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Automatically translated version. May contain inaccuracies compared to the original.
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Subsoil during public service: who should be held accountable for permits issued in Zlochevsky’s time
Mykola Zlochevsky headed the environmental protection ministry under Yanukovych from 2010–2012, and after leaving the ministerial post in April 2012 he became deputy secretary of the NSDC; he left that post in February 2014.
The dates of permits issued to companies whose corporate ties require verification intersect precisely with these periods — not according to today’s registry, but as of the time each decision was made.
⚙️ The question of this investigation is simple: did the state permitting system operate in the public interest, or did particular businesses receive advantages thanks to access to power? The answer must be found in the documents: permit files, decisions, signatures, corporate archives, and payments.
Not general suspicions, but specific permits
Kharkiv region
✔️Permit No.5360 for the Rakytnyansky field for Esko-Pivnich, dated 13 January 2011;
✔️Permit No.4096 for the Derkachivsko-Voytenkivska block dated 16 February 2012.
Lviv region
✔️Special permit No.5398 for Pari LLC for the Semyhynivske field was issued on 25 October 2011 based on order dated 15 September 2011, year No.69. The circumstances of its issuance later became the subject of an administrative dispute, which ended unsuccessfully for the prosecutor’s office on procedural grounds due to the statute of limitations for bringing the case to court.
✔️Permit No.4212 for the Vodyanivske field for Systemoilynzhenering dated 27 August 2012.
The IPVG report contains information about the beneficial links of Esko-Pivnich and Pari with Zlochevsky as of a later corporate snapshot 2016. This is important evidence for reconstructing ownership history, but it does not replace documents on control in 2011–2012.
🕵️♂️ It is necessary to establish who submitted the application, who verified the grounds, who approved the decision, who signed the order, and who actually received the economic benefit.
⚖️ In the case of the Semyhynivske field, the Supreme Court 13 in May 2025 upheld procedural rulings that prevented the prosecutor’s lawsuit from being heard due to the missed deadline. No judicial assessment on the merits of the alleged claims took place. The court noted that the prosecutor could have obtained the relevant information at least since March 2021 and that a request was made only on 7 August 2024.
This raises a separate line of responsibility. If the state considered the permit unlawful, why did its representatives not ensure timely consideration of the claims? Who monitored the deadlines, who made decisions, and was any verification conducted after the procedural defeat?
NABU and the SAP must check the circumstances of permit issuance during Zlochevsky’s public service. A separate request to the SBI will concern possible improper performance of official duties in prosecutorial response; ultimate jurisdiction depends on the established facts, the subject, and the legal qualification.
🔍 The subject of verification must be specific:
Permitting decisions: complete case files, grounds for issuance, use of auction or other procedures, approvals and signatories.
Historical control: owners, beneficiaries, representatives, and financing of applicants on the date rights were obtained.
Economic benefit: value of the rights obtained, payments to the state, subsequent revenues and transactions in corporate rights.
Procedural decisions: who investigated the relevant circumstances, what was checked, why proceedings were closed or why a timely court claim was not filed.
⚙️ The question “where did the money come from?” is not answered by pointing to the existence of a successful gas business. It requires investigating how the asset itself arose, who financed its acquisition, and whether official position was used as a tool to gain advantage.
Criminal qualification requires evidence of a specific offense: for abuse of power, coincidence of official dates alone is insufficient; for money laundering, it is necessary to establish the criminal origin of the funds; and tax claims require their own evidentiary basis. The law should be applied with proper regard to the time the act was committed, retroactive application of a milder law, and statute of limitations rules.
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