Signs of aiding the aggressor state: why law enforcement should launch an investigation against the former leadership of the State Aviation Service

Decisions made by the former leadership of the State Aviation Service of Ukraine – ex-head Oleksandr Bilchuk and his deputy Ihor Zelinskyi – should be investigated within the framework of criminal proceedings. Creating obstacles to the use of Il-76 military transport aircraft by the army, cooperation with sanctioned Russian companies, and using documents from enterprises connected with the Russian military-industrial complex created risks for the country's defense capabilities. As lawyer Dmytro Kasianenko told UNN in an exclusive comment, this situation may not be about management errors, but about possible complicity with the aggressor state.

Earlier, UNN investigations revealed that the former leadership of the State Aviation Service of Ukraine, including ex-head Oleksandr Bilchuk and his deputy Ihor Zelinskyi, made a number of decisions clearly in Russia's interests, which could have caused significant damage to Ukraine's defense capabilities.

Upon examining the situation, it became evident that the decision-making process, which did not serve state interests, was systemic rather than an isolated technical error.

Bilchuk and Zelinskyi effectively established approaches under which documents from the aggressor state and sanctioned Russian companies were regularly used by the Ukrainian aviation regulator to make decisions. This refers to decisions regarding airworthiness, technical compliance, and admission of aircraft to operation. 

Decisions detrimental to Ukraine's interests

According to UNN, it was Zelinskyi who blocked the possibility of the Ministry of Defense using Il-76MD military transport aircraft, which could have significantly strengthened the logistics of the Armed Forces of Ukraine during the full-scale war. Despite legal decisions dating back to the 1990s that allowed the operation of such aircraft without changing their status, Zelinskyi effectively halted their use in 2023, sharply changing his own position.

Initially, in June 2023, Zelinskyi officially acknowledged the absence of obstacles to the operation of Il-76MD in Ukraine's interests, which was consistent with the position of the aviation market and the Ministry of Defense. However, six months later, in December, he stated that these aircraft allegedly lacked civil certificates, making their registration and use impossible. This decision led to the creation of artificial obstacles to the use of critically important aviation equipment, additional costs for its maintenance, and the loss of opportunities to perform military, humanitarian, and evacuation missions in the midst of the war.

The story with the Il-76MD is just part of a larger narrative. Over the years of Zelinskyi's work with Bilchuk, other resonant decisions were made that clearly played into the hands of the aggressor country. 

For example, in early August 2025, the then head of the State Aviation Service, Oleksandr Bilchuk, transferred the maintenance documentation for Mi-8MT(MTV) helicopters to AAL Group Ltd, a company with direct ties to the Russian military-industrial complex. This decision jeopardized the operation of this type of helicopter by all components of Ukraine's security and defense sector.

It was later revealed that AAL Group Ltd, registered in the offshore jurisdiction of the UAE, has direct ties to the Russian military-industrial complex. And as reported by Fedir Venislavskyi, a member of the Verkhovna Rada Committee on National Security, the ultimate beneficiaries of AAL Group Ltd are the company "Russian Helicopters" from the state concern "Rostec."

Bilchuk's decision was made despite the fact that the US Transportation Command USTRANSCOM had already declared AAL Group Ltd unsuitable for cooperation in 2024. After a public scandal, the Government dismissed Bilchuk from his position as head of the regulator.

In addition, by decisions of Bilchuk and his "right-hand man" Zelinskyi, more than 20 such Il-76 aircraft were excluded from the state register and came under Russia's control. The former leadership of the State Aviation Service also allowed gross violations of sanctions legislation by continuing cooperation with the sanctioned Russian PJSC "Il". In particular, under Zelinskyi's signature, airworthiness certificates were issued based on the decisions of this Russian developer of Il-76 transport aircraft, despite the presence of a certified organization in Ukraine for such support. This effectively put Ukrainian operators before a choice between cooperation with Russia or stopping the operation of aircraft, and could also provide Russia with tens of millions of dollars in additional revenue. 

Criminal liability instead of a new appointment

In February of this year, Deputy Prime Minister for Reconstruction Oleksiy Kuleba dismissed Ihor Zelinskyi from the post of Deputy Head of the State Aviation Service. As already noted, Oleksandr Bilchuk, the head of the regulator, was also dismissed in the fall. However, in December it became known that Kuleba submitted Zelinskyi's candidacy for consideration by the Cabinet of Ministers of Ukraine for his appointment as head of the State Aviation Service. What forced the Deputy Prime Minister to change his position is not yet known. However, according to lawyer Dmytro Kasianenko, the facts revealed by journalists indicate the need for law enforcement agencies to intervene in the situation.

"The regulator has no right to issue permits, certificates, or other acts if their basis is decisions or conclusions of Russian companies that are under sanctions. The sanctions regime means a complete ban on any direct or indirect cooperation, including through documents, expert opinions, or 'technical justifications.' Issuing a permit in such a situation actually legalizes the influence of a sanctioned entity through a state body of Ukraine. If such permits are issued, it gives grounds to talk about circumventing sanctions and continuing actual interaction with the Russian Federation," explained lawyer Dmytro Kasianenko.

According to him, the actions of former officials of the State Aviation Service can be qualified under Article 111-2 of the Criminal Code of Ukraine (complicity with the aggressor state), if intent and real assistance to the aggressor country are revealed, Article 364 of the Criminal Code of Ukraine (abuse of power), provided that the decision was made contrary to the interests of the State Aviation Service, Article 367 of the Criminal Code of Ukraine (official negligence), if the officials "did not check" the sanctions restrictions and procedures. 

Investigation of such facts is the competence of the SBU (in terms of national security) and the SBI/NABU - depending on the subject and consequences. The key here is not rhetoric, but documents: who signed, on what basis, whether there was a sanctioned chain, and what legal effect it created. This is what determines responsibility 

The story with Zelinskyi and Bilchuk is not just a matter of the past, but a direct challenge of the present. After all, some of their decisions still create problems and actually destroy Ukrainian aviation. That is why a public and legal analysis of these decisions is fundamentally important.

In conclusion, it is not just about the personnel responsibility of individual officials, but about the need to eliminate the practice whereby the Ukrainian regulator, in the conditions of a full-scale war, actually recognizes the technical and legal subjectivity of the aggressor state. The decisions of the regulator under the leadership of Zelinskyi and Bilchuk contradict the interests of national security, Ukraine's sanctions policy, and undermine trust in the aviation regulator as a whole. And it is obvious that there is a high probability that after returning to the State Aviation Service, Zelinskyi will continue this practice.