Ghost Cargo: The Hidden Journey of Sanctioned Oil to Europe

In 2023-2024, 99,000 tons of oil of Georgian origin entered Spain from Georgia, totaling 49 million euros. This statement has two suspicious circumstances: Georgia neither produces nor extracts such a quantity of oil, and these export figures are not found in the National Statistics Office of Georgia database but in Spain’s records.

Due to these suspicious circumstances, we became interested in understanding what explains this situation—is it merely a technical error in the databases, or is our neighboring aggressor involved, seeking alternative routes to sell sanctioned products as it is prohibited from exporting oil to Europe? Our journalistic investigation aims to answer this question.

Russia’s full-scale war in Ukraine has been ongoing for three years. To weaken the aggressor, the civilized world imposed sanctions on it. The goal was to collapse its economy and, as a result, limit the occupier’s combat capability. From December 2022, the sale of Russian oil in European countries was gradually banned. By the end of 2022, direct oil imports from Russia to Europe decreased from 24% to 4%.

Don’t let the numbers mislead you; this does not mean that our northern neighbor can no longer sell oil or is losing its primary resource. Under sanctions, it has simply moved to new, non-traditional routes and markets. In other words, indirect methods of selling sanctioned products have been found. The Russia-Europe route has changed to Russia-third country-Europe, but the cargo remains the same.

We have previously reported that Georgia is a “black hole” for Russia, successfully used to evade sanctions. We uncovered how we supply Russia with sanctioned expensive vehicles and dual-use items suitable for the battlefield. We will tell you how Georgia’s territory has become a supplier and reseller for Russia. If we previously heard that sanctioned products from Europe entered Russia through Georgia, we can now say that sanctioned products from Russia also entered Europe through Georgia.

We studied official statistics from Georgian, international, and European countries for five months. We compared thousands of data points from four independent databases, examined oil importing and exporting companies, tracked the movement of Russian cargo across Georgian territory, spoke to specialists in railway and maritime transportation, and ultimately revealed that:

• Since the war in Ukraine in 2022, oil exports from Georgia to European countries have increased almost 15 times.
• Since the war in Ukraine began, Russia has continued to be Georgia’s leading oil importer, via maritime and railway transportation.
• Official data released by Geostat regarding oil imports and exports from Georgia to Europe do not match the official data from the UN’s international trade database or other authoritative sources.
• More oil and petroleum products enter Georgia from Russia than officially recorded by Georgian authorities.
• More oil and petroleum products are “Georgianized” in Europe than Georgia itself extracts.

Research Methodology

While working on this investigation, we analyzed foreign trade data for two types of products that Russia can no longer export to EU member states. These are:

• Crude oil and petroleum products (international trade code 2709);
• Oil and petroleum products (international trade code 2710).

To examine Georgia’s oil trade, we had to work with four different databases:

1. volza.com – An international trade portal that collects import-export data from official structures and customs declarations, thus considered reliable.
2. comtradeplus.un.org – A UN website that provides global foreign trade data.
3. importgenius – A private database that gathers trade information globally.
4. Ex-trade.geostat.ge – Georgia’s National Statistics Office portal exclusively provides foreign trade data.

Comparing these databases, we discovered discrepancies between Georgia’s official statistics and international data. If Georgia is set as the reporting party on the UN trade portal, the information matches Geostat’s figures. However, the system shows entirely different data if Spain is selected as the reporting party, and we search for how much oil was imported from Georgia to Spain. The foreign databases (Volza and Comtrade) present similar numbers. Here are some specific cases where Georgia’s official statistics differ from international systems:

1. According to the Geostat database, no oil was exported from Georgia to Spain in 2023. However, international databases show that $25 million of oil was imported from Georgia to Spain in the same year.
2. Geostat reports that $4.7 million of oil was sent from Georgia to Greece in 2024. According to Volza, $10.4 million of oil was shipped in just the first seven months of 2024.
3. In April-May 2022, more than 5,000 tons of “Georgian-origin” oil, worth $6.4 million, were exported from Georgia to Italy. This is evident in the Volza international trade database. The exact figures are reflected in the UN foreign trade portal. At the same time, this oil was not automotive. The Volza database identifies the product as jet fuel intended for aircraft with jet engines. This data is absent from the National Statistics Office of Georgia’s records. According to the Georgian database, no oil was exported to Italy in 2022.

Author’s Note:
The National Statistics Office of Georgia collects statistical information from various agencies. In this case, trade statistics must be provided by the Revenue Service. If agencies fail to deliver complete information to Geostat, it cannot reflect accurate statistics in its records.

4. In June 2022, $16.5 million worth of oil, totaling 20,000 tons, was shipped by sea from Georgia to Belgium. This information was also found in the Volza and Comtrade databases. However, Geostat’s foreign trade portal states that no oil was exported from Georgia to Belgium in 2022.

Such discrepancies in data were also observed before the war. For example, in 2016, according to Geostat, oil and petroleum products worth around $4 million (under the HS 2710 trade code) were exported from Georgia to the EU. However, Comtrade data shows that over $13 million worth of oil under the same trade code was imported into EU countries from Georgia.

How can it be explained that data in international databases match, but this information does not appear in our official statistics?

As mentioned earlier, the foreign trade data presented on the Georgian portal is provided to Geostat by the Revenue Service. These discrepancies raised our suspicions, so we approached both agencies with questions. Geostat responded that such mismatches could be caused by triangular trade, either with or without resale. Here is an explanation of these two scenarios:

Triangular trade with resale occurs when, for example, a Russian company sells oil to a Georgian company, and the Georgian company resells it to an Italian one. However, the cargo never physically enters Georgia, going directly from Russia to Italy. In such cases, this shipment would not be reflected in Georgia’s official statistics, as it never entered the country’s territory.

Now, triangular trade without resale means the goods are exported from Russia to Georgia and then sold and shipped to Italy. In this case, Italy might indicate that the cargo was received from Russia, Russia records the export to Georgia, and Georgia records the export to Italy. Ultimately, this creates asymmetry in the statistical data between countries, leading to different versions.

Geostat could not provide a more detailed response. The Revenue Service did not answer our questions at all. Yet, when working on sanctions-related topics, we always strive to understand and reflect on their responses and positions in our materials. The Revenue Service does not cooperate with us, and only after the publication of our materials do they respond with defamatory posts, claiming that we did not attempt to communicate with them and questioning the findings of our investigations. When sending our questions this time, we specifically clarified that if they did not respond, any subsequent accusations would be unfounded excuses.

To understand the causes of these confusing foreign trade discrepancies, we spoke with people with extensive knowledge of export-import and oil trade issues. Most of our sources agreed to talk on the condition that their identities remain confidential, as they still work in government agencies and fear losing their jobs if they speak openly.

While working on this article, we interviewed 15 people: employees of the Batumi, Poti, and Kulevi ports; current employees of the Maritime Agency, which oversees all three ports; former employees of the Adjara Ministry of Environmental Protection; sailors; oil terminal staff; railway transportation specialists; and employees of railway distribution stations. Their accounts corroborate the statistical data obtained by comparing multiple databases, presenting a cohesive picture.

Sources explained that a ship can leave port without its cargo being sold, meaning the crew may not know the final destination of the oil. The ship’s owner informs the captain mid-voyage that the oil has been sold en route. In such cases, the cargo is transferred via pipelines to another tanker in neutral waters where no country’s customs jurisdiction applies. This process, known as Ship-to-Ship Transfer (STS), is an entirely legal method of selling oil mid-journey practiced before the war. However, post-sanctions, it has become a loophole for selling Russian oil.

This is not only Georgia’s experience. Similar practices occur in neutral waters, such as in the Aegean and Red Seas.

Bloomberg was already reporting on ship-to-ship transfers of Russian oil in 2023. According to their article, in just two months of 2023, at least 23 million barrels of Russian oil were transferred from one tanker to another in Greece’s Laconicos Bay to be sold, bypassing sanctions. Greek officials stated that they are limited in preventing this, as the transfers occur outside the country’s territorial waters.

International media indicates this is just one example. Traders and shipping companies have found multiple ways to sell Russian oil. They also use areas near Spain’s North African enclave of Ceuta.

Using the pseudonym Giorgi, a sailor, has been a seafarer for years and has worked on various ships, primarily tankers transporting oil. We met him in Kulevi. He told us that sometimes he doesn’t know where the oil is ultimately being taken and learns about the destination during the voyage. We met him in December 2024 when his ship was preparing to load oil at the port.

“Now we’ll load Georgian oil, then go to sea for a few days. We’ll come back and add the remaining cargo. We don’t know where it’s going yet. We’ll find out when we leave. Probably to Bulgaria or Turkey,” Giorgi told us.

He also confirmed that sometimes his ship carries oil from Russia without knowing the final destination.

Another source is Alexi (name changed), who has been a ship captain for over 20 years. He explained that often, even the captain does not know where the cargo on his tanker will ultimately end up.

“For example, a ship loaded with oil at Batumi or Kulevi port may not yet be sold. Let’s say it’s carrying 100,000 tons of oil bound for Greece. Before it reaches Greece, the hiring company looks for a buyer. The ship reaches the middle of the sea, and at that point, the captain receives an order that the oil has been sold. The captain isn’t asked anything at all. An empty tanker approaches the Black Sea, and the oil is transferred. There’s nothing criminal about this, as it happens in neutral waters. Therefore, it does not fall under the customs regulations of any country,” Alexi told us.

“Georgian” oil in Europe

According to international estimates, Georgia’s oil reserves in 2016 amounted to 35 million barrels. Recent figures are unavailable, but this estimate likely hasn’t changed significantly. At most, the amount extracted annually by companies—approximately 40,000 tons yearly—would have been deducted.

The consumption of petroleum products has not increased significantly either. According to Geostat’s official data, if 1.4 million tons of petroleum products were consumed in 2021, by 2023, this figure had grown to 1.5 million tons, an increase of only 6%.

However, the sharp rise in imports and exports stands out, raising suspicions that imported oil is being sold to other countries. According to Georgia’s official foreign trade data, since the war in Ukraine in 2021, the export of oil and petroleum products to EU member states has increased by 1,465.%,  while globally, it has grown by approximately 440%.

The graph presents Georgia’s official data. However, we must also review the data from international markets, where the figures are even more impressive. Below is a graphic depicting export figures from Georgia exclusively to European Union countries.

In Georgia, the statistics for the import of oil and petroleum products do not increase as dramatically as exports.

In the overall import statistics, it is noteworthy that we have reduced oil imports from Azerbaijan in recent years while increasing imports from Russia and Central Asia.

Since the data from international and Georgian markets do not align, we decided to compare the number of tons of oil shipped from Russia to Georgia and the amount that entered Georgia. We suspected discrepancies here as well.

We compared Georgia’s official statistics with data from two international databases: Import Genius and Volza.

Import Genius is a private database that officially purchases information from various governments. According to their data, 2,096,934 tons of oil were sent from Russia to Georgia between 2022 and 2024 under three trade codes: 2709, 2710, and 2713. Meanwhile, Volza’s data indicates 5,906,535 tons of oil

Oil is imported by sea, rail, and road transport into the country. Even Georgia’s official statistics show that the import of petroleum products via rail transport has sharply increased in the past two years. Georgian citizens can observe this with their own eyes, as railroads are constantly busy with wagons from Russian companies. These include oil tankers belonging to “Russian Railways” (РЖД) and “Ruski Mir.”

In the second part of this investigation, we will detail these sanctioned oil transport companies and the exporter-importer companies involved in Georgia.

While working with the Volza database, we found that the origin of the oil (under HS2709 and HS2710 codes) imported from Georgia into the EU is also listed as Georgia. This involves tens of thousands of tons of oil annually.

Since oil extraction in Georgia does not exceed 40,000 tons annually, it becomes evident that oil produced in other countries is being “Georgianized” before reaching Europe. How does this happen technically?

Cargo exported or re-exported is accompanied by a Certificate of Origin (CO). This document contains the following information:

• Exporter’s name, registration code, address, and contact information;
• Importer’s name, registration code, address, and, if needed, the final destination country of the goods;
• Precise description of the exported goods (e.g., name, weight, volume, HS Code, quantity);
• The place of departure for the cargo, mode of transport (e.g., maritime, land, air), and the final destination port;
• Details of the certifying authority, date, and stamp;
• The name of the country where the goods were extracted or produced is the Country of Origin.

International markets also rely on origin documents when collecting their data. When the “Country of Origin” field lists Georgia, it indicates that the oil was either produced or processed in Georgia. Officially, the country of origin cannot be where the oil was exported or re-exported. For instance, if Russian-extracted oil is shipped from a Romanian port, Russia will be the country of origin, and Romania will be the exporter.

This raises even more questions: how was such a volume of “Georgian-origin” oil and petroleum products exported?

When and under what circumstances can information about the country of origin be altered? There are two possible ways this can happen, and our sources confirm that both occur in Georgia:

1. Physical mixing of oil:
   After oil is physically mixed, it becomes difficult to determine which oil belongs to which country. For example, suppose 25,000 tons of Russian crude arrive at a Georgian port mixed with 5,000 tons of oil extracted in Georgia. In that case, the cargo can then be exported to Europe as Georgian-origin oil. Once combined, it is challenging to establish which portion of the oil originates from sanctioned countries.

Four individuals working in ports, terminals, and the Maritime Transport Agency (who do not know each other and work in different roles) explained that oil arriving at ports by rail cannot be directly transferred onto tankers. The process follows: oil is first loaded into terminal reservoirs from railway tanks. From there, it is moved into tankers via pipelines when needed. In many cases, oil products of the same composition delivered by different companies are stored together in terminals, resulting in their mixing. Ultimately, oil products from various countries are blended, making it difficult to trace their origin.

“First, the oil is loaded into reservoirs, then it waits for the right time, price changes, or a buyer. Whether the oil comes from Russia, Azerbaijan, or Kazakhstan, it is stored in these reservoirs and later transferred onto a ship. It’s not as though Russian or Kazakh oil is stored separately in individual reservoirs. For example, in Kulevi, a reservoir with a 50,000-ton capacity might hold 30,000 tons of Kazakh oil. Then, 20,000 tons of Russian oil might arrive and get mixed with the Kazakh oil. Once exported, it is labeled as Kazakh oil. You won’t be able to trace this back—it’s tough to determine,” said a former ship captain with over 20 years of experience in this field.

2. Changes to the oil’s origin documentation:
   This can occur at the port, a distribution point, or the company that imported the oil from a foreign country. All cargo entering Georgia by rail through Azerbaijan undergoes initial inspection at the Gardabani railway station. We asked a Gardabani railway employee how oil continues to arrive from Russia at the same intensity as before the war and how it gets exported to Europe despite sanctions. He explained it as follows:
   “Europe doesn’t know that the cargo is Russian. Georgia just labels it as its own [production] and sends it… It depends on the company. A company takes the cargo, [changes the origin documentation], and sends it to Europe.”

He added that it is possible to bring oil to a Georgian company and designate Georgia as the country of origin: “Yes. Or they might label it as coming from Kazakhstan rather than Russia. A company can do whatever it wants. This is possible. Then it’s exported to Europe by ship from Poti or Batumi.”

Georgian media frequently circulated videos and photos of Russian wagons or ships at Georgian railways and ports, including as recently as January 2025. According to reports, a tanker loaded with oil from sanctioned Rosneft was docked at the port of Batumi.

In June 2022, several anonymous and public sources told “Mtavari Arkhi” that a tanker loaded with sanctioned Russian oil was at the port of Batumi. Sources stated that efforts were being made in Georgia to change the origin of the oil so that it could be exported to Europe.

International media has also reported similar cases in different countries. For example, in 2023, Bloomberg wrote that as the EU reduced oil imports, Russia was forced to shift to markets in China and India.

“India is playing an increasingly important role in global markets, as it buys more cheap Russian oil and processes it into fuel for Europe and the US… When Russian oil is processed outside the EU, such as in India, the refined product is not considered Russian origin and can be supplied to the EU,” the outlet reported in a February 2023 article.

In November 2023, Politico reported on the trade of Russian oil in Bulgaria. According to the investigation, the EU allowed Bulgaria to replenish its oil supplies from Russia under exceptional rules. However, the investigation revealed that “Lukoil,” a Russian-origin company with the largest oil refinery in Bulgaria, “Neftohim Burgas,” was processing Russian oil and exporting it to Europe, bypassing sanctions. “Lukoil” generated approximately 1 billion euro in revenue for Russia through this. Data from the Comtrade database confirmed Politico’s investigation. Between 2022 and 2023, Bulgaria exported a considerable quantity of oil globally: While the country exported an average of $1.1 billion worth of oil in 2020-2021, this figure rose to $4 billion in 2022 and $2.7 billion in 2023.

Our database analysis highlighted three countries—Belgium, Italy, and Spain—that received large quantities of so-called “Georgian-origin” oil. We contacted these countries’ customs departments and supervising ministries, asking what they knew about these shipments and whether they suspected Georgia was not the actual country of origin. We also inquired whether they had initiated investigations into the true origin of the cargo.

Only Spain responded. The press office of Spain’s Tax Agency informed us that in 2023-2024, 99,000 tons of Georgian oil, worth $49 million, were imported into Spain. This data matches the information we found in the Volza and Comtrade databases. In response to other questions, they stated that various methods are used to identify products of Russian origin. However, when goods of Russian origin first enter another EU country before arriving in Spain, they often do not conduct additional checks. This approach may also apply to oil received from Georgia.

We did not receive any responses from the agencies in Belgium or Italy, nor did we hear back from Georgia’s Revenue Service.

Sources used in the material

Data from international databases obtained with the assistance of OCCRP ID

Worked on the material: 
Investigative Journalists: Natia Mikhelidze, Aidan Yusifi, Eto Midelashvili
Editor: Nino Bakradze
Designer: Nino Gagua