26 August, 20:11
In late August, Femida published my analysis under the title Why the operators of fraudulent call centres remain outside Ukraine's Criminal Code. It answered an arithmetical question: why a nationwide police operation that shut down 1,794 fully equipped operator workstations ended with twenty-six notices of suspicion.
Stated plainly, without the catalogue of article numbers, the answer comes down to this. Ukraine's Criminal Code, like any code in the continental legal tradition, is built around the event. It requires a specific offender, a specific injured person, a specific sum and a specific episode that can be reconstructed in court from beginning to end. That is a sound construction. It has worked for centuries, and it protects people from arbitrary prosecution.
A call centre operates on an entirely different logic. There is no event there, there is a flow. An operator makes two hundred calls a shift, the overwhelming majority of which lead nowhere, and only the statistics of that flow turn into money. A single call is nothing in itself, and yet the entire job consists of nothing but such calls. The law demands a point, and what stands in front of it is a conveyor belt, where every point has to be proved separately, with a separate person, a separate complaint and a separate examination in court. Multiply that procedure by seventeen hundred operators and you get a workload no prosecution service on earth could carry.
Article 255, on participation in a criminal organisation, makes no such demand: it punishes the fact of membership in a structure, and no injured party is required at all. But it demands something else. To prove an organisation, investigators must establish its apex, because without a leader and a single common plan the organisation does not legally exist. In other words, that provision forces you to move upwards, towards the owners of the floor and towards those who pay for protection, which is precisely why it is applied in careful doses, in a handful of showcase cases.
And there is no third path in the Code. A provision describing what an operator actually does, meaning systematic participation in a structure created for the industrial-scale deception of people by telephone, simply does not exist in Ukrainian criminal law. Not "poorly drafted", not "rarely used", but non-existent.
That was the analysis of the gap. Now about what has fallen into that gap, because that is where the real problem lies, and next to it the stolen millions look like small change.
Over the past decade Ukraine has built a fully functioning system of vocational education that nobody planned and nobody licensed. Every year it graduates tens of thousands of qualified specialists in a single discipline: breaking another person's mind at a distance. It has admissions, a curriculum, practical training, examinations, a career ladder and a graduation ceremony. There is only one thing it does not have. A list of its graduates.
The call centre as a full-cycle educational institution
We are used to saying "office", "shop", "outfit", and that vocabulary throws off our perspective. Look at this structure not as a criminal gang but as an educational establishment, and everything falls into place.
Start with admissions. The Geneva-based Global Initiative Against Transnational Organized Crime records that recruiters work openly, through social media and job websites, and that the preferred age for a candidate runs from fifteen to twenty-eight. Members of a parliamentary inquiry estimated the share of teenagers and young adults between fourteen and twenty as significant. The target audience is therefore exactly the same as a college's: a school-leaver with no experience, no profession and an urgent need for money. The admissions board does not ask for a diploma. It asks whether you are afraid of talking to strangers.
Then the curriculum. A newcomer does not go straight to "closing". He starts on cold-calling the base, works under a mentor, learns the script by heart and reviews recordings of his own failed calls with that mentor. This is a perfectly conventional craft-guild pedagogy: master, apprentice, analysis of mistakes. In three months a person covers ground that a legitimate profession would take a year to cover.
Then the examination. There is only one, and it is entirely unambiguous: the first client who transfers money. Until that moment you are a student, afterwards you are a specialist. And not everyone passes it, which is the whole point. The system has a filter, and it filters out not those who speak badly but those who could not take the final step. The selection is therefore made on willingness to cross a line, not on ability.
Then the regime. The same study describes these premises as follows: cameras, access control with electronic keys, hired physical security, phones confiscated at the door, constant monitoring of the employee's screen, and polygraph tests used to identify police officers, journalists and potential informants. Picture an educational institution with that kind of security perimeter. This is no longer a college, it is a closed specialist school, and the graduate leaves it carrying not only a skill but an ingrained habit of operating under secrecy, which is itself a separate and highly valuable asset to the next employer.
There is a career ladder, and it is transparent: cold-calling, "closing", retention of the client after the first payment, then shift administrator, then head of a unit. And the incentive structure is arranged so that nobody can retain any illusions about the nature of the work. In a case that Eurojust closed together with the Ukrainian police, the file records that a rank-and-file employee received up to seven per cent of the sum extracted, and that for an episode above one hundred thousand euros he was promised a cash bonus or a car. That is not a salary. A salary is paid for hours worked regardless of outcome. Here a person takes a share of the haul, which means he knows exactly what has been taken and from whom.
What is actually taught there
And here we come to the heart of the matter, to the content of the curriculum.
It is commonly assumed that operators are trained in sales technique. This is untrue, and it is precisely this misunderstanding that keeps the subject from being read as a threat. Sales technique can be learned in a week. The three months are spent on something else.
People are trained to strip away another person's psychological safeguards, one by one. Fear, because fear is the easiest thing to steer. Loneliness, because a lonely person will keep talking and will volunteer everything you need. Deference to office, because "security officer at your bank" sounds like authority, and authority is not argued with. Shame, because someone ashamed to admit a mistake will hand over a second sum to conceal the first. Greed, because the entire investment legend rests on it.
But the central discipline is none of these. What is really taught there is to treat one's own compassion as a technical obstacle. Not some abstract "don't think about the victim", but a very concrete operation: when the person on the other end starts crying, you do not end the call, you move to the next block of the script. Tears have their own entry in that manual, exactly like objections in ordinary sales. And a person who has performed that operation fifteen hundred times has not changed a behaviour. She has changed a default setting.
Now compare. Every legitimate profession that works with human vulnerability necessarily has a deontology. Doctors, psychologists, social workers, lawyers, clergy, investigators. All of them are trained to see weakness in another person, because without that ability they could not do the job at all. And all of them are simultaneously trained where the line is beyond which that ability may not be used. Each of these professions has an oath or a code, a disciplinary body and a mechanism for withdrawing the right to practise. A licence can be revoked, a member can be struck off, a name can be kept out of the register.
The call centre teaches the same discipline with the sign reversed. It too trains people to read vulnerability from half a sentence, only it trains them to exploit it. This is deontology inside out, complete, coherent and consolidated by practice. And a mechanism for withdrawing the right to practise cannot exist here in principle, because the profession itself does not legally exist. No profession, no disbarment.
The diploma issued by the state
And now the most uncomfortable part. The graduation certificate is not issued to these people by the owner of the office. It is issued by the state.
When 1,794 operators pass through a case file as witnesses, each of them receives from the state something far more valuable than money. He receives official confirmation that he did nothing. No conviction, no record, no entry anywhere at all. In the documents these people appear not as fraudsters but as persons who gave explanations. Legally impeccable citizens.
That is the diploma. And it is genuine, issued by an authorised body, and it cannot be revoked, because formally nobody ever issued it.
Now take that graduate and look at him through the eyes of an ordinary HR manager. Twenty-two years old, eighteen months of experience in telephone sales, speaks beautifully, holds a conversation, unfazed by rejection, good at handling objections, used to targets and to performance-based pay. The ideal candidate. Not a single red flag. The HR manager physically has nowhere to look up what this person was actually doing, because no such place exists.
And here the state displays its priorities with unmatched candour. It is building a register of money mules. The cyber police are drafting a dedicated offence for those who hand over their bank cards, the National Bank is compiling a database of suspicious accounts, banks are capping peer-to-peer transfers. So the state does keep a register of bank cards, and it is investing resources in doing so.
A register of people trained to break other people it does not keep, and does not intend to.
How many of them there are, and what that means
The same GI-TOC report estimates employment in the sector at roughly sixty thousand people. To make that figure tangible, the researchers offer a benchmark: it is around two thirds of the entire headcount of the country's banking sector. Centres operate in all twenty-four regions, and victims have been recorded in at least twenty-nine countries.
Sixty thousand is not the total number of people who have passed through this system. It is a snapshot of current employment. And staff turnover there is high, because the work burns a person out within a year or eighteen months: constant stress, night shifts aligned to European time zones, the security regime, the pressure of targets. People leave and new ones are hired in their place, meaning the system functions as a school with an annual intake and an annual graduation. How many people it has produced in total over the decade of its existence, nobody can say, and nobody can say precisely because no records are kept. But it is certainly not sixty thousand. It is considerably more.
And now consider what every successful police operation actually does to this system.
Ninety-four offices raided. Equipment, cars and gold seized. Twenty-six people charged. And more than seventeen hundred trained individuals walked out onto the street with their qualifications fully intact and without a single mark in a single document. Within a week some of them will be sitting one floor up under a new sign, and the rest will go out onto the open market.
From the industry's point of view, in other words, the destruction of an office is not a loss. It is a graduation. The state ran a mass commencement ceremony with its own hands and did not even count how many people walked out of it.
The market for the product
The question that remains is a simple one: who needs sixty thousand people with this qualification.
Begin with the quality of the goods, because that is what decides everything here. The value of these cadres does not lie in the ability to talk. Nobody is impressed by the ability to talk. The value lies in the fact that the threshold has already been crossed. An ordinary person has to be worked on for a long time before she will agree to rob the elderly every evening, and it is on that grinding down that a recruiter spends most of his time and takes most of his risk, because every attempt is a potential report to the police. Here there is nothing to grind down. These people crossed their threshold as a matter of routine, with a lunch break and a New Year's office party. They have also been polygraphed, drilled in operational secrecy, and accustomed to working for a percentage and keeping quiet about where they work.
From the point of view of any recruiting structure, this is not raw material. It is a finished product with a warranty.
And the principal solvent buyer for that product today is a single one, and it sits three hundred kilometres away. For several years now Russia has been building its recruitment pipelines on exactly the same logic: a contact base, cold calls, a script, walking the interlocutor towards a required action, payment on confirmed result. The same methodology, the same cycle, the same performance metrics. The only thing that changes is what comes out at the end. Instead of a transfer to a mule account there will be a relay cabinet set on fire, a targeting report on a recruitment centre, a photograph taken at a facility, or a package delivered to a designated point.
A person who has walked a stranger to a required action fifteen hundred times does not need the methodology explained. She needs a new script and a rate. Retraining takes one evening.
Behind Russia in the queue stand quieter buyers: political campaign headquarters ahead of every election, paid-blogger networks, crypto operations, grey debt collectors. But they are competing for this resource against someone who pays more, does not haggle and does not ask for references.
What can be done
If we accept that what we are dealing with is not a scattering of individual offences but an educational system, then the response has to match, which means working with a profession rather than with events.
First and cheapest: keep records. The state already holds, in its own case files, name-by-name lists of everyone who sat at those desks. These people have been questioned, identified, their passport details entered into protocols. Building a register of persons who worked in structures found by a court to be fraudulent is technically no harder than the money-mule register already under construction. The obstacle is not capability. It is that nobody has set the task.
Second: a ban on the profession. Article 55 of the Code allows a court to deprive a person of the right to hold certain positions or engage in certain activities. A ban on work involving telephone sales, the processing of personal data and financial intermediation, for up to five years, visible to employers through a register, strikes exactly where it should: at the convertibility of the acquired skill. A custodial sentence for a twenty-year-old returns nothing to the victim, while adding one further course to his education, this time a prison one, with new contacts and a new specialisation.
Third: the recruiters. Article 304, on drawing minors into criminal activity, carries up to five years and was written precisely for the person who signs up fifteen-year-olds for an "office". Mass prosecutions under it against call centre recruiters are nowhere to be heard of. Yet the recruiter is the admissions board of this system, and without him it would not run for a single day.
And fourth, which nobody discusses at all. The state needs an answer to the question of what to do with a person who has come out of this school. Not how to punish her, but where to place her. Because a proportion of these twenty-year-olds will walk out on their own the moment they see any other exit, and for exactly those people Ukrainian law already provides part six of Article 255. It releases from criminal liability a participant in a criminal organisation who was not its organiser and who, before being served with a notice of suspicion, comes forward about his own involvement and actively assists in exposing the structure. The provision has been in force since 2020 and requires no legislative change whatsoever. It is simply never offered to the rank and file, because it works in one direction only, upwards, and upwards, as we have established, is where investigations do not go.
The country's largest educational institution
The conclusion is this, and it is not a comfortable one.
For ten years a system of vocational training has been operating on Ukrainian territory that is comparable in scale to a major economic sector and that has no equivalent in Europe in its single field of specialisation. It teaches people to strip away the psychological safeguards of others, and to strip away their own. It has selection by willingness to cross a line, a career ladder, a regime of secrecy, and an incentive system built on a share of the haul.
The state knows it exists. Periodically it storms the campuses, reports the seized Rolexes and Bentleys, and sends the students home with a clean record each. It keeps no list of graduates, withdraws no right to practise, and leaves the admissions board untouched.
And as long as this curious partnership continues, the principal beneficiary of Ukraine's educational system remains whoever comes for these people first. He is already standing in the queue, and he will not even have to pay the tuition.