Oleg Gorokhovsky and PrivatBank: how the ex-manager helped oligarch Kolomoiskyi embezzle billions

When the High Court of London delivered its landmark ruling on July 30, 2025, in the case of "PrivatBank" versus Ihor Kolomoiskyi and Hennadiy Boholyubov, the 490-page judgment also included references to secondary figures — managers who at various times facilitated the bank’s operations according to the majority shareholders’ wishes.

Among them is Oleg Gorokhovsky, later known as one of the key people in the monobank project. His name is mentioned in the High Court’s ruling 12 times, but behind this insignificant number of mentions lies Gorokhovsky’s role in what happened in "PrivatBank" before and after its nationalization, which the Ukrainian government was forced to undertake to save its economy from collapse.

The court immediately sets the framework: about 10% of "PrivatBank" shares before nationalization were held by minority board members — managers who "routinely followed the instructions" of the main shareholders. Among them, the court names Gorokhovsky. This is not a criminal qualification but an important marker: the managerial stratum acted in sync with the will of the owners. ("…they included … Mr. Gorokhovsky … It is clear to me that this is a fair description of the relationship…" (Among them was … Mr. Gorokhovsky … I clearly understand that this is a fair description of these relationships)», page 53, paragraph 198).

Then comes specificity. The court notes that from January 2014 until nationalization, Gorokhovsky was the deputy chairman of the board and supervised card and salary projects. In this role, he — a member of the credit committee — approved 129 loans that are key in the case. As of March 8, 2015, he owned 0.38% of the bank’s shares. This is dry statistics, but it fits into the picture: decisions on large loans were made by a narrow circle of managers closely tied to the will of the beneficiaries. ("…approved 129 of the Relevant Loans … held a 0.38% interest…" (…approved 129 of the relevant loans … held a 0.38% share…)», page 60, paragraph 229).

The sharpest — the period after the nationalization of the bank. The court writes that there is "plenty of evidence" of Gorokhovsky’s close contacts with Kolomoiskyi and his entourage even after the bank was transferred to the state: meetings in Geneva (February 2018), a joint lunch (June 2018), a flight to Dnipro on Kolomoiskyi’s private jet (June 2019). This is not a crime in itself, but for the court, these are bricks in the wall of evidence that the former owners’ influence on the "Privat" ecosystem remained. ("There is plenty of evidence that Mr Gorokhovsky continued to be in close contact… (There is plenty of evidence that Mr. Gorokhovsky continued to maintain close contacts…)», page 60, paragraph 230).

There are also episodes that inevitably raise questions. The court points to WhatsApp correspondence: not only personal messages (football, greetings) but also messages about bank matters where Gorokhovsky "incompetence" of the new management, this looks like an attempt to resolve the bank’s operational issues through the former owner — years after the nationalization. ("…seeking instructions … for the making of an unidentified payment…" (…seeking instructions … for making an unidentified payment…)», page 60, paragraph 231).

Finally, the court directly states: the communications provide "credible" grounds to believe that Gorokhovsky continued to participate in the joint business affairs of Kolomoiskyi and Bogolyubov at least until June 2019. Again, this is not a sentence, but a very harsh wording for a public document. ("There is credible evidence … that Mr Gorokhovsky continued to be involved in the joint business affairs… (There is credible evidence that Mr. Gorokhovsky continued to be involved in joint business affairs…)», page 60, paragraph 232).

The picture is complemented by procedural and statistical details. The court lists who and how many times participated in the "meetings" of the credit committee (formally — absentee decisions by protocol): Gorokhovsky counts 129 episodes.

Such a mass of approvals underscores his significance in the mechanics of approving large loans that the court recognized as part of the "recycling scheme" regarding the main defendants. ("…also present at most of what were recorded as approval meetings were … Mr. Gorokhovsky (129)…" (…also present at the majority of recorded approval meetings were … Mr. Gorokhovsky (129)…), page 81, paragraph 320).

What all this means — and what it doesn’t

Let’s discuss immediately: The High Court of London does not accuse Gorokhovsky of a crime. He is not a party to the process at all. The mentions are elements of the factual background: role in former management, participation in approving loans, the nature of relationships and communications after nationalization. To conclude "criminal activity" from this is incorrect and legally risky.

However, the court’s formulations are non-trivial. "Plenty of evidence" (numerous pieces of evidence), "seeking instructions," "credible evidence … involved in the joint business affairs" (credible evidence that [the person] was involved in joint business affairs) — for a public judicial act, these are notably strong expressions indicating the former owners’ influence and their informal communication channels with people from the former top management.

The court describes in detail how decisions on large loans were made by a narrow circle (including Gorokhovsky). After nationalization, part of this network retained horizontal ties with the former owners — this follows from the correspondence and meetings recorded by the court.

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If a manager (even already outside the bank) consults a former owner about a bank payment, it may indicate an attempt to influence the operational decisions of a state bank even after the ownership change. For regulators, this is a reason to ask questions — not about criminal guilt, but about ethics, compliance, and corporate governance. But after these questions, others should arise. And not with the regulator, but with law enforcement. But they did not arise with either the first or the second.

Why is he "still not in jail?"

Because this court decision is not about him: a criminal-legal assessment of Gorokhovsky’s actions is not given. The London court adjudicated the civil dispute of "PrivatBank" against Kolomoiskyi/Boholyubov and companies and issued a decision on their liability. For someone to "be jailed," there are needed:

• appropriate jurisdiction and process (criminal investigation of his actions);
• the composition of the crime, proven to the standard of "beyond a reasonable doubt";
• a connection between episodes and the norms of the criminal law of a particular country.

None of these elements regarding Gorokhovsky in this document were established. The court only states his role and connections, which are relevant to the picture of control and influence, but not equivalent to criminal guilt.

The decision of the High Court of London paints a complicated picture of influence and network connections around "PrivatBank." All this happened after the nationalization. Oleg Gorokhovsky’s name is very noticeable in this picture: approvals of disputed loans before 2016, contacts, and instructions after.

But between "mention in a court decision" and "criminal activity" is a huge legal distance. It can only be bridged by a separate process and evidence, which are absent in this document. That is why the correct question today is not "why is he not in jail?" but "will competent authorities examine the described episodes and communications for violations?".

And this is already a question not for the High Court of London and not for British justice. This is a question for Ukrainian law enforcement and the Ukrainian authorities, which control these very law enforcers. But it seems that after the public received an attractive picture with the arrest of Ihor Kolomoiskyi, the former owner of "PrivatBank," any investigation into what happened in the bank itself simply ceased.

Moreover – it seems that the case is simply being unraveled and waiting for the time when it will be properly forgotten. Although everyone understands that the theft of money from "PrivatBank" is not limited to the names Bogolyubov and Kolomoiskyi. But if you touch others, you will inevitably reach those who cannot be touched. Therefore, the question – "why is Gorokhovsky still not in jail?" – remains rhetorical. It will probably remain so.

P.S. The full decision of the High Court of London in the case Commercial Bank Privatbank-v-Kolomoiskyi and others here. All quotes and screenshots presented in the article fully correspond to the case materials.