LLC Omega Energy (the claimant) applied to arrest the Tassos, owned by Tassos International Ltd (the defendant), to secure a future claim for damages arising from the loss of oil cargo. The preliminary value of the lost cargo was USD 1,364,122.97.

The Tassos was sanctioned by the US government on 31 July 2025. The ship, laden with oil originating in Russia, was en route to Vadinar, India. The buyer rejected the goods, and the ship was ordered to proceed to Vostochniy. From 31 October-2 November 2025, the oil on the Tassos was transhipped to the Yi Tong. The survey report showed that the Yi Tong's tanks were completely empty at the time the transhipment commenced. On the same day, the surveyors found that part of the cargo transhipped was water instead of oil. The claimant sought damages for the loss of this part of the cargo.

The claimant argued that the Tassos's master and crew provided no explanation or comment to the surveyors; before the surveyors arrived to inspect the Tassos's tanks, they had been washed; the ship could leave Russia or be sold to another person; the defendant had no property other than the ship. For these reasons, the claimant argued that the defendant aimed to avoid liability, and that if the ship was not arrested, the claimant could not enforce its claim.

Held: The arrest is granted.

Under art 90(2) of the Commercial Procedure Code of Russia (the CPC RF), a security measure is granted if its absence would make enforcement of a judgment impossible or more difficult, including in cases where enforcement is expected to be carried out outside Russia. Under s 14 of the Resolution of the Plenum of the Supreme Court of Russia No 15, dated 1 June 2023 (Resolution No 15), a court should establish the grounds for granting the security measure, how it is connected to the claim, whether it is proportionate to the claim, and whether it serves the statutory purpose of security measures. To prevent significant losses to the claimant, security measures can be aimed at maintaining the status quo in the parties' relationships.

Under s 15 of Resolution No 15, security measures are an expedited and preliminary remedy, so it is not necessary to submit evidence in the volume that would be required in proceedings on the merits. Modern legislation does not stipulate any special circumstances that must be established to grant a security measure. Therefore, the measure is discretionary.

According to art 388(1) of the Merchant Shipping Code of Russia (the MSC RF), arrest is any detention or moving restriction relating to the ship when it is located in Russia. A security measure can only be imposed on property that is owned and held by the defendant. Under art 389 of the MSC RF, a ship can be arrested only for a maritime claim. Under art 390(1) of the MSC RF, the ship in relation to which a maritime claim arose can be arrested. In the present case, the maritime claim arose in relation to the Tassos.

After considering the claimant’s arguments, the Court decided that the arrest should be granted as it was in accordance with the statutory purpose of security measures. The ship was arrested.