Analytical Note on the Results of Transferring Sanatoriums into Temporary Management

The case concerns the management of four seized complexes: «Polyana» and «Sonyachne Zakarpattya» sanatoriums (Zakarpattia region), the «Beskyd» recreation center (Ivano-Frankivsk region), and the «Vedmezha Dibrova» sports, residential, and health complex (Zakarpattia region). These assets are linked to the Federation of Trade Unions of Ukraine and Viktor Medvedchuk, who is accused of high treason. They were seized within the framework of criminal proceedings and transferred to ARMA’s management to ensure their preservation and to generate income pending the conclusion of judicial proceedings.

The total estimated value of the assets exceeds UAH 585 million, the largest of which is the «Vedmezha Dibrova» complex (UAH 493.5 million). In 2024-2025, ARMA organized manager selection procedures through the Prozorro system. For certain assets, the transfer process was accompanied by repeated tenders, appeals, and the rejection of bids due to insufficient justification of an abnormally low price. Notably, the «Polyana» sanatorium was successfully transferred for management only on the fourth attempt.

Competitiveness in the procedures was limited. In a number of cases, only one or two participants took part in the tenders, while for some assets, auctions did not take place due to a lack of bids. The amount of managers' remuneration varies significantly, ranging from 1% to 27.5% of revenue. The management of two sanatoriums is concentrated under a single business entity, «INVESTMENT COMPANY «TVK» LLC. Based on the results of 2025, revenues to the state budget from the management of all assets amounted to approximately UAH 1.86 million. In 2026, there have been no revenues for some of the assets.

At the same time, an analysis of judicial proceedings indicates that the management of these assets is complicated by systemic procedural issues. Seizures and transfers for management were carried out within several criminal proceedings related to both the illegal alienation of state property by structures of the Federation of Trade Unions of Ukraine and suspicions of financing the actions of the aggressor state and the illegal use of land and property.

Overall, the case demonstrates typical challenges in managing complex and politically sensitive assets: low competition in the asset management market, protracted procedures, low budgetary returns compared to the value of the assets, and the significant impact of lengthy and fragmented judicial processes, which create legal uncertainty and directly limit the effectiveness of seized asset management.

Identified Issues as of April 7, 2026

• Low competitiveness of manager selection procedures. In most cases, there is a limited number of participants in the tenders, or a complete lack thereof.
• Systemic rejection of bids due to «abnormally low prices,» which indicates attempts by participants to formally enter the tender without a viable economic model.
• Protracted procedures for transferring assets into management. The selection process for the «Polyana» sanatorium lasted over a year due to multiple bid rejections, cancellations of management contract offers, and repeated tenders.
• Low profitability in the management of large property complexes. A significant imbalance is observed between the market valuation of assets and the volume of revenues generated for the state budget.
• Procedural inconsistency and fragmentation of judicial decisions regarding components of a single asset, sometimes within different criminal proceedings, creating legal uncertainty and the risk of conflicting rulings.
• Limited capacity for full-scale management and monetization of assets due to judicial restrictions (partial use by third parties), risks of alienation, and general legal instability, which reduces the economic return on assets.

«Polyana» and «Sonyachne Zakarpattya» Sanatoriums are operational health resorts located in the Svalyava district of the Zakarpattia region. The sanatoriums provide services for recreation, treatment of digestive and respiratory organs, SPA and cosmetology procedures, mud therapy, etc.

Both sanatoriums are owned by the Federation of Trade Unions through the Private Joint-Stock Company (PrJSC) «Ukrprofozdorovnytsia.» Several wells are located on the territories of the sanatoriums, from which medicinal table waters «Polyana Kvasova» and «Polyana Kupil» are extracted.

«Beskyd» Recreation Center and «Vedmezha Dibrova» Sports, Residential, and Health Complex

Both complexes are linked to Viktor Medvedchuk, who is accused of high treason and stripped of Ukrainian citizenship.

The property complex of the «Beskyd» recreation center is located in the Yozifstal tract of Myslivka village, Kalush district, Ivano-Frankivsk region. The facility itself still formally belongs to «Investment Company «Ukrcapital» LLC. Historically, this was Viktor Medvedchuk's firm, founded by him in 2003, though he transferred it to his wife, Oksana Marchenko, in 2016. The «Beskyd» SPA-hotel continued to operate until the end of 2022, as evidenced by activity on the SPA complex's social media pages.

The elite, furnished «Vedmezha Dibrova» sports, residential, and health complex was personally owned by Viktor Medvedchuk and is located in the Parazhyn tract on the territory of the Zhdeniievo community, Mukachevo district, Zakarpattia region. It occupies an area of approximately 150 hectares and includes a main house, guest houses, a helipad, a «kolyba» (traditional wooden restaurant), a chapel, and a farm with a creamery. The list also includes movable property, specifically two electric cars, a tractor, kitchen and sanitary equipment, and furniture.

The announcement of preliminary consultations took place on November 30, 2023. On the same day, a tender for the selection of an appraiser was announced.
The appraisal contract was concluded on January 30, 2024 with PE «BUSINESS-EXPERT». The cost of the appraisal amounted to UAH 8,000.00. The asset was valued at UAH 33,004,481.00.
The tender for the selection of a manager was announced on Prozorro four times: May 15, 2024; October 8, 2024; May 21, 2025; and July 9, 2025. The expected cost of management was UAH 300,000 each time, except for the first tender (UAH 200,000). The guarantee payment remained at UAH 330,044.81, except for the first tender (UAH 250,000.00). Three participants competed for the asset in each of the four tenders.
During the first tender (May 15, 2024), the following bids were submitted:
CONSORTIUM «AKVA RESURS 24» (UAH 900.00);

• LLC «SANATORIUM «KRYSHTALEVE DZHERELO» (UAH 1,000.00);
• LLC «SALAMANDRA-ZAKARPATTIA» (UAH 20,000.00).

All bids were reviewed and rejected due to improper justification of abnormally low prices or failure to eliminate inconsistencies in the tender documentation. A previously submitted proposal to conclude a contract with CONSORTIUM «AKVA RESURS 24» was later canceled.

The next tender took place on October 8, 2024. Bids were submitted by:

• LLC «SANATORIUM «KRYSHTALEVE DZHERELO» (UAH 1,501.00);
• CONSORTIUM «AKVA RESURS 24» (UAH 1,950.00);
• LLC «INVESTMENT COMPANY «TVK» (UAH 98,500.00).

All bids were rejected for the same reasons. However, during the evaluation process, a contract was proposed twice to LLC «INVESTMENT COMPANY «TVK». In both cases, the proposal was challenged by other participants and canceled,.
The third tender took place on May 21, 2025, with the same participants submitting higher bids:

• LLC «
• ORTIUM «AKVA RESURS 24» (UAH 129,900.00).

The tender was unsuccessful again. The first two bids were rejected due to non-compliance with technical specifications and other procurement requirements. The last bid was rejected due to the submission of false information.

The final tender, which proved successful, took place on July 9, 2025. Three participants took part:

• LLC «INVESTMENT COMPANY «TVK» (UAH 7,000.00);
• LLC «AKVA MED» (UAH 8,000.00);
• CONSORTIUM «RECOVERY POWER» (UAH 9,000.00).

This time, LLC «INVESTMENT COMPANY «TVK» substantiated its abnormally low bid. The management contract was concluded on August 27, 2025. According to the contract, the manager’s remuneration amounts to 7% of the monthly income, and the guarantee payment is UAH 306,941.67.

LLC «Investment Company «TVK» (State Register code 32712470)
Registered more than 22 years ago (November 13, 2003) in Morshyn.

• The main activity according to the Classification of Economic Activities is 55.10 - hotel and similar accommodation services.
• Authorized capital: UAH 349,680,611.23.
• Ultimate beneficial owner: Taras Kytzmei (Ukraine) - 46.15%.

In 2025, the Antimonopoly Committee of Ukraine fined the company UAH 1,119,356 for acquiring control over the assets of the Poliana and Sonyachne Zakarpattia sanatoriums without prior approval and subsequently granted the necessary permissions.

The company is part of the «Kmit Family Group» (agribusiness, construction, real estate).
Key persons: Mykola and Nazar Kmit.
Group companies operate in real estate, construction, and farming. Assets include: LLC «Investment Company «TVK» (health resort complex «Saint Charbel» in Morshyn), LLC «Hrafska Vezha», dairy farm «Mukko» (cattle breeding, cheese production under TM «Mukko», 1,300 ha of cultivated land).

The asset was transferred to the manager in accordance with the Asset Transfer and Acceptance Certificate dated October 17, 2025. Based on the results of the latest performance review conducted by ARMA staff, the asset management generally complies with the terms of the management agreement.
In 2025, UAH 647,688.98 was received by the State Budget of Ukraine from the management of this asset. For January and February 2026, two payments were made in the amount of the guarantee payment, totaling UAH 613,883.34.

Preliminary consultations were also announced on November 30, 2023. The appraiser selection tender was announced the same day and repeated five more times.

The appraisal contract was concluded on January 30, 2024 with LLC «TR Invest-Company». The cost was UAH 45,000.00. The asset was valued at UAH 28,704,258.00.

This asset was transferred to management on the first attempt. The tender was announced on June 26, 2025. Expected cost: UAH 300,000; guarantee payment: UAH 287,042.58.

Two participants submitted bids:

• CONSORTIUM «RECOVERY POWER» (UAH 50,000.00);
• LLC «INVESTMENT COMPANY «TVK» (UAH 200,000.00).

The consortium’s bid was rejected due to insufficient justification of an abnormally low price. The contract with LLC «INVESTMENT COMPANY «TVK» was signed on August 27, 2025. The remuneration is 20% of monthly income; the guarantee payment is UAH 229,634.06.

More detailed information about the manager is provided above.

The asset was transferred to the manager in accordance with the Asset Transfer and Acceptance Certificate dated October 17, 2025. Based on the results of the latest performance review conducted by ARMA staff, the asset management generally complies with the terms of the management agreement.
In 2025, UAH 685,095.89 was received by the State Budget of Ukraine from the management of this asset. For January and February 2026, two payments were made in the amount of the guarantee payment, totaling UAH 459,268.12. 

Preliminary consultations were announced on November 4, 2024. The date of the appraiser tender is unknown.
The appraisal contract was concluded with LLC «Independent Expert Evaluation «Expert». The asset was valued at UAH 30,169,875.00.

The manager selection tender was announced twice (November 28 and December 17, 2024). Expected cost: UAH 200,000; guarantee payment: UAH 10,000.

The first tender failed due to lack of participants.

During the second tender, only one bid was submitted:

• STATE ORGANIZATION «SANATORIUM «TRUSKAVETS» of the Security Service of Ukraine (UAH 10,000.00).
• The participant corrected documentation inconsistencies and signed the contract on January 27, 2025. Remuneration: 1% of monthly income; guarantee payment: UAH 10,000.

Notably, the manager is a sanatorium owned by the Security Service of Ukraine.

• Sanatorium «Truskavets» of the Security Service of Ukraine (State Register code 20000060)
• Registered 22 years ago (February 13, 2004) in Truskavets.
• The primary activity according to the Classification of Economic Activities is 86.10: Activities of hospitals. 
• Founder/participant: Security Service of Ukraine.

In 2019, the Administrative Board of the Lviv Regional Branch of the Antimonopoly Committee fined LLC «Ovochi-Frukty» and entrepreneur Mykola Tkachyshyn 272,000 UAH for anti-competitive actions during a tender. This concerns their participation in the procurement of vegetables by the «Truskavets» sanatorium of the Security Service of Ukraine.

The asset was transferred to the manager in accordance with the Asset Transfer and Acceptance Act dated March 6, 2025. As of the end of 2025, an audit of management effectiveness conducted by ARMA staff found that measures regarding asset insurance had not been implemented; other measures taken by the manager generally comply with the terms of the management agreement.

In 2025, UAH 88,387.10 was transferred to the State Budget of Ukraine from the management of this asset. In January 2026, the amount was UAH 0.00, and in February, it was UAH 10,000.00.

Preliminary consultations were announced three times: September 19, 2024; May 19, 2025; September 4, 2025. The appraiser tender was announced once (September 19, 2024).

The appraisal contract was concluded on January 30, 2024 with LLC «Independent Expert Evaluation «Expert». Cost: UAH 245,000.00. Asset value: UAH 493,528,617.00.

The asset was transferred to management on the first attempt. The tender was announced on September 23, 2025. Expected cost: UAH 300,000; guarantee payment: UAH 357,000.00.

Only one participant submitted a bid:

• LLC «AVGM-GROUP» (UAH 275,000.00).
• That participant became the winner of the tender. The contract was signed on October 30, 2025. Remuneration: 27.5% of monthly income; guarantee payment: UAH 258,825.00.

LLC «AVGM-GROUP» (State Register code  43376932)

• Registered on December 2, 2019 in Kyiv.
• The primary activity according to the Classification of Economic Activities is 46.77 - wholesale of waste and scrap, indicating possible lack of experience in hotel management.

In a job posting on the website of the Tomashpil Territorial Community in Vinnytsia Oblast, seeking workers for «AVGM-GROUP», the company is described as a representative of a group of foreign firms engaged in the design and construction of solar power plants and wind power plants.

• The authorized capital is 25,000 UAH.
• Founder/Shareholder/Legal Representative:

- since March 2025: Mykhailo Valentynovych Ostrikov (100%);
- as of July 31, 2024: Nazar Oleksandrovych Bubuk;
- as of June 16, 2021: Volodymyr Pavlovych Serhiievskyi.
The director is Valentin Viktorovich Ostrikov.

Nazar Oleksandrovych Bubuk also served as the authorized representative/director/accountant.

Nazar Bubuk and Mykhailo Ostrikov are also co-owners of «Robotics Solutions» LLC, a company that manufactures and sells drones and was founded 2.5 years ago.

According to journalists, AVGM Group LLC and Robotics Solutions LLC are named in criminal proceeding №42024113330000026 dated February 29, 2024, regarding the embezzlement of funds allocated by the Kyiv City State Administration to the 112th Brigade of the Territorial Defense Forces for the purchase of drones - they may have been involved in a scheme of alleged embezzlement of budget funds.

The asset was transferred to the manager in accordance with the Asset Transfer and Acceptance Act dated October 17, 2025. Based on the results of the latest audit of management effectiveness conducted by ARMA employees, asset management generally complies with the terms of the management agreement.
In 2025, UAH 440,002.50 was transferred to the State Budget of Ukraine from the management of this asset. In January 2026, the amount was UAH 0.00, and in February, UAH 517,650.00, which is double the guaranteed payment and includes the payment for the previous month.

The Main Investigation Department of the State Bureau of Investigations, under the procedural supervision of the Office of the Prosecutor General, is conducting a pre-trial investigation in criminal proceedings No. 62019100000001170 dated August 20, 2019, under Part 1 of Article 15, Part 5 of Article 191, Part 2 of Article 364, Part 2 of Article 367, and Part 5 of Article 191 of the Criminal Code of Ukraine.

According to the investigation, the management of the State Property Fund of Ukraine failed to properly control the disposal of real estate that was under the management of the Federation of Trade Unions of Ukraine and its affiliated legal entities. As a result, officials of trade union structures unlawfully alienated the relevant real estate objects without approval from the State Property Fund, causing significant material damage to the state. Law enforcement authorities also obtained information indicating plans to further alienate real estate objects that are components of the asset. These objects have been recognized as material evidence in the criminal proceedings.
Since 2021, there has been an ongoing and intense procedural dispute over the real estate included in the asset, including within other criminal proceedings. A key issue is procedural inconsistency, as the legal status of each individual real estate object within the asset is determined by separate court decisions adopted at different times. This creates a risk of conflicting judicial decisions regarding interrelated assets, complicates their coordinated enforcement, undermines legal certainty, and ultimately hinders effective management of seized assets.

The asset includes the following real estate:

• premises of SE «Poliana Sanatorium» (seized 7 times, transferred to management 3 times, appealed 10 times - 6 successful appeals);
• real estate object at 171 Dukhnovycha Street, Poliana village (6 seizure rulings; 3 transfers to management; 12 appeals - only 3 successful);
• real estate object at 131 Dukhnovycha Street, Poliana village (seized 5 times, transferred 3 times, appealed 8 times - 2 successful);
• a 16/1000 share in Poliana Sanatorium, unlawfully alienated in favor of LLC «Remira Zakarpattia».

Despite prolonged litigation, all components of the asset have ultimately been seized and transferred to the management of ARMA.

Within the above-mentioned criminal proceedings No. 62019100000001170, the integrated property complex of the «Sonyachne Zakarpattia» sanatorium has also been recognized as material evidence.

The procedural situation is similar to the previous asset: the property was seized 8 times and transferred to management 5 times, with 13 appeals (6 successful), including within other criminal proceedings. As of now, the asset has been seized and transferred to ARMA.

At the same time, the court allowed continued use of the mineral water bottling facilities and warehouse located on the sanatorium’s территории by a company that has been operating them since 2020.

Movable Property (639 items) within the Integrated Property Complex of the «Beskyd» Recreation Base

The Investigative Department of the Security Service of Ukraine in Ivano-Frankivsk region is conducting a pre-trial investigation in criminal proceedings No. 222023090000000042 dated January 31, 2023, including on suspicion against the wife of Viktor Medvedchuk under Part 3 of Article 110-2 of the Criminal Code of Ukraine.

The investigation established that Oksana Marchenko organized financing of paramilitary and armed formations of the Russian Federation in occupied Crimea in the total amount of nearly UAH 10.5 million.

The court imposed a seizure on the company «Ukrkapital» (ultimate beneficial owner - Oksana Marchenko), which owns the «Beskyd» recreation base. During a search of the facility, movable property (639 items), solely owned by Oksana Marchenko, was seized. In 2023, this property was arrested and transferred to ARMA. Two attempts by defense lawyers to appeal were unsuccessful.

The Main Investigation Department of the National Police of Ukraine, under the procedural supervision of prosecutors of the Office of the Prosecutor General, is conducting a pre-trial investigation in criminal proceedings No. 12021070000000095 (merged with proceedings No. 12021000000000381 dated March 12, 2021) dated March 10, 2021, under Part 2 of Article 364 and Part 3 of Article 191 of the Criminal Code of Ukraine.

The investigation established that LLC «Investment Company «Sport-Tour» (ultimate beneficial owner - Oksana Marchenko), having unlawfully obtained ownership and lease rights to state-owned forest land with the assistance of officials of the Volovets District State Administration, uses these lands for private interests, namely:

• illegal logging;
• unauthorized fencing of an area exceeding 130 hectares;
• restriction of Ukrainian citizens’ access to state-owned forests;
• illegal construction of a residential complex.

There is also a high likelihood of continued unlawful actions involving the real estate objects forming part of the asset, including their potential alienation.

Currently, the «Vedmezha Dibrova» complex (land plots, real estate, and movable property) has been seized and transferred to ARMA.
LLC «Investment Company «Sport-Tour» unsuccessfully appealed the seizure of land plots three times.
Additionally, the land plots and real estate within the asset were also seized and transferred to ARMA three times within another criminal proceeding.