Contract analysis

1. Executive Summary The purpose of this memorandum is to analyze approximately £4,200,000 in receivables owed to Korinthian Maritime Holdings Ltd. ("KMH") and its subsidiaries by four identified sub-charterer debtors and to recommend the most effective legal mechanisms for attachment and recovery of those receivables in the relevant jurisdictions. This analysis forms part of the broader enforcement campaign in respe

2. Background and Context 2.1 The Underlying Award and Enforcement Campaign LCIA Award No. 224718 was issued on 28 June 2024 following a hearing on the merits that took place over twelve days in January and February 2024, with post-hearing submissions concluding in April 2024. The Tribunal was constituted as follows: • Presiding Arbitrator: Sir Malcolm Fenton-Clarke • Claimant-nominated Arbitrator: Professor Athena D

1. M/V *Aegean Fortuna* — IMO 9784521; Supramax Bulk Carrier; 58,200 DWT; beneficially owned through Dnepr Shipholding Inc.

2. M/V *Crimson Horizon* — IMO 9801334; Handymax Bulk Carrier; 37,500 DWT; beneficially owned through Dnepr Shipholding Inc. (since judicially sold in Singapore on 15 November 2024).

3. M/V *Volga Spirit* — IMO 9756892; Panamax Bulk Carrier; 76,400 DWT; beneficially owned through Dnepr Shipholding Inc.; Cyprus flag; last reported at Fujairah anchorage. The Tribunal found that KMH had committed repudiatory breaches of the charter-party agreements in respect of all three vessels and awarded TSL damages as follows: In addition, the Tribunal allocated costs 85% to KMH, resulting in a costs award comp

1. Sub-charterer receivables — approximately £4,200,000, as analyzed in this memorandum.

2. M/V *Volga Spirit* — owned by Dnepr Shipholding Inc. (BVI Company No. 2014876), Cyprus flag, last reported at Fujairah anchorage. Arrest and judicial sale of this vessel is being pursued separately and is the subject of a separate memorandum. The vessel's estimated market value, based on comparable sales data and broker assessments obtained by HP, is in the range of USD $18,000,000–$22,000,000 (approximately £14,5

3. Continuing post-award interest accrual — interest continues to accrue at approximately £13,877 per day (£96,450,000 × 5.25% / 365) on the unpaid principal balance. The accrual of interest increases the total amount owed but does not itself generate a recoverable asset. 2.3 KMH's Corporate Structure Relevant to Receivables An understanding of KMH's corporate structure is essential to the analysis of the sub-charter

3. Sources of Information on Sub-Charterer Receivables 3.1 WFO Asset Disclosure The worldwide freezing order granted on 16 July 2024 by Mr. Justice Ashworth in the Commercial Court (CL-2024-000487) required KMH to disclose all of its assets worldwide exceeding £25,000 in value, whether held in its own name or through any entity owned or controlled by it, within seven days of service of the order. The WFO was served o

1. Preliminary Findings Report (15 August 2024): This report identified KMH's global asset structure, including bank accounts, vessel ownership, real property interests, and the existence of sub-charter arrangements. The report was instrumental in shaping the enforcement strategy and identifying the key jurisdictions for enforcement action.

2. Updated Findings Report (1 October 2024): This report provided further detail on specific sub-charter agreements, the amounts outstanding under those agreements, and the identity of the sub-charterer debtors. The report drew on publicly available shipping databases, port records, broker intelligence, and financial analysis of payment flows through bank accounts disclosed by KMH and identified independently by HP.

3. Post-Award Asset Movement Analysis (25 November 2024): This report tracked payments received by KMH and its subsidiaries from sub-charterers in the period following the issuance of the Award. The analysis revealed that certain payments, particularly from Caspian Logistics & Chartering DMCC, had been diverted to accounts connected to Andrei Volkov rather than being held in the ordinary course of business. These div

4. Identified Sub-Charterer Receivables 4.1 Summary Table of Receivables The following table summarizes the four identified sub-charterer receivables. Each receivable is discussed in detail in Sections 4.2 through 4.5 below. Exchange rates used for GBP equivalents are approximate and based on prevailing rates as at 10 February 2025 (USD/GBP 0.8038; AED/GBP 0.2125; EUR/GBP 0.8590). Actual amounts recovered will vary w

5. Legal Mechanisms for Attachment of Receivables by Jurisdiction 5.1 England & Wales Applicable mechanism: Third-party debt order under Part 72 of the Civil Procedure Rules 1998. A third-party debt order ("TPDO") enables a judgment creditor to intercept a debt owed by a third party to the judgment debtor and to have that debt paid directly to the judgment creditor in satisfaction (or part satisfaction) of the judgme

6. Practical Considerations and Risks 6.1 Cost-Benefit Analysis The total estimated value of the four identified sub-charterer receivables is approximately £4,200,000. Against this, the estimated incremental costs of pursuing attachment across the relevant jurisdictions are as follows: C&H fees: The attachment analysis, strategy, and coordination work falls within the scope of the enforcement engagement. The current