Sanctions Evasion Reference

Keystone Shipping: Russian bitumen via sham sales chains

An Estonian court convicted a trading company and its board member in 2026 for buying Russian bitumen through a chain of sham sales and forged Kazakh and Uzbek export papers, and for buying from a state-owned Gazprom Neft subsidiary.

period

2023–2026

outcome

Criminal conviction

parties

Keystone Shipping OÜ; Andrey Kolesnikov

programmes

Russian Federation

reviewed

2026-09-20

Cite this page
APA 7
Sanctions Evasion Reference. (2026, September 20). Keystone Shipping: Russian bitumen via sham sales chains. https://sanctionsevasion.org/cases/keystone-shipping-estonia-2026/
Chicago
Sanctions Evasion Reference. “Keystone Shipping: Russian bitumen via sham sales chains.” Last reviewed September 20, 2026. https://sanctionsevasion.org/cases/keystone-shipping-estonia-2026/.
BibTeX
@misc{ser-cases-keystone-shipping-estonia-2026,
  author = {{Sanctions Evasion Reference}},
  title  = {Keystone Shipping: Russian bitumen via sham sales chains},
  year   = {2026},
  note   = {Last reviewed 2026-09-20},
  url    = {https://sanctionsevasion.org/cases/keystone-shipping-estonia-2026/}
}

The date is when this page was last reviewed, not when it was first published.

Penalties imposed

AuthorityDate AmountNote
Harju County Court (Estonia) 2026-01-21 €250,000 Fine on the company. The board member was fined 250 daily rates of €130 (€32,500, with one day of detention credited), and €179,200 of proceeds from selling the seized bitumen was confiscated. Plea-agreement procedure.

An EU court judgment that lays out an import scheme in unusual detail, because the defendants agreed the facts. It is in Estonian and the translations here are this site’s. The judgment anonymises everyone except the two defendants, so this page names only them.

What the court found

Keystone Shipping OÜ, a Tallinn company, bought bitumen made in Russia, at least in 2023, from four Russian companies. The court records that the arrangement was meant to move Russian bitumen into Europe and other countries, and that Andrey Kolesnikov, the company’s only board member from 2017 until January 2025, set it up with a deputy and a legal adviser.

The volumes in the judgment are large. Between June and October 2023 the company bought about 52 million kilograms from one Russian company alone, exported from Russia in the same period and imported into Latvia, Germany, Peru, Mexico and Panama. From another Russian supplier, a subsidiary of Gazprom Neft, it bought about 11 million kilograms, shipped to South Africa, Uruguay and Peru.

The sham chains

To hide that the seller was a Russian company and the buyer was Keystone, the court says a “chain of sham transactions” was built in which the bitumen appeared to pass between foreign companies.

  • In one chain, a Russian company appeared to sell to a Georgian company, which appeared to sell to a Hong Kong company, which appeared to sell to Keystone.
  • In another, goods appeared to pass from the Georgian company to the Hong Kong company, to a Kazakh company, and on to a German one.

The judgment says the contracts in the names of the foreign companies were signed by a Keystone employee, who “added the electronic signature of the relevant company’s manager and the company’s stamp” to each.

The customs papers

On 29 December 2023 the ship M/S Valday arrived at Muuga port from St Petersburg carrying bitumen. The entry declaration filed that day named Keystone as consignee and Uzbek and Kazakh companies as consignors. The court found that employees of a Russian supplier gave the customs declarant, who passed them to the Estonian Tax and Customs Board, falsified Kazakh and Uzbek export declarations, origin certificates and invoices. It also found that a made-up reply letter, apparently from the Kazakh company, was drafted to explain why a Kazakh export declaration had become invalid, so as to hide that the bitumen came from Russia. The legal adviser, whose role was to monitor sanctions, took part in preparing it, the judgment says.

The rules broken

The court applied two provisions of Council Regulation 833/2014:

  • Article 3i, which since 26 February 2023 has banned buying, importing or transferring listed goods originating in or exported from Russia. The judgment notes that bitumen products under customs headings 2713 and 2715 were among them, with a wind-down for contracts signed earlier that ended on 27 May 2023.
  • Article 5aa(1)(b), which bans transactions with an entity outside the EU that is more than 50 per cent owned by a listed one. The court found that one supplier was more than 97 per cent owned by Gazprom Neft, which is on that annex. This is the EU form of the ownership test explained on the 50 percent rule page.

The outcome

Under a plea agreement, on 21 January 2026 the Harju County Court fined the company €250,000 and Kolesnikov €32,110 after crediting a day in detention. It confiscated €179,200 held from the sale of bitumen and ordered the company to pay about €61,900 in costs, most of it storing and testing the seized bitumen.

What the record shows

  • The documents and the ship disagreed. The entry declaration named Uzbek and Kazakh consignors, and the vessel had sailed from St Petersburg.
  • The person tasked with monitoring sanctions was part of it. The judgment describes the legal adviser’s job as watching the sanctions and says he also coordinated the chain with the Russian side.
  • The ownership test reached a supplier. The finding on the Gazprom Neft subsidiary rests on ownership, not on the subsidiary’s own name appearing on a list.

See also third-country transshipment, cargo origin blending and front companies, and for the same jurisdictions in trade statistics, Kazakhstan, Georgia and Hong Kong.

Techniques this case demonstrates

Programmes and jurisdictions in this case

  • Russia sanctions — Measures imposed from 2014 and greatly expanded from 2022, combining designations, sectoral restrictions, export controls and a price cap on seaborne oil.
  • Georgia — A transit economy on the Black Sea whose trade and re-export figures feature in the same commodity-code analysis applied to other neighbouring states.
  • Hong Kong — A major financial and trading centre whose company formation regime, banking sector and re-export role place it in a large share of published corporate concealment cases.
  • Kazakhstan — A customs union member with extensive land connections to Russia and China, prominent in trade-statistics analysis of re-routed goods since 2022.

Enforcement documents and sources

  1. Judgment in criminal case 1-25-7117, Harju County Court (Harju Maakohus). Harju County Court, Estonia, 2026. Case 1-25-7117, 21 January 2026, plea agreement procedure (in Estonian).
  2. Council Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine. Council of the European Union, 2014. Articles 3i and 5aa as inserted in 2022 and 2023.

All enforcement cases