Big Construction, Small Accountability: Where Did the Suspicions on Ten Billion Dollars Go

25 May, 07:29
On December 24, 2021, at a forum titled "Big Construction: Roads and Bridges," Prime Minister Denys Shmyhal delivered a sentence that ought to be framed above the desk of every future NABU detective.

"In total, more than 10 billion dollars has been spent on the development of road and bridge infrastructure. This is, of course, a record," the head of government announced. A record. In a country that had already been at war in the east for seven years, where the health budget was being patched with COVID-fund money and the army was chronically underfunded, the record went to asphalt. And it was not the finance minister who tapped it out, but the head of government himself, with deliberate pride.

Four and a half years have passed. The program is closed, renamed, reorganized, absorbed under other brands. The forum itself interests no one anymore. The number, however, has not gone anywhere. Ten billion dollars is roughly 270 billion hryvnias at the exchange rate of the time. More than the entire Ministry of Defense budget for 2021. More than annual state spending on education and science. A sum of that scale ought to leave a legal trail behind it: suspicions, searches, in absentia arrests, extradition requests, eventually convictions. Something should be there.

There is nothing.

As of May 2026, in the largest infrastructure project of independent Ukraine, not a single suspicion has been served on those who launched, coordinated, and publicized it. The Presidential Office curator who chaired the program's coordination council, dismissed in January 2023, has no criminal suspicion. The minister who built it received, in January 2026, the post of Presidential Adviser on Infrastructure and Community Cooperation — by decree №66/2026, filed in the official registry under that number. The consultant through whose phone billions of roadwork overpayments flowed has, since June 2024, been residing in Austria — having exited under the "Shliakh" wartime travel system on the basis of a disability certificate. In the proceedings he appears as a witness. Not as a suspect. As a witness.

This article is an attempt to explain why this is neither accident nor negligence. It is a repetition of a script Ukraine's anti-corruption vertical has already lost once before. The script has a name. Its name is "Rotterdam+."

How Rotterdam Was Dismantled

In March 2017, NABU opened a case that was meant to be the first great triumph of the anti-corruption reform. At issue was the wholesale electricity pricing formula, adopted by the National Energy and Utilities Regulatory Commission (NEURC) in March 2016. The formula pegged the price of Ukrainian coal to the quotations of the European port of Rotterdam, plus the cost of hypothetical transportation. Meaning: electricity produced from coal mined, say, in Pavlohrad was priced as though that coal had arrived in Odesa from the Netherlands. Across seas and oceans. Freight included.

The business logic was clear. Ukraine had just lost access to anthracite from the occupied Donbas; energy prices had to rise to keep thermal generation afloat. Except thermal generation was being kept afloat by one specific holding — Rinat Akhmetov's DTEK. And according to NABU's estimates, between 2016 and 2019, Ukrainian consumers paid more than 39 billion hryvnias in excess costs under this formula. In plain terms: thirty-nine billion hryvnias from your electricity bill and mine went into the pockets of structures whose only contribution was being near the right regulator at the right moment.

The investigation dragged on for three years. In 2020, the SAP prosecutor closed the case for lack of sufficient evidence. He closed it four times. A HACC investigating judge agreed with him in September 2020. The appeal reversed. He closed it again. Reversed again. In 2023, the indictment finally reached court — and at that point a different mechanism kicked in. The Lozovyi amendments, adopted back in 2017 under the guise of humanization, restricted pretrial investigation timelines to the period before the formal suspicion is served. Legally, what does that mean? That if a detective spent a year and a half building an evidentiary base, then another year fighting for an expert assessment, after the suspicion is served he is left with mere months to finish. In October 2023, HACC closed the case for expiration of pretrial timelines. The appellate chamber reversed in December. In April 2024, two defendants — Borys Tsyhanenko and Yurii Hollyak — were released from liability on the same grounds. In August 2025, the former head of the regulator, Oksana Kryvenko, was released. In September — her colleague Olena Antonova on the same grounds. Dmytro Vovk, the man who actually signed that formula, has been on the international wanted list since 2019. No verdict. No extradition. No prospect.

This is the full anatomy of a collapse. Nine years from the first scandal to a quiet expiration of timelines. Four prosecutorial closures, two appellate reversals, one full court closure, one reopening, three defendants released from liability, the principal target on an international wanted list with no realistic prospect of extradition. The result: thirty-nine billion hryvnias that traveled from consumers' pockets into beneficiaries' pockets remain in the beneficiaries' pockets. Legally — clean. Morally — as usual. Now let us see how this anatomy repeats itself on the road market.

Six Companies, One Association, Zero Investigations

In November–December 2019, when Ukravtodor was already headed by Oleksandr Kubrakov, the six largest contractors on the market — Avtomahistral-Pivden, Rostdorstroy, the Turkish Onur, Tekhno-Bud-Tsentr, the Donetsk-based Altkom, and Vinnytsia-based Avtostrada — founded the National Association of Road Builders of Ukraine. This happened precisely on the eve of the program's official launch, announced on March 1, 2020. In 2020, those six firms absorbed roughly 67% of all Ukravtodor contracts. The discounts on tenders in which they competed against each other rarely exceeded two to five percent. On the rare tenders where some outsider somehow broke through, the price drop reached twenty to thirty percent.

The Anti-Trust League filed a complaint with the Antimonopoly Committee, listing the markers of cartel collusion. The Antimonopoly Committee, then chaired by Olha Pishchanska, officially declined to investigate. To a cartel complaint that laid out — tender by tender — the factual record of six companies splitting the state pie under a profit-sharing arrangement, the regulator replied that it saw no grounds to look into the matter. Without an AMCU ruling on a cartel, NABU is deprived of the first legal handhold. The same handholds whose absence dissolved the Rotterdam+ formula. You cannot prosecute a contractor for the collusion itself — only for a specific episode of misappropriation, only with a specific expert finding on a specific amount of damages.

It is worth pausing here and listening to how this sounds in historical perspective. In Rotterdam, the state failed to prove the existence of the formula — even though the formula could be located in the NEURC registry by number and date. In Big Construction, the state does not acknowledge the existence of the cartel — even though the six founding firms of the National Association of Road Builders can be counted on one hand. In both cases, the absence of an initial official finding about the systemic nature of the scheme buries every subsequent investigation. Because a detective who cannot lean on a sectoral regulator's conclusion is left alone with allegations about an isolated episode. An episode can be closed. A system — much harder.

The figures into which this design eventually metastasized deserve to be read slowly. In 2021, the road tender market reached roughly 261 billion hryvnias. Avtostrada, owned by Maksym Shkil — a former aide to Mykola Demyanko, a Party of Regions MP — won contracts worth 47 billion hryvnias. Cash actually received over the year — about 13 billion. In a single company. In the hands of a beneficiary whose biography begins in the office of a Party of Regions deputy. Nashi Hroshi linked Avtostrada's ascent to the strengthened position of Andriy Yermak, head of the Presidential Office; Shkil himself denied this in his well-known 2024 interview with Babel. Who is right is now a question for a different investigation. Because in May 2026, Yermak received a SAP suspicion for laundering 460 million hryvnias — but under the scheme of the Dynastia residential development in Kozyn, not under road billions. The roads, like Rotterdam, also remained outside the frame.

One more company — Budinvest Engineering — deserves a separate mention, because its story best explains the word "umbrella." In 2021, this firm won road tenders worth nearly 15 billion hryvnias. Onto its own accounts it received over four billion. Journalist Mykhailo Tkach of Ukrainska Pravda published in November 2022 a story titled "A Fitness Trainer for a Billion." It established that 49 percent of the company that was absorbing the billion-hryvnia contracts of Dnipropetrovsk region belonged to a 34-year-old powerlifting trainer named Yana Khlanta. A close personal acquaintance of Valentyn Reznichenko, then head of the Dnipropetrovsk regional state administration. The other portion was controlled through intermediaries by the Dubynsky brothers, on the US wanted list. The program is called Big Construction. The customer is the Dnipropetrovsk RSA. The executor is a fitness trainer. The curator in Kyiv is Yuriy Holyk, a man without an official position.

The entire construction held together on the premise that no beneficiary could be presented as random. The trainer is not merely a trainer. Holyk is not merely a consultant. Reznichenko is not merely a governor. All of them moved within a single logic, with one coordination center, in one mode of absorbing budgets under one brand. The brand mattered more than the people. The brand legitimized what, in any other context, would have raised seven questions during the tender preparation stage.

How the Umbrella Works

In the dictionary of corruption mechanisms, there is a term that Ukrainian political tradition produced earlier than the Western one. The "umbrella." It is when the name of a project or the status of the customer functions as a legal amulet: any question from below is automatically deflected by the reference to a priority above. A major reform. A strategic build-out. A personal project of the president. Roads to victory. Each of these phrasings transmits to the executors a single message: your contract will not be opened by anyone, even when the assessment shows the price inflated by a factor of one and a half. Because behind you stands another assessment. Not a technical one.

In the logic of the umbrella, the program's brand does two things at once. First, it provides contractors with a tender indulgence — the risk of having a contract reversed after a complaint is minimized by the political rank of the customer. Second, and more importantly, it makes the curators of the program personally invulnerable. Not because the law protects them. Because the public understanding protects them — the understanding that this particular official will leave his office only together with the entire floor.

That is how Rotterdam+ worked. NEURC acted "in the interests of national security" — because without the formula, supposedly, thermal generation would have collapsed after the occupation of the Donbas. That is how Big Construction works. The program is not corrupt — it has been built. The roads are there. The schools are open, the hospitals are renovated. And here the umbrella enters its final phase: one cannot question a project that millions have seen with their own eyes. Because that would mean questioning the very prospect of a normal life for the country. One does not do that. It is not done.

What happens when the umbrella is fully deployed? Criminal cases do appear — but in a constrained format. Against a regional executor. Against a particular governor. Against a second-tier official. Against an MP caught on a minor bribery episode. Each such case looks like a system victory: look, the anti-corruption bodies are working, here is the suspicion, here is the search, here is HACC setting bail. Meanwhile, the program's curators remain untouched. Because they are formally absent from the case files. Because their names are mentioned only in testimony. Because their phones do appear in video footage — but as the phones of persons in whose homes investigative actions were conducted and who then left the country on a disability certificate.

Look at these five cases in which "Big Construction" is ostensibly being investigated. Look carefully.

First. Vasyl Lozynskyi, the former first deputy minister of communities development, detained on January 21, 2023 over a 400,000-dollar bribe for generator procurements. That was 8% kickback for facilitating three contracts worth 500 million hryvnias with the company TekhnoTransBud. The total procurement tender was around 1.8 billion. HACC set bail, the appeal switched the measure to detention. In January 2025, one of the accomplices, Oleksandr Kroshka, reached a plea deal with the investigation — 50 million hryvnias in compensation toward the defense budget. As for Lozynskyi, the principal defendant, there is no verdict. Three and a half years after the detention.

Second. Andriy Odarchenko, an MP from the ruling Servant of the People party, who offered Mustafa Nayyem a bribe in bitcoin for allocating funds to renovate the biotech university where he himself was rector. Nayyem in this story cooperated with NABU as a whistleblower from the outset. Odarchenko was sentenced in absentia in November 2024 to eight years with confiscation. In October 2025, the HACC appellate chamber upheld the verdict. Odarchenko himself has been abroad since September 2024 — Romania, then Hungary, where in Budapest he applied for refugee status. In February 2025, Hungarian police detained him briefly, then released him. He retained his Ukrainian parliamentary mandate through the end of the year. The eight-year sentence is in absentia, meaning it will only be served if extradition is granted — which neither Romania nor Hungary typically arrange in cases of this rank. Odarchenko is free. Somewhere in Budapest or Debrecen.

Third. MP Serhiy Labazyuk, caught on a 150,000-dollar bribe — in a Chinese-style decorative box, in the parking lot of a Kyiv supermarket. The bribe went through Nayyem to Kubrakov — 5% kickback on the 50 million hryvnias already paid to Labazyuk's company URD for a bridge reconstruction contract. Both Nayyem and Kubrakov were cooperating with NABU as whistleblowers: the essence of the scheme was Labazyuk offering them 3–5% on roughly one billion hryvnias of contracts that were meant to flow to his company. Detained also on November 21, 2023. HACC completed his questioning on April 22, 2026 — two and a half years after the suspicion. The questioning lasted over a month. On the same day, the court permitted Labazyuk unrestricted travel abroad. The parliamentary mandate is intact. No verdict has been issued.

Fourth. The "Kvity Ukrainy" case. Kyiv developer Serhiy Kopystyra was building a residential complex on the lands of a state agro-firm and selling apartments to Ministry of Regional Development officials at discount prices — from one to eight thousand hryvnias per square meter, against a market rate of thirty. In June 2025, NABU and SAP issued suspicions to a former adviser of Minister Chernyshov, Maksym Horbatyuk, to former state secretary Volodin, and to the head of the state enterprise, Sushon. On June 23, 2025 — to Oleksiy Chernyshov himself. The classification is abuse of office plus receipt of unlawful benefit worth 14.5 million hryvnias. HACC set bail at 120 million. In October 2025 — a second suspicion, this time over the scheme of the Dynastia cottage development in Kozyn. The very same Dynastia for which, in May 2026, Andriy Yermak received a suspicion. At which point one can no longer tell where Big Construction ends and Midas begins. Because it is one and the same person in both frames, with the same call sign on the tapes. "Che Guevara."

Fifth. Reznichenko-Holyk proper. Dnipropetrovsk region. 392 million hryvnias of theft on road repairs in 2022 — already wartime funds. The suspicion was served on Reznichenko in September 2024, 30-million-hryvnia bail paid the same month. In November 2024, the appellate chamber left the measure of restraint intact. On December 10, 2025, NABU and SAP completed the investigation and opened the case files to the defense. Which in detective parlance means that the matter has not yet been sent to court. What will happen next? Look at the Labazyuk trajectory: HACC completes the questioning of the accused two and a half years in. Holyk in this case remains a witness. Even though his phone — seized back in May 2023 — became a key piece of evidence. It contained correspondence with contractor Denys Ostrovskyi of Stroyinvest, and a message in correspondence with an unidentified person, published by Glavcom in September 2024: "The lawyers will sort it all out." The lawyers, evidently, sorted it. Because Holyk received no suspicion. Because in June 2024 he left for Austria under the "Shliakh" wartime travel system on the basis of a disability certificate. Because somebody at the Dnipropetrovsk RSA approved that certificate. Because somebody at the State Border Service processed that exit. Because none of those who did received any questions from either NABU or DBR.

Five cases. Ten billion dollars. Not a single verdict against the program's curators. One in absentia verdict against a bribe-taking MP who fled. Not a single suspicion against the three people whom the country knows by name as the architects of the program.

Kubrakov, Tymoshenko, Holyk: Where They Are Now

On January 20, 2026, presidential decree №66/2026 appeared. Oleksandr Mykolaiovych Kubrakov was appointed presidential adviser on infrastructure and community cooperation, non-staff. The same Kubrakov whom the Verkhovna Rada removed from the office of deputy prime minister on May 9, 2024, with 272 votes, under the approximate formula of "weak regional policy." The same Kubrakov at whose home on July 11, 2025, DBR conducted searches in the case of MP Yevhen Shevchenko — the Belarusian-fertilizer story worth 14.5 million hryvnias. Kubrakov wrote on Facebook the same day: "I want to say that I have no connection whatsoever either to Yevhen Shevchenko, or to Belarus, or to the procurement of fertilizers, or to any other machinations. Our last contact took place before the full-scale invasion." No suspicion has been served on him. The decree exists. The office exists.

Kyrylo Tymoshenko, the man whose name appeared in every press release of the program throughout 2020–2022, was formally dismissed on January 24, 2023 — the same day as Lozynskyi — in the wave that swept out the first wartime corruption figures. The Chevrolet Tahoe scandal involving General Motors humanitarian aid, the Porsche Taycan scandal where someone provided him with the car for several months free of charge — all this swept Tymoshenko out of the deputy chief of staff position. In 2024 he became an adviser to Defense Minister Umerov on media affairs. In June 2024, NABU conducted searches at his home within the case of "leaks" from the Bureau itself. Tymoshenko confirmed the fact of the search — on his own, via Telegram. He received no suspicion. In 2026, by open sources, he continues to orbit the media bloc at the Ministry of Defense. No criminal case directly related to his role in running "Big Construction" has been opened against him.

Yuriy Holyk is the most curious of the three. He is the only one of the trio who never formally held a state position. Adviser to the prime minister in 2019–2020, head of "Regional Development" at the UIF analytical center from 2020 onward — he publicly called himself the "ideologist" of the program, filed no declarations, was not subordinate to any minister. Bihus.Info investigations recorded how his car entered the government quarter for years without being inspected at the checkpoint. In May 2023, NABU seized two phones from him. In December 2022, his home had already been searched. In July 2024, Bihus.Info published fragments of correspondence from his phone — with contractor Denys Ostrovskyi of Stroyinvest, who from 2016 had received roughly 4.5 billion hryvnias in state contracts. In September 2024, Glavcom added another quotation from Holyk's phone — correspondence with an unidentified person containing the phrase "The lawyers will sort it all out." A separate proceeding concerns the very fact of information leaks from NABU through these contacts. It involves not only Holyk, but also presidential adviser Heorhiy Birkadze and Gizo Uglava, the first deputy director of NABU, suspended in May 2024.

On June 13, 2024, Holyk exited Ukraine to Austria under the "Shliakh" wartime travel system on the basis of a disability certificate, issued on the strength of an assessment of his volunteer work with the "Songs Born in the ATO" charitable foundation. The travel permit was extended through October 16, 2024. What happened after that date is not documented in public sources. On paper: a man whose phone is the key piece of evidence in a 392-million-hryvnia theft case, whose correspondence with contractors has been published by the country's leading investigative outlets, whose name appears in every discussion of "NABU leaks" — is abroad. Without a suspicion. Without restrictions. Without any prospect of returning in handcuffs.

This is the umbrella's end product. Not amnesty. Not the absence of investigation. But a state of investigation in which all formalities are performed — searches, seizures, expert assessments, even television exposés — while the legal endpoint is neither there nor scheduled to arrive.

Why Midas Was Unveiled, and Big Construction Was Not

On November 10, 2025, NABU and SAP announced Operation Midas. Energoatom. Underboss Tymur Mindich ("Carlson" on the tapes) left for Poland hours before the searches. His partner Tsukerman ("Sugarman"). Former Energy Minister Halushchenko ("Sigismund," a.k.a. "the Professor"). Oleksiy Chernyshov ("Che Guevara"). A grand opening. Over a thousand hours of audio, more than seventy searches, a hundred million dollars channeled through the laundering office, by the estimate of NABU director Semen Kryvonos. Seven suspicions at once, plus six more in the parallel Dynastia case. On November 28, searches at Andriy Yermak's residence. On May 11, 2026, a suspicion served on Yermak himself for laundering 460 million hryvnias. The same Yermak who for five years had decided which ministers and curators to appoint, whom to send into disgrace, whom to rehabilitate. The Surgeon. Or Ali Baba — your choice.

How, fundamentally, does Midas differ from Big Construction? Not in scale. Ten billion dollars in road money is an order of magnitude larger than the hundred million that passed through the Energoatom laundering office. Not in structure. In both cases — a cartel design, beneficiaries close to the Presidential Office, the brand as umbrella. Not in procedural toolkit. The same HACC, the same SAP, the same NABU.

Midas differs in one detail. In the evidentiary base that became public. A thousand hours of recordings. One could listen to those recordings continuously for a week. In Big Construction, no such mass exists. There is Holyk's phone. There is correspondence. There are expert assessments. There are witness statements. But there is no audio that closes every question about motive, agreement, personal presence. Without audio, the evidentiary base remains the same as the one NABU brought against Rotterdam+. And, as we recall, that base did not arrive at a verdict.

Midas was unveiled not because the anti-corruption bodies suddenly became fearless. It was unveiled because for fifteen months, NABU detectives worked in a regime difficult for an ordinary lawyer to imagine — with wiretaps, hidden cameras, several agents under cover. They gathered so much that concealing it became more dangerous than announcing it. And one more thing. In July 2025, the Verkhovna Rada attempted, in a single amendment, to eliminate the independence of NABU and SAP. On July 22 — Law №12414, passed in ten minutes, transferring key powers to the Prosecutor General. Signed by the president the same evening. Within 24 hours — the European Union, via diplomatic channels, informed the government of Yulia Svyrydenko that it was halting the disbursement of all financial aid to Ukraine. Within two days — the so-called cardboard revolution on Ivan Franko Square, the first mass protests in Kyiv since the start of the full-scale invasion. Roughly five thousand people in a single evening. On July 31, the Rada reversed its July amendments by Law №13533. In that context — when the institution had just survived an attempt at extermination — NABU needed to demonstrate that the institution still functioned. Midas was that demonstration. Its sacrifices included the highest floors of Bankova — because only at that price could the trust of international partners and of the street be regained.

Big Construction stayed where it stayed. In the shadows. In yellow folders. In testimony that never became indictments. In the phone of a man who lives in Austria.

What This Means Now

In Rotterdam+, the first suspicions appeared a year after the formula. The first searches — two years in. The first closure — three and a half years after the case began. Today, nine years later, it is finally lost.

In Big Construction, the first prominent cases — Lozynskyi, Labazyuk, Odarchenko — appeared three to four years after the program's launch. Reznichenko — two years after the scheme was uncovered. The first verdicts: one, in absentia, against a fugitive. The rest remain in the waiting room. Counting from the date the Anti-Trust League's cartel complaint was filed with the Antimonopoly Committee (April 2020), today is the seventh year. In Rotterdam+, the seventh year was 2023 — when HACC closed the case for the first time on the expiration of pretrial timelines. Meaning: the point of bifurcation has already been passed. The trajectory from here, if nothing changes, is known — expert assessments, appeals, reclassifications, expired timelines. The Lozovyi amendments, which to this day have not been repealed, will do that work automatically.

The chair of the parliamentary committee on legal policy, Serhiy Ionushas, blocks the repeal of the Lozovyi amendments. The Antimonopoly Committee, now under new leadership, does not revisit the cartel allegations filed five years ago. The anti-corruption bodies are working on Midas, which is politically more important. For Big Construction, no resources remain. Perhaps, no political will remains either.

But that is the surface answer. The depth begins where one starts to understand how an umbrella works over time. An umbrella, raised from above, looks like a protective instrument at the moment of its opening. I stand above you, my brand is on you, you will not be touched. So thinks the contractor entering a tender with the minimal discount. So thinks the governor signing off on inflated work-completion reports. So thinks the coordinator in Kyiv who files no declarations but holds a permanent access pass to the government quarter. The brand above makes everyone below untouchable. At least — that is how it looks in the first year.

In the second year, the scheme begins to function differently. A suspicion in one region generates a request for a name from another region. Testimony in one case drags in defendants from three adjacent ones. Fragments of correspondence leak onto Telegram, where "the lawyers will sort it all out." And it turns out that the person holding the umbrella has lost the ability to lower it and walk away. Because the moment that person steps aside, the first contractor in interrogation will give testimony against the governor, the governor against the coordinator, the coordinator against the person who appointed the coordinator. This is called a chain reaction. In nuclear physics, it is stopped with cadmium rods. In political physics, with case closures.

So the umbrella holder is compelled to save everyone. Not out of compassion. Out of arithmetic. Every saved case is one blocked channel of testimony. Every defendant who receives the status of witness instead of suspect is one torn-out page from the testimonies that might have traveled upward. Reznichenko could not be left entirely untouched — too public, too visual a story, with the fitness trainer in the middle of it. But Holyk next to Reznichenko — categorically could not be touched. Because Holyk is not a Dnipropetrovsk episode. Holyk is Kyiv, he is Tymoshenko, he is the coordination council, he is the personally approved budgets, he is correspondence in which a chain of decisions becomes visible. A suspicion against Holyk is a suspicion against the coordination council. A suspicion against the coordination council is a question to whoever created the coordination council. That is already a different floor of the umbrella. Its upper edge.

The same mechanism operated in Rotterdam+. Initially Dmytro Vovk was being saved — because his suspicion would have dragged in the entire NEURC board. Then Kryvenko — because her suspicion would have dragged in whoever approved the formula at Cabinet level. Then Antonova — by the same logic. Each new closure was not an act of mercy. It was a piece torn from the puzzle that would otherwise have shown the full sequence of decision-making from regulator to Cabinet and above. As long as a single piece remained, the picture could be hidden. When the missing pieces outnumbered the threshold for recognition — the picture became legally invisible. An invisible picture does not arrive in court. It does not arrive at a verdict. It does not enter history as a corruption case — only as "a former scandal that led nowhere."

This is the final function of the umbrella. Not the protection of subordinates, but the hermetic sealing of the construction. At that moment, the umbrella holder ceases to be its owner. He becomes its hostage. He can no longer lower it, even if he wished to. Because lowering it means opening access to all the testimony at once. The first contractor will give evidence against the governor, the governor against the curator, the curator against someone else. Up to the top floor. To the floor that created the program as its own brand. The umbrella that initially hung over everyone turns into a noose that holds one. The brand's owner.

Hence the explanation of the peculiar moves by the top floor of the government beginning in the autumn of 2025. Why the attack on NABU-SAP in July 2025? Because the detectives had come too close to the cases where names began to align into the required chain. Why was Midas, in November 2025, finally announced despite maximum political damage? Because concealment became more dangerous than disclosure: the EU pressure, the cardboard revolution, the reputational consequences of freezing the anti-corruption reform. Why the suspicion against Yermak in May 2026 specifically for Dynastia and not for roads? Because Dynastia is a smaller, politically more containable episode. Roads are a different scale. Roads are the chain that begins with a fitness trainer and leads where it cannot be allowed to lead. So roads remain in the Reznichenko zone. Holyk remains in Austria. Tymoshenko remains an adviser at the Ministry of Defense, and Kubrakov an adviser to the president.

Big Construction is not being investigated not because it cannot be investigated. It is not being investigated because investigating it would mean dismantling the umbrella. And the umbrella, at this moment, is no longer holding only the brand's owner aloft. It holds a vertical construction of people who rose because of the brand and who cannot step away from it now. Not into ministerial advisory posts, not into presidential advisory posts, not into Austria on disability certificates. They can physically depart — but legally they remain elements of the same construction. And as long as the construction stands, none of them will be touched.

Ten billion dollars — is that a lot or a little, when the question is whether to allow them to disappear? If it is a lot, then where are the suspicions against those who coordinated the program? If it is a little — how much would it take for this system to function?

The question seems rhetorical. In fact it has a precise, unpleasant answer. Ten billion dollars is exactly the amount it takes for a program's brand to turn from an umbrella into a noose. The amount it takes for the person who installed the brand to lose the ability to renounce it without losing everything else. The amount it takes for a chain reaction, on the first suspicion served against a curator, to tear through the entire vertical to the very top.

And this explains the silence. Not the corruption silence. The legal one. The same silence in which Rotterdam+ has been dissolving for nine years. And the same silence into which everything that, between 2020 and 2022, was called the largest infrastructure project of independent Ukraine is now slowly sinking.

The seventh year. The same point at which Rotterdam+ was first closed. Everyone who has read that case to the end knows that, in the Ukrainian anti-corruption tradition, such points always resolve in favor of silence. This one, in all likelihood, will too.

Unless this protective canopy, at last, plays with its holder the same cynical game it inevitably plays with everyone who holds it too long over other people's sins. While the rain falls to one side, it seems you are safe — you take no part in the dirty business, you merely create the conditions for it, preserving a proud distance and the illusion of full detachment. Those acting under your canopy seem foreign and far away. But this lasts only until the first storm. When the executors are finally pressed to the wall, every gaze turns instantly to the hand that held the shelter. And then you realize, with horror, that you have long since ceased to be a bystander and have become the principal hostage of the scheme. Writing it all off as coincidence or bad weather will no longer work: the umbrella that made the crime possible becomes the iron proof of your complicity — a burden you can no longer carry, but lowering which now means signing your own verdict.