Sevastopol exports: how Russia circumvents sanctions programmes

GRAIN exports out of occupied territories in Ukraine, particularly Sevastopol, have garnered international attention since the start of the war in Ukraine as Russia has been accused of using these ports to move what is described as “stolen” grain.

Financial restrictions have been introduced by western regulators to tackle this activity, but a Lloyd’s List investigation into a recent voyage out of the sanctioned port of Sevastopol reveals just how Russia evades these sanctions.

On April 7, a serial Crimea caller, the Russia-flagged bulk carrier Matros Pozynich (IMO: 9573816), disabled its Automatic Identification System data in the Black Sea, a typical behaviour displayed by those moving cargoes out of occupied ports.

Matros Pozynich was “dark” for 35 days, according to Lloyd’s List Intelligence vessel tracking data.

Satellite imagery from Planet Labs PBC shows the large handysize berthed in Sevastopol on May 5.

This cargo was delivered to the Egyptian port of El Iskandariya at the end of May.

A review of the contracts, correspondence and shipping documents relating to this shipment shows NaturalGem Petroleum was the initial buyer in this transaction.

John Lim of NaturalGem Petroleum told Lloyd’s List his company wanted to enter the Black Sea grain trading market and was in discussions with a company called AnyGrain to purchase cargo.

Lim said he understood AnyGrain to be the seller, and was confused when the agreement came through listing Swiss-based AnyGrain as the broker and the seller as a Dubai company called Cereal Crops Trading LLC.

Cereal Crops Trading has an operational link to Russia’s OZK, a state-owned trade and logistics operator of agricultural products, with export data showing a significant portion of OZK’s sales being conducted through this entity.

Researchers say it is possible that Cereal Crops Trading acts as an intermediary to allow OZK to indirectly engage in certain business, which is a common tactic for Russian companies.

When contacted for comment AnyGrain told Lloyd’s List that it had never acted as a broker in cases where the port of loading or discharging specified in the contract was a sanctioned or occupied port and had “never seen and never transferred any shipping or cargo documents with any specified occupied or sanctioned port”.

Sevastopol is not directly cited on any documentation reviewed by Lloyd’s List.

The Russian port of Kavkaz is named as the loading port for this shipment, a known method used by exporters moving grain from occupied Crimea to disguise the true origin of the cargo.

While Cereal Crops Trading is named as the seller in the contract with AnyGrain, unusually, an entirely different company called Pallada LLC is listed as the seller on the bills of lading.

NaturalGem said it had not heard of Pallada, which is located in the Rostov region of Russia.

There is limited public information on Pallada, but a paper published by the Organised Crime and Corruption Reporting Project indicates the company has received wheat from occupied parts of Ukraine.

Ultimately, this shipment of wheat, worth $7.3m, was paid for to Cereal Crops Trading in US dollars through the Swift network, with JPMorgan

Chase acting as the correspondent bank. JPMorgan declined to comment.

Some Russian banks are banned from the Swift international payment system, however NaturalGem, transferred this money to a non-Russian bank called Bank MisrUAE.

After purchasing the cargo NaturalGem, with the assistance of another Swiss broker named Get Brokers, sold the wheat to a Dubai-based company call Mnasek.

Lim told Lloyd’s List that Mnasek did not nominate a terminal or agents and there was never a discussion on sending surveyors, which led them to suspect a violation of sanctions.

There is no suggestion of any direct sanction violations over the course of this transaction.

But it does raise questions over the efficacy of the programmes introduced by the US, UK and EU to limit exports out of occupied territories.

All the ports in occupied Crimea are sanctioned, and the EU recently renewed these restrictive measures that were first issued in response to the illegal annexation of the territory for another year.

There have also been efforts to target specific vessels involved in the transport of stolen Ukrainian grain.

In December the EU sanctioned three general cargoships for this reason: Monte Rosa (IMO: 9274343), San Damian (IMO: 9274331) and Monte Bianco (IMO: 9385233).

The US Treasury’s Office of Foreign Assets Control sanctioned bulk carrier Zafar (IMO: 9720263) in April for shipping grain from Sevastopol to the Houthi-controlled port of Saleef.

Still, most ships employed to move cargo out of occupied ports remain unsanctioned, including serial offenders like Matros Pozynich which is almost exclusively deployed on this route.

“If there was a complete embargo then these things wouldn’t happen, but there are consequences, unintended or otherwise, of targeted sanctions programmes because a focus on particular activities means there are things that inevitably fall through the cracks,” said HFW partner Daniel Martin.

Western governments have so far avoided taking sweeping measures against the trade.

The sanctioning of food cargoes was a sensitive matter, Martin said, and understandably the US, EU and UK would not want to create food insecurity by targeting Russia’s food exports.

Yörük Işık, a geopolitical analyst from the Istanbul- based consultancy Bosphorus Observer, argued that the current restrictions needed to be tightened.

He describes the stance taken on agricultural issues by Western governments as naïve and says that Russia profits enormously from grain sales with these proceeds helping to fund its war effort.

“There should not be any loopholes with sanctions and any vessel that calls to a port in Crimea should be targeted,” said Işık.

Lloyd's List Daily Briefing 24 June 2025

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