Procedural Posture and Background

This document is a Complaint filed by Spectrum UA Credit LLC and Geno Pikulik (Plaintiffs) against Ukraine, the National Bank of Ukraine (NBU), the Deposit Guarantee Fund (DGF), and the Security Service of Ukraine (SSU) in the United States District Court for the District of Columbia. The Plaintiffs assert subject matter jurisdiction under the Foreign Sovereign Immunities Act (FSIA), alleging that the Defendants are not entitled to sovereign immunity due to their engagement in commercial activities that caused a direct effect in the United States, as well as the expropriation of property in violation of international law.

Factual Allegations and Legal Claims

The Plaintiffs allege a coordinated campaign by the Defendants to unlawfully expropriate their investments in Ukraine. Specifically, the Plaintiffs contend that Spectrum Ukraine, a wholly-owned subsidiary of Spectrum UA Credit LLC, lawfully acquired substantial distressed assets and loan portfolios through DGF-administered auctions. Following allegedly unfounded assertions regarding the citizenship of Spectrum's ultimate beneficial owners, the NBU arbitrarily revoked Spectrum Ukraine's financial services license without affording due process or an opportunity to cure the alleged defects. Subsequently, the DGF unilaterally nullified the asset acquisitions and initiated proceedings to reclaim the assets while imposing substantial financial penalties.

The Complaint asserts multiple causes of action, including tortious interference with property rights, tortious interference with contracts, intentional interference with prospective economic advantage, conversion, unjust enrichment, and civil conspiracy. Furthermore, the Plaintiffs allege that the Defendants' actions constitute a discriminatory expropriation of valuable property without due process or prompt, adequate, and effective compensation, in direct violation of the bilateral investment treaty between the United States and Ukraine.

Relief Sought

The Plaintiffs seek a declaratory judgment affirming the validity of the assignment of membership interests under California law and confirming Geno Pikulik as the sole lawful owner of Spectrum UA Credit LLC. Additionally, the Plaintiffs demand compensatory and consequential damages in excess of $127 million, representing the total value of the expropriated assets and lost investment opportunities, alongside pre-judgment interest and any further relief deemed appropriate by the Court.