Putin’s Top Central Banker Accused of Complicity in War Crimes

Coalition alleges that Russian central bankers, finance minister, and banking executives are complicit in crimes against humanity and war crimes in occupied Kherson Oblast.

16 July 2025 –  LexCollective, with support from B4Ukraine and Ukrainian Legal Advisory Group (ULAG), filed a landmark Article 15 Communication with the Office of the Prosecutor of the International Criminal Court (ICC) in The Hague yesterday, highlighting the alleged roles of senior office holders from Russia’s Central Bank, the Ministry of Finance, Russian-controlled banks, and the Kherson occupation administration in systematic atrocity crimes against Ukrainian civilians in occupied Kherson Oblast.

Unprecedented Legal Action Against Financial Enablers

The Communication represents the first comprehensive legal filing specifically targeting the financial architecture of Russia’s illegal occupation. It alleges that Russia's Central Bank Governor and Deputy Governor, the Russian Minister of Finance, the head of the Kherson Russian-installed military-civil administration, and executives from Russian-controlled banks are complicit in the crime against humanity of persecution and war crimes, including wilfully causing great suffering to Ukrainian civilians, pillaging and appropriation of property, and compelling participation in military operations.

Systematic “Russification” Campaign

Following Russia’s invasion of Ukraine on 24 February 2022, Russian authorities launched an aggressive “russification” campaign designed to erase Ukrainian national, political, and cultural identity in occupied territories. The Communication provides evidence of how Russia weaponised the economic and financial systems and conditioned access to essential services—medical care, emergency services, banking, and education—on obtaining Russian passports and pledging allegiance to Russia.

Ukrainian civilians who refused faced severe reprisals including deportation, arbitrary detention, imprisonment, torture, property confiscation, forced displacement, and other physical and psychological violence. This systematic campaign of persecution targeted Ukrainians explicitly for refusing to abandon their Ukrainian identity.

“Rublisation” as Economic Warfare

Central to Russia’s strategy was the implementation of coercive economic and financial policies, like “rublisation.” Russian occupation authorities deliberately devalued and prohibited circulation of the Ukrainian hryvnia—a symbol of national sovereignty—forcibly replacing it with the Russian ruble. Local Kherson residents were compelled to register in the Russian tax system and open accounts at designated Russian-controlled banks to access salaries, pensions, or employment.

Through these measures, Russia dominated all aspects of Ukrainian civilians’ daily lives while effectively forcing them to financially contribute to the war against their own country. Ukrainian bank branches were systematically appropriated, seized, and replaced by Russian-controlled banks licensed by Russia’s Central Bank. These banks began their operations in occupied Kherson Oblast soon after Russia’s invasion.

Coalition Response

“This Communication exposes how Russia turned the banking system into an instrument of illegal occupation,” said Nadia Volkova, Founder & Director of ULAG. “To weaponise financial services, Russia and its enablers violated fundamental principles of international humanitarian law and have committed a plethora of international crimes, such as persecution, illegal detention and torture, deportation, etc., while causing immense suffering to Ukrainian civilians in Kherson Oblast who simply sought to maintain their livelihoods and identity.”

Kristin Rosella, Co-Executive Director at LexCollective, emphasised the broader implications: “This case demonstrates how modern armed conflicts extend beyond the traditional battlefields into economic and financial spheres. The systematic nature of Russia’s atrocities—orchestrated at the highest levels of Russian financial and political authority—demands accountability.”

Nezir Sinani, Executive Director of B4Ukraine highlighted the urgency of the case: “International crimes do not take place in a vacuum, but rather, are facilitated by a vast network of actors. The continued impunity of the Russian central bankers and other banking executives enables the expansion of the persecution and war crimes.”

Next Steps

The Communication provides detailed, credible evidence of how Russian financial authorities, occupation forces, and banking executives are central to developing and implementing Russia’s persecutory policies in occupied Kherson Oblast. By documenting Russia’s aggressive russification campaign and coercive economic and financial measures, the Communication establishes a reasonable basis for the ICC’s OTP to proceed with investigating the alleged international crimes. The case builds upon the OTP’s ongoing investigation into the situation in Ukraine and could lead to formal charges against the identified individuals.

Filing and Supporting Organisations

LexCollective is a global network of legal minds utilising innovative legal tools and collaborative strategies to address interconnected human rights issues faced by communities worldwide. Through its Alliance, Academy, and Lab initiatives, LexCollective bridges access to justice by connecting communities with experts, mentoring lawyers, and developing legal solutions.

B4Ukraine is a global coalition of civil society organisations driven by a common goal: to block access to the economic resources behind Russian aggression. It aims to restore the peace and security of Ukraine by asking responsible businesses to respect human rights in word and in deed and exit Russia to stop funding the war in Ukraine.

Ukrainian Legal Advisory Group (ULAG) ULAG is a Ukrainian NGO with lawyers, analysts, and advocates focusing on conflict-related justice and protection of human rights. It brings strategic litigation in domestic, foreign, and international jurisdictions, conducts legal analysis, advocacy, and training, and documents international crimes. Through these activities, ULAG helps victims and survivors of grave crimes in Ukraine and around the world to restore their rights and hold perpetrators to account.

Additionally, the Coalition was supported by research and investigative partners:

KSE Institute is an analytical center at the Kyiv School of Economics. It specializes in analytics, consulting, research, develops strategies and recommendations for supporting a strong and innovative economy of Ukraine. KSE Institute is a leading think tank in Central and Eastern Europe working in the area of sanctions and geoeconomics. The institute is also actively involved in assessing the damages caused by the Russian war of aggression and contributes to efforts to secure war reparations and funding for Ukraine’s reconstruction and recovery.

FIND is a UK non-profit that investigates the actors, technologies, and systems that enable and profit from human rights abuses, international crimes, and environmental harm. It uses finely tuned investigative skills and research tools to put critical information into the hands of communities fighting to secure justice. Its work feeds into legal proceedings, regulatory action, investigative reporting and advocacy campaigns.

Read the full summary of Article 15 Communication and a Q&A:
https://www.lexcollective.com/icc-art-15-2025