181 Million in Charter Capital and Retainers Amid Raids: How a Relocated Sievierodonetsk Enterprise Operates Out of Dnipro and Kyiv

While hundreds of thousands of internally displaced persons (IDPs) from the Luhansk region await temporary housing options, budget resources from occupied Sievierodonetsk continue to fund municipal corporate entities whose operating infrastructure remains behind enemy lines.

Official records from the Sievierodonetsk City Military Administration (MVA) show a pattern of massive capital injections into a communal utility. While zero housing units have been provided to displaced residents, public funds have financed commercial office leases in major cities and direct-award legal retainers executed amidst law enforcement operations by the Security Service of Ukraine (SBU).

181.5 Million UAH in Equity Injections and Zero Completed Apartments

Under Executive Order № 155 BA of April 2, 2026, the Head of the Sievierodonetsk MVA approved the 2025 performance report for the communal enterprise "Sievierodonetsk Investment and Development Agency" (KP "SAIR", EDRPOU code 34306262), led by Director Alyona Prysiajna.

The financial data in the report indicates the following allocations:

The organization's core programmatic objective—securing housing for displaced citizens—stands at zero delivery. Rather than constructing residential assets, funds were utilized for preliminary engineering, topography, and surveying across a 2.24-hectare land parcel located in the village of Khalepya, Obukhiv district, Kyiv region.

Operating Footprint: Offices in Dnipro and the Capital

The enterprise's day-to-day operations are located far from the Luhansk front line. By MVA Executive Order № 290 BA/2026 of June 9, 2026, the formal operating location of KP "SAIR" was established at: Dnipro, 5 Yevropeyska Street, Offices 502 and 513.

The budget report lists commercial lease payments under expenditure code KEKV 2240:

• A 27.5 m² office in Dnipro;
• A 108 m² administrative office in Kyiv;
• Storage units and a metallic shed totaling 62.2 m².

At the end of the reporting period, the entity maintained 18 staff members, drawing more than 3.8 million UAH in payroll supported by public funding.

Absence of 2024 Accounting Records: Statutory War Exemptions

In response to a formal Freedom of Information request, the Head of the Sievierodonetsk MVA, Yevgenia Boyko, stated in official correspondence (Ref. № 23 BC/ZG/01 of September 17, 2026) that the administration holds no financial performance documentation for KP "SAIR" for the 2024 calendar year.

The authority attributed the absence of an approved financial plan to the repeal of the Economic Code of Ukraine on August 28, 2025 (Law № 4196-IX), and cited wartime legislation protecting reporting entities, which allows enterprises to defer financial and audit disclosures until three months following the termination of martial law.

160,000 UAH Direct Procurement for Defense Counsel

Parallel to active inquiries by investigative bodies, the municipal entity entered into an uncompetitive contract for external legal services.

In its official disclosure, the MVA confirmed that it authorized a direct contract for legal aid and representation services (CPV code 79110000-8) running from September through December 2026, valued at 160,000.00 UAH excluding VAT (structured as 40,000 UAH monthly installments).

The procurement system Prozorro details the transaction parameters:

• Procurement ID: UA-2026-09-08-013067-a (published on September 8, 2026, at 15:33);
• Contract Reference: № 0109/1 executed on August 31, 2026;
• Selected Contractor: Law Firm "VIDSYCH" (EDRPOU 44565375, Kharkiv, 26 Otakara Yarosha Street);
• Source of Funding: Listed as "own commercial revenue", despite the agency's performance report documenting that operational and legal services are covered directly by municipal equity injections.

Civil Docket Absence Versus Specialized Criminal Representation

Civil court registries show that KP "SAIR" has not been involved in active commercial litigation, debt recovery, or operational contracting claims over recent years. Nevertheless, this 160,000 UAH contract was awarded on August 31, 2026, immediately prior to law enforcement searches and arrests of enterprise management.

A founding partner and designated signatory of Law Firm "VIDSYCH" is Andriy Velykotskyi, former head of the Troitske branch of the Starobilsk Local Prosecutor's Office in Luhansk region. Velykotskyi was licensed by the Luhansk Regional Bar Council in late 2022 and specializes in white-collar criminal defense, asset forfeiture litigation, and proceedings before the High Anti-Corruption Court (VAKS).

Official records demonstrate that while millions of hryvnias in public capital remain concentrated in an entity that has delivered zero municipal housing units, priority expenditures for late 2026 were directed toward external legal defense retainers.