- Russia has stolen over 4 million tonnes of Ukrainian grain across all four occupied regions (estimated $580 million), operating through state monopoly entities - the DZO in Zaporizhzhia and the Kherson Grain Company - that control inputs, outputs, and prices, ensuring permanent farmer dependency on occupation structures.
- The DZO's harvest paradox - revenue falling 59% in 2024 despite a 9.8% larger harvest - is assessed as deliberate profit concealment via artificial accounting, with real value extracted through shadow schemes while official losses justify continued Russian federal subsidy.
- Export routes remain active and uninterdicted: Turkey, Egypt, Syria, and Iran are primary documented markets. The key entities executing current trade - exporter TERRAMAX and vessel IRKUTSK - remain unsanctioned as of April 2026 despite confirmed shipments.
Grain Expropriation in Occupied Ukraine: State Operators, Control Networks, and Beneficiary Structures
1. Overview and Legal Context
Russia has established parallel grain control structures across all occupied territories, operating through state monopoly entities, occupation administration officials, and private extraction networks. These structures serve three functions: (1) confiscating Ukrainian agricultural assets; (2) providing a revenue base for occupation officials; and (3) supplying grain to Russia and third-country export markets through occupied ports.
1.1 Scale of expropriation
Pre-war, Ukraine was one of the world’s largest grain exporters, accounting for approximately 10% of global wheat exports, 13% of global corn exports, and 40% of global sunflower oil trade. The south-east, now substantially occupied, contained a disproportionate share of that productive capacity.1
As of mid-2025, Russia had stolen over 4 million tonnes of Ukrainian grain across all four occupied regions, estimated at over UAH 23 billion (approximately $580 million). In Zaporizhzhia Oblast alone, approximately 500,000 tonnes were removed in 2024, representing roughly one-seventh of occupied territories’ total grain export volume at that time.2
1.2 International law classification
Under international humanitarian law, the seizure of grain and agricultural assets in occupied territory, absent imperative military necessity, constitutes pillage, a war crime. Applicable frameworks include the Hague Regulations on War on Land (1907), the Fourth Geneva Convention on the Protection of Civilian Persons, and the Rome Statute of the International Criminal Court. A 2023 legal analysis commissioned by Global Rights Compliance concluded that the grain seizures in Zaporizhzhia and Luhansk do not meet the threshold of military necessity.3
1.3 Russian legislative framework for extraction
Russian Government Resolution No. 2535 (30 December 2022) established tariff quotas for exporting agricultural products from occupied territories at reduced or zero export duty rates. Russian companies wishing to export grain must obtain authorisation from the relevant regional head: for Kherson Oblast, quota allocation decisions were signed by Vladimir Saldo; for Zaporizhzhia, the process runs through Balytsky’s administration.4
The June 2025 State Duma legislation recognising pre-annexation Ukrainian property title documents (Section 5 below) will compound this by enabling consolidation of confiscated agricultural land under Russian jurisdiction through regional commission processes running until 1 January 2028.
2. State Grain Operator (DZO/GZO) - Occupied Zaporizhzhia Oblast
2.1 Legal entity and registration
The DZO was established on 15 May 2022 by Balytsky decree No. 08/1-р. It operated without formal registration in the all-Russian state register until December 2022, meaning its early transactions, including the first Berdyansk grain shipments of June–July 2022, were conducted outside any formal legal framework.6
| Ukrainian name | Державне унітарне підприємство «Державний зерновий оператор» |
|---|---|
| Russian name | ГУП «Государственный зерновой оператор» |
| Registered addresses | Melitopol, pl. Peremohy 4; Melitopol, Vakulenchuka St 99 |
| Operational address | Melitopol, Hetmana Sahaidachnoho St 51 |
| INN / KPP | 9001011019 / 900101001 |
| OGRN | 1229000019346 |
| OKPO | 49745792 |
| Bank | Promsvyazbank, Additional Office 'Zaporizhzhia' |
| Website / Telegram | gzomelitopol.ru / t.me/@gupgzo |
| Legal form | State Unitary Enterprise (SUE); de jure subordinated to Ministry of Agro-Industrial Complex of Zaporizhzhia VCA |
| Controlling authority | Zaporizhzhia Oblast occupation administration (Governor Yevhen Balytsky) |
| Founding documents approved by | Yevhen Balytsky (convicted in absentia by Ukraine to 15 years’ imprisonment) |
| Sanctioned (US OFAC) | 24 February 2023 |
| Sanctioned (EU FSF) | 22 May 2025 |
2.2 Capitalisation and financial structure
The DZO was capitalised through three sources: (1) an RUB 800 million injection from the Russian federal budget, provided from September 2022; (2) a RUB 1 billion ‘returnable financial assistance’ from Balytsky personally; and (3) a RUB 4 billion credit from Promsvyazbank. This capitalisation structure, combining federal funds with a personal loan from the occupation governor, directly indicates Balytsky’s de facto ownership stake and primary beneficiary status. Total initial capitalisation: approximately RUB 5.8 billion.10
From its creation the DZO was staffed by approximately 400 persons. Monitoring of social media channels (2022–June 2025) detected neither mass redundancies nor significant additional recruitment, suggesting the workforce stabilised at this level.6
2.3 Leadership and organisational structure
The DZO underwent a significant leadership change on 18 June 2024, when Yefremov Oleksiy Mykhailovych was appointed acting Director General, replacing Busel Mykyta Petrovych who had held the post since the enterprise’s founding.8
Directors General
| Name | Period | Notes |
|---|---|---|
| Busel Mykyta Petrovych b. 11.12.1982, Kuibyshev RF citizen | Until 18.06.2024 | US OFAC sanctioned 24 February 2023. Founded and led the DZO from its establishment. Also linked to Agrogroup, a shell company operating as a DZO intermediary. |
| Yefremov Oleksiy Mykhailovych b. 26.03.1972, Makiivka, Donetsk Oblast Obtained RF citizenship | From 18.06.2024 (Acting) | Ukrainian IPN: 2638300357; RF IPN: 615435962020. |
Ministry oversight
| Name | Role |
|---|---|
| Shevchenko (Lyshkova) Svitlana Yuriivna b. 07.02.1982, Vurnary, Chuvash Republic RF | Minister of Agro-Industrial Complex and Food Policy, Zaporizhzhia VCA. Responsible for approving DZO financial and economic activities: credit procurement, agricultural machinery acquisition, joint inventory at nationalised facilities, and operational reporting. |
Senior personnel (department directors)
The following individuals have been identified as holding senior roles within the DZO. All are citizens of Russia or occupied Ukrainian territories, and all function as officials of an illegally created occupation entity.9
| Name / DOB / Origin | Role | Notes |
|---|---|---|
| Shchepin Oleksandr Viktorovych b. 27.08.1985, Simferopol, Crimea RF citizen | Deputy Director General, Commercial Affairs | |
| Semyriak Denys Oleksandrovych b. 23.06.1988, Krasnovardiiske, Crimea IPN 3231608110 | Director, Commercial Department | |
| Mykhailovskyi Dmytro Leonidovych b. 24.12.1973, Donetsk IPN 2702111315 | Director, Economics and Finance | Appointed by Busel M.P. |
| Dzhurkín (Dzhurkin) Oleksiy Serhiyovych b. 28.10.1979, RF St. Petersburg registered | Director, Logistics Operations | Also runs Agrogroup, a shell company identified as a DZO intermediary in the export chain. |
| Verkhaturov Yuriy Yuriyovych b. 16.01.1985, Nerchinsk, Chita Oblast, RF St. Petersburg registered | Director, Logistics Operations | |
| Hrynko Taras Viktorovych b. 26.03.1983, Hola Prystan, Kherson Oblast IPN 3040001534 | Director, Plant Growing Department | |
| Kavtaradze Nana Hochaivna b. 29.08.1989, RF Moscow registered | Director, Protocol Department | |
| Burtsev Oleh Volodymyrovych [Partially identified] RF citizen | Director, Security Department | Partial identification only. |
| Tatiosova Evheniia Olehivna [Partially identified] RF citizen | Director, Internal Audit and Control | Partial identification only. |
| Riesin Viacheslav Leonidovych b. 21.11.1972, RF Yekaterinburg registered | Director, Operations and Production Planning | Responsible (with Ryabukhin) for functioning of DZO branches (elevators, grain warehouses). |
| Ryabukhin Serhiy Oleksandrovych b. 20.10.1970 RF citizen | Director, Operations and Production Planning | Former MVS RF officer. |
Territorial operations management
| Name | Role | Branches supervised |
|---|---|---|
| Mukhin Andriy Valeriiovych RF citizen | Deputy, territorial operations - controls loading and dispatch | Branches 5, 12, 13, 14, 15, 16 (Berdyansk cluster and Melitopol facilities) |
| Horban Valerii Ivanovych b. 17.06.1974, Kostiantynivka, Melitopol district IPN 2719601370 | Deputy, territorial operations - controls loading and dispatch | Branches 1, 8, 9, 10 |
| Pysanets Maksym Volodymyrovych b. 23.02.1984, Voznesenka, Melitopol district IPN 3073413793 | Deputy, territorial operations - controls loading and dispatch | Branches 2, 3, 4, 6, 7, 11 |
2.4 Financial data and the harvest paradox
The DZO’s official financial results for 2023–2024 present a structural paradox. Primary source analysis concludes this reflects deliberate profit concealment rather than genuine commercial underperformance.10
| Indicator | 2023 | 2024 | Change |
|---|---|---|---|
| Revenue | RUB ~5.9 billion | −59% year-on-year | |
| Net profit / (loss) | RUB ~322 million | RUB −1,131 million | Swing of RUB −1.45 billion |
| Balance sheet | - | RUB −2.5 billion | |
| Accounts payable | - | RUB ~1.56 billion | |
| Accounts receivable | - | RUB ~1.27 billion | |
| Tax debt | - | >RUB 1 billion | |
| Court judgments outstanding | - | of 911m total; ~45 proceedings (Rusprofile) | |
| Harvest (regional, total) | 5.7 million tonnes | 6.26 million tonnes | +560,000 tonnes (+9.8%) |
The paradox is stark: the 2024 harvest was approximately 560,000 tonnes larger than 2023, yet official revenue fell 59% and the enterprise recorded a net loss of RUB 1.131 billion. The occupation administration’s official explanation attributed the revenue decline to the Kakhovka dam destruction; this is directly contradicted by harvest data showing no volumetric decline. Since the DZO operates as a monopoly purchaser at self-set prices, a revenue collapse unaccompanied by a harvest decline is structurally explicable only through artificial accounting manipulation.11
Primary source analysis identifies three probable trajectories, in descending order of likelihood:
• Most probable - Subsidised extraction: DZO continues as a federal budget grant recipient, with losses socialised to the Russian state while real profits are channelled via cash operations, fictitious trading entities, or offshore intermediaries. Official losses legitimise continued subsidy while Balytsky and associates extract real value.
• Alternative - Controlled bankruptcy: Formal bankruptcy followed by debt write-off and asset transfer to a successor entity under a new name, restarting the cycle with legacy liabilities extinguished.
• Alternative - Reorganisation: Restructuring under a new corporate identity, preserving operational assets while paper losses remain with the defunct entity.11
2.5 Corruption scheme (confirmed, primary sources)
According to sources within the occupation administration (Zaporizhzhia September and October 2025 reporting), the following scheme was planned following the crisis-level 2025 harvest:
• The 2025 harvest was predominantly Classes 4–5 (feed-grade wheat); only 27% was Class 3, the minimum standard for human consumption or export.
• Balytsky’s circle planned to pay farmers monetary compensation for the poor harvest, then force those same farmers to purchase the identical low-grade seed wheat from the DZO for the following year’s sowing, channelling gains to occupation officials under cover of agricultural support policy.
• The 27% of Class 3 grain was planned for full export via Berdyansk port.
• The scheme will structurally prevent yield improvement in 2026 through the use of inferior seed stock.
This mechanism represents a textbook colonial extraction pattern: the DZO controls inputs (seed supply), outputs (storage and export), and the prices at which both are set, ensuring permanent farmer dependency on occupation structures.
2.6 Export routes and confirmed shipments
Berdyansk Commercial Port is the primary export terminal. The first grain shipment departed on 30 June 2022 - 7,000 tonnes, announced by Balytsky as heading for ‘friendly countries.’ All arrivals have since been characterised as dark port calls (AIS transponders off), though satellite imagery confirms continuous activity.14
The primary source documents the following confirmed shipment in the most recent reporting period: September 2025, vessel IRKUTSK (ex-ALFA M, IMO: 9419084) departed Berdyansk carrying 7,208.68 tonnes of wheat to Iskenderun, Turkey. Exporter recorded: TERRAMAX (INN 7751352898). No international response was recorded.
Open-source data confirms a multi-year pattern of substantial volumes:
• Q1 2023: approximately 250,000 tonnes exported from occupied Zaporizhzhia, primarily to Turkey and Egypt; full-year 2023 target set at over 1.5 million tonnes from Zaporizhzhia Oblast alone.
• 2024: approximately 212,000 tonnes, estimated value $46 million, based on customs declaration analysis.
• Since early 2024: approximately 500,000 tonnes removed from occupied Zaporizhzhia Oblast.15
Export markets include Turkey, Egypt, Syria, Iran, Libya, and Israel. Iran and Syria typically receive discounted cargoes routed through shadow fleet infrastructure. Egypt, Israel, and Lebanon are reported to have ceased purchasing Crimea-origin grain after being informed it was stolen.16
2.7 Verified counterparties (May–December 2022)
Centre for the Study of Occupation monitoring has provided verified data on 25 Russian grain traders to which DZO agricultural product was dispatched in May–December 2022. Total removal in this period was approximately 200,000 tonnes. Full counterparty data - including legal addresses, INN/KPP, OGRN, OKPO, and exact tonnages - is set out in Appendix A.12
Three observations of particular accountability significance:
• Inviktus Treyd LLC (INN/KPP 9002000806 / 900201001): registered in occupied Berdyansk, at Melitopolskoye Shosse 68. This entity operates directly within the occupation administration’s legal framework. Approximately 2,092 tonnes of wheat received.
• Elevator Oktyabrskoye LLC (INN 9105000847): registered in Oktyabrskoye, Krasnovardiiysky district, occupied Crimea. Participation in the DZO supply chain constitutes compounded sanctions exposure, as Crimea has been under separate sanctions since 2014.
• Dukush-2 LLC (INN 2012009876), registered in Avtury village, Shali district, Chechnya, and Kolibri LLC (Ingushetia): the North Caucasus registrations suggest deliberate geographic diversification of counterparty risk across jurisdictions less subject to routine financial monitoring.
2.8 Shell company intermediary layer
A network of affiliated companies sells DZO-sourced grain on foreign markets, providing commercial deniability. Agrogroup is run by Oleksiy Dzhurkín, who simultaneously serves in the DZO’s logistics leadership. Tesori Della Terra (founder Irina Kurganskaya) and Samson (80% held by Tesori Della Terra) function as intermediary sales entities. A Swiss-based agricultural trader in Zug was identified by Public Eye as having potentially purchased a cargo of Ukrainian wheat from a Russian company in October 2023, illustrating how the intermediary layer reaches into European commodity trading.17
2.9 Federal-level integration: ministerial link
In March 2023, the DZO’s official Telegram channel documented meetings between Director Busel, Russian Agriculture Minister Dmitry Patrushev, and Zaporizhzhia occupation authority representatives in Moscow. This confirms the DZO’s direct integration into Russia’s state agricultural apparatus at ministerial level, not merely at regional occupation administration level.18
2.10 Agricultural workforce collapse
Primary source data documents formal employment through the occupation employment service collapsing from 13,300 workers (2023) to 8,200 (2024) to a projected 3,700–3,800 (2025) - approximately a 60% decline over two years. Source reporting also documents up to 100 farming families departing per month due to expropriation of seed stock and catastrophic harvest results. In parallel, extraordinary asset concentration has been documented among a small number of beneficiaries: in 2024, the revenues of a single private farm linked to Volodymyr Krupko were second only to the DZO itself across all agricultural enterprises in occupied Zaporizhzhia, at over RUB 4.5 billion.19
2.11 Sanctions status
| Entity / Individual | Sanctioning Jurisdiction | Status / Notes |
|---|---|---|
| DZO (State Grain Operator) | United States (OFAC) | Sanctioned 24 February 2023 |
| DZO (State Grain Operator) | European Union (FSF) | Sanctioned 22 May 2025 |
| Nikita Busel (DZO Director until June 2024) | United States (OFAC) | Sanctioned 24 February 2023 |
| Yevhen Balytsky | EU, US, UK (multiple) | Sanctioned as head of occupation administration |
| TERRAMAX (INN 7751352898) | None (as of April 2026) | Identified Berdyansk grain exporter; not yet sanctioned |
| Vessel IRKUTSK (ex-ALFA M, IMO 9419084) | None (as of April 2026) | Berdyansk–Iskenderun grain transit, September 2025; not yet sanctioned |
Sanctions data from OpenSanctions, EU FSF, and OFAC designations database.20
3. Kherson Grain Company - Occupied Kherson Oblast
3.1 Legal entity and function
| Name | Khersons’ka Zernova Kompaniya / Херсонська Зернова Компанія |
|---|---|
| Registration date | July 2022 (under Russian occupation authority) |
| Status | Illegally created occupation entity for legalising and exporting stolen grain |
| Head | Kiva Serhii - appointed head of Kherson Grain Company, approximately June 2024 (Rusprofile EGRUL; TASS) |
| Controlling authority | Volodymyr Saldo’s occupation administration; Saldo personally signed export quota allocations |
Primary source characterisation: ‘An illegally created enterprise on the occupied part of Kherson Oblast, designed to legalise stolen grain crops for their subsequent export to Russia and abroad.’ The company functions as a controlled intermediary in land allocation, distributing land not directly to producers but to a limited circle of loyal individuals or subleasing at inflated prices. This embeds corrupt rent extraction into the land access mechanism itself, while the interests of company leadership are structurally encoded into agricultural governance.22
3.2 Kiva’s background and expansion plans
Serhii Kiva previously worked for large Ukrainian agricultural companies and held commercial contacts in China and Morocco prior to his collaboration. As of mid-2025, Kiva and his team were planning to: (a) reorganise the Kherson Grain Company into a joint-stock company; (b) create an agricultural holding with a 50,000-hectare land bank; and (c) develop downstream processing capacity including a bakery, an oil extraction facility, and a feed mill. This trajectory indicates the structure is moving beyond simple extraction toward an integrated agro-industrial holding.21
Russia was also reportedly planning to require Kherson farmers to surrender harvested vegetables at below-market fixed prices, indicating intent to extend the compulsory procurement model beyond the grain sector.22
3.3 Infrastructure
Total elevator network: 11, of which only 2 were functional as of October 2025. The primary operational facility is the Bratolyubivsky elevator in Kostiantynivka village, Kakhovka district: 163,600-tonne capacity (elevator 130,000 t; warehouse 33,600 t); formerly a branch of JSC State Food and Grain Corporation of Ukraine. As of October 2025, it had resumed rail grain transport and was the only large-capacity operational elevator in the Kherson Oblast occupation grain network.23
The fact that only 18% of the elevator network is operational (2 of 11) indicates either deliberate capacity restriction or an inability to staff and operate inherited Ukrainian infrastructure.
3.4 Export markets
Stolen grain from the occupied left bank of Kherson Oblast is exported to Turkey, Egypt, Lebanon, and Syria. Open-source investigations also document exports to Azerbaijan and Iran (barley at significant discount to market). Egypt, Israel, and Lebanon reportedly ceased purchasing Crimea-origin grain after being informed it was stolen.24
3.5 Saldo prosecution timeline
| Date | Event |
|---|---|
| April 2022 | Saldo appointed Chairman of Russian Civil-Military Administration for Kherson Oblast; established control over the agricultural sector. |
| Autumn 2022 | Ordered creation of temporary administration at Kherson Bread Products Plant. Over 30,000 tonnes of grain and industrial crops seized before liberation of Kherson city (November 2022). Three barges - over 2,800 tonnes of 2021 barley harvest - exported before liberation. |
| November 2023 | Convicted of treason in absentia by Ukrainian court. |
| August 2024 | Charged in absentia for seizing and relocating over 2,800 tonnes of grain; under provisions concerning violation of the laws and customs of war. |
| 20 March 2026 | Indictment filed with Ukrainian court for organising systematic grain seizure and export scheme valued at over UAH 5.3 billion across occupied Kherson Oblast. Grain sold to Syria, Egypt, Turkey, Lebanon, and other countries. |
Prosecution sources as cited in notes.25
4. Mariupol Port - Grain Export Node
| Period | Recorded Activity |
|---|---|
| October 2024 | Port entered active navigation phase. At least 3 bulk carriers and 1 cargo vessel recorded. Cargoes: coal, ore, kaolin. First confirmed integration of rail-port logistics chain. |
| September 2025 | One vessel recorded with grain cargo (2022/2023 harvest remnants) loaded from port elevator. Departed for Turkey. |
| 14 September 2025 | Vessel ‘Alpha-1’, from the fleet of Russian Deputy Prime Minister Marat Khusnullin and associate Yulia Maksimova, departed Mariupol with coal cargo hastily loaded same day. |
| January 2026 | Three vessels entered port; two departed with coking coal to Turkey; one with wheat to Egypt. First instance of customs clearance directly at Mariupol port, removing the Temryuk intermediary - significantly reducing costs and transit time. Signals Russian commitment to long-term port exploitation. |
In the first half of 2024, an estimated 15 ships carrying approximately 81,000 tonnes of wheat departed Mariupol for Turkey.26
Russia has deliberately divided the port into two economic zones: a state (non-profit) entity absorbing all costs - GUP DPR ‘Administration of the Sea Port of Mariupol’ (revenue ~RUB 183 million, net loss ~RUB 54 million in 2024, authorised capital RUB 237.4 million, funded through DPR budget from Russian federal transfers) - and private stevedoring companies extracting export revenues through offshore intermediary chains including Green Rabbit Limited. The Khusnullin–Maksimova shipping network represents the private profit extraction layer operating above the state port administration.
5. Russian Legislative Developments (Property and Land)
On 24 June 2025, the Russian State Duma passed legislation (2nd and 3rd readings) recognising property title documents issued by Ukrainian state bodies, local self-government, or notaries before annexation as valid for the occupied Donetsk, Luhansk, Zaporizhzhia, and Kherson Oblasts. The law enters force 90 days after official publication; special regional commissions will operate until 1 January 2028.
Conditions for recognition: documents issued before inclusion in the Russian Federation and in accordance with Ukrainian legislation at the time. Refusal conditions: documents issued after 30 September 2022, or issued in violation of Ukrainian norms.
For agricultural property, the practical implications are significant:
• Creates a legal vehicle for consolidating confiscated agricultural land under Russian jurisdiction through commission processes.
• Generates substantial corruption opportunities within regional commissions, enabling property redistribution to loyal settlers and intermediaries.
• Documents forged using stolen Ukrainian notary blanks during early occupation will likely be exposed in commission review, creating further instability and potential for occupation authorities to seize assets on compliance grounds.
• Combined with the DZO seed stock scheme and the Kherson Grain Company’s land bank consolidation plans, this legislation represents a multi-vector long-term strategy for agricultural control.
6. Accountability and Legal Proceedings
| Individual | Proceedings | Key Details |
|---|---|---|
| Dmitry Patrushev (Russian Deputy PM; former Agriculture Minister, February 2022–May 2024) | Suspicion notice in absentia, 11 July 2025 (SBU / PGO) | War crimes under Criminal Code Art. 28 Pt. 2 / Art. 438 Pt. 1. Accused of coordinating theft of 4+ million tonnes (UAH 23 billion / ~$580 million) across Zaporizhzhia, Kherson, Donetsk, and Luhansk. Used Ministry powers to re-register enterprises, appoint loyal managers, and subordinate assets to the Russian agro-industrial complex. Assets include Nibulon, TESSLAGROUP, Kernel-Trade, State Food and Grain Corporation of Ukraine, and Starobilsk Elevator. Grain resold via shadow fleet to Middle East and North Africa as Russian exports. |
| Volodymyr Saldo (Head, occupied Kherson) | Indictment filed, 20 March 2026 (PGO) | Systematic forced confiscation and illegal export of agricultural products worth UAH 5.3 billion. Grain sold to Syria, Egypt, Turkey, Lebanon, and other countries. Earlier charged in absentia (August 2024) for the 2,800-tonne Kherson barley seizure. |
All proceedings are in absentia, as both individuals remain on Russian-controlled territory. Patrushev is the son of Nikolai Patrushev, former FSB Director and Security Council Secretary. The SBU has indicated additional individuals from Russia’s political and agricultural ministry leadership are under active investigation.2728
Despite a substantial documented pattern of ongoing grain export, neither TERRAMAX nor the vessel IRKUTSK had been sanctioned as of April 2026. Turkey - the primary destination for Berdyansk and Mariupol grain exports - has stated it bans vessels from occupied Ukrainian terminals, but enforcement remains contested.
7. Conclusions
• The DZO seed stock scheme is a textbook colonial extraction mechanism: the monopoly controls inputs (seed), outputs (storage and export), and the price at which both are set, ensuring permanent farmer dependency on occupation structures and structural prevention of yield recovery.
• The harvest paradox - revenue −59% in 2024 despite harvest +9.8% - is assessed by primary source analysis as indicating artificial, administratively-constructed losses concealing real profit extraction via shadow schemes. The 45 active court proceedings (RUB 911 million) and RUB 1 billion tax debt are consistent with a deliberate insolvency strategy.
• Export routes are confirmed and ongoing with no effective interdiction. Turkey (grain, coal), Egypt (grain), Syria (grain, maize), and Iran (barley at discounted prices) are primary documented markets. The Berdyansk-Turkey route is confirmed across multiple primary and open sources with no recorded international response to individual shipments.
• The Kherson Grain Company is only 18% operationally functional (2 of 11 elevators), but its planned expansion (50,000-hectare land bank, joint-stock conversion, downstream processing) indicates long-term consolidation intent exceeding current capacity.
• Mariupol port is being integrated into a direct Russian customs regime from January 2026, removing the Temryuk intermediary and signalling long-term exploitation.
• The accountability picture at federal level is developing: Patrushev charged, Saldo indicted. The specific entities executing current trade - TERRAMAX, vessel IRKUTSK - remain unsanctioned as of April 2026.
• The June 2025 Duma property legislation will create a second wave of agricultural asset consolidation, providing a formal legal mechanism for land title transfer to loyal actors and compounding the structural transformation already underway through DZO monopoly control and Kherson Grain Company land distribution.
8. Sanctionable and Accountability-Relevant Entities
| Entity / Vessel | Category | Status and Basis |
|---|---|---|
| TERRAMAX (INN 7751352898) | Russian company | Berdyansk grain exporter; September 2025 IRKUTSK shipment. Not yet sanctioned. |
| DZO / GZO (State Grain Operator) | State unitary enterprise | EU-sanctioned May 2025; US-sanctioned February 2023. |
| Vessel IRKUTSK (ex-ALFA M, IMO 9419084) | Vessel | Berdyansk–Iskenderun grain transit, September 2025. Not yet sanctioned. |
| LLC ‘Nika Trade Invest’ | Private company | Mariupol port logistics; Khusnullin network. |
| Green Rabbit Limited | Offshore intermediary | Mariupol port profit extraction. |
| Kherson Grain Company | Occupation entity | Grain legalisation vehicle, occupied Kherson. Head: Kiva Serhii. |
| Agrogroup | DZO affiliate | DZO intermediary; director Oleksiy Dzhurkín (also DZO logistics director). |
| Tesori Della Terra | DZO affiliate | Intermediary; founder Irina Kurganskaya. |
| Samson | DZO affiliate | 80% held by Tesori Della Terra; intermediary chain. |
| Inviktus Treyd LLC (INN 9002000806) | Occupied-territory entity | Registered in occupied Berdyansk. Received ~2,092 t wheat from DZO in 2022. |
Notes
1. Silvie Lang, Thomas Braunschweig, and Robert Bachmann, "Russian Grain Plundering in Ukraine: Risky Business for Swiss Commodity Trade," Public Eye, 13 February 2024, https://www.publiceye.ch/en/topics/ukraine; "Stolen Grain," NGL.media, 28 October 2024, https://ngl.media/en/2024/03/29/stolen-grain/.
2. Office of the Prosecutor General of Ukraine, "Dmitry Patrushev Notified of Suspicion for Organising Mass Theft of Ukrainian Grain," 11 July 2025; "Russia Steals about 500,000 Tonnes of Ukrainian Grain from Zaporizhzhia Region," Ukrinform, 15 August 2024; "Russia Makes at Least Billion Dollars on Stolen Ukrainian Grain," Ukrainska Pravda, 16 September 2024.
3. Global Rights Compliance and the Starling Marte Justice Team, Agriculture Weaponised: The Illegal Seizure and Extraction of Ukrainian Grain (The Hague: Global Rights Compliance, November 2023), https://globalrightscompliance.org/wp-content/uploads/2025/06/20231115-Grain-Report-External.pdf.
4. Investigative Journalism and Bribery Centre (BIC), Skhemy (RFE/RL Ukraine), and Verstka, "How and Where Russian Companies Export Ukrainian Grain," June 2024, https://investigatebel.org/en/investigations/rossiya-ukrainskoe-zerno-vyvoz.
5. Centre for Journalistic Investigations (CJI), "Bloody Bread: How Russian Occupants Steal Ukrainian Agro-Assets in Zaporizhzhia," investigator.org.ua, February 2026, https://investigator.org.ua/en/investigations/282021/; "Stolen Grain," NGL.media; OpenSanctions, "State Unitary Enterprise 'State Grain Operator,'" citing EU Financial Sanctions Files (FSF), updated 22 May 2025, https://www.opensanctions.org/entities/NK-hBwvaLRAcnapoHgaoejwmY/.
6. Centre for the Study of Occupation monitoring; "How Russia Exports Grain," Babel.ua/Financial Times, 30 October 2022.
7. Centre for the Study of Occupation monitoring, including legal registration data, capitalisation structure, personnel roster, financial results, counterparty data, and branch network documentation.
8. Centre for the Study of Occupation monitoring, personnel section; Nikita Busel under US OFAC sanctions since 24 February 2023.
9. Centre for the Study of Occupation monitoring, personnel section and operational data.
10. Centre for the Study of Occupation monitoring, financial results section; Rusprofile, DZO financial data (public Russian corporate registry).
11. Centre for the Study of Occupation monitoring, financial analysis section.
12. Centre for the Study of Occupation monitoring, Appendix on verified counterparties. Note: Appendix states total volume removed in May–December 2022 was approximately 200,000 tonnes.
13. Centre for the Study of Occupation monitoring, branch network documentation.
14. "Russia-Appointed Official Says Grain Shipment Left Ukraine's Berdyansk for 'Friendly Countries,'" Radio Free Europe/Radio Liberty, 2 July 2022, https://www.rferl.org/a/ukraine-grain-berdyansk-shipment-russia/31922653.html; "EU Sanctions Russian Grain Operator in Occupied Zaporizhzhia," Lloyd's List, 21 May 2025.
15. Public Eye, citing TASS (export target for 2023); "Stolen Grain," NGL.media (2024 volumes); Ukrinform/Fedorov (500,000 tonne figure).
16. "Russia Makes at Least Billion Dollars on Stolen Ukrainian Grain," Ukrainska Pravda, 16 September 2024; Office of the Prosecutor General of Ukraine, Patrushev suspicion notice, 11 July 2025.
17. "Stolen Grain," NGL.media (Agrogroup, Dzhurkin, Tesori Della Terra, Samson); Lang, Braunschweig, and Bachmann, "Russian Grain Plundering" (Swiss commodity trader).
18. Global Rights Compliance and SMJT, Agriculture Weaponised, citing DZO official Telegram channel, March 2023.
19. Employment figures: Centre for the Study of Occupation, Zaporizhzhia reports, September–October 2025 (primary). Krupko asset concentration: CJI, "Bloody Bread."
20. OpenSanctions, EU Financial Sanctions Files (FSF), 22 May 2025; OFAC designation, 24 February 2023; TERRAMAX and vessel IRKUTSK status from Centre for the Study of Occupation, Zaporizhzhia October 2025 report (primary).
21. "Kherson Grain Under Russian Rules: Who Profited from the Ukrainian Harvest," intent.press, August 2025, https://intent.press/en/news/anti-corruption/2025/kherson-grain-under-russian-rules-who-profited-from-the-ukrainian-harvest/.
22. "Russia Takes Direct Control of Kherson's Farming Sector," RBC Ukraine, 12 January 2026, https://newsukraine.rbc.ua/news/russia-takes-direct-control-of-kherson-s-1768179104.html.
23. "Kherson Grain Under Russian Rules," intent.press, August 2025; RBC Ukraine, January 2026.
24. BIC, Skhemy, and Verstka, "How and Where Russian Companies Export Ukrainian Grain," June 2024; "Russia Makes at Least Billion Dollars," Ukrainska Pravda.
25. Kyiv Independent, "Russian-Installed Occupied Kherson Head Charged," 15 August 2024; Euromaidan Press, "Ex-Mayor Saldo Accused," 15 August 2024; "Stolen Grain from Kherson Region Was Sold to Syria," intent.press, March 2026; "Collaborator Saldo Will Be Tried," Ukrainian Shipping Magazine, March 2026.
26. "Russia Makes at Least Billion Dollars on Stolen Ukrainian Grain," Ukrainska Pravda, 16 September 2024.
27. Office of the Prosecutor General of Ukraine and SBU, Patrushev suspicion notice, 11 July 2025; "Ukraine Charges Russian Deputy PM Dmitry Patrushev," Kyiv Insider, 15 July 2025; "Russian Deputy Agriculture Minister Accused of War Crime," Seed World, 10 November 2025.
28. Office of the Prosecutor General of Ukraine, announcement, 20 March 2026, reported in "Stolen Grain from Kherson Region Was Sold to Syria," intent.press; "Collaborator Saldo Will Be Tried," Ukrainian Shipping Magazine.
Appendix A: Verified DZO Counterparties (May–December 2022)
Source: Centre for the Study of Occupation monitoring. The following 25 Russian grain trading entities received DZO agricultural product during May–December 2022. Total removal in this period: approximately 200,000 tonnes. Legal addresses, INN/KPP, OGRN, and OKPO are as recorded in the source.
| # | Company | Legal address | INN | Commodity / Volume |
|---|---|---|---|---|
| 1 | Grin-Layn LLC | St. Petersburg, Fontanka Emb. 172, fl. 2 | 7813443890 | 6,932.17 t wheat |
| 2 | Agroeksport-Yug LLC | Pyatigorsk, Stavropol Krai, Delegatskaya St 97 | 7714461659 | 94.84 t peas |
| 3 | Kuban-Forward LLC | Krasnodar, Severnaya St 357, rm. 511 | 2308103230 | 44,857.8 t wheat |
| 4 | Vidan LLC | Moscow, Ryabinovaya St 45 | 7715588288 | 766.66 t sunflower |
| 5 | TD Agroprom-Impeks LLC | Taganrog, Rostov Oblast, Krasniy Lane 21 | 6154160647 | 1,217.3 t sunflower |
| 6 | TD Fregat LLC | Moscow, Zubovskiy Blvd 13 | 7704388784 | 3,815.95 t wheat + 1,126.3 t barley |
| 7 | Krona LLC | Krasnodar, Mitrofana Sedina St 209/1 | 2310217254 | 835.52 t sunflower |
| 8 | Agro-Trading LLC | St. Petersburg, Shevchenko St 18 | 7805754388 | 129.78 t sunflower + 3,204.18 t wheat |
| 9 | Elevator Oktyabrskoye LLC | Oktyabrskoye, Krasnovardiiysky district, Crimea (occupied) | 9105000847 | [volume not listed in source] |
| 10 | NAYM LLC | St. Petersburg, Lenina St 28 | 7813640426 | 16,298.43 t sunflower + 337 t wheat |
| 11 | Flagman-Yug LLC | Simferopol, Crimea (occupied) | 9102224616 | 2,842.2 t sunflower + 1,153.36 t rapeseed |
| 12 | Inviktus Treyd LLC | Berdyansk, Melitopolskoye Shosse 68 [OCCUPIED TERRITORY] | 9002000806 | 2,092.42 t wheat |
| 13 | Aval LLC | Moscow, Derbenyovskaya Emb. 7 | 7720314451 | 29,882.92 t wheat |
| 14 | Dukush-2 LLC | Avtury, Shali district, Chechnya | 2012009876 | 4,526.04 t rapeseed |
| 15 | Kolibri LLC | Nazran, Ingushetia | 0608054507 | 779.5 t sunflower |
| 16 | TD Agro-Premium LLC | Krasnodar, Yana Poliyana St 33 | 2311245600 | 350.7 t sunflower + 1,107.94 t rapeseed |
| 17 | AgroKapital LLC | Bataysk, Rostov Oblast | 6164138351 | 489.76 t sunflower |
| 18 | Novaya Niva LLC | Novokrasnovka, Donetsk Oblast (occupied) | 9305005916 | 1,923.8 t wheat |
| 19 | Agropraym LLC | Taganrog, Rostov Oblast | 6154139589 | 235.94 t rapeseed |
| 20 | Voskhod-R LLC | Rostov-na-Donu | 6166092504 | 1,063.9 t rapeseed |
| 21 | AgroResurs LLC | Moscow, Aviamotornaya St 50 | 7730269046 | 269.52 t rapeseed + 210.24 t sunflower |
| 22 | Milyev LLC | Donetsk (occupied) | 9309024740 | 9,053.14 t sunflower |
| 23 | Nika LLC | Rostov-na-Donu | 6168091111 | 972.5 t sunflower + 1,695.65 t wheat |
| 24 | IP Dmitrienko S.P. | Krasnodar | 233900448980 | 994.36 t sunflower + 1,371.12 t rapeseed |
| 25 | Global Treyd LLC | [Not listed] | - | 1,312.4 t barley + 4,418 t corn |
Appendix B: DZO Branch Network - Complete Listing with Pre-occupation Ukrainian Owners
Source: Centre for the Study of Occupation monitoring. All branches represent seized Ukrainian enterprises or state research facilities. EDRPOU codes are Ukrainian pre-occupation registration numbers.
| Branch | Location | Pre-occupation Ukrainian owner | EDRPOU / Notes |
|---|---|---|---|
| Branch 1 | Yakymivka, Melitopol district | Yakymivske PSP / Optimusagro Treyd LLC | 41161689 |
| Branch 2 | Tokmak, Polohy district | Tokmak-Agro LLC | 31845237 |
| Branch 3 | Vasylivka | Vasylivka-Agro LLC | 32017811 |
| Branch 4 | Polohy | Polohivskyi MEZ PJSC (oil extraction plant) | 00384147 |
| Branch 5/12/13 (merged) | Berdyansk (all port grain facilities) | Berdyansk Crane Equipment Plant PJSC / 'Agriia' Private Marine Grain Terminal; Politechnika LLC; Berdyansk Prylyv Plant LLC (leased to Asket Shipping LLC); Nova Khortytsia LLC | 01124980 / 34217047 / 36141719 / 35355771 / 30545888 - Primary export node |
| Branch 6 | Kamianka-Dniprovska | Nibulon LLC (Kamianka-Dniprovska branch) | 14291113 - Ex-Nibulon elevator |
| Branch 7 | Tokmak (second facility) | Tokmak-Agro LLC | 31845237 |
| Branch 8 | Verkhniy Tokmak, Berdyansk district | Verkhnotokmatske PSP / Optimusagro Treyd LLC | 41161689 |
| Branch 9 | Rozivka, Polohy district | Rozivske PSP / Optimusagro Treyd LLC | 41161689 |
| Branch 10 | Troiany, Berdyansk district | Troianivske PSP / Optimusagro Treyd LLC | 41161689 |
| Branch 11 | Pryshyb, Vasylivka district | Firm Advers LLC | 40387906 |
| Branch 12 - Sub-unit 1 | Rozivka | Rozivska Research Station, State Institute of Grain Crops (NAAU) | 00496722 - 4,500 ha |
| Branch 12 - Sub-unit 3 | Solodkovodne, Polohy district | Agrofirma Solodkovodne LLC | 35815811 - 2,662 ha |
| Branch 12 - Sub-unit 4 | Vyshnuvate, Polohy district | Agrofirma Vyshnuvate LLC | 40921623 - 3,320 ha |
| Branch 13 | Berdyansk | Berdyanskyi Khlibkombinat PJSC | 00378218 - Bread plant |
| Branch 14 | Obilne, Melitopol district | Agrokhimservis LLC | 31522332 - Fertiliser / agrochem warehouse |
| Branch 15 | Melitopol, Sahaidachnoho St 212 | Dozh LLC | 40000980 - Fertiliser warehouse + freight station |
| Branch 16 | Berdyansk | Asket Shipping Road Transport LLC | 42354326 - Transport / logistics base |
| Branch 17 - Sub-unit 1 | Vysoke, Melitopol district | Freedom Farm Terra LLC | 31585444 - 5,000 ha |
| Branch 17 - Sub-unit 2 | Romashky, Melitopol district | Mahistral-Servis LLC | 30542138 - 3,248 ha |
| Branch 17 - Sub-unit 3 (MOSS) | Melitopol, Vakulenchuka St 99 | Melitopol Research Station of Horticulture (M.F. Sydorenko), Institute of Horticulture NAAS Ukraine | 00415451 - 235.5 ha; state research station |
| Branch 17 - Sub-unit 4 | Fruktove, Melitopol district | State Enterprise 'Melitopolske' (Horticulture Research Station NAAS) | 19269779 - 1,500 ha (1,000 ha perennial plantations) |
| Branch 17 - Sub-unit 5 | Yakymivka | State Enterprise 'Yakymivske' (Research Station of Essential Oils Crops NAAS) | 00496739 - 1,100 ha |
| Branch 17 - Sub-unit 6 | Kamianka-Dniprovska, Vasylivka district | Khors-Agro LLC | 40938996 - 2,700 ha |
| Branch 18 - Sub-unit 1 | Zaporizhzhia village, Polohy district | Heolan-Agro LLC | 36496721 - 3,897 ha |
| Branch 18 - Sub-unit 2 | Ostrykivka, Polohy district | Iksprom Agro LLC | 40995597 - 604 ha |
| Branch 18 - Sub-unit 4 | Voskresenka, Polohy district | Agrofirma Batkivshchyna LLC | 30791236 - 15,000 ha (largest single farming unit) |
| Branch 19 - Sub-unit 1 | Lantsevy, Polohy district | SFH Viktor | 30952248 - 5,430 ha |
| Branch 19 - Sub-unit 3 | Shevchenkivske, Bilmak district | Prydonetske LLC | 00853286 - 4,951 ha |
| Branch 20 - Sub-unit 1 | Shyroke, Veselivka district | State Enterprise 'Shyroke' (Donetsk State Agricultural Research Station NAAS) | 00853317 - 7,150 ha |
| Branch 20 - Sub-unit 2 | Tavriia, Veselivka district | State Enterprise 'Tavriia' (Donetsk State Agricultural Research Station NAAS) | 00853323 - 3,785.7 ha |
| Branch 20 - Sub-unit 3 | Vidrodzhennia, Melitopol district | State Enterprise 'Vidrodzhennia' (Donetsk State Agricultural Research Station NAAS) | 00724838 - 4,090 ha |
| GUP Berdyansk Commercial Port | Berdyansk, Horkoho 13/7 | State Enterprise 'Berdyansk Commercial Sea Port' | INN 9002008361 / OGRN 1229000019984 - Nationalised; primary export terminal |
Note on Optimusagro Treyd LLC (EDRPOU 41161689): assets appear across Branches 1, 8, 9, and 10, indicating targeted seizure of one of the larger regional agro-operators. Tokmak-Agro LLC (EDRPOU 31845237) appears in both Branches 2 and 7. The seizure of multiple National Academy of Agrarian Sciences Ukraine (NAAS) research stations across Branches 12, 17, and 20 represents the expropriation of Ukrainian publicly-funded scientific infrastructure.
Corrections are reviewed by the research team and incorporated into the next update.