PRIVILEGED AND CONFIDENTIAL — ATTORNEY WORK PRODUCT

PRIVILEGED AND CONFIDENTIAL — ATTORNEY WORK PRODUCT
MEMORANDUM
TO: Samuel Eklund, Responsible Partner; Hannah Brinkley, Lead Associate
FROM: Patrick Gallagher, Working Associate
DATE: 25 February 2025
RE: M/V Volga Spirit (IMO 9756892) — Remaining Enforcement Options for Recovery of Outstanding Balance
MATTER: Thalassa Shipping & Logistics SA v. Korinthian Maritime Holdings Ltd. — Enforcement of LCIA Award No. 224718
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1. Executive Summary
The purpose of this memorandum is to analyse the remaining enforcement options available to Thalassa Shipping & Logistics SA ("TSL") in respect of M/V Volga Spirit (IMO 9756892) as a means of recovering a portion — or potentially the entirety — of the outstanding balance owed under LCIA Award No. 224718 dated 28 June 2024 (the "Award"). This memorandum is intended for review by the responsible partner and lead associate in advance of the next client status update and for the purpose of directing the enforcement team's immediate next steps.
The Award ordered Korinthian Maritime Holdings Ltd. ("KMH") to pay TSL damages in the total principal amount of £96,450,000. The tribunal further allocated costs to KMH in the aggregate amount of £12,150,000, comprising £3,240,000 in LCIA administrative and tribunal costs and £8,910,000 in respect of TSL's legal costs. The grand total of the Award plus costs is therefore £108,600,000.
Post-award interest accrues at 5.25% per annum simple on the principal sum of £96,450,000 from 29 June 2024 (the day following the date of the Award). Calculated through an estimated enforcement target date of 15 March 2025 — a period of approximately 260 days — the accrued interest is estimated at £3,607,726.03. The grand total owed by KMH as of 15 March 2025 is therefore estimated at approximately £112,207,726.03.
The enforcement campaign, conducted simultaneously across four jurisdictions, has been substantially successful. Total recovered to date across all jurisdictions is £96,590,000, representing approximately 88.94% of the Award plus costs figure (before interest). The outstanding balance — inclusive of post-award interest estimated to 15 March 2025 — is approximately £15,617,726.03.
M/V Volga Spirit represents one of the principal remaining tangible assets available for enforcement. The vessel is a Panamax Bulk Carrier of 76,400 DWT, Cyprus-flagged, and registered in the name of Dnepr Shipholding Inc., a BVI special purpose vehicle which forms part of KMH's corporate fleet structure. The vessel was last reported at Fujairah anchorage, United Arab Emirates, where she appears to be engaged in bunkering or awaiting loading instructions.
This memorandum addresses the following matters:
(a) vessel particulars and ownership structure;
(b) beneficial ownership analysis linking the vessel to KMH;
(c) current vessel location and intelligence concerning the vessel's movements and operational status;
(d) arrest prospects in the United Arab Emirates and alternative jurisdictions;
(e) estimated vessel value on both a fair market and forced sale basis; and
(f) recommended course of action, including immediate, contingent, and budgetary steps.
The central recommendation of this memorandum is that arrest papers should be pre-positioned on an expedited basis for filing in the Fujairah Court of First Instance, and that parallel lines of inquiry — in particular the status of the Oceangate Ventures Ltd. shares following the Cyprus forced sale — should be pursued as a matter of urgency.
2. Background — Recovery to Date
2.1 Summary of Enforcement Campaign
Enforcement proceedings were commenced simultaneously across four jurisdictions — England and Wales, Cyprus, Singapore, and the United Arab Emirates — following the issuance of the Final Award on 28 June 2024. The Award was rendered by the LCIA tribunal constituted as follows:
•  Presiding Arbitrator: Sir Malcolm Fenton-Clarke
•  Co-Arbitrator: Professor Athena Drakopoulos
•  Co-Arbitrator: Dr. Henrik Dalmqvist
•  Tribunal Secretary: Fiona Beckett
The underlying dispute arose from charter-party arrangements concerning three dry-bulk carriers: M/V Aegean Fortuna, M/V Crimson Horizon, and M/V Volga Spirit, all of which were chartered by TSL from KMH under English law time charter-party agreements incorporating LCIA arbitration clauses with a London seat. The tribunal found, among other things, that KMH had fabricated off-hire deductions totalling £8,420,000 across the three vessels, had breached its obligations to maintain the vessels in a seaworthy and efficient condition, and had wrongfully terminated the charter-parties. The tribunal awarded TSL principal damages of £96,450,000, comprising restitution of the fabricated off-hire deductions, loss of profit and market differential damages, and consequential losses arising from the wrongful terminations.
The multi-jurisdictional enforcement strategy was developed in coordination with the responsible partner and client in the immediate aftermath of the Award and was designed to maximise the speed and reach of recovery while KMH's assets could still be identified and restrained. The approach has been materially successful, as set out below.
2.2 Recovery Table
The following table summarises the recoveries achieved to date, by jurisdiction:
The outstanding balance as of 15 March 2025, inclusive of post-award interest estimated to that date, is approximately £15,617,726.03.
It should be noted that the sterling equivalent figures for the Singapore and UAE recoveries are based on the exchange rates prevailing on the respective dates of receipt and have been confirmed by the firm's accounts department. Minor adjustments may arise following final reconciliation of foreign exchange costs and bank charges.
2.3 Remaining Assets Available for Enforcement
Our ongoing asset identification efforts, conducted in coordination with Hartwell Pemberton LLP, have identified two principal categories of remaining assets against which enforcement may be pursued:
(a) M/V *Volga Spirit* (IMO 9756892), the subject of this memorandum, which is the last remaining vessel in KMH's fleet that has not been arrested, sold, or otherwise dealt with through enforcement proceedings; and
(b) Sub-charterer receivables owed to KMH and its subsidiaries, estimated at approximately £4,200,000 in the aggregate, arising from a number of ongoing sub-charter arrangements for tonnage outside the core fleet. These receivables are the subject of a separate memorandum currently in preparation.
The successful arrest and judicial sale of M/V Volga Spirit could substantially close — or potentially fully satisfy — the outstanding balance. When combined with anticipated recovery from the sub-charterer receivables, TSL would be well positioned to achieve complete satisfaction of the Award.
3. Vessel Particulars — M/V *Volga Spirit*
3.1 Technical Specifications
The principal particulars of the vessel are as follows:
M/V Volga Spirit is the third of the three vessels that were at the centre of the charter-party dispute underlying the Award. The tribunal made specific findings in relation to this vessel, including that KMH had fabricated off-hire deductions of approximately £2,740,000, which were found to be entirely without basis. The tribunal ordered restitution of those sums. In addition, the vessel attracted a proportionate share of the loss of profit and market differential damages of £16,480,000 awarded by the tribunal in respect of KMH's wrongful termination of the charter-party arrangements.
A full vessel particulars summary, including builder details, yard number, year of build, dimensions, and machinery specifications, is set out at Appendix A to this memorandum. We are awaiting updated classification and survey information from Northcape Maritime Advisory Ltd. and will circulate an updated version of Appendix A when that information is received.
3.2 Registered Owner
The registered owner of M/V Volga Spirit is Dnepr Shipholding Inc., a company incorporated in the British Virgin Islands as a special purpose vehicle (SPV) for the purpose of holding title to vessel assets. The relevant details are as follows:
•  Company number: 2014876
•  Jurisdiction of incorporation: British Virgin Islands
•  Registered agent: Vantage Corporate Services Ltd., Road Town, Tortola, BVI
•  Function: Fleet SPV; registered owner of vessel tonnage
Dnepr Shipholding Inc. is not only the registered owner of M/V Volga Spirit but is also the registered owner of M/V Aegean Fortuna (IMO 9784521, Supramax Bulk Carrier, 58,200 DWT, marshall Islands flag). M/V Aegean Fortuna is not currently the subject of enforcement proceedings; its present status and trading activity will be addressed in a separate update if the enforcement team considers it a viable target.
The use of single-purpose BVI-incorporated shipholding companies is standard practice in the shipping industry and is not in itself indicative of any improper purpose. However, the SPV structure creates a corporate separation between the judgment debtor (KMH) and the registered owner of the vessel (Dnepr), which KMH can be expected to invoke in resisting any arrest of the vessel. The analysis of beneficial ownership and the means of overcoming the corporate separation are addressed in Section 4 below.
3.3 Charter-Party History
The time charter-party agreement for M/V Volga Spirit was signed on 10 June 2021 between TSL (as charterer) and KMH (as disponent owner). The charter-party was governed by English law and incorporated an LCIA arbitration clause with a London seat. KMH acted as the disponent owner throughout the charter period, assuming all commercial and operational management responsibilities in relation to the vessel, while Dnepr Shipholding Inc. remained the registered and beneficial owner for title and insurance purposes.
The tribunal found that KMH had applied fabricated off-hire deductions of approximately £2,740,000 to TSL's hire payments for M/V Volga Spirit, purportedly on account of mechanical breakdowns and cargo hold deficiencies that either did not occur or were of a de minimis nature. The tribunal rejected KMH's evidence on these points in strong terms, characterising certain of the documentary evidence advanced by KMH as "unreliable and, in material respects, fabricated." Restitution of the full amount of the fabricated deductions was ordered, together with damages for lost trading days.
4. Beneficial Ownership Analysis — Linking Dnepr Shipholding Inc. to KMH
4.1 Corporate Chain
The beneficial ownership analysis set out below is based on the asset tracing work conducted by Hartwell Pemberton LLP (Rebecca Saunders, Partner; Mark Huxley, Director) and the firm's own independent analysis of corporate registry filings, the tribunal record, and information disclosed by KMH pursuant to the worldwide freezing order.
The corporate ownership chain for M/V Volga Spirit is as follows:
Level 1 — Vessel: M/V Volga Spirit is registered in the name of Dnepr Shipholding Inc. (BVI Company No. 2014876). Dnepr is a special purpose vehicle with no independent operations, employees, or commercial activities beyond holding title to vessel assets. Its sole function is to serve as the registered owner of vessels in the KMH fleet.
Level 2 — Intermediate Holding Company: Dnepr Shipholding Inc. is wholly owned by Oceangate Ventures Ltd. (Cyprus, Registration No. HE 401293, registered address: 28 Themistokli Dervi Avenue, Suite 604, Nicosia 1066, Cyprus). Oceangate is the intermediate holding company for KMH's fleet SPVs and is the direct shareholder of both Dnepr Shipholding Inc. and the SPVs holding title to other vessels in the KMH fleet.
Level 3 — Ultimate Corporate Parent: Oceangate Ventures Ltd. was, prior to the Cyprus forced sale proceedings, wholly owned by Korinthian Maritime Holdings Ltd. (Cyprus, Registration No. HE 387421, registered address: 28 Themistokli Dervi Avenue, Suite 601, Nicosia 1066, Cyprus). KMH is the judgment debtor and the entity against which the Award was rendered.
Level 4 — Ultimate Beneficial Owner (UBO): KMH is beneficially owned by the Volkov family through a series of BVI and Cypriot holding structures. Andrei Volkov is the ultimate beneficial owner and de facto director of KMH and its subsidiaries. Sergei Volkov (son of Andrei Volkov) is a director of KMH and of several entities in the group.
A corporate ownership chart illustrating this structure is set out at Appendix B, based on information sourced from the Hartwell Pemberton LLP asset tracing reports.
An important complication must be noted in relation to the current status of this ownership chain. The forced sale of the Oceangate Ventures Ltd. shares in the Cyprus enforcement proceedings — which took place between October and November 2024 and yielded a portion of the £22,350,000 recovered in Cyprus — may have altered the intermediate ownership layer. Specifically, analysis is required as to the following:
(a) Whether the Oceangate shares sold in the Cyprus proceedings represented the entirety of the issued share capital of Oceangate, or only a portion thereof;
(b) Whether the purchaser of the Oceangate shares thereby acquired indirect ownership of Dnepr Shipholding Inc. and, in turn, M/V Volga Spirit;
(c) Whether Dnepr's shares were held directly by Oceangate at the time of the forced sale, or whether they had been transferred to a new entity prior to or as part of the Cyprus execution proceedings; and
(d) Whether TSL, as the judgment creditor at whose instance the forced sale occurred, may now have an indirect ownership interest in Dnepr — and thus in M/V Volga Spirit — depending on the identity and status of the share purchaser.
These questions are addressed further in Section 8.2 below and are the subject of the first recommended step at Section 9.1(5).
Even if the Oceangate share sale has severed KMH's direct ownership chain to Dnepr, the enforcement judgment remains executable against KMH's assets, and the vessel was beneficially owned by KMH at the time the liabilities arose and at the time the Award was rendered. The principle that a judgment debtor cannot frustrate enforcement by transferring assets — particularly where such transfer occurs after the crystallisation of the underlying liability or in breach of a freezing order — is well established in most of the relevant jurisdictions.
4.2 Implications for Arrest
The arrest of M/V Volga Spirit depends on establishing, in the jurisdiction where arrest is sought, that the vessel is owned by, controlled by, or otherwise sufficiently associated with the judgment debtor (KMH) to permit the vessel to be seized in satisfaction of the judgment.
The legal mechanisms for achieving this vary by jurisdiction:
(a) In admiralty jurisdictions that recognise an "associated ship" doctrine — such as Singapore — sister-ship arrest is available where the vessel is owned by a person who is liable on the claim and who was, at the time when the cause of action arose, the owner or charterer of, or in possession or control of, the vessel giving rise to the claim. Given that KMH was the disponent owner and effective controller of M/V Volga Spirit throughout the relevant period, and Dnepr is wholly owned through the KMH group, the associated ship arrest route presents strong prospects in Singapore.
(b) In the UAE (onshore courts and DIFC), the position on in rem arrest based on beneficial ownership through an SPV requires careful analysis under UAE Federal Law No. 26 of 1981 (the UAE Maritime Code) and the applicable provisions of the UAE Civil Procedure Code. The concept of piercing the corporate veil in the maritime arrest context is less well developed in UAE jurisprudence than in common law jurisdictions, and the position will need to be assessed in detail with Al-Rashid Hatem & Associates. This analysis is addressed further in Section 6.1 below.
(c) In Cyprus, as the flag state, the vessel is subject to Cyprus's admiralty jurisdiction, and arrest may be obtained under the Merchant Shipping (Registration of Ships, Sales and Mortgages) Law (Law No. 45(I)/2010) and the applicable admiralty procedural rules. TSL already holds an enforcement order from the Nicosia District Court.
The corporate chain analysis confirms that, irrespective of the formal registration of the vessel in the name of a BVI SPV, the economic reality is that M/V Volga Spirit is — or was at all material times — an asset of the KMH group, held through a transparent single-purpose holding structure for the ordinary purposes of shipping finance and title management. The enforcement team should be prepared to advance this argument forcefully in any jurisdiction where arrest is pursued.
5. Current Vessel Location and intelligence
5.1 Last Reported Position
M/V Volga Spirit was last reported at Fujairah anchorage, United Arab Emirates. Fujairah is a major bunkering and anchorage hub located in the Gulf of Oman, on the eastern coast of the UAE, outside the Strait of Hormuz. It is one of the world's largest bunkering ports and serves as a staging point for vessels trading in the Arabian Gulf, the Indian Ocean, and the wider Middle East region.
The vessel's position intelligence has been obtained from commercial AIS (Automatic Identification System) tracking data provided by our regular maritime intelligence suppliers and has been independently confirmed by Northcape Maritime Advisory Ltd. (Captain Ian Forsyth, Managing Director, 3 Thomas More Square, London E1W 1WY). Captain Forsyth's team has been monitoring the vessel's AIS transmissions on an ongoing basis since the commencement of enforcement proceedings. The most recent AIS position report is attached as Appendix D.
As at the date of this memorandum, the vessel appears to be at anchor in the Fujairah anchorage area and has been stationary for approximately 72 hours. The vessel's AIS status indicates "at anchor," and there are no current port call or destination entries in the vessel's AIS transmission data. The vessel may be awaiting loading instructions, bunkering, or conducting crew changes.
5.2 Vessel Movement Patterns
Post-Award, M/V Volga Spirit has been trading primarily in the Arabian Gulf and Indian Ocean region. Based on AIS data and port call records compiled by Northcape, the vessel's principal port calls since the date of the Award include Fujairah (multiple calls), Jebel Ali (Dubai), and various ports on the west coast of India, including Mundra and Kandla.
Notably, the vessel has avoided ports in jurisdictions where enforcement orders are in force, specifically England, Cyprus, and Singapore. This pattern is consistent with KMH's broader post-Award behaviour, which Hartwell Pemberton characterised in their Post-Award Asset Movement Analysis (dated 25 November 2024) as reflecting a deliberate strategy of asset-shifting and dissipation. Hartwell Pemberton identified, among other things, the movement of funds between accounts in non-enforcement jurisdictions, the acceleration of payments to related parties, and the redirection of vessels away from jurisdictions with active enforcement proceedings. The avoidance of Singapore is particularly telling, given that Singapore was previously a regular port of call for the KMH fleet.
There is a continuing and material risk that the vessel may be re-flagged or transferred to a new SPV in an attempt to frustrate enforcement. The worldwide freezing order ("WFO") granted by Mr. Justice Ashworth on 16 July 2024 in the Commercial Court (CL-2024-000487), and continued on 30 July 2024, prohibits KMH from disposing of, dealing with, or diminishing the value of any of its assets worldwide up to the value of £108,600,000 (the full Award plus costs figure, subject to reduction upon partial discharge application in light of recoveries to date). The vessel, as an asset of KMH held through the Dnepr/Oceangate structure, is squarely within the scope of the WFO. Any transfer of the vessel — whether by re-flagging, change of registered owner, or disposal of the shares in Dnepr Shipholding Inc. — would constitute a breach of the WFO and could give rise to contempt proceedings in the English Commercial Court.
However, the practical effectiveness of the WFO in preventing asset dissipation depends on enforcement, and the risk of non-compliance by KMH (a Cypriot company controlled by BVI structures and the Volkov family, with limited personal exposure to the English court's contempt jurisdiction) should not be underestimated. The monitoring and protective measures recommended in Section 9 are designed to mitigate this risk.
6. Arrest Prospects by Jurisdiction
6.1 United Arab Emirates
6.1.1 Existing UAE Enforcement Infrastructure
TSL is well positioned to pursue arrest of M/V Volga Spirit in the UAE, given the existing enforcement infrastructure established during the successful recovery of AED 53,400,000 from Korinthian DMCC's accounts.
TSL already holds an enforcement order in the Dubai Court of First Instance (Case No. 1893/2024, granted 20 November 2024). This order was obtained following the recognition of the LCIA Award in the UAE courts and has been the basis for the precautionary attachment and subsequent execution against Korinthian DMCC's accounts and receivables at Emirates Gulf Commercial Bank PJSC.
Al-Rashid Hatem & Associates ("ARH") are already instructed as local counsel in the UAE and are thoroughly familiar with the matter. The relevant contacts at ARH are:
•  Tariq Al-Rashid, Managing Partner
•  Leila Hatem, Partner
•  Office 1802, Emirates Financial Towers (South Tower), DIFC, Dubai
ARH's existing engagement and familiarity with the case, the parties, and the factual matrix represents a significant advantage in terms of speed and efficiency. The precautionary attachment mechanism has already been successfully deployed in this matter, demonstrating that the UAE courts are receptive to enforcement of the Award.
6.1.2 UAE Maritime Law — Vessel Arrest
Under UAE Federal Law No. 26 of 1981 (the UAE Maritime Code) and related provisions of the UAE Civil Procedure Code, vessels may be arrested in UAE waters to satisfy maritime claims and to enforce court judgments. The UAE is a signatory to the 1952 International Convention Relating to the Arrest of Sea-Going Ships, which provides a framework for the arrest of vessels in respect of specified maritime claims.
Several procedural and jurisdictional points require analysis:
Territorial jurisdiction — Fujairah versus Dubai. Fujairah is a separate Emirate from Dubai and falls under the jurisdiction of the Fujairah Court of First Instance (onshore). The DIFC courts — which have their own separate jurisdiction within the Emirate of Dubai — do not exercise territorial jurisdiction over Fujairah. The existing enforcement order from the Dubai Court of First Instance (Case No. 1893/2024) was obtained in the Dubai onshore courts. A critical threshold question is whether this Dubai enforcement order can be executed directly in Fujairah — for example, through the inter-Emirate enforcement mechanisms available under UAE federal law — or whether a fresh arrest or execution application must be filed in the Fujairah courts.
ARH has advised on a preliminary basis that the Dubai enforcement order may need to be domesticated in Fujairah through the federal court system, but that this process can be expedited. An alternative route would be to file a fresh precautionary arrest application directly in the Fujairah Court of First Instance, relying on the underlying Award and the Dubai recognition order as the basis for the claim. We are awaiting ARH's detailed analysis on the most efficient procedural route and the likely timeline for each option.
Arrest against an SPV vessel — beneficial ownership and veil-piercing. A central issue is whether arrest can be obtained against a vessel owned by Dnepr Shipholding Inc. (a BVI SPV) on the basis of the enforcement judgment against KMH. The vessel is not registered in KMH's name; it is registered in the name of Dnepr. KMH is likely to argue that the vessel cannot be seized to satisfy a judgment against a different legal entity.
UAE law's approach to piercing the corporate veil in the maritime arrest context is less well developed than in common law jurisdictions such as England or Singapore. However, there are a number of arguments that may be advanced to overcome this obstacle:
(a) Under Article 115 of the UAE Maritime Code, a vessel may be arrested if the debtor is the owner, charterer, or operator of the vessel. KMH was the disponent owner and operator of M/V Volga Spirit throughout the charter period, and the tribunal's Award confirmed KMH's status as such.
(b) UAE courts have shown a willingness in certain commercial contexts to look behind the corporate form where the SPV is a sham or where it has been used as a vehicle to frustrate creditors. The single-purpose nature of Dnepr, its complete absence of independent operations, and the unity of control between Dnepr and KMH support such an argument.
(c) The WFO asset disclosure provided by KMH to the English Commercial Court identifies the vessel as an asset of KMH. This disclosure can be deployed as evidence that KMH itself regards the vessel as its own asset.
(d) The Hartwell Pemberton asset tracing reports confirm the unbroken chain of beneficial ownership from the vessel through Dnepr and Oceangate to KMH and the Volkov family.
We have asked ARH to provide a detailed analysis of the veil-piercing and beneficial ownership arguments under UAE law, with specific reference to the available UAE and GCC case law on maritime arrest of SPV-owned vessels.
Flag state considerations. The Cyprus flag of the vessel does not impede arrest in UAE waters. The UAE Maritime Code permits the arrest of foreign-flagged vessels in UAE territorial waters, subject to the applicable procedural requirements. No notification to or consent from the Cyprus flag-state authorities is required for the arrest itself, although Cyprus maritime law and the vessel's Cyprus registration may become relevant in connection with any application to de-register or re-flag the vessel.
6.1.3 Practical Considerations — UAE
Several practical considerations are relevant to the timing and execution of an arrest in Fujairah:
Speed of arrest. Based on ARH's experience and the general practice in UAE courts, the Fujairah port authority and local court are capable of executing a vessel arrest within 24–48 hours of a valid court order. The court process for obtaining the arrest order itself may take an additional 1–3 days, depending on the complexity of the application and the court schedule. If arrest papers are pre-positioned and ready for filing, the total time from decision to arrest to actual arrest of the vessel could be as short as 48–72 hours.
Local counsel in Fujairah. ARH is based in the DIFC (Dubai) and is licensed to practise in the DIFC courts and the Dubai onshore courts. For proceedings in the Fujairah onshore courts, ARH may need to either (a) obtain admission to appear in the Fujairah courts, (b) instruct a Fujairah-based co-counsel to file and argue the application on the ground, or (c) apply through the Dubai enforcement order using the federal inter-Emirate enforcement framework. ARH has indicated that they have established relationships with Fujairah-based practitioners and can mobilise a local filing team on short notice.
Risk of departure. The most significant practical risk is that the vessel departs Fujairah anchorage before the arrest can be perfected. Fujairah anchorage is an open roadstead, and vessels at anchor may depart at any time without notice to the port authority (unlike vessels at berth, which are subject to port clearance procedures). To mitigate this risk, we recommend the following measures:
(a) Place the vessel on a "watch list" with commercial AIS tracking providers and Northcape Maritime Advisory Ltd. for immediate notification (via SMS and email) of any departure from Fujairah anchorage or significant change in the vessel's status;
(b) Pre-position arrest papers with ARH (and Fujairah local counsel, if applicable) so that filing can be effected within hours of a decision to proceed; and
(c) Consider approaching the Fujairah port authority (through local counsel) to request notification of any clearance application by the vessel, although the feasibility and propriety of this step will need to be assessed by ARH in light of local practice.
Judicial sale process in the UAE. If arrest is obtained, the judicial sale of the vessel will be administered through the UAE execution judge, with the auction conducted by the court in accordance with the procedures set out in the UAE Civil Procedure Code. The typical timeline from arrest to completed judicial sale and receipt of proceeds is 3–6 months, depending on the complexity of any challenges to the arrest, the number of intervening claimants, and the court's auction schedule. The sale will be by public auction, and the court will set a reserve price, typically based on a court-appointed valuer's assessment.
Priority of claims. Any existing maritime liens — including crew wages, bunker supplier claims, salvage claims, and port authority charges — would have priority over TSL's judgment claim in the distribution of the judicial sale proceeds. It is therefore important to assess the likely quantum of any priority claims before the arrest. We are not presently aware of any outstanding maritime liens against M/V Volga Spirit, but this information should be verified through a lien search with a maritime lien reporting agency and through inquiries with the vessel's P&I club (if identifiable).
6.2 Alternative Jurisdictions
While the UAE (Fujairah) is the preferred jurisdiction for arrest given the vessel's current location and TSL's existing enforcement infrastructure, the enforcement team should maintain preparedness for arrest in alternative jurisdictions in the event that the vessel departs Fujairah and calls at a port in another jurisdiction where arrest is feasible.
6.2.1 Singapore.  Singapore has been the most successful enforcement jurisdiction to date, with a total recovery of approximately £36,780,000 comprising both the garnishee order against Pinnacle Bank (Singapore) Ltd. and the judicial sale of M/V Crimson Horizon.
The Singapore High Court (Admiralty Jurisdiction) Act (Cap. 123) provides for the arrest of vessels in Singapore waters, including the arrest of "associated ships" — i.e., ships that are beneficially owned by a person who is liable in personam on the relevant maritime claim. The associated ship doctrine in Singapore is well developed and would provide a strong legal basis for arrest of M/V Volga Spirit, given the ownership chain linking the vessel to KMH through Dnepr and Oceangate.
Our Singapore local counsel, Straits Meridian LLP (David Teo Wei Lin, Partner; Priya Subramaniam, Senior Associate; 1 Raffles Place, #44-01 One Raffles Place Tower 2, Singapore 048616), are experienced in the matter and have demonstrated their capability through the successful arrest and judicial sale of M/V Crimson Horizon.
However, M/V Volga Spirit has been systematically avoiding Singapore waters since the commencement of enforcement proceedings. Given KMH's awareness of the Singapore enforcement proceedings and the successful arrest of M/V Crimson Horizon in Singapore, the probability of a voluntary port call in Singapore is assessed as low. We do not recommend diverting resources to prepare Singapore arrest papers at this stage but would recommend doing so immediately if AIS tracking indicates any movement toward the Strait of Malacca or Southeast Asian waters.
6.2.2 India.  The vessel's trading pattern includes Indian port calls, with recent visits to Mundra and Kandla on the west coast of India. India therefore represents a viable alternative jurisdiction for arrest if the vessel returns to Indian waters.
India is a signatory to the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, subject to the reciprocity and commercial reservations. The Admiralty (Jurisdiction and Settlement of Maritime Claims) Act, 2017 permits the arrest of vessels in Indian territorial waters in respect of maritime claims, including claims arising from charter-party disputes.
However, enforcement of the LCIA Award in India would first require recognition of the Award by an Indian court under Part II of the Indian Arbitration and Conciliation Act, 1996. This adds a layer of complexity and time that is not present in the UAE (where the Award has already been recognised) or Singapore (where enforcement orders are already in place). The recognition process in India can take several months and may be subject to challenge on public policy or other grounds, although in practice Indian courts have been generally receptive to the enforcement of London-seated arbitral awards.
We have not yet instructed Indian local counsel on this matter. If the vessel moves toward Indian waters, we would recommend identifying suitable Indian counsel through the firm's professional network and conducting a rapid cost-benefit analysis of Indian enforcement and arrest, taking into account the additional jurisdictional layer, the likely timeframe, and the costs involved.
6.2.3 Other Gulf Ports
Other potential ports of call in the Arabian Gulf and wider Middle East region include:
•  Oman: Sohar and Muscat (Oman is a New York Convention signatory)
•  Saudi Arabia: Dammam and Jeddah (Saudi Arabia acceded to the New York Convention in 1994)
•  Bahrain: Mina Salman and Khalifa Bin Salman Port (Bahrain is a New York Convention signatory)
Enforcement and arrest procedures in these jurisdictions are less tested in the context of London-seated LCIA awards than in the UAE, and may involve additional procedural complexity, delay, and uncertainty. In particular, the recognition and enforcement of foreign arbitral awards in the courts of Saudi Arabia and Oman has been the subject of mixed jurisprudence, and the procedural requirements for vessel arrest in these jurisdictions are less well documented in the publicly available case law.
For these reasons, the UAE (Fujairah) remains the preferred option for arrest. The alternative Gulf jurisdictions should be maintained on a contingency basis only, and arrest papers should not be prepared for these jurisdictions unless the vessel is positively identified as calling at a port in one of them.
6.2.4 Cyprus.  M/V Volga Spirit is Cyprus-flagged, and Cyprus could exercise flag-state jurisdiction over the vessel. TSL already holds an enforcement order from the Nicosia District Court (Case No. 2247/2024, granted 30 September 2024), and local counsel Kyprianos Makrides & Partners (Andreas Kyprianos, Senior Partner; Nadia Makrides, Partner; 15 Grivas Digenis Avenue, Nicosia 1066, Cyprus) are fully instructed and familiar with the case.
Arrest of the vessel in Cypriot waters could be pursued on the basis of the existing Nicosia enforcement order, and Cyprus's admiralty law provides a well-established framework for vessel arrest. However, two practical obstacles limit the utility of this option:
(a) The vessel has not been calling at Cypriot ports and there is no indication that it intends to do so. KMH's pattern of avoiding enforcement jurisdictions makes a voluntary call at a Cypriot port unlikely.
(b) KMH may seek to re-flag the vessel from Cyprus to another registry — for example, a convenience flag jurisdiction with limited enforcement cooperation — in order to sever the Cyprus flag-state nexus. The protective measures recommended in Section 9, including notification to the Cyprus Registrar of Ships, are designed to guard against this risk.
Cyprus remains a viable contingency option, and Kyprianos Makrides & Partners should be kept abreast of developments so that arrest papers can be prepared on short notice if the vessel is identified in or near Cypriot waters.
6.3 Worldwide Freezing Order — Relevance to Arrest
The WFO granted by Mr. Justice Ashworth in the Commercial Court (CL-2024-000487) on 16 July 2024 and continued on 30 July 2024 prohibits KMH from disposing of, dealing with, or diminishing the value of any of its assets worldwide up to the value of £108,600,000. The vessel, as an asset of KMH held through the Dnepr/Oceangate corporate chain, is subject to the WFO.
The WFO serves an important protective function in the enforcement campaign: any attempt by KMH to sell, re-flag, transfer, mortgage, or otherwise encumber the vessel would constitute a breach of the WFO and could result in contempt proceedings in the English Commercial Court. The contempt remedy is in personam and could be enforced against the directors of KMH (including Sergei Volkov, who is within the personal jurisdiction of the English court by virtue of his directorship of a Cypriot company with English law-governed obligations) as well as against third parties who knowingly assist in a breach of the order (the Chabra jurisdiction).
However, the WFO does not itself effect arrest of the vessel. The WFO is an in personam order directed at KMH and does not create any proprietary interest in the vessel or any in rem right enforceable against the vessel itself. A separate in rem or execution proceeding is required in the jurisdiction where the vessel is physically located in order to arrest the vessel, restrain her from departing, and ultimately achieve a judicial sale. The WFO and the arrest proceedings are therefore complementary mechanisms that should be deployed in parallel.
It should also be noted that the WFO is subject to the usual proviso permitting KMH to deal with its assets in the ordinary course of business up to specified limits. The vessel's continued commercial trading does not, in itself, constitute a breach of the WFO, provided that the vessel is not disposed of or dealt with in a manner that diminishes the value of KMH's asset base.
7. Estimated Vessel Value
7.1 Northcape Maritime Advisory Ltd. Assessment
Northcape Maritime Advisory Ltd. (Captain Ian Forsyth, Managing Director) has served as TSL's maritime advisory consultant throughout the enforcement campaign and previously provided vessel valuations for enforcement and arrest purposes in the Singapore proceedings involving M/V Crimson Horizon. Northcape's valuation of M/V Crimson Horizon proved to be materially accurate — the vessel ultimately sold at judicial auction for USD $22,800,000, which was within the range indicated by Northcape's pre-arrest valuation.
A formal desktop valuation of M/V Volga Spirit has been requested from Northcape and is expected within 5–7 business days. In the interim, Captain Forsyth has provided preliminary guidance based on comparable Panamax bulk carrier market data, recent sale and purchase transactions, and the vessel's known characteristics:
The sterling equivalents are based on the prevailing USD/GBP exchange rate of approximately 0.804 and are subject to fluctuation.
By way of comparison, the actual forced sale price achieved for M/V Crimson Horizon (a Handymax Bulk Carrier of 37,500 DWT) at judicial auction in Singapore was USD $22,800,000. This is broadly consistent with market expectations for that class of vessel at the time of sale. M/V Volga Spirit, as a Panamax of 76,400 DWT — approximately twice the deadweight tonnage of M/V Crimson Horizon — would be expected to achieve a meaningfully higher price, subject to the vessel's age, classification status, condition, and the prevailing state of the dry bulk freight and second-hand tonnage markets at the time of sale.
Preliminary comparable vessel data sourced by Northcape from the Panamax bulk carrier market is set out at Appendix E. The data indicates that Panamax bulk carriers in the 70,000–80,000 DWT range have been transacting in the range of USD $24,000,000 – $35,000,000 over the past twelve months, depending on age and condition. The formal valuation from Northcape will include a more granular analysis based on the vessel's specific age, survey history, and classification status.
We recommend instructing Northcape to provide the formal desktop valuation on an expedited basis, including consideration of the vessel's age, classification status, and recent survey history, in order to support the arrest application and to provide the client with an informed assessment of the likely recovery.
7.2 Sufficiency of Vessel Value to Satisfy Outstanding Balance
The outstanding balance owed by KMH as of 15 March 2025 is estimated at approximately £15,617,726.03 (inclusive of post-award interest).
Based on the preliminary valuation guidance from Northcape, even at the lower end of the forced sale estimate — approximately £17,700,000 — the vessel's value would be sufficient to satisfy the outstanding balance in full, subject to deductions for:
(a) Arrest and judicial sale costs, including court fees, auctioneer's commission, vessel custodian costs during the arrest period, and associated legal and administrative expenses. These costs are typically in the range of 5–10% of the sale proceeds in the UAE;
(b) Priority maritime liens (if any), including crew wages, bunker supplier claims, and port authority charges. These claims rank ahead of TSL's judgment claim in the distribution of proceeds; and
(c) Legal costs of the arrest proceedings, including local counsel fees and the firm's own costs.
If the vessel achieves a price at the higher end of the forced sale estimate — approximately £20,900,000 — TSL would recover the full outstanding balance with a comfortable margin, and a surplus would exist. Under applicable UAE law, any surplus remaining after satisfaction of all claims against the vessel would be returned to the vessel's registered owner (Dnepr Shipholding Inc.) or to the party otherwise entitled thereto.
Taking the midpoint of the forced sale estimate (approximately £19,300,000) and deducting estimated costs and priority claims of approximately £1,500,000 – £2,000,000, the net recovery to TSL would be in the range of approximately £17,300,000 – £17,800,000, which would be more than sufficient to satisfy the outstanding balance of £15,617,726.03.
The analysis confirms that the vessel represents a highly attractive enforcement target and that arrest and judicial sale would, on reasonable assumptions, result in full satisfaction of the remaining Award balance.
8. Procedural Considerations and Risks
8.1 Veil-Piercing / Beneficial Ownership Challenge
As noted above, KMH is likely to raise the defence that M/V Volga Spirit is owned by Dnepr Shipholding Inc. — a separate legal entity incorporated in the BVI — and that the vessel therefore cannot be seized to satisfy a judgment rendered against KMH. This is the standard defence employed by judgment debtors who hold assets through SPV structures, and it is to be expected.
The counter-arguments available to TSL are substantial:
(a) Dnepr is a single-purpose vehicle with no independent operations. It was incorporated for the sole purpose of holding title to vessels in the KMH fleet. It has no employees, no independent management, and no commercial activities beyond its function as a registered owner. Its affairs are directed entirely by KMH and the Volkov family.
(b) The tribunal's Award confirmed KMH's status as disponent owner and beneficial controller of the fleet. The Award contains findings of fact regarding KMH's operational control over the vessels, including M/V Volga Spirit, which are res judicata as between the parties.
(c) The WFO asset disclosure identifies the vessel as an asset of KMH. KMH was required by the terms of the WFO to disclose all of its assets worldwide. The disclosure provided by KMH identified M/V Volga Spirit — held through Dnepr and Oceangate — as an asset of KMH. KMH cannot now claim in enforcement proceedings that the vessel is not its asset when it has previously disclosed it as such to the English Commercial Court.
(d) The Hartwell Pemberton asset tracing reports provide detailed documentary and corporate registry evidence confirming the unbroken chain of beneficial ownership from the vessel through Dnepr and Oceangate to KMH and the Volkov family.
(e) The alter ego / single economic entity doctrine, applicable in various forms across the relevant jurisdictions, supports treating Dnepr and KMH as a single economic unit for enforcement purposes, given the complete absence of separation between the two entities in terms of management, control, and economic substance.
Risk assessment: The veil-piercing argument carries moderate risk. The argument is more favourable in some jurisdictions than others. In Singapore, the associated ship doctrine and the well-developed jurisprudence on beneficial ownership in the admiralty context provide a strong basis for overcoming the corporate veil. In the UAE, the position is less certain, and the outcome may depend on the specific approach of the Fujairah court to veil-piercing in the maritime arrest context. We have asked ARH to provide their assessment of the risk and to identify any UAE or GCC case law that supports TSL's position.
8.2 Oceangate Share Sale Complications
The forced sale of the shares of Oceangate Ventures Ltd. in the Cyprus enforcement proceedings (October–November 2024) introduces a complication in the ownership chain between KMH and Dnepr. If the Oceangate shares have been acquired by a third party, the direct corporate link between KMH and Dnepr — through which KMH controlled the vessel — may have been severed.
The following questions require urgent clarification through Kyprianos Makrides & Partners and, if necessary, through direct inquiry with the Cyprus Registrar of Companies:
(a) Identity of the purchaser of the Oceangate shares. Who acquired the Oceangate shares at the forced sale? Was the purchaser TSL itself, a TSL-affiliated entity, or an independent third-party buyer?
(b) Scope of the Oceangate share sale. Did the forced sale encompass the entirety of the issued share capital of Oceangate, or only a portion? If only a portion was sold, KMH may retain some interest in Oceangate and, through it, in Dnepr.
(c) Status of Dnepr's shares. Were Dnepr's shares held directly by Oceangate at the time of the forced sale, or had they been transferred to another entity — whether by KMH in anticipation of the sale or by Oceangate itself — prior to the execution? Any such transfer in breach of the WFO would be subject to challenge.
(d) TSL's indirect interest. If TSL or a TSL-friendly purchaser acquired the Oceangate shares, TSL may now hold indirect ownership of Dnepr Shipholding Inc. and, through Dnepr, of M/V Volga Spirit itself. This would fundamentally change the enforcement calculus, as discussed below.
If the Oceangate share analysis confirms that TSL (or a TSL-friendly entity) now controls Oceangate, then TSL may be able to exercise shareholder control over Dnepr and direct the sale of M/V Volga Spirit on the open market. An open-market sale would likely achieve a significantly higher price than a judicial sale, would avoid the costs and delays associated with arrest proceedings, and would avoid the legal risks associated with the veil-piercing argument. This would be a significantly simpler and faster route to recovery and should be explored as a priority.
Conversely, if a third-party purchaser acquired the Oceangate shares, the enforcement team will need to assess whether the purchaser is cooperative or hostile, whether the purchase disrupts TSL's ability to assert beneficial ownership arguments against Dnepr, and whether any additional steps are required to protect TSL's enforcement interests.
8.3 Re-flagging and Transfer Risk
As noted in Section 5.2, there is a material risk that KMH may attempt to re-flag M/V *Volga Spirit* from Cyprus to another registry — for example, a convenience flag jurisdiction such as Palau, Cameroon, or Tanzania, which have limited enforcement cooperation with the jurisdictions where TSL holds enforcement orders. Re-flagging would sever the vessel's connection to the Cyprus flag-state jurisdiction and could make arrest more difficult in certain jurisdictions where flag-state jurisdiction is a factor.
KMH may also attempt to transfer Dnepr's shares or the vessel itself to a Volkov-family-controlled entity outside the established enforcement chain. Such a transfer would be designed to place the vessel beyond the reach of enforcement orders directed at KMH.
Any such action would constitute a breach of the WFO and could give rise to contempt proceedings in the English Commercial Court. However, as noted above, the practical deterrent effect of the WFO depends on the willingness of the relevant individuals to comply with an English court order, and the Volkov family has demonstrated a pattern of aggressive asset protection that raises concerns about future compliance.
To mitigate the re-flagging and transfer risk, we recommend the following immediate measures:
(a) Monitor the Cyprus Ship Registry (through Kyprianos Makrides & Partners) for any application to de-register the vessel, transfer the vessel's registration, or change the registered owner;
(b) Maintain the vessel on active AIS monitoring for any flag changes, which would typically be reflected in the vessel's AIS transmission data;
(c) Notify the Cyprus Registrar of Ships of the pending enforcement and the WFO, and request that the Registrar notify TSL's counsel of any application to delete or transfer the vessel's registration. The Cyprus Registrar has cooperated with similar requests in other enforcement matters and is generally receptive to orders of the Nicosia District Court; and
(d) Consider applying to the Nicosia District Court (through Kyprianos Makrides & Partners) for an order restraining the de-registration or re-flagging of the vessel, which could be served directly on the Cyprus Registrar of Ships.
8.4 Crew and Operational Claims
If M/V Volga Spirit is arrested, the distribution of the judicial sale proceeds will be subject to the priority of maritime liens under the applicable law. Maritime liens that typically rank ahead of a judgment creditor's claim include:
(a) Crew wages and repatriation costs, which enjoy the highest priority under virtually all maritime lien regimes;
(b) Salvage claims, if any;
(c) Port authority charges and dues, including pilotage, towage, and berth fees;
(d) Bunker supplier claims, which may or may not enjoy lien status depending on the applicable law (the position varies between jurisdictions, and the UAE Maritime Code provides for certain supplier liens); and
(e) Damage claims arising from collision or pollution, if any.
We are not presently aware of any outstanding maritime liens against M/V Volga Spirit. However, this information should be verified before the arrest through the following steps: (a) conducting a maritime lien search through a specialist maritime lien reporting agency; (b) making inquiries with the vessel's P&I club (if identifiable from public records or the tribunal file); and (c) requesting ARH and Northcape to make inquiries through their respective local contacts and industry networks.
The quantum of any priority claims will affect the net recovery to TSL. On the assumption that the vessel is currently operational and that crew wages and bunker suppliers are being paid in the ordinary course (there is no information to suggest otherwise), the likely quantum of priority claims is expected to be modest — estimated at no more than USD $500,000 – $1,000,000 (approximately £400,000 – £800,000). However, if the vessel has been operating with deferred maintenance, outstanding crew wages, or unpaid bunker invoices, the priority claims could be higher. This risk should be assessed and factored into the recovery analysis.
8.5 Time and Cost Considerations
The estimated costs and timeline for the UAE arrest proceedings are as follows:
Legal costs:
•  Al-Rashid Hatem & Associates (local counsel fees): AED 350,000 – AED 500,000 (approximately £74,000 – £106,000), in addition to ARH's existing engagement fees for the Dubai enforcement. This estimate covers the preparation and filing of arrest papers, the arrest application hearing, management of the arrest and vessel custody, the judicial sale process, and the distribution of proceeds. It does not include any contested proceedings in the event that KMH challenges the arrest.
•  Fujairah local co-counsel (if required): AED 50,000 – AED 100,000 (approximately £11,000 – £21,000), if a Fujairah-based practitioner is needed for filings in the Fujairah Court of First Instance.
•  Disbursements: Court fees, Sheriff's costs, vessel custodian costs during the arrest period (including port authority charges, crew maintenance, and insurance), and auctioneer's commission. These are difficult to estimate precisely in advance but are typically in the range of 5–10% of the vessel's sale price. On a sale price of USD $24,000,000 (midpoint estimate), disbursements could be in the range of USD $1,200,000 – $2,400,000 (approximately £965,000 – £1,930,000).
Timeline:
•  Pre-positioning of arrest papers: 5–10 business days from instruction.
•  Filing and arrest: 2–5 business days from filing, assuming no prior departure of the vessel.
•  Arrest to judicial sale: 3–6 months, depending on the complexity of any challenges, the number of intervening claims, and the court's auction schedule.
•  Sale to receipt of proceeds: 4–8 weeks following the auction, to allow for completion of the sale, transfer of title, and distribution of proceeds.
Fee cap considerations. The engagement letter between the firm and TSL provides for a fee cap of £4,200,000 in respect of Sutherland & Carrington LLP's ("C&H") fees for the enforcement phase. Fees billed to date total £3,870,000, leaving a remaining balance under the cap of approximately £330,000. The arrest proceedings would likely require additional C&H time for coordination with local counsel, preparation of arrest documentation, management of the arrest and sale process, and client reporting. This time is likely to approach or exceed the remaining cap.
A discussion with the client regarding the fee cap and the potential need for an amendment may therefore be necessary. It should be noted that the fee cap applies to C&H's professional fees only; local counsel fees and disbursements fall outside the cap and are billed to the client as pass-through costs. The arrest strategy should be presented to the client with full transparency regarding the cost implications and the potential need to revisit the fee arrangement.
9. Recommended Course of Action
9.1 Immediate Steps
The following steps are recommended for immediate action:
1.  Instruct Northcape Maritime Advisory Ltd. to provide a formal desktop valuation of M/V Volga Spirit on both a fair market value and forced sale value basis. The valuation should include consideration of the vessel's age, classification status, recent survey history, and prevailing market conditions for Panamax bulk carriers in the 70,000–80,000 DWT range. Request expedited delivery within 5–7 business days. Contact: Captain Ian Forsyth, Managing Director, Northcape Maritime Advisory Ltd., 3 Thomas More Square, London E1W 1WY.
2.  Place the vessel on active AIS monitoring with immediate alerts (SMS and email) for departure from Fujairah anchorage, any change in the vessel's flag state, and any significant change in the vessel's AIS-reported status. Coordinate monitoring with Northcape and the firm's internal enforcement tracking systems. Ensure that alerts are routed to the responsible partner, lead associate, and working associate simultaneously.
3.  Instruct Al-Rashid Hatem & Associates to prepare arrest papers on a pre-positioned basis for filing in the Fujairah Court of First Instance upon short notice. Request ARH to provide a detailed analysis of: (a) the most efficient procedural route for arrest in Fujairah (including whether the existing Dubai enforcement order can be executed directly in Fujairah or whether a fresh application is required); (b) the beneficial ownership and veil-piercing arguments under UAE law; (c) the likely timeline and costs; and (d) the identity and availability of Fujairah-based co-counsel if needed. Contact: Tariq Al-Rashid, Managing Partner; Leila Hatem, Partner.
4.  Contact the Cyprus Registrar of Ships (through Kyprianos Makrides & Partners) to flag the vessel's Cyprus registration and request notification of any application to de-register, re-flag, or transfer the vessel's registration. Explore the possibility of obtaining an order from the Nicosia District Court restraining any de-registration or re-flagging pending enforcement. Contact: Andreas Kyprianos, Senior Partner; Nadia Makrides, Partner.
5.  Clarify the status of the Oceangate Ventures Ltd. shares following the Cyprus forced sale proceedings. Determine: (a) the identity of the purchaser of the Oceangate shares; (b) whether the purchaser acquired indirect ownership of Dnepr Shipholding Inc. and, through it, M/V Volga Spirit; and (c) whether TSL or a TSL-friendly party now controls Oceangate. Coordinate this inquiry through Kyprianos Makrides & Partners, with the assistance of Hartwell Pemberton LLP if necessary. This inquiry should be treated as the highest priority, as its outcome may determine whether arrest proceedings are necessary at all.
9.2 Contingent Steps
The following steps should be taken on a contingent basis, depending on the outcomes of the immediate steps and developments in the vessel's position:
6.  If the Oceangate share analysis confirms TSL's indirect control over Dnepr, explore directing Dnepr (as registered owner) to sell M/V Volga Spirit on the open market through a reputable shipbroker. An open-market sale would likely achieve a higher price than a judicial sale (estimated USD $28,000,000 – $32,000,000 at fair market value versus USD $22,000,000 – $26,000,000 at forced sale value) and would avoid the costs, delays, and legal risks associated with arrest proceedings. The firm should advise the client on the mechanics of exercising shareholder control over Dnepr through Oceangate, including any BVI corporate law requirements and the need for BVI legal advice.
7.  If the vessel departs Fujairah for Singapore, instruct Straits Meridian LLP to prepare arrest papers for Singapore on an expedited basis. The associated ship doctrine in Singapore provides a strong legal basis for arrest, and Straits Meridian LLP have demonstrated their capability through the successful arrest and sale of M/V Crimson Horizon. Contact: David Teo Wei Lin, Partner; Priya Subramaniam, Senior Associate.
8.  If the vessel calls at an Indian port, conduct a rapid cost-benefit analysis of Indian enforcement and arrest, including the timeline and cost of recognising the Award in an Indian court, the applicable Indian admiralty law and procedure, and the availability and cost of suitable Indian local counsel. Identify Indian local counsel through the firm's professional network as a precautionary measure.
9.3 Fee and Budget Discussion
9.  Raise the vessel arrest strategy with the client (Nikolaos Papadimitriou, Chairman & CEO; Ioanna Christodoulou, General Counsel) at the next scheduled status update. The discussion should cover: (a) the enforcement rationale for arrest of M/V Volga Spirit; (b) the estimated vessel value and likely net recovery; (c) the cost estimates for the arrest proceedings; (d) the proximity to the C&H fee cap and the potential need for an amendment; and (e) the Oceangate share analysis and the possibility of an alternative route to recovery that avoids arrest.
10.  If the client approves the arrest strategy, prepare a supplemental fee estimate for the arrest phase, distinguishing between C&H professional fees (subject to the fee cap) and local counsel fees and di