Review of Inrostopt shipments to North Korea

A review of Inrostopt LLC export operations from 2022 to 2024 identified volumes above the UN cap, payments through UAE companies, and petroleum shipments to two recipients in North Korea.

Gas tanker at a storage and transfer terminal

Case overview

Category
Sanctions risk review
Subject
Inrostopt LLC, tax ID 2538114016
Review period
2022–2024
Jurisdictions
Russia · UAE · North Korea

Context

Inrostopt LLC is registered in Vladivostok and exported petrol, diesel fuel, and liquefied petroleum gas from 2022 to 2024. Customs declarations identified North Korea as the final destination. UssuriNefteprodukt LLC, tax ID 2511044682, supplied the raw materials.

Bondar N. V. was identified as the founder and de facto manager of Inrostopt. Bondar A. A. acted as director and customs declarant. Directorship was transferred within the family shortly before the active shipment period.

Objective

Compare the goods and payment flows, assess shipment volumes against UN Security Council Resolution 2397, and identify the companies, banks, individuals, and logistics infrastructure supporting the operations between Russia, the UAE, and North Korea.

Goods and payment routes

Goods moved from Russia to North Korea. Payments travelled in the opposite direction through Esgravity General Trading FZCO and Amax General Trading FZCO in the UAE, a Russian bank, and finally to Inrostopt LLC. The mismatch between the goods and payment routes obscured the final payer in a standard review.

Map of the goods and payment routes between Russia, the UAE, and North Korea

How the review was conducted

Comparison of customs declarations and bank statements

Review of companies, directors, and beneficial owners in Russia and the UAE

Analysis of payments in roubles, US dollars, euros, and yuan

Review of the Russia–North Korea rail route

Data sources

Customs declarationsBank statements and payment recordsRussian and UAE corporate registriesInternational shipment dataCorporate press and open sources

Participants in the operations

The chain included UssuriNefteprodukt LLC, Inrostopt LLC, Promselkhozbank, Esgravity General Trading FZCO, and Amax General Trading FZCO. The North Korean recipients were Ka Thae JV and Won Bok FTC. The documented transaction volumes were approximately USD 5.6 million and USD 0.6 million respectively.

Payments through Esgravity exceeded RUB 200 million, while Amax processed RUB 94 million. The ultimate beneficial owners of both UAE companies could not be established.

Diagram of companies, individuals, banks, and recipients linked to shipments to North Korea

What the review established

01

Inrostopt shipments exceeded the annual cap of 500,000 barrels established by UN Security Council Resolution 2397 within six months.

02

The shipments included petrol, diesel fuel, and liquefied petroleum gas. Some of these categories are directly restricted or prohibited by the resolution.

03

Esgravity and Amax were registered in the UAE shortly before the transactions, used Russian digital infrastructure, and did not disclose verifiable ultimate beneficial owners.

04

Shipments passed through a rail terminal serving the Russia–North Korea border crossing. A national rail operator handled the freight under a long-term contract with Inrostopt LLC.

05

The combined routes, payments, management structure, and unidentified beneficial owners formed a consistent picture of potential sanctions circumvention.

Review outcome

The report connected specific declarations, payments, companies, directors, and recipients into a single structure. The recommended next steps were to establish the beneficial owners of the UAE companies, separately review Promselkhozbank contract No. C-1112, and examine the biographies and links of A. A. and N. V. Bondar to the bankrupt energy group.

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