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    Ukrainian hacktivists from the 256 Cyber Assault Division gained access to correspondence between Russian ministries and exposed a large-scale oligarchic enrichment scheme in the temporarily occupied territories of Ukraine. The group obtained a secret list of almost 200 Russian companies participating in the so-called “Special Infrastructure Project” – essentially a scheme for channeling Russian public funds into well-connected companies under the guise of “reconstruction.”

    Volunteers of InformNapalm international intelligence community analyzed this data and came to the conclusion that behind these high-profile projects there are elaborate chains of contractors and shell companies, built with a goal not only to pocket billions, but also to shield the real beneficiaries – Russian business giants, which have thus far avoided international sanctions.

    This investigation reveals how Russia is trying to legalize money laundering and profiteering in the occupied territories, turning war crimes into a lucrative business.

    Why does Russia need the “Special Project”?

    Following the full-scale invasion in 2022, the Kremlin faced two major challenges:

    1. Management chaos. The occupied territories were not integrated into the administrative and financial system of Russia. This created great difficulties in terms of management and control.
    2. Wariness of major business. Large Russian companies were reluctant to operate openly in the occupied territories, fearing sanctions and hoping to someday resume “business as usual” with the West.

    The solution was found in a model already tested in Crimea.

    How the scheme works: the Crimean blueprint and the promise of anonymity

    The mechanism that has been in place in Crimea since 2014 is simple and cynical.

    • Cash injections. Through the system of government contracts, huge funds are allocated to the occupied territories for the implementation of large infrastructure projects (such as the infamous Crimean Bridge).
    • Propaganda image. This allows Russian propaganda to create the illusion of “development of new territories” and of “economic recovery”.
    • Guaranteed anonymity. Companies that agree to participate are promised complete secrecy. To this end, government contracts are classified, and major businesses are instructed to establish shell companies—subsidiaries that operate only in the occupied territories and are not formally affiliated with their parent companies.

    To coordinate this scheme, a dedicated department “for the implementation of the Special Infrastructure Project” (SIP) was set up under the Ministry of Construction of the Russian Federation back in May 2022.

    The Illusion of “reconstruction” vs reality

    In fact, there’s no economic miracle happening. The money from the Russian budget is distributed among Russian companies. Workers are also mainly brought in from Russia. They spend part of their salary locally, whereas their employers contribute some taxes to local budgets, creating the appearance of “economic recovery”.

    In essence, this is a self-contained system where Russian taxpayers’ money ends up in the hands of Kremlin-connected corporations, while the occupied territories serve as a backdrop for propaganda narratives.

    This article is part of a series of CYBINT investigations. Related reads:

    What is the Special Infrastructure Project, and how do Russian subsidies for the maintenance of temporarily occupied territories of Ukraine work?

    Already at the beginning of the full-scale invasion of Ukraine in 2022, Russian authorities faced the question of maintaining the “new territories.” One of the challenges faced by the occupiers is that the Ukrainian territories were not integrated in the Russian administrative, financial and other systems. According to the Center of National Resistance report on the situation in the Russia-occupied territory of Ukraine covering the first half of 2025, this issue has not been resolved to this day. This complicates management of the occupied territories.

    Another challenge: big Russian businesses continue to avoid direct involvement in the temporarily occupied territories, fearing sanctions and hoping for a post-war return to the Western markets.

    So after 2022, the Kremlin extended to these territories the same model used in Crimea: gradual administrative integration and large-scale funding for infrastructure projects via state procurement mechanisms. This not only fuels propaganda about “rebuilding,” but also creates an illusion of rising local revenues. In reality, it’s the result of workers spending part of their income in the regions where they’re temporarily stationed, and companies paying limited local taxes.

    To encourage participation, companies are promised anonymity. Government contracts are classified, and businesses are urged to operate in the occupied territory through shell companies that cannot be traced back to their real owners.

    This system brings about no real improvement in the local economies, as all the money is distributed among Russian legal entities, and workers at the sites are also mainly brought in from Russia.

    The SIP: maximum anonymity, minimal oversight

    Back in May 2022 the Russian Ministry of Construction established a department for the “implementation of the Special Infrastructure Project” in order to distribute funding in the newly occupied territories.

    The SIP is a mechanism to use the money allocated for occupied territories of Ukraine with maximum anonymity. There is no detailed reporting on the SIP in the public domain, nor is there a specific list of participating companies. However, 256 Cyber Assault Division retrieved the data on the contractors and subcontractors of the SIP, and handed it over to InformNapalm.

    Which company lists did hacktivists obtain? How do they differ from each other?

    Departments for the implementation of the SIP in the occupied territories were established not only under the Russian Ministry of Construction. According to the Russian business magazine RBC, as of the end of 2022, “at least six government agencies and 55 regions of the Russian Federation” were contracting work at the occupied territories of Ukraine. In particular, the Russian Ministry of Construction, the Ministry of Energy, the Ministry of Transport, the Ministry of Defense (through subsidiary legal entities founded under the ministries), as well as the state company Avtodor and the Territorial Development Fund.

    Russian officials refuse to disclose contractors’ names, and since 2022, all relevant budget allocations have been classified, and go through the relevant part of the Russian state budget.

    The two lists that we are publishing today contain companies approved by the Russian Ministry of Construction to work on the occupied territory of Ukraine (the first list was compiled as of November 2022) and the list of contractors of the Territorial Development Fund (the second list was compiled as of September 2024).

    The first list makes part of a letter from the First Deputy Minister of Construction of the Russian Federation, Alexander Lomakin, to organizations authorized to “restore and construct facilities within the framework of the SIP.” Entities are required to report the number of workers and special equipment that they can involve in projects. This letter was e-mailed to 99 companies, with their names included.

    The second list contains contractors of the Russian Territorial Development Fund performing work in the occupied territory of Ukraine within the framework of the SIP. The letter was sent out on behalf of another Deputy Minister of Construction of the Russian Federation, Valery Leonov.

    Companies are requested to connect to the automated reporting system for the implementation of contracts in the occupied territories of Ukraine no later than October 1, 2024. The request was sent out to 111 companies, with their names indicated.

    Surprisingly, there are almost no overlaps in the two documents. There are only five names appearing on both lists: PTK LLC [Rus: ООО “ПТК”], NIC PS LLC [Rus: ООО “НИЦ ПС”], Stroyputizyskaniya LLC [Rus: ООО “Стройпутьизыскания”ООО “Стройпутьизыскания”], Transproekt JSC [Rus: АО “Транспроект”] and Interline Engineering LLC [Rus: ООО “Интерлайн Инжиниринг”]. In addition, the second list includes 11 Russian departments (ministries, funds, autonomous agencies, etc.) that are the administrators of funds, and not the contractors (listed at the end of the list). Overall, we have the list containing 194 enterprises that illegally operate in the occupied territory of Ukraine. A significant number of them conceal this activity, and only a few of them have been subject to any kind of sanctions.

    A closer look at the lists reveals that the second list (contractors of the Territorial Development Fund) features significantly larger enterprises than the first. In particular, at least four of them are listed as systemically important enterprises by the Russian Ministry of Economy: VAD JSC [Rus: АО “ВАД”], Avtodor-Engineering LLC [Rus: OOO “Автодор-инжиниринг”], DSK LLC [Rus: ТОВ “ДСК”], Rostelecom PJSC [Rus: ПАО “Ростелеком”].

    How large companies hide their operations in the occupied territory of Ukraine

    R-Stroy LLC listed as number 67 on the contractors list of the Territorial Development Fund.

    is already well-known. In February 2024, it featured in a Financial Times investigation, Inside Mariupol: Russia’s new Potemkin village. FT journalists established that the company actually belongs to the oligarch Alexey Repik who also has businesses in the USA and Germany. Repik denied any involvement in the company. And the company itself keeps its presence in the occupied territories as discreet as it can. For example, R-Stroy posted a job opening in July on their own VK page, where they mysteriously write about working on a “facility near the Sea of Azov.” They promise to provide transportation to the place of work and three meals a day.

    Now, the materials obtained by 256 Cyber Assault Division contain a documented proof for the presence of R-Stroy on the list of major contractors operating on the temporarily occupied territory of Ukraine. In addition, the hacktivists retrieved several samples of subcontracting agreements concluded between R-Stroy and a company called SK Sirius LLC [Rus: ООО “СК Сириус”] for the actual performance of work in the occupied Makiivka and Mariupol.

    The contracts specify the scope and locations of work, and also reveal the scheme for the application of funds. The customer on behalf of the Russian government is the Public Non-profit Company Unified Customer [Rus: ППК “Единый заказчик”], Whereas R-Stroy becomes the first-level contractor. However, the latter simply keeps part of the money for itself and hires another company to actually fulfill the contract.

    The legal seat of SK Sirius is in occupied Crimea. However, according to available data, this subcontractor has no connection to the population of the occupied territories. SK Sirius is a typical shell company. As evidenced by the company’s profile on one of the Russian business information websites, it was registered in 2023 (i.e., the year when the subcontracting agreements with R-Stroy were signed), and now the company is in the process of liquidation. The head of this enterprise, Petr Georgievich Bogatyrev, registered a private enterprise in St. Petersburg back in 2013.

    Why are sanctions against these companies important?

    The lists exposed by hacktivists are of great value because they point to the real players. Shell companies like SK Sirius are just a front that is easy to create and close. They do not own any assets and do not manage billion-dollar budgets.

    The real money goes through first-tier companies such as R-Stroy and nearly 200 other companies from the lists obtained. Each such contractor is approved at the highest level, right up to the Russian Presidential Administration, and replacing it is a lengthy bureaucratic process. Their owners, such as oligarch Alexei Repik, are individuals close to the Kremlin.

    These companies are the weak point of the scheme. They conduct their main business in Russia, purchase Western equipment and are systemically important for their industries. Sanctions against them will complicate access to technologies and credit, which will inevitably slow down the entire Russian machine developing the occupied territories. This is why the Kremlin is so eager to keep the information about them secret.

    Unfortunately, to date, only a small portion of these companies have been subject to sanctions. For example, Miranda Media and its subsidiary Mirtelecom, key providers of telecommunications services in the occupied territories since 2014, were only included on the EU sanctions list at the end of 2023.

    The aforementioned R-Stroy was only included on the EU and Swiss sanctions lists in the summer of 2024, after the publication of journalistic investigations into its participation in Mariupol projects. Perhaps the only exception is VAD JSC, which was sanctioned by a number of countries even before the full-scale invasion for its participation in projects in occupied Crimea.

    Most of the companies on the lists have not yet received any restrictions, including from Ukraine. We call on the National Security and Defense Council of Ukraine and the international community to pay attention to take note and address the situation.

    In addition, we invite journalists and volunteers to further study the published lists. Often, there are representatives of Russian intelligence services lurking behind formal names. Thus, in March 2025, journalists from the Agents Media established that the real overseer of GC EKS JSC (No. 2 on the list of contractors, with government contracts worth 500 bln rubles), is the Russian GRU officer Alexey Vlasov.

    The specified GC EKS is number 2 on the list of contractors of the Fund for Development of Territories, operating in the temporarily occupied territories of Ukraine.


    сс.jpgCompiled specially for InformNapalm readership. Distribution and reprint with reference to the source is welcome! (Creative Commons — Attribution 4.0 International — CC BY 4.0) . Subscribe to InformNapalm social media pages.


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