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Organizing the Pillage

A new report about Russian occupying authorities illegally appropriating agricultural assets in occupied parts of Kherson Oblast


In a recent report, Project Expedite Justice (PEJ) highlights how Russian occupying authorities and newly established Russian companies conspired to take over Ukrainian agribusinesses and control the grain trade in occupied parts of Kherson Oblast. 


Soon after the full-scale invasion of Ukraine in February 2022 and the accompanying military looting of stocked grain, Russian occupiers rolled out a more meticulous, deliberate policy of pillage of all agricultural assets. Through official decrees, orders, and decisions, a so-called “Governor,” alongside other Russian authorities and surrogates, wrested supposedly “ownerless” business objects from Ukrainian companies. PEJ collected evidence of 52 agro-industrial companies that the occupying authorities unlawfully appropriated and temporarily transferred to Russian-registered private companies and parastate organizations. Using subsidies and export licensing policies, the authorities positioned a handful of these companies to lead the wholesale storage and export of stolen grain via occupied Crimea.


As PEJ Investigator Bohdan Bernatskyi said, “After the full-scale invasion, the Kremlin quickly installed former Ukrainian politician Vladimir Saldo to head the so-called Military Civilian administration in Kherson Oblast and appointed him Governor after the illegal annexation on November 30, 2022. Using his very active media profile, Saldo told business owners to return – if ready to work under Russian law. At the same time, he cast a harsh verdict of nationalization on enterprises belonging to those ‘supporting aggression against Russia.’ Meanwhile, some Russian companies work hand in hand with the occupying authorities. They identify vacant businesses and appeal to the authorities to take over management. These appeals are often granted.”


PEJ investigators and analysts were able to collect evidence and reconstruct a detailed timeline. It illuminates the systematic transfer of all agricultural properties and lands to Russian control. This crime stripped vast sums of wealth from Ukraine.


Russian authorities in Kherson Oblast constitute an “Occupying Power.” The report describes how the blatant dispossession of Ukrainian agricultural resources by an “Occupying Power” violated international humanitarian law (IHL) on multiple counts. Under the Rome Statute, which criminalizes IHL, the conduct of responsible officials and businesspeople may amount to the war crimes of “pillage” and “seizing enemy property.” While strong indications of such crimes exist, further investigation is required to prove criminal responsibility for them.


PEJ Legal and Program Director Pascal Turlan said, “Both national courts and the International Criminal Court (ICC) have jurisdiction over the situation in Ukraine, which has been under ICC investigation since March 2, 2022. The Rome Statute establishes a threshold for the Court's exercise of jurisdiction over war crimes, in particular when committed as part of a plan or policy or as part of a large-scale commission of such crimes. Although it is not a jurisdictional prerequisite, the fact that we see a clear policy of pillage established in Kherson Oblast should be of particular interest to the Court. In the meantime, we will continue to bring evidence of such crimes before the Prosecutor General Office to achieve accountability for the many people impacted by the systematic pillage of Ukraine’s resources.”


Since early 2022, PEJ has worked to ensure accountability for those affected by the Russian aggression in Ukraine. Through its Ukraine program, PEJ has reached out to parties throughout the country to document international crimes and harms. The widespread abuses we have investigated include attacks against the civilian population, destruction of civilian property, pillaging, resource plunder, improper mining, destruction of the environment, and sanctions violations. 


PEJ is helping Ukrainians understand the legal bases on which they can seek redress and connecting them with the most appropriate and effective accountability mechanisms. We collect information, provide custom expert- and technical-based support, and lead investigative and information collection activities. With an array of partners, PEJ prepares analysis and evidentiary packages and legal briefs to support judicial cases, sanctions submissions, and compensation claims. We help track suspects and their assets.


For questions or media inquiries, please contact ukraine@projectexpeditejustice.org. 


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