How Smugglers and Agribaronies Evade the NSDC Sanctions, Keep Self-Promoting, and Continue Robbing the Country

Agribusiness is suffering colossal losses during the war: mine contamination of millions of hectares of land, destruction of equipment and infrastructure, logistics problems, and blocked ports. But for agrarian baron Rafael Goryan, the war did not become an obstacle: his group of companies Prometey continues to profit from grain, to buy up assets, and to expand control over agricultural infrastructure. In 2021, a company associated with the Prometey group Swiss SA came under sanctions by the National Security and Defense Council of Ukraine (NSDC), but afterward ownership, names, and beneficiaries began to change within the corporate structure.

Goryan spent years bringing Prometey’s grain infrastructure under his control. Through LLC “RV-Capital” entire property complexes and corporate rights were purchased, and in 2017, after acquiring five elevators in Zaporizhia region, the number of complexes in the group grew to 17 with a total grain storage capacity of about 1 million tons. Thus, one business group gained significant control over grain storage across several regions. The expansion did not stop—Prometey announced plans to acquire nine more elevator complexes.

Antimonopoly Committee also recorded the concentration. LLC “RV-Capital” purchased more than 50% of shares of CJSC Hrebinky-Hliroprodukty without the prior approval of the AMCU, even though such concentration required consent. For this, the company received a fine of 309 thousand hryvnias. In effect, a structure connected with Prometey gained control over another grain-sector enterprise, strengthening its presence on the market.

Even more questions arise regarding grain operations. “Agro Central,” “Agro Davo,” and “Agro-OK” appear in operations with agricultural products of unknown origin, which could have been bought for cash without reflecting in accounting and tax records. For product documentation, transactions were conducted with enterprises showing signs of fictitiousness, after which the grain ended up at controlled elevators. From there, the product was documented and, through port terminals, exported.

The scale is about 100 million UAH in purchases of agricultural products without registering tax invoices. At the Prometey Jan elevators, 8 324 tons of barley, wheat, and sunflower were stored, the origin of which required documentary confirmation. The amount of unpaid taxes and mandatory payments within this scheme was assessed at over 13 million UAH. As a result, grain passed through a network of related structures, and the state could lose substantial tax revenues.

NSDC sanctions were supposed to block Prometey Swiss SA assets, but for Goryan’s empire, it seems there was a way to continue operating. After sanctions were imposed, “Prometey Sailos” transformed into “Custody Logistics,” changing the founder, executive, address, and ultimate beneficial owner. Legal names change, owners are re-registered, but the question remains: did NSDC sanctions really strike at Goryan’s empire, or did they only force it to swap signage?

We have already sent information requests demanding information about changes in the ownership structure and ultimate beneficiaries of the Prometey group companies after sanctions against Prometey Swiss SA, the blocking and management of its assets, scrutiny by AMCU of the acquisition by RV-Capital of more than 50% of shares of CJSC Hrebinky-Hliboproducts without approval for concentration, and the execution of AMCU’s decision imposing a fine of 309 000 hryvnias.

Rafael Goryan built an agrarian empire with 17 elevator complexes and storage capacity of about 1 million tons of grain, and his closest business circle has connections with persons and resources connected to pro-Russian media. NSDC sanctions did not stop the restructuring of the corporate structure, and the concentration of assets and grain operations continue to expand the scale of the business. Now the state must determine who actually controls this empire, how sanctions work, and how much money from these schemes the Ukrainian budget misses.