State Posts and the Gas Business: How Companies Linked to Zlochevsky Obtained Special Permits for Subsoil

State Posts and the Gas Business: How Companies Linked to Zlochevsky Obtained Special Permits for Subsoil

A state post, the gas business, and subsoil permits. While Mykola Zlochevsky headed the Ministry of Ecology and Natural Resources, Esko-Pivnich received a permit to develop the Rakytnyansky field in Kharkiv region, and Pari received one for the Semyhyniv field in Lviv region. A later IPVG report links these companies to Zlochevsky, but the question of who actually controlled them at the time the permits were issued requires verification using archival documents.

We need to determine:

Who exactly signed the decisions granting the permits, on what grounds the business obtained extraction rights, and who ultimately became the beneficial owner. We will analyze permit files, companies’ ownership histories, and officials’ actions. We plan to approach NABU and SAP with specific documents and questions, not with general statements.

A separate issue is why the state lost the opportunity to have its claims considered on the merits. In the case of the Semyhyniv field, the prosecutor’s suit was not accepted because the filing deadline was missed, so the legality of the permit’s issuance was never established.

We will examine not only the permit recipients but also those officials who should have timely protected the state’s interest. Next will be specific fields, dates, decisions, and questions for documentary verification of asset origins and officials’ responsibility.

Mykola Zlochevsky headed the environmental protection ministry during the Yanukovych era in 2010–2012 years, 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 the permits issued to companies whose corporate links require review coincide with these periods; verification should use the status at the time of each decision, not the current registry.

The question of this investigation is simple: did the state permitting system operate in the state’s interest, or did certain businesses gain advantages through access to power? The answer should be in documents: permit files, decisions, signatures, corporate archives, and payments.

Not general suspicions, but specific permits

Kharkiv region

Permit No.5360 for the Rakytnyansky field to Esko-Pivnich, dated 13 January 2011.

Permit No.4096 for the Derkachivsko-Voytenkiv block, dated 16 February 2012.

Lviv region

Special permit No.5398 for Pari LLC for the Semyhyniv field issued on 25 October 2011 on the basis of the order dated 15 September 2011 No.69. The circumstances of its issuance became the subject of a later administrative dispute that ended unfavorably for the prosecutor on procedural grounds due to a missed filing deadline.

Permit No.4212 for the Vodyaniv field for Systemoilengineering, dated 27 August 2012.

The IPVG report contains information on the beneficiary links of Esko-Pivnich and Pari to Zlochevsky as of a later corporate snapshot 2016. This is important evidence for building the ownership history, but it does not replace documents establishing 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 Semyhyniv field case, the Supreme Court on 13 May 2025 upheld procedural rulings that prevented consideration of the prosecutor’s suit due to the missed deadline. The court did not assess the merits of the claimed allegations. The court noted that the prosecutor could have obtained the relevant information at least since March 2021 and filed its request only on 7 August 2024.

This raises a separate line of responsibility. If the state considered the permit illegal, why did its representatives fail to ensure timely consideration of the claims? Who monitored deadlines, who made decisions, and was any verification conducted after the procedural failure?

NABU and SAP must investigate the circumstances of permit issuance during Zlochevsky’s public service. A separate request to the SBI will concern circumstances of possible improper performance of duties in the prosecutors’ response; final jurisdiction will depend on the established facts, the subject, and the qualification.

The subject of verification must be specific:

Permit decisions: complete files, grounds for issuance, use of auction or other procedures, approvals, and signatories.

Historical control: owners, beneficiaries, representatives, and financing of applicants as of the date they received rights.

Economic benefit: the 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 court action was not filed in time.

The question “where did the money come from?” is not dismissed by pointing to the existence of a successful gas business. It requires investigating how the asset itself arose, who financed its acquisition, and whether an official position was used as an instrument to gain advantage.

Criminal qualification requires evidence of a specific offense: for abuse of power the coincidence of official dates is insufficient; for legalization of funds it is necessary to establish their criminal origin; and tax claims require their own evidentiary basis. The law must be applied taking into account the time of the act, retroactive application of a more lenient law, and statutes of limitations.