The “golden silence”: The State Bureau of Investigation explains why it doesn’t see a $6 billion black market for precious metals
10 April 12:47
ANALYSIS 
The gold market in Ukraine has always been one of the most opaque. According to various estimates, the state treasury loses up to 6 billion hryvnias annually due to the black market trade in gold. Schemes involving customs value, the mass import of gold bars by “smugglers” disguised as personal belongings, the fragmentation of large chains into hundreds of sole proprietorships, and the sale of products without the hallmark of the State Assay Service—this is a reality that demands decisive action from government and law enforcement agencies, particularly the State Bureau of Economic Security (SBES).
The BEB’s Position
In response to the journalists’ detailed inquiry, which contained 14 strategic questions—ranging from the fate of the “B2B Jewelry” pyramid scheme’s assets to an analysis of the detectives’ own corrupt ties—the Bureau gave a curt reply. They claimed that journalists were asking them to “create new information,” while they are only authorized to provide documents that are already prepared.
Questions
1. According to various expert estimates, the budget loses up to 6 billion UAH per year due to the shadow gold market. What portion of these losses is attributable to manipulation of customs values, and do your experts confirm the figure of 6 billion UAH? What is your agency’s estimate of the size of the shadow and transparent markets? What is the ratio of the shadow market to the official market in percentage terms?
2. How does the State Customs Service (SCS) collaborate with the State Customs Service to identify “couriers” (individuals) who import bank gold in small batches disguised as personal belongings?
3. Do you track where gold is currently being imported for large jewelry factories? 4. What are the countries of origin for the yellow metal? How much of this gold is smuggled or remelted from scrap without paying taxes?
5. Does the BEB have any investigations into retail chains that sell gold for cash without using cash registers and without proper hallmarking by the State Assay Service? Please provide a list of these chains.
6. Has the BEB conducted an analysis to determine whether a banking license for metal transactions is being used as a “front” for individuals to transfer capital abroad?
7. What is the status of the assets of financial pyramid schemes (such as B2B Jewelry) that operated with gold certificates? How much actual gold was seized, and where is it currently located?
8. Have there been documented instances of BEB employees or other law enforcement officials facilitating illegal gold trading schemes? What measures are being taken to ensure your investigators do not become “insiders” for major market players?
9. What specific powers does the BEB lack to completely shut down channels for the sale of gold without documentation?
10. What karat gold most frequently appears in corrupt shadow schemes, and what is its origin (countries)?
11. How many pieces of jewelry in large chains have been tested for hallmark compliance over the past year (or several years)? Do you record cases where lower-quality metal, smuggled from Turkey or the UAE, is sold under the guise of 585-karat gold?
12. Has the BEB analyzed the scheme of “fragmenting” large jewelry chains into hundreds of sole proprietorships? 13. Why does a chain with a well-known name operate as a collection of individual entrepreneurs, avoiding the general taxation system, and isn’t this a direct indication of an organized tax evasion scheme?
14. What percentage of transactions in jewelry stores bypass the cash register or involve fictitious receipts? Have test purchases been conducted to verify the actual taxation of expensive jewelry costing over 50–100 thousand hryvnias?
The official response signed by Deputy Department Head Andriy Sergeyev states:
“Complying with a request for public information does not involve creating new information and does not require analytical work… The defining characteristic of public information is that it is, by its very nature, a pre-existing product recorded on a specific medium.”
In other words, if the BEB does not have a separate folder labeled “List of networks trading gold without cash registers,” then such a problem does not seem to exist for the agency.
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Analytics Outside the Law?
The Bureau of Economic Security was created precisely as an analytical body that was supposed to see through schemes. However, when it comes to specific figures on the shadow market, the BES has distanced itself from any estimates.
“The requested information must be ‘ready and available’ and should not require the collection of any additional data, and information managers should not specifically create or collect certain information in response to the request,” the response states.
Instead of answering questions about how much gold was seized from pyramid schemes and which countries are the leading suppliers of contraband (Turkey or the UAE), journalists were advised to change their status from “information requesters” to “complainants.”
This raises a rhetorical question: wouldn’t such a stance by the Bureau effectively serve as a signal to “shadow operators”? While the budget continues to lose billions due to the scheme of “fragmenting” networks into sole proprietorships and the uncontrolled circulation of scrap metal, analytical oversight of the gold market in Ukraine currently remains in a state of “procedural hibernation.”
RESPONSE FROM THE BEB
The Economic Security Bureau of Ukraine has reviewed the request from the Ukrainian edition of Kommersant
dated April 2, 2026 (BEB Ref. No. ZPI-79/0/5 dated April 3, 2026), which was sent to
the BEB’s email address designated for requests for public information, and
concerns issues related to the shadow circulation of gold.
Part 2 of Article 19 of the Constitution of Ukraine provides that
state authorities and local self-government bodies, as well as their officials, are obligated to act solely on the basis of, within the limits of, and in the manner prescribed by the Constitution and the laws of Ukraine.
In accordance with Part 1 of Article 19 of the Law of Ukraine “On Access to
Public Information” (hereinafter—the Law), a request for information is a request by a person to
the information holder to provide public information in their
possession.
According to Part 1 of Article 1 of the aforementioned Law, public information is
recorded and documented by any means and on any medium
information that has been obtained or created in the course of public authorities performing their duties as provided by applicable law, or that is in the possession of public authorities or other
of public information as defined by the Law. Thus, fulfilling a request for public information does not involve the creation of new information and does not require analytical work.
Furthermore, the Review of Supreme Court Case Law on Disputes Concerning the
an individual’s right to access public information (2020) establishes that
the defining characteristic of public information is that it is, by its very nature, a pre-existing product recorded on a specific medium. Only a public authority may obtain and/or create such a product in the course of performing its administrative functions.
In view of the above, one of the key characteristics of public information is its
prior recording, i.e., its existence in a documented form at the time the request is submitted.
2 The Law of Ukraine “On Access to Public Information” regulates relations regarding
access to information that already exists and does not oblige information holders
to create new information in response to a request.
Thus, information that requires summarization, analytical processing of data,
conducting additional substantive analysis, or being created in any other way, does not fall under the provisions of Part 1 of Article 1 of the Law, does not meet the criteria
“reflected and documented,” and is not yet formed.
We also inform you that the requested information must be “ready and accessible” and
must not require the collection of any additional data, and information managers
information must not specifically create or collect certain information in
response to the request.
Thus, in response to requests for public information, only
information created in the course of the activities of the Economic Security Bureau of Ukraine or held by it.
In light of the foregoing and based on the results of our review of the issues raised in the request
we hereby inform you that the aforementioned letter does not contain a request for the provision of existing and
documented public information within the meaning of the Law, but includes questions
of an analytical and evaluative nature, the consideration of which is carried out in accordance with
the requirements of the Law of Ukraine “On Citizens’ Appeals.”
In accordance with Article 5 of the Law of Ukraine “On Citizens’ Appeals,” the appeal
must include the citizen’s last name, first name, and patronymic, as well as their place
of residence, a description of the issue raised, comments, suggestions, statements, or complaints, as well as requests or demands. A written appeal must be signed by the applicant and dated.
An electronic petition must also include an email address or other
means of communication through which a response can be sent to the applicant. The use
an electronic digital signature when sending an electronic appeal is not
required.
Pursuant to Part 1 of Article 8 of the Law of Ukraine “On Citizens’ Appeals,”
, a petition that does not comply with the requirements of Article 5 of this Law is deemed
anonymous and shall not be considered.
Please be advised that citizens may submit appeals to the Bureau of Economic
Security of Ukraine in electronic form via the official website of the BEB at the following link:
https://esbu.gov.ua/dlia-hromadskosti/zvernennya-gromadyan/formy-zvernen.
In addition, appeals may be submitted by mail to the following address:
31 Sholudenko St., Kyiv, 04116, or by calling the BES hotline: (044) 236-13-97.
Requests are accepted Monday through Thursday from 9:00 AM to 6:00 PM,
and on Friday from 9:00 AM to 4:45 PM.
Deputy Head of the Department –
Head of the Organizational
Support and Archives of the Department
Document Flow and Control
Andriy SERGEYEV
Who profits from shady schemes in the jewelry industry?
As a reminder, in Ukraine, the state budget loses at least 5.9 billion UAH in taxes every year due to shadow schemes in the jewelry market. This was stated by Danylo Getmantsev, chairman of the parliamentary committee on finance, tax, and customs policy.
According to him, the jewelry market is one of the sectors where shadow practices have become systemic. Large chains are massively splitting their businesses into sole proprietorships, which allows them to operate under a simplified tax system, pay only a single tax, and avoid VAT and income tax.
Separately, Getmantsev draws attention to the widespread underreporting of wages. The average declared wage in the industry is only about 8,800 UAH, although actual wages are significantly higher: jewelers can earn 30,000 UAH or more, and salespeople—22,000 UAH or more. Such a gap, he says, indicates widespread “under-the-table” payments.
READ ALSO: Businesses “Split” into Sole Proprietorships: Well-Known Jewelry Chains Fined 70 Million Hryvnias
Another indicator of the shadow economy is the market structure: the number of sole proprietorships in the jewelry sector is approximately nine times higher than the number of legal entities. This directly points to the systematic use of a scheme to “fragment” large businesses. Even within the simplified tax system, some entrepreneurs continue to minimize their tax liabilities: certain sales are not processed through cash registers and are not reflected in official reports.
At the same time, as Getmantsev emphasizes, there are also transparent companies in the market that operate “above board,” pay taxes, and officially pay employees 18–37 thousand UAH depending on their position. However, the shadow segment, in his estimation, still significantly predominates.
Despite the fact that the government previously made concessions to the business community and abolished the assay fee, the expected effect of de-shadowing did not materialize—a significant portion of players continue to operate under the old schemes.
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