Threat Assessment

Black Sea 04 March 2024

Type Level Trend

Terrorism Moderate Unchanged

Piracy Low Unchanged

Insurgency and Military Operations Severe Up

Cargo Theft Moderate Unchanged

Smuggling High Up

Stowaways and Human Trafficking Moderate Unchanged

Fraud and Corruption Elevated Unchanged

Activism Moderate Unchanged

Summary
Risk Intelligence guidance on the situation in Ukraine:
https://admin.riskintelligence.eu/system/files/documents/guidance_on_operations_related_to_the_ukraine-russia_conflict.pdf

Martial law, introduced on 24 FEB 2022 in Ukraine, remains in place. This includes localised nightly curfews - which can vary.

The war continues to develop and the general threat picture remains dominated by the ongoing Russian war with Ukraine. There remains
an increased presence of naval assets in the area, which increases the possibility of a quick escalation and there is an ongoing severe
threat from military operations in the northwestern, area of the Black Sea. Implications for operating in the northern Black Sea area, in
particular, can include complications with crew changes, with known cases of complications based on nationality, and possible collateral
damage to vessels caught in Ukrainian ports or in the vicinity of, where the ports cities are being targeted by shelling as a consequence
of the ongoing war. Furthermore, regional maritime operations can be affected by the sanctions targeting Russian trade and trade with
Russia.

Reported warnings of mine danger, particularly, in the north-west area of the Black Sea - but also reports of, what is likely, sea-mines
drifting which have impacted some maritime operations in the wider sea - similar future incidents cannot be ruled out. Additionally, some
reports indicate the added possibility of encountering drifting landmines, following the breeching of the Nova Kakhovka dam, the water
from which has washed away the landmines. Some have been spotted long the Odessa Oblast coast.

Following the withdrawal, by Russia from the BSGI, on 17 July 2023, Russia announced that any ships travelling to Ukraine's Black Sea
ports will viewed by the Russian military as possibly carrying military cargo, meaning that they will be legitimate military targets. It
remains uncertain if Russia is willing to act on this, but the threat highlights the Russian focus to impact any traffic into Ukrainian Black
Sea ports. Nevertheless, this is in effect reinstating the Russian prohibition of navigation north of 45-21N. Subsequently, the Ukrainian
Defence Ministry announced, what seemed in response to the Russian announcement, that Ukraine would also consider all vessels
travelling to Russian Black Sea ports as potential carriers of military cargo, and as legitimate targets. It is also unclear to what degree
Ukraine is prepared to act on its statement. The overall security situation can change at short notice and without prior warning.

Wider area threats include incidents of GPS spoofing, fraud and corruption and smuggling. Politically charged demonstrations can also
impact normal operations, although these are not known to directly target the maritime sector. Irregular migration crossing the Black
Sea is a lesser threat than for the Mediterranean Sea. However, a smaller number of migrants have previously been intercepted
attempting to cross the Black Sea, often trying to reach Bulgaria or Romania. It is not assessed that this will become an increasing threat
in the near term.

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The general threat of terrorism must also be taken into account - although such incidents are more likely, given previous incidents and the
general political climate, to target in-country political representations and institutions, including police and military instillations in the
countries surrounding the Black Sea. Russia has its own problems in the region with Islamic extremism in the Caucasus, in
particular from the Chechen Islamist groups, and Turkey conducts counter-terror operations against Kurdish Separatists. For Georgia the
coastal region of Abkhazia, remains a conflict zone and landmines are reported to be in the region.

Protests have previously occurred in Bulgaria on issues including the transshipment of illicit drugs, arms, counterfeit goods
and trafficking in persons and the movement of irregular migrants into Europe's eastern border. As a consequence of unregulated
transport services, public transport operators are known to orchestrate strikes in multiple cities. The protests can affect port operations,
though most likely the impact is indirect, for instance road-closures, which form part of the protest route.

Terrorism
Level: Moderate
Trend: Unchanged
Following the Russian invasion of Ukraine on 24 FEB 2022, an assessment of a general threat of terrorism in Ukraine remains influenced
by this ongoing war. Any current assessment must be viewed in the context of how this influences the regional situation. Prior to the
recent Russian invasion the threat of terrorism was assessed as moderate and was mostly connected to the then ongoing conflict with
pro-Russian rebels in the eastern part of Ukraine - where the threat was assessed as being higher. Since the invasion there are incidents
in both Russia and Ukraine which have been reported as terrorism activity and would, under other circumstances, most likely be
categorised as such. However, these incidents are more likely to have a connection to the ongoing hostilities than any particular group
undertaking terrorism operations to achieve a specific goal.

For the wider Black Sea region, counter-terror operations do take place in all surrounding countries, to varying degrees. However, the
direct impact, of terrorism activity, on shipping operations is, in general, assessed as less likely. For Turkey there are terrorist elements
such as Kurdish separatists and various loosely affiliated Islamist sympathisers. Counter-terror operations are often reported as part of
police investigations. However, these are not known to focus on or target the maritime sector.

The threat from terrorism, for the rest of the Black Sea, in relations to maritime operations is assessed as lower. Although counter terror
operations do take place in Romania, Bulgaria, Georgia these are considered as unlikely to target or impact the maritime sector.

Piracy
Level: Low
Trend: Unchanged
The threat of piracy is considered low.

There has been no reported piracy activity in the region and there are no known reported maritime-related activity that could be
categorised as piracy and no actors are known to engage in piracy activity in the area.

Insurgency and Military Operations

Level: Severe
Trend: Up
The current regional threat from insurgency and military operations in relation to the maritime operations, in the Black Sea,
remains heightened. This reflects the ongoing war in Ukraine with Russia with both announcing that merchant vessel transiting to each
others' regional ports, might be considered parties to each side of war, and therefore as possible targets.

Although there is a general heightened threat to maritime operations in the Black Sea, the threat picture does vary, with the threat to
operations in southern Black Sea is largely considered lower than in the northern area. In particular in relation to the northwestern area of
the Black Sea - including the Danube delta and the Sulina Canal - and around the Crimean peninsular and the Sea of Azov, where
the overall threat picture regarding insurgency and military operations is assessed as severe, reflecting the current and continuously
developing war in Ukraine and within Ukrainian territorial waters. For the rest of the Black Sea the threats are assessed as lower.

There are insurgency and military operations taking place involving Ukraine and Russia and there remains an increased likelihood of
encountering naval operations in the Black Sea and the disturbance to normal maritime operations should be expected.

The announced prohibited access to the north-west area of the Black Sea, north of 45° 21’, as announced by the Russian Navy (26 FEB
2022) and that vessels in this area will be regarded as a terrorist threat, is assessed as remaining in place - although it also remains
unknown how or if the Russian navy would continue to enforce the ban. The overall security situation can change at short notice and
without prior warning. Furthermore, ongoing reports indicate that mines remain a threat - with especially mines that are drifting, present a
wider and increased threat when operating in the area. Although these may originally have deployed in the northern Black Sea, for
instance as part of the Ukrainian coastal defences, circumstances such as weather conditions may result in them drifting, including

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reports of mines being disposed of along the Romanian, Bulgarian and Turkish coastlines. Although likely, any specific connection of
individual mines to the war in Ukraine is uncertain.

Incidents of GPS signal interference, state-sponsored or otherwise, are known to occur at multiple locations, and this is a threat that
should be taken into consideration. Harassment and the detention of vessels operating in the Black Sea and the Sea of Azov, by both
Russian and Ukrainian authorities, has previously been reported and similar future incidents cannot be ruled out.

Turkey is also engaged in a separate conflict targeting Kurdish forces in both Syria and Iraq, and the eastern Turkish
provinces. Additionally, in Georgia, the breakaway regions of South Ossetia and Abkhazia and the Administrative Boundary Lines with
Abkhazia and South Ossetia, also continues to be an elevated threat of military and insurgency activity. However, neither of these are
assessed to present any significant impact to maritime operations.

Cargo Theft
Level: Moderate
Trend: Unchanged
The threat of cargo theft, in relation to maritime operations is generally assessed as overall moderate, however, the actual threat is likely
to vary depending on geographical location.

Given the current and ongoing war with Russia, following the Russian invasion of Ukraine on 24 FEB 2022, an assessment of a general
threat of cargo theft in Ukraine remains unclear. Therefore, regarding Ukraine, any current assessment must be viewed in the context of
the countrywide situation, which is being significantly affected due to the ongoing conflict.

Localised crime is assessed as endemic in the region, in particular in Russia, Ukraine, Turkey, Bulgaria and Romania and in most
countries, mainly orchestrated, by organised criminal groups. Container traffic, and cargo transiting between modes of transport and
storage facilities, has always been seen as an easier and more likely target for criminals and containers have reportedly been intercepted
in one port and rerouted to another. This likelihood increases with any potential delays which may hold up cargo transportation. Although
comparable statistical information on the types of theft and occurrence, is not readily available, and a degree of under-reporting is
expected. Although crime is assessed as endemic throughout the region - some local variations are likely, including a variation in
the degree of incidents, types of cargo targeted and general modus operandi by the crime groups. The levels of corruption in the different
countries also influences on these factors. Although a degree of direct threat of cargo theft from vessels, opportunistic or organised,
cannot be ruled out, this is threat is assessed as lower than cargo theft from port facilities.

Smuggling
Level: High
Trend: Up
The threat of smuggling in relation to maritime operations is generally assessed as high, however, the actual threat level is likely to vary
depending on the geographical location.

Given the current and ongoing war between Russia and Ukraine, following the Russian invasion of Ukraine on 24 FEB 2022, an
assessment of the threat of smuggling in relation to Ukraine remains unclear - although an increase in smuggling, or other illicit
transportation of goods does has been extensively reported, assessed as a result of the war.

The exact extent that smuggling activity directly impacts individual port operations and individual vessels varies, but reports of illicit
goods, including weapons and narcotics, being smuggled through the regional Black Sea ports are known. However, smuggling activities
of all commodities in the Black Sea region are known and the region is widely used for the movement of weapons, cigarettes and
narcotics. Russian and eastern European weapon manufacturers often use ports in the Black Sea for moving illicit military cargoes, in
particular to the Middle East and Africa. Military cargoes are often disguised on cargo manifests and are often moved through multiple
ports to hide origin and identity and to circumvent international bans on arms sales. Tobacco smuggling, both genuine and counterfeit, is
often routed through or destined for countries in the region. Turkey and also Turkish-controlled Northern Cyprus are key hubs in the
movement of illicit tobacco products.

Smuggling of narcotics is also endemic in the region. The Black Sea is a principle destination point for heroin from Afghanistan and Asia
– and more recently from South America. Turkey has also long been associated with the smuggling of heroin, as has Russia. Smuggling
of general commodities takes place in Ukraine. Criminal groups from all countries have their own distinct transit routes for the movement
of narcotics, and maritime routes are often utilised, particularly across the Black Sea, typically for further distribution into Europe. As well
as heroin, synthetic drugs and the chemical precursors to make them are increasingly becoming more common, particularly in Bulgaria
and Turkey. It should be noted that the movement of narcotics is widespread and a problem for all countries in the region.

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Incidents of custom personnel, in the various countries, being involved in the smuggling operations, have been reported, which also
indicates to a likely degree of associated corruption.

Stowaways and Human Trafficking

Level: Moderate
Trend: Unchanged
The threat of human trafficking, in relation to maritime operations, is overall, assessed as moderate.

The current and ongoing war with Russia, following the Russian invasion of Ukraine on 24 FEB 2022, strongly affects the
overall assessment for Ukraine, and any current assessment must be viewed in the context of the countrywide situation.

On a whole crossing the Black Sea is a much less preferred route for people smugglers, mainly given the difficulty of the sea, but also
due to possible land-routes. Nevertheless, some incidents are occasionally reported and the occurrence cannot be completely ruled out.
Furthermore, the countries surrounding the Black Sea have various issues with irregular migration and people smugglers are known to
use both land routes and sea routes to cross the Black Sea – although at much lower levels than the Mediterranean Sea - previously
often, though not exclusively, organised by Ukrainian and Turkish people smugglers.

Of all the Black Sea countries Turkey remains the most used gateway for migrants, primarily from Syria, Iraq and Afghanistan but also
from other regions, seeking access to Europe. People smugglers facilitating irregular migration include, amongst others, Turkish and
Ukrainian nationals. For all vessels calling at Turkish ports, the threat of stowaways is higher, especially for vessels that move on regular
scheduled trips to mainland Europe. Vessels that exclusively transit the Black Sea are now considered either highly likely to move
clandestine migrants on the initial part of their journey to Europe - or to be targeted by people smugglers for such activity.

Fraud and Corruption

Level: Elevated
Trend: Unchanged
The overall threat from corruption is overall assessed as elevated,

Given the current and ongoing conflict with Russia, following the Russian invasion of Ukraine on 24 FEB 2022, an assessment of a
general threat of fraud and corruption in Ukraine remains uncertain. Any current assessment must be viewed in this context which is
unlikely to change significantly in the near term.

Although the overall threat of fraud and corruption is assessed as elevated, local variations are to be expected and the actual impact may
therefore be experienced as higher or lower, depending on the circumstances. The wider region is known to be plagued with corruption
and fraud, with also the EU countries of Bulgaria and Romania reported as having significant issues. Although it is not always clear how
the general occurrence of corruption directly affects maritime operations, it is assessed that it does, to varying degrees. International
reports, focussing on corruption, indicate that all the surrounding countries have varying degrees of corruption in both the public and
private sector. Georgia being the country considered the least corrupt and making the most progress in combating corruption.

A general lack of available and comparable data regarding impact on operations in specific ports, means any direct comparison would
not be useful, however, the assessment is considered within the wider context of fraud and corruption activity, throughout the region, and
is assessed as a significant issue at all levels of business and public administration. There is no specific information to suggest that the
maritime domain is more or less corrupt, but therefore fraud and corruption the maritime sector can also not be ruled out and reports of
wide spread smuggling activity further indicates that a significant degree of corruption takes place.

Activism
Level: Moderate
Trend: Unchanged
The threat activism towards maritime operations is assessed as moderate.

The Black Sea region countries do see a notable amount of civic activism. However, not all authorities react in the same way and
demonstrations, including permitted ones, have the propensity to turn violent and clash with the local police. Impact on the maritime
sector cannot be ruled out, as indirect consequences of either an escalation of activism or the response by authorities may have a
negative effect on normal operations.

Given the current and ongoing war Ukraine and Russia, following the Russian invasion of Ukraine on 24 FEB 2022, an assessment of a
general threat from activism in Ukraine remains unclear. Any current assessment must be viewed in the context of the countrywide
situation including the ongoing Martial law, and a nighttime curfew, which also affects activism and though demonstrations now
predominantly are against the Russian invasion, the wider complications stemming from the conflict are more likely than activism to
affect maritime operations.

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Activism as directly targeting the maritime sector, is considered less likely. However, there are varying degrees of activism in the region.
Demonstrations against government policies do occur – with regularity increasing during election periods. Incidents of activism,
focussing on pollution and environmental issues, have also occasionally been reported. Protests with an environmental focus can disrupt
normal maritime operations. Demonstrations, in all the bordering countries, have previously seen differing levels of violence. In summary,
activism could well turn into an issue for maritime operations in Ukraine, Russia and Turkey. It is less likely to affect maritime operations
in Georgia, Romania or Bulgaria, but should not be discounted in security planning. In general, as protests, politically charged or
otherwise, can result in severe responses from the authorities.

In Russia, the principal demonstrations are from political opposition; these are also met with a degree of intolerance by the police and
security services. Political assassinations are known to occur and are widely reported in Western media.

In Georgia, there is a degree of anti-Russian feeling that remains following the short-lived conflict between the two countries. Protests
against Georgian political interference are common in South Ossetia and in Abkhazia. Demonstrations against Russian interference often
take place, but are not supported by the ruling political parties, avoiding the risk of a diplomatic issue.

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