Zelenskyy’s United24: the platform collected USD 337 million, but the lawyers found weak points

It’s been a year since the United24 fundraising platform started operating in Ukraine as an initiative of President Volodymyr Zelenskyy. Thanks to world-famous ambassadors including Barbra Streisand, Timothy Snyder, Richard Branson, and well-known projects such as the Army of Drones, Artemsil, Azovstal bracelets, the platform has collected more than USD 337 million. Donating is simple: from anywhere in the world to the chosen direction – in two clicks, as millions of people and businesses from 110 countries have done.

The platform is being developed by the well-known public figure Yaroslava Gres together with the Ministry of Digital Transformation, and the top auditing company Deloitte is checking the expenses. These are two key reasons for the platform’s 100 percent success rate.

We support the United24 initiative, which can become an example of responsible use of funds. Meanwhile, in order to increase the transparency of accounts of the platform, we have conducted an independent research and must pay attention to the existing risks.

United24: backstage

United24 has raised more than USD 337 million in three directions — defense, medical aid, and reconstruction. On the anniversary of its founding, the platform was expanded to two more areas – education and humanitarian demining.

However, United24 operates 11 accounts to which USD 790 million have been received — twice as much as reported on the platform. Most of the accounts are active — they are filled, and funds are used. Nonetheless, not all of them are audited by Deloitte and some of them have risks in the committees’ activities. In particular, there is controlled composition of committees for the distribution of funds, which means that members are selected from among the employees of ministries – or there are no such committees at all.

Accounts of six ministries are not presented on the platform. But formally, the government has categorized them as “official accounts for donations in support of Ukraine within the framework of United24”. This distorts the perception of benefactors regarding the publicity and accountability of the use of funds. Therefore, it is advisable to either clearly separate United24 accounts or ensure full publicity and international audit of any and all accounts involved.

We have analyzed the activities of the committees and the procedures for using funds in each direction.

How funds from the UNITED24 platform have been used

Defense. The defense account has collected more than UAH 25.5 billion (about USD 700 million), which is almost 90 percent of United24’s funds. The account was active before the launch of the platform and even then, it collected UAH 16.7 billion (USD 460 million). After the launch of United24 — another UAH 8.8 billion have been collected, reports on which are published on the platform.

Meanwhile, the Ministry of Defense explains that they only approve the use of funds for state bodies (including for the National Police, the Border Guard, the National Guard, the State Emergency Service, the Special Communications and Information Protection Service, the Defense Intelligence, the Special Transport Service, the National Security and Defense Council, and the Security Service), but they do not have copies of the reports and are not responsible for filling the United24 portal.

The committee for the distribution of funds in the direction of defense has not been created, a separate procedure has not been approved.

Reconstruction. Over the year, UAH 631 million was raised in the Destroyed Property and Infrastructure Restoration Fund, which is managed by the Ministry of Reconstruction.

More than UAH 465 million from the Fund has been allocated for the reconstruction of 18 high-rise buildings in the Kyiv region. Despite the fact that the Kyiv Regional State Administration, as the recipient of funds, has already conducted almost all tenders, not a single cent from the account has been used as of early May. International organizations, in particular UNDP, will be involved in the support of procurement procedures. This will help restore housing as transparently as possible and minimize corruption risks.

The direction of reconstruction is one of the most transparent. The committee took into account the proposals of the Institute of Legislative Ideas – all meetings are broadcast, funding applications and minutes are made public. This gives the public an opportunity to see how and where funds are directed.

Medical aid. The account of the Ministry of Health has collected more than UAH 1.4 billion. It was among the first to be followed by reports with the publication of protocols. However, protocol data is unsystematized.

The funds have been spent on materials, medical and rehabilitation equipment, sanitary transport, as well as on the reconstruction of Chernihiv Hospital No. 3 and the oncology center. The latter should be handled by the Ministry of Reconstruction, not the Ministry of Health.

Education. Before May 5, 2023, the account was off the platform. During the year, it was possible to attract only UAH 47,000, which has not been distributed.

Immediately after the announcement, right on the anniversary of the platform, it was possible to attract USD 1 million for the restoration of the educational institution in Buzova. This emphasizes that the platform, where funds are collected for specific purposes, has more credibility and wider opportunities to attract partners than in individual ministries.

The Ministry of Education has a fund distribution committee, but the website does not contain any information about the amount of funds collected and their use.

Humanitarian demining. The manager of the account is the Ministry of Economy. The account was opened in April 2023. Currently, there is no approved procedure for the use of funds, which is a negative trend and an anti-example for the transparency of the platform. After all, the principle “first collect funds, and then decide how to use them” will not contribute to the accountability of the use of funds.

Funds outside the platform

Another six accounts of the ministries – the Ministry of Social Policy, the Ministry of Digital Transformation, the Ministry of Veterans Affairs, the Ministry of Reintegration, the Ministry of Youth and Sports, and the Ministry of Culture and Information Policy – are not represented on the United24 platform. The total amount of funds collected by them is more than UAH 1 billion.

Accounts must be separated from the platform, or conditions of accountability and transparency must be introduced. A valid example is the account of the Ministry of Digital Transformation, which received more than UAH 380 million and used UAH 37.7 million to combat information threats. Funds were distributed through a committee with the participation of representatives of the National Agency on Corruption Prevention, state bodies and the publicity, and information on the use and balance of funds is public. The Ministry considered the recommendations of the Institute of Legislative Ideas and initiated changes to its own procedure for the use of funds to develop reporting and publicizing of information.

The Ministry of Social Policy, on whose account more than UAH 780 million has been collected, also publishes information on the use of funds. UAH 704 million has been used, including for the purchase of food, medicine, evacuation of the population, provision of temporary accommodation for citizens, payments to IDPs (part of the funds were directed through the Ministry of Reintegration to meet the needs of evacuees). In the future, the Ministry of Social Policy plans to use the funds from the account for decompression for military personnel and their families and expensive prosthetics.

The ones to have collected the least funds are the Ministry of Culture and Information Policy (UAH 5.4 million), the Ministry of Youth and Sports (UAH 15 thousand), and the Ministry of Veterans Affairs collected nothing at all (0 UAH) outside the platform. None of the ministries publishes information about committees, receipt of funds, and applications for funding.

What has to be changed

See the seven key conditions introduced by experts at the presentation of the transparency of reconstruction using the example of United24.

1. Clear separation of fundraising accounts on the United24 platform and regular ministry accounts.

This minimizes reputational risks for the operation of the United24 platform.

2. Independent committees for funds distribution.

This provides for clear requirements and criteria for members of committees, their transparent formation, inclusion of public representatives, and resolution of conflicts of interest.

3. Prioritization criteria.

It is necessary to avoid chaotic reconstruction and to prevent a situation where a lot of minor things are financed, but not the main ones.

4. Elimination of duplication of directions for different account managers.

It should be agreed upon that funds for the reconstruction of damaged/destroyed real estate are allocated from the account of the Ministry of Infrastructure.

5. Clear procedures for committees.

There should be an exhaustive list of reasons for deciding on the allocation of funding or refusal, deadlines for considering applications and deadlines for transferring funds.

6. Application of the DREAM system (Digital Restoration Ecosystem for Accounable Management).

18 houses that will be rebuilt in the Kyiv region have already been included in the DREAM system. The use of the ecosystem should become mandatory for all reconstruction objects from the moment of the official start of its work.

7. Transparent procedures and reporting.

This covers publishing the agenda of meetings at committees, applications, protocols and decisions, ensuring public access, and conducting online broadcasts of such meetings.

Law No. 8433 adopted by the Verkhovna Rada on the publication of charitable donation funds on the official websites of fund managers is a good opportunity to take into account the recommendations and consolidate the principles of transparency in practice.

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