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On 18 February 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Rosneft Trading S.A. for "operating in the oil sector of the Venezuelan economy." OFAC's announcement included, under "Recent Rosneft Trading S.A. Activity" the following:
- "In January 2020, Rosneft Trading S.A. facilitated, on behalf of PdVSA, a shipment of two million barrels of Merey-16 crude oil from Venezuela to West Africa."
- "In the fall of 2019, PdVSA planned oil shipments with Rosneft Trading S.A. involving 55 million barrels of crude oil liftings from September to December 2019."
On 12 March 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated TNK Trading International S.A. for "operating in the oil sector of the Venezuelan economy."
For their operations in Venezuela, Rosneft / TNK used a number of tankers owned by third parties.
Prior to OFAC's designation of Rosneft / TNK, on 2 January 2020, Lloyd's List Maritime Intelligence published an article entitled "Oil trader begins West Africa STS route for Venezuelan cargoes", which described activities of three vessels in particular that had "...received transfers of crude loaded from Venezuela just off the coast of Lome, Togo."
The vessels in question were: Ridge S, Ridge U, and Ridge A. Lloyd's List Maritime Intelligence described the owner behind these vessels: "Low-profile oil trader and former Glencore executive Murtaza Lakhani is the director of the company, formerly known as IMMS Pte Ltd, which owns these ships."
Lloyd's List Maritime Intelligence posted that "Singapore-based Mercantile & Maritime Trading Ptd Ltd is the commercial operator of eight tankers, including five very large crude carriers purchased last November. All but one of the fleet is now tracked on this new trade route over the past four weeks. Three of the VLCCS were purchased in October for just under $100m in total from Ridgebury Tankers." [bold added]
Regarding the October purchase of vessels for $100m referred to in Lloyd's List Maritime Intelligence's article, Hellenic Shipping News published in Weekly Shipping Market Report Week 42 (11th Oct to 18th Oct 2019) the following:
"Ridgebury Holdings are on subs to sell their three VLCC “Ridgebury Utah” 299/2001 Daewoo, Korea (SS/DD 01/2021) & “Ridgebury Utik” 299/2001 Daewoo, Korea (SS/DD 05/2021) & “Ridgebury Artois” 298/2001 Hitachi Zosen, Japan (SS/DD 07/2021) to Turkish buyers Medship at a price of USD 32,5 mill each.". [bold added]
In "Below-radar Turkish outfit linked to string of tanker deals", published 8 November 2019, TradeWinds also commented on the deal, stating "Medship Shipping listed as manager of former Ridgebury Tankers", adding "A little-known company in Turkey has emerged as playing a role in a string of high-profile tanker deals lately..." [bold added]
On 2 March 2020, Reuters reported that "Mercantile & Maritime said on Monday it would terminate its shipments of Venezuelan oil for Rosneft after the United States imposed sanctions on the Russian oil firm’s Swiss trading unit." [bold added]
Mercantile & Maritime published statements in its website in relation to OFAC's designations.
On 18 February 2020, the company announced "On February 18 the US’ Treasury’s Office of Foreign Assets Controls announced further sanctions in relation to oil sales from Venezuela. Following an extensive review of our live arrangements, we can confirm that any activities impacted by the recent U.S sanctions will be terminated in accordance with the specified timeline."
On 12 March 2020, Mercantile & Maritime announced: "We are monitoring updates from the Office of Foreign Assets Controls (“OFAC”) and are continuing with the wind down of our impacted operations in line with the specified timeline. This includes the termination of any activities linked with Venezuela."
On 23 April 2020, Mercantile & Maritime announced it had concluded sale of Trident fleet. The fleet had ten vessels, among which:
- Trident Symphony (IMO 9227948), formerly Ridge S. Current name Mirame.
- Trident Tenacity (IMO 9221918), formerly Ridge U. Current name Kitakaze.
Chronology is of utmost importance in order to establish who owns and operates Mirame and Kitakaze these days. While Medship is described in late October / early November 2019 as buyer, Lakhani's Mercantile & Maritime was, without question, involved in their operational aspects, acting as point of contact with enquiring media from January 2020 till sale of Trident fleet in April 2020.
Medship (MEDSHIP DENIZCILIK VE TICARET ANONIM SIRKETI) is, indeed, a Turkish company. Records from Istanbul's companies register shows Medship was incorporated 17 October 2018 by Senol Bartin.
The address used by Bartin to incorporate Medship is the same as that of Medbulk Shipping, another Bartin company. Mercantile & Maritime's office in Istanbul has the same address.
Bartin has been described in the UK media as Lakhani's business partner.
Sources informed this site in early January 2021 that Mirame was loading 1.9 million barrels of crude in PDVSA's José Terminal in Venezuela, on behalf of a new client: Tracor Trading Company Limited. It was also relayed to this site that, allegedly, Lakhani was involved. This site's editor tweeted about it, on 3 January 2021.
Lakhani's PR agents (Hawthorn Advisors) took issue with the tweet, and sent an email on 4 January stating that Lakhani "is not involved in the trade or transport of PDVSA oil". Hawthorn's representative wrote that Mirame vessel "was sold by Mercantile & Maritime Trading to an unconnected third party in Q1 last year."
Hawthorn Advisors added that Lakhani had "no association with Tracor Trading Company Ltd or any alleged shipments made by Tracor Trading Company Ltd."
Included in the communication, Hawthorn stated that failure to delete tweet in question with "immediate effect" would result in escalation to its "client's legal team."
On 5 January 2021, Lakhani's lawyers (Schillings) emailed a Letter of Claim, complaining about allegation made in tweet referred. Schillings's Letter reiterated what Hawthorn Advisors had written with regards to sale of Mirame vessel. Schillings directed this site's editor to Mercantile & Maritime's 23 April 2020 announcement about sale of Trident fleet, as well as to a report published by Hellenic Shipping News:
"Mercantile & Maritime decided to dispose their three VLCC’s that were accused of trading Venezuelan oil. The “Trident Tenacity” 299/2001 Daewoo, Korea (SS/DD 01/2021), her sister vessel “Trident Symphony” 299/2001 Daewoo, Korea (SS/DD 05/2021) and the Japanese built “Trident Agility” 298/2001 Hitachi Zosen, Japan (SS/DD 07/2021), which were purchased in October last year for USD 98 mill enbloc, have now been sold again to undisclosed interests." [bold added]
In its Letter of Claim from 5 January, Schillings made an extraordinary claim in relation to the position of Mirame vessel, stressing that records showed that Mirame was not, and had not been, anywhere near Venezuela. Schillings further stated that it was "incumbent upon" this site's editor to "verify" the information.
Regarding verification of information and in addition to PDVSA's shipping data, this site consulted with shipping experts TankersTrackers.com regarding Mirame's position. A satellite image produced on 4 January 2021 by TankersTrackers.com corroborated Mirame's position, loading crude in PDVSA's José Terminal in Venezuela.
Furthermore, TankersTrackers.com alerted its clients (23 December 2020) on the position of Kitakaze in José Terminal, which according to PDVSA's shipping line up loaded another 1.9 million barrels of crude.
That is, 3.8 million barrels of crude had been lifted in quick succession at José Terminal in Venezuela by Mirame & Kitakaze. Both ships journeyed to Venezuela with their AIS transponders turned off.
In the meantime, requests for comment regarding relation between Bartin (Medship) and Lakhani were put to Hawthorn, as well as to Bartin. Hawthorn replied by saying that both had funded a separation operation of conjoined twins in London's Great Ormond Street Hospital. Reports about this operation describe Bartin as Lakhani's business partner. As per Medship, Hawthorn wrote that Medship had been involved as "technical / crew manager" but did not own, nor was the commercial operator of vessels. Ultimately, Hawthorn confirmed that Bartin and Lakhani are business partners.
Bartin also replied, saying that "Medship never owned any vessels." Bartin claimed Medship had been technical and crew manager, and stated that since "early 2020" was no longer involved. Bartin also said he did not know who the new owners / managers were. Bartin's email also included a legal threat.
This site published an article on 9 January 2021 about Mirame & Kitakaze, and about connections between Bartin, Medship, Lakhani and vessels in question. The article had included information -obtained at time of writing from MarineTraffic- that showed Lakhani's company (MMT) as owner of both vessels.
On 9 January 2021 Schillings sent another Letter of Claim. Schillings stated that any allegations with respect to current alleged involvement of Lakhani or his Mercantile & Maritime were "...false... grossly defamatory... reckless... untrue... indefensible..." based on "...out of date and inaccurate shipping records..." and were published with "malice", which made them "indefensible".
In the Letter, Schillings claimed to be an authoritative source on what is "public interest basis" pertaining Venezuela's energy sector, and added that there was "absolutely no urgency" in publication of this site's findings.
Schillings reiterated "Mr Lakhani sold the Mirame vessel in early 2020" and had "no connection with its current operator."
The article was deleted following email exchanges with both Hawthorn and Schillings. Hawthorn agreed to send further ownership information in relation to the vessels. To question as to who is the current owner, i.e. to whom did Lakhani's MMT company sold the vessels in April 2020, Hawthorn replied stating confidentiality agreements prevented further comment.
This site has been researching and checking Mirame & Kitakame information with different sources: MarineTraffic, VesselFinder, Q88, Equasis, International Maritime Organization's GISIS and Lloyd's List Maritime Intelligence.
This site informed MarineTraffic that its records on ownership of Mirame & Kitakaze were out of date. MarineTraffic subsequently corrected the inaccurate information.
Trident Symphony Ltd appears as Mirame's new owner, and Trident Tenacity Ltd as Kitakaze's new owner. This information coincides with what Hawthorn has told this site. Both entities appeared to be related, according to GISIS, to Trident Asia Shipmanagement Pte Ltd, registered 13 August 2020. Founder / Director Sridhar Pingali is one of the founders of MPartners, a separate corporate restructuring and shipping consultancy.
Equasis has SISALANA TECHNIK LTD, as vessels' ISM Manager since late October 2020. Sisalana appears to be a Belize shell, incorporated 15 October 2020.
While most sources coincide on registered owners being Trident Symphony Ltd for Mirame and Trident Tenacity Ltd for Kitakaze, Lloyd's List Maritime Intelligence has Bartin's Medship as Commercial Operator and Beneficial Owner: since 1st March for Mirame, and 2nd of March for Kitakaze.
Lloyd's List Maritime Intelligence has Trident entities becoming registered owners of record on 1st and 2nd March 2020. Medship's beneficial ownership records in relation to Mirame & Kitakaze coincide with these dates.
Hawthorn stated that such information (Lloyd's List Maritime Intelligence) regarding Medship's beneficial ownership in early March 2020 is "plainly wrong". No further clarification has been received from Hawthorn with regards to the fact that MMT sold the vessels in April 2020, therefore in early March Mirame & Kitakaze belonged to Lakhani's MMT.
Hawthorn explained that "...vessels were transferred to the Trident Symphony Ltd and Trident Tenacity Limited in November and December 2019 (not March 2020)."
Indeed, Lloyd's List Maritime Intelligence records have similar information, showing MMT as beneficial owner / owner of record for Kitakaze on 4th November 2019, and MMT as beneficial owner / owner of record for Mirame on 18 November 2019.
Hawthorn stated in an email that ships had been sold by Lakhani's company in April 2020, after having been bought in October 2019. As of this writing, no reply has been received about report from Hellenic News regarding purchase by Medship, i.e. the very source that Lakhani's representatives picked -to prove sale of vessels- had reported that it was Medship (not MMT) which bought them.
Hawthorn shared data from Q88, which they consider industry leader, showing Trident Symphony Ltd and Trident Tenacity Ltd as new owners.
Hawthorn added: "To be clear, neither MMT, Mr Lakhani nor any MM Group company or affiliate retained any shareholding, interest or control of the vessels or the holding companies, and they have no affiliation with the current Trident Symphony Ltd or Trident Tenacity Ltd."
Istanbul's company records show Medship is in the process of being dissolved.
MarineTraffic and Lloyd's List Maritime Intelligence show Prosperity Ship Management DWC LLC's involvement with Mirame & Kitakaze.
Staff associated with Medship in the recent past, appear currently associated with Sisalana and Prosperity, as per LinkedIn records.
Since first communication from Hawthorn Advisors, this site's editor has been dealing with what can only be described as inexplicably aggressive, Putinesque attempts by Lakhani's representatives to silence and censor any mention suggesting involvement, of either him or his company, in recent activities of Mirame & Kitakaze vessels in Venezuela. All manner of ultimatums, demands and threats have been sent.
Lakhani, described elsewhere as the "The Billion-Dollar Broker Who Managed a Nation’s Oil Wealth", basically wants to gag this site's editor forevermore, here and on social media, from making any comments that may imply a connection to anything remotely untoward, in relation to Mirame & Kitakaze's current ownership structure and deceptive practices seeking to avoid U.S. sanctions on Venezuela's oil sector. Lakhani's is seeking retractions, payment of legals costs and damages, while continuing to reserve his rights.
This site is not making, nor intending to make, allegations as to Lakhani's involvement in current operations of Mirame & Kitakaze.
However, Lakhani's legal counsel accusations levelled against this site's editor, of dishonesty, malice, inaccuracy, and, even, on what their beliefs are, as to this site's stance on being "above the law", are astonishing considering regulation of the legal profession in the UK.
In the 5 January 2021 Letter, Schillings chose to comment on position of Mirame, as per consulted "shipping records", despite the fact that their client had sold the vessel in April 2020. The argument was used, presumably, to advance the notion that information as to Mirame's real location in Venezuela published by this site's editor was false.
Moreover, Schilling's 5 January 2021 Letter's reference to Venezuela Sanctions Regulation General License No 8G, a license that addresses authorisation of American companies (Chevron, Halliburton, Schlumberger, Baker Hughes and Weatherford) in "Transactions Involving Petróleos de Venezuela, S.A. (PdVSA) Necessary for the Limited Maintenance of Essential Operations in Venezuela or the Wind Down of Operations in Venezuela", as a benchmark that somewhat governs activities or otherwise of their client's Singaporean entity, is baffling.
U.S. Treasury designated, directly, Rosneft Trading S.A. and TNK Trading International S.A.
Lakhani's operations in Venezuela -prior to sale of his Trident fleet- were related to Rosneft / TNK, as reported by Lloyd's List Maritime Intelligence, corroborated by Reuters, and confirmed by Mercantile & Maritime.
The U.S. Treasury issued a license (No 36A), "Authorizing Certain Activities Necessary to the Wind Down of Transactions Involving Rosneft Trading S.A. or TNK Trading International S.A."
This is the license that related to Lakhani's activities in Venezuela. The directive on the License was observed by Mercantile & Maritime, which on the very date of termination of allowed wind down period (20 May 2020), announced that "In accordance with the timeline set out by the Office of Foreign Assets Controls (“OFAC”) in its guidance issued on 12 March, Mercantile & Maritime has now completed the wind-down of its operations with Rosneft Trading S.A."
Apart from Rosneft / TNK, the U.S. Treasury has not issued secondary sanctions.
Crucial to this discussion, however:
1- Mirame lifted crude in early January 2021 that used to be traded by Rosneft Trading S.A. Mirame's trip to Venezuela was not reported, as AIS transponder had been switched off.
2- Said crude is produced by PetroMonagas, a PDVSA / Rosneft joint venture.
This is reflected in PDVSA's official shipping line up. Such activity may expose involved parties, i.e. Mirame and Kitakaze current owners, to OFAC sanctions.
Hence, vessels that used to be owned / controlled by Lakhani, are still involved in Venezuela with Rosneft.
These vessels journeys to Venezuela are shrouded by AIS switch offs, and are lifting crude that used to be traded by Rosneft Trading S.A.
One of the vessels, Mirame, loaded crude produced by PetroMonagas (Rosneft / PDVSA JV).
The jurisdictions of new ownership structure behind Mirame & Kitakaze (Seychelles, Belize, Djibouti) are notoriously opaque, i.e. perfect to hide UBOs and avoid existing sanctions by U.S. Treasury.
