DEKSA Warns of Hidden Sanctions Control

A Norwegian cargo ship leaves the Arctic coast and heads south towards the Netherlands. It is a familiar journey for vessels carrying Russian seafood to European buyers.

The trade has continued despite the sanctions imposed on Russia after its invasion of Ukraine. But the ships are only one part of the story. Behind the cargo are exporters, shipping companies and buyers whose business relationships can be difficult to trace.

On October 27, Norway’s Directorate for Export Control and Sanctions (DEKSA) answered questions from The New Backyard about a central concern: How can shipping companies know whether sanctioned Russians still benefit from businesses that have changed owners?

From Murmansk to the Netherlands

Earlier this year, The New Backyard examined import documents showing that three Norwegian ships transported 1,156 tonnes of Russian fish to the Netherlands. According to the documents, the vessels SILVER DANIA, SILVER BIRD and SILVER CRYSTAL carried fish from eight Russian suppliers.

The documents identify the Danish seafood company Sirena Group as the importer, with Daalimpex Velsen representing the importer in the Netherlands.

The shipping did not end in spring. In September, SILVER DANIA was again recorded sailing towards the Netherlands. On October 4, it departed Kirkenes in northern Norway with the Dutch port of Velsen listed as its destination.

These later movements show that the route remains active. They do not establish what the vessel carried or which companies were involved in those particular voyages.

The Owner May Have Changed. The Power May Not.

The investigation also uncovered historical connections between some Russian seafood suppliers and Igor Zubarev, a Russian senator sanctioned by Norway and the European Union. Several of the companies have been connected through a Russian investment fund.

Whether those arrangements leave sanctioned individuals with influence or financial benefits remains unanswered. There is no established evidence that Zubarev currently controls the suppliers or receives money from the documented shipments.

In its general explanation of sanctions rules, DEKSA referred to EU guidance on how a sanctioned person may transfer ownership of a company while retaining control. Norwegian companies may therefore need to look beyond registered shareholdings when checking their business partners. This was general guidance, not an assessment of Zubarev or the companies discussed in this article.

Norway Expects More Than Paperwork

In its response, DEKSA said companies must establish who owns or controls the businesses they deal with. The authority referred to EU guidance warning that ownership transfers around the time sanctions are imposed may require closer investigation. According to DEKSA, Norwegian companies are expected to take reasonable precautions, examine risks and keep records of their assessments.

DEKSA is bound by statutory confidentiality obligations under Section 8 of Norway’s Sanctions Act and is therefore legally prohibited from commenting on individual cases. This also prevents it from confirming whether it has received sanctions-related inquiries concerning the vessels or companies named in this investigation.

No sanctions violation has been established in connection with the documented shipments.

The Money Behind the Fish

The Norwegian vessels, Russian suppliers and European importers can be identified in the shipping and customs records. What those documents cannot show is who ultimately benefits from the transactions. For the later voyages, even the cargo and commercial partners remain unconfirmed.

That leaves the most important question unresolved: the money moving between European buyers and Russian businesses.

The ships can be followed across the sea. The money is harder to follow.