The Antimonopoly Committee of Ukraine has established that participants in five auctions of the State Geological Survey of Ukraine acted in concert and artificially simulated competition for licenses for the extraction of granite, amber, sapropel and mineral waters. The territorial branches of the Antimonopoly Committee imposed fines and effectively opened the way for the judicial recognition of such special permits as invalid. This is reported by the specialized publication Nadra.Info with reference to the decisions of the Eastern and Western interregional territorial branches of the Antimonopoly Committee, adopted in late September - early October 2025.
The AMCU has recorded several schemes in which companies did not compete for the right to use the subsoil, but played lots among "their own", inflating the rates for third-party players or, conversely, imitating the struggle, after which the right to the deposit passed into the right hands at a low price. As a result of the consideration of the cases, fines were imposed on participants in five auctions, and the special permits themselves can be canceled through the court as those obtained in violation of competition rules.
Granite: Natalivske deposit, Zaporizhia region
On September 25, 2025, the administrative board of the Eastern Interregional Territorial Department of the Antimonopoly Committee of Ukraine established that LLC "Mokryanskyi Kamyany Karyer" (this is, in fact, LLC "Mokryanskyi Kamyany Karyer No. 3") and LLC "Vector ZM" acted in concert during the Derzhgeonadra auction for the extraction of granite at the Natalivske deposit in Zaporizhia region. Both companies were fined a total of UAH 136,000.
The auction took place back in December 2021. The starting price was UAH 5,852,609. Mokryanskyi Kamyany Karyer No. 3 offered UAH 5,952,609, and Vector ZM won with a symbolic advantage of UAH 5,960,000. There were no other participants. After that, Vector ZM received special permit No. 6612 valid until 2042. The AMCU has been investigating a possible conspiracy since 2023. The companies are linked to Serhiy Kiryushko ("Mokryanskyi Kamyany Karyer No. 3") and Serhiy Tkachenko ("Vector ZM").
Granite: Pivnoplisetsk area
On September 30, 2025, the Eastern MTV of the AMCU recognized that Dalergranit LLC and Transkom-19 LLC committed anti-competitive concerted actions that distorted the results of the auction for the sale of a permit for geological study and experimental and industrial development of the Pivnichny Plysetsk granite site. Both companies received fines in the total amount of UAH 136 thousand.
The scheme looked like this: in October 2021, the bidding started with UAH 213,873. Dalergranit raised the bid to UAH 1,001,000 and formally won, but did not sign the bidding protocol. As a result, the right to the lot went to Transkom-19 for UAH 580,000. Then this company received mining permit No. 6752 for the Pivnichnoplisetske deposit and transferred it to a company from the same orbit — LLC Pivnichnoplisetske deposit of sand and granite. All these structures are controlled by the spouses Svitlana and Valery Samofal, that is, there was no actual competition in the bidding.
Amber: "West First" area, Rivne region
On September 29, 2025, the Western MTV of the AMCU established a conspiracy between LLC Zemresursinvest and LLC Ecocentrresurs during an auction for a special permit to use amber subsoil, which took place back in 2020. It concerned the “Western First” plot in the Sarny district of the Rivne region. The starting price was UAH 159,800, and three participants competed. The winner – Ecocentrresurs – declared a bid of UAH 10.2 million, but then actually “withdrew from the race”, and the special permit was bought by LLC BurProm for a much lower amount – UAH 3.32 million. The total fine for Ecocentrresurs and Zemresursinvest is UAH 69,800.
According to Nadra.Info, all three companies — Ecocentrresurs, Zemresursinvest, and BurProm — are connected through Oleg Bohelsky and Olga Rudkovskaya. Zemresursinvest is part of a group associated with the family of former Minister of Transport and Communications Mykola Rudkovsky, and is already one of the largest amber miners in the country.
Sapropel: Hryvynske deposit
On September 29, 2025, the Western MTV of the AMCU also fined LLC "Syvy Potik" and LLC "Planeta Komfort" for collusion at the auction for the sale of a special permit for the Hryvynske sapropel deposit (the auction took place in April 2023). The starting price was UAH 504,308. "Planeta Komfort" made a bid of UAH 560,000, "Syvy Potik" offered UAH 563,000 and became the winner. There were no other participants. Both companies received fines of UAH 68,000 each.
According to the AMCU, on the same day, these same companies played off two more special permits for other sapropel deposits - Vepryk and Trostne - and were previously the only players in the bidding for the Dovhe deposit. According to the registers, "Syvy Potik" is associated with Maksym Breslavsky, and "Planeta Komfort" is associated with Andriy Dobrosotskov, a business partner of Igor Kohut (FINEX group).
Mineral therapeutic and table waters: Rina site, Vinnytsia region
On October 9, 2025, the Eastern MTV of the AMCU recognized that Ukrainian-Georgian LLC Charte and FOP Mushkudiani M.D. acted in concert during the auction for the sale of a permit for the Rina subsoil site with mineral therapeutic and table waters in Vinnytsia region. Both participants received fines in the total amount of UAH 20,590.
The auction took place back in July 2021. The starting price was UAH 225,120. Individual entrepreneur Mushkudiani offered exactly the starting amount and, in fact, simply "confirmed presence," while Charte added only UAH 10,000 on top — UAH 235,120 — and became the winner. Both participants, as it turned out, are registered at the same address and are associated with Vladimir Bokuchava.
The Antimonopoly Committee qualifies such "collusion" as anticompetitive concerted actions that distort the results of bidding. These are not only fines and a temporary ban on participating in public procurement. The key thing is the legal consequences for the special permits themselves.
Courts already have a practice of invalidating auction results, concluded contracts for the purchase and sale of special permits, and even the special permits themselves, if it is established that the bidding was collusive and there was no actual competition. Such a decision of the Kyiv City Commercial Court in 2023 regarding Murafynska Square (Kharkiv Region) showed that proven collusion is a basis for canceling a subsoil permit as an agreement that contradicts the interests of the state and society.
The AMCU directly emphasizes: establishing collusion between auction participants creates grounds for a judicial appeal and cancellation of a special permit for subsoil use. That is, extraction rights obtained "in a friendly circle" can be seized through the court.
Context
• In most of the described cases, the auctions took place in 2020–2023, but decisions on them are being made only now — in the fall of 2025. This means that some of the permits have already been in operation for several years, and the companies have managed to issue mining rights or even resell them to related entities.
• A number of stories (granite, amber) indicate stable groups of beneficiaries who enter the auctions as several legal entities and then reissue the special permit within their own network.
• The AMCU publishes such decisions openly, and information about collusion is included in the consolidated information on violations of competition law. This may be the basis for excluding such companies from future procurements.
Once the fact of collusion is established, the courts have the final say: they can declare the auction results invalid, terminate the subsoil use agreement, and cancel the special permit. This practice has already been used before, when courts canceled permits purchased through coordinated bidding.
The anti-corruption aspect is obvious: subsoil is a state resource, and collusion at the auction means that the budget did not receive enough money, and the right to extract was obtained by "their" structures under a previously agreed scenario. Now these cases can become the basis not just for fines, but for returning the plots to a normal competitive procedure.
