From 1994 to 2002, Andriy Kliuyev held various senior public positions in municipal and regional councils of the city of Donetsk, as well as in the regional state administration. In particular, Mr. Kliuyev was Deputy Chairman of Viktoy Yanukovych’s Regional State Administration in Donetsk from 1998 to 2002. Andriy Kliuyev was elected to the Verkhovna Rada (Parliament) of Ukraine in 2002. He was appointed Deputy Prime Minister of Ukraine three times between 2002 and 2012.

Since 2001, A. Kliuyev is Deputy Chairman of the Party of Regions of Ukraine. In the 2012 parliamentary elections, he headed the electoral headquarters of the Party of Regions. Moreover, he has been appointed head of Viktor Yanukovych’s electoral headquarters for the presidential elections that are scheduled in 2015.

In March 2013, President Yanukovych officially appointedAndriy Kliuyev as Chairman of Ukraine’s group in charge of preparations for the signing of the Association Agreement with the EU. It is common knowledge that Azarov’s government rejected this agreement, which caused thousands of protests and demonstrations throughout Ukraine. According to the online edition of Ukrayinska Pravda (Ukrainian Truth), it was A. Kliuyev who was responsible for the violent dispersal of peaceful protesters in Kyiv on November 30, 2013. This thesis was confirmed by by Oleksandr Popov’s testimony(Mr. Popov was Head of the Kyiv Municipal State Administration).

Serhiy Kliuyev, Andriy Kliuyev’s brother, has been a deputy from theParty of Regions since 2006. He has also been a member of the National Bank of Ukraine since 2007. He is also in charge of an inter-parliamentary group working with Austria. S. Kliuyev is currently a member of the Parliamentary Committee on Finance and Banking and of the Special Oversight Commission of the Verkhovna Rada of Ukraine on privatization.

The business activities of the Kliuyev brothers are closely linked; it is precisely for this reason that their wealth and business capital are usually regarded as joint assets in Ukraine.

In March 2013, Focus magazine estimated the Kliyev brother’s fortune at 618 million dollars. In 2011-2012, Korespondentmagazine estimated both brothers’ fortune at 130-140 million dollars.

Andriy Kliuyev’s official salary as a public servant amounted to 395,892 UAH in 2012. According to his tax declaration, A. Kliuyev did not have any revenues or profits from abroad.

Serhiy Kliuyev’s official salary as a public servant totaled 189,561 UAH in 2011. That same year, he made a profit amounting to 946 UAH abroad.

Serhiy and Andriy Kliuyev resideon luxury estates near Kyiv.

In September 2013, Serhiy Kliuyev bought Tantalit LLC for 146.6 million UAH,which leases a luxurious residence in Mezhyhiryato Viktor Yanukovych, the President of Ukraine.

The Official Residence of a Business Empire in Austria

The Kliuyev family business empire is centered around Zavod Napivprovidnykiv PrJSCandUkrpidshypnyk PrJSC, whose ownership was registered through two Austrian companies – ActivSolarGmbHandSlavHandelVertretungundBeteiligungAG (SlavAG). Both Activ Solar GmbH and Slav AG are listed at the Austrian bank UniCredit Bank Austria AG, 1010 Vienna, and both are registered at the same address – 35 Wipplingerstrasse, 1010 Vienna.

The Kliuyev brothers own more than 70 companies in Ukraine that are directly or indirectly related to the above-mentioned Austrian holding companies. These include large industrial plants, financial holding companies, banks and front companies that are used to optimize taxation, develop budget funds and inhibit the identity of the actual business owner. Moreover, their business empire includes dozens of offshore companies in Cyprus, the Netherlands, Luxembourg and many other countries in Europe and around the world. These companies operate thanks to important groups of professional international lawyers and experts in offshore business.

Slav AG was founded in 1994 and is completely owned by the Kliuyev brothers. Ms. Iryna Kliuyev, Serhiy Kliuyev’s wife, is a member of the board of directors. She is also registeredat 12 Groissaustrasse, Tulbinger (an expensive suburban building owned by the Austrian company GBM Handels-und Vertretungs GmbH). The shareholders of GBM are composed of two legal entities – Bulinga Ventures LLC and Revaldo Holdings Ltd.

As of December 2013, Slav AG showed a turnover amounting to 108,990,000 euros. The company seems to be very successful and profitable. Through its subsidiaries, Slav Ag is engaged in renewable energy, financial services and business development. The company provides a wide range of services – loans, deposits, securities holding, gold trading, accounts for investment transactions and insurance services. In addition, the company sells various metal products and boilers. Slav AG runs operations in the CIS countries, Poland, the Czech Republic, Macedonia, Bulgaria, Israel, Denmark, Hungary, Romania, France, Turkey, Russia, Kazakhstan, Great Britain, India, the Netherlands, Pakistan, Slovakia, Slovenia and Switzerland. Slav AG is the majority owner of the Gazometer Business Centre in Austria. Slav Handel shares were placed on the Austrian stock market by the end of 2009.

Activ Solar GmbH was registered in Austria on February 15, 2008 by Slav Beteiligung GmbH, which, in turn, was founded on December 7, 2005 and is owned by Slav AG. At the end of 2008, Kaveh Ertefai, Serhiy Kliuyev’s son-in-law, became the sole owner of Activ Solar GmbH. Kaveh Ertefai is also the director of a subsidiary of Activ Solar GmbH in Cyprus – AST ACTIV SOLAR TRADING LTD. Information and videos about Olha Kliuyev (Serhiy Kliuyev’s daughter) and Kaveh Ertefai’s expensive wedding in Liechtenstein Palace in Vienna can be easily found on the Internet.

Since July 2009, 100 % of the shares of Activ Solar GmbH have been controlled by P&A Corporate Trust in Liechtenstein, which is managed by a lawyer called Reinhard Proksch. Andriy Kliuyev’s son, Bohdan, is the Business Development Manager of Aktiv Solar LLC, the Ukrainian subsidiary of Activ Solar GmbH.

Activ Solar GmbH is currently the largest producer of solar energy in Ukraine. In June 2013, in an interview with Bloomberg, Kaveh Ertefai stated that the company plans to extend its achievements in solar energy development in Ukraine to the Middle East, particularly to the United Arab Emirates, Qatar and Jordan. Moreover, the company also invested in energy projects in the U.S. in 2012, and plans to invest in Mexico.

How Activ Solar GmbH became the largest and most successful producer of solar energy in Ukraine…

On its website, Activ Solar GmbH reports that it is building eleven power plantsin Ukraine, ten of which have been completed. These power plants are located in three regions of Ukraine, namely Odesa, Mykolayiv and Crimea. According to the Activ Solar website, the development of these power stationsinvolves planning, searching for and structuring financing, as well as building and managing ready sites.

According to Mykhailo Cherevko, Director of Activ Solar LLC, the Ukrainian representative company of Activ Solar GmbH, the company invested 8.1 billion UAH in the Crimean power plant alone. Once again, according to Mr, Chernenko, these investments were basically loans from foreign banks; not a single penny was taken from budget funds for the construction of these stations.

However, there are reasonable grounds to believe that Activ Solar owes its success to the full support of the Ukrainian government and the assistance of the highest state authorities, particularly those where Andriy and Serhiy Kliuyev work and exercise a certain influence.

Who owns the power plants?

The elevensolar power plants,mentionedon Activ Solar GmbH’s website,are used by 28Ukrainian companies, which are officiallylicensed toproduce solarelectricity.25 of them are already using the green tariff rate, which was introduced inUkrainein 2008, when several amendments were adopted to the Lawof Ukraine“On electric power engineering”.

The companies were registeredbetween2009 and 2012.They havesimilar names, similar official addresses and management, as well as an impressive network of offshore ownerships.

For example, the Perovo Power Plant, which has the largest industrial facilities in the world, is registered in the name of five companies: Delta Solar,Zeta Solar, Alpha Solar, Beta Solarand Gamma Solar. They were all registered on June 23-25, 2010 at 12/4 SERGEYEVA-TSENSKOHO/TURETSKA STREET, Tsentralny District, Simferopol, 95011, Autonomous Republic of Crimea, and they both have a common executive director – Roman Viktorovych Kovalenko. The founder of the companies was either the Austrian company Activ Solar GmbH or its subsidiary company Activ Solar, the address of which is identical to Serhiy Kliuyev’s public reception office at 3 Reznitska Street in Kyiv.

Activ Solar GmbH invested 488.7 million UAH in Delta Solar, which it also controlled until 2013. Recently, this portion of Delta Solar’s authorized capital was purchased by another Austrian company – BlackSeaRenewableEnergiesGMBH, founded on March 25, 2011. The latter owns Aurnia Commercial Ltd in Cyprus, founded in February, 2011. The newly-formed Aurnia Commercial Ltd, with an authorized capital amounting to 1,000 euros, somehow managed to raise the necessary funds and “invest” about 900 million UAH in Ukrainian solar companies, purchasing a controlling stake in Zeta-, Alpha-, Beta- and Gamma- Solar. Moreover, these “investment transactions” took place outside of Ukraine, as the de jure Cyprus company was meant to buy an authorized portion of the Austrian company Activ Solar GmbH.

The Austrian company Black Sea Renewable Energies GMBH also “invested” about 40 million UAH in the Rodnikovoye Power Plant, which is registered in the name of Crimea Solar 1, Crimea Solar 2, Crimea Solar 3, Crimea Solar 4, and Crimea Solar 5.

The owner of the Black Sea Renewable Energies GMBH is another Austrian company CEE Clean Economic Energy AG, which belongs to CEE CLEAN ECONOMIC ENERGY HOLDINGS .A.R.L., established in Luxemburg in 2012. The latter is, in turn, owned by CEE CLEAN ECONOMIC ENERGY HOLDINGs Limited in Jersey, the director of which is Michael George Jeffrey, a UK resident who works at the Carey Olsen Law Firm, which specializes in servicing offshore business companies. The end owner in Jersey is hidden.

The Okhotnikovo and Limanska Power Plants are registered to six Ukrainian clone companies – Omao Solar, Ospriy Solar, Oriol Solar, Ouzil Solar, Limanska Energy 1, and Limanska Energy 2 – with a total authorized capital of 1 billion 270 million UAH, which are owned by HyperionNetherlandsB.V., established on April 2, 2013 with an authorized capital of one euro. Hyperion Netherlands B.V. is, in turn, owned by another Dutch company Larnaca B.V.with an authorized capital of 18,000 euros, the owner and executive director of which is Marcus Jacobus Maria Hollander.

The Starokozacha and Dunayska Power Plants are registered in the name of Dunayska SES-1, Dunayska SES-2, Franko Solar таFranko Piwi. All four companies with a total authorized capital are owned by Helios Netherlands B.V.with an authorized capital of one euro. In fact, this company was coincidentally established on April 2, 2013. Another Dutch company and three Luxembourg firms finally lead us to the end owner of Helios Netherlands B.V. – Fiduciaire Probitas S.a.r.l, the managing partner of which is a certified Dutch auditor, Stéphane Spedener.

The end owners of the Mitiayevo, Mykolayivka and Bolhrad Power Plants are five Cyprus nationals, who have a 100% equity stake as Cyprus “investors” (with an authorized capital of 1,000 euros). In total, these five persons invested one billion 650 million UAH in the Ukrainian companies Owl Solar,Orion Solar, Clarion Solar, Capella Solarand Bolhrad Solar through the following Cyprus companies – Krasolena Investment LTD,Koltreso Commercial LTD and KVALISTO HOLDINGS LTD. In fact, all these funds should end up on the accounts of the previous owner of the Ukrainian solar companies – Activ Solar GmbH of Austria.

The Pryozerna Power Plant is registered to Pryozerne 1 and Pryozerne 2, which belong to the Dutch company AbHolom B.V. with an authorized capital of 18,000 euros and the Cyprus company – Gunaldi Commercial Ltd. with an authorized capital of 1,000 euros. The owners of the Cyprus company are two Cypriots. The owner of the Dutch “investor” is not known, but the executive director is Zuidema Hendrikus.

Only the Voznesenska Power Plant is still directly owned by Solar Activ Solar GmbH through Neptune Solar; the former invested 239.8 million UAH. Based on the trends described above, we can expect to soon see the sale of this power station to different newly-formed offshore companies.

In summary, 28 Ukrainian companies belonging to a number of newly-formed offshore companies with an authorized capital ranging from one to 1,000 euros from Cyprus, the Netherlands and Luxembourg, have a license to produce solar electricity in Ukraine. These companies are allowed to sell solar electric power to the state at the highest Green Tariff rate in Europe until 2030. In 2013, the state paid 1.6 billion UAH for solar electric energy to companies from the Aktiv Solar Group. In subsequent years this amount will increase as only a few power plants have been put into operation and new ones are still being built.

These numerous facts and pieces of evidence indicate that Andriy and Serhiy Kliuyev are the actual beneficial owners of these 28 companies in Ukraine and of the fore-mentioned network of offshore companies.

The Green Tariff

The Green Tariff in Ukraine is a special rate, whereby electric power is purchased from producers of alternative energy sources. Solar energy in Ukraine is purchased by the state for 505.09 copecks, while nuclear power costs 21 kopecks per one kWh. This constitutes the highest Green Tariff rate in Europe. It will be effective until 2030. By that year, alternative energy will satisfy the needs of no more than 5% of the Ukrainian market.

In Ukraine, all electric power producers sell their product on the wholesale market, which is controlled by the state-owned company Ukrenergo. Ukrenergo, in turn, markets the production to Oblenergo, which provides electricity to end consumers – individuals and legal entities. In summary, all the residents of Ukraine end up paying the Green Tariff rate to solar power plants.

As of November, 2012, the rule on local content was added to the legislative regulation on solar energy; it stipulates that a 30% of the content of electric power facilities must be of Ukrainian origin in order to benefit from the Green Tariff rate. This prerequisite was extended to include facilities, which were built as of January 1, 2012 and which were put into operation before January 2013. Sites that are put into operation before January1, 2014 should have 50% of local content. The rule on local content has been in force since 2008, but it was deferred as there was no approved order for specific calculations before October, 2012.

Experts and investors of the solar electric power market have made very critical comments on the provision concerning “local content” as no one in Ukraine actually manufactures machinery, equipment and materials for the solar power industry. Foreign manufacturers have not had time to prepare for such discriminatory rules. However, one foreign investor has been systematically working to produce local content for solar electricity since 2008. The name of this investor is Activ Solar GmbH, which has been operating Zavod Napivprovidnykiv PrJSC since 2008.

Manufacturers of solar electricity may satisfy the rule on local content by using Ukrainian-produced polycrystalline silicon, as stipulated in Article 17-3 of the Law of Ukraine “On electric power engineering”:

b) for electric power facilities, including commissioned newly-built electric power plants (launched complexes), which produce electric energy generated by solar power:

Local content elements	Operations, which should be implemented on the territory of Ukraine	Fixed share,%
polycrystalline silicon	production	32
Monocrystalline, multicrystalline or pseudo-monocrystalline solutions	production	13
Monocrystalline or multicrystalline plates	production	7
Photoelectric elements	production	20
Photoelectric modules	assembly	23
Construction work	execution	5
Total		100%

Polycrystalline siliconis produced by ActivSolarGmbHat the industrialfacilities of Zavod Napivprovidnykiv PrJSC.

Zavod Napivprovidnykiv PrJSC: gold polysilicon

Zavod Napivprovidnykiv PrJSC was established in 2002 after the reorganization of Zavod Napivprovidnykiv OJSC, which had been created during the Soviet era and was part of the Zaporizhya Titanium and Magnesium Plant.

By the second quarter of 2007, the plant was taken over by the state.

As of the third quarter of 2007, 75 % of the property was transferred to Silicon LLC, which then transferred its share to SI-INVEST by the fourth quarter of 2007. As of the first quarter of 2008, SI-INVEST had a 99 % equity stake in the plant, having bought out the government’s share. 75 % of the share of the plant was transferred to Activ Solar in the fourth quarter of 2008. It should be noted that the plant was privatized when Viktor Yanukovych was Prime Minister of Ukraine and Andriy Kliuyev was Deputy Prime Minister.

In 2009 – early 2010, as Zavod Napivprovidnykiv PrJSC was not a profitable enterprise, several loan agreements totaling close to 458 million euros were signed with the state-owned Ukreximbank JSC.

The loans were allocated to finance an investment project for modern production of trichlorosilane, polysilicon and monosilicon. Assets and property rights to foreign trade contracts on supplying equipment, as well as future products were used as collateral for these loans. This means that a state-owned bank issued a huge loan secured by non-liquid assets (equipment) and illiquid future products to an unprofitable enterprise owned by an Austrian company. The decision to grant such an important amount of risky loans should be taken at the highest level of Ukreximbank JSC. However, the bank is monitored by a higher administrative body – the Special Oversight Council, whose members are appointed by the President, the Cabinet of Ministers and the Verkhovna Rada (Parliament) of Ukraine (five persons each).

In October 2010, the State Commission for the coordination of activities related to the implementation of investment projects approved the decision to provide financial assistance amounting to almost 200 million UAH to Zavod Napivprovidnykiv PrJSC. This assistance was provided “for the implementation of the innovative project “Creating a vertically integrated company producing photovoltaic products”. Zavod Napivprovidnykiv received compensation amounting to 200 million UAH for interest rates on loans, which the plant had obtained from the state-owned Ukreximbank a few months before. It was Andriy Kliuyev himself who was in charge of the State Commission.

Thanks to generous “investments” from the state budget and loans from a state-owned bank, Zavod Napivprovidnykiv PrJSC launched the first production of polysilicon. A full cycle of polysilicon production was launched in 2011.

Thus, the Activ Solar Group was ensured long-term access to polysilicon, which the company obviously uses to build solar power plants, through state funds. In addition, Zavod Napivprovidnykiv received a guaranteed market for their products – new manufacturers of solar electricity will be obliged to purchase polysilicon produced by the plant in order to ensure state requirements for local content.

Tax Benefits

A Green Tariff rate, multimillion loans from state-owned banks and direct financial assistance from the state – these are far from all the state privileges enjoyed by the Activ Solar Group. In accordance with paragraph 16, Article 197 of the Tax Code of Ukraineanditem16, paragraph 1, Article 282 of the Customs Code of Ukraine, the following are exempt from VAT and customs duty – machinery, equipment, components and materials used for the production of solar electricity.

In addition, according to paragraphs 1,2, Article 158 of the Tax Code of Ukraine, enterprises implementing energy-efficient projects are exempt from paying a profit tax by 50%. Companies, which sell equipment, materials and raw materials used to produce electricity from alternative sources, must pay an 80% profit tax on such transactions. It is evident that the fore-mentioned rule is most beneficial to Zavod Napivprovidnykiv PrJSC, which produces polysilicon.

Land

Solar electric power plants, created by Activ Solar GmbH in Ukraine, are built on land that the government has distributed generously to groups of related newly-formed companies through preferential long-term lease agreements. In January 2012, the Council of Ministers of Crimea allocated a 49-year lease for a 336-hectare land plot to eight companies for the construction of solar power plants. In particular, Bora Solar and Calypso Solar LLC received 50 hectares each in the Kirov Region of Crimea, and Canary Solar, Clarion Solar and Lyennet Solar received 40 hectares each. Moreover, 40 hectares were allocated to Orion Solar and Jupiter Solar, and 36 hectares to Capella Solar for the construction of power plants near Mykolayivka. Incidentally, the last power plant has been completed and incorporated into Activ Solar GmbH’s projects.

In addition, in April 2012, the Council of Ministers of Crimea allocated 540hectaresof land to 17 companies for the construction of facilities producing solar electricity. The names of all 17 companies are related as they contain the word “Solar” or “Piwi” paired with additional letters of the Greek alphabet, or the names of planets. Information from the Unified State Register confirm the supposition that these firms are included in the Activ Solar Group as they often have the same registration address, the same executive director, and the same founding companies, among which we can find Activ Solar Gbmh and/or Activ Solar LLC.

The allocation of land was changed from agricultural land to power engineering land. In April, 2012, the Council of Ministers of Crimea issued an immediate decision on the allocation of 23 land plots totaling 646 hectares to 20 companies with a required discussion period of 2-5 minutes.

Using budget funds to connect to the national grid

The state ensures the connection of solar energy facilities to the national grid. Hundreds of millions of hryvnias (UAH) from the state budget have been assigned to the “state target programme for energy efficiency and the development of energy production from renewable energy sources and alternative fuels” for 2010-2015.

In 2011, the Ministry of Energy and Coal Mining held a tender for 69.69 million UAH for the construction of a 110-kV, 1.72-km power transmission line SES (from Sonyachna to Artsyz) and a nearby unit with video surveillance to protect perimeters. The Dunayska Power Plant belonging to Activ Solar GmbH operates in the Artsyz District of the Odesa Region. The tender was won by Zvyazotekhservice LLC, the co-founder of which happens to be De Sanctis-Invest. The latter was, in turn, established by the Austrian company De Sanctis Holding GmbH, which is controlled by Reinhard Proksch.

In general, from 2011 to early 2013, Zvyazotekhservice LLC won state tenders amounting to 382.32 million UAH to connect solar energy sites of the Activ Solar Group to the national grid.

We remind you that Reinhard Proksch also controls P&A Corporate Services Trust, which is the full 100 % owner of Activ Solar GmbH.

The President lobbies the Kliuyev brothers’ solar business interests in China

Despite a serious political crisis in the country and protests voiced by hundreds of thousands of people, the President of Ukraine Viktor Yanukovych made a working visit to China on December 3, 2013. A framework agreement on alternative power engineering was concluded between the Ukrainian company Greentech Energy LLC and the Chinese National Building Materials Group of Corporations and the Chinese Export and Credit Insurance Corporation (SINOSURE). The agreement “defined the basic principles and preconditions for attracting direct investments and project financing from China to the construction and development of different projects in the field of renewable energy in Ukraine with an installed capacity of over one GW.” It is expected that Greentech Energy LLC will receive several hundred million euros in investments.

Investigations by the magazine Insiderrevealed a link between this company and several companies of the Activ Solar Group. In particular, the history of Greentech Energy’s ownership structure is connected with a company based on the British Virgin Islands (BVI) – namely Merandal Investments, which once owned a Cyprus offshore company – Krasolena Investment. The latter is the co-owner of several companies of the Active Solar Group, including Activ Solar’s Mitiayevo Power Plant. From the founding of Greentech Energy to December, 2011, the CEO of the company was Serhiy Kolobov, who also managed the following companies – Crimea Solar 1, Crimea Solar 2, Crimea Solar 3, Crimea Solar 4 and Crimea Solar 5, all of which control the Rodnykovo Power Plant. The magazine cites other evidence pointing to links between Greentech Energy and the Activ Solar Group.

Conclusion: Activ Solar GmbH’s formula for success

If we make a brief summary of the above-mentioned facts, Activ Solar GmbH’s formula for success, the actual owners of which happen to be Serhiy and Andriy Kliuyev, will look as follows:

1. Privatize a state factory.
2. Get a loan from a state-owned bank in order to organize the production of polysilicon (458 million euros).
3. Pay interest on the loan thanks to assistance from the state budget (200 million UAH)
4. Exempt the plant from paying profit tax from polysilicon sales.
5. Register some five dozen clone companies in Ukraine, which will buy the polysilicon from the company for the construction of power plants.
6. Import equipment for the construction of solar power plants that is exempt from customs duties and VAT.
7. Obtain a preferential leasing agreement from the state for several hundred hectares, making prior changes to their intended purpose.
8. Register already built power plants in the name of about three dozen clone companies, which obtain a license to sell solar energy, and are accordingly eligible for the Green Tariff rate until 2030.
9. At the state’s expense, build a power transmission line, which will connect all the solar power plants of Activ Solar GmbH to the national grid. Win all state tenders to carry out this work.
10. Completely monopolize the Ukrainian market for the next 27 years by requiring all new power plants to use locally produced materials, machinery and equipment for solar power engineering.
11. Make the “foreign investments” visible: register all clone companies, which receive at least 1.5 billion UAH from the state every year, in the name of an entire network of unknown front companies in Austria, the Netherlands, Luxembourg and Cyprus and in the name of a few professional foreign lawyers acting as intermediaries.
12. Use the profits stripped from Ukraine and taken out of the country to implement new investment solar engineering projects in the U.S., Mexico, the United Arab Emirates and other countries.
13. Instruct the President of Ukraine to actively lobby for new business projects and new “investments” for Activ Solar during his working visits abroad.

Finally: if the citizens of Ukraine are not happy with the formula for success of an Austrian investment company with Ukrainian roots and hundreds of thousands of people come out to protest in the streets, then proceed to disperse them by force, discredit and intimidate them, and beat up a few journalists.

What should be done…

This is only a part of the “business scheme” instigated by the Kliuyev brothers.

All the information has been collected from open sources and publicly available information. Obviously, if law enforcement officers began investigating such schemes and had access to classified information (bank transactions, accounting source documents, etc.), they could formally prove the criminal nature of such a business scheme and qualify it as money laundering and abuse of office. They could at least check the information published in the media on companies of the Activ Solar Group being extended aloan totaling 2.6 billion UAH from the state-owned Oshchadbank in order to build power plants.

Ukrainian law enforcement officers will not do this because they are completely controlled by the president and the executive vertical branch of the government. In addition, they are now terribly busy preparing provocation against investigating journalists and peaceful demonstrators in Ukraine.

However, we believe that the law enforcement authorities in Austria, Cyprus, the Netherlands, Luxembourg and the United States have sufficient grounds to institute criminal proceedings on money laundering charges.

First, Western law enforcement authorities could check from where newly-formed companies from Austria, Cyprus, Luxembourg and the Netherlands, with an authorized capital of one to 1,000 euros, received hundreds of millions of euros for the purchase of a controlling stake in companies belonging to the Activ Solar Group in Ukraine. All they need to do is gain access to the initial financial documents of all the offshore companies within the ownership structure of the Activ Solar Group.

Second, Western law enforcement authorities could check transactions between Activ Solar GmbH and its subsidiaries and the offshore companies mentioned above.

Third, Western law enforcement authorities could approach Mr. Stéphane Spedener from Luxembourg, Marcus Jacobus Maria Hollander from the Netherlands, Michael George Jeffrey from Great Britain and Cypriot citizens ΑΡΙΑΔΝΗ ΝΕΟΚΛΕΟΥΣ, ΔΕΣΠΩ ΣΩΚΡΑΤΟΥΣ, ΕΛΈΝΗ ΠΑΠΑΧΡΙΣΤΟΔΟΎΛΟΥ ΨΙΝΤΡΟΥ, ΖΩΗ ΘΩΑΝΝΟΤ and ΠΑΝΑΓΘΩΣΑ ΥΡΘΣΟΦΗ, and of course Reinhard Proksch from Liechtenstein. These “shareholders”, lawyers and auditors should be asked why they do not perform their duty and identify their client, as well as verify the source of his wealth.

And finally, who is the actual owner of the above-mentioned companies? Who are the real directors and/or owners that are officially represented by these individuals?

To be continued…

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