SAP Changes? Ukrainian Anti-Corruption Architecture

March 21, 2018

The Special Anti-Corruption Prosecutor Nazar Kholodnitsky, it is rumoured, is about to resign.

He is currently in Brussels with NABU Chief Artem Sytnyk holding a series of meeting until the weekend.

It is no secret that there has been some friction between the SAP and NABU leadership, with NABU accusing Mr Kholodnitsky of being slow to sign off on high profile investigations and case submissions.  Mr Kholodnitsky in turn has been critical of NABU and its engagement in PR and politics, notwithstanding investigative shortcomings.

Perhaps both have a point – at least to some degree.

There are however several rumours circulating relating to the reason for any possible resignation by Mr Kholodnitsky.

The first, and neatest by way of institutional relationships and avoiding ugly headlines, is that of Mr Kholodnitsky’s ill-health.  It is widely understood that he has heart problems apparently diagnosed during a short hospitalisation at the end of 2017.

Well maybe.  No doubt there are pressures of office, (and from external offices) that are not conducive to a heart condition.

There are also rumours, without much by way of substantiation, that when Yuri Lutsenko eventually leaves his role as Prosecutor General (and that is likely to be well before the presidential election campaign officially begins to facilitate his return to politics as a politician), Mr Kholodnitsky has been maneuvering to become Prosecutor General.  A matter of lobbying friendly foreign capitals while discussing the anti-corruption fight in private meetings.

A somewhat less convincing reason for resignation perhaps, when considering the mechanics of being so appointed – Presidenital nomination and Verkhovna Rada approval.  Neither would be particularly keen.

However, there is also the matter of Mr Kholodnitsky’s office being bugged for several weeks – the listening device apparently attached to a fish tank near his desk.  What was said, who heard it, how has that been disseminated around the elite of the Ukrainian political elite, and to what end?

Was there enough for coercion or blackmail to provide for a more “understanding” line toward the elite?  Was there enough to force a resignation?  Is resignation and falling upon his own sword a moral preference to being coerced by the elite for Mr Kholodnitsky?

It appears that the bugging of his office was actually carried out by NABU, with the able assistance of Volodymyr Hutsulyak.  Mr Hutsulyak is understood to be the “head of the Kononenko-Granovsky department” – a non-entity unofficially charged with dealing with/influencing/interfering in particularly sensitive political cases for The Bankova.

Exactly who within NABU was doing the listening will perhaps become known in the fullness of time.  Presumably the only way such eavesdropping could have been authorised was because NABU suspected the SAP of collusion with the elite political class.  All else would fall outside of NABU’s remit.

Whatever the case, many will see a prima facie case of a situational alliance between either NABU and the Prosecutor General to replace Mr Kholodnitsky as the SAP. or between NABU and The Bankova more directly.  Neither may be true, but perceptions are a personal thing.

Yet others will be concerned that friction between the two existing parts of the anti-corruption structure is effectively weakening both – an undesirable situation in the continuing absence of a dedicated anti-corruption court.

Whatever the case, should Mr Kholodnitsky resign (or otherwise be forced out) a new public competition for his position will be required by law, perhaps further slowing anti-corruption prosecutions as that process occurs.

As usual, who would fulfill his role on an acting basis is unclear – presumably it will be either the very political Prosecutor General Yuri Lutsenko, or Mr Kholodnitsky’s direct subordinate Deputy SAP, Maksym Hryshchuk (with whom it is rumoured NABU have a reasonable relationship).

A cynical reader knows which one to expect.

In the meantime, all await a decision by Mr Kholodnitsky on his future.


Odessaoblenergo – A good buy?

March 19, 2018

On 19th March 2018 the State Property Fund (SPF) seemingly canceled the sale of State shares in Odessaolenergo and Sumyoblenergo.

An apparent last minute decision with Odessaolbenergo shares due for sale via the Ukrainian exchange on 20th March, and Sumyoblenergo scheduled to be sold on 30th March.

In August 2017 the 25% of Odessaoblenergo and Sumyoblenergo for sale were given the starting price of UAH 631.3 million and UAH 370.32 million respectively, and managed to attract no bidders whatsoever.

It was thus decided to drastically reduce the price and in February 2018 the SPF announced the sale at auction of the 25% stake in Odesaoblenergo at a starting price of UAH 149.081 million, and Sumyoblenergo for UAH 106.275 million – about 25% of the original valuation/starting bid price in the case of Odessaoblenergo, and about 30% of the opening bid price for Sumyoblenergo.

Not for the first time have SPF auctions seen zero interest due to questionable initial valuations – the still unsold Odessa Port Side is a prime example.

The reason given for this last minute decision to cancel the bids is not for a lack of bidders, but that the sale of the State 25% shares should occur via the recently amended/updated laws on privatisation.

So, a reader may ponder, are there in fact bidders now that the opening bid prices have been so dramatically reduced?

Is Odessaoblenergo any more attractive as an asset now that UAH 631.3 million has dropped to UAH 149.081 million?

In the case of Odessaoblenergo, almost 70% is owned by Arthur Altbergs, Valts Vigants, Vilis Dambins, Oleg Sizerman and Marina Yaroslavskaya – mostly German and Latvian citizens.

However for many, many years, the locals of Odessa have been steadfast in stating that these people are in fact a front for VS Energy.  VS Energy has shares in numerous Ukrainian businesses and is owned by (former Russian Duma Deputy) Alexandr Babakov.

Mr Babakov most recently in the local news headlines in Odessa when the roof of a hotel on Fransuski Boulevard collapsed of which he is also reported to be the ultimate owner behind the facade of others.

Ergo any purchaser of the 25% State shares for sale will be, according to steadfast local gossip, shareholders with Mr Babakov – and all that may entail.

In July 2017 an entry appeared pondering RAB tariffs and their use and misuse in the proposed application to Oblastenergos across the nation.

The misuse of the tariffs will relate significantly to the valuation of assets – click the above link for detail.

Naturally in order to prepare for privatisation, Odessaoblenergo assets were necessarily valued by the SPF.  They were however valued at almost 25 less than that of the proposed RAB tariff valuation of UAH 15.4 billion by the energy regulator.

How can the SFS value Odessaoblenergo assets for privatisation at 25 times less than the NKRECU regulator that is involved with RAB tariffs?

How, if at all, does this affect the attractiveness (or otherwise) of the Odessaolbenergo 25% share the State is selling?

Some very simple (perhaps too simple) math – The proposed RAB tariff rate per the above link from July 2017 was 12.5%.  At the time of writing that has not changed as far as the NKRECU regulator is concerned.

So to the numbers – 12.5% annual tariff return on assets of UAH 15.4 billion provides for approximately UAH 1.925 billion.

Whomever purchases the 25% State shares will therefore be entitled to 25% of that – UAH 481 million.

However, those shareholders will only have the right to withdraw 50% of that as dividends – the other 50% to be reinvested in infrastructure upgrade per the RAB requirements.

Thus whomever purchases the 25% State share will actually only be able to take out UAH 241 million as cash profit.

UAH 241 million dividend withdrawal for a UAH 149 purchase price (if sold at the opening bid price) on year 1 of an investment?  Almost double your money in a year?

Further, this before the RAB tariffs actually provide the Oblenergos with the ability to forecast and collect some very attractive profits under that system year on year.

No wonder this time the privatisation has not been canceled through a lack of potential bidders!


A consistent and disproportionate 2% – Ukraine

March 18, 2018

Much is said about corruption in Ukraine – and rightly so.  Corruption is a national security issue.  It undermines the effectiveness and capabilities the military and the military industrial complex.  It undermines the economy.  It is pervasive among the political class and the institutions of State.  It ultimately undermines to confidence and standard of life of the population.  National resilience, as referred to in Article 3 of the Washington Treaty is thus also undermined, posing a significant issue for Ukrainian aspirations regarding the NATO alliance.

Ergo it is hardly surprising that corruption ranks highly as a major problem for the Ukrainian constituency in every opinion poll.  It is also no surprise that tackling corruption is an issue that repeatedly and consistently tops the agendas of all external partners of Ukraine – be those partners State or international organisation.  After all corruption in Ukraine and its effects are hardly confined or constrained by the limitations of its sovereign borders.  Ukrainian corruption and any associated organised criminality is also a matter of security for its immediate neighbours – and beyond.

However, when pondering such issues, defining corruption is often a matter of personal perception and certainly there is a lack of consistency when defining corruption domestically, regionally or internationally.

Should any corruption definition be limited to phrases such as “the abuse of entrusted power for personal gain” – whether that gain be on a grand or petty scale, or political in its grotesque or subtle warping of procedures, policies, allocation of resources, subsidies et al in order to maintain or increase political power or wealth?

Where does favouritism, cronyism and nepotism fit into corruption, particularly in its current political system and management of Ukrainian State Owned Enterprises?

What about passive or active corruption?

How does supply, or indeed demand drive Ukrainian corruption?

What of advocacy and lobbying?  Is one man’s advocate another man’s lobbyist, and at what point do either cross into the realms of corruption?

How has the fairly successful decentralisation reform, moving power and budgets to local governance, affected the distribution of corruption across the nation?  Is it more evenly spread, or does the “big figure” corruption at the centre remain constant while new or rejuvenated corruption thrive under decentralisation – be it grand, petty, or political in nature?  Has decentralisation reduced corruption?  If so, has it done so evenly, or are some regions getting better while others are getting worse?

Is the State and/or oligarchy capture of large spheres of the Ukrainian economy a driver, or at least corrosive constant, when it comes to maintaining core corruption levels?

It is no secret that the oligarchs are connected to corruption via tax scams, the backing of political parties and the “sponsoring” or “renting” of politicians thus influencing legislation and policy while sucking greedily upon the teat of government subsidies and inserting “no added value” into supply chains within the areas of the economy they monopolise.

The World Bank figures put forward the argument that 2% of Ukrainian companies are politically connected.  Politically connected being set within the parameters of “An influential political person is a person entrusted with important public functions, including leading politicians and party officials, senior government, judicial or military officials, and senior management of state-owned enterprises.

That 2% of politically connected Ukrainian companies however, are responsible for 20% of company turnover across the entirety of Ukraine – or so sayeth the World Bank.

Further, that 2% of politically connected Ukrainian companies own almost 29% of assets owned by all Ukrainian companies.

Interestingly, that 2% and the related percentages have remained a fairly consistent between 2006 and 2016.  That would suggest, prima facie, that there has been little appetite or opportunity for the captured spheres of the economy to expand into others under the oligarchy.  Preferential asset acquisition across other economic arenas either not forthcoming or simply deemed unworthy of the effort?

Indeed, behind these numbers the WB claims that 40% of the turnover in energy, transport and mining, notwithstanding roughly 25% of turnover and assets in agriculture (mostly grain production and export) is achieved by politically connected companies .

Unsurprisingly it seems that politically connected companies are 61% less likely to be subjected to audit.

Throw into the mix the widely recognised fact that SOEs are far less efficient than other companies and there is a wider and unanswered question as to whether that is due to the fact that they are politically connected companies with an understanding that profitability is not dependent upon making a profit.  State subsidies, supply chain mismanagement, and loss write-offs being the source of profitability.

If including favouritism, cronyism and nepotism in any definition of corruption, rather than labeling them ethical issues, then loyalty and political favour clearly take precedence over ability and competency.  How greatly that impacts upon profitability probably depends upon whose profitability is in question – that of the company or the individuals behind the curtain.

The next 10 years of WB statistics will be interesting, for they (presuming consistent methodology) will display the effects of prozorro procurement, the closure or privatisation of thousands of SOEs, and attempts to introduce/broaden the market players within the currently captured spheres of the economy – or not.  In short it will display the effects of anti-corruption policy rather than the operational wins and losses of the anti-corruption institutions so often in the headlines.


Poroshenko “EU Membership is a matter of years, not decades” – It isn’t

March 17, 2018

In a recent interview with a German media group President Poroshenko stated “I am absolutely sure that Ukraine will be accepted into the European Union. And it will be a matter of years, not decades. It is unlikely that any other country will be more enthusiastic about Europe than Ukraine.”

There is a lot to ponder from those three short sentences.

Putting aside on-going EU frustration over deliberately slow reform, particularly with regard to the genuine independence of institutions and regulators, and notwithstanding the obvious and deliberate glacial pace of completing the anti-corruption architecture in which so much EU (and others) energy and money has been invested, and despite already being far behind the implementation schedule of the Association Agreement (and DCFTA) with the EU, there are internal and structural issues within the EU that simply prevent Ukrainian membership within “a matter of years“.

Among the internal issues, disregarding any particular Member State objections and/or unwillingness for their own sovereign reasons (agriculture and France for example) there are wider EU institutional issues.

The European Parliament is not an institution that expands when new members join.  The number of MEPs is dictated on a per capita basis, with a minimum and maximum number per Member State among the finite number of MEP seats.

Ukraine with a population of 40+ million would make it one of the largest nations and by extension have among the most MEPs.

To facilitate that, many nations would have to surrender MEP seats to accommodate a large influx of Ukrainian MEPs.

Should that ever occur, there will be a perceptional (and perhaps ideological) shift from a Centre-Club Mediterranean centre of power/mindset, to that of a Centre-Eastern European centre of power/mindset.  Not something that Italy, Spain, France et al may look forward to, even if perhaps Poland, Slovakia, Slovenia, Czech Rep, Romania, Bulgaria and Hungary might.

Rather than concentrating on Berlin, at the very least it will be necessary for Ukraine to have Paris and Madrid “on side” when it comes to getting in.  Serious and prolonged work on and with those capitals would have to begin now, not only to remove or mitigate any objections, but to actually have them advocate the welcoming of Ukraine within the EU.  To achieve that will take more than “a matter years” – and that means convincing more than a few governments current and future.

At its current momentum, one that is missing agreed implementation timelines, it will take Ukraine about another 10 – 15 years to meet all of its Association Agreement obligations.  Those obligations fall short of the requirements of the 31 Chapters of the Aquis Communautaire that are to be met prior to membership occurring by any aspirant.

However, “a matter of years” will be put into context in the immanent future by the EU, not via the rhetoric of any political leaders, but by the setting of its next budget.  This will make EU intent unambiguously clear regarding any Ukrainian membership in “a matter of years”, for accepting a new Member State is a costly affair – very costly – and therefore must be budgeted for.

The EU budget is set over a 7 year period.  It can take between a year and 18 months to negotiate and agree among Member States.  The current EU budget period ends in 2020.  Preliminary negotiations for the 7 year budget that follows will begin to get fraught by May 2018.  The last EU budget of Euro 960 billion over its duration, took almost 18 months to agree.

The next EU budget will be a budget without UK contributions.  Thus those contributions will have to be offset by a combination of cuts/savings and an increase of contributions by Member States – and there is a limit (1.23% of EU GNI) and 10% leveraging via financial instruments when it comes to increases.  The line items within the budget will make clear the EU common budget priorities – migration, rule of law, the upholding of EU values in budgetary distribution etc.

To be blunt in such an environment, to budget for the accession of a nation as large as Ukraine seems highly unlikely – and thus it would be very surprising to see that accession budgeted for.

If it is not budgeted for then President Poroshenko’s “a matter of years” becomes not only a matter of at least another 7 years from the end 2020, but it is then dependent upon negotiations that will begin sometime around 2025 when the next EU budget will be negotiated and within which funds for Ukrainian accession would have to be set.  Therefore it will probably be 2 full budgetary cycles to insure all funds are received and available to achieve it.

Thus logic dictates it will be “a matter decades and not a matter of years” based purely upon the abilities and priorities dictated by EU budgetary cycles – this notwithstanding any sovereign politics of a Member States that may create additional hurdles.

As always it is a question of following the money.

If the EU budget is absent the significant and allocated costs of Ukrainian accession, the political rhetoric simply will not become reality – even if by some miracle Ukraine can fully meet its existing obligations to the EU and surpass them to meet the requirements of the Aquis Communautaire to mitigate political arguments against its membership.


The PGO goes after Savchenko

March 15, 2018

Recently an entry appeared relating to the arrest of Volodymyr Ruban and allegations of plots to assassinate leading political figures associated with the leadership of the national security and defence institutions of Ukraine.

It concluded with several obvious questions one of which was – “That would clearly have to involve more than just Mr Ruban – and thus is a reader is to expect further arrests relating to the assassination plot?”

Since that entry and the arrest of Mr Ruban, the SBU has conducted over two dozen raids around Ukraine, allegedly seizing propaganda, weapons, explosives and other subversive materials.

Attending Mr Ruban’s court remand hearing was Verkhovna Rada MP Nadia Savchenko, most famous for her capture and detention within the temporarily occupied territories, and later within Russia.  With both Mr Ruban and Ms Savchenko widely believed to be creatures of the loathsome Viktor Medvechuk, her attendance at the court hearing was perhaps to be expected.

It may also be related to the two having an input, officially, nefariously, or otherwise, in the swapping of captives over which Mr Medvedchuk has significant influence as interlocutor between presidents Poroshenko and Putin.

Such is the populist nature of Yulia Tymoshenko that Ms Savchenko was placed Number 1 on the Batkivshchyna Party list, above Ms Tymoshenko herself.  As the blog stated at the time, and prior to Ms Savchenko’s release, a military heroine does not automatically transform into a competent or viable politician –  that not withstanding the fact that the ego of Ms Tymoshenko and Ms Savchenko would never last within the same political party structure.

So indeed has that come to pass.  Upon her release Ms Savchenko has proven to be a dismal politician, and the inevitable departure from Ms Tymoshenko swiftly occurred too.  Ms Savchenko then appears to have become a political creature of Mr Medvedchuk (if she wasn’t already – which she probably was).

Whatever the case, whether through Mr Medvedchuk or not, Mr Ruban and Ms Savchenko know each other – if for no other reason than a common interest in facilitating the swaps of captives.

On 12th March the SBU requested Ms Savchenko attend for questioning.  Ms Savchenko however had left Ukraine at 0400 hours that day for Europe on the morning of that request.

She has subsequently returned.

Should a reader want to know what Ms Savchenko was doing whilst in the EU, she states – “In Europe, these 3 days, I managed to testify to the European legal and judicial authorities against Poroshenko’s corruption, against the criminality of our power and on political persecution.”  Whether that testimony related to Mr Ruban or an impending sense of personal doom is unclear.

However the Ides of March for Ms Savchenko have clearly arrived.

15th March witnessed Prosecutor General call upon the Verkhovna Rada to strip Ms Savchenko of her parliamentary immunity.

The claims are such that there is indisputable evidence of her collusion and conspiracy in an attempt to bring down the Verkhovna Rada and those within – quite literally.

Some rather stunning allegations were made.  “The investigation has solid evidence that Nadezhda Savchenko personally planned and personally instructed how to conduct a terrorist attack in this room, destroying two government and guest boxes with military grenades, smashing the dome of the Verkhovna Rada with automatic weapons and destroying those who survived by submachine guns. today I, as the Prosecutor General of Ukraine, will submit to the Verkhovna Rada a proposal to bring to criminal responsibility, detention and arrest of People’s Deputy Savchenko.

Presumably there is either SIGINT, or witness testimony, or both, to support such serious allegations.

It is without doubt that Ms Savchenko holds the current Ukrainian leadership and many of her colleagues in contempt.  To be blunt, the feeling is probably mutual.  Following her SBU interview of 15th March she stated “I know that now there are many military people who hear me, who agree that a military coup in Ukraine is quite an expected and probably quite a right event.

She has also displayed a course of action that calls into question any regard for the security services of Ukraine by occasionally ignoring protocols, and thus drawing SBU angst, regarding undisclosed visits to the temporarily occupied territories.

Without dwelling upon the pre-existing personal issues of Ms Savchenko prior to her captivity, clearly detention within the occupied territories, and subsequently Russia, will have a psychological effect – particularly so as there is no question that she will have been subjected to various forms of interrogation – and various degrees of severity of interrogation with regard to method and application too.

Who would fully trust anybody that claimed they were unchanged having emerged from such an experience?

Clearly whatever the substance to the allegations made, Ms Savchenko can no longer remain a member of the Verkhovna Rada Committee on National Security and Defence until the matter is resolved.

It remains to be seen what will make it into the public domain.  It has become habit for the PGO or certain Ukrainian politicians to produce evidence in the (social) media long before any court case begins. The court of public opinion seemingly taking priority over the court of law with regard to evidence and its disclosure.

Regardless, there will be intense interest in what now follows, and not only domestically – for which foreign ambassador to Ukraine upon her release did not host, be photographed with, or (despite what may have been otherwise privately expressed) fail to publicly orate robust words of support for Ms Savchenko?

The fall of Ms Savchenko then, will have to be achieved under the gaze of many particularly sharp eyes.


Meanwhile in London…..

March 14, 2018

This is not an entry regarding what Prime Minister May had to say – or indeed did not say – relating to the latest Kremlin outrages in the UK.

Suffice to say what has overtly been said will fall well within the acceptable pain threshold and endurance of The Kremlin, especially as it was completely predictable and will no doubt be subject to reciprocity – albeit that reciprocity not necessarily entirely symmetrical in nature.

Perhaps the Prime Minister’s statement indicates but Round 1 of other actions yet to come over the following weeks and months – or perhaps what is unsaid may indicate a serious covert action of some sort.  However what was clearly notable from what was unsaid is that business relationships such as that between BP and Rosneft are effectively ring fenced from interference by Gov UK.

A less predictable and more asymmetrical response was far more likely to get the attention of The Kremlin.  What was publicly stated fell far short of that.

Thus there is little else to say that has not been said before – indeed that has not been said long ago:  “The policy and practice of the Russian government has always been to push forward its encroachments as fast and as far as the apathy or want of firmness of other Governments would allow it to go, but always to stop, and retire when it met with decided resistance” – Lord Palmerston circa 1858

Ergo from what has been announced, and what would have been anticipated by The Kremlin are unlikely to seriously force even the slightest consideration regarding a change of course from Moscow – unless further actions are yet to be announced, or covert actions taken that cannot be announced but are nevertheless implemented by the UK result in outcomes that go beyond Kremlin predictions.

However, while such headline grabbing events and oratory rightly take centre stage, other matters of interest for Ukraine are unfolding at the High Court of Justice in London relating to the former PrivatBank owners, a number of their subsidiaries and other interested parties.

The High Court has now ordered Rossyn Investing Corp., Milbert Ventures Inc and ZAO Ukrtransitservice Ltd, the structures associated with Igor Kolomoisky and Gennady Bogolyubov, to detail the information on transactions with Privatbank funds.

Unless the SAP manage to formally attached the Kroll investigation report into the PrivatBank shenanigans to the court documents, it may prove to be the case that whatever the UK High Court specifically requires producing will be all that ultimately falls into the public domain by way of transparency.

It now remains to be seen just what Rossyn Investing Corp., Milbert Ventures Inc and ZAO Ukrtransitservice Ltd submit to the court – but whatever that may be, it will be far more than they would otherwise wish to.

Something to keep an eye upon – even if not quite as exciting/frighting as Russia attempting to assassinate its traitors with a nerve agent in sleepy southern English counties.


A return to the State Bureau of Investigation

March 12, 2018

It was November 2017 when the newly created State Bureau of Investigation (SBI) was last mentioned by the blog – questioning both the integrity of the institution from the offset, and also its structure, processes, and resources to effectively get to work.

Truth be told, it has still not got to work.

However, that is not entirely the fault of the SBI “competition winning” leadership.

There is a small matter of national statute that requires amending to provide for public and transparent appointments to be made, rather than the current “external commission” that holds such powers of appointment.

The most recent plea to the Verkhovna Rada to make those legislative amendments was made on 5th February 2018 by the SBI Chief – who largely remains without any institutional structure or staff beyond vacancies on an Excel spreadsheet – and Excel spreadsheets are not capable, in and of themselves, of investigating serious criminality.

Nevertheless, 12th March 2018 witnessed the announcement of the first recruitment wave, 219 staff initially, of which 152 posts are for Bureau Investigators.  That small number, a reader may ponder, is sufficient for the SBI headquarters, for it is nowhere near sufficient to encompass the requirements of the regions.

Thus perhaps by the end of the summer there will be something approaching a central structure with bums on seats per an Excel spreadsheet – yet in all probability no meaningful regional presence, or as importantly, work being done.  Decentralisation of power and budgets, something of a policy success story for the current authorities, also no doubt equates to the decentralisation of corruption, criminality and abuse of office.  Regional presence is therefore an unquestionable requirement.

Suffice to say this investigative institution charged with the policing serious criminality of the elite (that which falls outside the remit of NABU) will not be functioning effectively until early 2019, perhaps mid to late 2019 – and thus post presidential and Verkhovna Rada elections – per the “delay for as long as possible” plan for any eventual anti-corruption court.

Therefore a reader should perhaps not hold their breath regarding the creation and functioning of the as yet unborn National Bureau of Financial Investigations.

Considering the gestation period for the State Bureau of Investigations, and its on-going difficult delivery and infancy, the NBFI will probably not be born, and will remain underdeveloped, until well into 2019 at the earliest, thus taking its first wobbly steps sometime in 2020.

Nevertheless, that fact that SBI recruitment has been announced at all, despite existing legislative hurdles to be removed, is perhaps something approaching progress?

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