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Ukraine Program – Support for Accountability Avenues Project
Analysis report:
San Cosmas
Introduction
Reports of the occupation of farms, pillage of harvest, and appropriation of agribusinesses emerged from the inception of the full-scale invasion of Ukraine in February 2022.[1] In parallel, Russia’s armed forces carried out targeted strikes on agricultural storage and logistics infrastructure in territories they were unable to occupy and control.[2] Failing to take Kyiv in April 2022, Russia successfully occupied most of the territory of 4 oblasts[3] – Kherson, Zaporizhzhia, Donetsk, and Luhansk[4] – in addition to Crimea, which had been occupied since 2014. During the early days of the occupation, Russian armed forces and paramilitary groups[5] inspected and, in several incidents, took over agricultural facilities, including those that stored grain, vehicles, and valuable equipment.[6] Logistical hubs in Crimean ports, specifically Sevastopol, Feodosia, and Kerch, have played a crucial role in such pillage schemes. Through these ports, Russia has exported pillaged grain to third countries. To carry out these operations, Russia organized a fleet of vessels designated specifically for grain transport from Crimean ports. This report focuses in particular on one vessel involved in these operations, namely the San Cosmas.
Since early 2022, Project Expedite Justice (PEJ) has supported small-scale agrarian farmers and larger entities in Ukraine by documenting international crimes and harms (e.g., attacks against the civilian population, destruction of civilian property and infrastructure, pillaging, plunder of resources, improper mining, destruction of the environment, sanctions violations, etc.) and facilitating their access to accountability mechanisms. This has included analyzing the crimes committed throughout the country based on direct investigative activities (Human Intelligence (HumInt), Open-Source Intelligence (OSINT), documentary evidence, and satellite imagery to support and inform prosecutorial efforts and the issuance of sanctions.
Project Expedite Justice (PEJ) continues to investigate war crimes related to pillage, specifically the theft of agricultural products from the occupied territories of Ukraine. Specifically, PEJ examines incidents involving the transportation for the further export and sale of looted goods by 56 vessels, which our organization refers to as the “Russian Gray Grain Fleet,” meaning the Russian Federation’s use of Crimea as a logistical “gray hub” and the identified patterns of deliberately concealing the movements of the vessels at sea. The use of the term “gray” throughout this report (e.g., “gray hub” and “Gray Grain Fleet”) makes reference to the vessels going “dark”, or deliberately hiding their activities, which is widely referred to as a “gray zone” initiative. Our report focusing on the pillage of Ukrainian Agricultural Assets presents the detailed findings of our investigation and analysis.[7]
We assisted the Ukrainian Prosecutor General’s Office (PGO) with its ongoing investigation and provided information about the transportation activity and loading of illegally appropriated agricultural products. We further provided information on ports of initial departure and final arrival, including photo-video recordings, satellite imagery, and other relevant information.
This report features the vessel San Cosmas. San Cosmas[8] and other vessels owned or managed by SYRIAMAR[9] are among the most active vessels involved in exporting looted goods. San Cosmas, alone, has carried out at least nine voyages, transporting a total of at least 100,000 metric tonnes of agricultural cargo from ports in occupied Crimea to third countries.
Our report showcases PEJ’s investigative and analytical work surrounding San Cosmas and other affiliated vessels. Section I provides background information on the investigated vessels. Section II includes a list of key facts and incidents identified by PEJ staff through open-source research. Section III reports four incidents that PEJ investigated that highlight the presence of vessels of interest in the waters near major Crimean ports with grain terminals. Section IV focuses on the exporting companies, outlining their roles, functions, and connections to San Cosmas and other agricultural infrastructure in Crimea. Finally, Section V includes our findings on Gam Express, an affiliated vessel we investigated at the PGO’s request. Our sources include publicly available information and images, as well as exclusive images and intel obtained by PEJ’s investigators and analysts.
[3] An “oblast” in Ukraine, sometimes translated as a “region” or “province,” is the main type of first-level administrative division of the country.
[4] Part of Kharkiv Oblast was temporarily occupied in February 2022, but almost all was liberated in November the same year.
[6] Such as the Novooleksiivskyi Elevator. See PEJ Witness Statements (P003, Sep. 8, 2022; P012, Sep. 30, 2022; and P131 Mar. 3, 2024).
[7] PEJ Ukraine Public Report, “The Pillage of Ukrainian Agricultural Assets: The Role of a Russian-organized fleet of vessels (the “Gray Grain Fleet”) in Exporting Pillaged Grain from occupied Ukraine to Third Countries”, (“The Pillage of Ukrainian Agricultural Assets”).
[8] The San Cosmas vessel was renamed Monte Rosa in early 2025 (around February 12 or 13, according to PEJ maritime analyst). To avoid confusion, this report refers to the vessel as San Cosmas, the name used in PEJ’s report “The Pillage of Ukrainian Agricultural Assets”.
[9] Syrian General Authority for Maritime Transport, a Syrian state-owned shipping company.
Section I.
Background details on the vessel
The general cargo ship San Cosmas was previously known as Laodicea and sailed under the Syrian flag until July 24, 2023. After its flag, name, and ownership changed, the cargo ship continued to engage in suspicious activity in the Black Sea under the identification number IMO9274343, remaining undetected during long periods with no Automatic Identification System (AIS) signal. This practice was systematic and ongoing.[10]
In August 2015, as the Syrian-flagged Laodicea, the vessel was sanctioned by the U.S. Department of the Treasury’s Office of Foreign Assets Control for its role in supporting the regime of Syrian President Bashar al-Assad.[11] The vessel has also recently been designated for sanctions by the Council of the European Union (EU).[12] The Syrian General Authority for Maritime Transport (SYRIAMAR), a Syrian state-owned shipping company, continues to showcase Laodicea as part of its cargo fleet.[13] Captains Ahmad Nouh[14] and Hasan Aris are known masters of the vessel, i.e., the persons with legal authority in command of the commercial ship.[15]
In 2023, San Cosmas (formerly Laodicea) appeared at least twice in ports of the temporarily occupied region of Crimea, Ukraine (See incidents in Section III). Laodicea’s first appearance in occupied Crimea was documented in December 2016 (See Section IV).
In January 2024, according to PEJ’s maritime analysts, San Cosmas was registered under the Eswatini flag[16] or used a “ghost” registration scheme to hide the absence of legitimate registration. The landlocked African kingdom of Eswatini, formerly known as Swaziland, has joined the growing list of countries establishing shipping registers and offering its flag to sanctioned ships. Eswatini Maritime Affairs and Development (EMAD), a private company established through government agreement,[17] registered with Eswatini’s Ministry of Commerce in November 2023, and then itself registered a total of 10 cargo-carrying ships under the Eswatini flag. The UN International Maritime Organization does not recognize the authority of a private company to issue flags, and has designated these operations as fraudulent.[18]
On January 25, 2025, PEJ analysts contacted Captain A-K Dhiman, the Deputy Director General of Eswatini Maritime Affairs. Captain Dhiman stated that his company signed a contract with the Eswatini Government to establish a maritime administration and an international ship registry, namely the Eswatini Maritime Affairs Company. Captain Dhiman confirmed to PEJ analysts that three sanctioned vessels, San Damian,[19] San Severus,[20] and San Cosmas,[21] had been registered with the Eswatini flag but had all since been de-registered. At the time of this report, none of the ships have reflected this change, and their AIS data still signals that they are flagged by Eswatini.
Like San Cosmas, San Damian and San Severus have recently undergone a series of changes in name, flag, and ownership. San Damian, a general cargo ship previously owned by the Government of Syria, was registered under the Eswatini flag on December 4, 2023. Until September 2024, San Damian was managed and operated by SYRIAMAR, which also operated San Cosmas and San Severus. All three vessels were sanctioned by the US government on August 3, 2015, for their role in supporting the Syrian regime and for engaging in sanctioned trades carrying cargo from Russian-occupied Crimea to Syria.[22]
The current owners of these vessels are unknown; however, Lebanon-based brokers ChartBrok[23] act exclusively for all three sanctioned Syrian vessels (San Damian, San Severus, and San Cosmas) flagged in Eswatini. Chartbrok declined to reveal the vessels’ current ownership or management details. PEJ’s Maritime Analyst found that GMD CHARTERING ISTANBUL[24] assisted San Cosmas in changing its registration to Eswatini.
PEJ’s analysts found that San Cosmas, as well as its sister vessels San Severus and San Damian, have undergone a reflagging and renaming operation to evade sanctions and continue their operations. These former SYRIAMAR vessels have been involved in trade out of occupied Crimea since its annexation. Despite the change in name, ownership, and flag, these ships continue to engage in sanctionable activities, trading stolen Ukrainian agricultural produce from and to the same destinations. This suggests that those changes are merely a tactic to allow the sanctioned ships to continue their operations freely.
[10] PEJ Ukraine Public Report, “The Pillage of Ukrainian Agricultural Assets”.
[12] Council Decision (CFSP) No. 2024/3187 of 16 December 2024 amending Decision 2024/512/CFSP concerning restrictive measures in view of Russia’s actions destabilizing the situation in Ukraine, 2024 O.J. (L) Annex XLII.
[19] IMO: 9274331.
[20] IMO: 9385233. The San Severus vessel was renamed Monte Bianco in early 2025 (around February 12 or 13, according to PEJ maritime analyst). To avoid confusion, this report refers to the vessel as San Severus, the name used in PEJ’s report “The Pillage of Ukrainian Agricultural Assets”.
[21] IMO: 9274343.
Section II.
OSINT incidents
While gathering information on the vessels as swiftly as possible, PEJ aimed to uncover potential connections or criminal networks relating to San Cosmas’ operations. PEJ documented all relevant findings, compiling key facts and notable incidents presented in this section. San Cosmas, under its previous name (Laodicea) and ownership (SYRIAMAR), was seized and detained in Lebanon in July 2022, after Ukrainian authorities accused the ship of carrying stolen barley and flour. The vessel was released and permitted to sail several days later, after the cargo owner submitted documentation to Lebanese customs officials and the Lebanese court, reportedly proving the legitimacy of the source of the grain shipment.[25]
According to one of the bills of lading, San Cosmas shipped sunflower seeds to Turkey with the exporting company Tezori della Terra[26], which acted on behalf of Mercalix Trade DMCC (UAE).[27] Notably, Mercalix Trade DMCC was involved in the occupied territories before the full-scale invasion of Ukraine, in a case involving the import of anthracite coal from the Russian company OJSC Donugol.[28] OJSC Donugol was allegedly involved in the looting of coal from occupied mines in Donbas. This may suggest that a network of companies involved in the theft of goods from the occupied territories is linked to Mercalix Trade DMCC and its affiliated entities, with San Cosmas being used to transport the looted grain.
The investigation published by Kiborg[29] includes a copy of a letter from the company Vidan, headed by Anatoliy Vasyliovych Tsurkin, in which the company asks to change the shipper from LLC Agrogroup to Tesori della Terra. The head of LLC Agrogroup, Aleksej Sergeevich Dzhurkin, is also the deputy head of the State Grain Operator (GZO) in Zaporizhzhia. These facts indicate that they acted in connection with each other.
Analysis of the incidents
San Cosmas has been used (at least nine times as of December 2024) as a part of a so-called Russian sea fleet to transport stolen agricultural products from Ukraine, operating in a group of three vessels that includes the San Damian and San Severus.[30] However, it is still uncertain whether the owner of San Cosmas has close ties with a particular group or if the company that owns the vessel provides services to all interested parties, including Tsurkin, Petrokhleb, GZO, and others.
[30] PEJ Ukraine Public Report, “The Pillage of Ukrainian Agricultural Assets”.
Section III.
Voyages of San Cosmas
PEJ has compiled a list of incidents documenting the entry of vessels of interest, including San Cosmas, into ports in occupied Crimea. These incidents illustrate their active presence near grain terminals and their use in the illegal transportation of looted Ukrainian grain to third countries. The most active port facility involved in this pattern of activities is the Aval terminal[31] in Sevastopol, while some incidents occurred in the ports of Feodosia and Kerch.
Incident No. 1
March 1, 2023, to May 23, 2023: The vessel’s AIS is only active in Latakia, Syria. However, there is a large 71-day gap without an AIS signal between March 16, 2023, and May 27, 2023.
Supplementary evidence:
Incident No. 2
May 27, 2023, to August 31, 2023: Voyage back to occupied Crimea from Syria. Two large gaps, totalling 58 days, between Latakia (May 27) and Iskenderun (July 25). Interestingly, during this gap, the vessel appears in the north of Cyprus with “LB KYE” (Port of Tripoli, Lebanon) as its destination (July 4) for a few hours and turns its AIS off again. The vessel then returns to occupied Crimea.
Supplementary evidence:
July 28, 2023, 08:35 UTC, San Cosmas is staying near Iskenderun (Turkey)
Screenshot by PEJ of the SI from Airbus OneAtlas on January 19, 2024 (F1061).
Incident No. 3
On or about August 31, 2023, to October 31, 2023: Round-trip voyage from occupied Crimea. San Cosmas departed occupied Crimea with Mersin, Turkey, as its indicated destination. The vessel transited the Turkish Straits on September 3 and 4. It arrived at Dardanelles, South Anchorage, between Bozcaada and Lesbos. The vessel stayed there for two days, which is an illogical move for a commercial vessel, suggesting it either met with another vessel or was trying to secure a customer for its illegitimate cargo. It changed its destination from Mersin to Tripoli, Lebanon. It departed late at night on September 6 en route to Alexandria. AIS was turned off for 22 hours south of Rhodes until it arrived in Alexandria by sunrise on September 9. It spent 18 days there and was unable to enter the port. Then, it set sail for Latakia (October 1). It departed from Latakia on October 16 and arrived at the Turkish port of Güllük on October 20. The ship departed from Güllük loaded with feldspar on October 23. It transited the Turkish Straits, entered the Black Sea on October 2, and returned to Crimea on October 31.
Incident No. 4
October 31, 2023, to December 29, 2023: The vessel stayed around Russia and occupied Crimea. The only relevant gaps are between November 25 and November 30 (five days AIS off), near Kerch, and between November 30 and December 29 (28 days off), also near Kerch.
Supplementary evidence:
-
December 25-26, 2023: San Cosmas was docked in Feodosia.[34]
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December 26, 2023: “To the north of the pier where the explosion happened after Ukraine’s attack on the occupied Feodosia port is the former Syria flag vessel Laodicea, now [Eswatini] flag San Cosmas,[35] which is still involved in transporting plundered grain from occupied territories of Ukraine.”[36]
The images from Feodosia are dated December 25-27, 2023, after the military landing ship Novocherkassk was hit.
[35] The LAODICEA>SAN COSMAS>MONTE ROSA vessel had several flags: From 2009 to 2023, Syria flag; From 2023 to October 2024 Tanzania flag; and from the end of 2024 to recently, the ship hoisted ESWATINI flag but according to IMO, this was a 'false flag" operation. Kingdom of Eswatini has no right to issue flags according to IMO. A private company was issuing Eswatini flag without IMO approval. All Eswatini flags were recalled. But throught out this period, the vessel hoisted Eswatini flag, and on the ship there was Eswatini port registry was painted, "MBABANE" as homeport. San Cosmas has been missing for last several months. The ship allegedly became MONTE ROSA with Comoros flag but there is no eyewitness nor a picture and its current state is unknown.
Incident No. 5
San Cosmas was spotted at Samsun Anchorage (Turkey) on January 23, 2024.
Section IV.
Suppliers of agricultural produce on LAODICEA/SAN COSMAS
From as early as 2016, general cargo vessel Laodicea,[37] owned and operated at the time by SYRIAMAR,[38] has been operating in the Black Sea region of Ukraine, facilitating the export of agricultural produce from ports of occupied Crimea, including the AVAL grain terminal complex in the port of Sevastopol.[39] Between 2016 and 2022, numerous port calls were recorded by independent ship-spotters in occupied Crimea, including in the ports of Sevastopol and Feodosia, as well as by investigative journalists, such as Myrotvorets “SeaCrime”[40] and Black Sea News.[41] However, the cargo suppliers remain unknown for this period.
PEJ analysts have reviewed available imagery as of December 1, 2016,[42] identifying that the Laodicea was carrying substances possessing similar visual characteristics to those of wheat, such as gold color, structure, and physical qualities.
On April 1, 2017, AVAL LLC,[43] via AVAL terminal, loaded 3,760 metric tons of wheat on the Laodicea vessel. The Russian-established Court of Arbitration of Sevastopol found that grain was delivered to the AVAL terminal in occupied Sevastopol via grain trucks.[44]
On November 4, 2018, the Laodicea vessel was spotted carrying out transshipment operations in the Kerch Strait. For this, they used the floating crane POSEIDON, operated by the Russian maritime company Linter LLC.[45] Linter LLC, in turn, is a direct affiliate of the TD RIF grain trading company, one of the largest grain traders and exporters on the Russian market.[46]
In 2019, “Black Sea News” registered a rising number of Feodosia port calls of the Laodicea vessel, reportedly carrying agricultural produce for export to the Syrian Arab Republic and Turkey.[47] PEJ analysts made similar observations from images and videos posted online.[48] A change of pattern was observed for other vessels operated by the “Syrian Mar Shipping,” including Finikia and Souria (San Severus and San Damian).[49]
PEJ analysts believe that since the full-scale invasion of Ukraine, the general cargo vessel Laodicea continued the general pattern of maritime and export activity established between 2016 and 2022. That includes a specific pattern of concealing vessel location by turning the AIS transponder off. On August 4, 2022, Krasnogvardeysky Elevator LLC[50] and Agro Fregat LLC[51] exported wheat and flour onboard the Laodicea vessel from the port of Feodosia, occupied Crimea, to Tripoli, Lebanon.[52] On September 2, 2023, State Unitary Enterprise “State Grain Operator” (GUP GZO), registered in Melitopol, via Russian-registered LLC Novorossiysk grain company LLC[53] and LLC Samson,[54] exported grain onboard the San Cosmas vessel.[55]
On December 22, 2023, State Unitary Enterprise “State Grain Operator” (GUP GZO), registered in Melitopol via Russian-registered “TEZORI DELLA TERRA” LLC,[56] exported sunflower seeds from the port of Feodosia onboard the San Cosmas vessel.[57]
[37] IMO: 9274343; MMSI: 677033900.
[38] F1044. Official web site of the SYRIAMAR SHIPPING LTD. The web site establishes that the company operates Laodicea, Finikia and Souria general cargo vessels.
[39] F1041. Photo of Laodicea vessel in the port of AVLITA, occupied Sevastopol on Dec. 1, 2016, published by the Fleet Photo.
[43] TIN: 7720314451.
[44] F1049. Court of Arbitration of Sevastopol Ruling in case A84-2434/2017, as of July. 26, 2017. The court established that “According to information from the General Director of Aval LLC (ref. No. 94 dated May 19, 2017), for the period from April 1, 2017 to May 16, 2017, 3,760.0 tons of wheat were transshipped from vehicles to the grain terminal. The date of the last loading of grain onto ships related to the operation of the facility is 05/10/2017, which is confirmed by the application to ensure the departure of the vessel “Laodicea” from the seaport of Sevastopol with cargo on board (wheat 10109.24 tons).”
[50] TIN: 9105010531.
[51] TIN: 6141055691.
[53] TIN: 2315226485.
[54] TIN: 9703129678.
[56] TIN: 9701259632.
Section V.
GAM EXPRESS
The Gray Grain Fleet consists of many vessels; in our report, we assess at least 56 vessels, including coasters, handysize, and handymax types.[58] One such vessel that appeared in the ports of occupied Crimea is Gam Express, which has called at least twice and carried a total of at least 6,000 metric tonnes of grain. Gam Express, a Guinea-Bissau-flagged cargo vessel, has changed flags 19 times in the past 15 years, further highlighting its probable involvement in gray operations with sanctioned or shell companies.
The vessel is registered for MGA SHIPPING CO;[59] commercial and security management is carried out by AGM EXPRESS CO;[60] and the technical manager is the Istanbul-based company UNIFLEET MANAGEMENT CO S.A.
[58] PEJ Ukraine Public Report, “The Pillage of Ukrainian Agricultural Assets”.
[59] IMO: 6379370. Address Strada Brailei, Gemenele, 1A, 810001 Braila, Romania.
[60] IMO: 6346994. Address C4, Strada Brailei, Gemenele, 1A, Braila, Romania.
Gam Express and San Cosmas docked in the port of Feodosia on December 28, 2023.
Gam Express was spotted at Samsun Anchorage (Turkey) on January 23, 2024 (docked near San Cosmas).
Video footage of Gam Express transiting the Bosphorus Strait en route to occupied Feodosia on December 10, 2023:[61]
[61] F1092. Gam Express, Video. Dec. 10, 2023.
Sources
[1] For example, see “Agricultural War Damages Review Ukraine - Rapid Damage Assessment,” Center for Food and Land Use Research at Kyiv School of Economics, Jun. 8, 2022, https://kse.ua/wp-content/uploads/2022/06/Damages_report_issue1-1.pdf, last accessed Sep. 30, 2024; and confirmed by PEJ Witness Statements (P010 Jan. 25, 2023; P012 Sep. 30, 2022; P013 No date; P115 Jan. 16, 2024; P128 Jan. 19 2024; P129 Jan. 16, 2024; and P131 Mar. 3, 2024).
[2] Josep Borrell Fontelles (@JosepBorrellF), “Another Russian missile strike contributing to the global food crisis…,” Twitter, Jun. 6, 2022, https://x.com/JosepBorrellF/status/1533870695586971648, last accessed Jan. 15, 2025; “РФ вперше застосувала проти України радянську ракету Х-59” [Russia has used the Soviet X-59 missile against Ukraine for the first time], Defense Express, Apr. 4, 2022, https://defence-ua.com/weapon_and_tech/rf_vpershe_zastosuvala_proti_ukrajini_radjansku_raketu_h_59_foto-6797.html, last accessed Jan. 15, 2025.
[3] An “oblast” in Ukraine, sometimes translated as a “region” or “province,” is the main type of first-level administrative division of the country.
[4] Part of Kharkiv Oblast was temporarily occupied in February 2022, but almost all was liberated in November the same year.
[5] Notably Chechen “kadyrovtsy” groups, see e.g., “Traitor Dmytro Tabachnyk steals Ukrainian grain, agricultural machinery and develops business in Crimea,” Television Toronto, Dec. 19, 2023, https://torontotv.substack.com/p/4ba, last accessed May 9, 2024. PEJ Witness Statements (P073, Sep. 30; 2023; P-077, Sep. 25, 2023; and P-079, Sep. 25. 2023).
[6] Such as the Novooleksiivskyi Elevator. See PEJ Witness Statements (P003, Sep. 8, 2022; P012, Sep. 30, 2022; and P131 Mar. 3, 2024).
[7] PEJ Ukraine Public Report, “The Pillage of Ukrainian Agricultural Assets: The Role of a Russian-organized fleet of vessels (the “Gray Grain Fleet”) in Exporting Pillaged Grain from occupied Ukraine to Third Countries”, (“The Pillage of Ukrainian Agricultural Assets”).
[8] The San Cosmas vessel was renamed Monte Rosa in early 2025 (around February 12 or 13, according to PEJ maritime analyst). To avoid confusion, this report refers to the vessel as San Cosmas, the name used in PEJ’s report “The Pillage of Ukrainian Agricultural Assets”.
[9] Syrian General Authority for Maritime Transport, a Syrian state-owned shipping company.
[10] PEJ Ukraine Public Report, “The Pillage of Ukrainian Agricultural Assets”.
[11] F0675. “Treasury Targets Syrian Regime Energy Networks,” U.S. Department Of The Treasury. Aug. 3, 2015, https://home.treasury.gov/news/press-releases/jl0137, last accessed Mar. 3, 2025.
[12] Council Decision (CFSP) No. 2024/3187 of 16 December 2024 amending Decision 2024/512/CFSP concerning restrictive measures in view of Russia’s actions destabilizing the situation in Ukraine, 2024 O.J. (L) Annex XLII.
[13] The official website of the Syrian company lists Laodicea as a part of its cargo fleet, “Syriamar Shipping LTD” Official Website, https://www.syriamarshipping.com, last accessed Mar. 3, 2025.
[14] F1054. “San Cosmas (Ex-Laodicea): Вивезення мелітопольської пшениці з окупованого Севастополя (ОНОВЛЕНО)” [“San Cosmas (Ex-Laodicea): Export of Melitopol wheat from occupied Sevastopol (UPDATED)”], Kiborg. Aug. 25, 2023, https://kiborg.news/2023/09/02/san-cosmas-ex-laodicea-vyvezennya-melitopolskoyi-pshenyczi-z-okupovanogo-sevastopolya/, last accessed Mar. 3, 2025.
[15] F1051. “San Cosmas (Ex-Laodicea): Викрадення українського насіння соняшника з окупованої Феодосії” [“San Cosmas (Ex-Laodicea): Theft of Ukrainian sunflower seeds from occupied Feodosia”], Kiborg. Dec. 2023, https://kiborg.news/2023/12/31/san-cosmas-ex-laodicea-vykradennya-ukrayinskogo-nasinnya-sonyashnyka-z-okupovanoyi-feodosiyi/), last accessed Mar. 3, 2025; F1058. “Chief Officer Aris Hasan Mohammad,” Crew Data. Jul. 24, 2016, https://crewdata.com/seafarer.php?lang=eng&id=51053&name=aris%20hasan&rank=CHIEF%20OFFICER, last accessed Mar. 3, 2025.
[16] F1090. “SAN COSMAS General Cargo (IMO: 9274343)”, Marine Traffic Website. Jan. 30, 2024, https://www.marinetraffic.com/en/ais/details/ships/shipid:679716/mmsi:669517000/imo:9274343/vessel:SAN_COSMAS, last accessed Mar. 3, 2025.
[17] F1088. “Eswatini Maritime Affairs Company” Official Website, https://www.ema.org.sz/index.php, last accessed Jan. 12, 2025.
[18] See e.g., Lloyd’s List, “UAE bans Eswatini-flagged ships from its port,” Kuehne-Nagel, Aug. 13, 2024, https://mykn.kuehne-nagel.com/news/article/uae-bans-eswatiniflagged-ships-from-its-ports-13-Aug-2024#:~:text=Eswatini%20was%20declared%20a%20false,of%20the%20landlocked%20country's%20government, last accessed Jan. 11, 2025.
[19] IMO: 9274331.
[20] IMO: 9385233. The San Severus vessel was renamed Monte Bianco in early 2025 (around February 12 or 13, according to PEJ maritime analyst). To avoid confusion, this report refers to the vessel as San Severus, the name used in PEJ’s report “The Pillage of Ukrainian Agricultural Assets”.
[21] IMO: 9274343.
[22] Sanctioned under their previous names, respectively Laodicea, Familia and Souria; F1089. “SPECIALLY DESIGNATED NATIONALS LIST UPDATE,” U.S. DEPARTMENT OF THE TREASURY. Mar. 8, 2015, https://ofac.treasury.gov/recent-actions/20150803, last accessed Mar. 3, 2025.
[23] https://www.linkedin.com/company/chartbrok, last accessed Apr. 15, 2025.
[24] F1091. “GMD CHARTERING ISTANBUL,” Official Website, https://gmdchartering.com/, last accessed Mar. 3, 2025.
[25] F1053. “Ukraine Says Ship Carrying Stolen Barley, Flour Docked In Lebanon, Warns Beirut Against Purchase,” Radio Free Europe / Radio Liberty. Jul. 28, 2022, https://www.rferl.org/a/ukraine-warns-beirut-against-buying-ship-stolen-barley-flour/31964365.html, last accessed Mar. 3, 2025.
[26] Tezori Della Terra is in Italian “Treasures of the Earth”. The cargo plan for San Cosmas was drawn up on the letterhead of the British company LEVANT FLEET LTD. One of the branches of Levant is registered in Turin. The companies might be interconnected (Turin - Italy, Tel: +39 328 8538199, Email: italy@levantfleet.com).
[27] F1051. “San Cosmas (Ex-Laodicea): Викрадення українського насіння соняшника з окупованої Феодосії” [“San Cosmas (Ex-Laodicea): Theft of Ukrainian sunflower seeds from occupied Feodosia”], Kiborg. December, 2023, https://kiborg.news/2023/12/31/san-cosmas-ex-laodicea-vykradennya-ukrayinskogo-nasinnya-sonyashnyka-z-okupovanoyi-feodosiyi/, last accessed Mar. 3, 2025.
[28] F1056. “OSCE Observer Mission at the Russian Checkpoints Gukovo and Donetsk,” OSCE Website. Apr. 9, 2015, https://www.osce.org/om/150566, last accessed Mar. 3, 2025.
[29] F1051. “San Cosmas (Ex-Laodicea): Викрадення українського насіння соняшника з окупованої Феодосії” [“San Cosmas (Ex-Laodicea): Theft of Ukrainian sunflower seeds from occupied Feodosia”], Kiborg. December, 2023, https://kiborg.news/2023/12/31/san-cosmas-ex-laodicea-vykradennya-ukrayinskogo-nasinnya-sonyashnyka-z-okupovanoyi-feodosiyi/, last accessed Mar. 3, 2025.
[30] PEJ Ukraine Public Report, “The Pillage of Ukrainian Agricultural Assets.”.
[31] The legal predecessor of AVAL, the Ukrainian-registered AVLITA LLC company, was subject to sanctions by the EU, “AVLITA Stevedoring Company | Sanctions Finder,” Sanctions-finder.com, 2025, https://sanctions-finder.com/sanction/4743d2bf-b0aa-452f-9ed5-fce1848b7722/AVLITA%20Stevedoring%20Company?query=eyJxdWVyeSI6IkFWTElUQSJ9.
[32] F1054. “San Cosmas (Ex-Laodicea): Вивезення мелітопольської пшениці з окупованого Севастополя (ОНОВЛЕНО)” [“San Cosmas (Ex-Laodicea): Export of Melitopol wheat from occupied Sevastopol (UPDATED)”], Kiborg. Aug. 25, 2023, https://kiborg.news/2023/09/02/san-cosmas-ex-laodicea-vyvezennya-melitopolskoyi-pshenyczi-z-okupovanogo-sevastopolya/, last accessed Mar. 3, 2025.
[33] F1054. “San Cosmas (Ex-Laodicea): Вивезення мелітопольської пшениці з окупованого Севастополя (ОНОВЛЕНО)” [“San Cosmas (Ex-Laodicea): Export of Melitopol wheat from occupied Sevastopol (UPDATED)”], Kiborg. Aug. 25, 2023 , https://kiborg.news/2023/09/02/san-cosmas-ex-laodicea-vyvezennya-melitopolskoyi-pshenyczi-z-okupovanogo-sevastopolya/, last accessed Mar. 3, 2025.
[34] F1051. “San Cosmas (Ex-Laodicea): Викрадення українського насіння соняшника з окупованої Феодосії” [“San Cosmas (Ex-Laodicea): Theft of Ukrainian sunflower seeds from occupied Feodosia”], Kiborg. December, 2023, https://kiborg.news/2023/12/31/san-cosmas-ex-laodicea-vykradennya-ukrayinskogo-nasinnya-sonyashnyka-z-okupovanoyi-feodosiyi/, last accessed Mar. 3, 2025.
[35] The LAODICEA>SAN COSMAS>MONTE ROSA vessel had several flags: From 2009 to 2023, Syria flag; From 2023 to October 2024 Tanzania flag; and from the end of 2024 to recently, the ship hoisted ESWATINI flag but according to IMO, this was a 'false flag" operation. Kingdom of Eswatini has no right to issue flags according to IMO. A private company was issuing Eswatini flag without IMO approval. All Eswatini flags were recalled. But throught out this period, the vessel hoisted Eswatini flag, and on the ship there was Eswatini port registry was painted, "MBABANE" as homeport. San Cosmas has been missing for last several months. The ship allegedly became MONTE ROSA with Comoros flag but there is no eyewitness nor a picture and its current state is unknown.
[36] F1057. Yörük Işık “To the North of the Pier where the Explosion Happened after Ukraine’s Attack on the Occupied Feodosia Port Is the Former Syria Flag Vessel Laodicea, now Tanzanian Flag San Cosmas, Which Is Still Involved in Transporting Plundered Grain from Occupied Territories of Ukraine,” Twitter Post. Dec. 26, 2023, https://twitter.com/YorukIsik/status/1739589615948841315/photo/1, last accessed Mar. 3, 2025.
[37] IMO: 9274343; MMSI: 677033900.
[38] F1044. Official web site of the SYRIAMAR SHIPPING LTD. The web site establishes that the company operates Laodicea, Finikia and Souria general cargo vessels.
[39] F1041. Photo of Laodicea vessel in the port of AVLITA, occupied Sevastopol on Dec. 1, 2016, published by the Fleet Photo.
[40] Myrotvorets Sea Crime Website (URL: https://myrotvorets.news/category/seakrime/).
[41] F1109.“Black Sea News” Website (URL: https://www.blackseanews.net/).
[42] F1041. Photo of Laodicea vessel in the port of AVLITA, occupied Sevastopol on Dec. 1, 2016, published by the Fleet Photo.
[43] TIN: 7720314451.
[44] F1049. Court of Arbitration of Sevastopol Ruling in case 84-2434/2017, as of July. 26, 2017. The court established that “According to information from the General Director of Aval LLC (ref. No. 94 dated May 19, 2017), for the period from April 1, 2017 to May 16, 2017, 3,760.0 tons of wheat were transshipped from vehicles to the grain terminal. The date of the last loading of grain onto ships related to the operation of the facility is 05/10/2017, which is confirmed by the application to ensure the departure of the vessel “Laodicea” from the seaport of Sevastopol with cargo on board (wheat 10109.24 tons).”
[45] TIN: 6165188718. F1040. Photo of Laodicea vessel with floating crane Poseidon in the Kerch Strait on Nov. 4, 2018, published by the Fleet Photo. (URL: https://fleetphoto.ru/photo/274409/?vid=65069).
[46] F1050. Corporate profile of TD RIF company published by the Union of Grain Exporters. The extract establishes that “Limited Liability Company “Trading House “RIF” is the largest multi-disciplinary organization of the agro-industrial complex. The main activity is the purchase and export of agricultural products. Other business areas: agricultural production and logistics. The organization owns 17 river-sea vessels for transporting goods, 1,510 hopper cars for transporting grain.”
[47] F1109.“Black Sea News” Website. (URL: https://www.blackseanews.net/).
[48] F1110. “Феодосия. Крым,” Алексей Коновалов. Mar. 3, 2020. Youtube Video, (URL: https://www.youtube.com/watch?v=N-zwlN_G-6c).
[49] F1043. “«Чорний список» морських суден-порушників кримських санкцій за 2020 рік (іноземні, крім РФ) - база даних” [“Black list” of maritime vessels violating the Crimean sanctions for 2020 (foreign, except the Russian Federation)”], Black Sea News, March 01, 2021. (URL: https://www.blackseanews.net/read/173938).
[50] TIN: 9105010531.
[51] TIN: 6141055691.
[52] F0923. “«Зерновой фронт» украинских дипломатов. Как Россия через Крым везла украинское зерно в Ливан” [“Grain Front” of Ukrainian diplomats. How Russia transported Ukrainian grain to Lebanon through Crimea], Krym.Realii, Aug. 04, 2023. (URL: https://ru.krymr.com/a/laodicea-livan-ukraina-zerno-krym-ugroza-goloda-rossia/31972586.html).
[53] TIN: 2315226485.
[54] TIN: 9703129678.
[55] F1046. Kateryna Yaresko, “SAN COSMAS (EX-LAODICEA): ВИВЕЗЕННЯ МЕЛІТОПОЛЬСЬКОЇ ПШЕНИЦІ З ОКУПОВАНОГО СЕВАСТОПОЛЯ” [“SAN COSMAS (EX-LAODICEA): EXPORT OF MELITOPOL WHEAT FROM OCCUPIED SEVASTOPOL”], MYROTVORETS NEWS. Sep. 2, 2023. (URL: https://myrotvorets.news/san-cosmas-ex-laodicea-vyvezennia-melitopolskoi-pshen/).
[56] TIN: 9701259632.
[57] F1051. “San Cosmas (Ex-Laodicea): Викрадення українського насіння соняшника з окупованої Феодосії” [“San Cosmas (Ex-Laodicea): Theft of Ukrainian sunflower seeds from occupied Feodosia”], Kiborg. Dec. 2023, https://kiborg.news/2023/12/31/san-cosmas-ex-laodicea-vykradennya-ukrayinskogo-nasinnya-sonyashnyka-z-okupovanoyi-feodosiyi, last accessed Mar. 3, 2025.
[58] PEJ Ukraine Public Report, “The Pillage of Ukrainian Agricultural Assets”.
[59] IMO: 6379370. Address Strada Brailei, Gemenele, 1A, 810001 Braila, Romania.
[60] IMO: 6346994. Address C4, Strada Brailei, Gemenele, 1A, Braila, Romania.
[61] F1092. Gam Express, Video. Dec. 10, 2023.