, the closures are selective rather than comprehensive. Most relate to datasets that intersect with: • defence and security, • senior public officials, • property ownership, • criminal and enforcement statistics. From a business-intelligence perspective, this does not eliminate access to information altogether, but it reduces consistency, comparability, and analytical depth. Key Data Categories with Limited Access Defence-related companies Certain companies connected to the defence sector are now allowed to request removal of their data from open platforms. This is intended to mitigate security risks but also means that company profiles may appear incomplete in public datasets. Officials’ asset disclosures Some senior officials can restrict public access to their asset declarations. While legal under current regulations, this limits the ability to conduct systematic governance or integrity analysis using open sources alone. Real estate and land data Changes to property registry access have reduced visibility over business real estate and land assets. This affects transaction screening, asset mapping, and long-term market analysis. Criminal statistics (selected categories) The discontinuation of certain aggregated datasets, such as monthly crime statistics, reduces the availability of structured historical data used for trend analysis and contextual risk assessments. What This Means in Practice For investors, advisors, and analysts, the impact is practical rather than dramatic: • Open-source research now requires additional verification layers • Longitudinal comparisons may be fragmented • Some risk indicators are less visible in public datasets • Greater reliance is needed on paid sources, local expertise, and triangulation This does not make informed analysis impossible, but it does make it more resource-intensive. Temporary Constraints, Long-Term Expectations Most of the restricted datasets were accessible for many years prior to the war and remain technically recoverable. From a governance and economic perspective, their restoration will be important for: • rebuilding investor confidence, • strengthening market transparency, • supporting anti-corruption infrastructure, • enabling evidence-based policymaking. The key issue is not whether data should be protected during wartime, but how clearly the state has to pursue post-war reopening and normalisation. Entrypoint Perspective For Entrypoint, these developments reinforce a simple point: open data alone is no longer sufficient for comprehensive risk assessment. In the current environment, effective business intelligence increasingly depends on: • structured verification, • jurisdiction-specific expertise, • cross-source validation, • and an understanding of what data is missing, not only what is available. When the war ends, Ukraine will move toward recovery, and restoring open data access will be a crucial step — but until then, informed decision-making requires a more layered analytical approach.

Kernel is not merely another Ukrainian agribusiness. It is the country’s largest integrated agro-industrial group, one of the most profitable exporters, and since 2007, a flagship for Ukraine’s presence on European capital markets. In 2024, Kernel topped Forbes Ukraine's ranking of Ukraine’s most prominent agricultural companies by revenue, highlighting its strategic importance to the economy. Yet Kernel now finds itself at the centre of one of the contentious corporate governance disputes in Ukraine’s business scene. The company’s controlling shareholder, Andriy Verevsky, has been accused by activist investors of exploiting the wartime environment to delist Kernel from the Warsaw Stock Exchange and force out minority shareholders at an unfair price. What initially was a corporate restructuring has developed into a broader debate about investor protection, fairness, and the long-term credibility of Ukrainian issuers on international markets. I. Kernel: A Flagship of Ukrainian Agribusiness Kernel’s scale is undeniable. It remains one of the most profitable agribusinesses in Eastern Europe and a key supplier of sunflower oil and grains worldwide. The company is vertically integrated, highly efficient and, under normal conditions, exactly the kind of success story that foreign investors seek. Its long-standing listing in Warsaw was also symbolic: Kernel was one of the most significant Ukrainian presences on an EU stock exchange, signalling that domestic companies could operate under European disclosure and governance rules. That symbolism has now cracked. II. The Dispute: Legal Mechanisms vs. Perceptions of Fairness The heart of the controversy lies in Verevsky’s decision to take Kernel private through a delisting and subsequent squeeze-out of minority shareholders. The legal reality Kernel is registered in Luxembourg. Under Luxembourg corporate law, once a shareholder crosses the 95% ownership threshold, they can initiate a mandatory buy-out of remaining minorities. This mechanism—common in Europe—requires: • an independent valuation, • regulatory oversight, • and confirmation that the offer price is “fair.” Regulators and courts have already acknowledged Verevsky’s controlling stake and rejected several minority claims. From a narrow legal standpoint, Verevsky appears to have operated within the structure allowed by law. But legality is not the whole story. Minority shareholders argue that: • the valuation was depressed due to Russia’s invasion, • liquidity was artificially low, • information asymmetry favoured the majority, • and the delisting forced them to exit at a moment when prices did not reflect Kernel’s long-term value. Some commentators describe it as deliberate “opportunistic timing.” Activist investors accuse Verevsky of building a campaign of “legal and illegal pressure” around the process. Whether or not such claims stand in court, they significantly shape market perception. This is where Kernel’s case becomes more than a legal dispute: it becomes a governance signal. III. How Other Ukrainian Champions Behave: Astarta, MHP, Ferrexpo Institutional investors immediately compare what Kernel is doing with what other major Ukrainian corporates are doing under similar wartime stress. • Astarta has maintained its Warsaw listing and continues to engage openly with minority investors. • MHP remains listed in London despite operational and geopolitical shocks. • Ferrexpo, facing sanctions-related pressure on its controlling shareholder and challenges in ore logistics, still honours its public-market obligations. These companies are not without problems, but they demonstrate an apparent willingness to preserve their listings, transparency, and minority rights—even in highly adverse conditions. Kernel’s approach stands out in the opposite direction: withdrawing from public markets when liquidity is low and valuations are depressed. For global investors, this contrast matters. IV. What Does This Mean for Ukraine’s Investment Reputation? Kernel is not just a company—it serves as a proxy for how foreign investors assess Ukrainian corporate behaviour. Its actions have several implications: 1. Elevated Governance Risk Premium Foreign equity funds will now account for a higher risk that, even if they invest in a Ukrainian issuer listed abroad, a controlling shareholder may later use legal mechanisms to take the company private at an unfavourable price. This translates into: • higher required returns, • increased caution, • and more rigorous due diligence. 2. Listing Abroad Is Not a Guarantee of Protection Many foreign funds assumed that a Warsaw or London listing automatically implied European-grade governance. Kernel demonstrates that: • the legal wrapper matters, but • so does the behaviour of the controlling shareholder, • and the responsiveness of local courts and regulators. Investors now know that jurisdiction alone does not eliminate governance risk. 3. Damage to “Ukraine Inc.” Narrative As Ukraine seeks massive post-war reconstruction capital, it positions itself as a future regional hub for agritech, logistics, metals, and energy. In that context, cases like Kernel’s become cautionary tales. Foreign investors discuss reputational markers. They share stories. One bad case can overshadow ten good ones. Kernel risks becoming the example that global funds cite when explaining why Ukrainian equity carries a discount. 4. Not All Ukrainian Issuers Are the Same The good news is that other Ukrainian corporates—Astarta, MHP, Ferrexpo—offer a counter-narrative. They show that Ukrainian companies can maintain public accountability even through war. This reinforces a key point: Ukraine is not monolithic. Governance quality varies by shareholder, sector, and corporate history. 5. So, Is Verevsky “Right”? The answer depends on perspective: Legally He might have acted within the boundaries of Luxembourg and WSE regulations. Courts and regulators have not ruled the process unlawful yet. From a governance and reputation standpoint The delisting and squeeze-out will be remembered as heavy-handed, timed to a crisis, and unfriendly to minority investors—even if would be recognised by courts as entirely legal. Strategically The move may benefit Verevsky as an owner, but it comes at a high reputational cost for both Kernel and the broader Ukrainian investment landscape. In global markets, perception often matters as much as law. 6. What Should Foreign Investors Take Away? The Kernel case underscores a critical point: When investing in Ukrainian companies—especially majority-controlled groups—financial statements are not enough. Investor security depends on understanding the character, incentives, and track record of the controlling shareholder. This is where business intelligence and governance due diligence become indispensable. A robust pre-investment review should assess: • shareholder behaviour across past transactions; • litigation history and corporate-governance patterns; • regulatory relationships; • ultimate-beneficial-owner structures; • red-flag patterns such as related-party transactions or opaque restructurings. In the Kernel’s case, sentiment among investors shows that even technically lawful actions can generate lasting reputational damage. Conclusion Kernel’s squeeze-out dispute is more than a disagreement between a majority owner and minority shareholders. It is a diagnostic moment revealing how fragile investor confidence can be—and how much corporate governance behaviour shapes Ukraine’s broader investment narrative. As Ukraine prepares for unprecedented foreign capital inflows during reconstruction, maintaining global trust will be essential. Companies like Astarta, MHP, and Ferrexpo show that Ukrainian issuers can uphold international standards even under wartime pressure. Kernel, in contrast, has highlighted the risks when majority power is used aggressively. For foreign funds, the lesson is clear: Business intelligence is no longer optional—it is the foundation of safe investment in post-war Ukraine. Entrypoint remains available to support investors with market intelligence, governance assessments, and risk advisory across Ukraine and the wider region.

The running controversy around Enwell Energy plc (formerly Regal Petroleum) is a striking reminder that the global reach of sanctions and opaque corporate ownership can challenge even well-regulated, foreign-listed companies. Through its Ukrainian subsidiaries, a UK-listed company Enwell operated several producing and exploration licences in the Poltava and Kharkiv regions, at one point ranking among Ukraine’s top private gas producers. The group was associated with Smart Energy, part of Smart Holding, whose founder Vadym Novynskyi was placed under Ukrainian sanctions in December 2022. In May 2023, the State Geology and Subsoil Service of Ukraine suspended Enwell’s licences at two fields, citing the presence of a sanctioned ultimate beneficial owner. Enwell countered that Novynskyi had relinquished his beneficial ownership and that the company’s governance was fully compliant with UK and Ukrainian disclosure requirements. By late 2024, the regulator extended suspension to three additional licences — effectively freezing Enwell’s production. Smart Energy estimated losses exceeding 78 million m³ of gas and tens of millions of hryvnias in lost tax revenues. A UK-Listed Company in a Sanctions Dispute Despite operating in Ukraine, Enwell is incorporated and listed in London, is regulated by the UK Financial Conduct Authority, and trades on AIM under the ticker ENW. Its shareholder base is dominated by Smart Holding Cy Ltd. (82.65%). The remaining float is spread among several institutional and retail investors, including Pope Asset Management LLC (6.95%, £6 million), Hargreaves Lansdown Asset Management Ltd. (0.21%, £175 k), HSBC Global Asset Management (UK) Ltd. (0.19%, £160 k), Clearstream Banking SA (0.17%, £138 k), and smaller holdings by IG Markets, Bourse Direct, Stichting DeGiro, Alpha Services & Holdings SA, and iDealing.com Ltd. That structure created a legal paradox: while Ukraine sanctioned a Russian-linked oligarch, the enforcement hit a UK-registered company with international minority shareholders — highlighting the blurred line between national security policy and investor protection. From AIM Admission to Arbitration Regal Petroleum, Enwell’s predecessor, joined AIM in September 2002, placing shares at 60 pence with Evolution Beeson Gregory Limited as its nominated adviser. Later placings were handled by Mirabaud Securities Limited, and legal support has involved Squire Patton Boggs (UK) LLP and Ukrainian counsel such as Asters. The company’s early listing history, complex ownership transitions, and heavy concentration of shares in a single group already signalled elevated governance risk — the kind that a proactive investor or analyst could have identified through robust business-intelligence due diligence. In August 2025, Enwell confirmed that it had initiated arbitration proceedings against Ukraine under the UK–Ukraine Bilateral Investment Treaty, reportedly with the International Centre for Settlement of Investment Disputes (ICSID). The case argues that licence suspensions deprived the company of its assets without fair compensation. Lessons for Investors Enwell’s experience demonstrates that: Regulatory and political exposure can override formal compliance. Ultimate beneficial ownership remains a decisive factor in sanctions enforcement. Minority investors can suffer collateral damage when governance structures concentrate control. Transparent BI and sanctions screening should be embedded in pre-investment analysis — even for companies listed on major exchanges. A well-executed business-intelligence review could have flagged these structural risks long before they crystallised into losses and arbitration. For global investors, the Enwell case underlines that due diligence cannot stop at audited financials or London listings; it must extend into ownership chains, local political context, and regulatory sentiment. The Takeaway Business intelligence is not an add-on — it is a strategic safeguard. In frontier and emerging markets alike, understanding who ultimately controls assets, how local authorities interpret sanctions, and where political lines intersect with commercial law is vital. For investors looking to navigate the FSU energy sector or similar high-risk jurisdictions, Entrypoint’s regional intelligence and vetting expertise provide the depth of context needed to anticipate—not merely react to—events like the Enwell Energy saga.

Ukraine holds extensive proven reserves of critical and strategic raw materials essential for the global energy transition, European industrial independence, and defence supply chains. According to the European Union study, Ukraine has deposits of 22 out of the 34 minerals it lists as critical, including lithium, titanium, graphite, zirconium, rare earth elements (REEs), and uranium. The sector of critical raw materials for battery and modern technology manufacturing is one of the fastest-growing sectors. Ukraine can integrate into international and regional value chains, diversifying and de-risking global demand. For our subscribers, we compiled several key aspects of it: Ukraine's reserves of critical and strategic raw materials Who owns Ukraine’s strategic subsoils Towards better transparency and straightforward regulation Ukraine's strategic resources: available investment arrangements Why is Risk Advisory and Business Intelligence for investors needed Strategic investors for Ukraine’s CRMs To learn more, subscribe to the Black Hawk Business Intelligence Review

Ukrainian fintech startup Fintech Farm has announced the launch of a new digital bank, Tezbank, in Uzbekistan, in partnership with local Hamkorbank, one of the country’s notable financial institutions. The launch positions Tezbank as a fully digital financial platform designed to bring modern banking services to Uzbekistan’s fast-growing, young, and mobile-first population. Fintech Farm was founded in 2020 by Former Privat Bank manager Dmytro Dubilet, former KPMG M&A head Mykola Bezkrovnyi, and Oleksandr Vityaz, owner of cloud service Corezoid. This marks Fintech Farm’s fifth international market after Azerbaijan, Kyrgyzstan, India, and Vietnam — a remarkable regional expansion for a company that began in Ukraine just a few years ago. Founded by a team behind Ukraine’s successful Monobank project, Fintech Farm has attracted over USD 20 million in international investment, including from strategic fintech investors, as reported by Forbes Ukraine. Fintech Farm’s international projects have shown impressive growth metrics. In Azerbaijan, its flagship Leobank already serves more than 1.3 million clients, becoming one of the fastest-growing neobanks in the South Caucasus. In Vietnam, Liobank reported record transaction volumes and user engagement. In India, the company’s latest venture, Roarbank, launched in early 2025, aims to capture the country’s booming digital lending and SME segments, leveraging lessons from earlier markets. Together, these results underline Fintech Farm’s operational agility and capacity to replicate success across diverse regulatory and consumer environments. However, Fintech Farm’s rapid ascent is not without controversy. Some founders and their close associates may have been previously connected to oligarch Ihor Kolomoyskyi and to schemes surrounding the alleged multibillion-dollar siphoning of funds from PrivatBank, Ukraine’s largest commercial bank, before its nationalisation. Investigations by the High Court of London and multiple Ukrainian outlets have connected Dmytro Dubilet to a circle of individuals involved in questionable transactions at PrivatBank. Adding to these concerns, Dmytro Dubilet’s father, who served as a senior manager at PrivatBank, has been formally accused by Ukraine’s National Anti-Corruption Bureau (NABU) of involvement in the embezzlement of over UAH 9.2 billion alongside Kolomoyskyi, and is now believed to be evading Ukrainian law enforcement in Israel. While Fintech Farm’s expansion underscores Ukraine’s entrepreneurial capacity and growing regional influence in fintech innovation, the group’s ownership background and prior associations warrant continued attention — particularly as they gain access to new banking systems abroad. For Uzbekistan, the Tezbank launch represents an ambitious step toward digital transformation. For risk analysts, it’s also a case study in how post-PrivatBank networks from Ukraine are reshaping regional finance under new banners.

Ukrainian titanium producer Velta , owned by businessman Andriy Brodskyi , has announced plans to build a USD 250 million titanium cluster in the Dnipropetrovsk region. The initiative is positioned as the first flagship project under the U.S.–Ukraine critical raw materials agreement signed in 2025. The cluster would integrate ilmenite mining, titanium dioxide processing, and additive manufacturing applications , signaling a shift toward higher-value industrial chains. In September, U.S. officials visited Ukraine to review potential mineral assets under the pact, including deposits of lithium, titanium, zirconium, and rare earths . Against this backdrop, Velta’s project is being framed as a strategic test case for whether U.S. partnership can anchor transparent development in Ukraine’s extractives sector. Risks remain significant. Velta has a complex operational history, with previous attempts to scale production disrupted by war, logistics, and financing constraints. The USD 250 million investment target will require either foreign equity partners or substantial credit guarantees, both uncertain in the current environment. In addition, titanium remains a dual-use material closely monitored in global supply chains, raising regulatory and export-control considerations. If successful, the cluster could reposition Ukraine as a strategic supplier of titanium products for Western industries, reducing dependence on Russian and Chinese sources. But if financing or governance falters, it risks becoming another stalled flagship project in Ukraine’s resource sector. For foreign investors, the case highlights both the opportunity of entering Ukraine’s mineral value chain and the structural risks of execution, transparency, and wartime disruption .

Lithium — the “white gold” of the energy transition — has long been a sensitive resource in Ukraine. For many years, access to strategic deposits was arranged through non-transparent schemes. People close to political power attempted to capture lithium and other mineral assets through insider arrangements rather than open competition. Such practices undermined public trust and discouraged responsible investors. Today, the picture looks different. On 27 August 2025, the Cabinet of Ministers announced an open competition for the development of the Dobra lithium deposit in the Kirovograd region. This strategic site will be allocated under a transparent procedure, marking a decisive step away from backroom deals toward EU-aligned standards. The change also fits into a broader new context. In 2025, Ukraine and the United States signed a cooperation agreement on critical raw materials, laying the groundwork for joint projects in lithium and other resources. A clean, transparent tender process is the best way to turn that agreement into a real investment and technological partnerships. While past attempts to monopolise resources cast a long shadow, today’s open call is a milestone. If implemented credibly, Ukraine’s mining sector could shift from a story of insider capture to one of transparency, rule of law, and international cooperation. 👉 Entrypoint is preparing a broader Business Intelligence overview of Ukraine’s mineral sector, covering its history and future. It will soon become available to subscribers through our website entrypointgroup.com .

Ukraine is about to enter a new regulatory era with the upcoming implementation of its Law on Lobbying . For the first time, lobbying will be legalised and regulated, aligning Ukraine’s political-business interface closer to EU and US standards —but not without growing pains. Under the new framework, any attempts to influence legislation, regulations, or state decision-making on behalf of business or interest groups must be declared through a newly established register of lobbyists , to be launched by the National Agency on Corruption Prevention (NACP). This is a substantial change in a country where informal networks and opaque influence often substituted for transparent policy advocacy. Why It Matters In Brussels and Washington, lobbying is recognised, disclosed, and—crucially—regulated. Ukraine, in contrast, has operated in a grey zone, where unofficial influence channels were often more effective than public consultation. Formalising lobbying not only enhances accountability but also reduces reputational risks for foreign investors operating in the country. The new law: Defines who can and cannot lobby (e.g. foreign agents, media outlets, and public servants are excluded). Imposes administrative fines for undeclared lobbying—up to ₴170,000 (~$4,200). Requires businesses and lobbyists to file declarations of lobbying efforts and identify beneficiaries. Business Concerns and Delays Despite good intentions, implementation risks are real. Leading business associations, including the American Chamber of Commerce and European Business Association, have urged Parliament to delay sanctions and improve legal clarity , citing legal uncertainty and regulatory overload. Many fear that inadvertent non-compliance could trigger penalties, particularly for companies engaged in routine advocacy without prior experience in regulated lobbying environments. Moreover, while the NACP promises clear guidance and a user-friendly portal, technical and procedural ambiguities remain , especially for multinational companies and law firms representing clients in policy matters. Comparing Models: EU and US In the US , the Lobbying Disclosure Act (LDA) mandates public registration and quarterly reports for all paid lobbying activities targeting federal officials. Non-compliance can lead to civil penalties and reputational damage. The EU Transparency Register operates on a voluntary basis, but is de facto mandatory for engaging with European Commission officials. It covers interest representation across a wide policy spectrum. Ukraine’s model borrows elements from both but goes further by threatening enforcement from day one —despite limited institutional experience. What’s Next Over the next six months, Ukraine’s public and private sectors will navigate a steep learning curve . If implemented constructively, this reform could decrease corruption risks, level the playing field , and support better governance. But if executed poorly or used punitively, it could discourage legitimate advocacy and stifle dialogue. For international stakeholders, now is the time to: Map exposure to lobbying-related activities across local teams and consultants. Engage with the NACP to clarify grey zones and ensure compliance readiness. Monitor legal amendments , as business pressure may yet reshape the rollout.