Welcome to the U.S.-Ukraine Business Council

UKRAINE BUSINESS NEWS - TEN ARTICLES
IMF, $3 Billion VAT Owed, Land Sales, Boeing-UIA, Bunge, Raytheon, Lilly

INDEX OF ARTICLES  ------
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1.  IMF SAYS UKRAINE HAS ENOUGH FOREIGN RESERVES TO MAKE
ALL EXTERNAL PAYMENTS, INCLUDING FOR GAS

Interfax Ukraine, Kyiv, Ukraine, Thu, February 18, 2010

2.  UKRAINE: VAT REFUNDS NOT PAID TO EXPORTERS TOTAL 
UAH 23 BILLION (3 BILLION DOLLARS), HURTING INVESTMENT 

Yurii Haiduchyk, Ukrainian News Agency, Kyiv, Ukraine, Fri, Feb 19, 2010

3 UKRAINE NEEDS UNPOPULAR REFORMS, BALANCED STATE FUNDS, SAYS NBU 
Low level of VAT reimbursement not taken into account when show budget deficit
Interfax Ukraine, Kyiv, Ukraine, Friday, Feb 19, 2010
 
4 UKRAINE INTERNATIONAL AIRLINES ADDS ADDITIONAL 
BOEING 737-800, FLEET NOW TOTAL NINETEEN PLANES

Ukrainian News-on-line, Ukrainian News Agency, Kyiv, Ukraine, Mon, Feb 22, 2010 

5 UKRAINE: MORATORIUM ON LAND SALES NOW UNTIL JAN 1 2012
MyLand, Center for the Land Reform Policy in Ukraine, Kyiv, Ukraine, Tue, Feb 2, 2010

6 UKRAINE: SO MUCH FOR LAND AUCTIONS AND FOR THE RULE OF LAW!
State land can be purchased for low prices. Ukraine not a state with rule of law.
MyLand, Center for Land Reform Policy in Ukraine, Kyiv, Ukraine, Wed, Feb 17, 2010

7.  UKRAINE MACRO MONTHLY - FEBRUARY
Erste Bank Ukraine Research, Kyiv, Ukraine, Tue, Feb 16, 2010

8.  BUNGE JOINS SPONSORS OF 'BLACK SEA GRAIN - 2010' CONFERENCE
UkrAgroConsult, Kyiv, Ukraine, Mon, February 22, 2010 

9.  RAYTHEON JOINS U.S.-UKRAINE BUSINESS COUNCIL (USUBC)
Technology and innovation leader in defense, homeland security and other government markets 
U.S.-Ukraine Business Council (USUBC), Wash, D.C., Fri, Feb 5, 2010 
 
10.  ELI LILLY JOINS U.S.-UKRAINE BUSINESS COUNCIL (USUBC)
Making medicines that help people live longer, healthier, more active lives.
U.S.-Ukraine Business Council (USUBC), Wash, D.C., Wed, Feb 3, 2010
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1 IMF SAYS UKRAINE HAS ENOUGH FOREIGN RESERVES TO
MAKE ALL EXTERNAL PAYMENTS, INCLUDING FOR GAS

Interfax Ukraine, Kyiv, Ukraine, Thu, February 18, 2010

KYIV - Ukraine has sufficient foreign reserves to remain current on all of its external payment obligations, including payments for imports of natural gas, Senior Advisor at the IMF External Relations Department David Hawley said at a regular press briefing in Washington on Thursday.

Asked about the possible resumption of the IMF's cooperation program with Ukraine under the Stand-By Arrangement (SBA) after the presidential election, Hawley said that the fund is ready to discuss this issue with the Ukrainian authorities. "I can say only that the fund stands ready to discuss with the authorities policy priorities and prospects for 2010," he said.

IMF officials haven't yet met with Ukraine's new authorities since the election, but the fund's regular contacts with the authorities continue on an ongoing basis, Hawley added.

As reported, the IMF in autumn 2008 decided to disburse about $17 billion under the SBA. Since then, Ukraine has already received three tranches worth almost $11 billion. The first $4.5 billion tranche was given to the National Bank of Ukraine (NBU) in November 2008. The IMF's second tranche - worth about $3 billion - was extended in May 2009.

The funds were split between the NBU and the government of Prime Minister Yulia Tymoshenko. The third tranche (worth $3.5 billion) was provided in August 2009 and was at the disposal of the Tymoshenko government alone.

The allocation of the fourth tranche, worth $3.8 billion, was scheduled for November 2009 following the third review of the IMF's cooperation program with Ukraine. The IMF mission ended its work in Kyiv late in October 2009, but did not issue a positive statement on the completion of the review. The IMF said repeatedly that it expected a consolidated position from the Ukrainian authorities in the question of implementing anti-crisis measures.

After the Ukrainian government received the third tranche, it also used about $2.1 billion through the conversion of Special Drawing Rights (SDR) allocated by the IMF as part of a general allocation of SDRs among all the IMF member countries.

Speaking at a press conference in Washington on January 14, 2010, IMF Managing Director Dominique Strauss-Kahn stressed the possibility of resuming cooperation with Ukraine under the Stand-By Arrangement (SBA) after the presidential election in Ukraine was over.
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2.  UKRAINE: VAT REFUNDS NOT PAID TO EXPORTERS TOTAL UAH 23 BILLION (3 BILLION DOLLARS), HURTING INVESTMENT 

Yurii Haiduchyk, Ukrainian News Agency, Kyiv, Ukraine, Fri, Feb 19, 2010

KYIV - The Ukrainian Union of Industrialists and Entrepreneurs estimates the amount of value-added tax that has not yet been refunded to exporters at about UAH 23 billion [around 3 billion US dollars.]  The Ukrainian Union of Industrialists and Entrepreneurs’ President Anatolii Kinakh announced this to journalists.

"According to our expert conclusions, about UAH 23 billion of un-refunded VAT has accumulated as of today. At this rate, it will amount to UAH 28 billion by March 1," Kinakh said. According to Kinakh, the failure to refund value-added tax is one of the main problems preventing implementation of investment projects in the Ukrainian economy.

"The problem involving refund of VAT is deepening. This problem is not new, but the amount that has accumulated in the country now is unprecedented in any difficult period," Kinakh said. According to him, this problem requires immediate solution because the non-refund of value-added tax has a negative effect on the country’s economy.

As Ukrainian News earlier reported, the State Tax Administration’s Chairman Serhii Buriak has estimated that the debt on VAT refunds exceeds UAH 20 billion. The Presidential Secretariat has estimated the amount of un-refunded value-added tax at UAH 25 billion. President Viktor Yuschenko estimated the amount at UAH 19 billion in December 2009.

FOOTNOTE: USUBC MEMBERSHIP URGES STRONG ACTION - The membership of the U.S.-Ukraine Business Council (USUBC) believes one of the highest priorities for the new Ukrainian president is to work out a plan for the government to pay out the huge VAT refunds that are long overdue to private businesses, especially exporters.  The track record of the Ukraine government on this issue is just horrible and unprecedented as explained by above by Anatolii Kinakh.  Ukraine owes private business more in VAT refunds for a longer period of time than any country in the world. 

The Ukraine government continues to crush, hinder and stop badly needed private business investments in Ukraine through its many anti-private business laws, regulations, policies, actions and lack of actions.  USUBC urges the new president to stop the many anti-business actions and take real and positive actions to move the Ukraine economy and private business investments forward.  Ukraine and its people need the income, the jobs, the taxes, the investment and the wealth, now, in 2010.
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3.  UKRAINE NEEDS UNPOPULAR REFORMS, BALANCED STATE FUNDS, SAYS NBU 
Low level of VAT reimbursement not taken into account when show budget deficit

Interfax Ukraine, Kyiv, Ukraine, Friday, Feb 19, 2010

KYIV - Unpopular reforms and balanced state funds could put the Ukrainian economy on the path of stable long-term growth, according to experts from the National Bank of Ukraine (NBU).

"Only a combination of a pragmatic monetary and credit policy, unpopular economic reforms and balanced state funds can be the proper response to modern global challenges and can put the Ukrainian economy on the path of stable long-term growth," reads an NBU report.

The NBU said that the improvement in the macroeconomic situation in the country seen since Q2, 2009 is slow and unstable, as it does not have a firm foundation.

The central bank said that the slow realization of economic reforms and imbalances of state funds created serious risks for the monetary and credit market in 2009.

"The state of the monetary and credit markets depends directly on the development of the real economy, and monetary and prudential measures cannot be considered as the only factors required for overcoming the crisis in the economy and the financial markets," reads the document.

The bank said that the improvement of economic development indicators was based on a certain improvement of the situation for Ukrainian exporters on foreign markets, which carries risks if there is a second wave of global economic crisis. In addition, the good harvest of 2009 and the statistical effects of a low comparative base also impact the situation.

"Domestic factors aiding the resumption of economic growth are still rather weak, in part due to the slow realization of structural reforms in the economy. Evidence of this is low investment activity of economic entities, the figures of which in 2009 had a downward trend," reads the report.

The NBU said that investment in fixed capital over the first nine months of 2009 year-over-year dropped by 43.7%, while in H1, 2009 it went down by 43.3% and in Q1, 2009 it fell by 39.5%.

The central bank said that a fall in economic activity entailed a fall in real wage for the first time in the past nine years. Real wages in 2009 declined by 9.2% year-over-year. The report also says that the 2009 consolidated budget posted a UAH 21.607 billion deficit, while in 2008 the deficit was UAH 14.183 billion.

LOW LEVEL OF VAT REIMBURSEMENT
"We should take into consideration that the actual deficit of the budget was higher, as the official indicator of the budget deficit does not take into account the low level of VAT reimbursement, payment of taxes in advance and the interpretation of SDRs from the International Monetary Fund [IMF'] as being budget revenues," reads the report.

The NBU said that the legitimacy of considering the IMF's SDRs as budget revenues and not as contributing to the budget deficit is not obvious from an economic point of view.
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4.  UKRAINE INTERNATIONAL AIRLINES ADDS ADDITIONAL 
BOEING 737-800, FLEET NOW TOTAL NINETEEN PLANES
UIA Expects to add fourth Boeing 737-800 in April

Ukrainian News-on-line, Ukrainian News Agency, Kyiv, Ukraine, Mon, Feb 22, 2010 

KYIV - Kyiv-based Ukraine International Airlines [UIA] company has against increased its aircraft fleet by one to nineteen planes, the company said.  According to the report, on February 20, Ukraine International Airlines obtained a Boeing 737-800 manufactured in Seattle.

The new airliner was registered in Ukraine and obtained the registration number of UR-PSB. The Boeing 737-800 is the third plane of this modification in the aircraft fleet of the company. Ukraine International Airlines hopes to obtain the fourth plane of this type in April.

As Ukrainian News earlier reported, in September 2009, the Ukraine International Airlines obtained the second Boeing 737-800. The number of passengers transported by Ukraine International Airlines shrank by 117,000 or 6.96% to 1,563,000 in 2009, compared with 2008. Ukraine International Airlines was founded in 1992.

The airline company has a fleet of 18 Boeing airplanes, including 17 passenger airplanes and one cargo airplane. The state owns 61.6% of the shares in Ukraine International Airlines (the State Property Fund manages these shares), Austrian Airlines owns 22.5%, and the European Bank for Reconstruction and Development 9.9%.

NOTE:  Ukraine International Airlines (UIA) and Boeing are members of the U.S.-Ukraine Business Council (USUBC), Washington, D.C.
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Promoting U.S.-Ukraine business relations & investment since 1995.
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5.  UKRAINE: MORATORIUM ON LAND SALES NOW UNTIL JAN 1 2012

MyLand, Center for the Land Reform Policy in Ukraine, Kyiv, Ukraine, Tue, Feb 2, 2010

KYIV - Today, on February 2, 2010,  the official newspaper of the Parliament of Ukraine, Holos Ukrainy (Voice of Ukraine), promulgated the law of January 19, 2010, which imposes additional restriction upon agricultural land market of Ukraine, namely, bares it by the date of January 1, 2012.

Before the trade in farmland was impossible due to clauses of the Land Code which required coming into force of two laws - on land market and land cadastre - as a precondition for lifting the ban on trade. On December 22, 2009 the Parliament passed the law introducing additional safeguard - a date earlier of which the trade was prohibited, laws or not.

President vetoed the law and sent it back to the Parliament on December 29, 2009. MPs managed to overcome the veto on January 19, 2010. President of Ukraine Victor Yushchenko did not sign the law, and it was signed by the Speaker, according to the Constitution. Thus from today on the moratorium shall last till January 1, 2012, and thereafter, if the two laws are not passed.

LINK: http://www.myland.org.ua/index.php?id=1847&lang=en &razd=NEWS
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6.  UKRAINE: SO MUCH FOR LAND AUCTIONS AND FOR THE RULE OF LAW!
State land can be purchased for low prices. Ukraine not a state with rule of law.

MyLand, Center for Land Reform Policy in Ukraine, Kyiv, Ukraine, Wed, Feb 17, 2010

KYIV - RBC-Ukraine [website] reports today that the Parliament of Ukraine, Verkhovna Rada, turned down the draft law on land auctions. The draft was submitted by the  Government of Ukraine on January 28, 2009.

As a result, land auctions which are declared by the Land Code as mandatory in many cases of alienation of state-owned or municipal land, are still a matter of very vague legal nature. Literally speaking, the Land Code does say that it is a must to hold an auction when selling or leasing out public land, but at the same time, the procedure for doing so shall be defined by the law passed by the Parliament.

Constitutional Court of Ukraine on many occasions ascerted that the Constitution of Ukraine in inambigous terms requires the "regime of property" to be defined and set up by the law only, not by any subordinate act or a bylaw.

The Court construed the regime of property as all rules regarding acquisition, possession, use and disposal of property, including land and landed property, by means of sale, lease or allocation into permanent use or other forms of tenure.

Thus land auctions which sporadically take place in Ukrainian cities are not fully legal. We would even say that they are fully illegal.

It is sadly enough that Ukraine, failing to pass the necessary law and holding land auctions without the said law, loses two points at once: it allows state land to be taken away for lesser money and it also denies its status as a state with a rule of law.

LINK: http://www.myland.org.ua/index.php?id=1912&lang= en&razd=NEWS
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7.  UKRAINE MACRO MONTHLY - FEBRUARY 2010

Erste Bank Ukraine Research, Kyiv, Ukraine, Tue, Feb 16, 2010

KYIV - The Erste Bank Ukraine Research team has issued the following macro monthly report for February 2010:

GDP
According to preliminary estimates from the State Statistics Committee, 4Q09 real GDP declined by 7% y/y. The figure came as a very big negative surprise for us and for other local economists. We will not change our outlook for 2010 GDP, which currently stands at 2.8% growth, until we see the full GDP breakdown. If the reason for the strong 4Q GDP decline was in inventories, taxes and imports, we will most likely not review our estimates. However, if there was a notable decrease in household consumption, we might have to reevaluate our view of the current economic environment.

INFLATION 
Inflation is likely to decrease in y/y terms for the next several months, due to a base effect, as during the same period of last year, Ukraine was still feeling the effects of sudden hryvnia devaluation.

WAGES 
In 2009, the average wage in Ukraine increased by 5.5% to UAH 1,906 (EUR 165). The increase is well below the official consumer inflation for 2009 of 12.3%. As for 2010, the income of the population is expected to increase only slightly, based on the expected 2.8% real GDP growth.

PUBLIC DEBT
Public debt now stands at 32% of the estimated 2009 GDP. The National Bank of Ukraine has monetized government debt obligations worth 3.5% of GDP. Officially, the government ended the 2009 fiscal year with an official deficit of only 2.7% of GDP. This is due to the use of coverage techniques of the actual deficit. Currently, we expect the total public debt to increase to 35% of GDP in 2010 on new borrowings and higher nominal GDP.

BALANCE OF PAYMENTS 
In 2009, Ukraine suffered the worst capital outflows in CEE in relation to GDP and net FX reserves. The total outflow covered by the country’s FX reserves totaled USD 13.8bn. The main problem for the balance of payments was sentiment among the population. The National Bank has estimated the total balance of payments deficit for 2010 at USD 3.2bn. This is a feasible target, as there should not be a money issuance commensurate to nominal GDP growth or a dramatic decline in consumer confidence.
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8.  BUNGE JOINS SPONSORS OF 'BLACK SEA GRAIN - 2010' CONFERENCE

UkrAgroConsult, Kyiv, Ukraine, Mon, February 22, 2010 

KYIV - BUNGE has joined the sponsors of the Seventh international conference ‘Black Sea Grain - 2010’. BUNGE is one of the leading agribusiness and food companies in the world. The company has representative offices in over 30 countries worldwide.
 
UkrAgroConsult Company is pleased to invite you to the Seventh International Conference Black Sea Grain - 2010 being held April 21-22, 2010, at the InterContinental Hotel, Kyiv, Ukraine. . The key topic of the Conference will be “Black Sea Region: Agrarian Strategies 2010+”.

 The participants of the Black Sea Grain - 2010 Conference will discuss the results of development of the ag sector of the Black Sea countries in 2000s, role of Asian economies as drivers of the growth of the global ag production and consumption, outlook of bank lending and investments in agrarian sector, prospects of grain trade pools and unions in short- and medium-term outlook.  Global markets, Black Sea markets (Ukraine, Russia, Kazakhstan), analysis of the South East Asian markets will be also covered by speakers.

The presentations of the Conference will be made by the leading experts of the agrarian markets and specialists in the world grain and oil crop trade. The discussions and networking will enrich your experience with more effective tools.

The representatives of more than 120 companies from 27 countries have already registered for the participation in BLACK SEA GRAIN -2010 Conference (about 180 participants already).

General sponsors - Glencore/Serna, exclusive financial sponsor - CALYON  Bank (Credit Agricole cib).  Sponsors of the Seventh  Conference - ASOS Grain S.A., Alfred C. Toepfer International Ukraine, CHS Ukraine, Viterra Inc, BUNGE.

NOTE:  Bunge, InterContinental Hotel and Alfred C. Toepfer International (through its major shareholder Archer Daniels Midland [ADM]) are members of the U.S.-Ukraine Business Council (USUBC), www.usubc.org.  
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9.  RAYTHEON JOINS U.S.-UKRAINE BUSINESS COUNCIL (USUBC)
Technology and innovation leader in defense, homeland security and other government markets 

U.S.-Ukraine Business Council (USUBC), Wash, D.C., Fri, Feb 5, 2010

WASHINGTON, D.C.  -  Raytheon Company has been approved for membership in the U.S.-Ukraine Business Council (USUBC), the USUBC executive committee announced today on behalf of the entire USUBC membership of over 100 companies and organizations who have business operations, investments or other development programs in Ukraine.  

Raytheon, with 2009 sales of $25 billion, is a technology and innovation leader specializing in defense, homeland security and other government markets throughout the world.

With a history of innovation spanning 88 years, Raytheon provides state-of-the-art electronics, mission systems integration and other capabilities in the areas of sensing; effects; and command, control, communications and intelligence systems, as well as a broad range of mission support services. With global headquarters in Waltham, Mass., Raytheon employs 73,000 people worldwide.
 
RAYTHEON IN UKRAINE SINCE 1994
Raytheon's representation office in Ukraine is part of Raytheon Technical Services Company, LLC (RTSC).  RTSC's Threat Reduction Office is active throughout the former Soviet Union and has been working in Ukraine since 1994, principally engaged in Strategic Nuclear Arms Elimination projects that were part of the Cooperative Threat Reduction (CTR) Nunn-Lugar Program. 

RTSC also specializes in program management, supply chain management, information management, fleet maintenance, training, shipping, and procurement.
RTSC has provided logistics support for NATO's Partnership for Peace "Peaceshield" exercises and has supported cooperative programs with the Ukrainian MOD and the State Border Guards and State Customs Services. Raytheon currently employees 95 Ukrainian and 10 expatriate employees in Ukraine.  Mark Beha is resident manager of the Raytheon office in Kyiv.

JOHN MILLER, DIRECTOR, INTERNATIONAL BUSINESS DEVELOPMENT
Raytheon will be represented on the USUBC board of directors by John Miller, Director, International Business Development: Europe, Israel, Sub-Sahara, Raytheon International, Inc. whose office is in the Arlington, VA office. John is a former top ranking U.S. military officer and has worked for Raytheon for over 10 years. John was elected as a new member of the USUBC Executive Committee at the annual meeting in December.

RAYTHEON COUNTRY MANAGER UKRAINE - MARK BAHA
USUBC has been working with Raytheon's Country Manager in Kyiv, Mark Beha for some time. Mark has worked in Ukraine for over 15 years on a variety of Raytheon projects, mostly in conjunction with the U.S. Defense Department contracts. USUBC has also worked with Bill Toti, VP, Raytheon Technical Services Company, in Reston, VA. 

More information about Raytheon can be found at www.raytheon.com.

USUBC is very pleased to have Raytheon as a member," said Morgan Williams, Director, Government Affairs, Washington Office, SigmaBleyzer Emerging Markets Private Equity Investment Group, www.SigmaBleyzer.com, who serves as President/CEO of the U.S.-Ukraine Business Council (USUBC).  

"Raytheon now joins with other aerospace and defense related companies who are members of USUBC such as AnaCom, Inc., Boeing; Defense Technology, Inc; DRS Technologies, Inc.; General Dynamics; Sweet Analysis Services Inc. (SASI); UMBRA and United Technologies (Pratt & Whitney)," Williams said. 

"USUBC now has a membership base of over 100 companies and organizations which allows USUBC to provide its new members such as Raytheon with a full-time operation and a significantly expanded program of work," according to USUBC membership director, Iryna Teluk.  
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10.  ELI LILLY JOINS U.S.-UKRAINE BUSINESS COUNCIL (USUBC)
Making medicines that help people live longer, healthier, more active lives.

U.S.-Ukraine Business Council (USUBC), Wash, D.C., Wed, Feb 3, 2010

WASHINGTON, D.C. -  Eli Lilly & Company, Indianapolis, Indiana, has been approved for membership in the U.S.-Ukraine Business Council (USUBC), the USUBC executive committee announced today on behalf of the entire USUBC membership of over 100 companies and organizations who have business operations, investments or other development programs in Ukraine. has asked to join USUBC. 

The company was founded by Eli Lilly in 1876, and is now the 10th largest pharmaceutical company in the world.  Lilly's global employees numbers over 40,000 with approximately 40,800 engaged in research and development.  Their medicines are marketed in 143 countries. Lilly has major research and development facilities in eight countries, conducts clinical trials in more than 50 countries, and has manufacturing plants located in 13 countries.

Lilly is consistently ranked as one of the best companies in the world to work for, and generations of Lilly employees have sustained a culture that values excellence, integrity, and respect for people.  Eli Lilly has been very active on the pharmaceutical market in Ukraine for several years.

JOHN STEELE, DIRECTOR, INTERNATIONAL AFFAIRS
Lilly will be represented on the USUBC board of directors by John Steele, Director, International Government Affairs, in the Washington office.  John recently transferred from working for Lilly in Vienna, Austria to Washington,  He has experience with the pharmaceutical market in Ukraine.  John was elected as a new member of the USUBC Executive Committee at the annual meeting in December.

SERGEY KALASHNYK, COUNTRY MANAGER, UKRAINE
Ludmyla Dudnyk, USUBC representative in Ukraine and Morgan Williams, USUBC President/CEO have been working with Sergey Kalashnyk, Lilly's Country Manager for Ukraine, Moldova, and Belarus for the past several months.  Sergey has supported USUBC activities, attended meetings and kept USUBC informed about the pharmaceutical market. 

Lilly and USUBC have been working together on joint industry actions designed to keep the pharmaceutical sector in Ukraine free of unnecessary governmental intervention and arbitrary price controls.  The government of Ukraine has taken some actions in recent months very detrimental in the long-run to the private pharmaceutical industry and Ukrainian consumers.

More information about Eli Lilly & Company can be found at www.lilly.com.

USUBC is very pleased to have Eli Lilly & Company as a member," said Morgan Williams, Director, Government Affairs, Washington Office, SigmaBleyzer Emerging Markets Private Equity Investment Group, www.SigmaBleyzer.com, who serves as President/CEO of the U.S.-Ukraine Business Council (USUBC).  

"USUBC now has a membership base of over 100 companies and organizations which allows USUBC to provide its new members such as Eli Lilly & Company with a full-time operation and a significantly expanded program of work," according to USUBC membership director, Iryna Teluk.  
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U.S.-UKRAINE BUSINESS COUNCIL (USUBC)
Mr. E. Morgan Williams, Director, Government Affairs,
Washington Office, SigmaBleyzer,
Emerging Markets Private Equity Investment Group;
President/CEO, U.S.-Ukraine Business Council (USUBC)
Publisher & Editor, Action Ukraine Report (AUR)
1701 K Street, NW, Suite 903, Washington, D.C. 20006
Telephone: 202 437 4707; Fax: 202 223 1224
mwilliams@sigmableyzer.com; mwilliams@usubc.org
www.sigmableyzer.com; www.usubc.org
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