Tag: Ukraine

Strategic minerals are those that hold strategic value for a country’s sustainable economic development and defense capabilities. In Ukraine, a list of 37 such strategic minerals has existed since 2021. The war in Ukraine waged by Russia has changed the market for these minerals, prompting the world to resist the influence of China and Russia on economic development, including altering sources and supply chains of strategic raw materials.

This is an opportunity for our country to make a statement because Ukrainian subsoil contains 117 types of useful minerals out of the world’s 120. Of these, 22 useful minerals are a priority for European Union countries. Their extraction, processing, and enrichment sometimes require billions of dollars, necessitating foreign investments. These investments will be particularly crucial after the war when funds will be needed for reconstruction. In the future, these investments could become a part of our security.

The Anti-Corruption Action Center (AntAC) has analyzed which companies hold special permits to use strategic subsoil. A special permit is a document issued by the state through the State Service of Geology and Subsoil (StateGeoNedra) to allow the use of subsoil for a specified period. The owner of Ukrainian subsoil is the people. The state either uses the subsoil itself or grants them to businesses for temporary use, with the business covering the cost of exploration and mining of useful minerals.

This broken-down material is an overview of the most interesting industries, with a focus on the most promising one according to our interviewees – titanium. You can view the full list of 121 “strategic” special permits and information about their owners here. It will be updated over time. Sixteen of these special permits relate to deposits located in the territories occupied by Russia. Several dozen more are located in the front-line areas. In total, Russia has captured one-third of Ukraine’s subsoil, which is over 700 out of more than 2,160 deposits. BACKGROUND. Uses of titanium: aerospace industry, aviation, equipment for the oil and gas industry, shipbuilding, defense complex, energy, 3D printing, medicine, laptops, smartphones, robotics, jewelry, paint and coatings, plastics, inks, cellulose, rubber hardware. Sixteen special permits are issued for the development of titanium-containing deposits.

Due to the war and the global search for supplies, titanium is becoming increasingly important. The most promising strategic mineral in Ukraine is titanium-bearing ores. According to some estimates, Ukraine holds 20% of the world’s titanium raw material reserves. We provide, also according to various estimates, 4-7% of the world’s production of titanium-bearing ores.

China is the leader in terms of total production of all titanium-bearing minerals and titanium raw materials. Mozambique is second. Ukraine’s production is between India and Madagascar, both of which are among the top 10 countries in this regard. Most of the ores mined in Ukraine are used to produce titanium dioxide. It imparts a white color to paint, paper, cosmetics, plastics, toothpaste, and more. The main consumers of titanium dioxide are China, India, the USA, Japan, and Germany.

Ores with a high content of titanium dioxide are used to produce titanium sponge. It is used to melt ingots, billets, and produce titanium products. This is the segment of metallic titanium that covers the needs of the defense industry (titanium is present in rockets, Abrams tanks, Bradley BMPs, M777 howitzers, Barrett rifles, Black Hawk helicopters), aerospace industry, medical field (prosthetics, implants), and more. Less than 5% of all titanium-bearing ores in the world are used to produce metallic titanium.

There are several stages from ore mining to metallic titanium or titanium dioxide. Titanium-bearing ore is processed into concentrates, primarily rutile and ilmenite (rutile and ilmenite are important titanium minerals).

And from them, titanium dioxide or sponge (metallic titanium) is produced. The technology for producing metallic titanium is outdated, energy-intensive, environmentally unfriendly, and complex. That’s why scientists are looking for new ways to process raw materials into metallic titanium. Ukrainian company “Veltha,” led by Andriy Brodsky, has announced that it is getting closer to discovering such a method.”
Until recently, metallic titanium was produced in seven countries: India, Kazakhstan, China, the USA, Russia (before the full-scale war, Russia imported raw materials from Ukraine), Ukraine, and Japan.

However, in 2020, the titanium plant in the USA, Timet, was closed due to competition from China and Russia. Ukrainian metallic titanium was produced at the Zaporizhzhia Titanium-Magnesium Plant (ZTMC), but it is currently not operational due to the war.

Major consumers of metallic titanium include the American corporation Boeing and the French company Airbus, which manufacture passenger planes, military equipment, and weapons.

BACKGROUND: Boeing produces and services airplanes, spacecraft, satellites, and defense products, such as precision-guided GLSDB bombs (the latest in cooperation with the Swedish company SAAB). Before Russia’s full-scale invasion of Ukraine, Boeing purchased about one-third of its titanium from the Russian company VSMPO-Avisma, with the rest coming from the USA, Japan, China, and Kazakhstan. After the invasion, Boeing suspended cooperation with Russia, closed its engineering office in Moscow, shut down its training center in Skolkovo, and stopped sending parts to Russian airlines, reorienting its supplies to the USA and Japan.

Airbus manufactures airplanes, drones, tankers, and satellites. Recently, the company joined the transatlantic mission to create the new Starlab space station. Not long ago, Airbus was embroiled in a scandal regarding the removal of the Russian company VSMPO-Avisma from the EU sanctions list. The latter services the Russian military-industrial complex and should be under sanctions as a weapons producer. However, in the summer of 2022, at the last moment, Avisma was removed from the sanctions list because France, Germany, Spain, and other EU members opposed it. Since the Russian company is a crucial supplier of titanium products to Airbus, opponents of sanctions argued that Russia could retaliate by blocking titanium supplies. In December 2022, Airbus still announced that they would stop using Russian titanium, calling it “a matter of months.” Reuters, citing industry sources, reported that Airbus “expanded its purchases from the United States and Japan” but was also seeking other sources of supply.

However, as investigations by The New York Times in May 2023 and The Telegraph in August 2023 reveal, Russia managed to obtain aircraft parts worth tens of millions of dollars through bypassing sanctions for Boeing, Airbus, and other companies. Although Russia had to reorient itself to other suppliers as well. After February 24, 2022, China became the source of about half of the parts for airplanes and other war-related products in Russia, followed by India.

According to information from The Wall Street Journal, Ukraine could be a potential supplier that would help reduce America’s dependence on titanium from unfriendly countries. However, Kiev’s attempts are undermined by internal political conflicts and the war. In any case, according to former Boeing CEO John Byrne, Ukraine “will definitely be among the places that will be considered” when looking for alternative sources of titanium supply.

Ukraine’s titanium industry has undergone changes in recent decades. In the Soviet Union, Ukraine had a complete closed-cycle titanium industry. Two enterprises operated in the extraction of titanium raw materials: the Irshansky Mining and Processing Plant (GOK) in the Zhytomyr region and the Volnogorsk Mining and Metallurgical Plant (GMK) in Dnipropetrovsk.

The Volnogorsk GMK supplied raw materials to producers of sponge titanium – VSMPO-Avisma – in Russia, the Ust-Kamenogorsk Titanium-Magnesium Plant in Kazakhstan, and ZTMC. Titanium dioxide was produced by Ukrainian Sumykhimprom and Crimean Titanium, which also imported raw materials from Ukrainian deposits. The last three enterprises were under the influence of oligarch Dmytro Firtash.
The titanium enterprises that remained in Ukraine after the dissolution of the Soviet Union, as well as those established later, primarily focused on exporting titanium-containing raw materials to foreign markets. According to the State Customs Service, the main consumers of Ukrainian titanium-containing ores and concentrates in the first seven months of 2023 were Turkey (30.6%), Japan (26.98%), and India (8.57%). In 2022, titanium-containing ores were exported to the Czech Republic (47.91%), the United States (11.94%), and Romania (9.75%). In 2021, exports were made to Mexico (21.22%), China (18.17%), and the Czech Republic (14.07%). Ukraine now faces the imperative of integrating into global supply chains, transitioning from the sale of raw materials to processing and enrichment, and ultimately replacing Russia in the global titanium market.

For instance, the United Mining and Chemical Company (UMCC) reveals that the profit margin for 1 ton of ilmenite concentrate can reach up to $70, while for titanium dioxide, it can reach up to $600, and for 1 ton of titanium sponge, it can be as high as $2500. However, the establishment of modern plants for deeper processing requires attracting substantial investments, often amounting to hundreds of millions of dollars. Our sources within the mining companies highlight the lack of “political will” in this regard. International investors demand improvements in the investment climate and transparent regulations, which can be particularly challenging during a full-scale war. Additionally, there are other challenges specific to the titanium industry. Currently, Ukraine only mines titanium ores from placer deposits that can be easily excavated. However, placer deposits constitute only about 10% of the known reserves, with the majority being primary deposits that require blasting. Mining in such areas is more complex and costly, as it necessitates the construction of mines and the acquisition of expensive equipment.

The mining industry has also been impacted by the COVID-19 pandemic and the ongoing war. The global market has experienced a slowdown in construction activities, leading to a decrease in demand for titanium dioxide. Moreover, the market is saturated with Chinese products, as China is responsible for over half of the world’s titanium dioxide production. The construction industry in China, like elsewhere, has faced stagnation. The production costs for Ukrainian manufacturers have risen due to increased prices of energy resources and fuel, logistical challenges related to the war, the implementation of new export control rules, shelling incidents, infrastructure destruction, and other factors.

For example, UMCC is heavily dependent on exporting its products through ports in the Odessa region, accounting for nearly 90% of its shipments. The full-scale war has severely disrupted titanium ore shipments from Ukraine, necessitating a complete overhaul of the country’s export routes.

The following are the owners of special permits for the use of Ukrainian titanium deposits:

– UMCC Titanium (United Mining and Chemical Company, or UMCC Titanium): This company mines titanium-containing ores and produces ilmenite, rutile, and zircon concentrates. Previously, the enterprise generated revenues of up to 600 million UAH per year, but the current financial results are undisclosed. The State Property Fund, acting on behalf of the state, announced in the summer that UMCC would be privatized in the fourth quarter of 2023. However, the former head of the State Property Fund, Rustem Umerov, recently spoke of the sale of UMCC in the past tense when questioned about its completion by the end of the year, stating, “We set such a goal.”

UMCC began operating in the summer of 2014 when the government decided to transfer the management of the Volnogorsk Mining and Metallurgical Plant and the Irshansk Mining and Concentrating Plant to the company. These plants were previously leased by Firtash’s structures and supplied Crimean Titanium. After the Maidan revolution, UMCC came under the management of the Ministry of Economic Development, and in 2019, it was transferred to the State Property Fund.

UMCC’s management has faced consistent accusations of supplying goods to Russia through intermediaries, which involved profit margins. Notable cases involved individuals such as Ruslan Zhurilo, the former head of UMCC, who had close ties to ex-MP Nikolai Martynenko, and Dmitry Sennichenko, the former head of the State Property Fund.

In an interview with Vladislav Itkin, who served as the head of UMCC in early 2023, he expressed pride in the fact that their team had not been accused of betraying national interests or engaging in shadowy supplies of titanium raw materials to sanctioned territories. Since 2014, they became the first management team at UMCC to avoid such disgraceful allegations.

Group DF, however, maintains that their titanium business does not require the outdated facilities of UMCC for ore processing, as they possess their own modern GOK plant, which is currently underutilized. The Firtash Group dismisses claims that Kalandadze is Firtash’s man or that David Arakhamia has any involvement in the matter, labeling them as mere fabrications created by PR specialists.

Despite the challenging reputational issues, OGKhK could potentially replace the Russian company VSMPO-Avisma under certain conditions. According to Kalandadze, UMCC is already engaging with various engineering companies to address technical challenges and conduct relevant research. However, such ambitious plans necessitate significant investments. The State Property Fund has previously attempted to sell the company three times before the outbreak of war, but no buyers emerged. Our sources highlight three reasons for this lack of interest.

Firstly, there is a limited resource base. Approximately 70-75% of OGKhK’s revenue is generated by the Volnogorsk plant, with the remaining 20-25% coming from the Irshansky plant. It is estimated that the Volnogorsk plant’s reserves will last for only a few more years. To replenish this resource base, new special permits are required. There has been some improvement in this regard, as in June 2023, the State Geographical Directorate seized the Selishchansky titanium ore site in the Zhytomyr region from Firtash. Additionally, OGKhK regained its special permit for subsoil use, No. 5269, which was previously held by Firtashevsky Mezhdurechensky GOK. However, there are ongoing legal battles and an investigation by the Antimonopoly Committee of Ukraine regarding this matter. Oleg Arestarkhov, the head of corporate communications at Group DF Firtash, states that if they lose the lawsuits for Selishchanka in Ukraine, they will pursue international legal avenues, which would further taint the asset.

According to Deputy Chairman of the State Property Fund, Alexander Fedorishin, there is a constructive dialogue and alignment of positions with the Antimonopoly Committee of Ukraine (AMCU) regarding the privatization of UMCC, acknowledging the need for an attractive product. However, the market remains cautious. As individuals within the titanium industry suggest, potential investors may prefer to observe how the state handles the situation rather than engage in legal battles with Firtash.

Another obstacle is the absence of JORC (international reserve assessment), which can cost up to $500,000 and requires up to two years for completion. Denis Aleshin, the director of strategic development at the lithium company Ukrlitiydobycha, emphasizes the necessity of JORC, stating that “no conscious international investor will consider data based on Ukrainian standards.” International investors are accustomed to specific standards, and adherence to these standards is crucial for companies seeking international success.

While Ukraine currently possesses technical, legal, and financial analyses of UMCC, accurate information regarding reserves remains the key missing piece. International investors would demand this information, seeking confirmation from reputable sources. The OGKhK case involving Zhurilo revealed official damages of nearly $13 million. If the ambitions of OGKhK managers had been more modest, a JORC assessment could have been completed long ago.

Furthermore, there is a lack of effective communication with investors. In 2021, the State Property Fund enlisted the services of auditing and consulting company BDO to engage with potential investors. BDO claimed to have identified 29 potential investors, including 16 foreign entities. However, these investors requested that the Ukrainian government ensure the accuracy of all information provided about OGKhK and compensate for potential losses resulting from events preceding the sale.

The road ahead for UMCC is challenging, requiring careful navigation of legal complexities, the establishment of a robust resource base, adherence to international standards, and effective communication with investors. Only with these crucial elements in place can UMCC position itself as a viable contender in the global titanium industry.
The Cabinet of Ministers has failed to provide the necessary guarantees, resulting in the cessation of cooperation between the Fund and BDO, as Alexander Fedorishin mentioned, “at some point.” Presently, the Fund is contemplating the option of appealing to the Cabinet of Ministers to reevaluate the privatization terms and exclude the advisor.

Our sources indicate that the acquisition of OGHC may pique the interest of individuals such as oligarch Rinat Akhmetov, Ukrainian billionaire Gennadiy Butkevich, the potential owner of the mining company “Velta,” Andrey Brodsky (despite his contrary statements), and Dmitry Firtash, who, due to sanctions, may not be inclined to participate. Additionally, a foreign company from Eastern Europe has been mentioned as a potential buyer.

One of our interviewees concludes, “If the Fund manages to sell OGHC to a reputable international investor amidst the challenges of a state of war, an unconventional investment climate, resistance from various interest groups, and considering the long-term nature of the mining industry, which no previous presidents have honored, it will be an extraordinary achievement.”

There was an event of significance that must be acknowledged as well. On August 7th, RBK Ukraine published an article alleging that “a significant portion of titanium raw materials exported from Ukraine ends up in Russia through intermediaries,” with OGHC and ZTMC being mentioned. The author of the article, Denis Kazansky, did not provide supporting evidence for the headline. Nonetheless, it gained significant traction in Ukrainian and international media, prompting the State Property Fund to publicly refute it. This scandal benefited many parties: OGHC’s competitors sought to remove the state-owned company from the market, sellers attributed the lack of demand to it, and potential buyers may have aimed to lower the price of the lot.

The article also shed light on two problematic aspects. Firstly, OGHC still engages in transactions through intermediaries. The company claims that these intermediaries now function as financial agents rather than “padlocks” used for fund routing. Presently, ultimate buyers pay for goods with a 90-day payment delay, not accounting for the extended logistics time during the war. Intermediaries serve as a bridge to overcome this gap. This practice is prevalent across the entire market, not limited to OGHC. However, due to the confidentiality of OGHC’s contract details, it is challenging to monitor the extent to which intermediaries receive public funds. Given past controversies with intermediaries, it is even more difficult to accept the company’s word on this matter.

Secondly, a portion of titanium-containing products exported abroad, which holds strategic importance for Russia, is subject to less stringent control by Ukraine than it could be. Currently, the State Export Control Service oversees the export of titanium-containing materials, and all ilmenite exporters must obtain special export permits. However, there are apparently certain titanium-containing products for which such permits are not required. This includes rutile, which is economically impractical for the production of metallic titanium but remains a possibility. Metallic titanium can also be derived from titanium slag and titanium tetrachloride.

Demurinsky Mining and Processing Plant (DemGOK), situated in the Demurinsky starostin district of the Dnipropetrovsk region, possesses a quarry, an enrichment plant, and a special permit for the extraction of zircon-rutile-ilmenite placers from the Volchansk deposit. Similar to OGHC, DemGOK is involved not only in raw material extraction but also in concentrate production.

Andrey Brodsky described DemGOK as follows in one of his interviews: “A significant portion of the equipment is domestically made, and the quarry resembles a large hole. I don’t know what to do with it next. Even if they offered it to me for free, I would decline.”

In 2021, the enterprise’s net profit exceeded 200 million hryvnias. However, in 2022, the plant incurred losses of 260 million hryvnias.

DemGOK was recently seized from Russian businessman Mikhail Shelkov in accordance with the sanctions imposed on him. Under Shelkov’s ownership, the plant served as a raw material base for Russian Avisma. According to the Security Service of Ukraine (SBU), Ukrainian titanium-containing raw materials were utilized in Russia for the production of “Caliber” missiles, MiG-35 and Su-35 combat aircraft, and Ka-52 helicopters. Avisma also imported titanium products into the Ukrainian city of Nikopol, in the Dnipropetrovsk region, to a facility controlled by Shelkov, VSMPO “Titan-Ukraine.” Titanium pipes were manufactured there and subsequently exported back to Russia. In January 2023, the court seized these assets for the benefit of the state and Titan-Ukraine. Currently, the enterprise is under the management of the State Property Fund.

Over the past six months, DemGOK has not been operational, partly due to legal disputes concerning its assets. While trial operations wereconducted at the plant in April 2023, production has not yet resumed. The FGIA, which currently oversees the enterprise, intends to put it up for sale. Alexander Fedorishin emphasizes that, in his personal opinion, DemGOK and OGHC “should cooperate” as the Volchansk branch of OGHC is located nearby.

According to Nadra.info, representatives from the company “Rudomain,” associated with businessman Konstantin Karamanitsa, visited DemGOK to explore the possibility of a purchase. The FGIA confirmed the visit but clarified that the purpose was to seek potential contractors for quarry work and to assess the suitability of their services.

Furthermore, the FGIA has already made some assets related to DemGOK available for sale. This includes the corporate rights of the agricultural enterprise “Investagro.” Almost half of the Volchansk deposit, where the plant operates, remains untapped. Currently, this area spans 1.3 thousand hectares and is owned by individuals and territorial communities, with Investagro leasing the land. Previously, the enterprise, like DemGOK, was owned by Mikhail Shelkov but was also confiscated, put up for auction, and remained unsold. It will now be offered for sale once again, at a reduced price.
Zhytomyr Ore Exploration (ZOE)

Zhytomyr Ore Exploration LLC (ZOE) possesses four titanium special permits. The state, through the State Geological Enterprise “Nadra of Ukraine,” controls 90% of the company, while the remaining 10% belongs to a company with a likely dummy co-owner. In March 2023, the Security Service of Ukraine (SBU) conducted a search at the company’s office, which employed Dmitry Kashchuk, the head of the subcommittee on subsoil at the European Business Association. During the search, they discovered the seal of a company associated with ZOE. Sources from the mining business, when preparing this material, cautioned that ZOE might be under the control of a “conglomerate of law enforcement, prosecutors, and criminal elements,” and advised against investigating this company.

Currently, ZOE is not engaged in any mining activities and is largely unprofitable. The company is entangled in prolonged legal disputes over its special permits and faces issues with land documents for areas where mineral extraction is possible. The land has been parceled out, and landowners oppose mining. Outdated equipment further exacerbates ZOE’s challenges. Since 2016, the company has not received any investments. Consequently, ZOE has been drilling wells for water for many years, earning meager profits and refraining from distributing dividends.

According to the State Geological Enterprise, the initial plan was to sell ZOE’s special permits to OGHC. However, this idea was eventually abandoned due to the need for changes in the work program for the highly prospective Trostyanets deposit in the Zhytomyr region. These changes could not be made due to unresolved legal intricacies. Without these changes, the special permits cannot be sold.

The Paromivske deposit in the Zhytomyr region includes protected reserves owned by another subsoil user. This matter will also need to be resolved through the courts, which is expected to take several years. Furthermore, our sources indicate that the special permits for the Krasnorechenske and Levoberezhne deposits in the Zhytomyr region are less promising for OGHC due to their geographical remoteness.

Therefore, unless ZOE’s permits are sold to OGHC with changes to the work program (which is possible but unlikely), they will be annulled and put up for sale again.

Velta LLC and Decart Minerals LLC

The mining company “Velta,” owned by businessman Andrey Brodsky from Dnipro, recently held two special permits for the Birzulivske and Lekarevske deposits in the Kirovohrad region. Velta’s mining and processing plant is situated near the town of Novomyrhorod in the Kirovohrad region, and commercial supplies of titanium raw materials commenced there in 2012. The plant has a capacity of up to 270,000 tons of ilmenite concentrate per year.

According to the company, it commands 2% of the global ilmenite supply market and 35% of the mining market in Ukraine. Velta supplies raw materials to the American chemical giant Chemours, which trades various products, including Ti-Pure pigments for the automotive industry, textiles, and construction. The Czech company Precheza, specializing in pigment supplies, is also a major customer of Velta.

Until recently, Velta claimed to face pressure from the National Police (NaPol) and, previously, from the Bureau of Economic Security (BES). The Deposit Guarantee Fund (FGVF) repeatedly and unsuccessfully attempted to auction Velta’s obligations to Prominvestbank. However, in recent times, Brodsky’s company has reported predominantly positive news.

According to the company, its scientists have developed and patented a new technology for producing metallic titanium. This technology is less energy-intensive, involves fewer production stages, and generates zero waste. Although the Wall Street Journal referred to this technology as unverified in October 2022, Brodsky’s company announced in the summer of 2023 that it is already collaborating with the New York-based boutique consulting firm EAS Advisors LLC. The collaboration aims to secure financing for the construction of a titanium powder plant in the United States, based on Velta’s technology. The Canadian company Hatch will oversee the design of this plant.

In the summer of 2023, Brodsky also announced the establishment of the Association of Titanium Industry of Ukraine (ATIU). The association’s objective is to “create a complete cycle of titanium raw material processing in Ukraine to protect the country’s national interests and enhance its defense capabilities.”

On August 10th, ATIU publicly disclosed the list of participants. Alongside Velta, it includes the state-owned Zaporizhzhia Titanium and Magnesium Combine (ZTMC) and the Titanium Institute. The Titanium Institute is the sole institution in Europe specializing in the design and technical solutions for large-scale titanium projects. It is managed by the StateProperty Fund of Ukraine. Additive Laser Technologies of Ukraine, the only Ukrainian manufacturer of 3D printers owned by Oles Dovgy’s group, and Dnepropress Plant, a producer of presses and equipment for mechanical engineering and forgings from steel and titanium alloys, with ties to Dmitry Mishalov’s family business group, are also participants. On August 16th, the association signed a memorandum of cooperation with the National Security and Defense Council (NSDC).

Until recently, Velta had plans to establish another Mining and Processing Plant (GPP) – the Lekarevske GPP, with a capacity of 120,000 tons of concentrate per year. However, when changes to the Subsoil Code took effect in the spring of 2023, allowing subsoil users to sell already occupied special permits (previously restricted to companies that owned these permits), Velta became the first to sell the special permit for subsoil use of the Lekarevske deposit.

The new owner of the titanium special permit is Decart Minerals LLC, a company previously focused on providing loans. Decart Minerals is owned by Alexey Tsarapkin, who has no prior involvement in the mining business.
Four special permits for titanium subsoil are currently held by companies affiliated with the Dmitry Firtash group of companies. Dmitry Firtash, an Ukrainian oligarch who has been subjected to sanctions since 2021, currently resides in Austria and faces the potential extradition to the United States. American law enforcement authorities have accused him of engaging in bribery with Indian officials to obtain the rights for titanium mining.

On March 28, 2023, there was a change in legislation regarding subsoil resources, granting the State Service of Geology and Subsoil (Gosgeonedra) the authority to suspend the operation of special permits held by sanctioned individuals. Consequently, on March 29, the agency suspended the operation of all special permits associated with the DF group. These permits remain suspended up to the present day.

According to the law, the state cannot revoke these permits. However, companies linked to sanctioned individuals are prohibited from conducting any mining activities. As a result, Firtash’s titanium enterprises have effectively ceased operations, leading to the unfortunate layoff of approximately five hundred employees.

Hence, there is a need to refine the mechanism for imposing sanctions on mining companies. An alternative approach to such restrictions could involve the suspension of special permits, such as the temporary freezing of corporate rights under state control. This would allow the company to continue its operations, fulfill tax obligations, pay salaries, while refraining from distributing dividends, and so forth.
The company known as the “Apatite-Ilmenite Group,” owned by Gennady Butkevich, holds a permit for the geological exploration of the Yurovsky site, which contains apatite-ilmenite ores in the Zhytomyr region. According to Forbes, Butkevich was ranked as the 16th wealthiest individual in Ukraine in 2020, with a fortune amounting to $415 million. He is a co-owner of the “ATB-Market” network and the sole proprietor of the “Kolo” supermarket chain. These assets are consolidated under the investment group BGV Group Management (BGV).

It is noteworthy that 8.4% of the “Apatite-Ilmenite Group” is owned by Alexander Nastenko and Vitaliy Yakimenko, who is the father of Pavel Yakimenko, a deputy from the Servant of the People party. Pavel Yakimenko chairs the subcommittee on the protection and rational use of subsoil resources within the Verkhovna Rada’s Committee on Environmental Policy and Nature Management.

Additionally, there is another permit for subsoil extraction at the “Zapadny” deposit of the “Krutaya Balka,” which is held by a company called “Non-Ferrous Metals” with foreign investments. The beneficiary of this company is Eugene Kossov. However, it is important to note that over 90% of the company is owned, through “Yumin” LLC, by a separate entity known as “Zemresursy,” which is under the ownership of Nina Vizgalova.

In the past, “Non-Ferrous Metals” was under the leadership of Dmitry Vizgalov, a businessman from the Dnipropetrovsk region. The company, which was part of the Umin group and traded in titanium-containing raw materials, operated near OGKH in Volnogorsk, Dnipropetrovsk region, within the territory of the Borovkovsky starostin district.

According to the court register, in 2019, “Non-Ferrous Metals” encountered financial difficulties and accumulated debts for subsoil rent, leading to the termination of its contract with the state.

Furthermore, in 2023, Gosgeonadra extended a special permit for the geological exploration of titanium ores at the Avramovsky deposit, which is located 20 km from Kropyvnytskyi, to CenterUkrGeology. This company, a subsidiary of NAK “Nedra Ukraine,” specializes in the search for solid minerals and water. However, it has been facing financial losses in recent years. Taras Kuzmich, the head of NAK “Nedra Ukraine,” has expressed that CenterUkrGeology plans to conduct exploration work and aims to attract investors due to the enterprise’s inability to handle such a large-scale project independently.