1. Graphite
  2. Gold
  3. Beryllium
  4. Lanthanide series metals
  5. Deposits that have not been distributed
  6. Reference. How we searched and organized information

In this piece, we analyze who owns special permits for Ukrainian strategic subsoil. Below is an overview of special permits for the use of subsoil for beryllium, lanthanide metals, graphite, and gold.


According to the US Geological Survey, in 2022, China, Mozambique, and Madagascar were the top producers of graphite. Turkey, Brazil, and China had the largest reserves.

According to the Financial Times, China's share of the graphite market is just over 20%. But its share of the graphite processing market is almost 70%. This puts electric car manufacturers in the United States and Europe in a threatening position.

After all, almost a quarter of graphite ore is used to produce anodes in lithium-ion batteries. Anodes determine how fast the battery can be charged. Anodes are the second largest market for electric vehicle battery components. The first is cathodes, which require lithium, among other things. The cost of the battery and the amount of energy it can store depend on the cathodes.

As in most of the electric vehicle supply chain, Chinese companies dominate the anode industry. One of the best-known Chinese anode manufacturers is Catl, which produces about 37% of the world's batteries.

Reference. Graphite is used in nuclear power, aerospace, mechanical engineering, metallurgy, batteries, medicine, synthetic diamond production, and the manufacture of normal pencils. There are four special permits for the use of graphite subsoil in Ukraine.

The United States has already included graphite in its list of critical materials and identified it as one of the key components of batteries that are at risk of supply disruption. Previously, Americans imported most of their graphite raw materials from China. Some came from Mexico, Canada, and Madagascar. The European Commission has also included graphite in the list of critical raw materials.

According to Benchmark Mineral Intelligence forecasts, a London-based agency, natural graphite will be the most scarce of all battery materials. The battery market will increase demand for graphite eightfold by 2030. To meet the global demand for graphite in all sectors, 97 medium-sized graphite mines will need to be launched by 2035.

Graphite is also used to produce graphene, a mineral discovered in 2004. In 2009, the European Commission initiated the Graphene flagship research program with a budget of 1 billion euros, which is still ongoing. Super-sensitive sensors, drones, water filters, and sensors are already being created on the basis of graphene.

Ukraine could become an alternative to foreign graphite. According to the State Service of Geology and Mineral Resources, Ukraine is among the top five countries in the world in terms of proven graphite reserves. The country currently has six known graphite deposits. But only one is in operation – part of the Zavallivske deposit located in Kirovohrad Oblast.

The special mining permit is held by the Zavalievsky Graphite Plant. According to Industrial Minerals (UK), the enterprise is among the world's top ten natural graphite producers and has a processing plant. The company's production capacity is up to 30,000 tons of graphite per year.

Zavalievsky Graphite Plant is part of Zavallia Graphite Group (ZG), which includes Zavallia Graphite LLC, Stone Foundation LLC, and Graphitinvest LLC. The last company owns 78.9% of the plant.

In 2021, 70% of ZG was acquired by Australia-registered Volt Resources Ltd (Volt), a graphite and natural graphite anode producer with a large Bunyu Graphite Project in Tanzania. Their shares are listed on the Australian Stock Exchange under the ASX VRC ticker and on the Frankfurt Stock Exchange under the R8L ticker.

30% of ZG is owned by Marta Yanko and the Slovak company of Yanko's relatives, Mogra s.r.o. According to the Prosud and investigations, Yanko is the daughter-in-law of Volodymyr Yanko, the prosecutor of Luhansk Oblast (until September 2019).

In November 2021, Mykhailo Tkach from the news outlet Ukrainska Pravda filmed people at the Ivano-Frankivsk airport who could have arrived at the birthday party of the head of the President’s Office Andriy Yermak at the state residence of Syniohora. The Austrian Karl Kontrus, who at the time had a "railroad" business in Russia, was caught in the lens.

Kontrus arrived with his companion on a private jet from Austria. Both were dressed, as the investigator notes, "solemnly". Kontrus's companion "held a branded package". The couple was picked up from the airport by a Porsche car registered to Zavalievsky Graphite LLC.

Kontrus returned to Austria when the guests began to leave after the celebration in Syniohora. Later, the Austrian businessman commented that he did not fly to Yaremche to see Yermak, but "to see friends he has known for 30 years."

According to Volt's stock exchange announcement, the Australians paid the first tranche of $3.6 million to four ZG sellers in 2021. The second payment of $3.8 was due in July 2022. But it was overdue. How come? We asked the Australian company, but have not yet received a response.

Roman Saramaha, CEO of Zavalievsky Graphite, when asked to comment on the delayed payment, said: "The Ukrainian management is engaged in operational activities aimed at preserving the enterprise and the workforce during the war and its further development."

Two more graphite permits belong to the companies of Hennadiy Butkevych, co-owner of the ATB supermarket chain. They are concentrated in BGV Group Management, named after his initials: Hennadiy Vladyslavovych Butkevych.

Among them is Rozvytok Pobuzhzhya, which has a permit to extract the Southern section of the Balakhivske field in Kirovohrad Oblast. And also the Ukrainian Supply Group, which has a special permit for extraction from the subsoil of the Zarichna area of the Zavallivske field located in Odesa Oblast.

Under the Balakhivskyi project, Butkevych is conducting pilot tests of the processing plant and completing the design of the production complex and pilot graphite mining. In 2024, the company plans to start construction of one of the largest production complexes in Europe. Its potential capacity will be 50,000 tons of graphite concentrate per year and 19,000 tons of spherical graphite for lithium-ion batteries.

BGV is carrying out a test drilling and sampling program at the Zarichna area in Odesa Oblast. The sampled ore will be sent to a laboratory to "test the beneficiation technology and determine the range of products that can be produced from the concentrate."

The fourth special permit for the Burtynske field in Khmelnytskyi Oblast was obtained in 2022 by Spys Ukraine, a company from the so-called Onur group, a corporation with owners registered in Turkey. In Ukraine, Onur builds roads, tramways, and produces concrete and asphalt mixtures.

The community of Mykhailiuchka village, where graphite deposits are located, opposed the Spys graphite project. On May 1, 2023, members of the local community appealed to the president to "prevent the development" because, in particular, the likely mining would be less than one kilometer from the village.


According to the US Geological Survey, in 2022, the largest gold production was in China, Australia, and Russia. The largest reserves are in Australia, Russia, and South Africa. According to the same estimates, 47% of the global gold market was accounted for by jewelry, 20% by banking and other institutions, 17% by bullion, 9% by coins and medals, 6% by electricity and electronics, and 1% by everything else.

In total, global demand for gold increased by 18% in 9 months of 2022, compared to the same period in 2021.

Reference. Gold is used in nuclear research, neutron bomb cladding, coating of mirrors operating in the far infrared range, brazing of metals, and jewelry. Ukraine has issued nine special permits for the use of gold-bearing subsoil.

We have also included gold-polymetallic ores in the Ukrainian gold special permits. This means that the deposit contains not only gold but also polymetals. These are mineral formations, among which the most valuable components are zinc and lead.

Three gold and polymetallic permits are held by Avellana Gold LTD through Carpathian Ore Company and Western Geological Exploration Company LLC. They got the Kvasivske ore field and the Berehivske and Muzhiyivske deposits in Zakarpattya Oblast. The media linked Muzhiyevo to the circle of Vitaliy Zakharchenko, who was the Minister of Internal Affairs under Yanukovych and fled to Russia after the Maidan.

In 2016, the "dormant gold special permits" from the management of Zakharchenko's companies were bought by Avellana Gold LTD, a company owned by American Brian Savage, who manages a number of other mining projects. Now the firm’s website says that the company was "founded by a group of international investors" without specifying which ones.

Currently, Avellana cannot produce gold, silver, or any other single metal from its products. The company says that this requires large investments and the construction of several separate pyro- and hydrometallurgical cycle facilities. Therefore, in the first three years, Avellana has built a modern enrichment plant in Berehove, Zakarpattya Oblast.

It processes polymetallic ore containing gold and silver and produces lead and zinc concentrates for sale. These concentrates also contain gold and silver. About 40% of the lead concentrate is lead, which is processed and used in the production of batteries. After lead is smelted, the rest of the product is used to extract precious metals at specialized facilities that do not yet exist in Ukraine.

Avellana Gold Ltd's zinc concentrate will contain 30% to 55% zinc and can be used in Ukraine for fertilizer production. The company plans to ship several test containers of standard quality this year and launch commercial operations. Unlike lead, gold, and silver, zinc concentrate can be processed in a hydrometallurgical cycle.

The company is now continuing its own technological research and has initiated negotiations with the European Union and the EBRD on the possibility of financing this project and creating a single production cycle with European steel companies.

According to Avellana Gold Ltd, the company's strategic goal, however, remains to invest in geological exploration and build a single underground mining complex that will combine the resources of Muzhiyivske and Berehivske deposits. Avellana plans to produce the first ore from underground mining next year.

Another permit for the extraction of gold ores from the Sauliak deposit in Zakarpattya Oblast is held by Sauliak LLC, owned by Boris Pokrass and his partners, Alex Zhdanov and Vladimir Palant. There has been no public information about this company in recent years. As for its founders, Palant's Linkedin profile states that in the late ‘90s he co-founded the Ukrainian Titanium Apatite Company (TAKO), which the media linked to Russian billionaire Viktor Vekselberg.

The website of another company of Boris Pokrass, CCI-Lubelia, which has a special permit for coal mining in Lviv Oblast, is also publicly available. It indicates that one of the three members of the board of CCI-Lubelia is Grant Sinitsyn, who appears to live in the Russian Federation, has Russian citizenship, and pays taxes there. Sinitsyn's residence in the Russian Federation is shown in the British business register. According to the Russian Unified State Register of Legal Entities, Sinitsyn has been registered as an individual entrepreneur in Moscow since 2014. During the registration, he used the documents of a foreigner. However, at the end of 2022, he re-registered as an entrepreneur as a Russian citizen. At the same time, it is worth noting that the website has not been updated for a long time. We wanted to clarify this connection with Russia directly with Sauliak. But our emails bounced back, and the company's phone did not answer.

Another holder of the permit for gold ores in the Klyntsiv district of Kirovohrad Oblast is Lyra Mine Minerals, a company from the orbit of influence of Hennadiy Butkevych. Its co-owners are Oleksandr Nastenko, Vitaliy Yakymenko (45% each), Andriy and Maryna Melnyk (5% each).

In 2020, Lyra Mine Minerals and another company of Nastenko and Yakymenko, Taurus Infinity, which has the only tantalum permit in Ukraine, were featured in an investigation by the Radio Liberty’s Skhemy (‘Schemes’) project program. The journalists claimed that when granting these companies special permits, the State Service of Geology and Mineral Resources probably turned a blind eye to violations of the document submission procedure.

On its website, Lyra Mine Minerals writes that it has planned a drilling program in Kirovohrad Oblast "to assess the resource base of the deposit according to international standards."

Another golden permit is held by Ukrainian Stone Company Ltd for the Serhiyivske deposit in Dnipropetrovsk Oblast. Subsoil market participants call this special permit "the only permit with high-quality geology outside the Carpathian region," although we do not see any activity of the company in the public space. The company's beneficiary is Olena Mahda from Dnipro.

However, 49% of the owners of the Ukrainian Stone Company are hiding behind an offshore company in the British Virgin Islands, which does not disclose company owners. Another 49% is owned by the Cyprus-based Clemencia LTD, a company owned by Oleh Kryshyn, MP of the 8th convocation, and his partners Serhiy Nedoluha and Valeriy Hurtovyi. Serhiy Yukhymenko owns 2%.

Kryshyn was previously a co-owner of CMK Corporation. According to The Page data, in May 2022, two companies of CMK Corporation -– Vercon-Trade and Balantonprom – co-owned a company in Russia.

At the end of 2020, a permit to explore gold ores (niobium ores are a related mineral) at the Zhovtovodske deposit in Dnipropetrovsk Oblast was bought for UAH 5.7 million ($156,187) by Spys Ukraine, a company associated with Onur. In an interview with Forbes in September 2023, Emre Karaahmetoglu, General Manager of Onur Group in Ukraine, said that "after investing $10 million, it turned out that the reality is very different from what is written on paper."

There are rumors in the mining market that Spys Ukraine has drilled 12 wells. But no gold was found. According to the National Extractive Industries Association of Ukraine, there are many such cases. They happen because the vast majority of geological exploration was carried out in the ‘80s and ‘90s of the last century. And in order to put up the sites for sale, it is necessary to conduct repeated exploration to verify the validity of the information provided 30-40 years ago.

Also in December 2022, the state-owned Nadra Ukrayiny received a permit to use gold ore deposits in Zakarpattya Oblast: at the Banskyi, Tukalo-Yasenivskiy and Bilopotikskyi ore deposits. We do not observe any moves on this permit.

The last special permit for the use of the currently occupied deposit in Luhansk Oblast through the Ukrainian company Donetsky Kriazh was issued to Lugansk Gold Ltd. registered in Australia. In March 2023, the State Service of Geology and Mineral Resources suspended their permit because Donetsky Kriazh was not listed in the register of beneficiaries.


Beryllium is part of the Ingenuity drone, the first device to fly over the surface of Mars. It is used in a variety of applications, from miniature parts to airplanes to tools for oil drilling and as a component of optics.

According to the US Geological Survey, in 2022, almost 60% of the world's beryllium resources were in the United States. The United States is also a leader in beryllium production, along with China and Mozambique.

Reference. Beryllium is used in nuclear reactors, the automotive industry, X-ray systems, and professional audio systems. It is a component of weapons, targeting systems, surveillance and reconnaissance, and aircraft construction. There is only one special permit for the use of beryllium subsoil in Ukraine.

Beryllium production is well-developed in Kazakhstan. One of the largest producers of beryllium, uranium, and tantalum products, the Ulba Metallurgical Plant, is located there. Several scientific enterprises that studied the properties of beryllium were in Ukraine during the Soviet era. But now they are not working. And beryllium is not being mined.

However, a special permit for beryllium mining has been issued. Perzhanska Ore Company LLC (PRK), which is part of Butkevych's BGV Group Management. It operates at the Perzhanske deposit in Zhytomyr Oblast. Zinc, niobium, and tantalum can also be mined there. The niobium-tantalum alloy is used, for example, in MRI systems.

Perzhanka is one of BGV's two largest projects, which the group presented in June at the Ukraine Recovery Conference 2023 in London. The group is currently preparing a PFS (Pre Feasibility Study) for the field and will soon "be ready to officially present its results to investors."

The Perzhanske deposit is the largest in the world in terms of the scale and quality of genthelvite beryllium mineralization. However, there are two nuances in beryllium mining there. Beryllium is toxic in nature. That is why there are stricter rules and regulations for its extraction all over the world.

According to Ukrainian ecologists, the development of Perzhanka will cause significant environmental damage and negatively affect the hydrological situation not only in the region but also in Ukraine as a whole. This will affect the agricultural sector, climate, etc.

Part of Perzhanka is still located in the Polissia Nature Reserve, where mining is prohibited by law. Environmental organizations argue that beryllium mining in the reserve and adjacent territories will cause irreparable harm to people and the environment. Oleh Lystopad, an expert of the ANTS National Interests Advocacy Network, writes about this damage in detail.

There are also court cases regarding beryllium mining. Administrative lawsuits concerning the ban on beryllium mining were filed by the NGO Protection and Justice and the Kyiv Ecological-Cultural Center. The Zhytomyr Prosecutor's Office also tried to stop the auction of the beryllium special permit through the court. It even succeeded in the lowest court.

The second point is that the company may have obtained the special permit for subsoil use in a dubious manner. The Anti-Corruption Action Center NGO (AntAC) has already covered the criminal proceedings regarding the fact that the State Service of Geology and Mineral Resources, according to the investigation, gave the Perzhanska Ore Company a beryllium deposit illegally. The court register also contains evidence from GeoExpert International, which also wanted to participate in the purchase of a special permit for the Perzhanske deposit in 2019. But it could not. The reason was that the State Service of Geology and Mineral Resources set a discriminatory condition – the mandatory requirement that the bidder have access to state secrets.

BGV Group Management says that in early 2023, the company filed documents with the State Service of Geology and Mineral Resources to remove part of the reserve from the special permit because it "does not conduct and does not intend to conduct its activities there." The auction for the Perzhanka special permit is considered transparent. They also emphasize that the company participated in the court hearings only as a third party.

"All court proceedings resulted in decisions that there were no violations of the law during the sale of the special permit and the procedure for putting it up for auction," BGV comments. "As for the criminal case, it was not initiated against the company, but against officials of the State Service of Geology and Mineral Resources.”

The criminal proceedings were closed three times, but then resumed, which "causes reputational risks." Nevertheless, the group assures that it responds "to all requests from law enforcement agencies."

Lanthanide series metals

In Ukraine, metals of the lanthanide series are recognized as "strategic". The 14 lanthanide elements, as well as scandium, yttrium, and lanthanum, are so-called rare earth elements (REEs).  

According to the US Geological Survey, China, the US, and Australia are the largest producers of REEs. Their deposits are found in China, Vietnam, Russia, and Brazil.

According to the Financial Times, the demand for REEs is growing due to their importance in the production of magnets, which are needed in various fields, from wind turbines to electric vehicles and scooters. REEs are also vital for weapons systems, such as fighter jets.

Reference. Field of use: defense, nuclear power, metallurgy, magnets, ceramics, and chemicals. There are two special permits for subsoil containing lanthanide series metals in Ukraine.

Not all countries exploit their REE resources, as their extraction is often uneconomic. Currently, China dominates the mining, processing, and production of rare earth metals. Last year, it accounted for 70%.

Even in technology areas where Europe has become a global leader, such as wind turbines, it is still dependent on China. Competition is complicated by China's lower social and environmental standards. After all, Europe relies on more expensive labor. There is currently one plant in Europe that extracts rare earth metals for the production of magnets - near the Russian border in the Estonian city of Narva. It belongs to the Canadian company Neo Performance Materials. However the plant is unfinished, and production is scheduled to start only in 2025.

The EU considers the United States and Australia, which supplies 6% of the world's rare earth metals, as an alternative source. Also, in January 2023, the Swedish state-owned mining company LKAB announced the discovery of Europe's largest rare earth deposit. However, it will take 10-15 years to start production at this deposit.

In Ukraine, there are two "rare earth" permits. The first one is for geological exploration of zircon-rare earth ores in the Yastrebetska area of Zhytomyr Oblast, held by TsFR Group LLC. The second one is for the extraction of rare earth ores from the Anadolske field in the occupied Donetsk Oblast - RM Minings LLC.

Despite the fact that neither company has Hennadiy Butkevych on its books, we still place them in Butkevych's orbit of influence. The co-owners of both companies are Oleksandr Nastenko and Vitaliy Yakymenko. And they also have stakes in other companies with strategic permits, the beneficiary of which is Butkevych.

In addition, 83.2% of TsFR Group is owned by Serhiy Voitsekhovsky, who is a member of the board of directors of BGV Group Management. In addition, BGV listed the Yastrebetske field on its website as controlled by the group. At the same time, BGV says that they do not agree with our wording - "orbit of influence".

"The fact that investors have some joint projects with Butkevych does not mean that all the projects of entrepreneurs are influenced by Hennadiy Vladyslavovych," BGV says.

The group also stressed that the billionaire has no relation to other companies in which Nastenko and Yakymenko have stakes, but Butkevych does not.

Deposits that have not been distributed

In addition to the licensed mineral market, there are still deposits that have not been distributed. On February 4, 2023, the Cabinet of Ministers approved a list of 26 "strategic" mineral deposits that will be distributed after the war by the Interagency Commission for the Organization of Conclusion and Implementation of Production Sharing Agreements (PSAs).

Our sources comment on the PSA story with caution. On the one hand, the PSA is better than an auction on the Prozorro platform because an auction is when a business first pays a large sum upfront for a special permit and then explores subsoil, which may not contain anything. Production sharing agreements provide for the possibility to conduct exploration on their own, and then agree with the state on how to divide the earnings.

However, according to our interlocutors, the PSA carries corruption risks, since the fate of the country's most important subsoil is determined by a group of arbitrarily selected people. Therefore, the distribution of strategic subsoil in this way is either "terrible incompetence" or "an attempt at systemic corruption."

PSAs can sometimes work for oil and gas fields: if there is gas, we share it, if not, we don't share it. But solid minerals projects do not have a defined budget and last for years. What if the concentrate is not sold and you need to invest another billion in the plant?

Also, according to the decision of the National Security and Defense Council (NSDC), the tender for the distribution of strategic subsoil requires "disclosure of beneficial owners of tender participants." However, we have been observing beneficiaries in hundreds of extractive companies for years. But do we see, for example, [Rudomain’s Kostiantyn] Karamanits in "strategic" mining special permits? That is why the PSA option looks to some of our sources as non-working and created only to bypass standard procedures for the distribution of subsoil.

We can only hope that by the time strategic subsoil is ditributed, we will be properly prepared for this and other challenges. So far, in off-the-record conversations, subsoil experts have said that Ukraine's great advantage is our infrastructure proximity to Europe and the fact that we have something to extract.

However, the problems include a lack of political will to support most extraction projects, unconstructive activities of law enforcement agencies and courts, lack of state policy in the industry in general, lack of deposits assessed according to international standards, mediocre subsoil reserves or their quality, and, above all, the war. These are serious challenges, and there are more. But they must be accepted. So that Ukraine can get the maximum dividends from its strategic resource.

Reference. How we searched and organized information

The list of special permits before the full-scale invasion was available on the website of the State Service of Geology and Mineral Resources, which issues and revokes these permits. After February 24, 2022, this information was hidden. In June 2023, it was reopened on the portal in a truncated version.

However, due to a large number of errors, the data was removed again and has not yet been updated to the point where an inexperienced user of the website could understand anything. When asked by the AntAC who exactly holds "strategic" permits, the State Service of Geology and Mineral Resources of Ukraine replied that they would not respond, using the wording "in order to avert a threat to national security."

Therefore, we collected the list of special permits for subsoil containing strategic minerals manually, based on the list of Ukrainian "strategic" minerals approved by the National Security and Defense Council in 2021. We used data from the State Service of Geology and Mineral Resources, judicial and other registers, the YouControl analytical system, and the specialized news agency Dozens of extraction market participants were interviewed. This piece also includes users who not only extract but also study subsoil. We also added suspended permits and those that are being extended.

We could have missed a component of a strategic mineral. Or, on the contrary, we could have included it, despite the fact that the content of the mineral in the subsoil is small or its extraction is not economically viable. We also have doubts about some of the persons who are listed as owners or beneficiaries in subsoil user companies - that they own or control a particular business (this is a topic for a separate article). Nevertheless, we think that this piece still shows the "ballpark figure".