Around the Stynavskyi oil and gas field in Lviv region, a real detective story is unfolding. It began long ago, back during Yanukovych’s time, when a company linked to then-Minister of Ecology Mykola Zlochevskyi received a license for its development. Later, the license was revoked, and logically, the rights to extraction should have been put up for auction.

That was indeed the direction things were heading, but after the state-owned Ukrnafta attempted to do so, it suddenly emerged that the Stynavske field overlaps in boundaries with the Semyhynivske field, the special permit for which belongs to LLC “Pari Naftogaz,” owned by Mykola Zlochevskyi’s daughters Anna and Karina.

The fields do not merely overlap in boundaries. The key issue is that the permit held by “Pari Naftogaz” contains no depth restriction on subsoil use, even though the productive horizons of the two fields differ by only five meters: 2,800–3,600 meters for Stynavske and 3,605–4,540 meters for Semyhynivske. In the current version of the “Pari Naftogaz” license, issued in July 2022, no depth limits are specified.

In other words, the two fields lie one above the other. The discrepancy in the licenses stems from the fact that on the surface the two fields partially overlap, yet their known deposits lie at different depths. The license of “Pari Naftogaz” does not indicate the upper and lower depth boundaries of the area.

The scandal arose for entirely obvious reasons: if the absence of depth limits allows “Pari Naftogaz’s” license to be interpreted as covering the entire vertical volume of subsoil beneath the adjacent territory, this can also be read as the right to extract minerals at any depth.

And the key question here is equally obvious: why was depth omitted from the permit when the protocol of the State Commission on Mineral Reserves defines the interval of the Semyhynivske field deposits as 3,605–4,540 meters? The answer suggests itself, but if one digs deeper and carefully examines not only journalistic publications but also official documents, the picture turns out to be far more serious than it first appears.

Geological information as a separate asset

The most interesting details appear in indirect documents that allow tracing the history of “Pari Naftogaz,” its geological assets, and financial relations. One such document is the Supreme Court ruling of 18 December 2025 in case No. 320/35831/24. Formally, it concerns a financial dispute between LLC “Pari” and the tax authority. Yet its text describes corporate decisions, the transfer of a special permit, the purchase of seismic survey results, and relations with other extraction companies.

In the previous paragraph, the name LLC “Pari” immediately stands out, as it does not appear anywhere in the scandal over the auction that was never held. Meanwhile, LLC “Pari” has the most direct connection to it. This becomes clear during the study of the tax dispute.

It turns out that on 17 September 2021, a new company — LLC “Pari Naftogaz” — was spun off from LLC “Pari.” The new legal entity received special permit No. 5398 for subsoil use at the Semyhynivske field, originally issued on 25 October 2011.

LLC “Pari Naftogaz” was registered on 7 December 2021. The company’s public record lists Andriy Pavliv as director, the Cypriot company Semyhynivske Holdings Limited as founder, and Anna and Karina Zlochevskyi as ultimate beneficiaries.

Earlier, on 30 March 2021, LLC “Pari” signed a contract with “Geoyunit” for seismic survey work. These studies were intended to clarify the geological structure of the area, identify prospective hydrocarbon traps, and prepare recommendations for deep drilling.

When the permit was transferred to the new company, the results of the work still required separate formalization. The court document states that on 9 January 2023, LLC “Pari” and LLC “Pari Naftogaz” concluded contract No. 15-K/P. Its subject was the documented results of seismic data interpretation and the construction of a structural model of the Semyhynivske field — a report on paper and in electronic form.

Licensing loopholes and multimillion-dollar schemes: How Zlochevsky’s companies seek to seize Ukraine’s oil and gas reserves

In other words, the special permit and geological information became objects of separate legal transactions. This is an important circumstance for understanding how the asset of the company that obtained the right to use the field was formed.

And here two fundamental questions arise: what specific geological data were transferred to “Pari Naftogaz” and whether they were used in designing extraction on areas adjacent to the Stynavskyi field? Also — what documents confirm that the actual use of these data complies with the boundaries and conditions of the special permit?

Of course, answers to these questions are not found in this court ruling — it was a tax dispute, and the license and change of its owner were of no interest to the court. But the devil is in the details: the course of this case shows that preparing the Semyhynivske area for development included not only obtaining the license but also costly research, the results of which could be managed by a separate company.

The Pylypivske field and the strange forgetfulness of the prosecutor’s office

The interesting details do not end there. They are extremely important for understanding how Mykola Zlochevskyi conducted business. The same court document describes relations between LLC “Pari” and the company “Binengo” related to the development of the Pylypivske gas field.

The parties concluded a production cooperation agreement on 16 July 2018. It provided for joint activities in drilling, equipping, and operating wells. Initially, net profit from the sale of extracted hydrocarbons after taxes and mandatory payments was to be divided equally between the participants; however, an additional agreement of 2 August 2023 changed the profit-sharing ratio: for the period from 16 October 2023 to 15 October 2024, “Pari’s” share was 30% and “Binengo’s” — 70%. Starting from 16 October 2024, the agreement provided for a return to a 50-50 ratio.

Licensing loopholes and multimillion-dollar schemes: How Zlochevsky’s companies seek to seize Ukraine’s oil and gas reserves

However, what interests us is not the distribution of money but the Pylypivske field itself. And it turns out that its fate also contains many interesting twists. In 2011, the company “Pari” received special permit No. 5384 for gas extraction at this field. In 2016, the Specialized Anti-Corruption Prosecutor’s Office attempted to annul the license through the courts, claiming that procedural requirements had been violated during its issuance, particularly regarding approval by the Ivano-Frankivsk Regional Council.

In June 2017, the Higher Administrative Court of Ukraine dismissed the prosecutor’s claim due to missing the deadline for filing the lawsuit. The permit remained in force. Of course, nothing can be asserted with certainty, but the missed deadlines by the prosecutor’s office here appear just as dissonant a detail as the strange forgetfulness regarding the indication of horizon depths at the Semyhynivske field.

Licensing loopholes and multimillion-dollar schemes: How Zlochevsky’s companies seek to seize Ukraine’s oil and gas reserves

In this same context, it should be recalled that shortly before this, the prosecutor’s office lost an appeal regarding the annulment of four more special permits issued to “Pari” and two other Zlochevskyi companies — LLC “Technoresurs” and LLC “Nadragaz.” The reason was the same — SAPO missed the deadline for filing the claims.

Dispute over gas prices

The same tax case also involves a dispute over the sale of natural gas by LLC “Pari” in 2019–2023. The tax authority claimed that the company sold gas at prices below ordinary market levels, which, according to its calculations, resulted in an understatement of the financial result by UAH 465.18 million.

The courts disagreed with the tax authority’s approach, and the Supreme Court upheld the conclusions of the lower courts.

This episode cannot be presented as evidence of tax evasion: the outcome of the court proceedings favored the company on the relevant disputed issues. Nevertheless, it illustrates the scale of financial operations in the extraction business and the need to analyze not only licenses but also gas sales contracts, the structure of counterparties, and cash flows.

A bit about money

The financial statements of LLC “Pari Naftogaz” show figures that deserve separate verification: in 2025, the company reported assets of UAH 174.5 million, liabilities of UAH 217.9 million, and a net loss of UAH 12.5 million. Meanwhile, for 2026, significantly changed quarterly indicators are reported: assets — UAH 417.8 million, liabilities — UAH 501.3 million, loss for the reported period — UAH 40 million.

Licensing loopholes and multimillion-dollar schemes: How Zlochevsky’s companies seek to seize Ukraine’s oil and gas reserves

These figures do not in themselves indicate violations, but they raise new questions. From what sources were the geological exploration works financed? What loans, intra-group settlements, and liabilities formed the balance sheet? How were rights to geological information and seismic survey results reflected? How did assets change after the transfer of the special permit and corporate changes?

Separately, it is important to establish what lies behind the growth of assets in 2026: new investments, revaluation, intra-group transfer of property, or another factor. But this requires financial statements and primary documents accessible only to state authorities.

The 2011 license

Now let us return to the license that triggered the scandal. And in the context of the above, the version of “forgetfulness” by someone involved in indicating the depth of the development horizon raises, to put it mildly, well-founded doubts.

If this were not Ukraine, the executor would long ago have struck a deal with the investigation and revealed the necessary details. In particular, why, given the different intervals of deposit occurrence, the dispute over the areas is considered mainly through the overlap of their boundaries on the surface.

At the same time, it should be understood that the five-meter difference in depth between the indicated intervals does not in itself prove the absence of any geological connections between the deposits and does not allow, without studying the design documentation, to conclude that one development cannot affect the other.

If no lower boundary of the area is defined in the documents, the question arises as to how exactly the regulator interprets the boundaries of the granted right and what restrictions follow from the documents on the basis of which the permit was issued.

Here emerges the most important contradiction of the entire story. On the one hand, the geological reserves referenced in the investigation materials have a specific interval of occurrence. On the other — the wording of the current permit form does not contain a corresponding depth restriction.

If this information is confirmed by a complete set of documents, the question arises whether the discrepancy between the geological justification and the text of the license creates an unjustifiably broad interpretation of the rights of a private subsoil user. Spoiler: it does. With all the consequences.