Part I — Situation overview

On Monday, 12 October 2026, three decisions and announcements were made on a single day that affect the National Asset Recovery and Asset Protection Office (NVVH) and, more broadly, the institutional framework of accountability. According to 24.hu’s parliamentary coverage, the National Assembly unanimously, with 185 votes in favour, ordered the urgent — that is, under the Rules of Procedure, accelerated — debate of the regulation on the prevention of money laundering and on closed-ended capital funds. With 131 votes in favour, it referred the amendment of the state security and secret services law to exceptional procedure. It also put on its agenda that today, 13 October, it will elect the NVVH’s three vacant deputy presidents. In a closed session, the Committee on Justice and Constitutional Affairs proposed Károly Ötvös for the public finance post, Károly Árpád Gellért for the post responsible for indictments, and Tibor Dávid Terhes for the appellate post. Based on the CVs uploaded to parliament’s website, Telex writes that all three have worked on money-laundering and other economic crime cases. Károly Ötvös is an investigation leader at the Integrity Authority, was previously a criminal expert investigator at the National Tax and Customs Administration (NAV), and took part in the investigation against György Simonka, a former Fidesz MP. The two other candidates are prosecutors.

On the same day, the National Authority for Data Protection and Freedom of Information (NAIH) stated in an announcement that the data processing taking place on Fidesz’s site called “ÁVH-figyelő” (“ÁVH watch”), which lists the NVVH’s staff by name, violates almost all the principles of the EU General Data Protection Regulation (GDPR). The ÁVH (State Protection Authority) was the political police of the Rákosi era. Fidesz rejected the accusation. According to HVG, the NVVH stated that the court had found the detention of Miklós Seszták on 28 September lawful at both first and second instance, although according to his defence counsel it took place before the suspension of his parliamentary immunity appeared in the official gazette. Citing a freedom-of-information request by Transparency International Hungary (TIM), HVG also reported that of the 45 private equity funds that together received 1,500 billion forints of public money, 12 do not appear in the NAV’s register of beneficial owners, and neither do 9 of the 26 fund managers. Citing Telex, 24.hu reported that the Government’s bill on wealth investigations would extend to parents and children only if they share a household.

MIAK wrote about wealth investigations on 18 September, about the NVVH’s first cases on 28 September, and about protecting investigators’ names on 1 October, and it proposed the creation of a beneficial-ownership register as early as June. The new element of today’s situation is that the rules already exist or are before parliament, and the question is where gaps remain. In MIAK’s reading, the credibility of accountability is now decided not by intention but by three structural gaps: the selection of the leaders is not publicly reasoned, the ownership register is incomplete, and the wealth investigation leaves out family members who do not live together.

Part II — Grounding in the literature

Three sources provide the interpretive framework. In his book Controlling Corruption, Robert Klitgaard (an American economist, author of one of the foundational works on anti-corruption institutional design) describes the selection of agents — that is, of authority staff and leaders — as the first group of anti-corruption tools. In his view, trustworthiness must be screened alongside professional competence. The Hong Kong anti-corruption commission avoided being seen as a secret police through internal control and external advisory boards. In Corruption and Government, Susan Rose-Ackerman (professor of law and political science at Yale University, a researcher of the political economy of corruption) writes that, because money launderers adapt, anti-money-laundering rules only work if they are combined with improvements in the accountability of the state. In her view, democratic accountability also requires the financial interests of politicians’ family members to be made public. Article 5 of the European Union’s General Data Protection Regulation (GDPR) lays down the principles of purpose limitation and data minimisation. Under Article 86, personal data in official documents may be disclosed in the interest of public access, but only within the framework of the applicable law. Together the three sources say that the credibility of an office with strong powers comes from the verifiability of selection, the full visibility of money flows and the purpose-bound handling of data. The detailed treatment of the literature — author by author, with quotations — is in section 6.4 Literature in detail.

Part III — MIAK’s concrete proposal

MIAK proposes three measurable steps. The first concerns today’s leadership election, the second the anti-money-laundering bill debated under urgent procedure, and the third the detailed debate on the wealth investigation bill.

3.1 A leadership selection reasoned in writing and public recusal declarations at the NVVH (within 15 days of the election)

According to Magyar Nemzet, the applicants’ names were not made public, and the decision on whom to interview was also taken in closed session. According to Telex, the interviews were assisted by experts from independent civil society organisations, and most of them supported the candidates. Protecting the applicants’ names is justified; protecting the reasons for the decision is not. MIAK proposes that the Committee on Justice and Constitutional Affairs publish, within 15 days of the election, the selection criteria, the number of applicants per post, and a short written justification for each elected deputy president. The opinions of the participating civil society experts should also be published, with their consent. The reason why the public finance call was declared unsuccessful in August must also be stated precisely. The second element is the recusal declaration. At the Integrity Authority, Károly Ötvös led investigations concerning asset declarations and EU funds, and the two prosecutors handled high-priority economic cases. This is a professional strength, but also a conflict-of-interest risk. All three leaders should declare in which groups of cases and in cases relating to which bodies they will not take part in decision-making. The NVVH, in turn, should publish the number of recusals quarterly, with anonymised case numbers. The leaders’ names and CVs are public on grounds of public interest, and that is as it should be. The NAIH’s statement, however, made it clear that even public data cannot be processed for just any purpose. According to Klitgaard (see 6.4.1), what protected the Hong Kong commission from the image of a secret police was that, with internal and external controls, it was demonstrably “cleaner than clean”. That — not polemics — is the answer to the “ÁVH” label. The proposal applies programme points A10 (independent investigation office) and A6 (checks and balances). MIAK proposed a scored recruitment protocol for the office’s 150-strong staff on 31 August; the present proposal is its counterpart for the leaders.

3.2 A completeness test for the beneficial-ownership register of capital funds (in the text of the bill debated under urgent procedure, before the final vote; first report by 31 January 2027)

The beneficial owner is the natural person who is the real beneficiary behind a company or fund. According to HVG, every private equity fund should in principle already have been entered in the register, yet the NAV confirmed that it cannot see 12 funds and 9 fund managers. MBH Bank stated that for its own clients it had uploaded the documents on time every month. The gap is therefore either a failure to supply data or an error in the register. Both can be fixed, but only if they are measured. MIAK proposes that the National Assembly build four provisions into the bill debated under urgent procedure. First: the NAV should compare the register every month with all funds and fund managers listed in the supervisory register, and publish the completeness rate as well as the names of the defaulting funds and fund managers. These are legal persons; publishing their names does not involve personal data. Second: for any fund that received state capital or funds from a state development bank, its beneficial owners should be accessible to journalists and civil society organisations that demonstrate a legitimate interest. Third: a defaulting fund manager should not receive new state funding until it has remedied the omission, and should pay a fine. Fourth: the NAV and the Magyar Nemzeti Bank (MNB) should jointly clarify the case of the current 12 funds within 30 days. Since the law is being prepared under urgent procedure with a short debate, it should also contain a 12-month ex-post review obligation. According to Rose-Ackerman (see 6.4.2), money launderers adapt their methods to the rules, so regulation can only keep pace with them through continuous measurement. The proposal transfers the data logic of G22 (financial-stability monitoring) and A1 (public-money dashboard) to capital funds.

3.3 The circle of relatives according to the money-laundering definition, with risk-based extension (in the detailed debate on the wealth investigation bill)

According to 24.hu’s summary, the bill would extend to parents and children only if they share a household. Persons and companies to whom the politician transferred assets can, however, be included. The gap lies where the family member grows richer not from the politician but from a third party, for example from a contract financed with public money. The transfer rule does not catch this. According to the paper’s example, from the family of the former prime minister only the spouse’s enrichment could thus be investigated. Experts at Transparency International and K-Monitor consider the circle too narrow and the period under examination unclear. MIAK proposes that the law define the circle of relatives in the same way as anti-money-laundering regulation defines the close relatives of politically exposed persons: the spouse and domestic partner, the child and the child’s spouse or domestic partner, and the parent. Banks already monitor this circle separately today, so the two laws now being debated in parallel would use the same concept. The extension should not be automatic. The NAV should be allowed to investigate the enrichment of a relative not living in the same household only if risk analysis shows a concrete signal. Such a signal is the simultaneous presence of disproportionate enrichment and a state contract, subsidy or asset transfer linked to the politician’s term in office. The NAV should publish the criteria in advance. The law should also fix the comparison period. MIAK already made a proposal on the limits of the limitation period on 18 September, so here it only asks that the text not leave the question open. In line with the 18 September proposal, relatives’ names should not appear on any disclosure list. According to Rose-Ackerman (see 6.4.2), the financial interests of politicians’ family members are the minimum of democratic accountability. The risk analysis of programme point A3 also names concealment of assets through family members as the main weakness of the asset declaration system.

The three proposals are linked by one principle: a strong tool is credible if both its gaps and its limits are visible. The reasoning of the leadership selection makes the office transparent, the completeness test the money, and the narrowly drawn but risk-based circle of relatives the family. Meanwhile, publicity must not turn into listing. The GDPR’s purpose-limitation principle (see 6.4.3) applies in both directions: to the office’s data processing and to the data processing of those who criticise the office. MIAK rejects the listing of staff for political purposes, whichever side does it.

Part IV — Expected effects and risks

Dimension Expected effect Risk
Institutional credibility The reasons for the leadership selection and the recusals become verifiable; the “ÁVH” label can be refuted with facts Publishing the reasoning risks making unsuccessful applicants identifiable if it is not sufficiently aggregated
Public money and financial markets The ownership gap of publicly funded funds becomes measurable every month; default will have a price The compliance burden of capital funds grows; faulty data supply and system errors must be separated, otherwise even a blameless fund manager may be sanctioned
Rule of law and fundamental rights A uniform definition of relatives; extension starts only on a concrete signal The risk criteria may be too broad and may disproportionately affect the privacy of family members who are not public figures
Administrative capacity NAV and MNB data become linked According to the impact assessment, the wealth investigation may affect as many as five thousand people even so, with fifty new tax inspectors; the extension adds further strain on capacity
Political discourse Publicity is directed at decisions, not at persons The rejection of listing may look like a party-political stance if it is not applied symmetrically

The most important dilemma lies in proposal 3.3. The wider the circle of relatives, the harder it is to escape investigation, but the more people who are not themselves public figures come into the authority’s field of vision. MIAK therefore proposes not an automatic widening of the circle but the adoption of the established money-laundering definition and initiation tied to a concrete signal. The second dilemma is urgency. A fast-track debate is justified if the missing ownership data is a real money-laundering risk. Urgency, however, does not replace an impact assessment. The proposed 12-month review is precisely what offsets this gap.

Part V — Measurability and summary

5.1 What is worth following? (suggested KPIs)

MIAK suggests the following key performance indicators (KPIs). These are suggested indicators, not government commitments.

  • The reasoning of the leadership selection. Target: within 15 days of the election, the selection criteria, the number of applicants per post, the three written justifications and the recusal declarations are published; the NVVH’s first quarterly recusal report by 31 January 2027.

  • Completeness of the beneficial-ownership register. Baseline, based on TIM’s freedom-of-information request: of the 45 publicly funded funds, 33 are listed (73%); of the 26 fund managers, 17 (65%). Target: both rates at 100% by 31 March 2027, with monthly publication.

  • The circle of relatives in the final law. It is worth following whether the adopted text includes close relatives not living in the same household, the risk-based initiation condition and a fixed comparison period. It should also be followed whether the NAV’s monthly statistics report the number of extended investigations in a separate, aggregated line.

  • Consistency in data protection. It is worth following whether, beyond its statement, the NAIH opens proceedings in cases of listing for political purposes, and whether its decisions apply the same yardstick irrespective of party.

5.2 Summary

MIAK’s request is addressed to three recipients. To the Committee on Justice and Constitutional Affairs: written justification and recusal declarations within 15 days of today’s election. To the National Assembly: in the anti-money-laundering bill debated under urgent procedure, a monthly completeness test, sanctions on defaulting fund managers and a 12-month review; in the wealth investigation bill, a circle of relatives according to the money-laundering definition, with risk-based initiation and protection of names. To political actors: an end to the listing of the office’s staff, regardless of side.

Of MIAK’s foundational values, accountability and transparency are at stake here, and here the two also limit each other. Accountability demands that the path of assets, owners and decisions be traceable, including through family and fund-manager detours. Transparency, however, remains legitimate only if it is directed at the office’s decisions and the path of public money, not at the persons of individual staff members or of family members who are not public figures.

Part VI — Reasoning and further sources

6.1 Press framing by spectrum

In the public-affairs segment, 24.hu gave the broadest picture. In live parliamentary coverage it recorded the 185-vote decision and the change to the agenda, and in a separate article it presented the candidates’ CVs and the NAIH’s statement. In the Seszták case the paper highlighted the opinion of law professor Péter Hack, according to whom a suspicion of violating parliamentary immunity arises, and recalled that the NVVH’s president had spoken contradictorily about the time of the detention. In the title of its article on the wealth investigation, it listed by name who might escape the investigation. In the left-liberal segment, Telex presented the candidates’ professional backgrounds through their earlier cases, for example the Simonka case and the case of a security company linked to Lőrinc Mészáros, and highlighted the participation of civil society experts. Another Telex article reported that two men who had posed as NVVH staff and tried to defraud two billion forints had been arrested. HVG published the NVVH’s legal position on parliamentary immunity. The weekly’s subscription article contrasted the ownership gap of capital funds with the political slogan of “purgatory”. MIAK’s press monitor did not record a 444.hu article on the topic that day.

In the conservative segment, Magyar Nemzet consistently referred to the office in its headlines as the “new ÁVH”. It emphasised that the applicants’ names remained secret and that the protection of the two leaders costs 849 million forints a year, which is expected to rise with the three new deputy presidents. It also recalled that in August the Tisza majority had expected one of the leaders of Transparency International Hungary to take the president’s post. MIAK’s press monitor did not record a Mandiner article on the topic that day. In the economic segment, Portfolio wrote that day about two other proposals of the Immunity Committee, made in defamation cases. It quoted the committee’s chair: parliamentary immunity can be neither a privilege nor a political weapon. The common blind spot of the segments is that none of the outlets analysed the content of the anti-money-laundering bill debated under urgent procedure. The fact of the vote became news; the text did not.

6.2 Facts and data

The parliamentary decisions of 12 October (based on 24.hu’s live coverage):

Decision Vote Source
Urgent debate of the regulation on the prevention of money laundering and on closed-ended capital funds 185 in favour, unanimous 24.hu
Exceptional procedure for the amendment of the state security and secret services law 131 in favour 24.hu
Election of the NVVH’s deputy presidents put on the agenda: 13 October agenda amendment adopted 24.hu

The NVVH’s leadership:

Post Person Status Source
President Anna Unger elected on 28 August, six-year mandate from 1 September Telex, Magyar Nemzet
Deputy president for investigations Katalin Tasnády elected on 28 August Telex
Deputy president for public finance Károly Ötvös (Integrity Authority) committee proposal, vote on 13 October Telex, 24.hu
Deputy president responsible for indictments Károly Árpád Gellért (prosecutor) committee proposal, vote on 13 October Telex, 24.hu
Deputy president for appeals Tibor Dávid Terhes (prosecutor) committee proposal, vote on 13 October Telex, 24.hu

Private equity funds (TIM freedom-of-information request, HVG):

Item Value
Publicly funded private equity funds examined 45, together HUF 1,500 billion of public money
Funds missing from the register 12
Fund managers examined / missing 26 / 9
State money invested in the MBH Private Equity Fund HUF 166 billion

The wealth investigation bill (24.hu, citing Telex): the investigation is carried out by the NAV, and the accuracy of asset declarations is checked by the Integrity Authority; it would extend to parents and children only if they share a household, and not to mayors; persons to whom the politician transferred assets can be included; the NAV would publish the number of investigations monthly and would disclose the names of officials affected by a tax shortfall of at least 5 million forints; according to the impact assessment it may affect as many as five thousand people, at a cost of three billion forints over five years and with fifty new tax inspectors.

Timeline of the Seszták case (HVG): according to the defence counsel, the detention took place on 28 September at 10:54, and the resolution suspending parliamentary immunity appeared in the Hungarian Official Gazette (Magyar Közlöny) at 11:46. In the NVVH’s position, the suspension becomes final immediately upon its announcement by the presiding chair of the sitting, and publication in the gazette is subsequent information. The court accepted this at first and second instance.

6.3 Policy dimensions

  • Transparency and anti-corruption policy (programme points) — the NVVH’s leadership selection is a question of the independent investigation office (A10) and of checks and balances (A6); the circle of relatives is a known weakness of the publicity of asset declarations (A3); the completeness rate could be part of the public-money dashboard (A1);
  • Economy (programme points) — the supervision of private equity funds and the transparency of the financial system fall within financial-stability monitoring (G22);
  • Justice (programme points) — the Seszták case shows that the legislator can make the moment at which the suspension of parliamentary immunity takes effect unambiguous; this is a typical question for the constitutional stress test (I10), without contesting the court’s decision;
  • Digitalisation and AI regulation (programme points) — the difference between data public on grounds of public interest and data that may be freely listed is a practical case of the purpose-limitation principle of data governance (D18).

6.4 Literature in detail

6.4.1 Robert Klitgaard: Controlling Corruption

Klitgaard arranges the tools against corruption into five groups, and considers the selection of suitable agents to be the first. He warns that merit-based systems too readily assumed that clever people are also moral. In selection, therefore, trustworthiness must be screened alongside professional competence: through background checks, professional recruitment criteria and rules against favouritism. Of the first head of the Hong Kong anti-corruption commission he writes that he monitored the office’s own abuses through internal control and external advisory boards:

“These steps contributed both to the fact and the appearance of a “cleaner than clean” agency at the public’s service–and helped avoid the image of a second police force or even, with the ICAC’s strong powers, a secret police.”

In other words, these steps made the office both actually and visibly “cleaner than clean”, and helped it avoid appearing, because of its strong powers, as a second police force or a secret police. Today one side of the political debate openly compares the NVVH to the political police of the Rákosi era. According to Klitgaard’s lesson, the answer to this is not a list of the office’s staff, nor a counter-accusation, but verifiable selection and controls that the office applies to itself. The written justification and recusal declarations of proposal 3.1 make this “visibly clean” operation measurable.

📖 Source: Robert Klitgaard: Controlling Corruption (University of California Press, 1988)

6.4.2 Susan Rose-Ackerman: Corruption and Government

In the chapter on the role of the international community, Rose-Ackerman discusses action against money laundering separately. In her view, bribery is more attractive if the money is easy to take out and hide. Money launderers, moreover, respond to legal changes with new techniques: if financial institutions are expected to know the origin of money, they obscure that origin with further steps. Her assessment is sober: anti-money-laundering rules are only negative sanctions and have little effect on their own unless they are combined with direct improvements in government performance and accountability. In the chapter on political corruption she also writes about family ties. Trust between relatives and friends facilitates gifts that carry an unspoken quid pro quo, and on financial disclosure she writes:

“Nevertheless, at a minimum, disclosure of politicians’ financial interests and those of their families seems necessary for democratic accountability.”

In other words, the disclosure of the financial interests of politicians and their families is the minimum of democratic accountability. Two lessons follow for the Hungarian situation. For capital funds, missing ownership data is precisely the gap that money launderers exploit, which is why proposal 3.2 asks not for a one-off remedy but for monthly measurement. In the wealth investigation, the circle tied to a shared household leaves out the very network of relationships Rose-Ackerman writes about. Proposal 3.3 widens this circle, but entrusts it to an official investigation rather than to publicity, so that family members’ names remain protected.

📖 Source: Susan Rose-Ackerman: Corruption and Government — Causes, Consequences, and Reform (Cambridge University Press, 1999)

6.4.3 European Union: General Data Protection Regulation (GDPR)

Article 5 of Regulation (EU) 2016/679 lists the principles relating to the processing of personal data. Under the principle of purpose limitation, data shall be

“collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes”.

Under the principle of data minimisation, data must be relevant to the purpose and limited to what is necessary. Article 86 expressly allows personal data in official documents held by bodies performing public tasks to be disclosed in the interest of public access, but only within the framework of Union or Member State law. The NAIH’s statement of 12 October links these two rules: personal data that is public on grounds of public interest does not lose its character as personal data, so listing for political purposes violates both the purpose-limitation and the data-minimisation principles. The names and CVs of the NVVH’s leaders are therefore lawfully public. Collecting the same data on a list intended to intimidate, however, is a different purpose and falls under a different yardstick. Proposal 3.1 therefore makes the reasoning of decisions public, not the persons. Proposal 3.3, for its part, allows relatives’ data to be used exclusively for the purposes of an official investigation.

📖 Source: Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation, GDPR), Articles 5 and 86

6.5 International comparison

The closest model is the Hong Kong anti-corruption commission described in 6.4.1. It counterbalanced its strong powers with internal control applied to itself and with external advisory boards, and this made its operation visibly clean. At the NVVH, the recusal declarations of proposal 3.1 are a smaller-scale equivalent of this.

As regards beneficial-ownership registers, according to MIAK’s background knowledge the EU framework has changed in the meantime. A November 2022 judgment of the Court of Justice of the European Union invalidated general access to the registers open to anyone, because it restricted privacy disproportionately. The new EU anti-money-laundering regulation therefore provides for access by those demonstrating a legitimate interest, including journalists and civil society organisations. The second element of proposal 3.2 is aligned with this: it asks not for general publicity but for access tied to a demonstrated interest. The definition of the circle of relatives is also of EU origin: the anti-money-laundering directives treat the family members of politically exposed persons as a separate risk group, and the Hungarian anti-money-laundering act adopted this. The United Kingdom’s unexplained wealth order, introduced in 2017, may also extend to family members of politically exposed persons, but only with judicial authorisation and where there is a concrete suspicion. The blog draws these parallels not from the current press sources but from background knowledge.

Transparency and anti-corruption policy

  • A1 — Public-money dashboard
  • A3 — Publicity of asset declarations
  • A6 — Strengthening checks and balances
  • A10 — Independent Corruption Investigation Office (CPIB model)

Economy

  • G22 — Financial-stability monitoring and shadow-bank regulation

Justice

  • I10 — Constitutional “stress test”

Digitalisation and AI regulation

  • D18 — Data governance and open data intermediaries

Proposed new programme point: A monthly completeness test of the beneficial-ownership register for investment funds managing public money — for the Economy area.

6.7 List of sources

Press sources (MIAK press monitor, 13 October 2026 — topic 1):

Knowledge-base references (books):

  • 📖 Robert Klitgaard: Controlling Corruption
  • 📖 Susan Rose-Ackerman: Corruption and Government — Causes, Consequences, and Reform
  • 📖 Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR)

MIAK internal materials:

  • MIAK policy area: Transparency and anti-corruption policy (background material)
  • MIAK policy area: Transparency and anti-corruption policy (programme points; programme point ID: A1, A3, A6, A10)
  • MIAK policy area: Economy (programme points; programme point ID: G22)
  • MIAK policy area: Justice (programme points; programme point ID: I10)
  • MIAK policy area: Digitalisation and AI regulation (programme points; programme point ID: D18)
  • MIAK press monitor, 13 October 2026 — topic 1, score: 95/100

Supplementary public data sources (if used):

  • Suggested data sources for follow-up: the agenda and voting data of the National Assembly (parlament.hu), the minutes of the Committee on Justice and Constitutional Affairs, the statistics of the NAV’s beneficial-ownership register, the MNB’s register of investment funds, TIM’s freedom-of-information requests, the decisions and statements of the NAIH, the annual report of the Integrity Authority

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