Contract analysis

1. Executive Summary Following the issuance of the Final Award on 28 June 2024 in LCIA Case Reference No. 224718, in the sum of £96,450,000 in damages and pre-award interest (together with costs of £12,150,000, yielding a grand total of £108,600,000), Korinthian Maritime Holdings Ltd. ("KMH") and entities under the common control of its ultimate beneficial owner, Andrei Volkov, have engaged in a systematic and coordi

2. Background 2.1 The Parties Thalassa Shipping & Logistics SA ("TSL" / "Thalassa") is a Société Anonyme organized under Greek law, with its registered office at 14 Akti Miaouli, 4th Floor, Piraeus 185 35, Greece. Thalassa was founded in 1987 by the Papadimitriou family and has grown to become a significant operator in the international dry-bulk, tanker, and container feeder markets. The company currently operates a

3. Sources of Evidence The evidence compiled in this memorandum is drawn from the following principal sources: Hartwell Pemberton LLP ("HP") — Asset Tracing Report (Preliminary Findings), dated 15 August 2024. HP is a leading forensic accounting and investigative firm based at 25 Old Broad Street, London EC2N 1HN. The Preliminary Findings report was prepared by Rebecca Saunders, Partner in the Forensic & Investigativ

4. Category 1: Transfers of Funds from KMH and Subsidiary Bank Accounts 4.1 Overview HP's preliminary findings identify a clear and troubling pattern of significant outbound transfers from KMH's accounts and those of its subsidiary entities in the period immediately following the issuance of the Final Award on 28 June 2024. The timing of these transfers — concentrated in the first two weeks of July 2024 — their aggre

5. Category 2: Attempted Sale of M/V *Crimson Horizon* 5.1 Background on the Vessel M/V Crimson Horizon is a Handymax Bulk Carrier, bearing IMO No. 9801334, with a deadweight tonnage of 37,500 DWT. The vessel flies the Liberian flag and is classed with Meridian Industries. Her registered owner is Korinthian Bulkers (Singapore) Pte. Ltd. (80 Robinson Road, #14-02, Singapore 068898), which is a wholly-owned subsidiary

6. Category 3: Re-Flagging and Repositioning of Vessels 6.1 Re-Flagging Activities HP's investigation and Northcape Maritime Advisory's market intelligence indicate that KMH and its SPV subsidiaries have taken or considered steps to re-flag certain vessels in the fleet — that is, to change the flag state under which the vessels are registered — to registries that may be less cooperative with enforcement processes or

7. Category 4: Restructuring of Cypriot Holding Entities 7.1 Oceangate Ventures Ltd. (HE 401293) Oceangate Ventures Ltd. is the linchpin of KMH's corporate holding structure. As the intermediate holding company through which KMH controls Dnepr Shipholding Inc. (which in turn owns M/V Aegean Fortuna and M/V Volga Spirit) and other fleet SPVs, the shares of Oceangate represent a primary enforcement target. A judgment c

8. KMH's History of Conduct in the Underlying Dispute 8.1 Pattern of Dishonesty The evidence of post-Award dissipation must be considered in the context of KMH's conduct during the underlying arbitration proceedings. The tribunal's Final Award contains significant findings regarding KMH's dishonest and improper conduct, which are directly relevant to the assessment of dissipation risk. Most significantly, the tribuna

9. Volkov Family Control and Decision-Making The dissipation activities described in Sections 4 through 7 span multiple jurisdictions (England, Singapore, the UAE, Cyprus, and the BVI), involve multiple entities within and outside the KMH corporate group, and affect multiple asset classes (cash, vessels, and corporate equity). The coordination and simultaneity of these activities are inconsistent with independent dec

10. Summary of Dissipation Evidence for WFO and Cross-Border Applications 10.1 Summary Table of Key Dissipation Indicators The following table summarizes each category of dissipation evidence, the relevant entities, the jurisdictions affected, the approximate values involved (where known), and the source of the evidence: The aggregate value of the dissipation activity identified to date — encompassing both actual tra