Our flag means cash: The Latvian trader abetting Russia’s billion-dollar oil sanctions evasion

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The editorial team extends its thanks to MarineTraffic for providing access to the merchant fleet database and to OCCRP for their assistance with the Cyprus registry.

How Halavins burst through the cap

The price cap is a restrictive measure designed to limit Russian budget revenues from crude oil sales without causing a global price surge. Western companies are prohibited from servicing Russian oil sales (that is, providing brokerage, transportation, and insurance services) if the price of the transaction exceeds $60 per barrel. Russia, however, continues to receive the oil revenue it needs so badly for its war in Ukraine due to the fact that many European intermediaries have moved their businesses to Dubai, where they continue to trade in market priced Russian oil. The Insider analyzed these legal entities and found EU citizens among their management.

One of the largest buyers of above-the-cap Russian oil is Latvian national Aleksejs Haļavins, who was found to have ties to three Dubai-based entities: Black Pearl Energy Trading LLC, which he owned and headed, along with its affiliates OGC Shipping LLC and Conmar Maritime. In 2023, the first two companies bought roughly 38 million barrels of oil from Surgutneftegaz at an average “above-the-cap” price of $82 per barrel. For the period from January to May 2024, customs records show only the activities of Black Pearl Energy Trading, which purchased over 20.6 million barrels of oil at an average price of $83.7 per barrel.

As a result, Surgutneftegaz alone received roughly $1.4 billion more in revenue than it would have by selling its oil at the price cap rate. The total yearly additional revenue to the Russian budget from oil sales bypassing the cap is estimated at $7-11 billion — a significant boost to the Russian war machine.

A fleet of tankers for “above-the-cap” oil — and Hezbollah

In July 2024, 44 European countries approved a crackdown on Russia's tankers transporting oil in circumvention of the price cap. The UK’s official estimate suggests that Putin’s “shadow fleet” is made up of approximately 600 ships that transport an average of 1.7 million barrels of oil per day. The Insider connected Haļavins to companies owning and operating tankers that deliver Russian oil to Indian and Chinese ports.

In a 2022 interview for YoungShip Cyprus, Haļavins presented himself as the “general manager” of Sparta Shipmanagement and “chair of the board of directors and ultimate beneficial owner” of the OGC Group. On LinkedIn, he was actively hiring commercial fleet operators in Dubai, providing his sparta-shipmanagement.com email for communication.

Sparta Shipmanagement is registered in Cyprus at the same address as Lagosmarine Ltd. Both companies are now managed and formally owned by the same Greek national. Lagosmarine also shares the address with a host of shell companies that own the tankers Clyde Noble, Sagar Violet, and Caroline Bezengi, according to the International Maritime Organization. As follows from records on marinetraffic.com, these vessels regularly navigate between the Russian ports of Primorsk, Ust-Luga, and Kozmino and ports in India and China. According to customs documents, the same routes were used to move oil sold to Dubai-based companies linked to Haļavins.

Incidentally, Israel accuses one of Lagosmarine's tankers, the Fuga Bluemarine, of transporting Iranian oil for the Quds Force and Hezbollah, as follows from a document signed by Israeli Defense Minister Yoav Gallant.

The Insider has sent an inquiry to Israel's National Bureau for Counter Terrorist Financing.

Halavins' ties with Russian state companies

How did little-known Emirati firms owned by a Latvian trader gain the right to purchase Russian oil worth billions of dollars?

Haļavins does not create the impression of someone whose companies generate billions of dollars in revenue. On social media, “Alex” presents himself as a specialist in maritime transport and a professional in oil trading, traveling between Surgut, St. Petersburg, Dubai, Cyprus, and Riga, often posing in front of a private jet (owned by a jet rental company) or at the helm of a maritime vessel.

On his LinkedIn profile, Haļavins identifies himself as the beneficiary and CEO of the Conrad Management Company. The Insider has obtained several residency permits issued in the UAE to employees of the Russian state-owned company Promsyrioimport. In some cases, Conrad Management Company is listed as the “sponsor” for these individuals' stays in the UAE. FGUP Promsyrioimport (ФГУП «Промсырьеимпорт») is a company under the jurisdiction of the Russian Ministry of Energy that handles maritime shipments of oil and petroleum products. This company is no stranger to sanctions violations: even before Russia’s full-scale invasion of Ukraine, Promsyrioimport was sanctioned by Kyiv for supplying fuel to Crimea, and in 2018, the firm was sanctioned by the U.S. for its role in facilitating Iranian oil deliveries to Syria, bypassing restrictions imposed by Washington.

At present, details about Promsyrioimport's management are concealed in the Russian registry. Mikhail Silantiev previously held the position of the company’s acting CEO. Border crossing records indicate that Silantiev has made numerous trips between Russia and the UAE in recent months.

Silantiev did not respond to calls or messages from The Insider. The Insider also contacted Vladimir Filippov, Promsyrioimport’s deputy CEO (as of at least 2019). Initially, Filippov seemed unperturbed by mentions of Lagosmarine tankers, but after the journalist introduced himself, Filippov claimed he had been mistaken and denied any knowledge of the matter.

The Insider also reached out to Denis Deryushkin, the former deputy head of the Russian Energy Agency and Russia's past representative in the OPEC+ technical committee. Sources have connected Derushkin to the leadership of Black Pearl. When asked about the Clyde and Sagar tankers, Deryushkin recognized their names. He also confirmed having seen Filippov “just three minutes ago” and promised to clarify the situation.

As for Haļavins himself, in response to The Insider's inquiry, he wrote:

“I don’t quite understand the essence of your messages and can assure you that all my actions are carried out within the framework of international law, including compliance with sanctions. With all due respect, your message seems like a provocation. Thank you and have a good day.”

Legal consequences

Current Western legal frameworks have mechanisms in place for prosecuting citizens of democratic countries who assist in evading trade embargoes and sanctions. For instance, Article 84 of the Latvian Criminal Code establishes criminal liability for circumventing sanctions imposed by Latvia or international organizations. Furthermore, Article 4 extends this responsibility to Latvian citizens even if the offense is committed outside the country.

Claims by Western law enforcement agencies and governments that the “unofficial” status of customs information prevents them from launching criminal cases are unconvincing. A U.S. Senate Subcommittee on Investigations report from September 10, 2024, effectively mandates that companies use commercially available customs data portals and counterparty verification systems like ExportGenius and ImportGenius to blacklist specific buyers (although these specific portals were not enumerated in the report). Given that platforms like ImportGenius may become mandatory for private companies, it is puzzling that law enforcement agencies do not employ the same data as a starting point for investigating sanctions violations.

Moreover, as lists of vessels owned by violating companies are publicly accessible through the International Maritime Organization, authorities in Denmark and Sweden have no trouble monitoring such ships when they pass through the Danish Straits en route from Ust-Luga to India.

The Insider has sent an inquiry to the Danish Maritime Authority.

The continued flow of “above-the-cap” oil revenues fueling Putin’s war machine points to the disorganization of supervisory governmental agencies. The obvious gaps in regulatory enforcement suggest that these authorities are failing to utilize tools readily available to investigative journalists — to say nothing of the more advanced financial intelligence methods that state services have at their disposal.

This report was produced with the assistance of Timur Olevsky.