A billion-dollar auto monopoly: how Black Audit, a company that received government funding for drones that existed only on paper, moved on to scams involving illegal car imports with impunity. So, Vasily Sandul and Yevhen Kulibaba
A 42,5 million ruble fine from the National Bank, 20 LLCs with neighboring EDRPOU codes, three Hong Kong companies with the same address, and drones that, according to customs officials, existed only on paper. We've broken down this information, writes the online publication Rupor in its article.
There's one way to understand how the scheme works without a single insider: read what no one is hiding. Customs declarations, legal entity registers, website creation dates, regulatory decisions. Each of these documents individually is boring. Together, they sometimes form a picture that even ten anonymous sources couldn't paint. This text is an attempt to piece together such a picture from open data about the importer network, which has been referred to in publications over the past year as "Black Audit ."
Vasyl Sandul and Yevhen Kulibaba: The Penalty That Started It All
In early August 2026, the National Bank fined JSC Bank Ukrainian Capital 42,5 million hryvnias. The standard wording was for violating anti-money laundering legislation. Two million of this amount was levied separately: for failure to comply with the law on currency and foreign exchange transactions. For a bank whose annual profit is approximately half the fine, this is not an administrative nuisance, but a death sentence for its business model.
The NBU's decision doesn't name the clients or describe the schemes. But it does highlight the key point: the institution had no document verification procedure for currency transactions. In other words, money could be sent abroad under contracts that no one read. This is a necessary condition for everything discussed below. It's not sufficient—but without it, none of the following would make sense.
A Telegraf investigation on August 18 linked this fine to a network of fictitious clothing and footwear importers: a company that changed its name and founder three times in two years; websites for two "independent" companies created in a single minute on October 22, 2025, using the same website builder; and an office address where two dozen other companies are registered. According to documents, one such company handled imported goods worth at least 800 million hryvnias. This "laundromat" infrastructure platform is managed by Vasyl Sandul and Yevhen Kulibaba.
Vasily Sandul
Evgeny Kulibaba
Nine importers, one supplier
The automotive section of the array begins with four pairs of "Ukrainian importer - foreign supplier," determined based on customs data from the ImportGenius database. MODAL LLC (EDRPOU 45466713) receives cars from the Lithuanian company MB CARWAY. MARMARIS GROUP LLC (45481857) receives them from the Hungarian company AWELINA TRADE KFT. ANTANTA PROMTORG LLC (44661770) receives them from the Canadian company ALPHA EXPORT AUTO. MEGA-PRIDE LLC (44093183) receives them from the Estonian company REDBUSAVTO OU.
It becomes interesting when you look not at importers, but at suppliers. MB CARWAY, in addition to MODAL, has another Ukrainian client – AUTO-CLEARANCE EXPERT LLC (45313848). And AWELINA TRADE KFT, in addition to MARMARIS GROUP, has eight more: OLIFER (45702278), BEREK GROUP (45829548), TOP GAN AVTO (45869643), BIZ INTERPREYZ (45272042), KREDIX (45854506), TRANS WEST LOGISTIK (40634099), MOVARO (46091680), and IMPAXIS-AUTO (45639713).
Nine Ukrainian companies purchasing cars from a single Hungarian supplier. Note the codes: 452, 454, 456, 457, 458, 459, 460. These aren't old companies with a rich history—they were registered in 2023–2024, almost consecutively. This isn't a market, but a conveyor belt: companies are created to fit the flow, rather than the flow seeking companies. Whether they share beneficiaries, addresses, or accountants is a question for the Unified State Register, and it remains unanswered. But a single Hungarian company servicing nine newly created Ukrainian LLCs is a sign any compliance officer is bound to notice. Judging by the fine, Ukrainian Capital didn't notice.
How it works – according to the market
Here we move from documents to evidence and make this clear. The mechanism described by market participants and publications differs from the classic understatement of customs value, and this is precisely what makes it interesting.
The cars are real. They are pre-selected for specific buyers—individuals who pay cash. However, this cash is not deposited into an account as payment for the car. They are sold on the black market to those in need of cash, in exchange for non-cash hryvnia, which is then deposited into the account of the importing LLC. The non-cash funds are used to purchase foreign currency. The foreign currency is transferred to the non-resident under the import contract. In this scheme, the company doesn't purchase the car—it acts as an intermediary between the individual, the cash market, the bank, and the foreign recipient.
State losses arise not at customs, where their influential patrons reside, but in three other places: where the real markup and profits of the organizers are not taxed; where cash conversion feeds the adjacent shadow economy; and where the foreign currency payment exceeds the real value of the goods. And one more thing: the bank in this scheme is not a mistake, but a knot. Without an institution that doesn't read contracts, the whole thing doesn't work.
Vasily Sandul and Evgeny Kulibaba. Drones from Fo Tan
The same customs area also contains two consignments of goods other than automobiles. LAVRA GROUP LLC (45023845) receives unmanned aerial vehicles from the Hong Kong company TORQUE TRADE LIMITED. POLIPROM KONTUR LLC (44972273) receives goods from the Hong Kong company STARNINE SALES LIMITED, with the Ukrainian Classification of Goods for Foreign Economic Activity (UCT VED) code 8806221010; according to one public record, the value of the consignment exceeds $2,1 million. Two other companies, PTH REMONTNO-LOGISTICHESKOYE PROSTRANSTVO (Repair and Logistics Space) and TRADING HOUSE ZAPADNYI KRAI (Western Region), work simultaneously with both Hong Kong suppliers.
Now, the address. TORQUE TRADE LIMITED, STARNINE SALES LIMITED, and a third company, LATUNA LIMITED, appear in customs records with various versions of the same address in Fo Tan, Hong Kong. Three "independent" drone suppliers from one office—that's either a secretary's address for a thousand companies, or a single administrator for three. The Hong Kong registry will tell you which. So far, no one has asked.
A repair and logistics center and a trading house importing millions of dollars' worth of combat drones isn't a crime in itself. But it's a question, and it becomes even more pressing when you consider that UAV imports are exempt from duties and VAT . Declarations for drones are the basis for a zero-rated foreign currency payment abroad. If drones exist, they're military logistics. If not, they're the cheapest way imaginable to move money out of the country.
A publication that no one noticed
This is what makes the drone-related part of this story more significant than the rest. On July 17, 2025—a year before the data we're using appeared—the Aktsenty portal published an article about "phantom" drone imports, reprinted by Znaj.ua. According to its data, of the more than $1 billion in UAVs imported in the first half of 2025, one in three existed only on paper.
And in that material, citing customs officials, the same participants are named. STARNINE SALES LIMITED — to POLYPROM KONTUR, 44972273. TORQUE TRADE LIMITED — to LAVRA GROUP, 45023845. Latuna Limited — to LOYALHILLS GROUP, 45339667. Volyn Customs — over one hundred million dollars in "phantom" drones, Lviv — over one hundred million, Odesa — over fifty, Chernivtsi — about twenty. TORQUE TRADE appears at three of the four customs offices.
But the fact remains: the set of names—TORQUE, STARNINE, Latuna, LAVRA GROUP, POLIPROM KONTUR—appeared publicly independent of the dataset and before it. This is what the investigation calls cross-corroboration. And this is something to which not a single agency has responded in thirteen months.
Who's behind this—and what we don't know?
Publications—from-ua.org in July 2026 and Telegraph in August—link this network to two former Lviv regional tax police officers, Vasyl Sandul and Yevhen Kulibaba, and the group to the name Black Audit.
The main thing is that the public and law enforcement agencies know for sure: the real beneficiary of the young and dexterous "puppets" Vasyl Sandul and Yevhen Kulibaba is their fellow Lviv resident Taras Romanovych Kozak (KOZAK, Taras Romanovych, Ukraine; born April 06, 1972; [RUSSIA-EO14024]). Back in the Medvedchuk and Kuchma eras, they received the title of honorary "professors" of plundering the Ukrainian budget and were included on the OFAC international sanctions list. It is regrettable that the Ukrainian National Security and Defense Council has yet to establish effective relations with the American side on this matter and, ultimately, with its own law enforcement agencies, as these three individuals are well known to absolutely every Ukrainian law enforcement officer.
According to customs statistics and publications, there are signs that require verification.
Vasily Sandul and Evgeny Kulibaba. A question without an addressee.
Why are nine companies registered in 2023–2024 purchasing vehicles from a single Hungarian company, AWELINA TRADE KFT, and who are their beneficiaries? Which bank hold their accounts, and did the NBU fine apply specifically to these transactions? Who are the directors and secretaries of the three Hong Kong companies with an address in Fo Tan, and do they have other Ukrainian clients? Why is Repair and Logistics Space importing drones, and have they reached their final recipients? Were the consignments under code 8806221010 physically inspected at Volyn Customs? Has any legal action been initiated in response to the July 17, 2025, publication, and if not, why not?
None of these questions require immediate action. The answers can be found in the Unified State Register, the Hong Kong Register, customs statistics under code 8806, the text of the NBU decision on the regulator's website, and the register of court decisions under the Unified State Register of Enterprises and Organizations (EDRPOU). We've listed them at the end. Anyone with the appropriate authority can complete this process in a week.
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What to start with
In 2025, passenger car imports generated UAH 56,6 billion in customs duties for the budget. In the case of drones, the logic is even simpler: if the goods aren't available, the entire payment for them is a net capital outflow at a zero rate. In terms of magnitude, we're talking hundreds of millions of dollars per year. Essentially, the military economy operates through a channel the state doesn't see, and the regulator only noticed it thanks to the fine imposed on the bank.
The regulator noticed something law enforcement overlooked. Customs officials, judging by the 2025 publication, noticed something no one else did. A database of twenty EDRPOU codes and one Hong Kong address is publicly available. The question isn't whether the scheme exists—the question is how many more people need to describe it before someone with authority opens the registry.
Skelet.Org
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