Security Council: United Nations

United Nations S/2021/229
Security Council Distr.: General

8 March 2021
Original: English
Letter dated 8 March 2021 from the Panel of Experts on Libya

established pursuant to resolution 1973 (2011) addressed to the
President of the Security Council
The Panel of Experts on Libya established pursuant to Security Council

resolution 1973 (2011) has the honour to transmit herewith, in accordance with
paragraph 12 of resolution 2509 (2020), the final report on its work.
The report was provided to the Security Council Committee established
pursuant to resolution 1970 (2011) concerning Libya on 18 February 2021 and was
considered by the Committee on 5 March 2021.
The Panel would appreciate it if the present letter and the report were brought
to the attention of the members of the Security Council and issued as a document of
the Council.
(Signed) Lipika Majumdar Roy Choudhury

Coordinator
Panel of Experts established pursuant to resolution 1973 (2011)
(Signed) Alia Aoun
Expert
(Signed) Dina Badawy
Expert
(Signed) Luis Antonio de Alburquerque Bacardit
Expert
(Signed) Yassine Marjane
Expert
(Signed) Adrian Wilkinson
Expert
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S/2021/229
Final report of the Panel of Experts on Libya established pursuant

to Security Council resolution 1973 (2011)
Summary
The military conflict triggered by the attack on Tripoli by armed groups
affiliated with Khalifa Haftar on 4 April 2019 dominated the first half of 2020.
Throughout and beyond the armed confrontation, Haftar Affiliated Forces (HAF) and
the Government of National Accord continued to receive increasing support from
State and non-State actors. In January 2020, HAF took control of critical oil terminals
and fields, leading to a de facto oil blockade. The Government of National Accord
regained control of the western coast in April 2020, pushed HAF away from the
environs of Tripoli by early in June 2020 and shifted the battle lines to the central
region of Sirte and Jufrah by July 2020. Throughout August and into October 2020,
ceasefire negotiations between both parties’ military commanders were held under the
auspices of the United Nations Support Mission in Libya (UNSMIL). Simultaneously,
an agreement to temporarily freeze oil revenue facilitated an end to the oil blockade
by HAF and the gradual lifting of an order of force majeure on the oil facilities by the
National Oil Corporation. On 23 October 2020, UNSMIL announced the terms of a
ceasefire agreement that the Libyan parties had signed, although their commitment to
its implementation remains questionable. On 7 November 2020, UNSMIL launched a
political negotiation track, known as the Libyan Political Dialogue Forum.
Throughout its mandate, the Panel of Experts on Libya has identified multiple
acts that threatened the peace, stability or security of Libya, and increased attacks
against State institutions and installations. Civilians in Libya, including migrants and
asylum seekers, continue to endure widespread international humanitarian law and
international human rights law violations and human rights abuses. Designated
terrorist groups remained active in Libya, albeit with diminished activities. Their acts
of violence continue to have a disruptive effect on the stability and security of the
country.
The arms embargo remains totally ineffective. For those Member States directly
supporting the parties to the conflict, the violations are extensive, blatant and with
complete disregard for the sanctions measures. Their control of the entire supply chain
complicates detection, disruption or interdiction. These two factors make any
implementation of the arms embargo more difficult.
Eastern authorities have continued their efforts to illicitly export crude oil and
to import aviation fuel. The impact of the coronavirus disease (COVID-19) outbreak
in global demand and bunker prices has brought illicit exports of refined petroleum
products by sea to a temporary halt. Fuel continues to be smuggled overland, although
at a small scale.
Evidence points to a persistent lack of transparency in beneficial and legal
ownership, financial dealings and control of investment within the designated entities.
One case of non-compliance with the assets freeze has been identified. The activities
of subsidiaries require monitoring. The impact of sanctions was not accurately
projected by the Libyan Investment Authority. Various issues regarding access to frozen
funds and a lack of a uniform approach to the freezing of assets require resolution.
Implementation of the assets freeze and travel ban measures with regard to
designated individuals remains ineffective.
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Contents
Page
I. Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
A. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
B. Cooperation with stakeholders and institutions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
II. Acts that threaten the peace, stability or security of Libya or obstruct or undermine
the successful completion of its political transition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
A. Libyan armed group dynamics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
B. International terrorist groups and individuals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
C. Foreign armed groups and fighters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
D. Acts that may lead to or result in the misappropriation of Libyan State funds . . 8
E. Acts that obstruct or undermine the successful completion of the political
transition in Libya . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
F. Attacks against any air, land or seaport in Libya. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
G. Attacks against State institutions or installations in Libya . . . . . . . . . . . . . . . . . . . . 9
H. Acts that violate applicable international human rights law or international
humanitarian law, or that constitute human rights abuses . . . . . . . . . . . . . . . . . . . . . 10
III. Implementation of the arms embargo . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
A. Investigative challenges . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
B. Impact on conflict dynamics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
C. Maritime violations and interdictions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
D. Arms embargo import violations by Member States . . . . . . . . . . . . . . . . . . . . . . . . . 21
E. Arms embargo export violation by a Member State . . . . . . . . . . . . . . . . . . . . . . . . . . 27
F. Air bridges . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
G. Private military and security company involvement . . . . . . . . . . . . . . . . . . . . . . . . . 30
H. Responses to arms embargo violations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
I. Updates to reported violations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
IV. Unity of State institutions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
A. Central Bank of Libya . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
B. Libyan Investment Authority . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
C. National Oil Corporation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
V. Prevention of illicit exports or illicit imports of petroleum . . . . . . . . . . . . . . . . . . . . . . . . 36
A. Attempts to illicitly export crude oil . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
B. Prevention of illicit exports of refined petroleum products . . . . . . . . . . . . . . . . . . . 36
C. Illicit import of aviation fuel. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
VI. Implementation of the assets freeze on designated entities . . . . . . . . . . . . . . . . . . . . . . . . 38
A. Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
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B. Transformation strategy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
C. Subsidiaries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
D. Impact of sanctions on frozen funds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41
E. Access to frozen funds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43
VII. Implementation of the assets freeze and travel ban on designated individuals . . . . . . 45
A. Update on non-compliance with the travel ban . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
B. Updates on designated individuals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
C. Actions taken for the effective implementation of the assets freeze and travel
ban measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
VIII. Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
IX. Annexes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48
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I. Background
A. Introduction
1. The present report, provided to the Security Council Committee pursuant to

paragraph 12 of resolution 2509 (2020), covers the period from the submission of the
Panel of Experts’ previous report (S/2019/914) on 25 October 2019 until 24 January
2021.1 It includes updates on ongoing investigations detailed therein. An overview of the
evolution of the sanctions regime concerning Libya can be found in annex 1 to the report. 2
2. In conducting its investigations, the Panel complied with the best practices and
methods recommended by the Informal Working Group of the Security Council on
General Issues of Sanctions (see S/2006/997). The Panel has maintained the highest
achievable standard of proof, even though travel to Libya and other destinations was
restricted owing to the coronavirus disease (COVID-19) pandemic.
3. The Panel relied on corroborated evidence and adhered to its standards in respect
of the opportunity to reply. 3 The Panel has maintained transparency, objectivity,
impartiality and independence in its investigations.
B. Cooperation with stakeholders and institutions
4. A list of Member States, organizations and individuals consulted can be found

in annex 4. Panel correspondence records can be found in annex 5. The Panel
maintained contact with the Committee, Member States and other interlocutors,
including other Panels of Experts, through electronic platforms. The Panel also
submitted 13 updates to the Committee on issues of significance.
5. The Panel benefited from regular exchanges with the United Nations Support
Mission in Libya (UNSMIL). The European Union military operation in the
Mediterranean (operation IRINI) also supported the Panel, specifically its
investigations into non-compliance of the arms embargo by both parties to the conflict
and on the illicit importation and exportation of petroleum products.
6. The Panel travelled to Libya in late November 2020 and acknowledges the travel
difficulties caused by to COVID-19 restrictions. However, the Panel’s travel to Libya
remains crucial to its mission and should be given priority by Member States and
supporting United Nations bodies.
7. The Libyan National Army (LNA) focal point has not responded to any
correspondence from the Panel, notwithstanding his participation in a videoconference
on 8 May 2020. On 20 July 2020, the focal point informed the Panel that he was being
replaced with a new liaison committee. No contact information has been provided and
attempts to contact LNA officials to address the issue have not been successful.
__________________
1
All hyperlinks accessed on 31 January 2021.
2
The annexes are being circulated in the language of submission only and without formal editing.
Owing to the word limits on reports of monitoring mechanisms, the Panel has provided further
details relating to a number of investigations in the annexes. A table of abbreviations and
acronyms can be found in annex 2.
3
Further information on methodology and the opportunity to reply can be found in annex 3.
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II. Acts that threaten the peace, stability or security of Libya or

obstruct or undermine the successful completion of its
political transition
A. Libyan armed group dynamics
8. The Panel noted the increased consolidation of various armed groups or their
leaders under the direct authority of the Presidency Council. The continued
infiltration by armed groups in State institutions, in particular by the Nawasi Brigade,
Ghenewa and the Special Deterrence Force, unduly legitimizes these groups and
fosters competition within the security structure (see annex 6).
9. A common modus operandi of armed groups is to use recordings as blackmail
to obtain coveted government positions, which give them access to power and money.
10. According to confidential sources, in late November 2020, Tripoli
Revolutionary Brigade leader Haitham Tajouri attempted to return to Tripoli from the
United Arab Emirates via Tunisia but was blocked by the Tunisian authorities. On
11 December 2020, social media reported Tajouri’s presence in Libya. 4 He has since
met other militia leaders and members, including designated individual Mohamed Al
Amin Al-Arabi Kashlaf (LYi.025) and Nawasi Brigade affiliate Muhammad Abu
Dara’, in Zawiyah. These developments signal a further realignment of armed groups,
which is intended to undermine the Ministry of Interior (see annex 6).
11. On 10 November 2020, lawyer Hanan al-Baraasi was shot to death in broad
daylight while driving her car in a major street in Benghazi. An outspoken critic of
Khalifa Haftar, al-Baraasi had posted multiple live videos a day prior to her killing,
in which she criticized the financial corruption of LNA and promised to share
evidence implicating Haftar’s son, Saddam. 5 One and a half years after the unsolved
kidnapping of parliamentarian Siham Sergewa, the assassination of al-Baraasi is
another illustration of violent silencing of a female public figure.
B. International terrorist groups and individuals
12. The Government of National Accord Affiliated Forces (GNA-AF) and the Hafter
Affiliated Forces (HAF) have disrupted terrorist cells and arrested high-profile
individuals. Arrestees include the leader of Islamic State in Iraq and the Levant-Libya
(QDe.165), Abu Abdallah Al-Libi, and the leader of the Organization of Al-Qaida in
the Islamic Maghreb (QDe.014), Hassan Al-Washi. Such arrests contributed to the
decrease in terrorist attacks in the third quarter of 2020 (see annex 7).
1. Islamic State in Iraq and the Levant-Libya (QDe.165)

13. The threat from Islamic State in Iraq and the Levant-Libya (QDe.165) remains
moderate, owing in part to the arrest of its leadership. Its members are mainly in the
southern desert cities of Taraghin, Awbari and Ghadduwah. They transit the southern
borders of Libya with Chad, the Niger and the Sudan in small groups. Their activities
are financed primarily by engaging in oil and drugs smuggling. The group continues
to maintain sleeper cells in the coastal cities of Sabratah and Tripoli. Bani Walid
remains a safe haven for all terrorist groups, including Islamic State in Iraq and the
Levant-Libya (QDe.165).
__________________
4
See https://twitter.com/emad_badi/status/1337469823404679172, 11 December 2020.
5
See www.facebook.com/100055605323049/videos/153680939828749/, 10 November 2020.
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2. Organization of Al-Qaida in the Islamic Maghreb (QDe.014)

14. The Organization of Al-Qaida in the Islamic Maghreb (QDe.014) is dormant in
Libya, although cells still exist in, for example, Sabratah. On 28 November 2020, the
116th Tarek Ibn Ziyad battalion of HAF 6 arrested seven members of an Organization
of Al-Qaida in the Islamic Maghreb cell in Awbari.
3. Case of Mohamed Bahrun (Al Far)

15. An arrest warrant issued on 17 October 2017 by the Office of the Libyan Attorney
General, under case No.131, is extant for a Libyan national named Mohammed Bahrun
(also known as Al Far). The Office suspects him of belonging to Islamic State in Iraq
and the Levant-Libya (QDe.165) in Sabratah. The arrest warrant notwithstanding,
Mr. Bahrun continues as commander of the “Isnad Force” under Zawiyah General
Security Directorate of GNA-AF. Imagery of Bahrun posted in open source media show
him mistreating and humiliating HAF Brigadier General Mohamed Al-Jagm, whose
plane was downed by GNA-AF on 7 December 2020 (see annex 8).
C. Foreign armed groups and fighters
16. Chadian and Sudanese armed groups remain active in Libya and have taken part
in the conflict. Many Sudanese fighters were deployed to the frontlines of the Tripoli
campaign of HAF to fill defensive and security tasks. A significant presence of Syrian
fighters on both sides is further exacerbating insecurity within Libya.
1. Chadian opposition groups

17. The Conseil du commandment militaire pour le salut de la République declared
its neutrality on 26 June 2020 and is now located primarily in the border area of Chad
and Libya. It has lost its large-scale operational capacity after suffering splits and
desertion within its ranks.
18. The Front pour l’alternance et la concorde au Tchad, led by Mahdi Ali Mahamat,
has been expanding its presence from Jufrah to Sabha, Tamanhint and Birak in the
south of Libya. From these bases, they deploy to protect HAF military installations
and some oil installations.
2. Sudanese groups and impact of the Juba Agreement for Peace in the Sudan
19. The transitional Government of the Sudan and a coalition of armed groups called
the Sudanese Revolutionary Front, composed of at least 12 Sudanese opposition
groups, signed the Juba Agreement for Peace in the Sudan, 7 which, among other
arrangements, grants amnesty to opposition group members and stipulates the
inclusion of their leaders in the political process. The Agreement triggered the
movement of many Sudanese armed group members from Libya. The Sudan
Liberation Army-Minni Minawi has moved at least 40 vehicles to Darfur. Similarly,
dozens of Justice and Equality Movement vehicles have left Libyan territory for
__________________
6
These include the armed group previously referred to as Khalifa Haftar’s Libyan National Army
(which is now being restyled as the Libyan Arab Armed Forces), and domestic and fo reign armed
groups. The Panel uses “Haftar Affiliated Forces” (HAF) to cover all Haftar-affiliated armed
groups. The lower case is used to refer to armed groups that refer to themselves as, for example,
“Brigade” or “Battalion”, in order to identify the group without providing them with the
legitimacy of being a formed military unit of a government. Similarly, the lower case is used, if
appropriate, when referring to the authorities in the east of Libya.
7
Original full text available at https://constitutionnet.org/sites/default/files/2020-10/2020.10.03%20-
%20Juba%20peace%20agreement%20%28Arabic%29%20%28signed%29.pdf, 9 November 2020.
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Darfur via northern Chad. The group of Musa Hilal and the Sudan Liberation Army -
Abdul Wahid led in Libya by Yusif Ahmed Yusif (Karjakola) have not signed the
Agreement and maintain elements in Libya.
3. Sudanese Rapid Support Forces in Libya

20. In paragraphs 24 and 25 of S/2019/914, the Panel identified the presence of the
Rapid Support Forces in Libya. The Panel has now established that the Rapid Support
Forces deployed approximately 700 fighters to Jufrah from 25 July to 17 September
2019, but they saw no combat. 8 On their return, the fighters were instructed to remain
silent about their deployment. Since then, there have been media reports on a leaked
document that suggests a more recent Rapid Support Forces presence in Libya. The
Panel can discount these reports as inaccurate or fabricated.
21. Annex 9 contains detailed information on Chadian and Sudanese groups.
4. Case of the Black Shield Security Services company

22. The Panel has established that the United Arab Emirates-based company Black
Shield Security Services recruited 611 Sudanese nationals through two Sudan-based
client companies named “Al Ameera external recruitment office” and “Amanda
office” under false pretences. They received military training in Al -Ghayathi camp, 9
United Arab Emirates, under the supervision of Emirati officers. On 22 January 2020,
a batch of 276 Sudanese recruits were transported to Libya, unbeknownst to them,
where they were tasked by the 302nd battalion of HAF to protect oil installations in
Ra’s Lanuf. They never deployed to the field. Following their protests, the y were
withdrawn from Libya after six days (see annex 10).
5. Syrian fighters
23. Syrian fighters have been active in Libya since late December 2019. Their
numbers have fluctuated from 4,000 at the beginning of the period to a maximum of
13,000, depending on conflict and regional dynamics and the availability of funding.
At least 4,000 Syrian fighters operate under the command of GNA-AF, including 250
minors. The Panel has established that the Government of National Accord -affiliated
Syrians train in Libyan camps (see annex 11). HAF-affiliated Syrians operate
alongside ChVK Wagner (see para. 94 below). 10
D. Acts that may lead to or result in the misappropriation of Libyan

State funds
24. Since its establishment in 2015, the Military Investment Authority of LNA has
engaged in the illegal export of scrap metal; the illegal sale of fuel (see para. 127
below); the sale of fishing licences and visas to foreign nationals; and the confiscation
of public companies, agricultural farms, cattle ranches, hotels and beach resorts. The
Military Investment Authority has gradually extended its reach to bring in sizeable
revenue for HAF, giving them the wherewithal to support military activities and for
the financial benefit of the senior leadership (see annex 12).
__________________
8
Confidential sources with detailed knowledge of the deployment.
9
23°51'01.6"N 52°48'03.9"E.
10
ChVK is the Russian acronym for “private military company”. The Wagner organization will be
referred to as ChVK Wagner throughout the report.
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E. Acts that obstruct or undermine the successful completion of the

political transition in Libya
25. During the initial round of the United Nations-facilitated Libyan Political
Dialogue Forum held in early November 2020, the Panel established that at least three
participants were offered bribes to vote for a specific candidate as Prime Minister.
The Forum participants involved in the incident were categorical in their rejection of
the bribes. The issue garnered considerable media attention at that point in time. The
office of the Libyan Attorney General also received complaints from members of the
Forum and civil society groups on the matter. The Panel does not envisage any further
reporting on the issue. More details on that particular case are provided in confidential
annex 13.
F. Attacks against any air, land or seaport in Libya
26. As reported in paragraphs 40 to 42 of S/2019/914, Tripoli Mitiga airport, the

only operating international airport in the capital, remained a strategic target for HAF
during the Tripoli campaign. Multiple attacks 11 resulted in injured civilians and
damaged infrastructure, and affected humanitarian activities. On 22 January 2020, a
HAF spokesperson announced12 a no-fly zone over the airport, given that it was used
for launching Turkish unmanned combat aerial vehicles and receiving Syrian fighters.
On 12 February 2020, HAF confirmed that the prohibition applied to UNSMIL flying
into Mitiga. 13
G. Attacks against State institutions or installations in Libya
27. Pressure on the National Oil Corporation from armed groups continued. From
18 to 20 January 2020, HAF threatened to use force to take control of National Oil
Corporation oil terminals and fields (see para. 107 below). On 25 July 2020, foreign
fighters entered the Zillah and Sabah oil fields.
28. On 23 November 2020, an armed group attempted to enter National Oil
Corporation headquarters in Tripoli. On 6 December 2020, Mustafa Al-Weheishy of
the General Intelligence Service called senior employees at the Brega Petroleum
Marketing Company asking for sensitive information. The Brega Company refused to
relay the information because the General Intelligence Service had no legal authority
over the company, and the National Oil Corporation reported the incident to the Office
of the Libyan Attorney General. On 14 December 2020, a group from the Nawasi
Brigade went to the Company, summoned three senior employees to meet with the
General Intelligence Service and demanded to know the home address of a senior
company official. The incident is yet another example of the blurred lines between
armed groups and State institutions (see para. 8 above).
__________________
11
See https://twitter.com/UNSMILibya/status/1221503029746307072, 26 January 2020;
https://twitter.com/UNSMILibya/status/1232986061250408449, 27 February 2020;
www.dw.com/ar/ ‫ طرابلس‬-‫في‬-‫ العامل‬-‫ الوحيد‬-‫ المدني‬-‫ المطار‬-‫ يستهدف‬-‫جوي‬-‫( قصف‬1 July 2020, URL
no longer active); and Reuters, “Tripoli airport shelling hits fuel tanks, passenger plane -
ministry”, 9 May 2020.
12
See www.facebook.com/watch/?v=661293197945718, 22 January 2020.
13
See www.facebook.com/LNAspox/videos/517072922269763/, 12 February 2020. Flights have
since resumed.
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29. The Great Man-Made River administration reported at least four attacks on
water supplies, including attacks on 6 April, 9 May, 13 July and 9 August 2020, 14
which denied water to Tripoli, Tarhunah and other cities in the west of Libya.
30. The General Electricity Company of Libya reported at least four attacks by
armed groups 15 on its staff at the Ruwais, Khums and Zawiyah power stations. There
were dozens of incidents of theft of electric cables and power transmission
components throughout 2020 in the west and south of Libya. The perpetrators of those
attacks have not been identified, notwithstanding repeated calls for the Libyan
authorities to investigate.
31. The frequent attacks on the water supply and electricity infrastructure highlight
the vulnerability of State installations and the hardship endured by the civilian
population. 16
H. Acts that violate applicable international human rights law or

international humanitarian law, or that constitute human
rights abuses
32. Both parties to the conflict have committed acts that violate the applicable legal
framework set out in paragraph 11 (a) of resolution 2213 (2015) and reaffirmed in
subsequent resolutions.
33. Civilian casualties increased owing to the escalation in hostilities during the first
half of 2020 and are attributable mainly to ground fighting, explosive remnants of
war, targeted killings and air strikes, 17 the first two being the leading causes of death
in the second quarter of 2020.
1. Forced displacement of civilian population

34. The Panel established that Sharif Marghani from HAF Sa‘iqah had forced
civilians to leave their homes in Benghazi. 18 Victims recounted to the Panel how
armed men had stormed their houses, ordering the residents and their children, under
the threat of death, to vacate overnight. 19
2. Arbitrary detention, torture and extrajudicial killings

35. The arbitrary detention and ill-treatment of prisoners continue to take place,
including in official detention facilities. As reported in paragraph 40 of S/2018/812,
__________________
14
See www.facebook.com/manmaderiver/posts/2649074425215372, 7 April 2020;
www.facebook.com/manmaderiver/posts/2720643431391804, 9 May 2020;
www.facebook.com/manmaderiver/posts/2894371374019008, 15 July 2020; and
www.facebook.com/manmaderiver/posts/2964414533681358, 9 August 2020.
15
See www.facebook.com/gecol.org/posts/1535998079921344, 13 November 2020;
www.facebook.com/gecol.org/posts/1471447213043098, 2 September 2020: and
www.facebook.com/gecol.org/posts/1402027973318356, 13 June 2020.
16
Attacks against civilian objects, in particular against objects that are indispensable for the
survival of civilian population, is prohibited, namely pursuant to article 14 of the Protocol
Additional to the Geneva Conventions of 12 August 1949, and relating to the Protection of
Victims of Non-International Armed Conflicts (Protocol II), 8 June 1977. Available at https://ihl-
databases.icrc.org/applic/ihl/ihl.nsf/Treaty.xsp?action=openDocument&documentId=AA0C5BCB
AB5C4A85C12563CD002D6D09.
17
United Nations Support Mission in Libya (UNSMIL), “Civilian casualties report: 1 April –
30 June 2020”, 29 July 2020.
18
See https://twitter.com/emad_badi/status/1269673977053667332, 7 June 2020.
19
The forced displacement of the civilian population in non-international armed conflict is prohibited
under article 17 of the Protocol Additional to the Geneva Conventions of 12 August 1949, and
relating to the Protection of Victims of Non-International Armed Conflicts (Protocol II).
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the Panel continued to receive testimonies from former detainees of the Special
Deterrence Force, who were held in Mitiga prison. They reported arbitrary detention,
torture, confiscation of property and sexual humiliation of detained women by male
guards. Khaled Al Hishri (also known as Al Buti) was identified as having a leading
role. The Panel requested a meeting with representatives of the Special Deterrence
Force in Tripoli, in vain.
Tarhunah
36. As had happened in Sabratah and Surman in mid-April 2020 (see annex 14), the
takeover of Tarhunah from HAF by the Government of National Accord early in June
was followed by acts of retaliation and looting that the Libyan authorities reportedly
attempted to curtail (see annex 15).
37. Since June 2020, mass graves have been discovered in Tarhunah an d south of
Tripoli. Although combatants are identified 20 among the bodies, 21 most of them
appear to be civilians. 22 The Government of National Accord has highlighted these
discoveries and linked them to reports of multiple abductions, incidents torture and
killings committed in areas held by the “Kaniyat” (see annex 16).
38. The “Kaniyat” has been operating in this region with impunity for several years.
It was previously aligned with the Government of National Accord as the 7th Brigade,
and since early 2019 as the 9th brigade of HAF. The Panel has established the
responsibility of Abdurahem El Shgagi (also known as Al Kani) for several cases of
abduction and illegal detention leading to murder. His victims are being identified as
exhumations continue and include:
(a) A man kidnapped from his home in Tarhunah on 19 December 2019. He
had previously shared a message on social media posted by one of his sons criticizing
Kaniyat. He went missing until his family was able to identify his body, which was
found in a well by a Tarhunah resident returning home after the Government of
National Accord had retaken the city;
(b) On 10 January 2021, the family identified the body of Layla Hrouda among
those exhumed from a grave in Tarhunah. 23 On 5 April 2020, Abdurahem El Shgagi had
abducted and arbitrarily detained Layla, along with her two sisters, Hawa and Rima.
39. The Panel continues to investigate the abduction of Shaheen Abdallah
Mohammed Naaji in late 2018 and cases of mass murder.
3. Human trafficking and migrant smuggling

40. Notwithstanding conflict and movement constraints due to COVID-19, Libya
remains a transit and destination country for migrants and asylum seekers. There are
widespread occurrences of trafficking, kidnapping for ransom, torture, forced l abour,
sexual and gender-based violence and killing. Most networks previously identified by
the Panel continue to operate through Bani Walid and other hubs (S/2019/914,
para. 50).
41. With assistance from Italy, Malta and the European Union, and training by
Turkey, the Libyan Coast Guard, operating under the Ministry of Defence, has ramped
up its interception activity at sea. The General Administration for Coastal Security of
__________________
20
The European Union provides technical assistance and capacity-building for forensics and DNA
analysis to the Libyan authorities for the identification of victims.
21
Of 106 bodies found in the Tarhunah hospital, 28 have been identified as HAF combatants.
22
Tim Whewell, “How six brothers - and their lions - terrorized a Libyan town”, BBC News,
7 January 2021.
23
See www.facebook.com/lpc.ly/videos/426675065212063, 10 January 2021.
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the Ministry of Interior also stepped up its contribution to hinder migratory

movements along the Libyan coast during the second half of 2020. 24
42. While most of those brought back to Libya end up in facilities rife with human
rights abuses, hundreds of them remain unaccounted for. 25 The Head of the Libyan
Coast Guard, Colonel Abdallah Toumia, affirmed to the Panel that all persons
disembarked were accounted for. 26 Owing to overcrowding in detention centres, the
Libyan Coast Guard was “sometimes compelled to let them go”. The Head of the
Counter-Illegal Migration Directorate, Colonel Mabrouk Abdelhafid, clarified that
the Directorate had no permanent presence in the ports. 27 When the Libyan Coast
Guard intercepted a boat, it contacted the Directorate, which sent staff to the
disembarkation point. He emphasized that the Directorate registered all those who
were transferred to detention centres. The Directorate did not provide the Panel with
the assignment criteria of migrants to the detention centres. No information was
provided on the role of data collection and investigation facilities, 28 which Colonel
Abdelhafid said did not fall under the Directorate’s authority.
43. Colonel Abdelhafid linked the need for the detention centres to the migratory
policy of European Union member States, emphasizing that 99 per cent of the migrants
present in detention centres had been intercepted at sea and handed over by the Libyan
Coast Guard. 29 While he dismissed the idea of closing all the detention centres, he
presented a reorganization policy, which was meant to disrupt smuggling networks and
allow for improved control by the Directorate, to the Panel (see annex 18).
44. The Minister of Interior, Fathi Bashagha, acknowledged the challenges posed
by the situation in detention centres. He also tied their existence to the pressure
exerted by a few European countries to prevent migrants from crossing the
Mediterranean (see annex 17 for an overview of policies and agreements). He also
emphasized the challenges posed by border management and the need to ensure that
humanitarian aid reached migrants. 30
45. Mr. Bashagha stressed that less than 0.5 per cent of all migrants in Libya were
held in detention centres (i.e., an estimated 2,000 31 of 574,146 32 migrants present in
Libya, as of November 2020). The vast majority were held in unofficial facilities in
degrading living conditions.
46. The Panel pursued its investigations into the Al-Nasr DC in Zawiyah 33 and
found that its de facto manager, Osama al-Kuni Ibrahim, had committed several
violations of international humanitarian law and international human rights law (see
__________________
24
In 2019, 9,225 migrants were intercepted and returned to Libya against 19,500 attempted
departures. In 2020, the ratio was 11,891 interceptions against 28,162 attempts.
25
International Organization for Migration (IOM), “Migrants missing in Libya a matter of gravest
concern, 17 April 2020.
26
Panel interview of 1 September 2020.
27
Ibid.
28
IOM, “Migrants missing in Libya a matter of gravest concern”.
29
A surge in interception on land was noticed recently, Office of the United Nations High
Commissioner for Refugees (UNHCR), “UNHCR position on the designations of Libya as a safe
third country and as a place of safety for the purpose of disembarkation following rescue at sea”,
September 2020.
30
Panel interview of 23 April 2020.
31
UNHCR, “UNHCR update: Libya”, 18 December 2020. A confidential source provides a figure of 572
for migrants detained in detention centres run by the authorities in the east, as of December 2020.
32
51 per cent are located in western Libya, 31 per cent in the east and 18 per cent in the south.
IOM, “Libya IDP and returnee report: round 33 – September–October 2020”, 16 December 2020.
33
In S/2019/914, the Panel emphasized the link between the Al-Nasr DC and the Zawiyah oil
complex, both controlled by the al-Nasr brigade, commanded by Mohammed Al Amin Al-Arabi
Kashlaf (LYi.025).
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annex 19). Victims recounted acts of kidnapping for ransom, torture, sexual and
gender-based violence, forced labour and killing. The centre is still operating,
notwithstanding regular statements announcing its closure (see recommendation 4 (a)
below).
Mizdah
47. The massacre perpetrated in Mizdah on 27 May 2020 illustrates the situation of
migrants. A total of 26 Bangladeshi nationals and 4 individuals from sub -Saharan
Africa died, and 11 Bangladeshi nationals were injured.
48. In July 2020, the Panel interviewed nine Bangladeshi survivors who had
received medical treatment in Tripoli. They entered Libya through Benina
international airport in 2019 and 2020, travelling from Dhaka via the United Arab
Emirates and Egypt, with the assistance of a network of intermediaries at every stage.
Each of them had paid traffickers in Bangladesh an amount ranging from $5,000 to
$8,000. All faced difficulties in finding work in Benghazi owing to the COVID-19
crisis and headed to Tripoli, once again through paid intermediaries. An armed group
attacked the convoy en route and took the migrants to Mizdah, where they were held
for approximately 10 days in a dark warehouse with dozens of other detained migrants
of various nationalities. Every day, a Libyan national accompanied by two
sub-Saharan Africans repeatedly entered the warehouse, tortured the detai nees and
threatened to kill them. Each Bangladeshi survivor was asked to pay $12,000 in
exchange for his release. All identified Yusef Mohammed Abd al-Rahman (also
known as Yusef Basoor al-Jareed al-Bousayfi) as the Libyan trafficker, referring to
him as the boss or the mafia leader, who was subsequently killed by other detainees.
As soon as his killing became known, a group of heavily armed men stormed the
warehouse, firing indiscriminately at the detainees and subsequently running over
bodies with vehicles. Injured victims in the warehouse pretended to be dead until
another group came in and rescued them. To date, the fate of the remaining 120 to 150
migrants is unknown.
49. Mizdah was under HAF control when the mass murder was carried out.
Currently, the Government of National Accord claims authority over the city and
therefore assumes responsibility for the arrest and prosecution of the perpetrators. The
Minister of Interior replaced the local director of security at the end of June and issued
a statement in which he called upon the Mizdah Security Directorate to arrest the
perpetrators (see annex 20). The Attorney General delegated the investigation to the
local prosecutor, but no significant progress had been made to date (see
recommendation 4 (b) and (c) below).
50. The authorities of Bangladesh announced the arrest of several individuals
suspected of organizing or abetting the human trafficking of their nationals to Libya. 34
4. Attacks using explosive ordnance

51. Eighteen attacks were recorded against schools during the first semester. By the
end of November 2020, there had been 32 attacks against health infrastructure,
making Libya the country with the fourth highest number of recorded attacks against
health facilities and personnel in the world.35
52. In the first quarter of 2020, there were at least 11 instances of explosive ordnance
detonating directly on medical facilities and staff in areas targeted as part of the HAF
__________________
34
“3 confess to trafficking Bangladeshis to Libya”, Daily Star (Bangladesh), 21 June 2020: and
Bdnews24, “Bangladesh arrests Libyan national on human-trafficking charges”, 7 August 2020.
35
United Nations, Office for the Coordination of Humanitarian Affairs, “November humanitarian
bulletin: Libya”, 18 December 2020.
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Tripoli campaign. For example, Khadra general hospital in Tripoli was hit three times
within 72 hours (see annex 21).
53. Attacks resulting in multiple casualties such as the air strikes against the Tripoli
military academy on 4 January 2020 and Qasr Bin Ghashir on 3 June 2020 shocked
the public and prompted accusations of war crimes from one party to the conflict to
the other.
Tripoli military academy

54. On 4 January 2020, an air strike targeted the Tripoli military academy, killing 30 36
academy students and injuring many others (see annex 22). Regardless of the civilian
or military status of the military academy’s students, 37 the lawfulness of the attack
depends on whether they were taking an active part in hostilities. The laws of war
prohibit acts of violence against the life and person of those taking no active part in the
hostilities, including members of armed forces. 38 The training of military personnel may
amount to direct participation in hostilities when carried out with a view to the
execution of a specific hostile act. 39 There are no indicators that the officer cadets at the
military academy were engaged in any preparatory measures for such a specific act, nor
is there any evidence that the military academy was being used as a base for any other
military purposes.40 In view of these two factors, the Panel finds that this attack has
almost certainly violated the provisions of international humanitarian law.
Qasr Bin Ghashir

55. At approximately 10 p.m. on 3 June 2020, 17 civilians, including 9 from one
family, died and 16 others were injured, either in, or close to, their homes in Qasr Bin
Ghashir.41 The area had seen armed conflict of high intensity between 2 and 4 June
2020, until HAF withdrew. The Panel could not verify the precise time of its departure
from the area. Although the Panel has obtained imagery that unquestionably shows
that the area was subjected to a high number of explosive attacks, the resolution of the
imagery was insufficient to identify the type and origin of the explosive ordnance used.
III. Implementation of the arms embargo

56. The Panel’s investigations pursuant to paragraphs 9 to 13 of resolution 1970
(2011), as modified pursuant to subsequent resolutions, identified extensive, blatant
and repeated violations of the arms embargo during the reporting period. This has
resulted in a totally ineffective arms embargo.
57. In paragraph 19 of its resolution 2213 (2015), the Security Council urged Member
States to inspect all cargo to determine whether the State had “reasonable grounds to
believe that the cargo contains items […] prohibited by paragraph 9” of resolution 1970
(2011). The Panel considers that the details contained in its letters to the Member States
involved, together with extensive open-source media coverage, provides sufficient
justification for inspections to take place. The Panel therefore finds Egypt, Jordan, the
__________________
36
See annex 22, appendix A (5 January 2020 statement by GNA Ministry of Health). Other sources
mention 26 deaths; see www.youtube.com/watch?v=wWkgzhZuSmg, 27 August 2020.
37
Individuals under training had military numbers, received pay from the military and would
graduate as second lieutenants after three years. They were therefore officer cadets. Those who
died were posthumously promoted (see annex 22, appendices B and C).
38
Common article 3 to the Geneva Conventions of 12 August 1949.
39
Nils Melzer, Interpretive Guidance on the Notion of Direct Participation in Hostilities under
International Humanitarian Law (Geneva, ICRC, 200) p. 47.
40
Confidential sources.
41
See https://airwars.org/civilian-casualties/lc413-june-3-2020/, 3 June 2020.
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Syrian Arab Republic, Turkey and the United Arab Emirates to be in non-compliance
with paragraph 19 of resolution 2213 (2015), in that they did not inspect the cargo of
suspicious commercial vessels or aircraft destined for Libya, which originat ed in or
passed through their territory, for which there were reasonable grounds.
A. Investigative challenges
58. Investigation of the supply chains is complicated by the fact that almost all are
fully under the control of parties involved in the conflict. Cooperation with Panel
investigations is extremely limited and requests for shipping documentation usually
go unanswered or result in very limited information being supplied. The Panel notes
that Jordan, Turkey and the United Arab Emirates did not provide responses or
detailed information in the responses that they sent, to the Panel’s enquiries
concerning arms trafficking and supply chains. The Panel therefore finds that they
were in repeated non-compliance with paragraph 13 of resolution 2509 (2020). Such
a limited level of cooperation undermines the ability of the Panel to comprehensively
fulfil its mandate to provide the Committee with fully documented conclusions
requested by the Security Council.
59. Determining non-compliance and violations, or otherwise, was made more
complex owing to the implementation of the measures outlined in paragraph 3 of
resolution 2214 (2015) by some Member States, in which the Security Council urged
them “to combat by all means, […] threats to international peace and security caused
by terrorist acts”. This often necessitates the deployment of military assets into or over
Libya with the approval of the Government of National Accord. These activities are
contrary to the requirements enumerated in paragraph 9 of resolution 1970 (2011), in
which the Council decided “that all Member States shall immediately take the neces sary
measures to prevent the direct or indirect supply, sale or transfer to the Libyan Arab
Jamahiriya […] of arms and related materiel of all types”. The Panel considers that,
because resolution 1970 (2011) was passed pursuant to Article 41 of Chapter VII of the
Charter of the United Nations, it takes precedence over resolution 2214 (2015), in which
Member States were urged to act in accordance with the Charter.42
B. Impact on conflict dynamics 43
60. The impact of these repeated violations of the arms embargo can be illustrated
clearly by the change in conflict dynamics during the reporting period. At the end of
2019, there was a tactical stalemate on the ground, with HAF controlling access routes
into Tripoli. Their fixed-wing fighter ground attack aircraft, rotary-wing attack
helicopters (Mi24/35) and unmanned combat aerial vehicle (Wing Loong II)
(S/2019/914, paras. 103–110, and annexes 45 and 47) provided local air superiority
over the majority of the country. The Government of National Accord controlled the
urban environments of Tripoli and Misratah. GNA-AF had the capability only for
local unmanned combat aerial vehicle strikes by their Turkey-supplied Bayraktar
TB-2 unmanned combat aerial vehicles, which were vulnerable to ground attack when
located at their operating bases at the Tripoli and Misratah airports. When launched,
they were easily destroyed in the air by the Pantsir S-1 air defence system initially
__________________
42
Reported in S/2016/209, para.126, S/2017/416, para. 147, S/2018/812, paras.108–109 and
S/2019/914, para. 93.
43
Developed from: (a) confidential military sources; (b) UNSMIL reporting; (c) Ioannis Sotirios
Ioannou and Zenonas Tziarras, Turning the Tide in Libya: Rival Administrations in a New Round
of Conflict, Policy Brief, No. 01/2020 (Nicosia, Prio Cyprus Centre, 2020); (d) ongoing Panel
analysis; (e) Jason Pack and Wolfgan Pusztai, “Turning the tide: how Turkey won the war for
Tripoli”, Middle East Institute, 10 November 2020; and (f) social media commentary.
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supplied to HAF by the United Arab Emirates in 2019 (S/2019/914, para. 96, and
annexes 28 and 40) and provided in mid-2020 to Russian private military operatives
by the Russian Federation (see annex 23). The HAF tactics of trying to draw GNA-AF
units out of position into rural areas, thereby making them vulnerable to more decisive
attacks, in general failed. By that stage, military success by HAF appeared to be
dependent on a local war of attrition.
61. The signing of a security and military cooperation agreement between the
Government of National Accord and Turkey 44 on 27 November 2019 was a strong
indicator that Turkey was to increase its military role in Libya. Shortly thereafter,
Turkey deployed Gabya-class frigates (see annex 24) to provide a medium-range air
defence “umbrella” along the western Libyan coastal littoral (see figure I), with
MIM-23 Hawk surface-to-air missile systems 45 providing area defence for the airports
in Tripoli and Misratah. Those systems were supported by the use of Korkut short-
range air defence systems (see annex 26) and man-portable air defence systems to
protect important locations.
Figure I
Illustration of Turkish air defence “umbrella” along western Libya coastal
littoral (in support of the Government of National Accord Affiliated Forces)
62. The local air superiority of HAF was thus effectively negated early in 2020,
allowing for an unchallenged build-up of military materiel through western Libyan
ports and airports by Turkey in support of GNA-AF. Turkish military advisers
deployed, which gave GNA-AF access to the advice of professional military staff,
trained in North Atlantic Treaty Organization tactics and with extensive recent military
operational experience. Operational planning was professionalized, with phased
__________________
44
Abdullah Bozkurt, “Full text of new Turkey, Libya sweeping security, military cooperation deal
revealed”, Nordic Monitor. 16 December 2020.
45
The Panel reported on MIM-23 Hawks defending Jufrah; see S/2019/914, para. 97. See also annex 25.
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objectives determined and assets allocated to meet them. This led to more flexibility
in the operational deployment of GNA-AF, allowing them to respond to events quicker
than HAF, where every military decision had to be cleared at the high est level.
63. On 27 March 2020, the Prime Minister, Faiez Serraj, announced the
commencement of Operation PEACE STORM, 46 which moved GNA-AF to the
offensive along the coastal littoral. The combination of the Gabya-class frigates and
Korkut short-range air defence systems provided a capability to place a mobile air
defence bubble around GNA-AF ground units, which took HAF air assets out of the
military equation. The enhanced operational intelligence capability included Turkish -
operated signal intelligence and the intelligence, surveillance and reconnaissance
provided by Bayraktar TB-2 and probably TAI Anka S unmanned combat aerial vehicles
(see annex 27). This allowed for the development of an asymmetrical war of attrition
designed to degrade HAF ground unit capability. The GNA-AF breakout of Tripoli was
supported with Firtina T155 155mm self-propelled guns (see annex 28) and T-122
Sakarya multi-launch rocket systems (see annex 29) firing extended range precision
munitions against the mid-twentieth century main battle tanks and heavy artillery used
by HAF. Logistics convoys and retreating HAF were subsequently hunted down and
remotely engaged by the unmanned combat aerial vehicles or the lethal autonomous
weapons systems such as the STM Kargu-2 (see annex 30) and other loitering munitions.
The lethal autonomous weapons systems were programmed to attack targets without
requiring data connectivity between the operator and the munition: in effect, a true “fire,
forget and find” capability. The unmanned combat aerial vehicles and the small drone
intelligence, surveillance and reconnaissance capability of HAF were neutralized by
electronic jamming from the Koral electronic warfare system. 47
64. The concentrated firepower and situational awareness that those new battlefield
technologies provided was a significant force multiplier for the ground units of
GNA-AF, which slowly degraded the HAF operational capability. The latter’s units
were neither trained nor motivated to defend against the effective use of this new
technology and usually retreated in disarray. Once in retreat, they were subject to
continual harassment from the unmanned combat aerial vehicles and lethal
autonomous weapons systems, which were proving to be a highly effective
combination in defeating the United Arab Emirates-delivered Pantsir S-1 surface-to-
air missile systems. These suffered significant casualties, even when used in a passive
electro-optical role to avoid GNA-AF jamming. With the Pantsir S-1 threat negated,
HAF units had no real protection from remote air attacks.
65. The introduction by Turkey of advanced military technology into the conflict was
a decisive element in the often unseen, and certainly uneven, war of attrition that
resulted in the defeat of HAF in western Libya during 2020. Remote air technology,
combined with an effective fusion intelligence and intelligence, survei llance and
reconnaissance capability, turned the tide for GNA-AF in what had previously been a
low-intensity, low-technology conflict in which casualty avoidance and force
protection were a priority for both parties to the conflict. The deployment of Mig -29A
(see annex 31) and Sukhoi Su-24 (see annex 32) FGA aircraft in May 2020, as well as
the Pantsir S-1 surface-to-air missile systems operated by the Russian private military
companies (see para. 94 below), has led to another military stand -off between forces.
__________________
46
Middle East Monitor, “Sarraj announces launch of Operation Peace Storm in response to Haftar
attacks”, 27 March 2020.
47
Confidential source.
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C. Maritime violations and interdictions
66. The identification of maritime violations at the ports was complicated by three
counter-surveillance measures initiated by perpetrators: (a) the suspension of cargo
discharges during the daily 90 minutes of daytime commercial satellite coverage, or
the limit of its occurrence to the night; (b) the use of container shielding at Libyan
ports; and (c) no relaxation of the crackdown on social media that was initiated by
both GNA-AF and HAF in 2019.
67. Nevertheless, the Panel developed a set of maritime delivery profile indicators
(see annex 33) that assist in determining the likelihood of non-compliance and thus
determine the focus of Panel investigations. Multiple indicators are required before a
vessel is classified as of interest to the Panel or reported as constituting a violation.
68. The Panel identified five maritime violations, one highly probable violation and
two interdictions by the vessels listed in tables 1 and 2 (full details can be found in
annex 34 (GNA-AF) and annex 35 (HAF)). The Panel wrote to the Member States of
the owners and operators of the vessels listed in those tables and is awaiting responses
from several of them.
Table 1
Maritime violations (in support of the Government of National Accord Affiliated Forces)
Violation
No. of
Highly profile
Name a IMO No. Flag Confirmed probable Interdiction indicators Remarks
Ana 7369118 Albania ✓ ✓ 8 • Renamed in March 2020 as

Palau MV Pray
• Displayed false IMO
number 7295666
• Interdicted on second
voyage
• Renamed and reflagged in
September 2020 as MV VAV
Bana 7920857 Lebanon ✓ 10 • Military vehicles
Cirkin 7728699 United ✓ 9 • Military vehicles
Republic
• Renamed MV Guzel
of
Tanzania • Displaying false flag
and Sao
Tome and
Principe
(false)
Single 8708830 Panama ✓ 10 • Air defence systems
Eagle
Abbreviation: IMO, International Maritime Organization.

a
Listed alphabetically.
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Table 2
Maritime violations (in support of the Hafter Affiliated Forces)
Violation
Number of
Highly profile
a
Name IMO No. Flag Confirmed probable Interdiction indicators Remarks
Gulf 9439345 Liberia ✓ 5 • Jet A-1 as combat supplies

Petroleum
4
Royal 9367437 Marshall ✓ 5 • Jet A-1 as combat supplies
Diamond 7 Islands
• Cargo seized by European
Union military operation in
the Mediterranean (operation
IRINI)
Sunrise 9338840 Bahamas ✓ 2 • 4x4 vehicles for use as
Ace “technicals” b
• The Panel considers this to
be technical
non-compliance c
Abbreviation: IMO, International Maritime Organization.

a
Listed alphabetically.
b
A “technical” being a light utility truck subsequently retrofitted with weapons. The Panel would not normally consider the
transfer of civilian 4x4 vehicles to be non-compliance, but in this case the sheer scale and destination of the transfer should
have raised suspicions.
c
The company could not reasonably be expected to know at that time that the transfer of those civilian vehicles would constitute
non-compliance and should take action to improve its due diligence protocols and procedures.
69. The Panel finds that the owners and/or operators listed in table 3 violated
paragraph 9 of resolution 1970 (2011) for the transfer of military materiel to Libya.
Table 3
Maritime confirmed violations (vessels, companies and owners)
Vessel Flag Owner a Operator a Transfer to entity Remarks
Ana Albania Shega Trans S.A. Shega-Group S.A. Government of • Renamed in March 2020
Albania Albania National as MV Pray
Accord
Bana Lebanon Med Wave African Government of • 1, possibly 3, violations
Shipping S.A., Mediterranean National
Lebanon Lines S.A.L., Accord
Lebanon
Cirkin United Redline Shipping Avrasya Shipping Government of • 2 violations
Republic and Trading Co Ltd, Turkey National
• Vessel escorted by
of Company, Turkey Accord
Turkish military surface
Tanzania
assets
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Vessel Flag Owner a Operator a Transfer to entity Remarks
Gulf Liberia AA Marine Inc, Gulf Shipping Hafter • Jet A-1 as combat
Petroleum United Arab Services FZE, Affiliated supplies
4 Emirates United Arab Forces
Emirates
Single Panama Dytamar Shipping African Government of • 1 violation
Eagle Limited, Liberia Mediterranean National
• Ownership and
Lines S.A.L., Accord
management connected
Lebanon
to MV Bana
Sunrise Bahamas Snowscape Car Mitsui Osk Lines Hafter • 600+ 4x4 for use as
Ace Carriers S.A, Ltd, Japan Affiliated “technicals”
Japan Forces
a
Full contact and case details can be found in annexes 34 and 35.
1. Regional response
70. The Security Council, in its resolutions 2473 (2019) and 2526 (2020), extended
the authority for the inspection of vessels on the high seas off Libya. 48 Although the
mandate of the European Union EUNAVFOR MED operation SOPHIA was extended
until 31 March 2020, 49 the operation did not have sufficient naval assets to conduct
physical inspections at sea and instead fulfilled mainly training and surveillance r oles.
71. On 1 April 2020, operation SOPHIA was replaced by operation IRINI, whose
mandate is more focused on providing direct engagement in support of the identification
and interdiction of arms transfers. Its mandate runs until 31 March 2021. 50
72. On 22 May 2020, operation IRINI assisted in a coordinated effort 51 that
prevented M/T Jal Laxmi (International Maritime Organization (IMO) No. 9213222)
from being used by HAF. The HAF was to utilize the vessel as a bunkering tanker in
the sea area off Tubruq; this would have constituted an illicit export of refined
petroleum products (see para.117 below).
73. On 10 June 2020, three attempts by operation IRINI naval assets to inspect the
United Republic of Tanzania-flagged M/V Cirkin were impeded by three Turkish
escort frigates claiming that the vessel was under their protection. M/V Cirkin docked
in Misratah on 11 June 2020, where its cargo was unloaded in secrecy with the port
“locked down” for all other commercial activities (see appendix D to annex 34).
74. On 10 September 2020, the frigate FGS Hamburg (F-220) was tasked by the
Operation Commander of operation IRINI to board the M/T Royal Diamond 7 (IMO
No. 9367437). Inspection of the cargo confirmed that it was Jet A -1 aviation fuel
destined for Benghazi. The Panel had previously reported 52 that it considered Jet A-1
to be combat supplies and thus military materiel falling under the ambit of paragraph 9
of resolution 1970 (2011), when supplied in quantity to eastern Libya in significant
excess of the quantities historically required for civil aviation activities. The tanker
and its cargo were detained under the ambit of paragraph 5 resolution 2292 (2016), as
reinforced by the Security Council in its resolution 2526 (2020). M/T Royal Diamond
7 was escorted by operation IRINI naval assets to Agios Georgios, Greece, where the
__________________
48
Authority was first granted in resolution 2292 (2016), paras. 3–4.
49
European Council decision (CFSP) 2019/1595 of 26 September 2019.
50
European Council decision (CFSP) 2020/472 of 31 March 2020.
51
Including member States, the flag State, the vessel and cargo insurers.
52
In S/2019/914, para. 147, and letters to the Committee dated 23 August 2019 and 24 March 2020.
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cargo was formally seized on 25 September 2020 by the Central Port Authority of
Lavrio under the ambit of paragraph 9 of resolution 1970 (2011), as modified pursuant
to subsequent resolutions.
75. As in the case of M/T Gulf Petroleum 4 (see para. 130 below), 53 the intended
recipients of the aviation fuel were entities directly under the control of HAF, and it
is almost certain that the fuel was required to support military activities. Accordingly,
the Panel finds that, in such cases, the transfer of Jet A-1 also falls under the ambit of
“other assistance, related to military activities”, and thus constitutes a violation of
paragraph 9 of resolution 1970 (2011).
D. Arms embargo import violations by Member States
76. Arms embargo violations are presented in a chronological tabular basis for ease
of reference (see tables 4 to 7). Infographics that provide the details and evidence of
the major violations are in the annexes as listed.
Table 4
Arms embargo transfer violations (for Government of National Accord Affiliated Forces) a
Date identified Type Equipment/Activity Responsible Annex Remarks
23 October Transfer of Aselsan Koral electronic Turkey N/A • Confidential sources

2019 military warfare system
materiel
16 November Transfer of Dehleyvah anti-tank guided Annex 36 • Manufactured in the
2019 ammunition missile Islamic Republic of
Iranb
17 January Transfer of 6 MiM-23 HAWK surface- Turkey Annex 25 • Satellite imagery
2020 weapons to-air missile systems
17 January Transfer of 12 Aselsan Korkut twin Turkey Annex 26 • By MV Single Eagle
2020 weapons 35mm cannon self-propelled
air defence systems
27 January Transfer of Roketsan UMTAS anti-tank Turkey N/A • Confidential.
2020 ammunition missile sources
28 January Transfer of 4 Gabya-class frigates Turkey Annex 24 • Ongoing
2020 military
materiel
21 March 2020 Transfer of FNSS ACV-15 armoured Turkey Annex 37 • By MV Bana
military combat vehicle
materiel
21 March 2020 Transfer of Firtina T-155 155mm SP Turkey Annex 28 • By MV Bana
weapons Howitzer
6 April 2020 Transfer of IAI Harpy loitering Annex 38
military munition
materiel
__________________
53
Full details can be found in annex 86.
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19 April 2020 Transfer of TAI Anka unmanned combat Turkey Annex 27 • >80 per cent
military air vehicles confidence level
materiel based on wreckage
imagery
21 May 2020 Transfer of C-130E Hercules aircraft c Turkey Annex 39
onwards military
materiel
23 May 2020 Transfer of F-16 C or D FGA c Turkey N/A • Confidential sources
military
materiel
27 May 2020 Transfer of STM Kargu-2 loitering Turkey Annex 30
military munition
materiel
28 June 2020 Transfer of Misagh-2 SAM Turkey Annex 40 • Turkey highly
weapons probable
• Manufactured in the
Islamic Republic of
Iran
8 July 2020 Transfer of A400B Atlas aircraft c Turkey Annex 39
onwards military
materiel
18 July 2020 Transfer of Roketsan T-122 Sakarya Turkey Annex 29
weapons multi-launch rocket system
9 October Transfer of 120mm high explosive Annex 41 • Lot numbers 04-17
2020 ammunition mortar bombs and 01-18;
manufactured in
Bulgaria
10 October Training d Diving training in Khums, Turkey Annex 42
2020 Libya, for Government of
National Accord Affiliated
Forces.
13 October Training Technical training to the Turkey Annex 43
2020 Government of National
Accord Affiliated Forces on
T155 Firtina 155mm
Howitzer in Tajura’, Libya
14 October Training Infantry training for 171 Turkey Annex 44
2020 brigade Government of
National Accord Affiliated
Forces soldiers at the “Libyan
Training College” in Isparta,
Turkey
20 October Training Training for the Libyan Turkey Annex 45
2020 Coast Guard by Turkish
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advisers and mentors in

Khums, Libya
21 October Training Special forces training for Turkey Annex 46
2020 the Government of National
Accord at the Turkish
special forces base
1 November Transfer of Lenco Bearcat G3 4x4 Annex 47 • Possibly captured
2020 military armoured personnel carrier from the Hafter
materiel Affiliated Forces
18 November Training Forward observation officer Turkey Annex 48
2020 training for the Government
of National Accord
Affiliated Forces by Turkish
advisers and mentors in
Khums, Libya
30 November Training Aabseil training for the Turkey Annex 49
2020 Government of National
Accord Affiliated Forces by
Turkish advisors and
mentors in Tajura’, Libya
a
In this and the three tables that follow, the Panel provides reference details for the companies and equipment in the
corresponding annexes.
b
In this and all other tables that follow, the Panel is not suggesting that the country of manufacture was alway s involved in the
arms embargo non-compliance unless specifically listed under “responsible”.
c
Each flight into Libya of a military aircraft is a violation of the arms embargo.
d
The Panel does not consider that any of the training provided to the Government of National Accord Affiliated Forces by
Turkey falls under the auspices of “security or disarmament assistance” and therefore does not fall under the exemption
contained in paragraph 10 of resolution 2095 (2013).
77. On 19 November 2019, imagery was identified on social media of three internal
Government of National Accord letters referring to the transfer of funds to Turkey for
the procurement of specific needs for the Ministry of Interior. Given that the Turkish
armaments group SSTEK 54 is the recipient of the funds, it is almost certain the
payments were for military materiel supplied in violation of paragraph 9 of resolution
1970 (2011). The transactions are summarized in table 5 and the related documents
can be found in annex 50. 55
__________________
54
See www.sstek.com.tr/.
55
Panel letter of 19 December 2019. No response was received.
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Table 5
Summary of documents authorizing transfer of Government of National Accord funds to Turkish
arms company
Date From To Regarding
2 June 2019 Fathi Bashagha, Governor of the Request to transfer 70.4 million euros
Minister of Interior Central Bank ($78.79 million)56 to Turkish arms group SSTEK
17 July 2019 Muhammad Milad Ministry of Interior Request made on 15 July 2019 from the Minister
Hadid, Comptroller of Interior to transfer 169.9 million euros
General ($190.8 million) to Turkish arms group SSTEK
3 November 2019 Fathi Bashagha, Governor of the Request to transfer 169 million euros
Minister of Interior Central Bank ($188.7 million) to Turkish arms group SSTEK
Table 6
Arms embargo transfer violations (for the Hafter Affiliated Forces)
14 May 2018 Training relating Hafter Affiliated Forces Jordan Annex 51 • Not previously
to military personnel training at identified
activities Royal Military College,
Jordan
16 October Transfer of Krusik 120mm M62P8 United Arab Annex 52 • Manufacturer
2019 ammunition mortar bomb Emirates confirmed supply
to United Arab
Emirates
19 November Transfer of KADDB Mared 8x8 Jordan Annex 53 • First sighting with
2019 military materiel infantry armoured Snakehead turret
fighting vehicle
11 December Transfer of AOI Terrier LT-79 Egypt Annex 54 • Built under licence
2019 military materiel armoured personnel from the Armored
vehicle Group, United
States of America,
in Egypt
22 December Transfer of MSPV Panthera T6 United Arab N/A • Brand-new vehicles
2019 military materiel armoured personnel Emirates
• First reported in
carrier
S/2018/812,
annex 29
1 January Transfer of IL-76 cargo aircraft a Russian Annex 55 •
2020 onwards military materiel Federation
4 February Transfer of Inkas Titan-DS United Arab Annex 56 •
vehicle
__________________
56
Currency converted to dollars on date of transfer request. For example, see
www.xe.com/currencytables/?from=LYD&date=2019-06-02.
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10 February Transfer of Transfer of at least 9 United Arab Annex 57 • Violation for

2020 military materiel Wing Loong II unmanned Emirates transfer out of
(from Libya) combat air vehicles from Libya to new
Khadim (HL59) to operational base
Uthman airbase (HE27)
in Egypt
26 February Transfer of Streit Spartan 4x4 United Arab N/A • Brand-new vehicles
• Presence in Libya
vehicle
first reported in
S/2018/812, annex 29
10 March Transfer of C17A Globemaster United Arab Annex 55 • Confidential source
2020 military materiel aircraft a Emirates
20 March Transfer of Dahua DHI-UAV-D- Annex 58 • Commercially
2020 military materiel 1000JHV2 anti-drone gun available
12 April 2020 Training relating Pilot training for the Syrian Arab Annex 59 • 6-month pilot
to military Hafter Affiliated Forces Republic course
activities on the Mi24D (Mi-25
export version) attack
helicopter by 64th
Helicopter Brigade of
the Syrian Arab Air
Force at Marj Ruhayyil/
Blay military airport
18 April 2020 Transfer of KBP RPO-A Shmel Annex 60 • New batch
ammunition thermobaric munition delivered since
2007 delivery
12 May 2020 Transfer of Dassault Mirage 2000-9 United Arab Annex 61 • Operating at Al
military materiel FGAa Emirates Jufrah (HL69) and
Tubruq (HLTQ)
airbases
18 May 2020 Transfer of MiG-29A fighter ground Russian Annex 31 •
military materiel attack aircraft (>9) a Federation
18 May 2020 Transfer of Sukhoi Su-24 FGA Russian Annex 32 •
military materiel aircraft (>4) a Federation
23 May 2020 Transfer of Armoured personnel Russian Annex 62 • ChVK Wagner
military materiel vehicle type to be private
confirmed military
company
26 May 2020 Transfer of MIC VPK Tigr-M Russian Annex 63 • ChVK Wagner
military materiel private
military
company
5 June 2020 Transfer of T-62 MV main battle Russian Annex 64 • Russian private
weapons tank upgrade private military company
military (to be confirmed)
company
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8 June 2020 Transfer of Russian Federation- N/A • Found in old

ammunition manufactured TulAmmo Russian private
7.62x39mm small arms military company
ammunition fighting positions
near Tarhunah
• Lot No. A421
manufactured in
November 2019
7 July 2020 Transfer of ML-8 anti-lift initiator Russian Annex 65 • Russian private
ammunition booby trap private military company
company
12 July 2020 Transfer of Pantsir S-1 air defence Russian Annex 23 • On KaMAZ
military materiel system Federation platform, therefore
not a United Arab
Emirates system
• Operated by a
private military
company
29 July 2020 Transfer of 141 4x4 vehicles for the United Arab Annex 66 • Seized in Malta
military materiel Hafter Affiliated Forces Emirates
29 July 2020 Transfer of PMN-2 anti-personnel Russian Annex 67 • Russian private
ammunition mine private military company
company
• Located in former
Russian private
military company
positions
5 August Transfer of LEMZ 96L6/E target Annex 68 • The launcher
2020 military materiel acquisition radar for an system has not yet
air defence system been identified
16 September Training relating Training of Hafter Jordan Annex 69 •
2020 to military Affiliated Forces
activities personnel at Royal
Military College, Jordan
21 September Transfer of Armoured vehicles with N/A • Manufacturer
2020 military materiel roof weapons mount very consulted denies
similar to the Tundra that it was a Tundra
vehicle manufactured by but provided no
a United Arab Emirates alternative
company explanation
23 September Transfer of POM-2R anti-personnel Russian Annex 70 • Lot 583-1-96
2020 ammunition mine private
military
company
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16 November Transfer of 155mm Howitzer gun, Annex 71 •

2020 military materiel very similar to G5
16 November Transfer of Morava 128mm Annex 72 • Manufactured in
2020 military materiel multi-barrel rocket Serbia
system (LRSCM)
a
Each flight into Libya of a military aircraft is a violation of the arms embargo.
Table 7
Arms embargo violations by unidentified suppliers and users
Date identified or of activity Type Equipment/Activity Annex Remarks
6 November 2019 Transfer of military Xiamen Mugin 4450 Annex 73 • Commercially available
materiel unmanned aerial vehicle
14 April 2020 Transfer of weapons WB Warmate loitering Annex 74 •
munition
E. Arms embargo export violation by a Member State
78. On 18 May 2020, HAF withdrew from the Watiyah air base. 57 Among the
military materiel captured by GNA-AF was a relatively intact Pantsir S-1 system (see
figures II and III), which was moved thereafter under the control of an armed group
to Zuwarah. After negotiations between the armed group in possession of the Pantsir
S-1, the Government of National Accord and one Member State, the system was
moved from Zuwarah to Mitiga airport in Tripoli and placed under Turkish protection
to ensure that it was not “accidently used”.
Figure II
Pantsir S-1 at Watiyah (18 May 2020) a
a
See https://twitter.com/Oded121351/status/1262343178356736003, 18 May 2020.
__________________
57
Patrick Wintour, “UN-backed Libyan forces take key airbase from rebel general”, The Guardian,
18 May 2020.
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Figure III
Pantsir S-1 at Watiyah (18 May 2020) a
a
See https://twitter.com/M1923Y/status/12623340208572702741, 18 May 2020.
79. The Pantsir S-1 was subsequently acquired as part of the United States of
America foreign military exploitation programme and subsequently transferred out of
Libya.58
80. On 1 July 2020, the Panel offered the United States an opportunity to respond,
but its response of 21 January 2021 contained no relevant information. The Panel
finds that this transfer is a violation of paragraph 10 of resolution 1970 (2011) by the
United States for using its flagged aircraft to transfer military materiel from Libya.
F. Air bridges
81. The Panel has identified a range of profile indicators of suspicious activities (see
annex 75) that, when considered collectively, cogently indicates that centrally planned
air bridges are in operation primarily between: (a) the United Arab Emirates and
western Egypt/eastern Libya (HAF); (b) the Russian Federation, via the Syrian Arab
Republic, to eastern Libya (HAF); and (c) Turkey to western Libya (Government of
National Accord) (see figure IV). Full details of the routes, air operators and
suspicious flights can be found in annexes 39 and 55.
82. Resupply of HAF and GNA-AF by air was extensive during the reporting period.
All flights are non-scheduled or special charter flights that attempt to disguise their
routing by not broadcasting on their ADS-B transponders.
83. Air bridge flights to Egyptian airbases form part of the wider supply chain to Libya.
The Panel finds that, because this airbridge is “an indirect supply […] of arms and related
materiel […] or other assistance” (resolution 1970 (2011), para. 9), the operators of the
aircraft forming the air bridge are in violation of that paragraph. Due diligence checks
should have established the military nature of the cargos and the intended end user.
__________________
58
Tom Rogan, “US seizes advanced Russian military system in Libya”, Washington Examiner,
19 June 2020; Samer Al-Atrush, “Libya, How the US and Turkey agreed to share a captured
Russian defence system”, The Africa Report, 25 February 2021; and (c) two confidential sources.
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Figure IV
Schematic of arms trafficking air bridges
Note: Map developed by C4ADS, with Panel input.
84. The Panel has observed that the airlines, operators, charterers and agents have
the ability to respond to sanctions investigations and sanctions measures to ensure
business continuity. They are very agile and can react before the international
community is able to respond, and can take the measures necessary to, among others,
disguise their activities, transfer the registration of aircraft and change air operators.
If an air operating company suspects that it is being too closely investigated by the
Panel, it forms a new company in a new jurisdiction and releases the same aircraft
from the owner. The owner avoids any potential designation because it “dry” leases
the aircraft, that is, the air operating company has the responsibility for providing the
crew and arranging all charters. A classic example is that, for the Ilyushin IL -76TD
aircraft (No. 1023414450), which had three operators and was registered within three
different national aviation registries over an 18-month period (see figure V and
documentary analysis in annex 75). In this case, the designation of the air operator
for merely the illicit use of this specific aircraft would achieve little, given that the
aircraft is not an asset owned by the company that would fall under an assets freeze
and could be leased by the owner to a new air operator. The Panel considers that
aircraft should be treated similarly as vessels pursuant to paragraphs 19, 22 and 23 of
resolution 2270 (2016) and be made subject to compulsory deregistering, landing bans
and/or assets freeze measures. This is the only effective way of disrupting air
trafficking operations (see recommendation 1).
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Figure V
Infographic for Ilyushin IL-76TD (No. 1023414450)
85. In specific circumstances, such as that shown in figure V, both the owner and
the air operator could be considered for sanctions measures, given that it is beyond
credulity that the owner was unaware of the reasoning for the transfers of air operator
and registration authority. It is worth noting that Infinite Seal LLC quickly transferred
the dry lease after the suspension of the Azee Air LLC (see appendix D to annex 55)
air operating certificate in order to allow the aircraft to continue to fly. The aircraft
was subsequently quickly sold after the re-leasing.
G. Private military and security company involvement
1. “Project Opus” private military intervention

86. In June 2019, the Panel identified a well-funded private military company
operation, named “Project Opus” (see annex 76), which was designed to provide HAF
with armed assault rotary-wing aviation, intelligence surveillance and reconnaissance
aircraft, maritime interdiction, cyber, unmanned armed vehicles, and intelligence
fusion and targeting capabilities. The Project Opus plan also included a component to
kidnap or terminate individuals regarded as high-value targets in Libya. Three United
Arab Emirates-based companies were used primarily for the planning, management
and finance of the operation: (a) Lancaster 6 DMCC; (b) L-6 FZE; and (c) Opus
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Capital Asset Limited FZE. Those companies were controlled and managed by
Christiaan Paul Durrant (Australia) and Amanda Kate Perry (United Kingdom of
Great Britain and Northern Ireland), with the Ground Team Leader being Stephen
John Lodge (South Africa). All three companies and individuals were found by the
Panel to have violated paragraph 9 of resolution 1970 (2011), in that they had each
violated or assisted in the evasion of the provisions of the arms embargo in Libya.
87. The original plan envisaged the purchase of surplus military helicopters from
Jordan, but that plan failed when the Jordanian authorities became aware of elements of
the plan and suspended the auction of the aircraft on 18 June 2019. This required the
Project Opus team to initiate a contingency plan to rapidly identify and procure new
aircraft. These included three medium utility helicopters from a South African company
and three light utility helicopters from a United Arab Emirates company. Also purchased
within a tight time frame were an Antonov AN-26B from a Bermudian company, a LASA
T-Bird light attack aircraft from a Bulgarian company and a Pilatus PC-6 intelligence,
surveillance and reconnaissance aircraft from an Austrian company. Those three aircraft
were deployed before any payment and normal due diligence could take place, thereby
demonstrating that a fourth individual, Erik Dean Prince (United States), who controlled
the companies owning the aircraft, had assisted in procurement for the operation. No one
else was in a position to arrange the sale of those aircraft within such a short time frame.
Further Panel investigations identified that Mr. Prince had made a proposal for the
operation to Khalifa Haftar in Cairo on, or about, 14 April 2019. The Panel therefore
finds that Mr. Prince also violated paragraph 9 of resolution 1970 (2011), in that, at the
very least, he assisted in the evasion of the provisions of the arms embargo in Libya.
88. The rotary-wing assault and maritime interdiction components of the operation
were mounted from Amman and Valletta on 25 and 26 June 2019, respectively. The
private military operatives were met on arrival in Benghazi by individuals who were
already deployed as part of the cyber and fusion and targeting cell components of the
operation.
89. The rotary-wing aviation and maritime interdiction component of the plan was
aborted on 29 June 2019, when Mr. Lodge took the decision to evacuate a team of 20
private military operatives to Malta using the two special forces specification rigid
hulled inflatable boats for the 350 nautical mile voyage from Benghazi to Valletta.
During the voyage, one of the inflatable boats had to be abandoned. The decision to
evacuate was taken because Khalifa Haftar was unimpressed with the replacement
aircraft procured for the operations and made threats against the team management.
The fusion and targeting cell was not part in the evacuation.
90. The Pilatus PC-6 intelligence, surveillance and reconnaissance aircraft deployed to
Libya on 25 June 2019. The Panel identified that this aircraft was available for intelligence,
surveillance and reconnaissance operations in Libya (from Benghazi, Al Jufrah and Birak
al-Shati) from at least 26 June 2019 to 24 December 2020. The intelligence, surveillance
and reconnaissance capabilities of the aircraft provides HAF with a force multiplier for
intelligence, surveillance and reconnaissance and targeting activities.
91. Project Opus private military operatives were deployed to Libya for a second
time, in April and May 2020, in order to locate and destroy high-value targets but
planned to use military equipment supplied by the United Arab Emirates. The
operation was aborted because any kinetic assault operations by rotary -wing assets
would be highly vulnerable to interdiction by GNA-AF air defence capability (see
para. 62 above). The deployment of rotary-wing assets would have been a suicide
mission at that time unless a route through was first cleared by fixed -wing or
unmanned combat aerial vehicle assets.
92. The United Arab Emirates, which could provide a significant amount of
assistance to the Panel, has yet to respond to any requests for information, and the
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responses from Jordan and South Africa contained little of the substantive information
requested by the Panel.
2. ChVK Wagner 59
93. Operational security surrounding the deployment of ChVK Wagner in support
of HAF has been effective, with verifiable open source information as to their
organization, structure, operational tasks and casualties being limited.
Notwithstanding this, the Panel has established from a variety of sources 60 that ChVK
Wagner has been present in Libya since October 2018. That initial deployment was to
provide technical support for the repair and maintenance of armoured vehicles.
94. By early 2019, the deployment had progressed to provide operational combat
support, which grew to an estimated deployment of 800 to 1,200 ChVK Wagner
operatives during 2019 and 2020. ChVK Wagner operatives were engaged in more
specialized military tasks such as acting as artillery forward observation officers and
forward air controllers, providing electronic counter-measures expertise and
deploying as sniper teams. Their deployment acted as an effective force multiplier for
HAF during 2019 and early in 2020.
95. The Panel noted that flights made by Russian Federation military aircraft peaked
in October 2018 and subsequently in January/February 2019, which coincided with
the initial reports of the deployment of Wagner ChVK operatives to Libya (see
appendix A to annex 55).
96. After the commencement of Operation PEACE STORM by GNA-AF on
23 March 2020, ChVK Wagner units withdrew, along with their HAF allies (see annex
62). The Panel confirmed that ChVK Wagner had withdrawn from Bani Walid on
27 May 2020. On 1 July 2020, ChVK Wagner military operatives were reported to be
based at Jufrah (HL69), Birak (BCQ), Qardabiyah (HLGD), Sabha (HLSS), Waddan
(HL72) and Shararah oil facility.
97. That withdrawal coincided with the deployment of the MiG-29A (see annex 31),
Su-24 (see annex 32) and Pantsir S-1 (see para. 65 above). All were operated by
ChVK Wagner, whose numbers had increased to approximately 2,000 by that time. 61
Notwithstanding the ceasefire agreement of 25 October 2020, there have been no
indications of any withdrawal from Libya by ChVK Wagner.
3. Rossiskie System Bezopasnosti Group

98. The Panel first identified another Russian Federation private military company,
Rossiskie System Bezopasnosti Group, 62 present in eastern Libya during 2017
(S/2017/466, annex 43), but this related to a legitimate commercial explosive
remnants of war clearance contract to remove mines and explosive remnants of war
from an industrial complex near Benghazi. 63 The Group was identified 64 in late 2019
as having provided approximately 15 technicians who either upgraded, maintained or
refurbished Russian-manufactured MiG and Sukhoi FGA aircraft at Khadim airbase.
The team was briefly accommodated at the only hotel in Marj. 65
__________________
59
Evidence can be found in annex 77.
60
Sources: international organization reports; open sources; open source satellite imagery; and
multiple confidential sources.
61
Not including 2,000 Syrian fighters recruited and deployed by ChVK Wagner.
62
See http://rsb-group.org/. Rossiskie System Bezopasnosti Group is a Moscow-based private military
and security consulting company that is registered for work with the United Nations (No. 403872).
63
Centred on 32°00'23.57"N, 20°07'57.47"E.
64
65
Hotel Marj. A confidential source also informed the Panel that four Russians had stayed in the
same hotel from 1 to 7 January 2020.
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4. SADAT International Defense Consultancy

99. There have been multiple credible reports 66 that SADAT International Defense
Consultancy of Turkey 67 has provided military training to GNA-AF and Syrian
fighters, and that SADAT is responsible for the supervision and payment of the
estimated 5,000 pro-Government of National Accord Syrian fighters. 68 Although
SADAT has denied all private military company activities in Libya 69 the Panel
considers that, on the basis of the role of SADAT in training Syrian fighters in Syri an
Arab Republic, 70 Member State reporting and the depth and breadth of open source
media reporting, on a balance of probability SADAT is engaged in Libya. Such
activities fall under the ambit of paragraph 9 of resolution 1970 (2011), given that the
provision of military “training” is clearly a violation of the resolution.
5. Other providers
100. The Panel identified two commercial entities that are contracted to provide
defence- and security-related consultancy advice to the Government of National Accord.
The Panel has looked at confidential documentation that includes the declared
consultancy tasks for each entity and is content that their activities are designed to
provide advice on the mid- to long-term organization and structure of the Libyan security
sector. Such work is complementary to the defence and security sector reform initiatives
conducted by the Security Institutions Service of UNSMIL since 2012. 71 The Panel
therefore considers this consultancy to fall under the ambits of paragraph 10 of resolution
2095 (2013), in which the Security Council decided that “the provision of any technical
assistance, […] when intended solely for security or disarmament assistance to the
Libyan government, shall no longer require notification to […] the Committee”, and
paragraph 8 of resolution 2214 (2015), in which the Council emphasized “the importance
of providing support and assistance to the Government of Libya, including by providing
it with the necessary security and capacity building assistance”.
H. Responses to arms embargo violations
101. Some Member States and regional organizations have taken a range of action in
response to non-compliances with the arms embargo by entities based in or registered
within their territories (see annex 78).
__________________
66
1) Suat Cubukcu, “The rise of paramilitary groups in Turkey”, Small Wars Journal, 3 March
2018; Ioannou and Tziarras, “Turning the tide in Libya”, p. 3; Africa Intelligence, “Turkish
military company Sadat turns Erdogan-Sarraj alliance into business opportunity”, 8 June 2020;
Eren Ersozoglu, “Sadat: the Turkish mercenaries who support Islamist groups”, Sofrep, 7 July
2020; Colin Freeman, “Erdogan nurtures elite mercenary force to rival Russia’s Wagner Group”,
The Telegraph, 12 September 2020; United States of America, Department of Defense, Office of
the Inspector General, East Africa Counterterrorism Operations: North and West Africa
Counterterrorism Operations – Lead Inspector General Report to the United States Congress,
1 April 2020–30 June 2020 (2020), p. 35; two confidential sources and one Member State.
67
See www.sadat.com.tr.
68
The Panel has discounted media reports that a specific Libyan security provider had partnered
with SADAT on that task.
69
Letter to Panel dated 29 July 2020.
70
See www.globalsecurity.org/military/world/europe/tu-sadat.htm.
71
See resolution 2542 (2020), in which the Security Council decided to “help consolidate the
governance [and] security […] arrangements of the Government of National Accord” (para. 1 (i))
and “provide support to key Libyan institutions” (para. 1 (vii)).
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I. Updates to reported violations
1. Deek Aviation FZE

102. In S/2019/914 (see also annexes 28 and 52), the Panel reported on violations by
Deek Aviation FZE 72 of the United Arab Emirates for two Ilyushin Il-76TD (UR-CMP
and UR-CRC) that it operated that were destroyed by a Government of National
Accord air strike against Jufrah airbase (HL69). On 5 November 2020, the Panel
received a letter from one Member State in which it informed the Panel that Deek
Aviation FZE had informed its authorities that the cargo was humanitarian aid. No
evidence was supplied to support that assertion, and the Panel’s finding in 2019 of a
violation of paragraph 9 of resolution 1970 (2011) remains extant. The supply of
humanitarian aid is often the “cover story” provided to the Panel. Figure VI illustrates
why the humanitarian aid claims are often easily rebutted.
Figure VI
Delivery of aid versus ammunition by air
IV. Unity of State institutions

103. This issue was examined in the light of the requirements of paragraph 5 of
resolution 2509 (2020).
__________________
72
See www.deek.aero.
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A. Central Bank of Libya
104. The Panel notes that the Board of Directors of the Central Bank of Libya met on
16 December 2020, the first meeting to have been held that year. They unanimo usly
agreed to unify the exchange rate at 4.48 Libyan dinars to the dollar (i.e., a 322 per
cent devaluation). The Board held a follow-up virtual meeting on 31 December 2020
prior to implementing the devaluation on 3 January 2021. The resumption of the
Board meetings and the agreement on the unified exchange rate are two significant
steps towards restoring the unity of the institution.
105. The Panel has no further information on the progress of the Central Bank of
Libya audit. 73
B. Libyan Investment Authority
106. After extended litigation, on 25 March 2020, a court in the United Kingdom
decided that Ali Mahmoud was the legitimately appointed Chair of the Libyan
Investment Authority (LIA). There appears to be no challenge to the authority of the
Chair in Tripoli. On 18 November 2020, the LIA Board of Trustees formally renewed
Mr. Mahmoud’s mandate for three years and appointed two new members from
eastern Libya to the LIA Board of Directors, bringing the total number to seven.
C. National Oil Corporation
107. On January 2020, purportedly spontaneous demonstrations in eastern Libya

calling for an oil blockade forced the National Oil Corporation to declare a force
majeure74 in the oil and gas export terminals in the east and at the Shararah and Fil
oilfields. The distribution of the oil revenue was a central factor behind the blockade.
In September and October 2020, the force majeure was gradually lifted, putting an
end to eight months without oil exports. The lifting was possible after an agreement
to freeze the oil revenue in the National Oil Corporation’s account in the Libyan
Foreign Bank, where that revenue is deposited (see annex 79).
108. That freeze, endorsed by the Economic Working Group of the International
Follow-up Committee on Libya, has been adopted as a temporary measure until a
more durable economic arrangement is reached. A total of $2.35 billion in oil revenue
now remain frozen. This decision has led the Central Bank of Libya to utilize the
already meagre Libyan foreign reserves to provide for budget expenses.
109. The National Oil Corporation supports the continued freezing of oil revenue to
ensure uninterrupted oil production. Such action will also permit the National Oil
Corporation to exercise oversight of the oil wells, export terminals and related oil
facilities. For the same reason, the National Oil Corporation also seconds a proposal, part
of the 5+5 Joint Military Commission agenda, to reunify and restructure the petroleum
facility guards. This force is de facto divided into an eastern and a western branch.
110. The National Oil Corporation aims to bring the petroleum facility guards fully
under its control, with a new name and equipped with modern technology. The
members will be expected to be free from political or tribal affiliations. The
restructured force will comprise some 2,500 operatives, which is less than 10 per cent
__________________
73
UNSMIL, “The United Nations is pleased to announce the launch of the international financial
review of the two branches of the Central Bank of Libya”, 27 July 2020.
74
Force majeure is a contractual clause that frees the National Oil Corporation from its legal
obligations to supply oil or gas when faced with circumstances outside its control. It is generally
lifted when the circumstances that led to it being imposed are removed.
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of the current petroleum facility guards. A pilot project will be launched at Erawan
oil field, 75 in the Murzuq basin, south-western Libya.
111. While the Tripoli-based National Oil Corporation, led by Mustafa Sanalla,
retains its leading institutional role, it remains concerned by the activities of the
Benghazi-based “eastern National Oil Corporation” led by Almabruk Sultan. This
parallel entity, with the support of the Al Baida-based non-legitimate government,
continues to challenge the authority of Sanalla in order to gain control over the export
of Libyan crude oil (see annex 80). The eastern National Oil Corporation has
continued its efforts to export crude oil and import refined petroleum products (see
paras. 115 and 130 below).
112. The National Oil Corporation is also facing budgetary constraints as result of the
lack of funds allocated by the Government of National Accord. These funds are not
enough for the increased maintenance needs of the oil facilities that resulted from the
lifting of the force majeure and from the COVID-19 crisis. The funding constraints could
erode the National Oil Corporation’s capacity to sustain increasing oil production levels.
113. The Board of Directors of the Brega Petroleum Marketing Company 76 was
restructured on 30 April 2020 and a new Chair, Ibrahim Abubridaa, was appointed
(see annex 81). Since then, the parallel “eastern Brega” has ceased most of its illicit
activities (S/2019/914, para. 139).
V. Prevention of illicit exports or illicit imports of petroleum

A. Attempts to illicitly export crude oil
114. No vessels have been designated pursuant to paragraph 11 of resolution 2146

(2014).
115. The Panel documented one attempt to export crude oil. An agreement to extend
the validity of a purchase and sale contract, as well as a subsequent allocation
certificate, were signed on 20 August 2020. No vessels were selected to load the cargo
(see annex 82).
116. The Panel also monitored several attempts to illicitly export condensate. 77 At
least two attempts were aborted at a later stage. In one case, a vessel was chosen to
load the condensate cargo. The operation was aborted after the Libyan authorities had
contacted the flag State of the vessel concerned to resolve the issue (see annex 83).
B. Prevention of illicit exports of refined petroleum products
117. The illicit exports of refined petroleum products have decreased substantially
compared with previous years. Local dynamics, in conjunction with the impact of the
COVID-19 outbreak on the global economy, have brought fuel smuggling by sea to a
temporary halt. On the other hand, fuel diversion overland persisted and even
increased in some regions, although it continued to be a relatively low -scale activity.
118. The appropriate Libyan institutions remained vigilant and continued their
activities to curb fuel smuggling. A new military unit called the “Joint Forces”,
established with a mandate that includes combating fuel smuggling (see annex 84),
__________________
75
Near Uwaynat, 25°46'31.0"N 10°33'39.5"E.
76
Brega Petroleum Marketing Company is the subsidiary of the National Oil Corporation
responsible for the storage and supply of fuel to the distribution companies in Libya.
77
Condensate is a mixture of light liquid hydrocarbons typically separated from of a natural gas
stream at the point of production.
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has conducted several operations against fuel smugglers overland. 78 The Tripoli
Security Directorate, affiliated with the Ministry of Interior, arrested Abd Al-Rahman
al-Milad (LYi.026) (see para. 176 below), who faces, among others, fuel smuggling
charges. The Office of the Libyan Attorney General oversees this and other
investigations related to illicit exports of petroleum products.
119. The Brega Petroleum Marketing Company, responsible for the supply of fuel to
the four distribution companies, 79 continued to improve the transparency of and
oversight of the supply chain. Details of fuel deliveries continue to be available on its
website. 80 The list of “trusted” petrol stations is maintained and updated (S/2019/914,
para. 157). New best practices resulting in improved governance, including customer
verification and market analysis, are enforced.
120. The fuel distribution companies continue to be immersed in internal legal
disputes and face efficiency problems. Their historical debt remains unresolved
(S/2019/914, paras. 160–162). The Brega Petroleum Marketing Company has opened
a negotiation track with the distribution companies. Meanwhile, it ensured fuel
availability in western areas by establishing eight permanent petrol stations, with the
goal of opening 13 more before the end of 2021. 81
1. The Zawiyah network

121. The al-Nasr brigade, led by Mohammed Al Amin Al-Arabi Kashlaf (LYi.025),
maintains control of the Zawiyah oil complex. Until his detention, Abd Al -Rahman
al-Milad (LYi.026) was the de facto head of the Libyan Coast Guard detachment at
the oil complex (see also paras. 118 above and 176 below). Small smuggling groups
emerged during the second half of 2020, raising tensions with established groups. The
Zawiyah network has exerted great efforts to maintain the status quo in the city. It
retains its central and prominent role in fuel smuggling (S/2019/914, para. 164).
2. Illicit exports by sea

122. Global demand for marine fuels in 2020 experienced a sharp decline owing to
the impact on world trade of the COVID-19 pandemic. 82 The ready availability of
bunker fuel means market prices have remained low, including in the bunkering areas
near Libya and Malta. The current average price of marine gas oil (0.1 per cent
sulphur) in Malta is $453 per metric tonne, compared with $655 in December 2019. 83
123. This sharp decline of crude oil and bunker fuel prices has also increased the
demand for tankers as floating storage units. The floating storage capacity for refined
products peaked in mid-May 2020, 84 and demand for tankers continues to be high. 85
124. The reduction in demand for bunker fuels, high fuel availability, lower bunker
prices and the low availability of product tankers have had a negative impact on the
__________________
78
Safa Alharathy, “Joint force arrests alleged ISIS members, fuel smugglers and migrants”, Libya
Observer, 30 September 2020; and Rabia Golden, “Joint force seizes four fuel smuggling trucks”,
Libya Observer, 16 August 2020.
79
Shararah Oil Services, Libya Oil, Rahilah and Turek Saria.
80
See https://brega.ly/category/sales/ (in Arabic).
81
Three are currently operating in Misratah, two in Tripoli, one in Gharyan, one in Msallata, and
one in Zlitan.
82
Jack Jordan, “The bunker industry’s 2020 fell flat for all the wrong reasons”, Ship and Bun ker,
7 January 2021.
83
See www.oilmonster.com/bunker-fuel-prices/malta-mgo-01-price/8/94. 18 December 2020.
84
Hellenic Shipping News, “Refined oil product temporary floating storage at 65mn barrels”,
13 July 2020.
85
Jack Wittels and Prejula Prem, “Demand to store a glut of diesel at sea is rising fast”,
Bloomberg, 16 September 2020.
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parallel market of refined products, principally marine gas oil (0.1 per cent sulphur),
illicitly exported from Libya by sea.
125. Fuel diversion by sea has therefore been almost nil, and no tankers have been
added to the sanctions list.
126. The infrastructure of the smuggling networks from Zuwarah and Abu Kammash
remains intact and their readiness to conduct illicit exports is undiminished. A
resumption of their illicit activities, once global demand for bunker fuel recovers, is
to be expected (see recommendation 2 below).
3. The case of M/T Jal Laxmi

127. On May 2020, the Panel received information that a product tanker had intended
to illicitly export heavy fuel oil and marine gas oil from Tubruq, which, if successful,
would have been in non-compliance with resolution 2146 (2014) (see annex 85).
4. Illicit exports by land

128. Refined petroleum products continue to be illicitly exported overland. Although
small scale, the activity has increased compared with previous years, in particular in
western Libya, where mainly gas oil continues to be diverted from the Zawiyah oil
complex, via Jawsh and Nalut, to Tunisia. One litre of gasoline is sold in the parallel
markets in Zawiyah area at 0.5 Libyan dinars ($0.11), while in September 2019 it was
sold at 0.75 Libyan dinars ($0.17). One litre of gas oil peaked at 2.00 Libyan dinars
($0.45), while in 2019 it remained below 1.00 Libyan dinar ($0.22). 86
129. In the south and south-east of Libya, many fuel stations continue to be closed or
sell fuel at unofficial rates. Fuel supplies can, in general, be found only in parallel
markets, where fuel prices vary from 2.4 Libyan dinars ($0.54) in the Kufrah area to
1.75 Libyan dinars ($0.39) in Murzuq. The Subul al-Salam brigade, affiliated with
LNA, plays a major role in fuel diversion in the Kufrah area.
C. Illicit import of aviation fuel
130. The Panel followed and reported one instance and one attempt to import aviation
fuel to Benghazi, conducted by an entity outside the framework of the Libyan Political
Agreement (see para. 75 above and annex 86). The Panel finds that such imports
constitute a threat to the integrity of the National Oil Corporation (see
recommendation 3).
VI. Implementation of the assets freeze on designated entities

A. Overview
131. The Panel continued its engagement with the two designated entities, the Libyan
Investment Authority (LIA) (LYe.001), also known as the Libyan Foreign Investment
Company, and the Libyan Africa Investment Portfolio (LAIP) (LYe.002), as well as
other interested parties.
__________________
86
On 3 January 2021, the Central Bank of Libya massively devalued its dollar exchange rate from
1.39 Libyan dinars (per dollar) to 4.48 Libyan dinars (per dollar). See also para. 102 (above).
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B. Transformation strategy
132. LIA presented its transformation strategy to the Committee on 15 December

2020. Its stated intention is to propose adjustments to the sanctions regime.
133. LIA started its work on the transformation strategy in 2019 and hired Oliver
Wyman Limited in 2020 to assist with the development of a strategy in accordance with
the Santiago Principles 87 for sovereign wealth funds. The project 88 focused on
developing broad investment guidelines, a risk management strategy, a code of conduct
for employees and basic capacity-building.
134. LIA received the projects’ recommendations and committed itself to beginning
to implement them as from January 2021. While this reform is long overdue and a
step in the right direction, the Panel considers that LIA overestimates its adherence to
the Santiago Principles on account of a transformation plan that is yet to be enacted.
The Panel will continue to monitor its actual implementation.
C. Subsidiaries
135. The Panel previously reported on subsidiaries and the application of

Implementation Assistance Notice No. 1 in paragraph 221 of S/2018/812 and
paragraph 209 of S/2019/914. The Panel commented on the varying approaches of
Member States with regard to subsidiaries and recommended the review of
Implementation Assistance Notice No. 1 because it conflicted with the relevant
provisions of Security Council resolutions.
136. Further factors for considering the application of sanctions to subsidiaries are
indicated as follows (supported by a case study):
(a) Most of the assets are not held directly by the parent company but by
subsidiaries;
(b) The designated entities have 100 per cent shareholding in most of the
important subsidiaries and play a major role in their decision-making and governance;
(c) Without consolidated financial statements for parent companies, there is
no visibility of the activities, assets and financial position of the subsidiaries;
(d) Many of the subsidiaries are underperforming and supported financially
by the parent company;
(e) There is a lack of clarity concerning the beneficial ownership, legal
ownership and the control of investment within the LIA group, for example, the Long-
Term Portfolio;
(f) Beneficial ownership and control are significant determining factors for
the application of the assets freeze in several jurisdictions.
137. The Panel finds that the activities, income and expenditure of subsidiaries need
to be monitored to avoid diminishment or the flight of assets (see annex 87).
1. Case study: transfer of LAP GreenN

138. In 2015, the Libyan Africa Investment Portfolio (LYe.002) transferred its
interest in one subsidiary to another company. (see annex 87 for the full structure of
LAIP and its subsidiaries). LAIP Mauritius, set up in 2006 as a holding company, is a
__________________
87
See www.ifswf.org/santiago-principles-landing/santiago-principles.
88
Prior to the launch of the transformation strategy, a separate United Kingdom -funded project had
laid the groundwork for governance reform and adherence to the Santiago Principles.
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wholly owned subsidiary of LAIP Libya. LAIP Mauritius, in turn, has five
subsidiaries, including LAP GreenN Ltd., Uganda (see figure VII).
Figure VII
Libyan Africa Investment Portfolio relationship to LAP GreenN
139. In 2015, LAIP transferred its shares in LAP GreenN to the Libyan Post,
Telecommunication and Information Technology Holding Company for the nominal
value of $1. The real value of approximately $1.1 billion is still reflected on the LAIP
balance sheet. This cannot be resolved until the LAIP General Assembly passes a
resolution to correct this imbalance. The Panel notes that LIA is the sole shareholder
and therefore constitutes the LAIP Assembly (see annex 88).
140. A subsidiary is an asset on the balance sheet of the parent company. The freeze
of funds and other financial assets includes preventing their use, alteration,
movement, transfer or access, unless allowed under specific exemption procedures.
The transfer has the effect of dissipating LAIP assets and diminishing their value.
141. The Panel finds that this transfer is in non-compliance with the assets freeze.
2. Palladyne/Upper Brook case

142. Notwithstanding the removal of Dutch company Palladyne International Asset
Management as director in 2014, and the subsequent loss of a legal appeal in
November 2019 (S/2019/914, paras. 184–192), Palladyne remains the investment
manager of all three Cayman Islands incorporated Upper Brook funds, effectively
controlling the assets. At no point since 2014 have the Upper Brook funds a nd the
LIA made any effort to replace Palladyne as investment manager.
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143. LIA appointed a forensic auditor to determine the location and value of the
assets. The audit report was submitted to LIA in September 2020, but it has not been
shared with the Panel.89
144. LIA has neither visibility of nor control over the assets valued at $700 million
on the original investment, of which 98.5 per cent is held in Deutsche Bank (see
recommendations 5 and 6 below).
145. This case again highlights the risks associated with the non-visibility of
transactions involving subsidiaries and varying interpretations by Germany and the
Netherlands (see annex 89).
3. Long-Term Portfolio
146. The Panel reaffirms its position that the assets managed through the Long-Term
Portfolio were, and remain, legally in the name of the Libyan Foreign Investment
Company (S/2019/914, annex 71). This is reflected in the reports of LIA, custodian
banks and financial institutions. In its analysis of the impact of sanctions (para. 152),
LIA presented the assets as belonging to the Long-Term Portfolio rather than, more
accurately, to the Libyan Foreign Investment Company.
147. The Panel finds that LIA is obfuscating the legal ownership of these assets,
rendering them susceptible to misuse. The Panel therefore recommends that the Long -
Term Portfolio be added to the list of designated entities (see recommendation 7 below).
148. The former Chair of the Management Committee of the Long-Term Portfolio,
Sami Mabrouk, stated that, in June 2013, he had opened a new portfolio in Jordan
funded by interest and dividends from frozen Libyan Foreign Investment Company
assets. The interest and dividends themselves should have been frozen, and therefore
the creation of the new portfolio was in non-compliance with paragraph 20 of
resolution 1970 (2011). That situation developed thusly owing to the lack of
transparency over the management of the Libyan Foreign Investment Company assets,
combined with minimal corporate and individual accountability.
149. The Panel’s analysis could have been deeper had the Jordanian authorities
responded to the Panel’s requests for information. 90 The Panel recommends that all
Libyan Foreign Investment Company and Long-Term Portfolio assets in Jordan be
immediately frozen (see recommendation 8 below).
150. An analysis of the legal and financial status of the Long-Term Portfolio can be
found in annex 90.
4. Review of Implementation Assistance Notice No. 1

151. Considering the contradiction between Implementation Assistance Notice No. 1
and the resolutions, the additional factors outlined above and the lack of uniformity
in the application of Implementation Assistance Notice No. 1, the Panel considers that
its applicability needs to be reviewed, to avoid a risk in the dissipation of assets. (see
recommendation 9 below).
D. Impact of sanctions on frozen funds
152. LIA provided two reports to the Panel, for the period from 2011 to 2019: (a) one
prepared by an international consulting firm (consultant report) covering the
purported negative effects of the sanctions on LIA; and (b) one done at the Panel’s
__________________
89
Letter to the Office of the Libyan Attorney General dated 19 October 2020.
90
Letters dated 5 September 2019 and 1 June 2020.
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request, covering details of all the equities and dividends (overall report). Owing to
major inconsistencies between the reports, the Panel analysed them using information
from the Bloomberg system as an independent source.
153. It was acknowledged in the consultant report that LIA investment funds had
grown from $19.3 billion in December 2017 to $20.1 billion in December 2019.
154. Companies were selected for comparison in the consultant report that had
underperformed in the equity market and in which LIA had the most significant
amount of investment. It also considered the only share price return and not the total
dividends received, which, if included, would significantly increase the total
investment return.
155. The Panel examined the performance of the investment in the four LIA equity
samples chosen by the consulting firm. When dividends were included, a specific
picture emerged, as shown in table 8.
Table 8
Comparison of returns on four equities in the consultant report and the Bloomberg system
(Percentage)
Variance Overall return Understatement

Location Sector (consultant report) (Bloomberg system) of return
BASF Germany Chemicals 8.0 67.3 59.3

Bayer Germany Pharmaceuticals 27.4 82.2 54.8
General Electric United States of America Industrial (37.7) (4.4) 33.3
UniCredit Italy Bank (82.4) (25.6) 56.8
156. The Panel’s conclusions regarding the consultant report are as follows:
(a) The fundamental approach of comparing only four equities for each fund
across the entire market index was flawed;
(b) Dividends, an important part of overall return, were left out entirely;
(c) The loss presented is purely hypothetical. The quantification of impact
presumed that LIA exited the equity investment and reinvested in others. There is no
guarantee that the new investment would have performed in accordance with the
market, especially given that proper investment guidelines, appropriate internal
controls and monitoring were not in place;
(d) The fact that a sizeable part of the equity portfolio consists of long-term
strategic assets was overlooked. If these shares are not to be traded, then it is irrelevant
to project hypothetical returns as if the money had been invested elsewhere. These
holdings include BASF, Eni S.p.A., Finmeccanica (Leonardo), Repsol, Pearson and
UniCredit.
157. It was observed in the consultant report that the sanctions had a minimal impact
on LAIP investments, given that approximately 96 per cent of the funds (FM Capital
and Palladyne International Asset Management) were actively managed between 2011
and 2019. It is understood that two Member States issued licences in 2011 to FM
Capital, permitting the company to actively trade/manage assets. Some LIA investment,
which was actively traded, was also not considered in the analysis. This again highlights
the confusion generated by different interpretations adopted by Member States.
158. In the overall report, equities held in dollars and euros have shown an increase
in overall return since 2011. The increase of 61 per cent in dollar-based equity
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investment is a respectable performance. The equities held in pound sterling have

shown a downward trend (see table 9).
Table 9
Trend in returns in equities
Currency 2011 2019
Dollar 2.262 billion 3.670 billion

Euro 2.583 billion 3.107 billion
Pound sterling 589 million 356 million
159. The cash-sampling analysis presented in the consultant report shows that the
negative interest rates of the European Central Bank and the additional fee imposed
by Euroclear do affect LIA funds. LIA has raised this issue on several occasions and
was repeatedly advised to engage the relevant national authorities, fiscal policy being
the responsibility of each Member State. Neither LIA nor the Government of National
Accord have done so. This would better serve their interests instead of raising the
issue in forums that have no authority in the matter.
160. The negative interest on cash holdings has been estimated at $23 million. No
analysis has been done of the income/earnings accrued for equities and from term
deposits, either with the Central Bank of Libya or custodian banks. These continue to
accrue interest, which should be balanced against the negative interest above to provide
a more accurate overview. Interest and other earnings (S/2018/812, para. 199) were also
received from the frozen funds from 2011 until the issue of Implementation Assistance
Notice No. 6 in December 2018, which were used to fund day-to-day operations.
161. In conclusion, the issue of the impact of the assets freeze must be viewed in
totality. LIA has no investment policy or asset allocation guidelines that would
influence any changes in investment approach. There is therefore a clear risk to the
frozen assets from any easing of the sanctions.
162. The Panel reiterates its conclusions contained in paragraph 224 of S/2018/812,
wherein it held that financial charges were the cost of doing business and could not be
termed as losses, and its observations on equities made in paragraph 228 of S/2018/812.
163. The need to use an international consulting firm to provide reports to the Panel,
the discrepancies between the consultant report and the overall report, and the
inability of LIA to provide audited consolidated accounts are all indicative of an
organization that does not have a properly established back office, an appropriate
accounting department and adequate financial controls. As with the lack of investment
policies, there is a clear risk to the Libyan people’s money from any easing of the
sanctions while this situation persists.
E. Access to frozen funds
164. The Panel reviewed the approaches taken by Member States to allow access to
funds pursuant to paragraph 19 of resolution 1970 (2011) and paragraph 16 of
resolution 2009 (2011). The Panel also considered the submissions of the designated
entities regarding problems in gaining access to the frozen funds.
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165. The Panel notes the standard definition 91 of an assets freeze is preventing any
move, transfer, alteration or use of, access to, or dealing with funds in any way that
would result in any change in their volume, amount, location, ownership, possession,
character, destination or other change that would enable the funds to be used,
including portfolio management. The Panel also notes that, in paragraph 19 (a) of its
resolution 1970 (2011), the Security Council listed a series of minimal derogations
that applied to assets, regardless of whether they belonged to an individual or an
entity. Apart from paragraph 19 (a), there is no other provision for routine activities
to be considered for exemption.
166. The United Kingdom has, in general, interpreted paragraph 19 (a) of resolution
1970 (2011) in a manner consistent with the Panel’s interpretation. It agrees that that
any general policy in which “trading activity/asset management activity”
automatically falls under the definition of a basic expense would be an incorrect
interpretation of paragraph 19 (a). The United Kingdom, however, considers it
necessary to interpret paragraph 19 (a) by taking into account the purposes of the
Libya financial sanctions regime. One of these purposes is to ensure the eventual
return of the frozen assets to the Libyan people. On that basis, the United Kingdom
considers that, in specific limited circumstances, the definition of basic expense may
be interpreted to cover “trading activity/asset management activity”. The United
Kingdom states that the issuing of such licences does not give the designated entity
access to frozen funds, and consequently the intent of the assets freeze is maintained.
167. The Panel’s view is that a trading or asset management activity neither falls
under the auspices of being a basic expense nor fulfils the other conditions outlined
in paragraph 19 (a) of resolution 1970 (2011). An exemption notification cannot be
considered if it is not covered under any of the extant provisions found in paragraphs
19, 20 or 21 of resolution 1970 (2011) and paragraph 16 of resolution 2009 (2011),
regardless of whether the designated entity has access to the frozen funds. Any other
approach would be inconsistent with the definition and intent of an assets freeze as it
currently exists.
168. It was revealed in the consultant report that some LIA and LAIP assets were
actively managed, the assets freeze notwithstanding. This underscores the need to
review the application of the provisions of paragraph 19 of resolution 1970 (2011),
with a view to ensure uniform application. In view of the inconsistent interpretations
of said paragraph by some Member States, the Panel recommends that the Committee
provide suitable guidance on the scope of the exemptions under paragraph 19 (see
recommendation 10 below).
169. The Panel notes that all Member States do not always comply with the requirement
of notifying the Committee of their intention to authorize access to frozen funds. In
addition, insufficient information made available to the Panel makes it difficult to
identify cases of non-compliance. Unless Member State regulatory authorities take a
more proactive role in making financial data available to the Panel, recommendations
for effective implementation of the sanctions measures will be constrained.
170. The designated entities raised issues regarding their inability to gain access to
frozen funds for all their requirements in view of the specific exemption provisions
and procedural delays in obtaining licences from Member States.
171. There have been attachments and attempts to attach LIA frozen assets in
connection with claims against the Libyan State for pre-2011 contracts (S/2018/812,
__________________
91
As commonly defined in the financial legislation and administrative instructions of many
Member States.
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para. 198, and S/2019/914, annex 71), including one case in Belgium. 92 These
attachments risk the loss of LIA frozen assets.
172. Further details on access to frozen funds can be found in annex 91.
VII. Implementation of the assets freeze and travel ban on

designated individuals
A. Update on non-compliance with the travel ban
173. In paragraphs 219 to 221 of S/2019/914, the Panel reported on non-compliance

with the travel ban by Abu Zayd Umar Dorda (LYi.006) and Sayyid Mohammed
Qadhaf al-Dam (LYi.003). A response to the Panel’s requests for an update from Egypt
and Libya remains pending.
B. Updates on designated individuals
174. The Panel provides additional identifying information for the following
individuals:
LYi.012
Name: 1: Mohammed 2: Muammar 3: Qadhafi
Also known as: Muhammed Muammar Muhammed Abdul Salam

Passport number: Oman passport No. 03824969 (date of issue: 4 May 2014)
Identification number: 97183904 (Oman)
LYi.026
Name: 1: Abd 2: Al-Rahman 3: al-Milad 4: n/a
Also known as: Abdurahman Salem Ibrahim Milad
Date of birth: 27 July 1986
Passport number: G52FYPRL (date of issue: 8 May 2014; date of
expiration: 7 May 2022)
175. The Panel has further confirmed that Aisha Muammar Muhammed Abu Minyar
Qadhafi (LYi.009) and Mohammed Muammar Qadhafi (LYi.012) both have Omani
citizenship. The Government of Oman provides their housing and basic expenses.
Safia Farkash Al-Barassi (LYi.019) has been residing in Egypt since 2015 without any
residency documents or financial support from the authorities.
C. Actions taken for the effective implementation of the assets freeze

and travel ban measures
176. Progress towards effective implementation of the assets freeze measures has
been slow in Libya. While the Office of the Libyan Attorney General took
__________________
92
Louis Colart, “Revirement du gouvernement sur le dossier «libyen» du prince Laurent: déblocage
en vue?”, Le Soir, 13 January 2021 (in French).
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administrative measures to identify the assets of designated individuals, to date, these

measures have not resulted in identification, let alone freezing. On 20 May 2020, the
Ministry of Interior instructed the Central Bank of Libya to implement the resolutions
regarding the designated individuals Mus’ab Mustafa Abu al Qassim Omar (LYi.024),
Ahmad Oumar Imhamad al-Fitouri (LYi.023), Mohammed Al Amin Al-Arabi Kashlaf
(LYi.025) and Abd Al-Rahman al-Milad (LYi.026). While the Central Bank of Libya
acknowledged receipt of the request on 31 May 2020, it remains unclear what
administrative action, if any, has been taken.
177. On 14 October 2020, Abd Al-Rahman al-Milad (LYi.026) was arrested by the
Tripoli Security Directorate on charges of human trafficking and fuel smuggling and
placed under provisional detention. The Panel has not received details of the Libyan
investigation into his finances and properties. The circumstances surrounding his
arrest in October 2020 illustrate the competing interests within the Government of
National Accord security services, to the detriment of law enforcement. The arrest
was followed by a backlash from the Military Prosecutor, who requested the transfer
of the Libyan Coast Guard commander under his authority. 93 The whereabouts of
al-Milad were unknown at the time of drafting of the present report.
178. The Panel has received no information from other Member States on the
identification of assets or identifying information of individuals.
179. The lack of complete identifying information in the sanctions list hinders the
effective implementation of the measures.
VIII. Recommendations
180. The Panel recommends:
To the Security Council

Recommendation 1. To consider mandating the Committee to designate aircraft and
impose the following measures on them: (a) flag deregistration;
(b) a landing ban; and (c) an overflight ban. [see para. 84 above]
Recommendation 2. To authorize Member States to inspect, on the high seas off the
coast of Libya, vessels bound to or from Libya that they have
reasonable grounds to believe are illicitly exporting or attempting
to export crude oil or refined petroleum products. [see para. 126]
Recommendation 3. To extend the scope of the measures contained in resolution
2146 (2014) to the illicit import of refined petroleum products
[see para. 130]
To the Committee
Recommendation 4. To urge Libya to:
(a) Implement measures to put an end to the arbitrary detention of migrants
and asylum seekers [see paras. 42–46];
(b) Effectively investigate, arrest, prosecute and bring to justice the
perpetrators of the killings in Mizdah through fair and transparent proceedings that
respect the rights of the accused and provide reparation to victims, and share
information on the entities or individuals involved [see paras. 47–50];
__________________
93
Letter from the Military Prosecutor dated 13 December 2020.
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(c) Investigate the status of the other detainees who were held in the Mizdah
warehouse at the time of the killings and share its findings with the Panel [see paras.
47–50].
Recommendation 5. To urge the Libyan Investment Authority (LYe.001) to reassert
control over the Upper Brook/Palladyne assets. [see para. 144]
Recommendation 6. To urge relevant Member States to freeze all Upper
Brook/Palladyne assets in their jurisdiction. [see paras. 144 and
145]
Recommendation 7. To include the Long-Term Portfolio as an alias of the Libyan
Investment Authority (LYe.001). [see para. 147]
Recommendation 8. To urge the relevant Member State to identify, audit and freeze
all Libyan Foreign Investment Company and Long-Term
Portfolio assets held in its jurisdiction. [see para. 149]
Recommendation 9. To review the applicability of Implementation Assistance
Notice No. 1 in view of the contradiction with the resolutions
and in the light of the additional information regarding a lack
of uniformity in its application and the risk in the dissipation
of assets. [see para. 151]
Recommendation 10. To provide guidance on the scope of the exemptions as
provided under paragraph 19 of resolution 1970 (2011), in
particular to clarify whether the active management of the
frozen assets of designated entities is envisaged. [see para. 168]
Recommendation 11. To update the sanctions list with the additional identifying
information. [see para. 174]
Recommendation 12. To expeditiously consider the information provided separately
by the Panel since 2018 on entities and individuals meeting the
designation criteria, as contained in the relevant Security
Council resolutions.
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IX. Annexes
Contents Page
Overview of the evolution of the Libya sanctions regime ....................................... 51

Abbreviations and acronyms ................................................................................... 54
Methodology ............................................................................................................ 58
Member States, organizations and institutions consulted ........................................ 64
Summary of Panel correspondence ........................................................................ 66
Continued encroachment of armed groups on state institutions .............................. 72
Counter-terrorism related events in Libya (2020) ................................................... 74
The Case of Mohamed Bahrun ................................................................................ 77
Chadian and Sudanese presence in Libya ................................................................ 83
Background and timeline of the Black Shield case ................................................. 88
Geolocations of Syrians in Libya (May to August 2020) ........................................ 99
Funding sources for the LNA’s Military Investment Authority ............................ 102
Bribery attempts at the Libyan Political Dialogue Forum ..................................... 119
Sabratha and Surman ............................................................................................. 120
Minister’s statement following GNA takeover of Tarhuna (6 June 2020) ............ 122
Ministry of Justice’s statement on Tarhuna mass graves (10 June 2020) ............. 123
Overview of the Libya-Malta and Libya-Italy migration agreements and evolution of
the EUNAVFOR MED Operation ......................................................................... 124
Overview of the situation in DCIM detention centres according to Colonel Mabrouk
Abdelhafid (1 September 2020) ............................................................................ 125
Provisions of international human rights law (IHRL) and international humanitarian
law (IHL) applicable to the situation of migrants and asylum seekers.................. 126
Ministry of Interior statement on Mizdah (28 May 2020)..................................... 128
Ministry statement on Al-Khadra General Hospital (9 April 2020) ...................... 129
Evidence related to the attack on Tripoli Military Academy (4 January 2020) .... 130
Infographics for Pantsir S-1 AD system (on KaMAZ 6560 mobility platform) ... 137
Infographics for Gabya Class frigates ................................................................... 140
Infographic for HAWK MiM-23 air defence system ............................................ 142
Infographics for Korkut Twin 35mm Air Defence system.................................... 143
Infographic for TAI Anka UCAV ......................................................................... 145
Infographic for Firtina T-155mm self-propelled howitzer .................................... 146
Infographic for T122 Sakarya MLRS .................................................................... 147
Infographic for STM Kargu-2 loitering munition ................................................. 148
Infographic for Mig-29A FGA .............................................................................. 149
Infographic for Sukhoi SU-24 FGA ...................................................................... 150
Maritime non-compliance profile indicators ......................................................... 151
Summary of maritime non-compliances (trafficking to GNA-AF) ....................... 152
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Summary of maritime non-compliances (trafficking to HAF) .............................. 174

Infographic for Dehleyvah ATGM ........................................................................ 177
Infographic for FNSS ACV-15.............................................................................. 178
Infographic for Harpy loitering munition .............................................................. 179
Airbridges in support of the GNA-AF ................................................................... 180
Infographic for Misagh-2 MANPADS .................................................................. 191
Bulgarian manufactured 120mm Mortar Bomb .................................................... 192
GNA-AF Diver Training in Khoms....................................................................... 193
GNA-AF Training on T155 Firtina Howitzer ....................................................... 194
GNA-AF Military Training ................................................................................... 195
GNA Coast Guard Training ................................................................................... 196
GNA-AF Special Forces Training ......................................................................... 197
LENCO Bearcat APC with GNA-AF .................................................................... 198
GNA-AF Forward Observation Officer (FOO) Training ...................................... 199
GNA-AF Abseil Training ...................................................................................... 200
GNA payments to Turkish arms group SSTEK .................................................... 201
HAF Training in Jordan (2018) ............................................................................. 207
Serbian manufactured P62M8 120mm Mortar Bomb ........................................... 208
Infographic for KADDB Mared 8x8 MPAV with “snakehead” turret .................. 209
Infographic for TAG/AOI Terrier LT79 AFV....................................................... 210
Airbridges in support of HAF ................................................................................ 211
Infographic for Inkas Titan-DS APV .................................................................... 282
Wing Loong II UCAV redeployed to Egyptian airbase ........................................ 283
Infographic for Dahua counter-drone weapon....................................................... 284
HAF Pilot Training in Syria .................................................................................. 285
Infographic for KBP RPO-A Shmel ...................................................................... 286
Infographic for Dassault Mirage 2000-9 ............................................................... 287
Infographic for “Wagner” armoured vehicle ......................................................... 288
Infographic for MIC VPK Tigr-M APV................................................................ 289
Infographic for T-62 main battle tank upgrade ..................................................... 290
Infographic for ML-8 anti-lift initiator .................................................................. 291
Infographic for interdiction of 4x4 vehicles in Malta............................................ 292
Infographic for PMN-2 anti-personnel mine (APM) ............................................. 293
Infographic for 96L6/E C-Band acquisition radar ................................................. 294
Training at RMC Jordan (16 September 2020) ..................................................... 295
Infographic for POM-2R anti-personnel mine (APM) .......................................... 296
Infographic for G5 155mm / 45 calibre gun howitzer ........................................... 297
Infographic for 128m Morava 128mm multi-barrel rocket system (LRSCM) ...... 298
Infographic for Xiamen Mugin 4450 unmanned aerial vehicle (UAV) ................ 299
Infographic for WP Warmate loitering munition .................................................. 300
Airbridge non-compliance profile indicators ........................................................ 301
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Project Opus PMC operation ................................................................................. 306

ChVK Wagner in Libya ......................................................................................... 428
Member States and regional organizations responses during 2020 to arms embargo
violations ............................................................................................................... 467
Oil blockade ........................................................................................................... 468
Letters from eastern authorities challenging the NOC legitimacy ........................ 469
New Board of Directors of Brega Petroleum Marketing Company ...................... 474
Attempts to illicitly export crude oil...................................................................... 475
Attempts to illicitly export condensate .................................................................. 477
Establishment of the ‘Joint Forces’ to fight fuel smuggling ................................. 478
The case of M/T Jal Laxmi .................................................................................... 481
The case of M/T Gulf Petroleum 4 and M/T Royal Diamond 7............................ 489
Subsidiaries ............................................................................................................ 496
Documentation regarding LAP GreenN transfer ................................................... 515
Palladyne/Upper Brook Case................................................................................. 518
LTP as a separate entity ......................................................................................... 522
Access to frozen funds ........................................................................................... 547
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Overview of the evolution of the Libya sanctions regime
1. By resolution 1970 (2011), the Council expressed grave concern at the situation in Libya,
condemned the violence and use of force against civilians and deplored the gross and systematic
violation of human rights. Within that context, the Council imposed specific measures on Libya,
under Chapter VII of the Charter of the United Nations, including the arms embargo, which relates
to arms and related materiel of all types, including weapons and ammunition, military vehicles and
equipment, paramilitary equipment, and spare parts for the aforementioned, in addition to the
provision of armed mercenary personnel. The arms embargo covers both arms entering and leaving
Libya. The Council also imposed travel ban and assets freeze measures, and listed individuals as
subject to one or both measures, in the resolution. Furthermore, the Council decided that the travel
ban and the asset freeze were to apply to the individuals and entities designated by the Committee
established pursuant to resolution 1970 (2011) concerning Libya involved in or complicit in
ordering, controlling or otherwise directing the commission of serious human rights abuses against
persons in Libya.
2. By resolution 1973 (2011), the Council strengthened the enforcement of the arms embargo
and expanded the scope of the asset freeze to include the exercise of vigilance when doing business
with Libyan entities, if States had information that provided reasonable grounds to believe that
such business could contribute to violence and use of force against civilians. Additional individuals
subject to the travel ban and asset freeze were listed in the resolution, in addition to five entities
subject to the freeze. The Council decided that both measures were to apply also to individuals and
entities determined to have violated the provisions of the previous resolution, in particular the
provisions concerning the arms embargo. The resolution also included the authorization to protect
civilians and civilian populated areas under threat of attack in Libya. In addition, it included a no-
fly zone in the airspace of Libya and a ban on flights of Libyan aircraft.
3. On 24 June 2011, the Committee designated two additional individuals and one additional
entity subject to the targeted measures. By resolution 2009 (2011), the Council introduced
additional exceptions to the arms embargo and removed two listed entities subject to the asset
freeze, while allowing the four remaining listed entities to be subjected to a partial asset freeze. It
also lifted the ban on flights of Libyan aircraft.
4. By resolution 2016 (2011)), the Council terminated the authorization related to the protection
of civilians and the no-fly zone. On 16 December 2011, the Committee removed the names of two
entities previously subject to the asset freeze.
5. In resolution 2040 (2012), the Council directed the Committee, in consultation with the
Libyan authorities, to review continuously the remaining measures with regard to the two listed
entities – the Libyan Investment Authority and the Libyan Africa Investment Portfolio – and
decided that the Committee was, in consultation with the Libyan authorities, to lift the designation
of those entities as soon as practical.
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6. In resolution 2095 (2013), the Council further eased the arms embargo in relation to Libya
concerning non-lethal military equipment.
7. By resolution 2144 (2014), the Council stressed that Member States notifying to the
Committee the supply, sale or transfer to Libya of arms and related materiel, including related
ammunition and spare parts, should ensure such notifications contain all relevant information, and
should not be resold to, transferred to, or made available for use by parties other than the designated
end user.
8. By resolution 2146 (2014), the Council decided to impose measures, on vessels to be
designated by the Committee, in relation to attempts to illicitly export crude oil from Libya and
authorized Member States to undertake inspections of such designated vessels.
9. By resolution 2174 (2014), the Council introduced additional designation criteria and
requested the Panel to provide information on individuals or entities engaging or providing support
for acts that threaten the peace, stability of security of Libya or obstructing the completion of the
political transition. The resolution strengthened the arms embargo, by requiring prior approval of
the Committee for the supply, sale or transfer of arms and related materiel, including related
ammunition and spare parts, to Libya intended for security or disarmament assistance to the Libyan
government, with the exception of non-lethal military equipment intended solely for the Libyan
government. The Council also renewed its call upon Member States to undertake inspections
related to the arms embargo, and required them to report on such inspections.
10. By resolution 2213 (2015), the Council extended the authorizations and measures in relation
to attempts to illicitly export crude oil from Libya until 31 March 2016. The resolution further
elaborated the designation criteria listed in resolution 2174 (2014).
11. By resolution 2214 (2015), the Council called on the 1970 Committee on Libya to consider
expeditiously arms embargo exemption requests by the Libyan government for the use by its
official armed forces to combat specific terrorist groups named in that resolution.
12. By resolution 2259 (2015), the Council confirmed that individuals and entities providing
support for acts that threaten the peace, stability or security of Libya or that obstruct or undermine
the successful completion of the political transition must be held accountable, and recalled the
travel ban and assets freeze in this regard.
13. By resolution 2278 (2016) the Council extended the authorizations and measures in relation
to attempts to illicitly export crude oil, while calling on the Libyan Government of National Accord
(GNA) to improve oversight and control over its oil sector, financial institutions and security
forces.
14. By resolution 2292 (2016), the Council authorized, for a period of twelve months,
inspections on the high seas off the coast of Libya, of vessels that are believed to be carrying arms
or related materiel to or from Libya, in violation of the arms embargo.
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15. By resolution 2357 (2017), the Council extended the authorizations set out in resolution 2292
(2016) for a further 12 months.
16. By resolution 2362 (2017), the Council extended until 15 November 2018 the authorizations
provided by and the measures imposed by resolution 2146 (2014), in relation to attempts to illicitly
export crude oil from Libya. These measures were also applied with respect to vessels loading,
transporting, or discharging petroleum, including crude oil and refined petroleum products, illicitly
exported or attempted to be exported from Libya.
17. By resolution 2420 (2018), the Council further extends the authorizations, as set out in
resolution 2292 (2016) and extended by resolution 2357 (2017), for a further 12 months from the
date of adoption of the resolution.
18. By resolution 2441 (2018), the Council extended until 15 February 2020 the authorizations
export crude oil from Libya.
resolution 2292 (2016) and extended by resolutions 2357 (2017) and 2420 (2018), for a further 12
months from the date of adoption of the resolution.
20. By resolution 2509 (2020), the Council extended until 30 April 2021 the authorizations
export crude oil from Libya.
resolution 2292 (2016) and extended by resolutions 2357 (2017), 2420 (2018), and 2473 (2019),
for a further 12 months from the date of adoption of the resolution.
To date the Committee has published six implementation assistance notices which are available
on the Committee’s website.1
__________________
1
http://www.un.org/sc/committees/1970/notices.shtml.
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Abbreviations and acronyms
ACA Administrative Control Authority

ACV Armoured Combat Vehicle
AFV Armoured Fighting Vehicle
AGO Attorney General’s Office
AIS Automatic Identification System
ALOC Air Line of Communication
AOC Air Operator Certificate
APC Armoured Personnel Carrier
APM Anti-Personnel Mine
APV Armoured Patrol Vehicle
ASM Air to Surface Misile
ATC Air Traffic Control
ATGM Anti-Tank Guided Missile
ATGW Anti-Tank Guided Weapon
AQ Al-Qaida
AQIM Al-Qaida in the Islamic Maghreb
ARMSCOR South Africa's Department of Defence acquisition agency
ATGM Anti-Tank Guided Missile
BCP Border Checkpoint
CBL Central Bank of Libya
CCMSR Conseil du Commandement Militaire pour le Salut de la République
CEO Chief Executive Office
CIHL Customary International Humanitarian Law
Committee Committee established pursuant to Security Council resolution 1970
(2011) concerning Libya
Council United Nations Security Council
DC Detention Centre
DCIM Directorate for Combating Illegal Migration
ECB European Central Banc
ECBL Easter Central Bank of Libya
ENOC Eastern National Oil Corporation
EOD Explosive Ordnance Disposal
ERA Explosive Reactive Armour
EU European Union
EUBAM European Union Border Assistance Mission EUC End-user certificate
EUNAVFOR EU Naval Force Mediterranean
EUR Euro
EUROJUST EU Judicial Cooperation Unit
FACT Front pour l’Alternance et la Concorde au Tchad
FAE Fuel/Air Explosive
FATC Fusion and Targeting Cell
FGA Fighter Ground Attack
FIBUA Fighting in Built Up Areas
FIR Flight Information Region
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FOO Forward Observation Officer

FSG Frontier Service Group
GACS General Administration for Coastal Security
GIS General Intelligence Service
GMMR Great Man-Made River
GNA Government of National Accord
GNA-AF Government of National Accord Affiliated Forces
GOJO Government of Jordan
GSA General Sales Agency Agreement
GSLF Gathering of the Sudan Liberation Forces
GT Gross Tonnes
HAF Haftar Affiliated Forces
HFO Heavy Fuel Oil
HMV High Mobility Vehicle
HVT High Value target
IAFV Infantry Armoured Fighting Vehicle
IAI Israeli Aircraft Industries
IAN Implementation Assistance Notice
ISR Intelligence Surveillance and Reconnaissance
ICC International Criminal Court
ICCPR International Covenant on Civil and Political Rights
IDP Internally Displaced Persons
IED Improvised explosive device
IHL International Humanitarian Law
IHRL International Human Rights Law
IMO International Maritime Organization
IOM International Organization for Migration
ISIL Islamic State in Iraq and the Levant
ISIR Intelligence Surveillance and Reconnaissance
ITAR International Traffic in Arms Regulations
JEM Justice and Equality Movement
JNIM Jamaat Nusrat al Islam wal Muslimin
JSC Joint Stock Company
KADDB King Abdullah II Design and Development Bureau
km kilometres
LAFICO Libyan Arab Foreign Investment Company, a.k.a. LFIC
LAICO Libyan African Investment Company
LAIP Libyan African Investment Portfolio
LASA Light Attack and Surveillance Aircraft
LAWS Lethal Autonomous weapons Systems
LCG Libyan Coast Guard
LFB Libyan Foreign Bank
LFIC Libyan Foreign Investment Company, a.k.a. LAFICO
LIA Libyan Investment Authority
LIFG Libyan Islamic Fighting Group
LLC Limited Liability Company
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LM Loitering Munition
LNA Libyan National Army
LOC Lines of Communication
LPDF Libyan Political Dialogue Forum
LRIT Long-Range Identification and Tracking system
LTP Long Term Portfolio
LUH Light Utility Helicopter
LYD Libyan Dinar
MANPADS Man Portable Air-Defense System
MBT Main Battle Tank
MIA Military Investment authority
MGO Marine Gasoil
MLRS Multi-Launch Rocket System
MMSI Maritime Mobile Service Identity
MRAP Mine Resistant Ambush Protected
MSPV Minerva Special Purpose Vehicle
MSR Main Supply Route
MUH Medium Utility Helicopter
M/T Motor Tanker
M/V Motor Vessel
NATO North Atlantic Treaty Organization
NGO Non-governmental organization
NM Nautical Miles
NOC National Oil Corporation
OCHA Office for the Coordination of Humanitarian Affairs
OHCHR Office of the High Commissioner for Human Rights
Panel Panel of Experts
PAR Parti d’Action Républicaine
PC Presidency Council
PIAM Palladyne International Asset Management
PFG Petroleum Facilities Guard
PMC Private Military Company
RHIB Rigid Hulled Inflatable Boats
RPA Remotely Piloted Aircraft
RSB Rossiskie System Bezopasnosti
RSF Rapid Support Forces
RWS Remote Weapon System
SACAA South African Civil Aviation Authority
SALW Small Arms and Light Weapons
SAM Surface to Air Missile
SARWP Stabilised Advance Remote Weapon Platform
SEAD Suppression of Enemy Air Defence
SIGINT Signal Intelligence
SRAC Sudanese Revolutionary Awajening Council
SRF Sudanese Revolutionary Front
SCUBA Self-Contained Undewater Breathing Apparatus
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SDF Special Deterrence Force

SEAD Suppression of Enemy Air Defence
SGBV Sexual Gender-Based Violence
SLA Sudan Liberation Army
SLA/AW Sudan Liberation Army/Abdul Wahid
SLA/MM Sudan Liberation Army/Minni Minawi
SRSG Special Representative of the Secretary-General
TMA Tripoli Military Academy
TPF Tripoli Protection Force
TRB Tripoli Revolutionaries Brigade
UAE United Arab Emirates
UAV Unmanned Aerial Vehicle
UCAV Unmanned Combat Aerial Vehicle
UID Unidentified
UMTAS Uzun Menzilli Tanksavar Sistemi
UN United Nations
UNHCR United Nations High Commissioner for Refugees
UNMAS UN Mine Action Service
UNSMIL UN Support Mission in Libya
URL Unified Resource Locator
US AFRICOM United States Africa Command
USD United States Dollars
UTC Universal Coordinated Time
VBIED Vehicle Borne IED
VBSS Vessel Board Search and Seizure
VTC Video Teleconferencing
WFP World Food Programme
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Methodology
1. The Panel ensured compliance with the standards recommended by the Informal Working
Group of the Security Council on General Issues of Sanctions (S/2006/997). Those standards call
for reliance on verified, genuine documents and concrete evidence and on-site observations by the
experts, including taking photographs, wherever possible. When physical inspection is not
possible, the Panel will seek to corroborate information using multiple, independent sources to
appropriately meet the highest achievable standard, placing a higher value on statements by
principal actors and first-hand witnesses to events.
2. The Panel used satellite imagery of Libya procured by the United Nations from private
providers to support investigations, as well as open source imagery. Commercial databases recording
maritime and aviation data were referenced. Public statements by officials through their official
media channels were accepted as factual unless contrary facts were established. Any mobile phone
records from service providers were also accepted as factual. While the Panel wishes to be as
transparent as possible, in situations in which identifying sources would have exposed them or others
to unacceptable safety risks, the Panel decided not to include identifying information in this
document and instead placed the relevant evidence in United Nations secure archives.
3. The Panel reviewed social media, but no information gathered was used as evidence unless
it could be corroborated using multiple independent or technical sources, including eyewitnesses,
to appropriately meet the highest achievable standard of proof.
4. The spelling of toponyms within Libya often depends on the ethnicity of the source or the
quality of transliteration. The Panel has adopted a consistent approach in the present update. All
major locations in Libya are spelled or referenced as per the UN Geographical Information System
(GIS) map at appendix A.
5. The Panel has placed importance on the rule of consensus among the Panel members and
agreed that, if differences and/or reservations arise during the development of reports, it would
only adopt the text, conclusions and recommendations by a majority of five out of the six members
including the Coordinator. In the event of a recommendation for designation of an individual or a
group, such recommendation would be done on the basis of unanimity.
6. The Panel is committed to impartiality in investigating incidents of non-compliance by any
party.
7. The Panel is equally committed to the highest degree of fairness and has offered the
opportunity to reply to Member States, entities and individuals involved in the majority of
incidents that are covered in this update. Their response has been taken into consideration in the
Panel’s findings. The methodology for this is provided in appendix B.
8. The Panel’s methodology, in relation to its investigations concerning IHL, IHRL and human
rights abuses, is provided in appendix C.
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Appendix A to Annex 3: UN GIS place name identification
Figure 3.A.1
UN GIS place names Libya
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Appendix B to Annex 3: ‘The opportunity to reply’ methodology used by the Panel
1. Although sanctions are meant to be preventative not punitive, it should be recognized that
the mere naming of an individual or entity2 in a Panel’s report, could have adverse effects on the
individual. As such, where possible, individuals concerned should be provided with an opportunity
to provide their account of events and to provide concrete and specific information/materiel in
support. Through this interaction, the individual is given the opportunity to demonstrate that their
alleged conduct does not fall within the relevant listing criteria. This is called the ‘opportunity to
reply’.
2. The Panel’s methodology on the opportunity to reply is as follows:
(a) Providing an individual with an ‘opportunity to reply’ should be the norm;
(b) The Panel may decide not to offer an opportunity of reply if there is credible evidence that
it would unduly prejudice its investigations, including if it would:
(i) Result in the individual moving assets if they get warning of a possible
recommendation for designation;
(ii) Restrict further access of the Panel to vital sources;
(iii) Endanger Panel sources or Panel members;
(iv) Adversely and gravely impact humanitarian access for humanitarian actors in the field;
or
(v) For any other reason that can be clearly demonstrated as reasonable and justifiable in
the prevailing circumstances.
3. If the circumstances set forth in 2 (b) do not apply, then the Panel should be able to provide
an individual an opportunity to reply.
4. The individual should be able to communicate directly with the Panel to convey their
personal determination as to the level and nature of their interaction with the Panel.
5. Interactions between the Panel and the individual should be direct, unless in exceptional
circumstances.
6. In no circumstances can third parties, without the knowledge of the individual, determine for
the individual its level of interaction with the Panel.
7. The individual, on the other hand, in making their determination of the level and nature of
interaction with the Panel, may consult third parties or allow third parties (for example, legal
representative or his/her government) to communicate on his/her behalf on subsequent interactions
with the Panel.
__________________
2
Hereinafter just the term individual will be used to reflect both.
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Appendix C to Annex 3: Violations relating to IHL, IHRL, and acts that constitute human
rights abuses investigative methodology
1. The Panel adopted the following stringent methodology to ensure that its investigations met
the highest possible evidentiary standards, despite it being prevented from visiting Libya. In doing
so it has paid particular attention to the “Informal Working Group on General Issues of Sanctions
Reports”, S/2006/997, on best practices and methods, including paragraphs 21, 22 and 23.
2. The Panel’s methodology, in relation to its investigations concerning IHL, IHRL and human
rights abuses, is set out as below:
(a) All Panel investigations are initiated based on verifiable information being made available
to the Panel, either directly from sources or from media reports.
(b) In carrying out any investigations on the use of explosive ordnance against the civilian
population, the Panel will rely on at least three or more of the following sources of
information:
(i) At least two eye-witnesses or victims;
(ii) At least one individual or organization (either local or international) that has also
independently investigated the incident;
(iii) If there are casualties associated with the incident, and if the casualties are less than
ten in number, the Panel obtains copies of death certificates and medical certificates.
In incidents relating to mass casualties, the Panel relies on published information from
the United Nations and other organizations;
(iv) Technical evidence, which includes imagery of explosive events such as the impact
damage, blast effects, and recovered fragmentation. In all cases, the Panel collects
imagery from at least two different and unrelated sources. In the rare cases where the
Panel has had to rely on open source imagery, the Panel verifies that imagery by
referring it to eyewitnesses or by checking for pixilation distortion;
a. In relation to air strikes, the Panel often identifies the responsible party through
crater analysis or by the identification of components from imagery of
fragmentation; and
b. The Panel also analyses imagery of the ground splatter pattern at the point of
impact from mortar, artillery, or free flight rocket fire to identify the direction
from which the incoming ordnance originated. This is one indicator to assist in
the identification of the perpetrator for ground fire when combined with other
source information.
(v) The utilisation of open source or purchased satellite imagery wherever possible, to
identify the exact location of an incident, and to support analysis of the type and extent
21-01654 61/548
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of destruction. Such imagery may also assist in the confirmation of timelines of the
incident;
(vi) Access to investigation reports and other documentation of local and international
organizations that have independently investigated the incident;
(vii) Other documentation that supports the narrative of sources, for example, factory
manuals that may prove that the said factory is technically incapable of producing
weapons of the type it is alleged to have produced;
(viii) In rare instances where the Panel has doubt as to the veracity of available facts from
other sources, local sources are relied on to collect specific and verifiable information
from the ground. (For example, if the Panel wished to confirm the presence of an armed
group in a particular area);
(ix) Statements issued by or on behalf of a party to the conflict responsible for the incident;
and/or
(x) Open source information to identify other corroborative or contradictory information
regarding the Panel’s findings.
(c) In carrying out its investigations on depravation of liberty and associated violations the Panel
relies on the following sources of information:
(i) The victims, where they are able and willing to speak to the Panel, and where medical
and security conditions are conducive to such an interview;
(ii) The relatives of victims and others who had access to the victims while in custody.
This is particularly relevant in instances where the victim dies in custody;
(iii) Interviews with at least one individual or organization (either local or international)
that has also independently investigated the incident;
(iv) Medical documentation and, where applicable, death certificates;
(v) Documentation issued by prison authorities;
(vi) Interviews with medical personnel who treated the victim, wherever possible;
(vii) Investigation and other documentation from local and international organizations that
have independently investigated the incident. The Panel may also seek access to court
documents if the detainee is on trial or other documentation that proves or disproves
the narrative of the victim;
(viii) Where relevant, the Panel uses local sources to collect specific and verifiable
information from the ground, for example, medical certificates;
(ix) Statements issued by the party to the conflict responsible for the incident; and/or
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(x) Open source information to identify other corroborative or contradictory information

(d) In carrying out its investigations on other violations, which can include forced displacement
and threats against medical workers, the Panel relies on information that includes:
(i) Interviews with victims, eyewitnesses, and direct reports where they are able and
willing to speak to the Panel, and where conditions are conducive to such an interview;
(ii) Interviews with at least one individual or organization (either local or international)
that has also independently investigated the incident;
(iii) Documentation relevant to verify information obtained;
(iv) Statements issued by the party to the conflict responsible for the incident; and/or
(v) Open source information to identify other collaborative or contradictory information
(e) The standard of proof is met when the Panel has reasonable grounds to believe that the
incidents had occurred as described and, based on multiple corroboratory sources, that the
responsibility for the incident lies with the identified perpetrator. The standard of proof is
“beyond a reasonable doubt”.
(f) Upon completion of its investigation, wherever possible, the Panel provides those
responsible with an opportunity to respond to the Panel’s findings in so far as it relates to the
attribution of responsibility. Detailed information on incidents will not be provided when
there is a credible threat that would threaten Panel sources.
(g) If a party does not provide the Panel with the information requested, as called upon by
paragraph 13 of resolution 2509 (2020), the Panel may consider this for reporting to the
Committee.
3. The Panel will not include information in its reports that may identify or endanger its sources.
Where it is necessary to bring such information to the attention of the Council or the Committee,
the Panel may include more source information in confidential annexes.
4. The Panel will not divulge any information that may lead to the identification of victims,
witnesses, and other particularly vulnerable Panel sources, except: 1) with the specific permission
of the sources; and 2) where the Panel is, based on its own assessment, certain that these individuals
would not suffer any danger as a result. The Panel stands ready to provide the Council or the
Committee, on request, with any additional imagery and documentation to supports the Panel’s
findings beyond that included in its reports. Appropriate precautions will be taken though to protect
the anonymity of its sources.
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Member States, organizations and institutions consulted
1. This list excludes certain individuals, organisations or entities with whom the Panel met, in
order to maintain the confidentiality of the source(s) and so as not to impede the ongoing
investigations of the Panel.
Table 4.1
ab
Member States, organizations, institutions and individuals consulted
Representative or International Institution / NGO /

Country/ Location Government
Organization Individual
Austria Permanent Mission to the UN
Bangladesh Permanent Mission to the UN
Embassy to Libya
Belgiuma EEAS
China a,b Permanent Mission to the UN
Egypt Ministries of Foreign Affairs, Permanent Mission to the UN
Finance and Defence
France a,b Ministries of Foreign Affairs, Permanent Mission to the UN NGO
Finance and Defence Embassy to Libya (in Tunis)
Germany a Ministries of Foreign Affairs, Permanent Mission to the UN Deutsches
Finance, and Economy and Bundesbank
Energy
Italy Permanent Mission to the UN MEDU
HQ EU NAVFOR Individuals
Jordan Permanent Mission to the UN
Libya Presidency Council, Permanent Mission to the UN Designated
Ministries of Interior, IOM entities
Defence and Justice, Libyan UNHCR CBL
Coast Guard, Audit Bureau, UNSMIL NOC
security agencies Individuals
NGOs
Malta Ministry of Foreign Affairs Permanent Mission to the UN Individuals
Morocco Ministries of Foreign Affairs,
Interior, and General
Directorate of National
Security
Netherlands Ministries of Foreign Affairs, Eurojust Individuals
Europol
ICC
South Africa Individuals
Spain EU Satellite Centre
Sudan Permanent Mission to the UN Individuals
Sweden Inspectorate of Strategic
Projects
Switzerland Permanent Mission to the UN Individuals
UN OHCHR NGO
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Representative or International Institution / NGO /

Country/ Location Government
Organization Individual
Tunisia a,b Ministries of Foreign Affairs Permanent Mission to the UN NGO
Defence, Finance, Interior EU Delegation to Libya Individuals
and Central Bank EUBAM
United Arab Emirates Permanent Mission to the UN Individuals
United Kingdom a,b Foreign, Commonwealth and Permanent Mission to the UN Individuals
Development Office, and NGO
Treasury AirWars
USAa,b State Department, OFAC Permanent Mission to the UN C4ADS
a Countries indicated ‘a’ are members of the Security Council (2020).
b Countries indicated ‘b’ are members of the Security Council (2021).
c Mainly by VTC / electronic platform.
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Summary of Panel correspondence 3
Table 5.1
Correspondence with Member States (2441 (2018) Mandate)
(25 October 2019 – 10 February 2020) a
# letters sent # replies from # awaiting reply

Member State by the Panel b Member State from Member State
Albania 3 2 1
Bahamas 1 1 0
Belize 1 1 0
British Virgin Islands 2 2 0
Comoros Islands 1 1 0
Egypt 3 3 0
France * 1 1 0
Isle of Man 1 1 0
Israel 1 0 1
Italy 5 5 0
Japan 1 0 1
Jordan 4 2 2
Kazakhstan 3 3 0
Lebanon 4 2 2
Libya 10 0 10
Malta 1 1 0
Marshall Islands 1 1 0
Moldova 1 0 1
Mongolia 2 1 1
Morocco 2 2 0
Netherlands 1 1 0
Panama 1 1 0
Romania 1 1 0
Russian Federation * 1 0 1
Serbia 1 1 0
Sierra Leone 1 0 1
Sudan 1 1 0
Tunisia 4 1 3
Turkey 8 4 4
Ukraine 5 5 0
United Arab Emirates 9 5 4
United Kingdom * 3 2 1
United States of America * 5 4 1
Total 91 55 36
\
a
25 October being the date that the last report was submitted to the Committee and for which data was then available.
b
Does not include letters requesting visas or visits.
__________________
3
Excluding updates to the Committee or letters to the Chair.
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Table 5.2
Correspondence with Member States (2509 (2020) Mandate)
(11 February 2020 to 24 February 2021) a
# letters sent by # replies from # awaiting reply

Member State the Panel b Member State from Member State
Albania 1 1 0
Algeria 1 1 0
Antigua and Barbuda 1 0 1
Australia 1 1 0
Austria 2 2 0
Bangladesh 4 1 3
Bermuda 3 3 0
Bulgaria 4 4 0
British Virgin Islands 3 3 0
China 1 0 1
Cyprus 2 2 0
Czech Republic 1 1 0
Egypt 12 9 3
Eritrea 2 2 0
Ethiopia 2 0 2
France 2 2 0
Honduras 1 1 0
Iran 1 0 1
Israel 2 2 0
Italy 1 0 1
Jordan 7 5 2
Kazakhstan 8 8 0
Kuwait 1 0 1
Kyrgyz Republic 3 3 0
Lebanon 1 1 0
Libya 26 6 20
Malta 1 1 0
Mauritius 2 2 0
Mongolia 1 0 1
Morocco 1 0 1
Netherlands 4 3 1
Niger 2 0 2
Nigeria 2 0 2
Oman 2 1 1
Palau 1 1 0
Panama 3 1 2
Poland 1 1 0
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# letters sent by # replies from # awaiting reply

Member State the Panel b Member State from Member State
Korea (Republic of) 1 1 0
Russian Federation 9 4 5
San Marino 2 2 0
Saudi Arabia 4 1 3
Serbia 5 2 3
South Africa 1 0 0
South Sudan 2 1 1
Sudan 6 0 6
Sweden 1 1 0
Switzerland 3 2 1
Syria 1 0 1
Tajikistan 4 3 1
Tanzania 1 0 1
Tunisia 4 4 0
Turkey 11 3 8
Uganda 2 0 2
Ukraine 7 5 2
United Arab Emirates 18 9 9
United Kingdom 5 5 0
Total 205 116 89
a
24 February 2021 being the date that the report was submitted for distribution and for which data was then available.
b
Includes all letters sent up until 18 January 2021 for which replies were requested before 15 February 2021.
Table 5.3
Correspondence with regional organizations and other entities (2441 (2018) Mandate)
(25 October 2019 – 10 February 2020)
# letters sent
Organization or entity by the Panel # replies # awaiting reply
DCIM (Libya) 2 1 1
EuroControl 1 1 0
Haftar Affiliated Forces 3 0 3
Libyan Investment Authority 1 1 0
UNHCR 1 0 1
Total 8 3 5
a
25 October being the date that the last report was submitted to the Committee and for which data was then available.
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Table 5.4
Correspondence with regional organizations and other entities (2509 (2020) Mandate)
(11 February 2020 to 24 February 2021)a
# letters sent
Organization or entity by the Panel # replies b # awaiting reply
AGO Libya 1 0 1
EU NAVFOR Operation IRINI 2 2 0
Haftar Affiliated Forces 4 0 4
Libya African Investment Portfolio 1 1 0
Libyan Investment Authority 1 1 0
Total 9 4 5
a
b
Table 5.5
Correspondence with commercial companies (2441 (2018) Mandate)
(25 October 2019 – 10 February 2020) a
# letters sent
Organization or entity by the Panel # replies # awaiting reply
Aviator at Work, South Africa 1 0 1
BMC, Turkey 1 1 0
Boies Schiller Flexner LLP, USA 1 0 1
Bridgeporth, UK 2 2 0
Cobham Industries, UK 1 1 0
Federal Advocates, USA 2 1 1
FlightRadar24, Sweden 1 0 1
Creative City Fujairah Media Free Zone Authority, UAE 1 0 1
Global Africa Aviation South Africa and Zimbabwe, South Africa 1 0 1
Holman Fenwick Willan MEA LLC, UAE 12 11 1
Hyundai Motors, Republic of Korea 1 0 1
Inmarsat, UK 1 1 0
IWAS, UAE 1 1 0
National Bank of Dubai, UAE 1 0 1
Nissan Motor Company, Japan 1 0 1
Panzer Logistics, Republic of South Africa 1 1 0
Presidency Defence Industries, Turkey 1 0 1
Remm Style and Travel, UAE 1 0 1
Sadat Security, Turkey 1 0 1
Speedway, Botswana 1 1 0
The Armoured Group FZE, UAE 1 0 1
Weevind Law, South Africa 1 0 1
Total 36 21 16
a
25 October 2019 being the date that the last report was submitted to the Committee and for which data was then available.
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Table 5.6
Correspondence with commercial companies (2509 (2020) Mandate)
(11 February 2020 to 24 February 2021) a
# letters sent
ABC Bank, UAE 2 2 0

African Express, Romania 1 1 0
Afrifin Logistics FZE, UAE 2 1 1
African Mediterranean Lines S.A.L., Lebanon 4 1 3
AIK Energy, Romania 1 1 0
Airborne Technologies, Austria 1 0 1
AK Gemi, Turkey 2 0 2
Akar Group, Turkey 1 1 0
ALA International, UAE 1 0 1
Almat Cars, Jordan 1 0 1
Altobigy Excellence, UAE 1 1 0
Alwan, UAE 1 0 1
Amber Tiger Limited, UK 1 1 0
Arkas, Turkey 2 0 2
Arpeni, Indonesia 1 0 1
Avrasya Shipping Co Limited, Turkey 3 0 3
Bereket, Turkey 2 0 2
BNP Libya 1 0 1
Boies Schiller Flexner, USA 1 1 0
Bravo Energy, UAE 1 1 0
Bridgporth, UK 1 1 0
Cabada, Allard Y Asociados LLC, Panama 1 0 1
Cargo Air Chartering FZE, Ukraine 1 1 0
CCM CGA, France 1 1 0
CPC Corporation, Taiwan, province of China 3 1 2
CSM, Germany 1 0 1
Eagle Enterprise, South Sudan 1 1 0
Emarat, UAE 2 1 1
EMO Investment, Trading and Marketing of Oil and Derivatives LLC, 3 2 1
UAE
Fehn Ship Management, Germany 1 1 0
Frontier Services Group, China 1 0 1
Gardaworld, Canada 2 1 1
Gulf Shipping Services FZE, UAE 1 0 1
Handytankers, Denmark 1 0 1
Hanjin Tankers, Singapore 1 0 1
Henkel AG and Company, KGaA, Germany 1 1 0
Holman Fenwick Willan MEA LLC, UAE 15 12 3
IMS Hellenic, Greece 3 0 3
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# letters sent
Jones Group International, USA 1 1 0
Kuloviec, David, LLC, USA 4 4 0
Kurstvaart Harlingen 1 1 0
Landseadoor, Indonesia 2 0 2
Lenco LLC, USA 1 1 0
Libyan Express, Libya 3 2 1
Maersk Shipping, Denmark 1 0 1
Mahoney Shipping & Marine Services, Egypt 1 0 1
Maleth Aero, Malta 1 1 0
Med Wave Shipping S.A., Lebanon 1 0 1
Middle East Maritime Consult, Lebanon 1 0 1
Mitsubishi Motors, Japan 1 1 0
MSPV LLC, UAE 1 0 1
Murex, UK 1 1 0
Nissan Motor Company, Japan 1 0 1
New Stage Shipping, Malaysia 2 0 2
New Wave Shipping Company S.A., Greece 2 2 0
Oil and Gas Global Services Ltd, Bulgaria 1 0 0
Pioneer, Egypt 1 1 0
Presidency of Defence Industries, Turkey 1 0 1
Rana Maritime Services S.A., Lebanon 1 1 0
Rose Partners Limited, UK 2 2 0
Sadat International Defence Consultancy, Turkey 1 1 0
Saida for Tourism, Lebanon 1 0 1
SCF Management Services, UAE 1 0 1
Security Side, Libya 1 1 0
SMEA, San Marino 2 2 0
Space Cargo FZE, UAE 2 2 0
Thales, France 1 0 1
Toyota Motor Company, Japan 1 1 0
United Shipping, Libya 1 0 1
Weewind Law, RSA 2 2 0
Total 116 62 54
a
b
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Continued encroachment of armed groups on state institutions
1. The détente among Tripoli’s competing armed groups started to unravel after HAF’s
withdrawal from Libya’s west in June 2020. The competition among the armed groups came to a
head in August 2020, as peaceful protests erupted in Tripoli, Misrata, and Zawiya over
deteriorating living conditions, most notably extended power outages during the summer. The
Panel received first-hand accounts and videos showing the firing of live ammunition to disperse a
demonstration in Martyrs’ Square in downtown Tripoli—an area controlled by the al-Nawasi
armed group. There were reports of arbitrary detentions and injuries among protestors that the
Panel was unable to independently verify. Some GNA officials4 denied the involvement of al-
Nawasi in responding to the protests, amidst assertions that Haftar had bought the allegiance of
some armed groups in Libya’s west, and perhaps fanned the flames of the summer protests, to push
the Presidency Council to resign.
2. The Minister of Interior issued public statements in support of the right to peaceful protest,
which put him at odds with the GNA’s stated position that some of the protestors engaged in acts
of sabotage and destruction of property, and that the LNA and its affiliates exploited the protests
for political gain. Prime Minister Sarraj announced the suspension of Minister of Interior Bashagha
on 28 August 2020 (decree 562), pending an investigation into the Minister’s public statements
and permits/authorizations concerning the protests. The suspension was subsequently lifted on 3
September 2020 (decree 584).
3. On 1 September 2020, the PC brought the Special Deterrence Force (SDF) under its direct
control (decree 578). Furthermore, the PC appointed armed group leaders in critical security
positions:
(a) On 8 September 2020, the PC appointed armed group leaders Imad Trabelsi (formerly of the
Western Joint Security Room) as the deputy head of the General Intelligence Service (decree
595) and Lotfi Harari (formerly of the Ghenewa militia) as the deputy head of the Internal
Security Service (decree 596), with both services reporting directly to the PC;
(b) On 11 January 2021, the PC established the Stability Support Service (decree 26), another
force under its direct authority; and
(c) On 17 January 2021, the PC appointed the Ghenewa militia leader Abdel Ghani Belgassem
Khalifa as the head of the new service (decree 38).
4. The Panel notes that al-Nawasi Brigade affiliates Al-Tahir Urwah and Mohamed Bu Dara’,
who were named in S/2019/914, Annex 12, in a reported 2019 attack on the Minister of Finance,
have been reportedly appointed as attachés to Libyan posts abroad and presumably receive
diplomatic immunity. The Panel has confirmed that Urwah is a Consular Attaché at the Libyan
Embassy in Tunis. The Panel learned that Abu Dara’ is a police officer, whom the Ministry of
__________________
4
Panel meeting with WMZ Commander Osama Juweili on 31 August 2020, and meeting with Nawasi leader
Mustafa Qaddour on 1 December 2020.
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Interior suspended and placed on a no-fly list in April 2020 pending the investigation into the
assault claim, yet he was reportedly appointed by the Ministry of Foreign Affairs as a health attaché
at the Libyan Consulate in Istanbul.
Figure 6.1
A chart showing various security services and armed groups with lines of authority to the Presidency Council
and the Ministry of Interior
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Counter-terrorism related events in Libya (2020)
1. The Panel has not been able to independently verify some of these events.
Table 7.1
Reported counter-terrorism related events in Libya
Date Event Source
29 Feb 2020 The spokesperson of the LNA’s Sebha Joint Security Room https://www.addresslibya.co/ar/archives
announced that a Sudanese doctor identified as Omar Fadl Al /90268, 1 March 2020.
Sayed Mohammed Lamine a.k.a. Abu Abdallah was arrested for
his affiliation with ISIL-Libya and plan to carry out a terrorist
attack.
26 Mar 2020 HAF 128 battalion arrested and interviewed a Syrian fighter in https://www.facebook.com/aldola.01/vi
Nakliyyah, named Ibrahim Mohammed Darwish, who claimed to deos/503118253718281/, 26 March
be member of the listed terrorist group Al-Nusrah Front for the 2020.
People of the Levant (QDe.137) fighting with the GNA-AF.
3 Apr 2020 LNA official Twitter account announced that Fathi Al-Rubaie, an https://twitter.com/LNA2019M/status/1
alleged terrorist affiliated with ISIL-Libya, was captured with 18 246132285923045385 (account
other terrorists in Tripoli. suspended by Twitter).
https://www.albayan.ae/one-
world/arabs/2020-04-05-1.3821450, 5
May 2020.
23 Apr 2020 LNA spokesperson Al Mismari declared that LNA forces https://alarab.co.uk/-‫ اﻋد‬-‫ﻋﻰل‬-‫لاﻘﺒﺾ‬
arrested the Egyptian national Mohammed Mohammed Al 2020. -‫ا لوفاق‬-‫ح ﻜﺔ‬-‫اتع اﺳنﺔ‬-‫ﺢ‬
‫ي ﻔﻀ‬-‫ﻋ اوي‬
Sayyed fighting alongside the GNA in Tripoli. This individual is ‫بارﻻھابييﻦ‬, 24 April
reportedly linked to Hicham Achmaoui, an Egyptian terrorist
affiliated to Al Qaida.
28 Apr 2020 The GNA affiliated Special Deterrence Forces (SDF) announced https://www.jana-ly.co/-‫ لﻦ‬-‫ﺔا لوفاق‬-‫دﺧلاي‬
the arrest of a Sudanese national born in Surt named Saeed ‫ا ل درع‬-‫ﻜ ليﺸيا‬-‫ﺗمﻦ‬/, 28 July 2020.
Kamel Saeed Abdelkarim, an alleged member of Ansar Al Charia
Benghazi (QDe.146).
30 Apr 2020 HAF allegedly arrested an ISIL-Libya fighter, Tarik al-Baroussi https://sahafahnet.com/show6858650.ht
(a.k.a. Abu Abdullah), on the Wadi Rabea axis in southern ml, 1 May 2020.
Tripoli.
25 May 2020 LNA’s spokesman Al-Mismari announced that HAF arrested in https://middle-east-online.com/en/lna-
Tripoli an ISIL-Libya member named Muhammad al- forces-arrest-commander-tripoli, 25
Ruwaidani, known as Abu Bakr al-Ruwaidani. He was described May 2020.
as "one of the most dangerous members of the Daesh terrorist
organization".
5 Jul 2020 Misrata’s Joint Security Operations Room (JSOR) captured a https://ar.libyaobserver.ly/article/8879,
Syrian ISIL fighter named Omar Dabbous, who entered Libya in 6 July 2020.
2016 as a refugee from Syria.
6 Jul 2020 The GNA’s Ministry of Interior declared that Al Zawiyah https://www.eanlibya.com/-‫ﻋﻰﻠ‬-‫ﻟاﻘﺒﺾ‬
security forces have detected a terrorist cell belonging to ISIL- ‫ﻲﻟﺪـاﻋﺶ‬- ‫ﺗﻨﻤ ﺘ‬-‫إھ ﺎرﺑﯿﺔ‬-‫ﺧﻠﺔﯿ‬/, 6 July 2020.
Libya. The cell was planning to perpetrate attacks in Libya.
14-15 Sep 2020 HAF undertook an overnight raid on an alleged ISIL-Libya https://arabic.rt.com/middle_east/11
cell in the Abd al-Kafi neighborhood in Sebha. According to -‫دواﻋش‬-‫أربعﺔ‬-‫يﻘتل‬-‫الليﺒي‬-‫الجيش‬54215-
HAF officials, the raid resulted in the deaths of three Saudi /, 17 September ‫الجنوبيﺔ‬-‫ﺳﺒها‬-‫بمدينﺔ‬
men, one Egyptian who held Australian identity papers and 2020.
two Libyans. Two women were also arrested, one Libyan and
the other Egyptian.
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Date Event Source

21 Sep 2020 HAF’s spokesperson Al-Mismari claimed the arrest an ISIL- https://www.skynewsarabia.com/mi
Libya member in the town of Ghadduwah in southern Libya, -‫مﻘتل‬-‫الليﺒي‬-‫الجيش‬ddle-east/1378499-
linked to the previously disrupted ‘Abd al-Kafi neighborhood’ , 25 September ‫أفريﻘيا‬-‫شمال‬-‫داﻋش‬-‫زﻋيم‬
cell. He revealed that Abu Muad Al Iraqi a.k.a. Abu Abdallah 2020
Al Libi leader of ISIL-Libya Africa was among those killed in
the aforementioned cell.
24 Sep 2020 HAF’s Khalid Bin Walid Brigade claimed through their https://www.facebook.com/permalin
official social media, that their commander Youssef Hussein k.php?story_fbid=18634767633793
Saleh, survived an assassination attempt allegedly carried out 7&id=112790383693667, 26
by ISIS-Libya members in the Nassriya district of Sebha. September 2020.
30 Sep 2020 The GNA Ministry of Defence’s Joint Force captured 5 alleged http://alwasat.ly/news/libya/296950,
ISIL-Libya members south of the Libyan town of Al-Jmeel, near 2 October 2020.
the Tunisian border. Those arrested include 2 Libyans, 2 Tunisians,
and another African National.
3 Oct 2020 HAF’s 116 Infantry Brigade claimed to have arrested a terrorist cell https://www.facebook.com/1086396
responsible for carrying out kidnappings and murders between the 50637318/posts/193502715484344/,
cities of Jufra and Sebha. The cell is composed of 3 Libyans and 7 5 October 2020.
African nationals.
18 Oct 2020 GNA’s Counter-Terrorism Force Commander, Major General https://akhbarlibya24.net/2020/10/1
Mohammed Al-Zein, announced on Libyan television that four /, ‫والخمس‬-‫بطرابلس‬-‫إرھابيﺔ‬-‫ﺧليﺔ‬-‫ﺗﻔﻜيك‬9/
ISIL-Libya suspects had been arrested for connections to a terrorist 20 October 2020.
group in two separate operations at Khoms and in the outskirts of
Tripoli. These individuals were reportedly planning to carry out
attacks in Libya.
28 Nov 2020 HAF’s spokesperson Al-Mismari announced that HAF conducted -‫السريﺔ‬https://www.facebook.com/
an operation against al-Qaeda in the Islamic Maghreb (AQIM), in -‫الي‬-‫مﺸاة‬-116-‫ك‬-‫الرابعﺔ‬
Awbari, which resulted in the arrest of Hasan Washi (an ex-JNIM , 587393035071266
member ) one of the leaders of the group and six other individuals. 10 December 2020.
Table 7.2
Alleged terrorism related events in Libya
Date Event Source
17 May 2020 ISIL-Libya (QDe.165) claimed responsibility through the Official ISIL weekly publication
official ISIL (QDe.115) weekly publication “Annaba’a”, of an “Annaba’a”. Official ISIL weekly
attack using Katyusha rockets against HAF members in publication “Annaba’a” n°235 ,
Taminhint base. https://s34.f102.casa/pdf/235.pdf, 21
May 2020.
18 May 2020 ISIL-Libya (QDe.165) claimed an attack against the HQ of HAF Ibid.
628 infantry battalion in Traghin using Katyusha rockets.
19 May 2020 ISIL-Libya (QDe.165) claimed an attack against HAF Tarek Ibn Ibid.
Ziyyad battalion using Katyusha rockets.
23 May 2020 ISIL-Libya (QDe.165) claimed a vehicle-borne improvised Official ISIL weekly publication
explosive device (VBIED) attack against a security checkpoint of “Annaba’a” n°236 ,
HAF 628 infantry battalion near the entrance of Taraghin, 140 https://s34.f102.casa/pdf/236.pdf,
km south of Sebha. 28 May 2020.
25 May 2020 ISIL-Libya (QDe.165) claimed an attack against a military police Ibid.
station in the city of Traghin.
26 May 2020 ISIL-Libya (QDe.165) in Libya claimed burning crop fields in Ibid.
Traghin belonging to an LNA member.
30 May 2020 Members of ISIL-Libya (QDe.165) claimed burning crop fields Official ISIL weekly publication
in Ghaduwwah belonging to a Libyan Police member named “Annaba’a” n°237 ,
Saleh Qaddafi. https://s34.f102.casa/pdf/237.pdf, 04
June 2020.
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Date Event Source
2 Jun 2020 ISIL-Libya (QDe.165) claimed a bomb attack against a Shopping Ibid.
Centre belonging to a member of HAF in Um’ Al Aranib, south
of Sebha.
3 Jun 2020 ISIL-Libya (QDe.165) claimed a rocket attack against HAF forces Official ISIL weekly publication
stationed in Tamenhint base. “Annaba’a n°238,
https://s34.f102.casa/pdf/238.pdf, 11
June 2020.
1 Sep 2020 A failed suicide bombing took place at a GNA-aligned checkpoint https://arabic.rt.com/middle_east/1149697-
at the Al-Ghariyan roundabout, near Janzour. There were no -‫ناريﺔ‬-‫دراجﺔ‬-‫ﻋلﻰ‬-‫انتحاري‬-‫الصور‬-‫بأولﻰ‬
casualties -‫الليﺒيﺔ‬-‫بالعاصمﺔ‬-‫بوابﺔ‬-‫قرب‬-‫نﻔسه‬-‫يﻔجر‬
‫طرابلس‬/, 3 September 2020.
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The case of Mohamed Bahrun
1. The Panel observed a video recording (figure 8.1) posted on March 2016 by the official
Facebook page of the GNA affiliated Rada group, of a testimony of a detained member of the
terrorist group ISIL-Libya, identified as Ahmed Sassi Al Fallah (alias Abu Allaith). He narrated
the background of his activities as a member of the terrorist group and described how Mohamed
Bahrun “Al Far” facilitated his passage, along with his associates, from Sabratha to Zawiyah where
he was arrested.
Figure 8.1
Extract from video published by Rada’s official Facebook page
Source: https://fb.watch/1TowkuhXG5/.
2. On 17 October 2017, an arrest warrant addressed to the Security Directorate of Sabratha was
issued by the AGO (figure 8.2), for several individuals suspected of connection with ISIL-Libya
in Sabratha, in relation to case n°131 of 2017. This list included Mohammed Bahrun.
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Figure 8.2
Arrest warrant issued by the AGO
Source : https://www.almasarly.com/2019/12/07/2, /‫ال‬-‫هو‬-‫من‬-‫الجيش‬-‫أسير‬-‫على‬-‫الوفاق‬-‫تعدى‬-‫ بعد‬November 2020
3. On July 2017, Mohammed Bahrun sent a letter on Ministry of Interior letter head (figure
8.3), to the Prime Minister, asking to be put in charge of securing the coastal road and proposing
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a cooperation with the Presidential Guard on the matter. Mohammed Bahrun signed the letter as
‘First Lieutenant’, Head of Al Isnad Force (affiliated to the Security Directorate of Al Zawiyah).
Figure 8.3
Letter addressed by Mohamed Bahrun to the PC
Source: https://www.almasarly.com/2019/12/07/‫بعد‬-‫تعدى‬-‫الوفاق‬-‫على‬-‫أسير‬-‫الجيش‬-‫من‬-‫هو‬-‫ال‬/, 2. November 2020.
4. On March 2018, a letter to the Minister of Interior from the Head of Al Zawiyah Security
Directorate, Ali Allafi, confirmed that Mohamed Bahrun was a member of the Security Directorate
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of Zawiyah. It contested the arrest warrant issued by the AGO and implicitly refused to execute
the warrant, claiming a lack of incriminating evidence against Bahrun (figure 8.4).
Figure 8.4
Letter from the Director of Al Zawiya security to GNA Minister of Interior
Source: https://i1.wp.com/almarsad.co/wp-content/uploads/2019/12/B4BF0AB9-FC53-4C0B-A12B-1B234CC1F2AD.jpeg, 2
November 2020.
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5. In an open-source image of December 2019,5 Mohammed Bahrun appears to be clearly

mistreating a HAF prisoner identified as the pilot Brigadier General Aamer Al-Jagm. This
prompted the GNA Minister of Interior to issue a letter to the Security Director of Zawiyah,
condemning the mistreatment of the prisoner, describing it as “against human rights” and asking
for a restructuring of the “Isnad Force” by appointing competent officers to command it (figure
8.5).
Figure 8.5
Letter from the GNA Minister of Interior to the Director of Al Zawiya Security
Source : https://almarsad.co/2019/12/08/-‫باشاآغا‬-131-‫داعش‬-‫قضية‬-‫فضيحة‬-‫وقع‬-‫على‬
8039612740077092864_2590488894381120_80216719/‫_يتهم‬o-1/, 2 November 2020.
__________________
5
https://twitter.com/evTucFAt8C3Rt1G/status/1325927528100409344/photo/1, 2 November 2020.
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6. The Panel finds that the treatment of Brigadier General Aamer Al-Jagm constitutes an IHL
violation.6
7. Following the letter from the Minister of Interior, further images were published in
December 2019,7 of Mohammed Bahrun, dressed in an official military uniform, in the presence
of the detained LNA pilot Brigadier General Aamer Al-Jagm, suggesting that Bahrun explicitly
belonged to the GNA Ministry of Interior.
8. The Panel has copies of the following documentary evidence:
a. AGO Travel Ban and Renewal of Arrest Warrant against Mohamed Bahrun, and 40
other individuals, dated 3 July 2019, as they were wanted in relation to investigations
concerning the arrest of an ISIL-Libya affiliated individuals in Sabratha;
b. A subpoena issued by the AGO on 20 August 2019, addressed to the Ministry of
Interior, asking for Mohamed Bahrun to present himself to the OGA for an interview relating
to case n°131 of 2017; and
c. A letter from the Libyan Ministry of Interior to the Director of Al Zawiya Security,
dated on 28 August 2019, asking him to make Mohamed Bahrun comply with the subpoena
issued by the AGO on 20 August 2019.
9. To date, Mohamed Bahrun has refused to comply with the subpoenas. The arrest warrants
issued against him are still valid, and he remains under the implicit protection of the Security
Directorate of Al Zawiya, where he commands an armed force (Al Isnad Force).
__________________
6
Article 3 common to the 1949 Geneva Conventions and Additional Protocol II provide that persons deprived of
liberty for reasons related to the conflict must also be treated humanely in all circumstances. In particular, they are
protected against murder, torture, as well as cruel, humiliating or degrading treatment.
7
https://pbs.twimg.com/media/ELM15TrXYAM4rhs, 1 November 2020.
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Chadian and Sudanese presence in Libya
1. The Chadian armed groups is omni-present in the South of Libya and have become part of
the social life. Sources of the Panel have reported that cities like Hun and Murzuq have seen an
increasing number of Chadians nationals established in those cities where their armed presence is
heavily noticed. On 17 July 2020, the GNA official media8 reported on the arrival of new batches
of Chadian fighters and have been witnessed in the city of Hun.
1. Chad (CCMSR)
2. This GNA-affiliated group issued a communiqué on 26 June 2020 claiming it will “keep
neutrality in the inter-Libyan conflict” and focus on Chad.9 It has lost some of its operational
capacities and its movement across the south is now restricted because of the risk of being targeted
by HAF. Most of the elements of the Group are based presently in the border area between Libya
and Chad in the area of Kouri Bougoudi. Sources of the Panel indicate that they operate at least
100 vehicle in the border area.10
2. Chad (FACT)
3. This group, which was based in Al Jufra has been expanding its camps through Sebha,
Tamenhint and Brak Shati. It is reportedly moving its command base to the area of Jabal Al Aswad.
It has been reinforced during the reporting period by some splinters of CCMSR after the latter
suffered splits and defections. The leader of FACT claims neutrality in the Libyan conflict,11
however his forces are guarding some HAF bases in the south. Elements of this group also serve
among HAF’s 116 and 128 battalions.
3. Sudan
4. The recruitment of Sudanese individuals by HAF is still active, especially by 116 and 128
battalions, whose forces are composed of hundreds of Sudanese combatants. 128 battalion is the
main point of contact for the Sudanese groups in terms of daily supplies of food, arms and
ammunition, and salaries. These groups are generally present in the areas of Jufra, Waddan, Hun,
Suknah (where some Sudanese groups have training camps), Zillah and its mountainous area of
Al Haruj.
5. On 10 August 2020 the GNA reported on a convoy of Sudanese fighters, affiliated to HAF,
of at least 70 vehicles passing from the city of Brega on their way to Surt12. Sources of the Panel
indicated that the Sudanese fighters were used to reinforce and secure the outposts around HAF’s
__________________
8
https://twitter.com/BurkanLy/status/1284057888051216384, 13 December 2020.
9
https://www.facebook.com/pg/www.CCMSR/posts/., 5 September 2020.
10
Military Parade of the CCMSR published online.
https://www.facebook.com/watch/?v=3998649556843858, 31 August 2020.
11
Panel interview with Mahmat Ali Mahdi, leader of FACT.
12
https://twitter.com/BurkanLy/status/1292769503298957313, 27 October 2020.
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defensive line of Surt. The Sudanese units within HAF participated actively in the June 2020
Sharara oil blockade.13
6. The Sudanese groups affiliated to HAF, for example the Gathering of the Sudan Liberation
Forces (GSLF) and Sudan Liberation Army-Abdul Wahid (SLA/AW) were still operating in
Libya with no apparent change in their chain of command by the beginning of the reporting period.
However, the Juba Peace Agreement prompted the movement of the elements of the signatories out
of Libya. Sources of the Panel indicated that large numbers were still on standby in Libya.
7. At the end of December 2020 a video posted on the internet14showed a grouping of GSLF
forces of at least 100 vehicles highly likely in the desert of south Libya. Sources of the Panel
indicated that at least 200 vehicles belonging to GSLF were spotted moving from Tamassah to
Waw, then further out heading south west. This suggests a possible return to Sudan as Taher Hajar,
leader of this group is a signatory of the Sudanese peace agreement. The GSLF is one of the main
Sudanese groups supporting HAF (see figure 9.1)
Figure 9.1
GSLF vehicle with HAF insignia
4. Sudan (SLA/MM)
8. This group was highly active in the combat front lines of HAF. It has been reinforced by
continuous recruitment, with weaponry provided by LNA during 2020. Its presence was visible
during most of HAF’s military operations in the outskirts of Tripoli (see figure 9.2) where they
were tasked to secure the rear echelons of the forces. They took part also in the battle led by HAF
to take over Surt in January 2020, along with other non-Libyan combatants of African nationalities,
__________________
13
Communiqué of the NOC: https://noc.ly/index.php/ar/new-2/6029-, 12 June 2020.
14
GSLF demonstration in Libya
https://web.facebook.com/100057021698416/posts/153072283270161/?sfnsn=wa&_rdc=1&_rdr, 30 December
2020.
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highly likely recruited as individual fighters. At least forty vehicles belonging to this group started
the process of leaving Libya after Minni Minawi, leader of the group, signed the peace agreement
but the Panel estimates that a larger number is still in Libya.
Figure 9.2
SLA beret found by GNA-AF in Abugrein axis after an attack on HAF
Source : https://twitter.com/emad_badish/status/1249357469991780353.
5. Sudan (Justice and Equality Movement (JEM))

9. Led by Abdelkarim Cholloy in Libya, JEM components were still present in Libya by the
beginning of 2020, but with less visible fighting activities. Sources of the Panel indicated that
elements of this group (including at least sixty vehicles) started to move south in September 2020,15
as this group is also a signatory of the Juba Peace Agreement.
6. Sudan (Abdallah Banda16 Group)

10. Reported to have been active in the border area between Libya and Chad. The group is
composed of at least 100 combatants. Elements have been operating under the command of other
Sudanese groups including SLA/MM.
7. Sudan (Sudanese Revolutionary Awakening Council (SRAC))

11. SRAC elements in Libya include those members of Musa Hilal’s group that fled to Libya
after his arrest. His force is composed of a few hundred fighters in Libya. They are highly likely
cohabitating with some of the Sudanese groups in the south.
__________________
15
https://web.facebook.com/permalink.php?story_fbid=128082732342695&id=11270477388049, 20 December
2020.
16
An-ex JEM commander wanted by the ICC.
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8. Arrest of Sudanese individuals on their way to Libya

12. On 29 June 2020,17 19 July 202018 and 4 December 2020,19 the Sudanese authorities
announced the arrest of at least 820 Sudanese nationals who were allegedly going to work as
mercenaries in Libya. The Panel was unable to determine whether the Sudanese nationals were
migrants, victims of human smugglers or combatants. No response was received from the
Sudanese authorities to Panel enquiries related to the process of recruitment, itineraries and
facilitators of the transfer of these Sudanese nationals to Libya.
9. Forged document regarding Sudanese Rapid Support Forces (RSF) in Libya

13. In early December 2020, open media sources20 reported that an internal document issued by
the RSF informs of “the arrival of 1,200 members of the RSF to Al Jufra base in accordance with
the ongoing military and security arrangements with Libya and the UAE”. On 3 December 2020,
the RSF spokesperson21 challenged the authenticity of the document and presented evidence as to
the fabrication of the document (figure 9.3). On 14 December 2020,22 the RSF spokesperson
claimed that the same forged document was fabricated by an individual based outside Sudan,
against whom charges have been brought.
__________________
17
https://www.middleeastmonitor.com/20200629-sudan-arrests-122-mercenaries-heading-for-libya/, 12 December
2020.
18
https://english.alarabiya.net/en/News/middle-east/2020/07/19/Sudan-forces-arrest-160-mercenaries-en-route-to-
Libya, 9 June 2020.
19
https://libyareview.com/8506/sudan-arrests-fighters-heading-to-libya/, 15 August 2020.
20
https://www.aljazeera.net/news/politics/2020/12/8/‫مرﺗزقﺔ‬-‫إرﺳال‬-‫ﺗؤكد‬-‫مسربﺔ‬-‫وثيﻘﺔ‬, Accessed 8 December 2020
21
https://www.youtube.com/watch?v=EpZHMgnh4BU. Accessed 5 December 2020.
22
https://youtu.be/PZHtrYlw8NQ, Accessed 5 December 2020
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Figure 9.3
Comparison between the real format of an RSF document (Left) and the fabricated one (Right)
1 The eagle logo represented in the RSF’s official insignia is originally in yellow but appears in black in the forged one;
2 The font and size of the header are different and unaligned with the shape in the background;
3 The document outline is exclusive to the “Bureau of Media” of the RSF and not used in any other department of the
institution. Furthermore, there is no department called the “Administration of Military Operations” within the RSF;
4 The color of the background of RSF’s official documents are white, while it is yellow in the forged one;
5 The watemark on an official document is one fading insignia in the center of the paper ; in the forged document there
are more than 9 watermarks of the same insignia;
6 The header of the document reads in Arabic “ the Office of Military operations” but it is signed by the head of the
“Office of Military Affairs”, normally they should match;
Source: Confidential.
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Background and timeline of the Black Shield case
1. In early September 2019 an Emirati company, Black Shield Security Services Company,
undertook the recruitment of 611 Sudanese nationals through its client companies “Al Ameera”
and “Amanda” promising job opportunities in the UAE as civilian security guards in Abu Dhabi,
as shown in sample contracts (see figure 10.1).
Figure 10.1
Black Shield contract with one of the Sudanese recruits
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2. On 9 September 2019, the Sudanese recruits were transported to Abu Dhabi from Khartoum
on Etihad Airways, Dubai Airlines and Air Arabia, after receiving entry visas (see figure 10.2).
The process continued until the arrival of the last batch in Abu Dhabi in January 2020.
Figure 10.2
Electronic visa granted to one of the recruits
3. On arrival at Abu Dhabi airport, delegates of Black Shield Company took the passports from
the recruits. The recruits were transferred on UAE military transport to the Ghayathi military camp
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(see figure 10.3). They were later inspected and deprived of their cellular phones, given military
uniforms (see figure 10.4) and organized into groups of approximately thirty-five to ninety-nine.
The most experienced members of the groups were placed in command. The Sudanese recruits
were later subjected to medical examination after which ten individuals were sent back to Sudan
due to their unfitness.
Figure 10.3
Buses used by the UAE armed forces to move the recruits
Figure 10.4
The Sudanese recruits wearing military uniforms in one of the hangars of Ghayathi camp
4. The remaining 392 individuals underwent three months of military training inside Ghayathi
camp, supervised by a former Sudanese Armed Forces officer and a UAE Armed Forces officer.
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The training included SALW weapon training (see figure 10.5), small unit offensive and defensive
tactics and first aid. The Panel notes that this included chemical defence training. Tactical training
and live firing took place in a desert area near the Saudi Arabian border. The Panel is looking
further into the involvement of the UAE officers in the training. Their names were given and
corroborated by several recruits and the Panel is examining this aspect. The Panel holds a video
recorded secretly in the Ghayathi camp by one of the Sudanese recruits showing the Sudanese
recruits undergoing close order drill in military uniform. (see figure 10.6)
Figure 10.5
Example of training material
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Figure 10.6
Sudanese recruits training in Ghayathi camp (23°51'01.6"N 52°48'03.9"E) 23
5. After completion of the aforementioned training, an evaluation and inspection committee

from UAE Armed Forces Headquarters assessed the recruits and recommended a continuation of
the training for two more weeks. At the end of the training period, an Emirati officer informed the
recruits that their salary had been increased from USD 500 to USD 1,000 per month.
6. The Sudanese recruits were later divided into two groups. The first, comprising 276
individuals, was transported to Al-Reef airbase from where they were flown on an Emirati C-130
military cargo plane to Al Abraq (HLLQ) in Libya, without their prior knowledge. On 22 January
2020, they were transferred by air to Ras-Lanuf airport, before an overland move to an abandoned
camp in the area between Ras Lanuf and Al Sidra. The recruits interviewed by the Panel stated
that they found empty shells and rounds as well as destroyed tanks and vehicles in the camp (see
figure 10.7).
__________________
23
Confidential sources and Google Earth Pro.
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Figure 10.7
Geo-location of the camp near Ras-Lanuf (30°31'23.6"N, 18°28'36.7"E) 24
7. On 23 January 2020, the Sudanese recruits were introduced to an individual named Issa
Daoud Al-Qabsi (figure 10.8) who identified himself as a representative of the UAE based Black
Shield Company, commander of the region and belonging to the HAF 302 Saeqah battalion. He
explained to the recruits the nature of their work in Libya, which would consist of guarding Libyan
oil installations. He then issued orders to distribute military uniforms, prepare weapons, and bring
cars to the recruits. He added that their salary was now USD 3,000 with an additional USD 700
bonus as an incentive to work. He informed them also that their salaries had nothing to do with the
UAE, and that it was for the period of their service in Libya.
__________________
24
Confidential sources and Google Earth Pro.
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Figure 10.8
Issa Daoud Al-Qabsi
8. On the same day, the recruits were handed their mobile phones, and were then able to contact
their families and explain to them that they had been deceived and sent to fight in Libya. This led
to their families to stage demonstrations in front of the UAE embassy in Khartoum on 26 January
2020, demanding that the UAE immediately return their relatives from Libya.
9. After six days in Libya, on 28 January 2020, the 276 recruits were airlifted to the Jabal Al
Akhdar military base east of Benghazi, then onward to Al-Reef Airport in Abu Dhabi, and later
transported back to Ghayathi camp to re-join the remainder of the recruits who had not been sent
to Libya.
10. On 30 January 2020, a group of individuals identifying themselves as representatives of
Black Shield held a meeting with eight representatives of the victims. They apologized to the
Sudanese recruits and offered them USD 3,000 for each member of the group that returned from
Libya on the condition that they appear in a live video to deny what was reported in media outlets
(including Al-Jazeera) on their deployment in Libya without their consent. This was refused by
the Sudanese representatives from the recruits.
11. On 31 January 2020, the 611 recruits began repatriating to Sudan using civilian airlines
from the UAE.
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Geolocations of Syrians in Libya (May to August 2020)
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Funding sources for the LNA’s Military Investment Authority
1. This Annex provides a snapshot of the illegal activities and measures undertaken by the
Military Investment Authority (MIA) to expand its funding sources and bring in sizeable revenue
for HAF.
2. This annex contains documents relating to the Military Investment Authority.
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Appendix A to annex 12: Illegal export of scrap metal

1. The documents below demonstrate the MIA’s illegal takeover of the scrap metal export
business in Libya’s east
Figure 12.A.1
Laissez Passer for transport of scrap from Al-Nafura Oilfield to Tobruk 13 September 2018
Source: https://globalinitiative.net/wp-content/uploads/2019/06/GITOC-Predatory-Economies-Eastern-Libya-
WEB.pdf, June 2019, p.11.
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Figure 12.A.2
Official UN translation
Translated from Arabic
Armed Forces General Command Subject: [illegible]

vehicles
Military Investment Authority File No.: mim ta’/13
Date: 13 September
2018
To: Commander, Ajdabiya Operation Room

All gateways and security checkpoints
The trucks carrying scrap driven by the persons noted in the attached list of 50
individuals, beginning with Ahmad Idris and ending with Abdulazim Abdulhamid, are
authorized to move from the Nafurah field to the city of Tubruq.
The persons concerned are asked to facilitate their task.
(Signed)
Brigadier
Faraj
Idris
Director,
Commerc
ial
Departme
nt
Military
Investme
nt
Authority
Copy to:
Secretary of the General Command (for information)
Inspector General of the Armed Forces (for information)
Director of the Military Intelligence Department (for information)
Director of the Military Police Department (for information)
General file (for archiving)
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Figure 12.A.3
MIA authorization for loading of scrap on to M/V Al-Nur in Tobruk (12 June 2018)
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Figure 12.A.4
Official UN translation
Armed Forces General Command

Military Investment Authority
Ref. No.: alif kha’ sin 676/167
12 June 2018
To:
Director, Directorate of Security, Sea Port of Tubruq -

Director-General, Sea Port of Tubruq -
Head, Customs Office, Sea Port of Tubruq -
Director, Libyan Ports Company -
Chief, Tubruq naval base -
Subject: Awa’il shipping contractors
We should be grateful if you would authorize the aforementioned company to complete the
procedures for the entry and loading the ship Al-Nur with a cargo of 5,000 tons of scrap.
Regards,
(Signed) Muhammad al-Madani Abdulhafiz al-Fakhiri
Major General (Pilot)
Head, Military Investment Authority
cc:
• Secretary-General, General Command, for information

• Department of Military Intelligence, for information
• Inspector-General of the Armed Forces, for information
• Director, Department of Investment, for follow-up
• Department of Military Intelligence, for information
• Archive
• Abdulhamid Ahmad al-Fakhiri
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Figure 12.A.5
Sign on MIA official scrap collection vehicle
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Figure 12.A.6
Sample bill of lading showing the MIA as the scrap shipper
Source: Confidnetial
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Appendix B to annex 12: Illegal visas authority for foreign nationals to enter
through the Benina Airport in Benghazi
1. Below is an official letter issued by the LNA’s Committee for Organizing and Recruiting
Foreign Workers that grants a 90-day, single entry permit to 7 Egyptian workers for arrival into
the Benina Airport (Benghazi) via Carthage Airport (Tunis). The LNA has assumed the authority
of issuing permits for a fee to foreign nationals to enter through eastern airports, a function that
normally fell under the authority of the Ministry of Foreign Affairs.
Figure 12.B.1
Official letter granting foreign nationals permission to enter through Benina aiport
Source: Confidential
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Appendix C to annex 12: A list of targeted businesses for confiscation

1. The documents below show a request from the MIA to the Prime Minister of the interim
government to transfer a wide range of public projects and businesses25 in the food, agriculture,
hospitality and other economic activities under its authority.
Figure 12.C.1
A 2017 Letter from Khalifa Haftar to the Prime Minister of the interim government demanding the transfer
of businesses and projects under the MIA’s authority
__________________
25
The Panel has been able to identify that at least 30% of these businesses have been taken over by the MIA and
continues to investigate the remainder.
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Figure 12.C.2
Official translation
Libyan Armed Forces General Command

Office of the General Commander
File No.: Date: 5 December 2017

mim qa ayn / 167 / 3160
To: The Prime Minister of the Libyan Interim Government
Sir,
It is no secret to you what has happened to agricultural, productive and industrial projects
as a result of the current situation of the country. They have been robbed, looted and destroyed because
they do not have sufficient protection to operate as desired. Most of these projects were originally
established as facilities of the Libyan Arab Armed Forces.
Some of the managers of those projects have submitted to us requests to restore their
affiliation with the Military Investment and Public Works Authority of the General Command to ensure
protection for their projects and revitalize them in the service of the military efforts of the Libyan Arab
Armed Forces.
We hereby submit to three pages containing a list of 96 projects that have been identified
by the committee charged in that regard, with a view to a decision being issued to bring these projects
under the aegis of the Military Investment and Public Works Authority of the Libyan Arab Armed Forces.
Accept, Sir, the assurances of my highest consideration.
May the peace, mercy and blessings of God be upon you.
Annexes: Three pages
(Signed) Khalifah Abu al-Qasim Haftar

Field Marshal
General Commander of the Libyan Arab Armed Forces
cc:
The Oversight Agency, for information

The Military Investment and Public Works Authority, for information
General outgoing file, for records
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List of agricultural and productive projects, reserves, farms, cattle and poultry stations, hotels, tourist
villages, parks, rest areas, companies, agencies and factories with regard to which a decision should be issued
restoring or transferring them to affiliation with the Military Investment and Public Works Authority
No. Project name Observations

1 Wadi al-Bab agricultural project
2 Jardinah agricultural project
3 Zawiyah agricultural and productive project
4 Sarir North-South productive project
5 Kufrah productive project
6 Kufrah settlement project
7 Ghariqah – Bayda’ agricultural zone
8 Marj al-Qadim agricultural zone
9 Bandar agricultural zone
10 Wadi al-Farigh date palm project - Husayyat
11 Five million palm and olive trees - Wahat
12 Lud agricultural project for date palms and olive trees
Sahabi agricultural project for date palms, olive trees, grains
13 and livestock
14 Aril grain and livestock project
15 Maknusah grain and livestock project
16 Tahalah grain and livestock project
17 Dabwat grain and livestock project
18 Barjuj grain and livestock project
19 Afiyah agricultural project for date palms and olive trees
20 Tasawah for grain and livestock
21 Irawan grain and livestock project
22 Disah grain and livestock project
23 Waygh grain and livestock project
24 Ninah date palm, olive tree and grains agricultural project
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Tashnah and Hirah date palm and olive tree agricultural
25 project
26 Jarf al-Qari date palm and olive tree project
27 Baydan reserve
28 Surman reserve - South Surman
29 Wahat farms
30 Wadi Rabi‘
31 Bubakr Yunus farm - Jalu
32 Jandawiyah Farm productive project - Asabi‘ah
33 Karimiyah farm and shops
34 Military farm - Ashnishan
35 Kutaybah farm - Shahat
36 Ra’s al-Hilal fish farm
37 Four of Muammar al-Qadhafi’s farms - Awjilah
38 Cattle project - Ajdabiya
39 Camel-raising project - Ajdabiya
40 Cattle project - Ra's al-Hilal
41 Cattle stations
42 Jakhirah poultry station
43 Martubah poultry station
44 Suluntah poultry station
45 Rumaniyah poultry station
46 Ghut al-Sultan poultry station
47 Wahat Hotel - Jufra
48 Blue Ship Hotel - Tripoli
49 Taqrifat Hotel - Tripoli
50 Fadil Hotel - Benghazi
51 Qarqarish military resort
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52 Seville resort - Benghazi
53 Military resort - Benghazi
54 Khums resort - Naqazah
55 Tallil resort
56 Mitiga resort
57 Ghut al-Rumman resort – Ta’jura’
58 Golden Beach resort - Qarqarish
59 Sidi al-Andalusi resort – Ta’jura’
60 Janzur resort – Tripoli
61 Al-Haruj tourist village – Ta’jura’
62 Wadan tourist park – Jufra
63 Mu‘ammar Tulmaythah rest area and surrounding land
64 Sham rest area – Ajdabiya
65 Dawrayn Tita market – Bayda’
66 Dawrayn market – Bayda’
67 Bil‘awn commercial market – Benghazi
68 Khurasani market – Tripoli
69 Jarmah shipping company – Benghazi
70 Shahat shipping and marine transport company
71 Africa engineering company
72 Global production company
73 Rumaniyah poultry company
74 Catering services company
75 Continental Shelf company
76 The development and improvement company
77 Fadil production agency - Benghazi
78 Production agency - Tripoli
79 Tahaddi agency
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80 Nahr al-Hayat agency
81 5 October construction agency
82 Well drilling, water reservoir and dam construction agency
83 The Zakhf al-Akhdar centre for technical works
84 Alwan centre for technical works
85 Medical cotton factory and accessories
86 Oven factory – Ajdabiya
87 Crockery factory – Ajaylat
88 Heater factory – Zahra
89 Cement factory – Misratah
90 Misratah cement mixer
91 Farmer’s feed factory
92 Boat factory – Benghazi
93 Ajwad events hall
94 Shorouk Press (Beirut) – Lebanon
95 Military press – Benghazi
96 Military press – Tripoli
(Signed) Muhammad al-Madani Abdulhafiz al-Fakhiri

Air Force General
Head of the Military Investment and Public Works Authority
-------------------
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Bribery attempts at the Libyan Political Dialogue Forum
CONFIDENTIAL ANNEX NOT FOR PUBLIC DISSEMINATION
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Sabratha and Surman
1. In S/2017/466, annex 17, the Panel reported on the human smuggling networks in the
western coastal towns of Sabratha, Surman and Zawiyah, and clashes among those competing
criminal networks. Annex 18 of the same report documented their fuel smuggling activities.
2. Subsequently, some of the smuggling leaders identified by the Panel were designated on 7
June 2018, namely: Musa’ab Omar (LYi.024), Ahmed Omar al-Fitouri (LYi.023), Mohammed
Kashlaf (LYi.025), and Abd Al-Rahman al-Milad (LYi.026).
3. In April 2019, HAF seized control of the western coastal region as part of the Flood of
Dignity military campaign. On 13 April 2020, however, the GNA wrested control of the coastal
region from HAF and reasserted its authority over Sabratha and Surman.
4. The Panel received reports of summary executions,26 acts of retribution including the
burning of private homes27 and desecration of corpses28 in the first few days of the GNA’s retake
of the coastal cities. There were also reports of a prison break in Surman, and the subsequent
release of 401 prisoners:29 an unlawful act that threatens peace and security in Libya.
5. During the GNA’s operation, the aforementioned designated smugglers became highly
visible in the military offensive against HAF-affiliates. On 13 April 2020, an online video30
showed al-Milad joining the GNA’s operation in Sabratha. On 15 April 2020, al-Fitouri followed
suit and appeared in an online video31 in which he declared his cooperation with the GNA and
urged Sabratha to come under its control. Multiple photos of Kashlaf circulated online showing
him presumably in Sabratha or Surman.
6. The rampant lawlessness that took place around mid-April as part of the GNA’s operation
on the western coast threatens the return of another cycle of retribution. In addition, the high
visibility of the UN-designated smugglers alongside GNA forces, despite an active arrest warrant
issued against them by the AGO, raises concerns about the resurgence and expansion of human
and fuel smuggling networks on Libya’s western coast.
__________________
26
A violation of the right to life protected notably by Article 6(1) of the ICCPR and Article 4(2)(a) of Additional
Protocol II to the Geneva Conventions of 12 August 1949 relating to the protection of victims of non-international
armed conflicts; extra-judicial executions also amount to war crimes under article 8(2)(c)(iv) of the ICC Statute.
27
A war crime under Article 8(2)(e)(xii) of the ICC Statute.
28
Prohibited by Article 8 of Additional Protocol II.
29
https://www.reuters.com/article/us-libya-security/u-n-concerned-by-alleged-abuses-prison-break-in-west-libyan-
towns-idUSKCN21X336, 15 April 2020.
30
https://twitter.com/LyWitness/status/1250405268208451585, 15 April 2020.
31
https://twitter.com/LibyaReview/status/1250522602096988161, 15 April 2020.
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Image 14.1
Al-Milad (pictured right) appeared in Sabratha alongside Abdelmalak Al-Madani (pictured left) a self-
proclaimed spokesperson of the GNA’s Volcano of Anger operation
Source: https://www.facebook.com/644257106018850/photos/a.697240460720514/895808660863692, 13 April

2020.
Image 14.2
Kashlaf presumably in Sabratha circa 13 April 2020
Source: https://www.facebook.com/1045745755454822/photos/pcb.3340204026008972/3340192209343487, 13
April 2020.
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Minister’s statement following GNA takeover of Tarhuna

(6 June 2020)
1. The Minister of Interior congratulates the people of Libya and its security and military forces
for the liberation of Tarhuna and simultaneously requests these forces to protect civilians and
civilian properties; those who would take advantage of the chaos to violate the law will be held
accountable.
Figure 15.1
Minister of Interior’s statement dated 6 June 2020
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Ministry of Justice’s statement on Tarhuna mass graves

(10 June 2020)
1. The Joint Commission tasked with the identification and documenting of human rights
violations is monitoring the rising casualties due to the explosion of landmines laid in civilian
homes; specialized teams have also exhumed bodies from mass graves and wells discovered in
Tarhuna after its liberation from the Al Kaniyat.
Figure 16.1
Ministry of Justice’s statement dated 10 June 2020
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Overview of the Libya-Malta and Libya-Italy migration agreements

and evolution of the EUNAVFOR MED Operation
1. In February 2020, the Libya-Italy memorandum of understanding on migration that provides

Italian support to Libyan maritime authorities to intercept boats and return migrants to Libya was
renewed for three years. In July 2020, the Italian parliament approved the financial component of
the agreement.32
2. In March 2020, the EU decided to end an anti-migrant smuggling operation primarily
involving only surveillance aircraft, known as Operation SOPHIA, and to deploy naval vessels
with the primary task of upholding the UN arms embargo, under the name of Operation IRINI.33
3. In June 2020, Libya signed with Malta an agreement “in the area of combating illegal
immigration” by which Malta committed to finance two coordination centres and to propose, to
the European Commission and the Member States of Europe, the increase of financial support to
help the Government of the National Accord, namely, in securing the southern borders of Libya
and enhancing interception capacities.
__________________
32
https://www.web24.news/u/2020/07/italian-parliament-approves-transfer-to-libyan-coast-guard.html;
https://www.forbes.com/sites/irenedominioni/2020/07/18/italy-refinances-immigration-agreement-with-libya-amid-
protests/#6ad0cfb3c49a
33
https://www.operationirini.eu/mission-at-a-glance/
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Overview of the situation in DCIM detention centres according to

Colonel Mabrouk Abdelhafid (1 September 2020)
1. None of the DCs in the East are under DCIM authority. The staff there continue to receive
salaries but the centres are not operating.
2. DCIM is in the of process of reserving the DC situated on Zawiyah street in Tripoli for
women, children and the most vulnerable.
3. The Ministry of Interior has closed three of those nominally operating under its authority:
Al Khums, Misrata Tajura.
4. The activities of two others are provisionally suspended: Souk el Khamis and Western
Zawiya. Their managers are suspected of corruption and are under investigation. The situation of
Dahr Al Jabal is under close monitoring.34
5. The following centres are operating under the DCIM: Zliten and Abu Salim in Tripoli,
Zuwarah, Shohada’ Nasr in Zawiya and Brak al Shati in Sebha. Colonel Mabrouk pointed out the
situation of Tariq Al Sikka as problematic.
__________________
34
The Dahr Al Jabal (Zintan) DC has been totally evacuated on 18 January 2021
https://twitter.com/UNHCRLibya/status/1351186543524904967/photo/1
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Provisions of international human rights law (IHRL) and

international humanitarian law (IHL) applicable to the situation of
migrants and asylum seekers
IHRL
(1) United Nations Convention against Transnational Organized Crime, the Protocol
to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and
Children and the Protocol against the Smuggling of Migrants by Land, Sea and Air;
(2) United Nations Convention Against Torture, Article 1 which prohibits torture and
other cruel, inhuman or degrading treatment or punishment;
(3) International Covenant on Civil and Political Rights (ICCPR), Article 6, which
protects the right to life;
(4) ICCPR, Article 7, which prohibits torture and cruel, inhuman or degrading
treatment or punishment;
(5) ICPPR, Article 8, which prohibits servitude and forced or compulsory labour;
(6) ICPPR, Article 9, which prohibits arbitrary detention and affirms the right to liberty
and security; and
(7) ICPPR, Article 10, which imposes a human treatment and respect for the inherent
dignity of the human person.
The abovementioned provisions of IHRL apply to State officials or to a “person acting in an

official capacity”35 and to non-State actors who exercise government-like functions and control
over a territory.36
IHL
(1) Common Article 3 to the four Geneva Conventions of 12 August 1949, applicable in
the case of an armed conflict not of an international character, which prohibits
violence to life and person, in particular murder, mutilation, cruel treatment and
torture and outrages upon personal dignity; and
(2) Article 4 of the Protocol Additional to the Geneva Conventions of 12 August 194937
(Protocol II), which prohibits violence to health and physical or mental well-being of
__________________
35
Article 1, CAT.
36
See, for example, the Reports of the High Commissioner for Human Rights on the implementation of Human
Rights Council Resolution 7/1, 6 June 2008: 1) A/HRC/8/17, para. 9; 2) A/HRC/12/37, para. 7; 3) A/HRC/17/45,
para. 62; and 4) A/HRC/25/21, para. 11.
37
Relating to the protection of victims of non-international armed conflicts.
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persons, any form of corporal punishment, collective punishments, rape, enforced

prostitution and any form of indecent assault, slavery and the slave trade in all their
forms as well as threats to commit any of the foregoing acts.
The provisions of IHL apply to all the parties in the context of an armed conflict.
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Ministry of Interior statement on Mizdah (28 May 2020)
1. Minister Bashaga calls on the Mizdah Security Directorate to arrest the relatives of the
alleged murdered migrants trafficker who are said to have killed 26 Bangladeshi and four Africans,
and injured eleven others, in retaliation for his murder.
Figure 20.1
Statement on Mizdah
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Ministry statement on Al-Khadra General Hospital (9 April 2020)
1. Tripoli’s Al-Khadra General Hospital (designated by the Ministry of Health as the capital’s
main center for treating and isolating COVID-19 patients) was a repeated target of shelling, with
recorded attacks on 6, 7, and 9 April 2020 that injured multiple health workers, and severely
damaged the hospital building and equipment.
2. The Ministry of Health 9 April 2020 statement on the Al-Khadra General Hospital reported
that the hospital was attacked three times within 72 hours. The repeated attacks forced the Ministry
of Health to temporarily suspend the hospital operations.
Figure 21.1
Statement on the Al-Khadra General Hospital
Source: Social Media
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Evidence related to the attack on Tripoli Military Academy

(4 January 2020)
1. This annex contains statements, imagery and official reports relating to the attack.
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Appendix A to Annex 22: Attack on Tripoli Military Academy

(4 January 2020)
Figure 14.A.1
5 January 2020 statement by the GNA Ministry of Health on the airstrike that targeted the Tripoli Military
Academy, which killed 30 and wounded 33
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Appendix B to Annex 22: Report on the explosion of a missile at the Military

College, Tripoli
Figure 14.B.1
Official translation of a Ministry of Defence report on the explosion of a missile at the Military College.,
Tripoli

Office of the General Staff Subject: Technical report
Military Engineering Date: 12 Rajab A.H. 0000
Department Corresponding to 10 March
A.D. 2020
Report on the explosion of a missile at the Military College, Tripoli

On 5 January 2020, the Director of the Military Engineering Department, acting on
oral instructions from the Chief of the General Staff, ordered a technical committee to go
to the Military College, which is located in the Hadabah area, in order to carry out a
technical inspection of the targeted location, at which 32 students were killed and others
injured. After examining the site and collecting fragments caused by the explosion, the
technical committee found that:
1. The site was attacked by a drone;
2. The fragments gathered indicate that they are from a Blue Arrow 7 BY-7 guided
missile;
3. The technical specifications of the missile are as follows:
(a) Made in China;
(b) For use against armoured vehicles and small ground targets;
(c) Equipped with a semi-automatic laser guidance system;
(d) The missile had been armed with a large quantity of highly explosive material
that could cause significant damage even to armoured targets;
(e) The committee determined that the surface of the College’s square consists of two
layers:
• The first layer is made of reinforced concrete and approximately 25 cm thick;
• The second layer is made of asphalt and approximately 10 cm thick, according
to the maintenance officer of the Military College.
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Students (deceased)
# No. Rank Four-part name Remarks
1. 12533 Freshman student xxxxxxxxxxxxxxxxxxxxxxxxxxx
2. 12535 Freshman student xxxxxxxxxxxxxxxxxxxxxxxxxx
3. 12536 Freshman student xxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
4. 12539 Freshman student xxxxxxxxxxxxxxxxxxxxxxxx
5. 12540 Freshman student xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
6. 12542 Freshman student xxxxxxxxxxxxxxxxxxx
7. 12543 Freshman student xxxxxxxxxxxxxxxxxxxxxxxxxxxxx
8. 12550 Freshman student xxxxxxxxxxxxxxxxxxxxxxxxx
11. 12556 Freshman student xxxxxxxxxxxxxxxxxxxxxxxxxxxx
12. 12557 Freshman student xxxxxxxxxxxxxxxxxxxxxx
17. 12565 Freshman student xxxxxxxxxxxxxxxxxxxxxx
25. 12583 Freshman student xxxxxxxxxxxxxxxxxxxxxxx
Students* (injured) (upper-level)

1. 12299 Upper-level student xxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxx

xxxxxxxxxxxxx
2. 12397 Upper-level student Xxxxxxxxxxxxxxx xxxxxxxxxxxx
xxxxxxxxxxxxx
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3. 12698 Upper-level student Xxxxxxxxxxxxxxx xxxxxxxxxxxx
xxxxxxxxxxxxx
Military Engineering Department
Injured students* (freshmen)

1. 12581 Freshman student xxxxxxxxxxxxxxxxxxxxxxxx Xxxxxxxxxxxxxxxxxxxxx

xxxxxx
2. 12573 Freshman student Xxxxxxxxxxxxxxxxxxxxxx Xxxxxxxxxxxxxxxxxxxxx
xxxx xxxxxx
3. 12585 Freshman student xxxxxxxxxxxxxxxxxxx Xxxxxxxxxxxxxxxxxxxxx
xxxxxx
4. 12572 Freshman student Xxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxx
5. 12580 Freshman student xxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxx
xxxxxxxxx
6. 12584 Freshman student xxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxx
xxxxx
7. 12544 Freshman student Xxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxx
8. 12546 Freshman student Xxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxx
xxxxxxx
9. 12549 Freshman student Xxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxx
10. 12562 Freshman student Xxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxx
11. 12548 Freshman student Xxxxxxxxxxxxxxxxxxxxx Xxxxxxxxxxxxxxxxxxxxxxx
xxxxx
12. 12579 Freshman student Xxxxxxxxxxxxxxxxxxxxxxx Xxxxxxxxxxxxxxxxxxxxxxx
13. 12547 Freshman student Xxxxxxxxxxxxxxxxxxxxx Xxxxxxxxxxxxxxxxxxx
xxxxx
14. 12531 Freshman student Xxxxxxxxxxxxxxxxxxxxxxx Xxxxxxxxxxxx
15. 12558 Freshman student Xxxxxxxxxxxxxxxxx Xxxxxxxxxxxx
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Appendix C to Annex 14: Press release of the Libyan Army

Figure 14.C.1
Press release from the standing committee for humanitarian affairs of the Libyan Army
Source: https://www.lana-news.ly/art.php?id=187230&lang=ar&p=2&ctg_id=5. Last accessed 12 January 2021
Figure 14.C.2
Official translation of the press release
The standing committee for humanitarian affairs of the Libyan Army confirms that it has
initiated preliminary investigations with a view to prosecuting, at the local and international
levels, those who attacked the Military College students
Published on 4 January 2021 at 14:23:00
Tripoli, 4 January 2021 (WAL) — The standing committee for humanitarian affairs of the Libyan
Army announced that those who died in the Military College attack have been promoted to the
rank of second lieutenant and that their relatives, like those of their colleagues who survived the
tragedy, would be paid a salary on a permanent basis. In a statement issued on the occasion of the
first anniversary of the attack against the Military College students, the committee said that it has
initiated preliminary investigations with a view to prosecuting, at the local and international levels,
the perpetrators. In addition, the committee has been charged by the Minister of Defence of the
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Government of National Accord to pursue charges at the International Criminal Court relating to
the civil rights of the Military College students who were killed or wounded. The committee, in
its statement, reaffirmed that it had been following up on this flagrant violation since the latter part
of last year, in coordination with the Association of the Families the Dead and Wounded, and that
it has spared no effort to overcome all administrative difficulties that might prevent it from
fulfilling its mandate. The committee said that, on this painful occasion, it should be remembered
that those heroes had left behind mothers, fathers, wives, children, friends, colleagues and people
who love them, and that we must all console them and stand with them. The committee called upon
local and international judicial authorities to continue their efforts to identify the perpetrators and
ensure that they are punished severely. (WAL)
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Infographics for Pantsir S-1 AD system (on KaMAZ 6560 mobility platform)
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Figure 23.1
Description Pantsir S-1 locations in September 2020.
11 Sep 2020 14 Sep 2020

29° 26' 53.64"N, 15° 52' 51.11"E 29° 26' 19.59"N, 15° 50' 10.98"E
14 Sep 2020 14 Sep 2020

29° 17' 0.79"N, 15° 49' 06.03"E 29° 17' 33.80"N, 15° 52' 15.78"E
14 Sep 2020 18 Sep 2020

29° 24' 35.60"N, 15° 53' 54.65"E 29° 10' 01.18"N, 15° 47' 35.81"E
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Infographics for Gabya Class frigates

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Infographic for HAWK MiM-23 air defence system
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Infographics for Korkut Twin 35mm Air Defence system
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Infographic for TAI Anka UCAV
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Infographic for Firtina T-155mm self-propelled howitzer
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Infographic for T122 Sakarya MLRS
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Infographic for STM Kargu-2 loitering munition
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Infographic for Mig-29A FGA
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Infographic for Sukhoi SU-24 FGA
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Maritime non-compliance profile indicators
Table 33.1
Maritime non-compliance profile indicators
# Type Indicator Remarks

1 Visibility Automatic Identification System ▪ “Dark activity” periods.
(AIS)a
2 Route(s) Destination Ports ▪ The ports of Gabes and Algiers are
often inaccurately declared.
▪ Unusual routing from past voyages
3 Ownership Frequent change of vessel’s owners ▪ Multiple ownership changes.
▪ Lack of corporate on-line presence.
4 Operators Frequent change of vessel’s ▪ Multiple operator presence
operators ▪ Lack of corporate on line presence.
5 Vessel Name Frequent change of vessel’s name ▪
6 Vessel Tonnage Tonnage Range ▪ Comparison to tonnage of known
non-compliant vessels.
7 Commercial Linkages ▪ Links between owners / operators /
Relationships agents.
8 Flag of Registry Flags of convenience ▪
9 Documentation Accuracy ▪ Transparency in supplying to Panel.
▪ Accuracy of completion.
10 Cargo Shielding Container layout on weather deck ▪ Containers are used to line the edge
of the weather deck to shield the
remainder of the deck from external
view.
11 Cargo Analysis Volumetric and mass analysis ▪ Does reported weight and packaging
match declaration on documentation.
12 Sanction Listings Current or previous listings of ▪ Previous reports by other UN Panels
owner, operator or vessel and Monitoring Groups
▪ Sanctions lists of Member States
▪
a Or Long Range Identification and Tracking system (LRIT).
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Summary of maritime non-compliances (trafficking to GNA-AF)
1. A summary of all non-compliances with paragraph 9 of resolution 1970 (2011) for the maritime delivery or arms and military
materiel to GNA-AF is shown in table 34.1 below, whilst infographics with more detail and evidence are in the appendices.
Table 34.1
Vessels of interest to the Panel (arms trafficking to GNA-AF chronologically)
Flag registry Commercial Delivery confirmed /

Name IMO GT at time Vessel owner manager Date event Remarks
Bana 7920857 9,367 Lebanon Med Wave African 3 Jan 2020 ▪ Called at Misrata ▪ See appendix A.
Shipping S.A., a Mediterranean port. ▪ Commercial manager was
Lebanon Lines S.A.L., b beneficial owner. Relation
Lebanon with M/V Single Eagle.
28 Jan 2020 ▪ Called at Tripoli ▪ Crew provided evidence
port. that military materiel
▪ Korkut SPAAG offloaded on this voyage.
▪ Flirtina 155mm
Howitzer T155
▪ ACV-15 FNSS
IAFV
▪ 40mm/60 cannon
07 Jul 2020 . ▪ Vessel arrived in Aliaga,
Turkey, to be broken up.
Single 8708830 6,429 Panama Dytamar African 16 Jan 2020 ▪ Korkut SPAAG ▪ See appendix B.
Eagle Shipping Mediterranean ▪ Commercial manager was
Limited, Liberia Lines S.A.L., b beneficial owner. Same as
Office in Lebanon M/V Bana
Lebanon c
30 Oct 2020 ▪ Vessel arrived in
Chittagong,
Bangladesh, to be
broken up.
Ana 7369118 7,564 Albania Shega Trans Shega Group 18 Feb 2020 ▪ Called at Tripoli ▪ See appendix C.
S.A.,d Albania S.A.,d port. ▪ Targeted by HAF artillery.
Albania
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Flag registry Commercial Delivery confirmed /

Name IMO GT at time Vessel owner manager Date event Remarks
19 Mar 2020 ▪ Renamed Pray, at
Haydarpasa port,
Istanbul, Turkey.
Palau Sept 2020 ▪ Renamed VAV, ▪ Authorized by the flag to
under the flag of one single voyage, under
Palau. tow, in ballast condition and
unmanned, from Istanbul to
Izmir, Turkey, for
demolition.
Cirkin 7728699 5,846 Tanzania Redline Avrasya 28 May ▪ Called at Misrata ▪ See appendix D.
Shipping and Shipping Co 2020 port ▪ Vessel escorted by two
Trading Ltd, f ▪ M60 MBT. Turkish surface assets.
Company, e Turkey ▪ MiM-23 HAWK.
Turkey
11 June 2020 ▪ Called at Misrata ▪ Vessel escorted by three
port. Turkish surface assets.
Sao Tome & January ▪ Renamed GUZEL ▪ New flag is fraudulent.
Principe 2021 under the flag of
(false) Sao Tome &
Principe (false)
a c/o African Mediterranean Lines S.A.L., Orient Queen Homes Building, John Kennedy Street, Ras Beirut, Beirut, Lebanon. +961 1 367368.
(operations@africamedlines.com).
b Orient Queen Homes Building, John Kennedy Street, Ras Beirut, Beirut, Lebanon. +961 1 373473. (admin@africamedlines.com).
c c/o African Mediterranean Lines S.A.L., Orient Queen Homes Building, John Kennedy Street, Ras Beirut, Beirut, Lebanon. +961 1 373473.
d Rruge Tefta Tashko 10, Tirane, Albania. www.shega-trans.com/. +355 4 255008. (info@shega-trans.com).
e c/o Avrasya Shipping Co Ltd, Karaca Apartimani, Gezi Caddesi 22/3, Liman Mah, Ilkadim, 55100 Samsun, Turkey. (info@avrasyashipping.com).
f Karaca Apartimani, Gezi Caddesi 22/3, Liman Mah, Ilkadim, 55100 Samsun, Turkey. (info@avrasyashipping.com).
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Appendix A to Annex 34: M/V Bana (IMO 7920857)

1. At the end of January 2020, the Panel identified the merchant vessel M/V Bana (IMO
7920857) as a vessel of interest to the Panel based on: 1) deviation from its normal routine activity;
and 2) multiple “dark periods” of Automatic Identification System (AIS) inactivity when in the
vicinity of a Libyan port. The Panel identified two particular voyages of interest.
Voyage of Interest 1
2. M/V Bana (IMO 7920857) departed Istanbul anchorage area, Turkey, during the early hours
on 25 December 2019, with a declared destination port of Gabes, Tunisia. The vessel’s Automatic
Identification System (AIS) was disconnected at 06:50 hours38 on 31 December 2019 and was re-
connected at 09:35 hours on 3 January 2020, whilst offshore Misrata port, Libya, resulting in a
“dark period” of 3 days 2 hours and 43 minutes. There is no evidence of the vessel visiting Gabes,
Tunisia.
3. Based on the vessel’s average speed until switching off its AIS, the time required to cover
the “dark period” distance would be 12 hours and 40 minutes. Therefore, a time period of 2 days
14 hour and 3 minutes was unaccounted for. See figure 34.A.1.
Figure 34.A.1
Route followed by M/V Bana (IMO 7920857) in December 2019 / January 2020 with indication of the “dark
period”
__________________
38
All indicated hours are in Local Time.
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Voyage of Interest 2
4. A subsequent voyage to Libya by M/V Bana (IMO 7920857), departed Mersin, Turkey at
07:37 hours on 24 January 2020, with the declared destination port again being Gabes, Tunisia.
The vessel’s AIS was disconnected at 07:08 hours on 27 January 2020 and was re-connected at
21:41 hours on 29 January 2020, whilst on a track clearly departing from Libya and not Tunisia.
This resulted in a “dark period” of 2 days, 14 hours and 33 minutes.
the “dark period” distance would be 1 day, 5 hours and 48 minutes. Therefore, a time period of 1
Day 8 hours 44 minutes was unaccounted for. In addition, on the late evening of 28 January 2020
and early morning of 29 January 2020 the vessel was identified off Tripoli as being escorted by a
Turkish ‘Gabya’ Class frigate into the port of Tripoli, Libya. See figures 34.A.2 and 34.A.3.
Figure 34.A.2
Route followed by M/V Bana (IMO 7920857) in its second voyage of interest in January 2020 with indication
of the “dark period”
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Figure 34.A.3
M/V Bana (IMO 7920857) escorted by a ‘Gabya’ class frigate
6. The Tripoli port call is also confirmed by a bunker delivery note at Tripoli port, dated 29
January 2020, in which is stated that the vessel received bunker fuel between 8:20 and 15:20 hours
See figure 34.A.4.
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Figure 34.A.4
Bunker delivery note for M/V Bana (IMO 7920857)
7. M/V Bana (IMO 7920857) departed Tripoli, Libya, for destination Genoa, Italy, where the
vessel was seized and its captain arrested, on 6 February 2020. This as result of an investigation
initiated by the local authorities related to the Tripoli visit.
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Military materiel trafficked in violation of the arms embargo
8. The Panel has had access to the written testimonies of three crew members of M/V Bana
(IMO 7920857) regarding both the above referred voyages. The testimonies were provided to the
Italian authorities in the context of the ongoing investigation and judicial procedures initiated after
the seizure of the vessel and arrest of its Captain on 6 February 2020. According to these
testimonies:
(a) The stop in the port of Mersin, Turkey, corresponding with the second voyage of
interest (22 to 24 January 2020) was not initially included in the navigation plan;
(b) While in Mersin, Turkey, tanks, trucks with rocket launchers and machine guns, all-
terrain vehicles and containers marked with stickers indicating ‘explosive’ were
loaded on board of the vessel;
(c) Instead of proceeding to Gabes, Tunisia, as planned, the vessel diverted its course
towards Tripoli, Libya, while escorted by two Turkish frigates;
(d) On the evening of 28 January 2020, the vessel arrived at Tripoli port, Libya, where
the military materiel was unloaded under the control of Libyan and Turkish military
personnel;
(e) Ten soldiers from the Turkish army embarked the vessel in Mersin, Libya, and
disembarked in Tripoli, Libya;
(f) There were multiple and deliberate disconnections of the AIS to conceal the
whereabouts of the vessel at the different stages of the voyage; and
(g) The vessel had conducted previous trips from Turkey to Libya loaded with similar
military materiel.
9. The Panel obtained access to images taken by the crew on board M/V Bana (IMO 7920857)
during the second voyage of interest. Military materiel is clearly visible (figure 34.A.5). There is
also an image taken from the bridge in which the escorting ‘Gabya’ class frigate is visible (figure
34.A.6).
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Figure 34.A.5
‘Firtina’ T-155 Howitzer (sand colour) and ‘Korkut’ SSA Twin 35 mm cannon (green camouflage) on board
M/V Bana (IMO 7920857)
Figure 34.A.6
M/V Bana (IMO 7920857) being escorted by a ‘Gabya’ class frigate off Tripoli
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Appendix B to Annex 34: M/V Single Eagle (IMO 8708830)
1. In January 2020, the Panel identified the merchant vessel M/V Single Eagle (IMO 8708830)
as a vessel of interest to the Panel based on: 1) deviation from its normal routine activity; and 2)
multiple “dark periods” of Automatic Identification System (AIS) inactivity when in the vicinity
of a Libyan port.
2. The M/V Single Eagle (IMO 8708830) departed Mersin, Turkey, on 12 January 2020, with
a declared destination port of Algiers, Algeria. When 53 nautical miles off the Libyan coast the
vessel changed course onto a heading of 90 degrees, the most direct track for Tripoli, Libya. The
vessel’s AIS was disconnected at 08:47 hours on 15 January 2020, soon after the course change,
and re-connected at 18:08 hours on 17 January 2020, resulting in a “dark period” of 2 days, 9 hours
and 21 minutes.
the “dark period” distance would be 1 day, 4 hours and 54 minutes. Therefore, a time period of 1
day, 4 hour and 26 minutes was unaccounted for. See figure 34.B.1.
Figure 34.B.1
Route followed by M/V Single Eagle (IMO 8708830) in December 2019 / January 2020 with indication of the
“dark period”
4. The Tripoli port call is confirmed by a bunker delivery note at Tripoli port, dated 16 January
2020, in which is stated that the vessel received bunker between 4:30 and 11:30 hours. See figure
34.B.2.
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Figure 34.B.2
Bunker delivery note for M/V Single Eagle (IMO 8708830)
5. On 16 January 2020, social media reported that M/V Single Eagle (IMO 8708830) had made
an undeclared, covert port call to Tripoli where it off loaded some cargo and then departed.39 The
__________________
39
https://twitter.com/Rjaonkey_mhamad/status/1217744456394444800/photo/1, 16 January 2020.
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timing of the report is consistent with the approximate period of port call of M/V Single Eagle
(IMO 8708830).
6. Social media also recorded the movement from Tripoli port of low loader vehicles of tracked
armoured vehicles of a type not seen in Libya before.40
7. The Panel has geo-referenced the images to Tripoli port gates, that show a low loader
transporting an Aselsan manufactured Korkut SSA Twin 35mm self-propelled anti-aircraft gun
from the docks. See figure 34.B.3.
Figure 34.B.3
Korkut SSA Twin 35mm gun leaving Tripoli Port on a low loader
__________________
40
https://twitter.com/MstrMax11/status/1217953086884536326, 16 January 2020.
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Appendix C to Annex 34: M/V Ana/Pray (IMO 7369118)

1. In March 2020, the Panel identified merchant vessel M/V Ana (IMO 7369118) as a vessel
of interest to the Panel based on: 1) deviation from its normal routine activity; and 2) multiple
“dark periods” of Automatic Identification System (AIS) inactivity when in the vicinity of a
Libyan port.
2. On 9 February 2020 the M/V Ana (IMO 7369118) departed Mersin, Turkey, central berth
14, at 13:31 hours41, with a declared destination port of Gabes, Tunisia. The vessel’s AIS went
dark from 21:44 hours on 12 February 2020. The vessel was identified as being present in the Port
of Tripoli, Libya on 18 February 2020, when it was the target of an attack by armed forces affiliated
to Khalifa Haftar. See figure 34.C.1.
Figure 34.C.1
M/V Ana (IMO 7369118) present at Tripoli port on 18 February 2020
Source: https://twitter.com/YorukIsik/status/1229941521417457664, 18 February 2020
3. Note that the owner’s name (Shega Line) had been removed from the hull of the vessel, and
the Albanian national emblem removed from the exhaust pipes. See figure 34.C.2.
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41
All indicated hours are in Local Time.
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Figure 34.C.2
M/V Ana (IMO 7369118) present at Koper, Slovenia, on 27 December 2019
Source: Marjan Stropnik on Marine Traffic. https://www.marinetraffic.com/ar/photos/of/ships/shipid:6162062/#forward. Accessed 7

January 2021.
4. The vessel was later identified offloading cargo at Misrata port on 21 February 2020. The
operation was concealed by a barrier of containers. Its AIS remained disconnected. See Figure
34.C.3.
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Figure 34.C.3
M/V Ana (IMO 7369118) present at Misrata port on 21 February 2020
Source: Maxar Technologies for Google Earth.
5. The vessel re-connected its AIS at 10:16 hours on 8 March 2020, whilst on a direct track
departing from Misrata, Libya, resulting in a “dark period” of 24 days 12 hours and 31 minutes.
There is no evidence of the vessel ever visiting Gabes, Tunisia as declared.
the “dark period” distance would be 12 hours and 4 minutes. Therefore, a time period of 24 days
and 26 minutes was unaccounted for. See Figure 34.C.4.
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Figure 34.C.4
Route followed by M/V Ana (IMO 7369118) with indication of the “dark period”
“Dark period”: 14 days 12 hrs 31 min

Distance:
7. M/V Ana (IMO 7369118) called at Haydarpasa port, Turkey, berth number 7, at 20:26 hours
on 11 March 2020. At 04:52 hours on 15 March 2020 the vessel moved to berth number 10. See
figure 34.C.6.
Figure 34.C.6
View of Haydarpasa port, berth number 10.
Source: Google Street View.
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8. At 17:08 hours, on 16 March 2020, an image of M/V Ana (IMO 7369118) was taken at
Haydarpasa port, Turkey, berth number 10, in which it can be distinguished that the name “Pray”
is now written in the hull. See Figure 34.C.7
Figure 34.C.7
M/V Ana (IMO 7369118) displaying the name “Pray”, at Haydarpasa port, berth number 10, on 16 March
2020
Source: Yoruk Isik on Marine Traffic. https://www.marinetraffic.com/ar/photos/of/ships/shipid:6162062/#forward, Accessed 7 January

2021.
9. M/V Ana/Pray (IMO 7369118) disconnected its AIS at 05:46 on 18 March 2020. Only 9
minutes later, at 05:55 hours, a new AIS signal is displayed from same berth number 10,
Haydarpasa port, Turkey. The signal was identifying a 110-meter length, Tanzanian-flagged,
passenger vessel, named Pray, with IMO number 7295666. See figure 34.C.8.
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Figure 34.C.8
AIS signals of M/V Ana (IMO 7369118) and M/V Pray (false IMO 7295666) displayed on the same location
within 9 minutes time-lapse, on 18 March 2020
10. Note that:

(a) M/V Ana (IMO 7369118) and M/V Pray (false IMO 7295666) displayed their AIS
signals at the exact same location within a 9-minute interval;
(b) The signal displayed by M/V Pray (false IMO 7295666) indicated a vessel of identical
length as M/V Ana (IMO 7369118); and
(c) M/V Ana (IMO 7369118) has not displayed any AIS signal since it was last
disconnected.
11. According to the IMO number scheme manager, IHS Maritime, the IMO number 7295666,
displayed by M/V Pray, is a number that has never been used or issued to any vessel.
12. M/V Ana (IMO 7369118), renamed as M/V Pray and displaying false IMO number
7295666, departed Haydarpasa port, Turkey, at 12:46 hours on 19 March 2020 with a declared
destination port of Gabes, Tunisia. Despite its declared destination, the vessel did not follow the
shortest and most economical route, but one along the Turkish coast designed to avoid Greek
territorial waters. See figure 34.C.9
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Figure 34.C.9
Route followed by M/V Ana (IMO 7369118) renamed as M/V Pray, with indication of the usual commercial
route
13. At 08:35 hours on 23 March 2020, while on a track consistent with Gabes, Tunisia, M/V
Ana (IMO 7369118), renamed as M/V Pray, conducted a sharp change of course. According to
social media, the change in the course was the result of the intervention of French Frigate Provence
(D652).42 The vessel set sail to Antalya, Turkey, where it remained anchored between 26 and 29
March 2020. According also to social media, the vessel was escorted by two Turkish Navy Gabya
class frigates.43
14. At 21:22 hours on 31 March 2020, M/V Ana (IMO 7369118), renamed as M/V Pray, called
at Mersin port, Turkey, passenger terminal number 1, where it remained until 23:30 hours of 6
April 2020.
15. At 10:19 hours on 12 April 2020, the vessel called to Haydarpasa port, Turkey, berth number
10. At 18:40 on 21 May 2020, the vessel was moved to berth number 5, where it displayed its AIS
signal, with a large number of interruptions, until 18 November 2020. See figure 34.C.10
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42
https://almarsad.co/en/2020/03/28/french-navy-intercepts-ship-with-turkish-weapons-heading-for-libya/
43
https://twitter.com/AegeanHawk/status/1243851532124270592?s=20
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Figure 34.C.10
M/V Ana (IMO 7369118) present at Haydarpasa port, Turkey, berth number 5, on 25 August 2020
Source: Maxar Technologies for Google Earth.
16. In September 2020, M/V Ana (IMO 7369118) was renamed M/V Vav and registered under
the flag of Palau. It was authorized by the flag to conduct one single voyage, to Izmir, Turkey,
under tow, on ballast condition and unmanned, for demolition. The certificate of registry expired
on 11 January 2021.
17. The Panel finds that M/V Ana (IMO 7369118) conducted a partial / incomplete offload in
Tripoli port. A barrier of containers was used to shield the offloading in Misrata.
18. According to social media, a new delivery of weapon systems was received on 21 February
2020, when M/V Ana (IMO 7369118) was being offloaded in Misrata.44
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44
https://www.facebook.com/2383067438376999-‫الصمود‬-‫لواء‬/photos/a.2383155261701550/3362817587068641
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Appendix D to Annex 34: M/V Cirkin (IMO 77286990)

1. In June 2020, the Panel identified merchant vessel M/V Cirkin (IMO 7728699) as a vessel
of interest to the Panel based on: 1) deviation from its normal routine activity; and 2) multiple
“dark periods” of Automatic Identification System (AIS) inactivity when in the vicinity of a
Libyan port.
2. On 24 May 2020 the M/V Cirkin (IMO 7728699) departed Haydarpasa port, Turkey, berth
number 7, at approximately 11.30 hours45, with a declared destination port of Alexandria, Egypt.
At 09:21 hours on 26 May 2020, while heading west 157 nautical miles north of Marsa Matruh,
Egypt, the vessel changed its destination to Gabes, Tunisia.
3. The Panel finds this was done to justify not following the shortest and most economical
route, but one along the Turkish coast designed to avoid Greek territorial waters. See figure 34.D.1.
Figure 34.D.1
Route followed by M/V Cirkin (IMO 7728699) on its first voyage with indication of the usual commercial
route
4. Although the vessel’s AIS was connected during the whole voyage, its IMO number and
home port were no longer displayed on the hull. Its name was changed to “Kin”.
5. During its voyage, M/V Cirkin (IMO 7728699) was escorted by two Turkish naval vessels.
6. M/V Cirkin (IMO 7728699) called at Misrata port, Libya, at 11:26 hours on 28 May 2020.
The vessel berthed prior to all other vessels in the port area. Containers were used to conceal the
offloading.
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45
All hours are in Local Time unless otherwise indicated.
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7. M/V Cirkin (IMO 7728699) departed Misrata at 09:16 hours on 29 May 2020. The vessel
called at Haydarpasa port, Turkey, berth number 7, at 07:14 hours on 4 June 2020. At 12:57 hours
on the same day the vessel moved to berth number 10.
8. M/V Cirkin (IMO 7728699) then departed Haydarpasa port, Turkey, berth number 10, at
12:33 hours on 7 June 2020, with again a declared destination port of Gabes, Tunisia. As in its
previous voyage, the vessel did not follow the shortest and most economical route, but one along
the Turkish coast designed to avoid Greek territorial waters. See figure 34.D.2.
Figure 34.D.2
Route followed by M/V Cirkin (IMO 7728699) on its second voyage with indication of the usual commercial route
9. During its second voyage, M/V Cirkin (IMO 7728699) was escorted by a Turkish Naval
Task Force comprising the Gabya class frigates Gokceada (F494) and Gokoba (F496) and the
Barbaros class frigate Orucreis (F245). These Turkish assets were declared to be providing
associated support to the NATO Operation SEA GUARDIAN.46
10. At 03:40 hours (UTC) on 10 June 2020, the vessel was interrogated by Operation IRINI
naval assets. One of the Turkish frigates escorting the vessel replied informing that M/V Cirkin
(IMO 7728699) was: (1) chartered by the Turkish State; (2) under their control and protection; and
(3) transporting medical supplies to Libya. Later that day, at 16:58 hours (UTC), M/V Cirkin (IMO
7728699) was interrogated by an Operation SEA GUARDIAN Naval asset. Although the answers
provided were consistent with the previous ones, the Turkish Naval Force hindered attempts to
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46
https://mc.nato.int/missions/operation-sea-guardian.
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approach the vessel by navigation manoeuvres including the use of radar emissions from the
TMKu fire control radar of Turkish frigate Orucreis (F245) and a TMX fire control system.
11. M/V Cirkin (IMO 7728699) called at Misrata port, Libya, at 11:27 hours on 11 June 2020.
On arrival, the vessel berthed immediately prior to all other vessels in the port waiting area.
Containers were once again used to shield the offloading operation.
12. The Panel finds that:
(a) The Turkish Navy claims that M/V Cirkin (IMO 7728699) transported medical supplies
are totally unconvincing; and
(b) M/V Cirkin (IMO 7728699), and the Turkish Navy escort frigates Orucreis (F245),
Gokceada (F494) and Gokoba (F496), all violated paragraph 9 of resolution 1970
(2011).
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Summary of maritime non-compliances (trafficking to HAF)
1. A summary of all non-compliances with paragraph 9 of resolution 1970 (2011) for the maritime delivery or arms and military
materiel to HAF is shown in table 35.1 below, whilst infographics with more detail and evidence are in the appendices and in Annex
86.
Table 35.1
Vessels of interest to the Panel (arms trafficking to HAF (chronologically)
GT Flag Delivery confirmed / Remarks

Name IMO registry Vessel owner Commercial manager Date event
Sunrise Ace 9338840 58,685 Bahamas Snowscape Car Mitsui Osk Lines 2 Jan 2020 ▪ 500+ 4x4 for ▪ See appendix A
Carriers S.A.a Ltd, b conversion to ▪ Loaded in Amman, Jordan.
Japan Japan “Technicals”.
▪ Offloaded in Misrata.
Gulf Petroleum 4 9439345 8,539 Liberia AA Marine Inc, c Gulf Shipping 13 Mar 2020 ▪ 10, 954 tonnes of ▪ See Annex 86.
UAE Services FZE, Jet A-1. ▪ Loaded in Sharjah.
UAE c ▪ Offloaded in Benghazi.
Royal Diamond 7 9367437 8,539 Marshal Gsh2 Chem-Prod Hanjin Overseas 10 Sep 2020 ▪ 10,245 tonnes of ▪ See Annex 86.
Islands Carrier I As f Tanker Pte Ltd g Jet A-1 ▪ Offload expected in
Singapore Singapore Benghazi but aborted.
▪ Boarded by Operation
IRINI.
▪ Ownership and
management fully
cooperated with the Panel.
a A subsidiary of Mitsui O.S.K. Lines, Shosen Mitsui Building 1-1 Toronomon 2-Chome, Minato-ku, Tokyo 105-8688. (www.mol.co.jp).
b Shosen Mitsui Building 1-1 Toronomon 2-Chome, Minato-ku, Tokyo 105-8688
c Gate 4, Land C1-3A, Ajman Port, Ajman Free Zone, Ajman, United Arab Emirates. +971 6 740 9982.
c Gulf Shipping Services FZC, Gate 4, Land C1-3A, Ajman Port, Ajman Free Zone, Ajman, UAE. Fax: +971 6 740 9982. (gulf.petroleum@hotmail.com).
d c/o Ims Hellenic Co. 9, Filellinon Street, 185 36 Piraeus, Greece. +30 210 429 2714. (ims.hellenic@gmail.com).
e 9, Filellinon Street, 185 36 Piraeus, Greece. +30 210 429 2714. (ims.hellenic@gmail.com).
f 58-00, One Raffles Place, 1, Raffles Place, Singapore 048616. +65 6533 1040
g 07-01, PSA Building, 460, Alexandra Road, Singapore 119963. +65 6373 5153. (chem@hanjin.com).
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Appendix A to Annex 35: M/V Sunrise Ace (IMO 9338840)

1. The M/V Sunrise Ace (IMO 9338840) departed Aqaba New Port, terminal number 4, Jordan, at
07:29 hours47 on 26 December 2019 and called at Benghazi port, Libya, at 21:46 hours on 1 January
2020.
2. The Panel identified that M/V Sunrise Ace (IMO 9338840) offloaded over 500 4x4 vehicles
suitable for conversion to “technicals”. The Panel noted from social media that a large number of
4x4 vehicles were for the use by forces affiliated to Khalifa Haftar. 48 During the offload an
individual was heard to say “these are for the Marshall” meaning Haftar. See figure 35.A.1.
Figure 35.A.1
Footage caption of the vehicles on board M/V Sunrise Ace (IMO 9338840).
Source: https://www.facebook.com/watch/?v=2315215998580109, 2 January 2020.
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47
All hours in Local Time.
48
See video imagery where an individual clearly states “ (...) this is following the orders of the Marshall (...) This is 2020 ,
they are here to support all the fronts ....”. The Marshall being Khalifa Haftar.
https://www.facebook.com/watch/?v=2315215998580109, 2 January 2020. Last accessed January 2021
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Figure 35.A.2
Infographic for M/V Sunrise Ace (IMO 9338840)
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Infographic for Dehleyvah ATGM
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Infographic for FNSS ACV-15
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Infographic for Harpy loitering munition
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Airbridges in support of the GNA-AF
1. The Panel has used a wide range of sources49 to identify an increase in covert, non-scheduled
and/or charter civilian flights from primarily Turkey to Western Libyan airports controlled by
GNA-AF. The Panel has written to the States of the owners and operators of the aircraft listed in
the appendices requesting copies of the flight manifests and air waybills for these particular flights.
2. The GNA-AF is almost certainly using civilian commercial airlines to form a major part of
its supply chain for military materiel. There are regular flights from Western Libya to Turkey, yet
it is almost impossible to book a seat on any of these flights. The Panel has identified the aircraft
and operators shown in table X.1.1 as of particular interest. All of these aircraft have routinely
used their aircraft registration number rather than a flight callsign when communicating with air
traffic control and broadcasting on ADS-B. This is unusual, and a strong indicator that the flight
is not for fare paying passengers. Suspicious flights are routine.
Figure 39.1
Overview of GNA-AF airbridges 50
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49
Flight data for flights shown in all of the annexes is based on data received from a combination of : 1) Confidential
sources; 2) www.flightradar24.com; 3) www.radarbox.com; 4) www.italmilradar.com; 5) C4ADS analysis; 6) Twitter
@Gerjon_; and 7) Twitter @YorukIsik.
50
Base map courtesy of C4ADS.
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Table 39.1
Libyan registered commercial aircraft of interest to the Panel
A/C # A/C type Hex Code Operated by Owned by Remarks

a
5A-LAP A320-214 018078 Libyan Airlines Operator ▪ Wholly owned by Government of
Libya.
5A-LAQ A320-214 01807A Libyan Airlines Operator ▪
5A-LAR A320-202 01807B Libyan Airlines Operator ▪
5A-LAT A320-202 01807F Libyan Airlines Operator ▪
5A-ONA A320-214 01802E Afriqiyah Airlines b Operator ▪ Wholly owned by Government of

Libya.
5A-ONB A320-214 01802F Afriqiyah Airlines Operator ▪
5A-ONJ A320-214 018057 Afriqiyah Airlines Operator ▪ Removed from storage on 19 March
2020.
5A-ONO A320-214 018070 Afriqiyah Airlines Operator ▪ Removed from storage on 2 March
2020.
5A-POL Police Aviation Government of ▪ Virtually daily flights.
Libya
5A-WLB A319-112 018087 Libyan Wings c DAE Capital d ▪
5A-WLC A319-112 01808F Libyan Wings DAE Capital ▪

5A-WLD A319-112 018090 Libyan Wings DAE Capital ▪ Removed from storage on 16 March
2020.
a
www.libyanairlines.aero. Website inaccessible. http://www.libyahavayollari.com.tr/en/iletisim.html. Old website active.
b
https://www.afriqiyah.aero/en/. Accessed 18 July 2020.
c
https://libyanwings.ly. Accessed 18 July 2020.
d
https://dubaiaerospace.com/dae-capital/. Accessed 18 July 2020.
3. The Panel has also identified that Turkey initiated an airbridge to Western Libyan airbases
in mid-May 2020 using Turkish Air Force military cargo aircraft. A summary is at appendix A.
The Panel finds that Turkey is in non-compliance with paragraph 9 of resolution 1970 (2011) for
the transfer of military materiel to Libya.
4. The Panel has also identified that Qatar made at least six flights to Western Libyan airbases
between 21 May 2020 to 3 June 2020 using Qatari Air Force military C-17 Globemaster cargo
aircraft (A7-MAC and A7-MAO). A summary is at appendix B. The Panel finds that Qatar is in
non-compliance with paragraph 9 of resolution 1970 (2011) for the transfer of military materiel to
Libya, that materiel at a minimum being the military cargo aircraft.
5. The 5+5 Joint Military Committee ceasefire agreement of 23 October 202051 provided
challenges to the Panel’s monitoring of the air bridges, as empty military cargo aircraft could enter
__________________
51
https://unsmil.unmissions.org/sites/default/files/ceasefire_agreement_between_libyan_parties_english.pdf, 23 October
2020.
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Libya to remove military equipment as required by the initial ceasefire agreement to remove foreign
fighters in 90 days, which was amended on 3 November 2020 to the withdrawal of foreign forces
from the contact lines.52 As such, they would have very similar profile indicators to aircraft suspected
of trafficking. Whilst the introduction of such military cargo aircraft into Libya is a violation of the
arms embargo, it would clearly be inappropriate of the Panel to report it as such if it were engaged
in the removal of military equipment. It would of course be helpful if the Member States involved
informed the Committee in advance of such flights to allow the Panel to deconflict them.
__________________
https://www.libyaherald.com/2020/11/04/55-joint-military-commission-agrees-permanent-ceasefire-steps-at-ghadames-
52
meeting/, 4 November 2020.
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Appendix A to Annex 39: Turkish military aircraft in support of GNA

1. The Panel has identified the Turkish military cargo aircraft shown in table 39.A.1 as of
interest to the Panel. The Panel has identified 89 confirmed flights into Libya by Turkish Air Force
military cargo aircraft during 21 May to 31 December 2020 (see table 39.A.2 and figures 39.A.2
and 39.A.3). The list is not exhaustive as the Turkish Air Force adopted an indirect route to avoid
certain Flight Information Regions (FIR).53 This route follows the Istanbul / Nicosia FIR boundary
and then the Athens / Cairo FIR boundary until reaching the Tripoli FIR, (see yellow dotted line
on figure 39.A.1).
Figure 39.A.1
Turkish military aircraft routing to Libya 54
Table 39.A.1
Turkish military aircraft of interest to the Panel
A/C # A/C type Mode-S # Unit Remarks

13-0009 A400M 4B8208 221 Breeze Squadron Based at Kayseri/Erkilat a
14-0013 A400M 4B820C 221 Breeze Squadron Based at Kayseri/Erkilat
14-0028 A400M 4B820E 221 Breeze Squadron Based at Kayseri/Erkilat
__________________
53
A Libyan NGO, the Silphium Foundation for Studies and Research, has reported identifying 105 Turkish Air Force
flights. https://www.facebook.com/211203056228201/photos/a.211240296224477/691316024883566/?_rdc=1&_rdr,
31 December 2020.
54
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A/C # A/C type Mode-S # Unit Remarks

15-0051 A400M 4B820F 221 Breeze Squadron Based at Kayseri/Erkilat
16-0055 A400M 4B8210 221 Breeze Squadron Based at Kayseri/Erkilat
61-0693 C-130E 4B8220 222 Flame Squadron Based at Kayseri/Erkilat
TBC C-130E 4B821F 222 Flame Squadron Based at Kayseri/Erkilat
TBC C-130E C9D52F 222 Flame Squadron Based at Kayseri/Erkilat
a LTAU. Joint Airbase. 38°46'13"N, 35°29'43"E.
Figure 39.A.2
Summary of flights from Turkey by Turkish military aircraft (1 May to 31 December 2020)
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Figure 39.A.3
Summary of maximum cargo (tonnes) from Turkey by Turkish military aircraft (1 May to 31 December 2020)
Table 39.A.2
Suspicious flights from Turkey to Western Libya by Turkish military aircraft (2020)
Maximum
# Date A/C # Mode-S # Type To load (t) Remarks
a
1 21 May 2020 C9D52F C-130E Misrata 19
2 23 May 2020 61-318855 4B8225 C-130E HLMS 19
3 23 May 2020 C9D52F C-130E HLMS 19
4 24 May 2020 61-3188 4B8225 C-130E HLMS 19
5 24 May 2020 C9D52F C-130E HLMS 19
6 26 May 2020 61-3188 4B8225 C-130E HLMS 19
7 26 May 2020 C9D52F C-130E HLMS 19
8 27 May 2020 61-3188 4B8225 C-130E HLMS 19
9 27 May 2020 71-1468 4B8228 C-130E HLMS 19
10 29 May 2020 61-3188 4B8225 C-130E Unknown 19
11 29 May 2020 71-1468 4B8228 C-130E Unknown 19
12 31 May 2020 61-3188 4B8225 C-130E HLMS 19
13 31 May 2020 71-1468 4B8228 C-130E HLMS 19
14 2 Jun 2020 61-3188 4B8225 C-130E HLMS 19
__________________
55
Possibly 61-03188.
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Maximum
15 2 Jun 2020 71-1468 4B8228 C-130E HLMS 19
16 3 Jun 2020 61-3188 4B8225 C-130E HLMS 19
17 6 Jun 2020 61-3188 4B8225 C-130E HLMS 19
18 6 Jun 2020 71-1468 4B8228 C-130E HLMS 19
19 11 Jun 2020 61-3188 4B8225 C-130E HLMS 19
20 11 Jun 2020 71-1468 4B8228 C-130E HLMS 19
21 24 Jun 2020 61-3188 4B8225 C-130E HLMS 19
22 24 Jun 2020 71-1468 56 4B8228 C-130E HLMS 19
23 29 Jun 2020 61-3188 4B8225 C-130E HLMS 19
24 8 Jul 2020 61-3188 4B8225 C-130E Tripoli 19
25 8 Jul 2020 17-0055 4B8210 A400M Tripoli 37
26 9 Jul 2020 17-0080 4B8212 A400M HLMS 37
27 16 Jul 2020 71-1468 4B8228 C-130E Al Wattiyah b 19
28 16 Jul 2020 17-0080 4B8212 A400M HLMS 37
29 17 Jul 2020 71-1468 4B8228 C-130E HL77 19
30 18 Jul 2020 71-1468 4B8228 C-130E HL77 19
31 18 Jul 2020 17-0080 4B8212 A400M HLMS 37
32 19 Jul 2020 71-1468 4B8228 C-130E HL77 19
33 20 Jul 2020 C9D25F C-130E HL77 19
34 21 Jul 2020 61-2634 4B8221 C-130E HL77 19
35 25 Jul 2020 17-0080 4B8212 A400M HLMS 37
36 29 Jul 2020 71-1468 4B8228 C-130E HL77 19
37 29 Jul 2020 4B821F C-130E HL77 19
38 7 Aug 2020 61-2634 4B8221 C-130E HL77 19
39 14 Aug 2020 61-2634 4B8221 C-130E HL77 19
40 15 Aug 2020 4B821F C-130E HL77 19
41 16 Aug 2020 61-0693 4B8220 C-130E HL77 19
42 16 Aug 2020 17-0078 4B8211 A400M HLMS 37
43 16 Aug 2020 17-0080 4B8212 A400M HLMS 37
44 21 Aug 2020 4B821F C-130E HL77 19
45 21 Aug 2020 17-0080 4B8212 A400M HLMS 37
46 25 Aug 2020 17-0080 4B8212 A400M HLMS 37
47 1 Sep 2020 61-0693 4B8220 C-130E HL77 19
48 1 Sep 2020 71-1468 4B8228 C-130E HL77 19
49 1 Sep 2020 17-0080 4B8212 A400M HLMS 37
50 3 Sep 2020 61-0693 4B8220 C-130E HL77 19
51 3 Sep 2020 71-1468 4B8228 C-130E HL77 19
52 3 Sep 2020 17-0080 4B8212 A400M HLMS 37
53 5 Sep 2020 61-2634 4B8221 C-130E HL77 19
54 5 Sep 2020 71-1468 4B8228 C-130E HL77 19
55 7 Sep 2020 17-0055 4B8210 A400M Tripoli 37
56 11 Sep 2020 71-1468 4B8228 C-130E HL77 19
__________________
56
Possibly 71-01468.
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Maximum
57 1 Oct 2020 15-0051 4B820F A400M HLMS 37
58 1 Oct 2020 16-0055 4B8210 A400M HLMS 37
59 1 Oct 2020 71-1468 4B8228 C-130E HL77 19
60 2 Oct 2020 71-1468 4B8228 C-130E HL77 19
61 7 Oct 2020 71-1468 4B8228 C-130E HL77 19
62 15 Oct 2020 61-0693 4B8220 C-130E HL77 19
63 15 Oct 2020 71-1468 4B8228 C-130E HL77 19
64 16 Oct 2020 61-0693 4B8220 C-130E HL77 19
65 18 Oct 2020 61-0693 4B8220 C-130E HL77 19
66 18 Oct 2020 71-1468 4B8228 C-130E HL77 19
67 23 Oct 2020 4B821F C-130E HL77 19
23 Oct 2020 Ceasefire
68 5 Nov 2020 18-0093 4B8213 A400M HLMS 37
69 5 Nov 2020 61-0693 4B8220 C-130E HL77 19
13 Nov 2020 HL77 extended to take A400M
70 21 Nov 2020 71-1468 4B8228 C-130E HL77 19
71 21 Nov 2020 17-0078 4B8211 A400M HLMS 37
72 26 Nov 2020 16-0055 4B8210 A400M HL77 37 First A400M
landing at Al
Watiya
73 26 Nov 2020 17-0078 4B8211 A400M Zuwarah 37
74 26 Nov 2020 18-0093 4B8213 A400M HL77 37
75 28 Nov 2020 16-0055 4B8210 A400M HL77 37
76 28 Nov 2020 17-0078 4B8211 A400M HL77 37
77 28 Nov 2020 18-0093 4B8213 A400M HL77 37
78 1 Dec 2020 17-0078 4B8211 A400M HL77 37
79 1 Dec 2020 18-0093 4B8213 A400M HL77 37
80 1 Dec 2020 18-0094 4B8214 A400M HL77 37
81 4 Dec 2020 15-0051 4B820F A400M HL77 37
82 4 Dec 2020 17-0078 4B8211 A400M HL77 37
83 4 Dec 2020 18-0093 4B8213 A400M HL77 37
84 16 Dec 2020 14-0028 4B820E A400M HL77 37
85 16 Dec 2020 18-0093 4B8213 A400M HL77 37
86 25 Dec 2020 16-0055 4B8210 A400M HL77 37
87 25 Dec 2020 18-0093 4B8213 A400M HL77 37
88 29 Dec 2020 16-0055 4B8210 A400M HL77 37
89 29 Dec 2020 17-0078 4B8211 A400M HL77 37
a HLMS. Joint Airbase. 32°19'31"N, 15°03'39"E.

b HL77. Military Airbase. 32°28'20"N, 11°54'00"E.
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2. The Panel noted a build-up of ground stored cargo at Misrata airport57 during the initial
period of the Turkish Air Force flights (see figures 39.A 4 to 39.A.7).58
Figure 39.A.4 Figure 39.A.5

Misrata airport (23 April 2020) Misrata airport (13 May 2020)

Misrata airport (1 June 2020) Misrata airport (14 June 2020)
3. The Panel also noted that on approximately 9 July 2020 the focus of C-130 inbound flights
moved from Tripoli/Misrata to Al Watiyah (HL77), whereas the A400 flights continued to Misrata.
The hardstanding for aircraft at Al Watiyah was increased by 70m x 140m between 20 August and
2 September 2020. The runway (10R/28L) runoff was repaved for 300m at each end, potentially
extending the effective runway length from 3,200m to 3,800m.
__________________
57
Centred on 32°18'44.87"N, 15°03'48.60"E.
58
Image sources: https://twitter.com/ahmedabdo1806/status/1273601918095556608, 18 June 2020.
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4. This part of the runway was then resurfaced and remarked between 13 and 23 November 2020.
This allows the Turkish Air Force A400B and Qatar Air Force C-17 Globemaster to operate more
safely, and a Turkish Air Force A400B was identified first using this runway on 26 November 2020.

Al Watiyah airport runway 10R/28L extension Al Watiyah airport runway 10R/28L extension
5. As these are military aircraft their landings at Libyan airports means that Turkey has violated
paragraph 9 of resolution 1970 (2011) regardless of whether or not their military cargo aircraft
transferred arms or military equipment to Libya.
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Appendix B to Annex 39: Qatari military aircraft in support of GNA

1. The Panel has identified the Qatari Air Force military cargo aircraft shown in table X.B.1 as
of interest to the Panel. The Panel has identified suspicious flights of Qatari Air Force military
cargo aircraft into Libya (table X.B.2). The list is not exhaustive as flight data is not available to
the Panel as the routing avoids air traffic control en route, and since 3 June 2020 the Mode-S
transponders for these aircraft have been disabled.
Table 39.B.1
Qatari military aircraft of interest to the Panel
Cargo Load
A/C # A/C type Hex Code Unit (tonnes) Remarks
A7-MAC C-17A 06A255 76.6
A7- C-17A 06A27C 76.6
MAO
Table 39.B.2
Suspicious flights from Qatar by Qatari military aircraft
# Date Flight # A/C # Type From To Flight # Remarks

1 21 May 2020 A7-MAC C-17A
2 23 May 2020 TUAF223 A7-MAC C-17A Istanbul Libya
3 23 May 2020 TUAF224 A7-MAO C-17A Istanbul Libya
4 26 May 2020 A7-MAC C-17A
5 26 May 2020 A7-MAO C-17A
6 3 Jun 2020 A7-MAC C-17A Mode-S tracking disabled
2. As these are military aircraft their landings at Libyan airports means that Qatar has violated
paragraph 9 of resolution 1970 (2011) regardless of whether or not their military cargo aircraft
transferred arms or military equipment to Libya.
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Infographic for Misagh-2 MANPADS
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Bulgarian manufactured 120mm Mortar Bomb
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GNA-AF Diver Training in Khoms
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GNA-AF Training on T155 Firtina Howitzer
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GNA-AF Military Training
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GNA Coast Guard Training
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GNA-AF Special Forces Training
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LENCO Bearcat APC with GNA-AF
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GNA-AF Forward Observation Officer (FOO) Training
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GNA-AF Abseil Training
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GNA payments to Turkish arms group SSTEK
Figure 50.1
Letter dated 2 June 2019
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Figure 50.2
True copy from the archive
State of Libya
Government of National Accord
Ministry of the Interior
Office of the Minister
Ref. No.: shin sin/768 2 June 2019
Sir,
We should be grateful if you would transfer the sum of EUR 70,438,940.00 (seventy million, four
hundred and thirty-eight thousand, nine hundred and forty euros) to the account of the SSTEK company for
the purchase of specific necessities for the Ministry of the Interior. The account number is
TR420001001745797949255014. The funds should be debited from our account with you, whose number
is Chapter III, No. 200-1733.
The funds are intended to fulfil the vital needs of the Ministry of the Interior. A statement and the
approval of the Audit Bureau are enclosed herewith.
Peace be upon you.

(Signed) Fathi Ali Bashagha
Acting Minister of the Interior
Governor of the Central Bank of Libya
Copied:
Confidential affairs
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Figure 50.3
Letter dated 17 July 2019
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Figure 50.4

Department of Financial Affairs
Ref. No.: 4-40/2270 17 July 2019
Sir,
We refer to letter shin sin/937 of 15 July 2019 from the acting Minister of the Interior to the Governor of
the Central Bank of Libya concerning the transfer of EUR 169,885,685.20 to account
TR420001001745797949255014 of the company SSTEK for the purchase of specific necessities for the
Ministry of the Interior.
We should like the balance in Libyan dinars to be debited from our account with you, whose number is
Chapter II, No. 1733-200, and transferred to the beneficiary’s account.
(Signed) Muhammad Milad Hadid

Comptroller-General
(Signed) Colonel Muhammad Sa‘id Faradah

Acting Director-General, Department of Financial Affairs
Director, Department of Financial Transactions, Central Bank of Libya
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Figure 50.5
Letter dated 3 November 2019
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Figure 50.4
State of Libya
Office of the Minister
Ref. No.: shin sin/1534 3 November 2019
Sir,
We write further to our letter shin sin/1446 of 21 October 2019. We should be grateful if you would
disregard that letter and transfer the sum of EUR 169,000,000 (one hundred and sixty-nine million euros) to
the account of the SSTEK company for the purchase of specific necessities for the Ministry of the Interior.
The account number is TR420001001745797949255014. The funds should be debited from our account
with you, whose number is Chapter III, No. 1733-200, rather than being transferred by a letter of credit as
stated in the aforementioned letter.
The funds are intended to fulfil the vital needs of the Ministry of the Interior. A statement and the
approval of the Audit Bureau are enclosed herewith.
(Signed) Fathi Ali Bashagha

Acting Minister of the Interior
Governor of the Central Bank of Libya
Copied:
- Director-General, Department of Financial Affairs
- Comptroller-General
- (Illegible)
Sources:
1) http://www.hawarnews.com/en/haber/leaked-documents-transfer-of-huge-sums-from-the-libyan-central-bank-to-turkish-company-
sstek-h17342.html, 22 June 2020;
2) https://libyareview.com/4019/, 21 June 2020; and
3) 29 November 2019. https://www.afrigatenews.net/article/‫التركية‬-‫األسلحة‬-‫الوفاق‬-‫حكومة‬-‫شراء‬-‫صفقات‬-‫تثبت‬-‫مسربة‬-‫وثائق‬/
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HAF Training in Jordan (2018)
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Serbian manufactured P62M8 120mm Mortar Bomb
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Infographic for KADDB Mared 8x8 MPAV with “snakehead” turret
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Infographic for TAG/AOI Terrier LT79 AFV
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Airbridges in support of HAF
1. The Panel has used a wide range of sources59 to identify an increase in covert, non-scheduled
and/or charter flights from the United Arab Emirates, Eritrea, Jordan and Syria to Eastern Libyan
airports controlled by HAF, or to Western Egyptian airports as part of the wider supply chain (see
figure 55.1 and table 55.1). The Panel has written to the States of the owners and operators of the
aircraft flying these airbridges requesting copies of the flight manifests and air waybills for these
particular flights. The Panel has analysed the few received and identified sufficient evidence that
these flights were in support of HAF.
Figure 55.1
60
Overview of HAF airbridges
2. Although satellite imagery,61 confidential sources and early ADS-B data supports Eastern
Libyan airfields as the destination for some flights, it is also known that other flights probably only
went as far as the air bases at Habata (HE18), Uthman (HE27) or Sidi Barani (HE40) in Egypt to
offload cargo for either: 1) collection by Libyan based cargo aircraft under the control of HAF (see
table 55.3); or 2) forward land transportation to Libya. These airbridge flights to Egyptian airbases
form part of the wider supply chain, and the Panel thus finds that as this is an indirect supply (…)
of arms and related materiel (…) and other assistance that the operators of the aircraft forming
__________________
59
Flight data for flights shown in all of the annexes is based on data received from a combination of : 1) Confidential
sources; 2) www.flightradar24.com; 3) www.radarbox.com; 4) www.italmilradar.com; 5) C4ADS analysis; 6) Twitter
@Gerjon_; and 7) Twitter @YorukIsik.
60
61
The satellite imagery (IMINT) can identify the type of aircraft but not the operator.
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the air bridge are in non-compliance with paragraph 9 of resolution 1970 (2011), even if only
flying the UAE to Egypt leg of the supply chain. Due diligence checks should have established the
military nature of the cargoes and the intended end user.
Table 55.1
HAF air lines of communication (ALOC)
# From To Operators a
v
1 Egypt Benghazi, Libya ▪ Air Cairo ▪
2 Eritrea HLLB ▪ Azee Air ▪ Azee Air AOC suspended for six
months on 12 April 2020.
▪ Jenis Air ▪ Jenis Air LLC AOC suspended for
6 months on 2 July 2020.
3 Eritrea Mersa Matruh, Egypt c ▪ Maximus Air ▪
▪ ZetAvia
4 Jordan HLLB ▪ Azee Air ▪
5 Syria HLLB ▪ Cham Wings ▪

d
6 Syria Labruq, Libya ▪ Russian Federation Air Force ▪
e
7 UAE Al Khadim, Libya ▪ Cham Wings ▪
▪ Russian Federation Air Force
8 UAE HLLB ▪ Azee Air ▪
▪ Cham Wings
▪ Jenis Air
▪ Russian Federation Air Force
▪ United Arab Emirates Air Force
9 UAE Ghardabiya, Libya f ▪ ZetAvia ▪

10 UAE Sidi Barani, Egypt g ▪ Azee Air ▪
▪ JenisAir
▪ United Arab Emirates Air Force
▪ Zet Avia
a Flights for each air operator are summarized in appendices A to J in alphabetical order. Contact details in aircraft specific tables.
b HL59. 31°59'55"N, 21°11'30"E.
c HEMM. 31°19'31"N, 27°13'18"E.
d HLLQ. 22°47'00"N, 17°28'00"E.
e HLLB. 32°05'48"N, 20°16'10"E.
f HLGD. 31°03'38"N, 16°36'42"E.
g HE40. 31°27'59"N, 25°52'41"E.
3. Imagery from a single source in social media, supported by commercial satellite imagery
though, has identified the concentration of a large number of vehicles at the Sidi Barani airbase in
Egypt. The numbers fluctuate as shown in table 55.2 and figures 55.2 to 55.10. The Panel is
currently investigating and obtaining independent satellite imagery. The presence of all these
vehicles though is highly indicative of a land supply route to Eastern Libya.
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Table 55.2
62
Fluctuation of vehicle numbers at Sidi Barani airbase in Egypt
Armoured Light Utility

Date Vehicles Trucks Vehicles 4 x 4 Totals Remarks
24 Apr 2020 0 0 0 0 ▪ Construction of a vehicle storage area is visible.
5 May 2020 0 1 19 20 ▪
7 May 2020 0 0 38 38 ▪
18 May 2020 0 3 84 87 ▪
30 May 2020 29 3 170 202 ▪
6 Jun 2020 16 19 283 318 ▪
7 Jun 2020 16 32 288 336 ▪
14 Jun 2020 16 24 200 247 ▪ 7 unidentified

18 Aug 2020 230 ▪
Figure 55.2 Figure 55.3

Sidi Barani airbase (24 Apr 2020) Sidi Barani airbase (5 May 2020)
__________________
62
https://twitter.com/Gerjon_/status/1261972421453787136, 17 May 2020 to 14 June 2020.
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Sidi Barani airbase (7 May 2020) Sidi Barani airbase (18 May 2020)

Sidi Barani airbase (30 May 2020) Sidi Barani airbase (6 Jun 2020)

Sidi Barani airbase (7 Jun 2020) Sidi Barani airbase (14 Jun 2020)
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Figure 55.10
Sidi Barani airbase (18 August 2020)
4. The Panel has identified the following aircraft (table 55.3 and figures 55.11 to 55.16), that
are directly controlled by HAF, and operating within HAF controlled territory of Libya. The Panel
considers that most of these, if not all, are almost certainly being used to ferry the materiel
delivered to Western Egyptian airfields into HAF controlled territory in Libya. They are certainly
being used to provide logistic support to HAF within Libya; both activities being in non-
compliance with paragraph 9 of resolution 1970 (2011).
Table 55.3
HAF controlled cargo aircraft
A/C # a Type Registered Operator Owner Remarks

5A-DRS IL-76 Deregistered by Libyan Arab Air Cargo b Government of ▪
Libya Libya
EY-332 AN-32B Deregistered by Sky Asia Lines c Sky Asia Lines ▪ Used to evacuate ChVK
Tajikistan Wagner staff from Bani
(20 Jun 2020) Walid.
▪ See appendix J.
ST-EWX IL-76 Sudan Green Flag Aviation d Green Flag ▪ Confirmed on 4 June
Aviation 2020.e
UP-AN601 AN-26 Deregistered by Space Cargo Inc f ▪ Sold to Space Cargo Inc
Kazakhstan on 22 Jun 2015.
(8 Oct 2015) ▪ False markings as H.A.D
Jet.
▪ Destroyed by GNA on 5
Apr 2020 at airstrip near
Tarhuna.g
UP-I7601 IL-76 Reported in S/2019/914, table 8, and annexes 28 and 52. ▪
UP-I7646 IL-76 Deregistered by Jenis Air LLC h Space Cargo Inc ▪ Confirmed operating
Kazakhstan from Benina since June
(2 Oct 2020) 2020.j
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A/C # a Type Registered Operator Owner Remarks

UP-I7651 IL-76 Deregistered by Azee Air LLC k Space Cargo Inc ▪ Last seen near Beida,
Kazakhstan Libya on 22 Mar 2020
(13 May 2020) after leaving Sharjah on
21 Mar 2020.
UP-I7652 IL-76 Kazakhstan Jenis Air LLC Jenis Air LLC ▪ Confirmed operating
from Benina since June
2020.
from Benina since Jun
2020.
ex EY-409 AN- Deregistered by HAF Allied Services ▪ Seen at Al Jufra on 25
12BP Tajikistan Limited l July 2020.
(11 Dec 2015) ▪ See appendix K.
UP-I1805 IL-18 Kazakhstan Jenis Air LLC Space Cargo Inc ▪ Seen at Al Jufra on 6 Jun
2020.n
▪ Ex-Jenis Air LLC
Unmarked IL-18 Unregistered p HAF ▪
a This is the registration number displayed on the aircraft. In many cases this is displayed illegally as the aircraft has been de-registered.
b Commercial Cargo Division of Libyan Arab Republic Air Force.
c No trace.
d http://www.greenflag-sdn.com. Web link inactive.
e https://twitter.com/Gerjon_/status/1268467153340174336, and https://twitter.com/HasairiOuais/status/1268466092265127937,
4 June 2020.
f
www.spacecargoinc.com. Saif Zone 125 M2, Warehouse A4-73, P.O. Box 7812, Sharjah, UAE. +971 65 570388, +971 65 724019,
+971 52 7888309. (s.ermolchev@spacecargoinc.com/ / maher@spacecargoinc.com).
g
https://aviation-safety.net/database/record.php?id=20200405-0. Accessed 25 September 2020.
h
No corporate web presence. Massif Aeroport, Ulitsa Aeroport 4/1, Taraz, Kazakhstan. +7 7073 222119.
(jenisair@mail.ru).
j
https://twitter.com/Gerjon_/status/1288512524023934976, 29 July 2020.
k.
www.azeeair.com. Office 303, Building 17, Naurizbay Batir SIRIUS (Business Centre), Almaty 050004, Kazakhstan.
+7 7273 469146. (gd@azeeair.com).
l
http://www.alliedservicesltd.com/. 1st Floor, Panorama Plaza, Airport Road, Juba, South Sudan. +211 920 880 880.
(marketing@alliedservicsltd.com).
m https://www.facebook.com/IrMa-Air-Service-2261018164215813/. +7 701 797 9879.
n https://twitter.com/Gerjon_/status/1287344519831265282, 26 July 2020.
p See annex 35 to S/2017/466 for details of unregistered aircraft operating in Libya. So possibly this is the Sky Prim Air ex-ER-ICS.
Also https://twitter.com/Gerjon_/status/1287815982350766085, 27 July 2020.
Figure 55.11 a Figure 55.12 b

IL-76 (5A-DRA) offloading on near Tarhuna (1 May AN-32 (EY-332) landing at Bani Walid (25 May 2020)
2020)
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Figure 55.13 c Figure 55.14 d

Stock image of IL-76TD (ex UP-I7651) AN-12BP (EY-409) at Al Jufra (25 July 2020)
Figure 55.15 e Figure 55.16 e

IL-18 at Al Jufra (6 June 2020) IL-18 (UP-I1805) at Al Jufra (26 July 2020)
a https://twitter.com/HasairiOuais/status/1256283060976443394/photo/1, 1 May 2020.

b Extract from https://www.youtube.com/watch?v=30H1-qXyvac, 25 May 2020.
c https://russianplanes.net/id218834. July 1987. Prior to transfer to Azee Air LLC.
d Confidential source.
e https://twitter.com/Gerjon_/status/1286994451609640961, 6 June 2020.
f https://twitter.com/HasairiOuais/status/1287356754255400963, 26 July 2020.
5. The Panel noted that most of the commercial operators in 2020 were UAE based, using
primarily Kazakhstan registered aircraft, as opposed to the primarily Ukrainian registered aircraft
used during 2019. On 30 July 2019, the Aviation Security Council of the Aviation Service of
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Ukraine issued instructions that banned flights by all Ukrainian registered aircraft from conducting
flights into Libya due to the ‘worsening security.
6. Since the suspension and revocation of air operator certificates (AOC) for Jenis Air LLC and
Sigma Airlines LLC, and the suspension of AOC for Azee Air LLC, by the Kazakhstan Civil
Aviation Administration the number of cargo aircraft commercially available for use on this route
has massively reduced. This has required the UAE to use their military C-17 Globemaster aircraft
to maintain their airbridge (see appendix B).
7. The 5+5 Joint Military Committee ceasefire agreement of 23 October 2020 63 provided
challenges to the Panel’s monitoring of the air bridges, as empty military cargo aircraft could
enter Libya to remove military equipment as required by the initial ceasefire agreement to
remove foreign fighters in 90 days, which was amended on 3 November 2020 to the withdrawal
of foreign forces from the contact lines.64 As such, they would have very similar profile
indicators to aircraft suspected of trafficking. Whilst the introduction of such military cargo
aircraft into Libya is a violation of the arms embargo, it would clearly be inappropriate of t he
Panel to report it as such if it were engaged in the removal of military equipment. It would of
course be helpful if the Member States involved informed the Committee in advance of such
flights to allow the Panel to deconflict them.
__________________
63
https://unsmil.unmissions.org/sites/default/files/ceasefire_agreement_between_libyan_parties_english.pdf,
23 October 2020.
64
https://www.libyaherald.com/2020/11/04/55-joint-military-commission-agrees-permanent-ceasefire-steps-at-
ghadames-meeting/, 4 November 2020.
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Appendix A to Annex 55: Russian Federation military aircraft in support of

HAF
1. The Panel has continued to monitor and analyse the quantity of military cargo flights by the
Russian Federation on the air line of communication (ALoC) from the Hmeymim military air base65
in Syria to Western Libya. The Panel has identified at least 505 flights by specific aircraft registration
number, equating to a maximum cargo delivery of 23,328 tonnes during 2020 (assuming a 48 tonne
cargo payload for an IL-76TD). Flights are summarised at table 55.A.1, figures 55.A.1 and 55.A.2.
One month’s flight details are shown at table 55.A.2 as an example of Panel data. The data is not
exhaustive as pre-departure flight plans are not usually filed directly with Eurocontrol66 for entry
into European airspace. Entry is usually activated by Cyprus air traffic control (ATC) Cyprus air
traffic control (ATC) using a ZZZZ code for departure airfield, or by the destination airfield.
Table 55.A.1
Summary of RFF military cargo flights to Libya (1 January – 31 December 2020)
Data set Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
# Flights 27 26 25 43 53 59 75 93 53 25 13 13
Maximum load (t) 1,296 1,136 976 2,064 2,512 2,768 3,416 4,488 2,376 1,208 504 584
2. The Panel has also identified 67 that although El Beida (HLLQ) is often declared on the
flight plan, aircraft subsequently leaving Libya have declared to air traffic control that they are
departing the Al Khadim military airbase (HL59). This can only be due to: 1) an internal flight
from Al Beida (HLLQ) to Al Khadim (HL59) before departing Libya; or 2) mis-declaration of
the original incoming flight destination by the aircraft.
3. The Panel has also identified that RFF IL-76 cargo aircraft, when allocated a flight level of
27,000’ (FL270) often request a lower flight level of 25,000’ (FL250) as the aircraft is flying
“heavy”. This indicates that the aircraft is flying with maximum cargo weights, as fuel is not an
issue in terms of its weight for the distance from Latakia to Libya (1,070 nautical miles).
__________________
65
Centred on 35°24'27.07"N, 35°57'8.00"E.
66
https://www.eurocontrol.int.
67
Voice recordings between RFF aircraft and Cyprus ATC. Available from Panel on request.
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Figure 55.A.1
Number of RFF military cargo flights to Libya (1 January – 31 December 2020)
Figure 55.A.2
Maximum potential cargo (tonnes) for RFF military cargo flights to Libya (1 January – 31 December 2020)
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4. The Panel has identified the confirmed flights shown in table 55.A.1 of Russian Federation
military cargo aircraft into Libya during an example month of August 2020. The Panel has data
for all flights made in 2020 available on request.
Table 55.A.1
Example of suspicious flights from Syria by Russian Federation military aircraft (August 2020 taken as example
month)
Maximum
# Date Aircraft # Type From To Flight # load (t)
1 1 Aug 2020 RA-76745 IL-76 Latika, Syria a Al Abraq (Bayda) b RFF8055 48
2 1 Aug 2020 RA-76771 IL-76 OSLK HLQQ RFF8059 48
3 1 Aug 2020 RA-09341 AN-22 OSLK HLQQ RFF8671 48
11 4 Aug 2020 RA-65996 T134 OSLK HLQQ RFF8061 8
28 8 Aug 2020 RA-78791 AN-22 OSLK HLQQ RFF8053 80
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Maximum
77 23 Aug 2020 IL-76 OSLK HLQQ RFF8053 48
78 23 Aug 2020 IL-76 OSLK HLQQ RFF8051 48
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Maximum
a
Latika. Joint Airbase (Hmeyminn). 35°24'27.07"N, 35°57'8.00"E.
b Al Abraq (Bayda). Joint Airbase. 32° 47' 19" N, 21° 57' 51.48" E
5. Figure 55.A.3 shows Al Khadim airbase (HL59) 68 on 24 December 2020. The imagery
clearly shows three Ilyushin IL-76 and one Tupolev TU-154 aircraft. Flight data confirms that
the Tupolev TU-154M aircraft is from the Russian Federation Ministry of Defence 223 rd Flight
Detachment and is registered as RA-85042 (Flight#: RFF8062). One of the IL-76 is almost
certainly flight# RFF8040 of the Russian Federation air force.
Figure 55.A.3
Russian Federation military aircraft at AL Khadim military airbase (eastern Libya) (24 December 2020)
__________________
68
31° 59' 55" N, 21° 11' 30" E.
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6. As these are military aircraft, their landings at Libyan airports means that the Russian
Federation has violated paragraph 9 of resolution 1970 (2011) regardless of whether or not their
military cargo aircraft transferred arms or military equipment to Libya.
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Appendix B to Annex 55: UAE military aircraft in support of HAF

1. In two earlier updates to the Committee dated 28 January 2020 and 1 May 2020 regarding air
transfers of arms, the Panel informed the Committee of a developing trend of suspicious flights from
the United Arab Emirates to Western Egyptian and Eastern Libyan airfields. The Panel continued to
monitor and investigate the issue and has now identified what is almost certainly the planned
“airbridge” components of a supply chain from the United Arab Emirates to HAF. In this case the
term “airbridge” is defined as the route and means of delivering primarily military materiel from one
place to another along a supply chain by airlift. The transfer of military materiel by an airbridge
would be a non-compliance with paragraph 9 of resolution 1970 (2011).
2. The flights are deemed suspicious by the Panel as: 1) signals from the aircraft ADS-B69
transponders are not visible on open-source ADS-B monitoring70 shortly after entering Egyptian
airspace; 2) the number of unscheduled flights on a previously little used route; 3) the flights are
often from military air bases; and 4) there have been no responses to the Panel’s request for
information from the UAE.
3. The Panel finds that these flights form an Air Line of Communication (ALOC) either directly
into Eastern Libya or to link with a land Main Supply Route (MSR) from Western Egypt into
Eastern Libya.
Table 55.B.1
UAE military aircraft of interest to the Panel
A/C # A/C type Hex Code Unit Remarks

1223 C-17A 896C2B Air Command
1225 C-17A 896C2D Air Command
1226 C-17A 896C2E Air Command
1227 C-17A 896C2F Air Command
1229 C-17A 896C3E Air Command
1230 C-17A 896C40 Air Command
1230 C-17A 896C40 Air Command
Table 55.B.2
Suspicious flights from UAE by UAE military aircraft
# Date A/C # A/C type From a Cargo for / via Remarks

b
1 23 Dec 2019 C-17A UAE Sidi Barani ▪ IMINT Sentinel-2
c
2 3 Jan 2020 1227 C-17A UAE Benghazi ▪
__________________
69
Automatic Dependent Surveillance - Broadcast. This is a surveillance technology whereby an aircraft determines its
position from satellites and then automatically broadcasts it, enabling the aircraft to be tracked without an interrogation
signal from the ground.
70
For example: 1) www.flightradar24.com; or 2) www.opensky-network.org; 3) www.adsbexchange.com; 4)
www.adsbhub.org; and 5) www.uk-flightaware.com.
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c
3 27 Feb 2020 1226 C-17A UAE Benghazi ▪
4 2 Mar 2020 C-17A UAE HE40 ▪ IMINT Sentinel-2

5 10 Mar 2020 1226 C-17A HLLB ▪
d
6 11 Mar 2020 1227 C-17A Qusahira Libya ▪
e
7 25 Mar 2020 1226 C-17A Abu Dhabi HLLB ▪
8 26 Mar 2020 C-17A Al Dhafra f Libya ▪
9 1 Apr 2020 1226 C-17A OMAA HLLB ▪
10 2 Apr 2020 C-17A UAE HE40 ▪ IMINT Sentinel-2

11 17 Apr 2020 1225 C-17A ▪
12 18 Apr 2020 1223 C-17A ▪
13 18 Apr 2020 1225 C-17A ▪
14 18 Apr 2020 1227 C-17A ▪
15 19 Apr 2020 1223 C-17A ▪
16 19 Apr 2020 1225 C-17A ▪
17 21 Apr 2020 1227 C-17A ▪
18 22 Apr 2020 1225 C-17A ▪
19 22 Apr 2020 1230 C-17A ▪
20 23 Apr 2020 1223 C-17A OMAM ▪
21 23 Apr 2020 1225 C-17A ▪
22 23 Apr 2020 1227 C-17A ▪
23 24 Apr 2020 1229 C-17A ▪
24 24 Apr 2020 1230 C-17A ▪
25 25 Apr 2020 1223 C-17A ▪
26 25 Apr 2020 1227 C-17A ▪
27 26 Apr 2020 1225 C-17A ▪
28 26 Apr 2020 1230 C-17A ▪
29 27 Apr 2020 1225 C-17A ▪
30 29 Apr 2020 1226 C-17A ▪
31 30 Apr 2020 1225 C-17A ▪
32 30 Apr 2020 1227 C-17A ▪
33 1 May 2020 1227 C-17A ▪
34 1 May 2020 1230 C-17A ▪
35 3 May 2020 1225 C-17A ▪
36 4 May 2020 1230 C-17A ▪
37 5 May 2020 1225 C-17A ▪
38 5 May 2020 1226 C-17A ▪
39 6 May 2020 1225 C-17A ▪
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40 6 May 2020 1226 C-17A ▪
41 6 May 2020 1230 C-17A ▪
42 7 May 2020 1225 C-17A ▪
43 7 May 2020 1226 C-17A ▪
44 7 May 2020 1230 C-17A ▪
45 8 May 2020 1225 C-17A ▪
46 9 May 2020 1225 C-17A ▪
47 10 May 2020 1223 C-17A ▪
48 10 May 2020 1230 C-17A ▪
49 11 May 2020 1227 C-17A ▪
50 13 May 2020 1227 C-17A ▪
51 13 May 2020 1230 C-17A ▪
52 14 May 2020 1230 C-17A ▪
53 17 May 2020 1230 C-17A ▪
54 18 May 2020 1225 C-17A ▪
55 21 May 2020 1225 C-17A ▪
56 23 May 2020 1227 C-17A ▪
57 24 May 2020 1225 C-17A ▪
58 26 May 2020 1223 C-17A Qusahira Libya ▪
59 26 May 2020 1225 C-17A Qusahira Libya ▪
60 28 May 2020 1223 C-17A OMAA Libya ▪
61 28 May 2020 1227 C-17A OMAA Libya ▪
62 28 May 2020 1230 C-17A OMAA Libya ▪
63 2 Jul 2020 1226 C17A UAE HE40 ▪
64 3 Jul 2020 1226 C17A UAE HE40 ▪
65 17 Jul 2020 1230 C-17A Assab HE40 ▪
a Best estimate based on ASD-B data. Certainly from a UAE airport.

b HE40. Joint Airport. 31°27'59"N, 25°52'41"E.
c HLLB. Civilian Airport. 32°05'48"N, 20°16'10"E.
d Military Airbase. 22°46'27.35"N, 55° 3'47.61"E
e OMAA Civilian Airport. 24°25'59"N, 54°39'04"E.
f OMAM. Military Airbase. 24°14'54"N, 54°32'52"E.
Table 55.B.3
Suspicious flights from Eritrea by UAE military aircraft
# Date A/C # A/C type From Cargo for / via Remarks

1 26 Mar 2020 896C2B C-17A Assab a Libya ▪ #UAF1229
a HSSB. Military Airbase. 13°04'18"N, 42°38'42"E
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4. As these are military aircraft their landings at Libyan airports means that the United Arab
Emirates has violated paragraph 9 of resolution 1970 (2011) regardless of whether or not their
military cargo aircraft transferred arms or military equipment to Libya.
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Appendix C to Annex 55: Sigma Airlines in support of HAF

1. Two aircraft (UP-I7601 and UP-I7645) operated by Sigma Airlines LLC and owned by Space
Cargo Incorporated (www.spacecargoinc.com)71 of the United Arab Emirates, were found non-
compliant with paragraph 9 to resolution 1970 (2011). in Panel report S/2019/914. The Sigma
Airlines business model and corporate relationships is complex and still under investigation by the
Panel, see infographic at figure 55.C.1. The Panel notes companies such as Reem Style Travel and
Leisure LLC that appear as companies of interest in other Panel investigations.
Figure 55.C.1
Sigma Airlines business relationships
2. The Panel has examined the flight journey logs and cargo manifests for 37 flights made by
Sigma Airlines Ilyushin IL-76TD cargo aircraft (UP-I7601 and UP-I7645) from either Egypt and
Jordan (see tables 55.C.1 and 55.C.2). The cargo manifests were considered highly suspicious by the
Panel as: 1) none had names, signatures or stamps; 2) the lack of specific detail as to the cargo; 3)
no details as to the consignee(s); and 4) some had been completed by the 4th Aviation Group of the
__________________
71
PO Box 7812, Sharjah Airport International Free Zone, A4-073, Sharjah, UAE. +971 6 557 0388.
maher@spacecargoinc.com.
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UAE Armed Forces.72 At least 65% of the aircraft flights were at less than 50% capacity, which is
unusual for routine chartered flights where payload efficiency is usually strived for. The Panel was
unconvinced of the veracity and accuracy of the flight documentation provided by Sigma Airlines.
3. The Panel also noticed at least 26 internal flights by aircraft UP-I7655 providing logistic
support to HAF. This activity by Sigma Airlines is also a non-compliance with paragraph 9 of
resolution 1970 (2011). for the provision of other assistance relating to military activities.
4. On 29 May 2020 the Civil Aviation Administration of Kazakhstan suspended the Air
Operators Certificate AOC) for Sigma Airlines LLP for a period of six months . The suspension
was based on multiple sources identifying that Sigma Airlines LLP had violated “paragraph 6 of
Security Council Resolution 1973 (2011)” of their air operators certificate and “four violations
of the most critical Level One were identified that pose an immediate threat to flight safety and
aviation security”.
Table 55.C.1
Sigma Airlines suspicious flights by IL-76TD (UP-I7601) to Libya (2019)
Date Flight# From Destination Declared cargo Cargo (kg) Remarks
4 Mar 19 SGL9601 Amman Al Abraq Tower Crane Parts 33,400 ▪

(OJAM) a (HLLQ) b
11 Mar 19 SGL9603 OJAM HLLQ Tower Crane Parts 28,000 ▪
5 Apr 19 SGL9601 Aqaba Benghazi Vehicles x 5 12,800 ▪

(OJAQ) c (HLLB) d
7 Apr 19 SGL9601 OJAQ HLLB Vehicles x 4 19,350 ▪
8 Apr 19 SGL9603 OJAQ HLLQ Vehicles x 5 18,020 ▪
9 Apr 19 SGL9603 OJAQ HLLB Vehicles x 4 16,000 ▪
16 Apr 19 SGL9603 OJAM HLLB Communication Spare 7,000 ▪

Parts
21 Apr 19 SGL9603 OJAM HLLB Communication Spare 29,000 ▪
Parts
24 Apr 19 SGL9603 OJAM HLLB Vehicles x 3 41,000 ▪
2 May 19 SGL9603 OJAQ HLLB Vehicles x 3 10,640 ▪ Noor Alhyat

Company listed as
Operator.
6 May 19 SGL9603 OJAQ HLLB Vehicles x 8 15,600 ▪
15 May 19 SGL9603 OJAM HLLB Communication Spare 13,000 ▪

Parts
19 May 19 SGL9603 OJAM HLLB Vehicles x 2 40,000 ▪ Each vehicle = 20T?
Parts
Parts
__________________
72
For example Flight SGL9511 from Sweihan airbase, UAE on 26 August 2019.
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Parts
2 Jun 19 SGL9603 OJAM HLLB Communication Spare 40,000 ▪
Parts
11 Jun 19 SGL9603 OJAQ HLLB Communication Spare 3,000 ▪
Parts
Parts
15 Jun 19 SGL9603 Cairo HLLB Communication Spare 7,000 ▪
(HECA) e Parts
Parts
Parts
19 Jun 19 SGL9604 Abeche HLLB Communication Spare 15,000 ▪ Cargo manifest not
(FTTC) f Parts submitted.
23 Jun 19 SGL9603 OJAM HLLB Trolley, Conditions, 15,000 ▪
General Cargo
2 Jul 19 SGL9603 OJAQ HLLB Vehicles (x4) 13,400 ▪ Cargo manifests
states HLLQ for
unloading.
4 Jul 19 SGL9603 HECA HLLB Communication Spare 18,000 ▪
Parts
12 Jul 19 SGL9603 OJAM HLLB Communication Spare 29,000 ▪
Parts
14 Jul 19 SGL9603 Alexandri HLLB Communication Spare 20,000 ▪
a (HEBA) Parts
g
15 Jul 19 SGL9603 HEBA HLLB Communication Spare 35,000 ▪

Parts
Parts
Parts
27 Jul 19 SGL9603 OJAQ HLLB Vehicles (x4) 12,000 ▪
10 Aug 19 SGL9603 OJAM HLLB Communication Spare 14,000 ▪

Parts
Parts
Parts
27 Aug 19 SGL9603 OJAQ HLLQ Vehicles (x4) 12,000 ▪
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4 Sep 19 SGL9604 HEBA HLLB Communication Spare 35,000 ▪ Eastbound flight
Parts number
6 Sep 19 SGL9603 HEBA HLLB Communication Spare 35,000 ▪
Parts
a OJAM = Amman, Jordan

b HLLQ = Al Abraq, Libya
c OJAQ = Aqaba, Jordan
d HLLB = Benghazi (Benina International Airport)
e HECA = Cairo, Egypt
f FTTC = Abeche, Chad
g HEBA = Alexandria (Borg El Arab), Egypt
Table 55.C.2
Sigma Airlines suspicious flights by IL-76TD (UP-I7645) to Libya (2019)
20 Jan 19 SGL9602 Abraq Benghazi Frozen Food 20,000 ▪ Internal support to

(HLLQ) a (HLLB) b HAF
20 Jan 19 SGL9602 HLLB HLLQ NO MANIFEST NIL ▪ Internal support to
HAF
4 Feb 19 SGL9601 Sharjah HLLQ Men’s Suit, Belt, 27,134 ▪ Panel assesses as
(OMSJ) c Hat, Boots Military Uniforms
18 Feb 19 SGL9601 HLLQ HLLB Toyota Hilux x 3 19,500 ▪ Internal support to
(7,5000kg) HAF
Food x 10 Pallets
(12,000kg)
18 Feb 19 SGL9601 HLLB HLLQ NO MANIFEST NIL ▪ Internal support to
HAF
03 Mar 19 SGL9601 HLLQ HLLB Truck Wheels x 250 20,000 ▪ Internal support to
(6250kg) HAF
Generator x 1
(13,750kg)
03 Mar 19 SGL9602 HLLB HLLQ NO MANIFEST NIL ▪ Internal support to
HAF
27 Mar 19 SGL9601 Aqaba HLLB Vehicles x 3 12,000 ▪
(OJAQ) d
27 Mar 19 SGL9601 HLLB Sabha NO MANIFEST 12,000 ▪ Internal support to
(HLLS) e HAF
27 Mar 19 SGL9601 HLLS HLLB Containers x 2 10,000 ▪ Internal support to
HAF
28 Mar 19 SGL9602 HLLB HLLM NO MANIFEST 35,000 ▪ Internal support to
HAF
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28 Mar 19 SGL9601 HLLM HLLB Tarpaulin Fabric 24,000 ▪ Internal support to
HAF
29 Mar 19 SGL9602 HLLB HLLS NO MANIFEST 25,000 ▪ Internal support to
HAF
29 Mar 19 SGL9601 HLLS HLLB Medical Equipment 10,000 ▪ Internal support to
HAF
31 Mar 19 SGL9602 HLLB HLLM Tower Crane Parts 20,000 ▪ Internal support to
HAF
31 Mar 19 SGL9601 HLLM HLLB 3 x Containers 20,000 ▪ Internal support to
HAF
1 Apr 19 SGL9602 HLLB HLLS Furniture 20,000 ▪ Internal support to
HAF
1 Apr 19 SGL9602 HLLS HLLB Container x 2 10,000 ▪ Internal support to
HAF
2 Apr 19 SGL9602 HLLB HLLS Oil Equipment 20,000 ▪ Internal support to
HAF
HAF
3 Apr 19 SGL9602 HLLB HLLS Fabrication 18,000 ▪ Internal support to
Equipment HAF
3 Apr 19 SGL9602 HLLS HLLB Medical Equipment 9,200 ▪ Internal support to
HAF
4 Apr 19 SGL9602 HLLS HLLB Water Heaters x 100 35,000 ▪ Internal support to
HAF
HAF
4 Apr 19 SGL9602 HLLB HLLS Water Heaters x 100 35,000 ▪ Internal support to
HAF
HAF
4 Apr 19 SGL9602 HLLB HLSS Boilers x 800 37,000 ▪ Internal support to
HAF
4 Apr 19 SGL9601 HLSS HLLB 24,000 ▪ Internal support to
HAF
10 Apr 19 SGL9602 Amman HLLQ Fabric – Tarpaulin 10,000 ▪ Military tentage.
(OJAM) f
11 Apr 19 SGL9602 OJAM HLLQ Equipment and 2 x 20,000 ▪
Container
16 Apr 19 SGL9601 Al HLLQ Cars x 3 15,126 ▪
Maktoum
(OMDW) g
5 May 19 SGL9601 OJAM HLLQ Oil Equipment 36,000 ▪ Possible legitimate
7 May 19 SGL9601 OJAM HLLQ Container x 3 30,000 ▪
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11 May 19 SGL9601 OJAQ HLLQ Vehicles x 8 15,600 ▪
5 Jul 19 SGL9606 OJAQ HLLQ No Cargo Declared ▪
12 Jul 19 SGL9601 OJAQ HLLQ Building Equipment 30,000 ▪
10 Aug 19 SGL9811 OJAQ HLLQ Vehicles x 4 12,000 ▪
23 Aug 19 SGL9511 Sweihan HE40 j Toyota Land 10,956 ▪ Then to HLLB

(OMAW) h Cruiser x 4 ▪ UAE Armed Forces
Load Manifest
26 Aug 19 SGL9511 OMAW HE40 Toyota Land 10,956 ▪ Then to HLLB
Cruiser x 4 ▪ UAE Armed Forces
Load Manifest
a HLLQ = Al Abraq, Libya

b HLLB = Benghazi (Benina International Airport)
c OMSJ = Sharjah, UAE
d OJAQ = Aqaba, Jordan
e HLLS = Sabha, Libya
f OJAM = Amman, Jordan
g OMDW = Al Maktoum Dubai
h OMAW = Sweihan Military Airbase, UAE
j HE40 = Sidi Barani Military Airbase, Egypt
5. The Panel thus finds that this flight activity by Sigma Airlines LLC is a violation of
paragraph 9 of resolution 1970 (2011) for the direct, and indirect, supply of (…) military (…)
equipment and (…) other assistance (…) to Libya.
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Appendix D to Annex 55: Azee Air LLC in support of HAF

1. Azee Air LLC was founded on 8 September 2017, but only started commercial activities in
June 2019. The company operated four Ilyushin IL-76 TD73 on the airbridges to Libya during the
first half of 2020. These aircraft have made at least 100 airbridge flights that meet the majority of
the Panel’s profile indicators at Annex 75. These flights equate to a maximum potential cargo
delivery of 5,000 tonnes (see later). Analysis of flight documentation provides further evidence of
the clandestine nature of the nine flights for which Azee Air LLC provided documentation.
2. On 24 January 2020, the ADS-B data for all Azee Air LLC operated aircraft went totally
blank on the FlightRadar24 AB (www.flightradar24.com) web platform. On 16 April 2020
FlightRadar24 AB confirmed to the Panel that on 17 January 2020 Azee Air LLC had requested
the “blocking” service for their aircraft. Azee claimed that this was done for “commercial reasons”
to “maintain its competitive advantage”.74 The Panel considers this a highly unusual action by a
freight operator, who would normally want clients to know routes to attract extra business, fill up
spare cargo space and thus maximise company profit. The Panel considers that Azee Air LLC was
really using the commercial “blocking” services of FlightRadar24 AB to disguise or conceal flights
being made to transfer military equipment in non-compliance with the arms embargo.75
Notwithstanding this, access to ADS-B data and analysis from other providers enabled the Panel
to maintain an overwatch of departures from the United Arab Emirates on similar tracks towards
Libya as before (see figure 55.D.1 as an example).
3. Among the AOCs Azee Air LLC provided to FlightRadar24 AB as justification for the
“blocking” services was one for IL-76TD aircraft registered UP-I7652. The Panel noted that Azee
Air LLC is not known to own or operate this aircraft, which the Panel has confirmed is operated
by Jenis Air LLC. On 21 April 2020 the Aviation Administration of Kazakhstan confirmed to the
Panel that the “AOC” supplied by Azee Air LLC was a forgery, which they are now investigating.
__________________
73
Aviation Administration of Kazakhstan registered as UP-I7646, UP-I7650, UP-I7651 and UP-I7654. On 18 February
2020 UP-I7646 was purportedly transferred to Jenis Air LLC as the operator but continued to operate using Azee Air
LLC flight numbers and call signs.
74
Letter from Kulowiec, Jorquera and Whalen LLP dated 20 November 2020.
75
Azee Air LLC aircraft also do not appear on similar ADS-B open source data platforms such as for example: 1)
www.flightradar24.com; or 2) www.opensky-network.org; 3) www.adsbexchange.com; 4) www.adsbhub.org; and 5)
www.uk-flightaware.com. Panel check of 23 April 2020.
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Figure 55.D.1
ADS-B track of IL-76TD (UP-I7650) on 26 January 202076
a Red circle indicates ADS-B disabled by aircraft when in Egyptian air space on track to Libya.
b Yellow rectangle indicates route over Saudi desert where no ADS-B ground stations are present to detect signal.
4. Azee Air LLC operated four IL-76TD aircraft during the reporting period. Tables 55.D,1 to
55.D.477 summarises the Panel’s evidence relating to each Azee Air LLC owned and/or operated
aircraft.
Table 55.D.1
IL-76TD (UP-I7646) (Operated)
Date Activity Panel Evidence
23 Dec 2019 Registered by Kazakhstan. ▪ Certificate of Registration No.1186.

▪ Operated by Azee Air LLC.
17 Jan 2020 Flight data blocked from public view on ▪ FR24 documentation.
www.flightradar24.com platform. ▪ NOTE blocked before transfer to Jenis Air LLC
operations at Jenis Air LLC request. Azee Air LLC and
Space Cargo Inc a also blocked their aircraft on same date.
26 Jan 2020 Sold to Space Cargo Inc (UAE) by Aganya ▪ Bill of Sale No. 80505-01-2020.
Limited (UAE) b ▪ Documents signed 1 Feb 2020.
__________________
76
Data analysis provided to Panel by www.c4ads.org. The Panel has similar flight tracks for a further fifteen flights as
part of this analysis.
77
All the documentation referred to in tables 55.1 to 55.4 is available from the Panel on request. Selected
documentation has been included in the annexes to illustrate the evidential levels.
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26 Jan 2020 Dry leased to Jenis Air LLC by Space Cargo ▪ Dry Lease No 26/01/20.
Inc. ▪ The aircraft still flew under Azee Air LLC callsign and
flight identifiers until at least 01 April 2020.
06 Feb 2020 First identified flying on UAE - Libya ▪
airbridge to start operating in support of HAF. ▪
19 Feb 2020 Registered by Kazakhstan on change of ▪ Certificate of Registration No.1186.

ownership.
14 Apr 2020 Identified flying into Libya to start operating ▪ C4ADS research and www.aerotransport.org, updated 16
in support of HAF. May 2020.
21 Apr 2020 Azee Air LLC Air Operating Certificate ▪ Until 20 October 2020.
Suspended
15 Jun 2020 Cancellation of Registration ▪ Certificate of Cancellation No.301.
2 Oct 2020 Reported as been returned to Space Cargo ▪ http://www.aerotransport.org/.
Inc from HAF.
a www.spacecargoinc.com. Saif Zone 125 M2, Warehouse A4-73, P.O. Box 7812, Sharjah, UAE. +971 65 570388,
+971 65 724019, +971 52 7888309. (s.ermolchev@spacecargoinc.com/ / maher@spacecargoinc.com). Please note that
a separate Statement of Case against Space Cargo Inc relating to similar arms embargo violations was submitted to the
Committee on 24 December 2020.
b No web trace. PO Box 123005, RAK Offshore, Government of Ras Al Khaimah, UAE.
Table 55.D.2
IL-76TD (UP-I7650) (Owned)

9 Jul 2018 Registered by Kazakhstan. ▪ Certificate of Registration No.1145.
14 Jan 2020 First identified flying on UAE - Libya airbridge ▪
to start operating in support of HAF.
17 Jan 2020 Flight data request to block from public view on ▪ FR24 documentation.
www.flightradar24.com platform at Azee Air
LLC request.
24 Jan 2020 Azee Air LLC aircraft blocked from public view ▪ Intended to disguise clandestine flights into Libya.
on FR24 platform.
Suspended
4 May 2020 Dry leased to FlySky Airlines (FSQ), a Kyrgyz ▪ Dry Lease No 04/05/20
Republic
9 Jun 2020 Registered by Kyrgyz Republic as EX-76003 ▪ Member State letter.
15 Jun 2020 Cancellation of Registration by Kazakhstan ▪ Certificate of Cancellation No. 301
awww.flysky.kg. Office 6, Building 82A, Ch Altmatove Boulevard, Bishkek 720044, Kyrgyz Republic. +966 312
979300. (info@flysky.kg).
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Table 3
IL-76TD (ex-UP-I7651) (Operated)

▪ Operated by Azee Air LLC
14 Jan 2020 First identified flying on UAE - Libya airbridge ▪
17 Jan 2020 Flight data request to block from public view on ▪ FR24 documentation.
www.flightradar24.com platform at Azee Air
LLC request.
24 Jan 2020 Azee Air LLC aircraft blocked from public ▪ Intended to disguise clandestine flights into Libya.
view on FR24 platform.
10 Mar 2020 Sold to Space Cargo Inc (UAE) by Infinite Seal ▪ Bill of Sale No. 6002-03-2020.
Inc (BVI) a ▪ Document signed 19 March 2020.
10 Mar 2020 Space Cargo Inc claimed to have sold to Eagle ▪ Eagle Enterprise deny all knowledge of this sale and
Enterprise Company Limited, South Sudan. are categorical that all documentation is fake. The
Sale Agreement EEC-SCI-009-01-20 provided. Panel is convinced the documentation is fake and
finds that Space Cargo Inc supplied fake
documentation to the Panel.
19 Mar 2020 Identified as flown into Libya and started ▪ https://twitter.com/Gerjon_/status/12845453251606
operating in support of HAF. 93766, 18 July 2020. Confirmed by C4ADS research
and http://www.aerotransport.org/, updated 16 May
2020. Last ADS-B contact on 19 March 2020 at 06:50
hours with aircraft heading on common track to
Libya.
▪ Operated by Azee Air LLC (but Space Cargo stated
operated by Jenis Air LLC).
21 Mar 2020 Reported as being operated by HAF in Libya. ▪ www.aerotransport.org.
Suspended
13 May 2020 De-registered by Kazakhstan. ▪ Certificate of Cancellation No.299.
a
No corporate web presence. As at 27 April 2015. BVI Company # 1784025.
Table 4
IL-76TD (UP-I7654) (Operated)

10 Apr 2019 Registered by Kazakhstan. ▪ Certificate of Registration No.1172.
17 Jan 2020 Flight data request to block from public view ▪ FR24 documentation.
on www.flightradar24.com platform at Azee Air
LLC request.
24 Jan 2020 Azee Air LLC aircraft blocked from public ▪ Intended to disguise clandestine flights into Libya.
view on FR24 platform.
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17 Feb 2020 First identified flying on UAE - Libya airbridge ▪
Suspended
28 Apr 2020 Dry leased to FlySky Airlines, Kyrgyz Republic ▪ Dry Lease No 28/04/20
9 July 2020 Registered by Kyrgyz Republic as EX-76003 ▪ Member State letter.
14 Jul 2020 Cancellation of Registration by Kazakhstan ▪ Certificate of Cancellation No. 302
5. The Azee Air LLC business model and corporate relationships are complex and still under
investigation by the Panel, see infographic at figure 55.D.2. The Panel notes companies such as
Space Cargo Incorporated (UAE) and Infinite Seal Limited (BVI) appear as companies of interest
in other investigations. Linked companies include Azee Aviation TOO (Kazakhstan),78 who own
the Boeing 747 (UP-B4701) operated by Azee Air LLC, and Azee Aviation FZE (UAE).79
Figure 55.D.2
Azee Air LLC relationships
__________________
78
35, kv.341, Boulevard Bukhar Zhyrau, Almaty, Kazkahstan.
79
Q4-075, PO Box 124005, SAIF Zone, Sharjah, UAE. +971 6 552 6263. info@azee.aero.
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6. The Panel has also identified that on 5 October 2020 the Director of the company was
changed to Natalya SHUMKINA, and a fourth address for the company was reported.80
7. On 21 April 2020, the Aviation Administration of Kazakhstan suspended the Air Operators
Certificate (AOC) for Azee Air LLC for a period of six months.81 The suspension was based on
multiple sources identifying that Azee Air had not complied with “the certification requirements
provided by the operational requirements and restrictions of the AOC (…)”.
8. The Panel noted that a General Sales Agency Agreement (GSA) dated 1 May 2019 was in
place between Deek Aviation FZE and Azee Air LLC. The Panel finds that this agreement does
not absolve Azee Aviation LLC from any illicit activity in terms of sanctions violations committed
by the aircraft that they own and/or operate. This finding is based on the following articles within
the GSA, and due diligence responsibilities:
(a) GSA Article 6 (viii). Assist the Principal to ensure all cargo does not include (a)
hazardous materials, (b) any materials which Principal is prohibited from transporting
pursuant to the Regulations or (c) any materials prohibited by the Contract of Carriage;
(b) GSA Article 12. The Principal will be responsible for the physical and technical
operation of the Aircraft and the safe performance of all Charter Flights and will retain
full authority and control including General operational control and possession of the
Aircraft at all times. The captain of the Aircraft82 and the flight dispatcher will have
absolute discretion in all matters concerning the preparation of the Aircraft for flight and
the flight itself, the load carried and its distribution, the decision whether or not a Charter
Flight will be undertaken, the route to be flown, the place where landings will be made,
and all other matters relating to the safety in the operation of the Aircraft; and
(c) Deek Aviation were named as violating paragraph 9 of resolution 1970 (2011) in Panel
report S/2019/914.83 Azee Air LLC due diligence should have identified the involvement
of Deek Aviation FZE regarding recent sanctions violation activities in Libya.
Opportunity to respond
9. The Panel requested clarification as to the nature of the flights and details of the cargo from
the Member State with copies to the airline; no response was received from the airline.84
Consequently neither the charterer nor cargo agent for many of the flights can yet be identified. The
airline also failed to provide the information to the Civil Aviation Administration of Kazakhstan
__________________
80
Apartment 4, Zavodskaya Streer 92, Karasu Microdistrict, Alatau Area, Almaty, 050000 Kazakhstan.
81
CAA Kazakhstan Order No.121.
82
In effect, the Captain of the aircraft, as a senior Azee Air LLC employee should have ensured that the aircraft did
not carry materiel, nor fly routes, that violated the UN arms embargo on Libya..
83
Annexes 28 and 53. Deek Aviation FZE were named alongside Infinite Seal Inc (BVI) (see above figure 3). Deek
Aviation LLC failed to respond to the Panel’s request for information in connection with this case.
84
Panel letters of 24 and 27 March 2020.
240/548 21-01654
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(www.caakz.com) on request.85 Their only communication with the Panel was a letter sent on
17 April 2020 from a specialist aviation lawyer in the USA. The Panel submitted an appropriate
explanatory response to the lawyer on 23 April 2020, which the lawyer immediately responded to
on 24 April 2020 stating that Azee Air were “working in earnest to provide the Panel with (…) data
in an organised manner”. The Panel’s multiple requests for copies of contracts, cargo manifests and
air waybills, which should always be readily available to an airline, were not acceded to.
10. The Panel received a second communication from the lawyer on 5 October 2020 to which the
Panel responded on 13 October 2020 explaining the investigative methodology followed by the
Panel. In this letter the lawyer stated that ADS-B does not allow for pilots to activate or deactivate
elements of its functionality and that remote regions such as North Africa and Libya do not afford
ubiquitous surveillance due to lack of ADS-B ground stations. Technical advice from the Kazakhstan
CAA, verified by an independent technical source, rebuts this claim: ADS-B is like all transponders
not hot wired into aircraft electrical systems and signals are now processed by space-based tracking
systems86 as well as ground equipment. In particular Ilyushin aircraft have the ability to stop flight
telemetry data from being broadcast. Crews have to activate the transponders as before with 4,096
type units. The space-based telemetry tracking means that areas of no ground-based tracking stations
are no longer an issue to obtain data where necessary to do so. The lawyer wrote to the Panel again
on 16 December 2020 and 7 January 2021 requesting that the Panel send a “clearance letter” to the
Civil Aviation Authority of Kazakhstan. The Panel responded on 12 January 2021 stating that this
would not be appropriate as the Panel reports to the Sanctions Committee, and that the Panel’s
findings in regard to its investigation to date relating to his clients will be submitted as part of the
Panel’s mandate under paragraph 12 of Security Council resolution 2509 (2020) to produce a final
report of its findings and recommendations to the Security Council by 15 March 2021.
Flight analysis
11. The Azee Air LLC flights are deemed suspicious by the Panel as: 1) signals from the aircraft
ADS-B transponders are not visible on open-source ADS-B monitoring87 shortly after entering
Egyptian airspace; 2) the number of unscheduled flights on a previously little used route; 3) some
flights are from a joint military air base known to be a UAE Armed Forces logistic hub; 4) the lack
of detail on the limited flight documentation supplied by Azee Air LLC and seen by the Panel; and
5) the use of Azee Air LLC callsigns by UP-I7646 after the aircraft was dry leased to Jenis Air LLC.
__________________
85
Panel discussions with the Aviation Administration of Kazakhstan on 20 – 22 April 2020.
86
For example: https://aireon.com.
87
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Table 55.D.5
Suspicious flights by Azee Air LLC operated aircraft
Kazakhstan
# Date A/C # A/C type From Cargo for Remarks
1 14 Jan 2020 UP-I7650 IL-76TD UAE Libya ▪
a b
2 14 Jan 2020 UP-I7651 IL-76TD Abu Dhabi Benghazi ▪
17 Jan 2020 Azee Air LLC requested FR24 platform blank Azee Air LLC flights from public view
7 17 Jan 2020 UP-I7650 IL-76TD UAE HLLB ▪ IMINT of IL-76TD @ HLLB on
18 Jan 2020.
9 20 Jan 2020 UP-I7650 IL-76TD UAE HLLB ▪ AZL1538

▪ Cargo of 3 vehicles consigned to 4th
Aviation Group, UAE Armed Forces.
▪ Manifest claimed Alexandria, Egypt
(HEBA) as destination.
10 20 Jan 2020 UP-I7651 IL-76TD Libya Libya ▪ Initial flight into Libya not identified.
24 Jan 2020 FR24 platform blanks Azee Air LLC flights from public view
26 Jan 2020 Space Cargo Inc dry-lease UP-I7646 to Jenis Air LLC ▪
24 27 Jan 2020 UP-I7650 IL-76TD UAE Sidi Baranic / ▪ IMINT of IL-76TD @ HE40 on
Libya 27 Jan 2020.
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Kazakhstan
30 30 Jan 2020 UP-I7650 IL-76TD UAE Libya ▪ AZL1538

▪ Manifest claimed HEBA as
destination. Errors on manifest.
32 31 Jan 2020 UP-I7650 IL-76TD UAE HE40 / Libya ▪ IMINT of IL-76TD @ HE40 on
31 Jan 2020.
34 01 Feb 2020 UP-I7650 IL-76TD UAE Libya ▪
43 06 Feb 2020 UP-I7646 IL-76TD UAE Libya ▪ AZL1536 Azee callsign used
although dry leased to Jenis Air LLC.
44 07 Feb 2020 UP-I7650 IL-76TD UAE Libya ▪ Using UP-Y4202 as cover

51 12 Feb 2020 UP-I7651 IL-76TD UAE Libya ▪ AZL1536
destination. Errors in manifest.
d
54 13 Feb 2020 UP-I7651 IL-76TD Al Dhafra Libya ▪
e
55 14 Feb 2020 UP-I7646 IL-76TD Sweihan Libya ▪ AZL1536 Azee callsign used
56 14 Feb 2020 UP-I7651 IL-76TD OMAW Libya ▪ AZL1538
57 15 Feb 2020 UP-I7650 IL-76TD UAE Libya ▪ AZL1535 (A Westbound code for an
Eastbound flight!)
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Kazakhstan
58 15 Feb 2020 UP-I7650 IL-76TD OMAW Libya ▪ AZL1535 (A Westbound code for an
Eastbound flight!)
60 16 Feb 2020 UP-I7650 IL-76TD OMAW Libya ▪


78 19 Mar 2020 UP-I7651 IL-76TD Sharjahf HLLB ▪ Not seen on ADS-B since and now
flying for HAF based in Benghazi.
79 28 Mar 2020 UP-I7654 IL-76TD UAE HLLB ▪ AZL1538
▪ IMINT of IL-76TD @ HLLB on
27 Mar 2020.
80 01 Apr 2020 UP-I7646 IL-76TD OMAW HLLB ▪ AZL1536 Azee callsign used
81 01 Apr 2020 UP-I7654 IL-76TD OMAW HLLB ▪
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Kazakhstan
87 07 Apr 2020 UP-I7654 IL-76TD OMAW HLLB ▪ AZL1538
6 Apr 2020.
88 07 Apr 2020 UP-I7654 IL-76TD OMAW Libya ▪ UID
89 08 Apr 2020 UP-I7654 IL-76TD OMAW Libya ▪
91 09 Apr 2020 UP-I7654 IL-76TD OMAW Libya ▪ AZL1538
92 10 Apr 2020 UP-I7654 IL-76TD OMAW HLLB ▪ AZL1538
10 Apr 2020.
93 10 Apr 2020 TBC IL-76TD OMAW HLLB ▪ IMINT of IL-76TD @ HLLB on
18 Jan 2020.
94 11 Apr 2020 TBC IL-76TD OMSJ Libya ▪
95 15 Apr 2020 UP-I7654 IL-76TD Eritrea Libya / ▪ AZL1536

Egypt TBC
97 16 Apr 2020 UP-I7654 IL-76TD UAE HLLB ▪ IMINT of IL-76TD @ HLLB on
16 Apr 2020.
98 17 Apr 2020 UP-I7654 IL-76TD UAE Libya ▪
99 18 Apr 2020 UP-I7654 IL-76TD UAE HLLB ▪ IMINT of IL-76TD @ HLLB on

16 Apr 2020.
100 19 Apr 2020 UP-I7654 IL-76TD UAE HE40 ▪ IMINT Sentinel-2.
21 Apr 2020 Azee Air AOC suspended for six months ▪
101 2 May 2020 UP-I7654 IL-76TD UAE HE40 ▪ IMINT Sentinel-2.

▪
a
OMAA. Civilian Airport. 24°25'59"N, 54°39'04"E.
b
HLLB. Civilian Airport. 32°05'48"N, 20°16'10"E.
c
HE40. Civilian Airport. 31°27'59"N, 25°52'41"E.
d
OMAM. Military Airbase. 24°14'54"N, 54°32'52"E.
e
OMAW. Military Airbase. 24°31'38"N, 54°58'27"E.
f
OMSJ. Civilian Airport. 25°19'43"N, 55°31'02"E.
Documentation analysis
12. The Panel has examined the flight journey logs and cargo manifests provided by Azee
Airlines for nine flights of Ilyushin IL-76TD cargo aircraft. No flight documentation was
provided for the remainder. The air waybills and cargo manifests were considered highly
suspicious by the Panel as: 1) none had names, signatures or stamps; 2) the lack of specific detail
as to the cargo; 3) no details as to the consignee(s); 4) air waybills incomplete and no customs
valuation; 5) inaccuracies between air waybills and cargo manifests; and 6) some had been
completed by the 4th Aviation Group of the UAE Armed Forces. 88. Unless the flights were for
__________________
88
For example Flight AZL1538 from OMAA on 20 January 2020.
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an official organization it is doubtful whether they would ever have received customs clearance
based on the flight documentation provided.
(a) ALL of the aircraft flights were at less than 50% capacity, which is unusual for
expensive chartered flights where payload efficiency is usually strived for; and
(b) ALL of the flights were allegedly for the Khalifa Foundation Representative in Egypt.
Yet the foundation website only reflects one project in 2020, and that was for ‘20 tonnes
of dates’ (https://www.khalifafoundation.ae/en-us/Pages/InteractiveMap.aspx). The
Panel contacted the Khalifa Foundation89 but received no response.
Table 55.D.6
Cargo
Date A/C# From Destination Declared cargo (kg) Remarks
20 Jan 2020 UP-I7650 OMAA HEBA b Ford Vehicle 19,609 ▪ 39.2% of load capacity
a ▪ Consignee signed for as 4th
3 x Pallets Aviation Group, UAE Armed
Forces
30 Jan 2020 UP-I7650 OMAA HEBA General 21,890 ▪ 43.8% of load capacity
Cargo ▪ Cargo Manifest said OMFJ not
OMAA
11 Feb 2020 UP-I7646 OMAA HEBA 3 x Vehicles 20,200 ▪ 40.4% of load capacity
▪ Cargo Manifest adds up to
20,600kg load
12 Feb 2020 UP-I7651 OMAA HEBA General 17,000 ▪ 34.0% of load capacity
Cargo ▪ Cargo Manifest said OMFJ c
not OMAA
13 Feb 2020 UP-I7646 OMAA HEBA Technical 17,680 ▪ 35.4% of load capacity
Equipments ▪ Cargo Manifest said OMFJ not
(sic) OMAA
Cargo ▪ Odd numbered flight number
normally used for Westbound,
not Eastbound flights.
Cargo (Steel
Beams)
26 Feb 2020 UP-I7651 OMAA HEBA Grain (Pulse) 14,595 ▪ 29.2% of load capacity
Bags ▪ Cargo manifest gave date of 24
Feb 2020
a OMAA = Abu Dhabi, UAE

b HEBA = Alexandria, Egypt
c OMFJ = Fujairah, UAE
__________________
89
Email of 26 December 2020.
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13. One example of fake documentation is that for flight number AZL1538 on 20 January 2020.
The Air Waybill (figure 55.D.3) clearly shows the shipper as the Khalifa Foundation, Abu Dhabi,
and the consignee as the Khalifa Foundation, Egypt. The corresponding Cargo Manifest shows the
shipper as Munawal Operations and the consignee (receiver) as the UAE 4th Aviation Group, a
unit of the UAE Armed Forces.
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Figure 55.D.3
AZL1538 (20 January 2020) Air Waybill
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Figure 55.D.4
AZL1538 (20 January 2020) Cargo Manifest
14. Other elements of the documentation are suspicious, for example Munawala Ground
Services operate from Abu Dhabi (Al Bateen Executive Airport) (OMAD), which is also a military
airbase, and not the civilian Abu Dhabi International Airport (OMAA) that is listed on the flight
documentation.
15. The Panel thus finds that this flight activity by Azee Air LLC has violated paragraph 9 of
resolution 1970 (2011) for the direct, and indirect, supply of (…) military (…) equipment and (…)
other assistance (…) to Libya.
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Appendix E to Annex 55: Jenis Air LLC in support of HAF

1. Jenis Air LLC90 was only formed in 2019 and has operated two Ilyushin IL-76 TD91 on the
route during the period 13 January to 21 July 2020. These aircraft have made at least 48 airbridge
flights that meet the majority of the profile indicator (see Annex 75). These flights equate to a
maximum potential cargo delivery of 2,400 tonnes.
2. Two of the aircraft (UP-I7646 and UP-I7652) operated by Jenis Air LLC are owned by
Space Cargo Incorporated (www.spacecargoinc.com)92 of the United Arab Emirates, who were
found non-compliant with paragraph 9 to resolution 1970 (2011) in Panel report S/2019/914.
The Panel notes that on some Air Waybills it has seen that Space Cargo Incorporated is also
unusually listed as the Shipper for cargo on the suspicious flights to Libya. The Cargo Agent
used was reported as being Sun Global Freight LLC of the United Arab Emirates
(http://www.sunglobalfreight.com/)93,94.
3. Aircraft (UP-I7646) was operated by Azee Air LLC until 18 Feb 2020. Since then Jenis Air
LLC has operated the aircraft.95 This aircraft was owned by Aganya Limited of the British Virgin
Islands96 until sold to Space Cargo Incorporated. An infographic illustrating the relationships is at
figure 55.E.1.
Figure 55.E.1
Jenis Air LLC relationships
__________________
90
No corporate presence on-line.
91
Kazakhstan Civil Aviation Administration registered as UP-I7652. On 18 February 2020 Jenis Air LLC began
operating UP-I7646 which was transferred from Azee Air LLC, the previous operator.
92
PO Box 7812, Sharjah Airport International Free Zone, A4-073, Sharjah, UAE. +971 6 557 0388.
maher@spacecargoinc.com.
93
Suite 101 and 108, Cargo Terminal 1, Sharjah International Airport, Sharjah, UAE. +971 50 455 6484.
kumar@sunglobalfreight.com.
94
93
94
95
Letter from Azee Air 070/XX dated XX April 2020 to confidential source obtained by the Panel.
96
RAK Offshore, PO Box 48904, Tortola, British Virgin Islands.
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4. On 23 March and 20 May 2020, the Panel requested clarification from the Member State97
as to the nature of the flights and details of the cargo for the Jenis Air LLC flights to Libya. Jenis
Air LLC supplied the Civil Aviation Administration of Kazakhstan with air waybills or cargo
manifests for only sixteen flights. The Panel is unconvinced of the veracity of this documentation
for the reasons shown in table 55.E.1:
Table 55.E.1
Suspicious elements of Jenis Air LLC air waybills and manifests
Element Details Remarks

Shipper For some flights the shipper is also the ▪ Highly unusual that an aircraft owner, who is also a cargo
owner of the aircraft. agent at the same airport, would use a second cargo agent.
▪ In this case the company was Space Cargo Inc, who were
found non-compliant with the arms embargo in S/2019/914.
Consignees Rose Company for General Equipment ▪ No online presence for a trading company is unusual.
and Supplies, Labraq, Libya ▪ No answer to numerous calls to the listed number.
+218 918 871213
Libya Capital Company, Labraq, Libya ▪ No online presence for a trading company is unusual.
+218 913 428878. ▪ No answer to numerous calls to the listed number.
Almoiutaaliq for Cars, Labraq, Libya ▪ No contact details provided.
▪ No online presence for a trading company is unusual.
▪ Armoured Cars shipped.
Al Wakeel Al Jadded, Labraq, Libya ▪ No contact details provided.
▪ No online presence for a trading company is unusual.
▪ Armoured Cars shipped.
Noor Alhayat Company for Trading, ▪ No online presence for a trading company is unusual.
Benghazi, Libya
+218 912 129944
__________________
97
All letters to the Member State were also copied to the airline.
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Element Details Remarks

Customs Tariff No declared value. ▪ Unusual for a cargo requiring the speed and convenience
of air freight to not have a commercial value.
Insurance No insurance cover. ▪ Unusual for a cargo of value requiring air freight to not be
insured when moved to a conflict zone.
Accuracy Minimal completion of document. ▪ More information would be required to allow the cargo to
pass customs in the majority of Member States.
5. On 10 April 2020 both aircraft operated by Jenis Air LLC on the airbridge started to transmit
using MLAT (multi-lateration) mode during the entire flight. Although the ADS-B transponder
emits the aircraft’s code, heading, altitude and speed, it does not transmit the current latitude and
longitude.98 This is highly unusual for a civil aircraft and the Panel considers that Jenis Air LLC
is using this technique to disguise or conceal flights being made to transfer military equipment in
non-compliance with the arms embargo.
6. The Panel has identified the Jenis Air LLC cargo aircraft shown in table 55E.2 as of interest
to the Panel. The Panel has identified suspicious flights by Jenis Air LLC aircraft into Libya (tables
55.E.3 and 55.E.4). Note the random nature of the flights and lack of an obvious schedule.
transponders are often not visible on open-source ADS-B monitoring100 shortly after entering
Egyptian airspace; 2) the number of unscheduled flights on a previously little used route; 3) some
flights are from a joint military air base known to be a UAE Armed Forces logistic hub; 4) declared
loads were far less than aircraft cargo capacity; and 5) the lack of detail on the flight
documentation. Although Jenis Air LLC provided thousands of pages of documentation for
analysis, the majority of pages were for flight planning, weather patterns, technical records of
flights etc. Very few Air Waybills or Cargo Manifests were provided for the flights listed in tables
55.E.2 and 55.E.3, and the detail in these was scarce.
Table 55.E.2
Suspicious flights from UAE by Jenis Air LLC operated aircraft IL-76TD (UP-I7646)
Cargo
Date Flight # From Cargo for Jenis Declared cargo (tonnes) Remarks
29 Mar 2020 Sweihana Benghazib ▪ No manifest provided. ▪
31 Mar 2020 OMAW HLLB ▪ No manifest provided. ▪ IMINT of IL-76TD @

HLLB on 30 Mar 2020.
__________________
98
This can be estimated from the time differences between signals reaching the various ADS-B ground transponders,
but requires real time, and constant, mathematical calculations.
99
Automatic Dependent Surveillance - Broadcast. This is a surveillance technology whereby an aircraft determines its
position from satellites and then automatically broadcasts it, enabling the aircraft to be tracked without an interrogation
signal from the ground.
100
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Cargo
Date Flight # From Cargo for Jenis Declared cargo (tonnes) Remarks
01 Apr 2020 AZL1536 OMAW HLLB ▪ No manifest provided. ▪ Still using Azee flight
numbers.
02 Apr 2020 AZL1536 OMAW HLLB ▪ No manifest provided. ▪
16 Apr 2020 AZL1536 UAE HLBB ▪ No manifest provided. ▪ IMINT of IL-76TD @

HLLB on 16 Apr 2020.
22 Apr 2020 UAE Libya ▪ No manifest provided. ▪ Ibid
25 May 2020 UAE Libya ▪ No manifest provided. ▪
3 Jul 2020 Jenis Air LLC AOC Suspended ▪
21 Jul 2020 JEN1365 UAE HLLB ▪ No manifest provided. ▪
30 Jul 2020 JEN1364 Jordan Libya ▪ No manifest provided. ▪
a
b
HLLB. 32°05'48"N, 20°16'10"E.
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Table 55.E.3
Suspicious flights from UAE by Jenis Air LLC operated aircraft IL-76TD (UP-I7652)
Cargo
Date Flight # From Cargo for Jenis Declared Cargo (tonnes) Remarks
2 Jan 2020 Sidi Barani a Abraqb ▪ Food 20.0 ▪ Manifest shows

HLLQ > HE40
which is highly
unlikely.
6 Jan 2020 JEN1366 Sharjah c HLLQ ▪ Olive green blankets 17.7 ▪ Military
equipment.
7 Jan 2020 Abu Dhabid HLLQ ▪ Ground equipment. 6.0 ▪ Shipped by Space
Cargo Inc.
13 Jan 2020 JEN1352 OMAA HLLQ ▪ Dental equipment 9.9 ▪
14 Jan 2020 UAE Libya ▪ No manifest provided. ▪
15 Jan 2020 UAE Libya ▪ No manifest provided. ▪

e
17 Jan 2020 UAE Benghazi ▪ No manifest provided. ▪
20 Jan 2020 OMSJ HLLQ ▪ Jackets 12.6 ▪ Military clothing.

▪ Garments 14.2
21 Jan 2020 Libya Libya ▪ No manifest provided. ▪
3 Feb 2029 HE40 HLLQ ▪ Machinery 24.0 ▪ Manifest shows

HLLQ > HE40
which is highly
unlikely.
12 Feb 2020 JEN1535 UAE Libya ▪ No manifest provided. ▪
d
14 Feb 2020 JEN1353 Sweihan Libya ▪ No manifest provided. ▪
15 Feb 2020 UAE Libya ▪ No manifest provided. ▪
21 Feb 2020 JEN1353 UAE Libya ▪ No manifest provided. ▪
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Cargo
Date Flight # From Cargo for Jenis Declared Cargo (tonnes) Remarks
27 Feb 2020 JEN1363 Aqabae HLLQ ▪ Armoured Vehicles x 4 13.4 ▪
1 Mar 2020 JEN1366 OJAQ HLLQ ▪ Vehicles x 4 17.9 ▪
12 Mar 2020 JEN1362 OJAQ HLLQ ▪ Vehicles x 4 13.4 ▪ AWB says

JEN1364.
28 Mar 2020 JEN1361 UAE Libya ▪ No manifest provided. ▪
f
29 Mar 2020 JEN1366 Marka HLLQ ▪ Garments 18.2 ▪ Manifest states
generators as
cargo.
31 Mar 2020 JEN1361 UAE Libya ▪ No manifest provided. ▪ via HE40
31 Mar 2020 JEN1361 UAE Libya ▪ No manifest provided. ▪ via HE40
02 Apr 2020 UAE HLLB ▪ No manifest provided. ▪ via HE40 on return
▪ IMINT of IL-
76TD @ HLLB on
2 Apr 2020.
06 Apr 2020 JEN1366 OMSJ HLLQ ▪ No manifest provided. ▪
09 Apr 2020 JEN1366 OMAA Libya ▪ No manifest provided. ▪

g
26 Apr 2020 UAE Al Jufra ▪ No manifest provided. ▪
29 Apr 2020 UAE HLLB ▪ No manifest provided. ▪ IMINT Sentinel-2.

3 Jul 2020 Jenis Air LLC AOC Suspended ▪ ▪
7 Jul 2020 Jenis Air LLC AOC Expired ▪ ▪
a HE40. Military Airbase. 31°27'59"N, 25°52'41"E.

b HLLQ. 32°47'19"N, 21°57'52"E.
c OMSJ. 25°19'43"N, 55°31'02"E.
d OMAA. Military Airbase. 24°25'59"N, 54°39'04"E.
e HLLB. 32°05'48"N, 20°16'10]
e OJAQ. 29°36'42"N, 35°01'05"E.
f OJAM. 31°58'22"N, 35°58'30"E.
g HL69. Military Airbase. 29°11'53"N, 16°00'04"E.
8. On 3 July 2020, the Civil Aviation Administration of Kazakhstan suspended the Air
Operators Certificate (AOC) for Azee Air LLC for a period of six months. The suspension was
based on multiple sources identifying that Azee Air had violated “the requirements of paragraph
9 of Security Council Resolution 1970 (2011)” and “operational requirements and restrictions” of
their air operator’s certificate. The AOC expired on 7 July 2020 and Jenis Air LLC has not applied
to renew it.
9. The Panel is convinced that Jenis Air LLC has now based the following aircraft in Benina in
direct support of the HAF supply chains: UP-I7646, UP-I7652, UP-I7656 and UP-I 1805 (see
paragraph 4 to Annex 55).
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Table 55.E.4
Jenis Air LLC aircraft of interest to the Panel
A/C # A/C type Registered Operator Owner

a
UP-II805 IL-18 Kazakhstan Jenis Air LLC Space Cargo Inc, b UAE
UP-I7646 IL-76TD Kazakhstan Azee Air LLC c Aganya Limited, d UAE
then from 8 Feb 2020 to then from 1 Feb 2020 to

Jenis Air LLC Space Cargo Inc, UAE
UP-I7652 IL-76TD Kazakhstan Jenis Air LLC Space Cargo Inc, UAE
UP-I7656 IL-76TD Kazakhstan Jenis Air LLC Jenis Air LLC
a No corporate web presence. Massif Aeroport, Ulitsa Aeroport 4/1, Taraz, Kazakhstan. +7 7073 222119.
(jenisair@mail.ru).
b www.spacecargoinc.com. Saif Zone 125 M2, Warehouse A4-73, P.O. Box 7812, Sharjah, UAE. +971 65 570388,
+971 65 724019, +971 52 7888309. (s.ermolchev@spacecargoinc.com/ / maher@spacecargoinc.com).

c www.azeeair.com. Office 303, Building 17, Naurizbay Batir SIRIUS (Business Centre), Almaty 050004,
Kazakhstan. +7 7273 469146. (gd@azeeair.com).

d No trace.
10. The Panel was unconvinced of the accuracy of the cargo documentation provided by Jenis Air
LLC. The Panel thus finds that this flight activity by Jenis Air LLC is a non-compliance with
paragraph 9 of resolution 1970 (2011) for the direct, and indirect, supply of (…) military (…)
equipment and (…) other assistance (…) to Libya.
11. On 11 November 2020, Jenis Air LLC changed the company name and re-registered with
the Kazakh business authorities as ‘Aircompany Feniks 2020 LLP’ (BIN 170740014751). The
Manager and Member of the company is the same as for Jenis Air LLC, Alexadnr Dimitrievich
Pyankov. The new airline has yet to receive Air Operator approval from the Kazakhstan aviation
authorities.
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Appendix F to Annex 55: Space Cargo Inc LLC

1. The Panel has identified a Sharjah based owner, cargo agent and freight forwarding
company, Space Cargo Inc LLC,101 that appears as a common denominator in many of the illicit
aviation activities relating to eastern Libya and airports under the control of armed forces affiliated
to Khalifa Haftar (HAF). Space Cargo Inc LLC was reported in S/2019/914102 as violating the
arms embargo, but the Panel has subsequently identified a much wider range of violations that
suggests that Space Cargo LLC Inc has a major coordination and operational role for the UAE
airbridge to eastern Libya, and the delivery of military materiel to HAF.
2. The Panel confirmed that “Maher Naifaa is the owner, decision maker and General Manager
of the company”,103 Maher Naifaa being an a.k.a. of Maher Nayef Alismail. The company structure
and individual responsibilities are as shown at table 55.F.1.
Table 55.F.1
Structure of Space Cargo Inc LLC
Role Name a.k.a Contact details Remarks

Owner and Maher Nayef Alismail Maher Naifaa maher@spacecargoinc.com ▪ Syrian
a
General Manager Maher Al Ismail gm@spacecargoinc.com
maher_naifaa@yahoo.com
+971 6 55 70 388
Executive Manager Alex Makarov b ▪ Since Feb 2013.
Head of Operations Sergey Ermolchev c s.ermolchev@spacecargoinc ▪ Since Feb 2015.
.com ▪ Uzbek.
+971 52 7888 309
Auditor Aleksandra Isamova auditor@spacecargoinc.com ▪
+971 6 55 70 388
▪
a
https://www.linkedin.com/in/maher-alismail-3214aa96/. Accessed 22 October 2020.
b
https://www.linkedin.com/in/alex-makarov-06320454/. Accessed 22 October 2020.
c
https://www.linkedin.com/in/sergey-ermolchev-1135aa117/. Accessed 22 October 2020.
3. The Panel has identified numerous activities and violations of paragraph 9 of resolution 1970
(2011) relating to Space Cargo Inc LLC, shown alphabetically in table 55.F.2 and as an infographic
in figure 55.F.1.
__________________
101
A4-73, Block A4 Street, G Floor, Sharjah International Airport, Al Ruqa Al Hamra, 61487 Sharjah, UAE or Saif
Zone 125 M2, Warehouse A4-73, P.O. Box 7812, Sharjah, UAE.
102
Table 8 and annexes 28 and 52.
103
Panel call to Aleksandra Isamova, on 8 September 2020.
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Table 55.F.2
Space Cargo Inc activities relating to arms embargo violations104
Date Activity Space Cargo Inc LLC Link Remarks

1 Nov 2017 AN-26 (ex-UP-AN601) identified Operated by Space Cargo ▪ 8 Oct 2015 - De-registered by Kazakhstan. a
in Libya flying in support of HAF. b Inc LLC. ▪ Flying under false flag of H.A.D Jet cargo
LLC.
20 Jan to IL-76TD (ex-UP-I7645) flying Chartered by Space Cargo ▪ Owned by Technoline FZE, UAE.
26 Aug 2019 primarily from Jordan to Libya. b Inc LLC.c ▪ Operated by Sigma Airlines LLC, UAE.
▪ 29 May 2020 - Sigma Airlines air operating
certificate suspended. d
▪ 14 Aug 2017 – Registered by Kazakhstan. e
▪ 10 Sep 2019 - Deregistered by Kazakhstan. f
▪ UAE Armed Forces Load Manifests identified
by panel.
4 Mar to IL-76TD (UP-I7601) flying from Chartered by Space Cargo ▪ Owned by Technoline FZE, UAE.
6 Sep 2019 Jordan to Libya, and then primarily Inc LLC.c ▪ Operated by Sigma Airlines LLC, UAE.
in Libya in direct support of HAF. b ▪ 4 Oct 2017 – Registered by Kazakhstan. g
Sep 2019 IL-76TD (UP-I7645) changed Transferred by Space Cargo ▪ Now flying in support of GNA primarily on
registration to Libya 5A-POL.h Inc LLC. Istanbul to Misrata route..
5 Nov 2019 Purchased IL-76TD (UP-I7652). Space Cargo Inc LLC ▪ From Global Aviation Services FZE.
ownership. ▪ Sales contract No. 07/GAS/SPACE/19.
▪ 24 Nov 2019 - Re-registered by Kazakhstan. j
24 Nov 2019 Leased IL-76TD (UP-I7652). Space Cargo Inc LLC ▪ Leased to Jenis Air LLC.
▪ 20 Jul 2020 - Jenis Air LLC air operating
certificate suspended. k
20 Dec 2019 Purchased IL-18D (UP-I1805) Space Cargo Inc LLC ▪ From Jenis Air LLC.
ownership ▪ Purchase Agreement No 20/19.
▪ 20 Jan 2020 – Registered by Kazakhstan. l
1 Feb 2020 Purchased IL-76TD (UP-I7646). Space Cargo Inc LLC ▪ From Aganya Limited, UAE.
ownership ▪ Bill of Sale No. 80505-01-2020.
▪ Operated by Azee Air LLC until 22 Apr 2020
and then by Jenis Air LLC.
19 Mar 2020 Purchased IL-76TD (UP-I7651). Space Cargo Inc LLC ▪ From Infinite Seal Inc, BVI.
ownership. ▪ Bill of Sale No. 6002-03-2020.
▪ 9 Jul 2019 - Registered by Kazakhstan. m
▪ 13 May 2020 - Deregistered by Kazakhstan. n
19 Mar 2020 IL-76TD (UP-I7651) flew into Space Cargo Inc LLC ▪ Operated by Azee Air LLC.
Libya and started operating in ownership. ▪ 21 Apr 2020 - Azee Air LLC air operating
support of HAF. p certificate suspended. q
9 April 2020 IL-76TD (UP-I7646) flew into Space Cargo Inc LLC ▪ Operated by Azee Air LLC until 22 April 2020
Libya and started operating in ownership. then Jenis Air LLC.
support of HAF. r ▪
12 Apr 2020 Purchased AN-32B (EY-332). Space Cargo Inc LLC ▪ From Sky Star FZC.
ownership. ▪ Warranty Bill of Sale (Unreferenced) of 27
Apr 2020.
▪ 12 Apr 2020 Deregistered by Tajikistan. s
▪ Flying illegally in Libya in support of HAF.
29 April 2020 IL-76TD (UP-I7652) flew into Chartered by Space Cargo ▪ Leased and operated by Jenis Air LLC.
Libya and started operating in Inc LLC.
support of HAF. t
a
Kazakhstan Certificate of Deregistration No.196, dated 8 October 2015.
b
Reported in S/2019/914, table 8, and annexes 28 and 52.
__________________
104
All the documentation referred to in this appendix is available from the Panel on request.
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c
Information received from Member State, based on their interview with Umirbek KENESBAEV, Director General of Sigma
Airlines.
d
Order OA No.167.
e
Certificate of Registration No. 1083 dated 14 August 2017.
f
Certificate of Cancellation from State Register of Civil Aircraft of Republic of Kazakhstan dated 10 September 2019.
g
Certificate of Registration No. 225 dated 20 January 2020.
h
www.aerotransport.org, updated 16 May 2020. Accessed 21 October 2020.
j
Certificate of Registration No.1188 dated 24 November 2019.
k
Order OA No.124.
l
Certificate of Registration No. 1185 dated 20 January 2020.
m
Certificate of Registration No. 1187 dated 7 September 2019.
n
Certificate of Cancellation No. 299 from State Register of Civil Aircraft of Republic of Kazakhstan dated 13 May 2019.
p
https://twitter.com/Gerjon_/status/1284545325160693766, 18 July 2020. Confirmed by C4ADS research and
www.aerotransport.org, updated 16 May 2020. Last ADS-B contact on 19 March 2020 at 06:50 hours with aircraft heading on
common track to Libya.
q
Order OA No.121.
r
Confirmed by C4ADS research and www.aerotransport.org, updated 16 May 2020. Last ADS-B contact on 9 April 2020 at
04:40 hours with aircraft heading on common track to Libya.
s
Letter from member State of 26 June 2020.
t
Confirmed by C4ADS research and www.aerotransport.org, updated 16 May 2020. Last ADS-B contact on 29 April 2020 at
01:20 hours with aircraft heading on common track to Libya.
Figure 55.F.1
Infographic of Space Cargo Inc LLC linkages to arms embargo violations
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4. After verbal enquiries by the Panel to the company105 it was noted that the company’s
website was removed from the internet on 25 September 2020, highly probably in response to the
Panel’s continued investigations into their activities.
5. The Panel wrote to Space Cargo Inc LLC106 and provided the company with an opportunity
to respond. The company responded on 15 November 2020 and denied any relationship with any
illegal or unlawful actions that may have occurred using aircraft under their control or influence.
Although they provided a significant amount of documentation, that documentation was
insufficient to counter other documentation in possession of the Panel relating to arms embargo
violations. Tables 55.F.3 to 55.F.10 summarises the Panel’s evidence relating to each aircraft under
the ownership, control or influence of Space Cargo Inc compared against the company’s response.
Table 55.F.3
107
AN-26 (ex UP-AN601)
Space Cargo Affirmation /

Date Activity Documentation Panel Evidence / Rebuttal
8 Oct 2015 De-registered by Kazakhstan. ▪ Kazakhstan Certificate of Deregistration
No.196, dated 8 October 2015 shows
owned by Space Cargo Inc.
1 Nov 2017 Identified in Libya flying in ▪ Flying under false flag of H.A.D Jet
support of HAF. cargo LLC.
▪ Reported in S/2019/914, table 8, and
annexes 28 and 52.
▪ Imagery analysis.
24 Jul 2019 H.A.D Jet Cargo deny ▪ Letter from Member State dated 2
operating aircraft. August 2019.
14 Nov 2020 Space Cargo Inc deny any ▪ No evidence of transfer of ownership
relationship with the provided by Space Cargo Inc.
aircraft, despite being the
registered owner on de-
registration.
Table 55.F.4
IL-76TD (ex-UP-I7601)
Space Cargo Affirmation / Panel Evidence / Rebuttal

Date Activity Documentation
5 Mar 2017 Space Cargo wet leased ▪ Prior to arms embargo violation offences
from Reem Style and so not relevant.
Travel, UAE.
__________________
105
Panel call to company on 8 September 2020.
106
Panel letters of 20 June 2019, 2 July 2020 and 29 October 2020.
107
All the documentation referred to in this annex is available from the Panel on request. It has not been included as
it would result in a very unwieldy final report.
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Space Cargo Affirmation / Panel Evidence / Rebuttal

Date Activity Documentation
Jan 2018 Space Cargo state wet ▪ Prior to arms embargo violation offences
lease concluded, but so not relevant.
document supplied shows it ▪ Space Cargo Inc dates do not agree.
ended 6 October 2017.
4 Oct 2017 Registered by Kazakhstan on ▪ Certificate of Registration No. 225.
change of ownership. ▪ Owned by Technoline FZE, UAE.
▪ Operated by Sigma Airlines LLC, UAE.
2019 Chartered by Space Cargo Inc ▪ Information received from Member

from Sigma Airlines LLC State, based on their interview under
caution with Umirbek KENESBAEV,
Director General of Sigma Airlines.
4 Mar to Identified flying from Jordan ▪ Reported in S/2019/914, table 8, and
6 Sep 2019 to Libya, and then primarily in annexes 28 and 52.
Libya in direct support of ▪ C4ADS flight analysis.
HAF.
9 Oct 2019 Sigma Airlines faked the ▪ Faked to allow for carriage of 62
Operations Specification for passengers.
the aircraft.
29 May 2020 Sigma Airlines Air Operating ▪ CAA Kazakhstan Order 167.
Certificate (AOC) suspended.
15 Jun 2020 Reported registered with ▪ http://www.aerotransport.org/.

Ukraine CAA as UR-CTO.
23 Sep 2020 Sigma Airlines AOC revoked. ▪ Member State.
14 Nov 2020 Space Cargo Inc deny ▪ No evidence of any transfer of

leasing or chartering from ownership provided by Space Cargo Inc.
Technoline FZE. ▪ Space Cargo did not deny chartering
from Sigma Airlines LLC though.
Table 55.F.5

Date Activity Documentation Panel Evidence
5 Mar 2017 Space Cargo negotiated wet ▪ Prior to arms embargo violation
lease from Reem Style and offences so not relevant.
Travel, UAE but did not
proceed.
14 Aug 2017 Registered by Kazakhstan on ▪ Certificate of Registration No.1083.
change of ownership. ▪ Owned by Technoline FZE, UAE.
▪ Operated by Sigma Airlines LLC, UAE.
2019 Chartered by Space Cargo Inc ▪ Information received from Member
from Sigma Airlines LLC State, based on their interview under
caution with Umirbek KENESBAEV,
Director General of Sigma Airlines.
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20 Jan to Identified flying from Jordan ▪ C4ADS flight analysis.
26 Aug 2019 to Libya, and then primarily in ▪ UAE Armed Forces Load Manifests
Libya in direct support of identified by Panel.
HAF.
29 May 2020 Sigma Airlines Air Operating ▪ CAA Kazakhstan Order 167.
10 Sep 2019 De-registered by Kazakhstan. ▪ Certificate of Cancellation No.291.
23 Sep 2020 Sigma Airlines AOC revoked. ▪ Member State.
Sep 2019 Now flying for GNA with ▪ www.aerotransport.org, updated 16 May
Libyan registration 5A-POL.h 2020. Accessed 21 October 2020.
▪ Flying primarily on Istanbul to Misrata
route..
14 Nov 2020 Space Cargo Inc deny ▪ No evidence of any transfer of
leasing or chartering from ownership provided by Space Cargo Inc.
Technoline FZE. ▪ Space Cargo did not deny chartering
from Sigma Airlines LLC though.
Table 55.F.6
IL-76TD (UP-I7646)

23 Dec 2019 Registered by Kazakhstan. ▪ Certificate of Registration No.1186.
▪ Owned by Aganya Limited, UAE.
▪ Operated by Azee Air LLC.
17 Jan 2020 Flight data blocked from ▪ FR24 documentation.

public view on ▪ NOTE blocked before sale and transfer
www.flightradar24.com to Jenis Air LLC.
platform at Jenis Air LLC
request.
26 Jan 2020 Purchased by Space Cargo ▪ Bill of Sale No. 80505-01-2020.
from Aganya Limited ▪ Documents signed 1 Feb 2020.
(UAE)
26 Jan 2020 Dry leased to Jenis Air ▪
LLC. Document provided.
19 Feb 2020 Registered by Kazakhstan on ▪ Certificate of Registration No.1186.
change of ownership. ▪ Owned by Space Cargo Inc, UAE.
▪ Operated by Jenis Air LLC.
9 April 2020 Identified flying into Libya ▪ Azee Air LLC identifier used on
to start operating in support flights until 22 April 2020 then Jenis
of HAF. Air LLC.
▪ C4ADS research and
www.aerotransport.org, updated
16 May 2020. Last ADS-B contact
on 9 April 2020 at 04:40 hours
with aircraft heading on common
track to Libya.
2 Oct 2020 Reported as been returned to ▪ http://www.aerotransport.org/.
Space Cargo Inc.
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14 Nov 2020 Space Cargo Inc deny any ▪
relationship regarding the
illegal actions of others
using this aircraft.
Table 55.F.7

▪ Owned by Infinite Seal, BVI.
▪ Operated by Azee Air LLC
17 Jan 2020 Flight data blocked from ▪ FR24 documentation.
public view on
www.flightradar24.com
platform at Azee Air LLC
request.
10 Mar 2020 Purchased by Space ▪ Bill of Sale No. 6002-03-2020.
Cargo from Infinite Seal ▪ Document signed 19 March 2020.
Inc, BVI.
10 Mar 2020 Claimed to have sold to ▪ Eagle Enterprise deny all knowledge of
Eagle Enterprise this sale and are categorical that all
Company Limited, South documentation is fake. The Panel is
Sudan. Sale Agreement convinced of their authenticity and finds
that Space Cargo have supplied fake
EEC-SCI-009-01-20 documentation to the Panel.
provided.
19 Mar 2020 Identified as flown into Libya ▪ https://twitter.com/Gerjon_/status/128454
and started operating in 5325160693766, 18 July 2020. Confirmed
support of HAF. by C4ADS research and
www.aerotransport.org, updated 16 May
2020. Last ADS-B contact on 19 March
2020 at 06:50 hours with aircraft heading
on common track to Libya.
▪ Operated by Azee Air LLC (but Space
Cargo stated operated by Jenis Air LLC).
21 Mar 2020 Reported as being operated by ▪ www.aerotransport.org.
HAF in Libya.
21 Apr 2020 Azee Air LLC Operating ▪ CAA Kazakhstan Order 121.
13 May De-registered by Kazakhstan. ▪ Certificate of Cancellation No.299.
2020
23 Sep 2020 Azee Air LLC AOC revoked. ▪ Member State.
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14 Nov 2020 Space Cargo Inc deny ▪
any relationship
regarding the illegal
actions of others using
this aircraft.
Table 55.F.8
IL-76TD (UP-I7652)

5 Nov 2019 Purchased by Space ▪ Sales contract No. 07/GAS/SPACE/19.
Cargo from Global ▪ 24 Nov 2019 - Re-registered by
Aviation Services FZE, Kazakhstan. j
UAE.
24 Nov 2019 Dry leased to Jenis Air ▪ Contract No 24/11/19.
LLC. Document
provided.
26 Nov 2019 Registered by Kazakhstan. ▪ Certificate of Registration No.1188.
▪ Owned by Space Cargo Inc.
▪ Operated by Jenis Air LLC
29 April Identified flying into Libya ▪ Confirmed by C4ADS research and
2020 and started operating in www.aerotransport.org, updated 16 May
support of HAF. 2020. Last ADS-B contact on 29 April
2020 at 01:20 hours with aircraft heading
on common track to Libya.
Jun 2020 Reported as being operated by ▪ www.aerotransport.org.
HAF in Libya.
20 Jul 2020 Jenis Air LLC Operating ▪ CAA Kazakhstan Order 124.
23 Sep 2020 Jenis Air LLC Operating ▪ Member State.
Certificate (AOC) revoked.
14 Nov 2020 Space Cargo Inc deny ▪
any relationship
regarding the illegal
actions of others using
this aircraft.
Table 55.F.9
IL-18D (UP-I1805)

22 Oct 2019 Purchased by Jenis Air ▪ Purchase Agreement No. 22/10/2019
LLC from Dasterro
Group Corporation,
Panama
4 Nov 2019 Registered by Kazakhstan ▪ Certificate of Registration No.1185.
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20 Dec 2019 Purchased by Space ▪ Purchase Agreement No. 20/19.
Cargo from Jenis Air
LLC.
20 Jan 2020 Registered by Kazakhstan on ▪ Certificate of Registration No.1185.
change of ownership.
6 Jun 2020 Identified at Al Jufra air base ▪ https://twitter.com/HasairiOuais/status/128735
operating in support of HAF. 6754255400963, 26 July 2020.
14 Nov 2020 Space Cargo Inc made no ▪

reference to this aircraft
in their response of 14
November 2020.
Table 55.F.10
AN-32B (EY-332)

12 Apr 2020 Purchased by Space Cargo Inc ▪ Purchase Agreement (Unreferenced)
from Sky Star FZE, UAE. of 12 Apr 2020.
▪ Warranty Bill of Sale (Unreferenced)
of 27 Apr 2020.
12 Apr 2020 Deregistered by Tajikistan. ▪ Letter from Member State of 26 June
2020.
25 Apr 2020 Identified as evacuating ▪ Imagery analysis.
Russian PMC military
operatives from Bani Walid in
Libya.
14 Nov 2020 Space Cargo Inc made no ▪
reference to this aircraft
in their response of 14
November 2020.
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Figure 55.F.2
Infographic EY-332 operating in Libya
6. The Panel was unconvinced of the accuracy of the documentation provided by Space Cargo
Inc LLC. The Panel thus finds that this aviation activity by Space Cargo Inc LLC has repeatedly
violated paragraph 9 of resolution 1970 (2011) for the direct, and indirect, supply of (…) military
(…) equipment and (…) other assistance (…) to Libya.
7. As the person in control of Space Cargo Inc LLC, the Panel also finds that Maher Nayef
Alismail has violated paragraph 9 of resolution 1970 (2011).
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Appendix G to Annex 55: Maximus Airlines LLC in support of HAF

1. The Panel has identified the Maximus Airlines LLC cargo aircraft shown in table 55.G.1 as of
interest to the Panel. The Panel has identified the flights shown in table 55.G.2 by Maximus Airlines
LLC aircraft into Libya. Note the random nature of the flights and lack of an obvious schedule.
transponders are often not visible on open source ADS-B monitoring109 shortly after entering
Egyptian airspace; 2) the number of unscheduled flights on a previously little used route; 3) the
flights are from a joint military air base known to be a UAE Armed Forces logistic hub; 4) the lack
of detail on the flight documentation; and 5) the flight documentation identified the consignee as
the UAE Armed Forces in Egypt.
Table 55.G.1
Maximus Airlines LLC aircraft of interest to the Panel
Listed Beneficial Owner

A/C # A/C type Registered Operator Owner Executive Director
UR-BXQ IL-76TD Ukraine Maximus Airlines LLC a Maximus Airlines LLC, Alex Makarov
Ukraine
UR-ZYD AN-124-100 Ukraine Maximus Airlines LLC Maximus Air LLC, b UAE Crown Prince Mohammed
bin Zayed c 110
a
No corporate web presence. 4th Floor, 8B Raisa Okipna Street, Kiev 02002, Ukraine. +380 44 227 9103. (office@maximus-airlines.com).
b
www.maximus-air.com. PO Box 35367, Abu Dhabi, UAE. +971 2 419 8666. Originally formed by UAE Ministry of Defence in 2004.
c
His Highness Sheikh Mohammed bin Zayed bin Sultan Al Nahyan.
Table 55.G.2
Suspicious flights on the HAF airbridge by Maximus Air LLC operated aircraft
Ukraine
# Date A/C # A/C type From To Cargo
a b
1 12 Jan 2020 UR-ZYD AN-124-100 Assab Marsa Matruh ▪ Vehicles x 18
2 14 Jan 2020 UR-ZYD AN-124-100 HHSB HEMM ▪ Vehicles x 18
__________________
108
Automatic Dependent Surveillance - Broadcast. This is a surveillance technology whereby an aircraft determines
its position from satellites and then automatically broadcasts it, enabling the aircraft to be tracked without an
interrogation signal from the ground.
109
110
1) https://www.routesonline.com/airlines/4022/maximus-air-/news/160637/three-of-abu-dhabis-leading-aviation-
companies-combine-to-give-boost-to-capitals-standing-as-aerospace-and-aviation-hub/, 26 August 2012; 2)
https://feitoffake.wordpress.com/2020/02/08/old-russian-cargo-aircraft-are-leased-by-united-arab-emirates-for-arms-
transport-to-libya/, 8 February 2020.
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Ukraine
# Date A/C # A/C type From To Cargo
c
13 5 Jun 2020 UR-BXQ IL-76TD UAE Libya ▪ #MXM3704
a
HSSB. Military Airbase. 13°04'18"N, 42°38'42"E.
b
HEMM. Civilian Airbase. 31°19'31"N, 27°13'18"E.
c
Highly probably but response awaited from Member State.
3. The Panel was unconvinced of the accuracy of the documentation provided by Maximus
Airlines LLC. The Panel thus finds that Maximus Airlines LLC has violated paragraph 9 of
resolution 1970 (2011) for the direct, and indirect, supply of (…) military (…) equipment and (…)
other assistance (…) to Libya.
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Appendix H to Annex 55: Cham Wings Airlines in support of HAF

1. The Panel has identified the Cham Wings Airlines cargo aircraft shown in table 55.H.1 as of
interest to the Panel. The Panel has identified the flights shown in table 55.H.2 for Cham Wings
Airlines aircraft into Libya. The list may not be exhaustive if some pre-departure flight plans were
not filed directly with Eurocontrol111 for entry into European airspace.
2. Note the random nature of the flights and lack of an obvious schedule. Cham Wings Airlines
website does not list an office or agent for Libya, flights to Libya did not appear on their schedule
and flights to Libya could not be booked through their on-line booking service. No response to
Panel enquiries was received from the Member State or the airline. It was reported on 13 December
2020 that Cham Wings Airlines would commence scheduled twice-weekly flights to Benghazi,112
and a Panel test booking found seat availability on 7 January 2021.
Table 55.H.1
Cham Wings Airlines aircraft of interest to the Panel
A/C # A/C type Registered Operator Owner

YK-BAA A320-211 Syria Cham Wings Airlines a Cham Wings Airlines
YK-BAB A320-211 Syria Cham Wings Airlines Cham Wings Airlines
YK-BAE A320-231 Syria Cham Wings Airlines Cham Wings Airlines
YK-BAG A320-212 Syria Cham Wings Airlines Cham Wings Airlines
a www.chamwings.com. Fardos Street, Damascus, Syria. +963 11 9211. (cs@chamwings.com).
Table 55.H.2
Suspicious flights from Syria by Cham Wings Airlines aircraft (2019)
Maximum load
Date From To Aircraft # Type Passengers (t)
12 Apr 2019 Damascus a Benghazi b YKBAE A320-231 174 19.9
23 Apr 2019 OSDI HLLB YKBAG A320-212 156 19.9
30 Apr 2019 OSDI HLLB YKBAG A320-212 156 19.9
1 May 2019 OSDI HLLB YKBAE A320-231 174 19.9
3 May 2019 OSDI HLLB YKBAG A320-212 156 19.9
17 May 2019 OSDI HLLB YKBAG A320-212 156 19.9
14 Jun 2019 OSDI HLLB YKBAB A320-211 156 19.9
29 Jun 2019 OSDI HLLB YKBAB A320-211 156 19.9
27 Aug 2019 OSDI HLLB YKBAB A320-211 156 19.9
30 Aug 2019 OSDI HLLB YKBAB A320-211 156 19.9
6 Sep 2019 OSDI HLLB YKBAB A320-211 156 19.9
__________________
111
https://www.eurocontrol.int.
112
https://libyareview.com/8705/syrias-cham-wings-airlines-operates-direct-flights-to-benghazi/. 13 December 2020.
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Maximum load
Date From To Aircraft # Type Passengers (t)
4 Oct 2019 OSDI HLLB YKBAB A320-211 156 19.9
8 Nov 2019 OSDI HLLB YKBAB A320-211 156 19.9
25 Nov 2019 OSDI HLLB YKBAB A320-211 156 19.9
30 Dec 2019 OSDI HLLB YKBAB A320-211 156 19.9
31 Dec 2019 OSDI HLLB YKBAB A320-211 156 19.9
Total: 3,312 398 t
Source: 1) Confidential source ; and 2) www.flightradar24.org.

a OSDI. Damascus. Joint Airbase. 33°24'25"N, 36°30'34"E.
b HLLB. Benghazi. Joint Airbase. 32°07'00"N, 20°04'00"E.
Table 55.H.3
Suspicious flights into eastern Libya by Cham Wings Airlines aircraft (2020)
Maximum
Date From Cargo for Syria A/C # A/C type Passengers load (t)
1 Jan 2020 Damascus a Benghazi b YK-BAB A320-211 156 19.9
3 Jan 2020 OSDI HLLB YK-BAB A320-211 156 19.9
1 Feb 2020 OSDI HLLB YK-BAB A320-211 156 19.9
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Maximum
22 Feb 2020 OSDI HLLB YK-BAE A320-231 156 19.9
29 Feb 2020 OSDI HLLB YK-BAG A320-211 156 19.9
3 Mar 2020 OSDI HLLB YK-BAG A320-211 156 19.9
4 Mar 2020 OSDI HLLB YK-BAA A320-211 156 19.9
10 Mar 2020 OSDI HLLB YK-BAA A320-211 156 19.9
c
6 May 2020 Amman HLLB YK-BAG A320-211 156 19.9
6 May 2020 OJAI HLLB YK-BAG A320-211 156 19.9
d e
11 May 2020 Latika Al Khadim YK-BAG A320-212 156 19.9
11 May 2020 OSLK HLLB YK-BAA A320-212 156 19.9
16 May 2020 OSLK HL59 YK-BAA A320-212 156 19.9
19 May 2020 OSDI HLLB YK-BAG A320-211 156 19.9
20 May 2020 OSLK HLLB YK-BAG A320-211 156 19.9
18 Jun 2020 OSLK HLLB YK-BAG A320-211 156 19.9
21 Jun 2020 OSDI HLLB YK-BAG A320-211 156 19.9
d
23 Jun 2020 OSDI Al Khadim YK-BAG A320-212 156 19.9
2 Jul 2020 OSDI HLLB YK-BAG A320-211 156 19.9
f
11 Jul 2020 Sharjah HLLB YK-BAG A320-212 156 19.9
12 Jul 2020 OMSJ HLLB YK-BAG A320-212 156 19.9
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Maximum
23 Aug 2020 OSDI HLLQ YK-BAG A320-211 156 19.9
19 Sep 2020 OSDI HLLB YK-BAG A320-211 156 19.9
19 Oct 2020 OSDI HLLB YK-BAG A320-211 156 19.9
20 Oct 2020 OSDI HLLB YK-BAG A320-211 156 19.9
28 Oct 2020 OSDI HLLQ YK-BAG A320-211 156 19.9
g
28 Oct 2020 Tehran HLLB YK-BAG A320-211 156 19.9
03 Nov 2020 OSDI HLLB YK-BAG A320-211 156 19.9
02 Dec 2020 OSDI HLLB YK-BAG A320-211 156 19.9
08 Dec 2020 OSDI HLLB YK-BAB A320-211 156 19.9
18 Dec 2020 OSDI HLLB YK-BAE A320-211 156 19.9
21 Dec 2020 OSDI HLLB YK-BAE A320-211 156 19.9
Totals: 12,324 1,572
a OSDI. Damascus. Joint Airbase. 33°24'25"N, 36°30'34"E.

b HLLB. Benghazi. Joint Airbase. 32°07'00"N, 20°04'00"E.
c OJAI. Amman. Joint Airbase. 31°43'21"N, 35°59'36"E.
d OSLK. Latika. Joint Airbase. 35°24'03"N, 35°56'55"E.
e HL59. Al Khadim. Military Airbase. 31°59'54"N, 21°11'30"E.
f OMSJ. Sharjah. Joint Airbase. 25°19'43"N, 55°31'02"E.
g OIIE. Tehran. Joint Airbase. 35°24'58"N, 51°09'08"E.
3. The Panel thus finds that this flight activity by Cham Wings Airlines LLC has violated
paragraph 9 of resolution 1970 (2011) for the supply of (…) military (…) equipment and (…) other
assistance (…) to Libya.
4. On 11 January 2021 the World Health Organization announced on social media that Cham
Wings Airlines LLC aircraft had been used to move humanitarian supplies from the UAE to Libya
in early January 2021. The aircraft were contracted by the World Food Programme (WFP), who
were responsible for the coordination of humanitarian logistics for Libya. This resulted in
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international media interest,113 which is institutionally damaging for the UN family. A

“deconfliction” mechanism within the UN system would allow their logistics teams to identify
which airlines, aircraft, shippers, vessels etc have previously violated UN sanctions.
Image 55.H.1
Open source media coverage (4 January 2021)
Source: https://www.independent.co.uk/news/world/middle-east/un-libya-embargo-arms-aid-b1786173.html
__________________
113
For example, https://www.independent.co.uk/news/world/middle-east/un-libya-embargo-arms-aid-b1786173.html,
12 January 2021.
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Appendix J to Annex 55: ZetAvia LLC in support of HAF

1. The Panel has identified the ZetAvia LLC cargo aircraft shown in table 55.J.1 as of interest
to the Panel. The Panel has identified the flights shown in table 55.J.2 for ZetAvia LLC aircraft
into Libya. ZZZ codes are also often used for these flights. Note the random nature of the flights
and lack of an obvious schedule.
transponders are not visible on open-source ADS-B monitoring115 shortly after entering Egyptian
airspace; 2) the number of unscheduled flights on a previously little used route; 3) the flights are
often from military air bases; and 4) there have been no responses to the Panel’s request for
information from the airline.
Table 55.J.1
ZetAvia LLC aircraft of interest to the Panel
Listed Beneficial
Owner Executive
A/C # A/C type Registered Operator Owner Director
UR-CIF IL-76TD Ukraine ZetAvia LLC a Technoline FZE, b UAE
UR-CIG IL-76TD Ukraine ZetAvia LLC Technoline FZE, UAE
a
www.zetavia.net. 5 Vyzvolyteliv Boulevard, Kiev 026600, Ukraine. +380 44 528 0959 / +971 6 744 1011. (office_za@ukr.net).
b
No corporate web presence. Sharjah Airport Free Zone, Sharjah, UAE. +971 65 578170. +971 65 573127. (technoline@nsc.ae).
Table 55.J.2
Suspicious flights from UAE by ZetAvia LLC operated aircraft
# Ukraine
Date A/C # A/C type From Cargo for Remarks
1 7 Mar 2020 UR-CIG IL-76TD Sweihan a TBC ▪

2 20 Apr 2020 UR-CIG IL-76TD OMAW TBC ▪
▪
6 30 Apr 2020 UR-CIG IL-76TD OMAW Ghardabiya b ▪
a
b
HLGD. Military Airbase. 31°03'38"N, 16°36'42"E.
__________________
114
Automatic Dependent Surveillance - Broadcast. This is a surveillance technology whereby an aircraft determines
its position from satellites and then automatically broadcasts it, enabling the aircraft to be tracked without an
interrogation signal from the ground.
115
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Table 55.J.3
Suspicious flights from Eritrea by ZetAvia LLC operated IL-76TD aircraft
Ukraine
# Date A/C # A/C type From To Remarks
a b
1 27 Nov 2019 UR-BXQ IL-76TD Assab Sidi Barani ▪
2 28 Nov 2019 UR-BXQ IL-76TD HHSB HE40 ▪
5 30 Nov 2019 UR-CIG IL-76TD HHSB Mersa Matruhc ▪
6 1 Dec 2019 UR-BXQ IL-76TD HHSB HE40 ▪
7 1 Dec 2019 UR-CIG IL-76TD HHSB HEMM ▪
8 2 Dec 2019 UR-BXQ IL-76TD HHSB HE40 ▪
11 4 Dec 2019 UR-CIG IL-76TD HHSB HE40 ▪
12 07 Feb 2020 UR-CIG IL-76TD ▪ ZAV9511
13 10 Feb 2020 UR-CIG IL-76TD ▪ ZAV9511
14 30 Mar 2020 UR-CIF IL-76TD ▪
15 31 Mar 2020 UR-CIF IL-76TD ▪
16 04 Apr 2020 UR-CIG IL-76TD ▪ ZAV9511
a
HSSB. Military Airbase. 13°04'18"N, 42°38'42"E.
b
HE40. Military Airbase. 31°27'59"N, 25°52'41"E.
c
HEMM. Civilian Airbase. 31°19'31"N, 27°13'18"E.
3. The Panel was unconvinced of the accuracy of the flight documentation provided by ZetAvia
LLC. The Panel thus finds that this flight activity by ZetAvia LLC is a violation of paragraph 9 of
resolution 1970 (2011) for the direct supply of (…) military (…) equipment and (…) other assistance
(…) to Libya.
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Appendix K to Annex 55: HAF controlled aircraft

1. The Panel has identified the following aircraft that are directly controlled by HAF and
operating within HAF controlled territory of Libya (see table 55.K.1). The Panel considers that
most of these, if not all, are almost certainly being used to ferry the materiel delivered to Western
Egyptian airfields into HAF controlled territory in Libya. They are certainly being used to provide
logistic support to HAF within Libya; both activities being a violation of paragraph 9 of resolution
1970 (2011). More detailed information is covered in tables 55.K.2 to 55.K.3 or in appendix F to
Annex 55 for Space Cargo Inc aircraft.
Table 55.K.1
HAF controlled cargo aircraft
A/C # a Type Registered Last known aircraft Operator Owner Remarks

5A-DRS IL-76 Unregistered Libyan Arab Air Cargo b Government of Libya ▪
EY-332 AN-32B Unregistered Unknown Space Cargo ▪ See appendix F to Annex
55.
ST-EWX IL-76 Sudan Green Flag Aviation c Green Flag Aviation ▪
UP-AN601 AN-26 Unregistered Sigma Airlines LLC Space Cargo Inc d ▪ See appendix F to Annex
55.
▪ Destroyed in Libya on 5
Apr 2020.
UP-I7601 IL-76 Unregistered Sigma Airlines LLC. ▪
Reported in S/2019/914, table 8, and annexes 28 and 52.
UP-I7646 IL-76 Unregistered Jenis Air LLC e Space Cargo Inc ▪ See appendix F to Annex
55.
f
UP-I7651 IL-76 Unregistered Azee Air LLC Space Cargo Inc ▪ See appendix F to Annex
55.
UP-I7652 IL-76 Kazakhstan Jenis Air LLC Space Cargo Inc ▪ See appendix F to Annex
55.
from Benina since Jun
2020.
ex EY-409 AN-12BP Unregistered HAF ALA International FZE g ▪ Seen at Al Jufra on 25

July 2020.
▪
UP-I1805 IL-18 Kazakhstan HAF Space Cargo Inc ▪ See appendix F to Annex
55.
Unmarked IL-18 Unregistered HAF Terra Avia h ▪
(ex ER-ICS)
a
The registration number is in many cases this displayed illegally as the aircraft has been de-registered from its last registry.
b
Commercial Cargo Division of Libyan Arab Republic Air Force.
c
http://www.greenflag-sdn.com. Web link inactive.
d
www.spacecargoinc.com. (See annex AE50).
e
No corporate web presence. Massif Aeroport, Ulitsa Aeroport 4/1, Taraz, Kazakhstan. +7 7073 222119. (jenisair@mail.ru).
f
www.azeeair.com. Office 303, Building 17, Naurizbay Batir SIRIUS (Business Centre), Almaty 050004, Kazakhstan. +7
7273 469146. (gd@azeeair.com).
g
ALA International FZE. SAIF Zone 9273, Sharjah, United Arab Emirates. tpapikyan@me.com.
h
www.terraavia.com.
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Table 55.K.2
IL-76 (5A-DRS) 116
23 Jun 2003 Acquired by Libyan Arab Air Cargo. ▪ www.aerotransport.org
1 May 2020 Identified in Libya flying in support of HAF. ▪ https://twitter.com/HasairiOuais/status/125628306097

6443394/photo/1. 1 May 2020.
Table 55.K.3
IL-76 (ST-EWX)

1 Aug 2011 Acquired by Green Flag Aviation. ▪ www.aerotransport.org
4 Jun 2020 Identified in Libya flying in support of HAF. ▪ https://twitter.com/Gerjon_/status/1268467153340174

336, and
https://twitter.com/HasairiOuais/status/126846609226
5127937, 4 June 2020.
▪ Extract from video imagery analysis.
Table 55.K.4
IL-76 (UP-I7656)

Nov 2019 Acquired by Jenis Air LLC from Global Charter ▪ www.aerotransport.org
Services, UAE
Jun 2020 Identified in Libya flying in support of HAF. ▪ https://twitter.com/Gerjon_/status/128851252402
3934976, 29 July 2020.
__________________
116
All the documentation referred to in this annex is available from the Panel on request.
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Table 55.K.5
AN-12BP (EY-409)

9 Jul 2014 Acquired by ALA International FZE, UAE ▪ www.aerotransport.org
1 Apr 2015 Leased by Allied Services Limited, South Sudan ▪ Letter to Panel from company dated 30 October
(www.alliedservicesltd.com). 2020.
▪ Lease Agreement No 15/03 dated 1 Apr 2015.
4 Nov 2015 Aircraft returned to owners by Allied Services ▪ Letter to Panel from company dated 30 October
Limited, South Sudan, but stayed in storage in 2020.
Juba.
11 Dec 2015 Deregistered by Tajikistan ▪ Letter to Panel from Member State dated 15
October 2020.
26 Oct 2019 Aircraft departed Juba, South Sudan flown by Asia ▪ South Sudan CAA Pre-Flight Inspection Report.
Airways LLC of Tajikistan.
22 Aug 2020 Confirmed in Al Jufra, Libya flying in support of ▪ Confidential source.
HAF.
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Figure 55.K.1
AN-12BP (ex EY-409) in Al Jufra during May 2020
Table 55.K.6
IL-18 (Ex ER-ICS)

8 Jul 2015 Transferred to HAF by Sky Prim Air, Moldova ▪ www.aerostransport.org
▪ Reported in annex 35 to S/2017/466 and annex 52
to S/2019/914.
2016 Under Terra Avia ownership when Sky Prim Air ▪
closed down.
27 July 2020 Again identified as operating in Libya in support of ▪ https://twitter.com/Gerjon_/status/1287815982350
HAF. 766085, 27 July 2020.
29 Nov 2020 Image from www.terraavia.com website showing
ER-ICS. Note registration across wings.
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2. Analysis of satellite imagery of Benghazi (Benina) and Al Khadim taken on 24 December

2020 provides evidence of the indigenous fleet available to HAF.
Table 55.K.6
Panel analysis of aircraft deployed in Benina and Al Khadim on 24 December 2020
Confirmed Al Khadim Confirmed Benina Confirmed Panel remarks

as HAF visiting Al visiting
Type controlled Khadim a Benina a Balance
AN-12 1 1 0 ▪
AN-24/26 1 1 0 ▪
AN-32 1 1 ▪
IL-18 2 2 ▪
IL-76 7 3 1 5 0 ▪ Visitor confirmed as Flight#
RFF8040
TU-154 0 1 1 0 0 0 ▪ Visitor confirmed as TU-154M
(RA-85042)
Unidentified 3 b 5 8
Cargo A/C
a See other appendices in this annex.

b Similar size to IL-24/32.
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Figure 55.K.1
Imagery of aircraft deployed in Benina and Al Khadim on 24 December 2020
3. The Panel noted that most of the commercial operators in 2020 were UAE based, using
primarily Kazakhstan registered aircraft, as opposed to the primarily Ukrainian registered aircraft
used during 2019. On 30 July 2019, the Aviation Security Council of the Aviation Service of
Ukraine issued instructions that banned flights by all Ukrainian registered aircraft from conducting
flights into Libya due to the ‘worsening security.
4. The suspension of air operator certificates (AOC) for Azee Air LLC, Jenis Air LLC and
Sigma Airlines LLC by the Kazakhstan Civil Aviation Administration significantly reduced the
number of commercial cargo aircraft available for use on this route. This required the UAE to use
their military C-17 Globemaster aircraft to maintain their airbridge (see appendix B to Annex 55).
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Infographic for Inkas Titan-DS APV
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Wing Loong II UCAV redeployed to Egyptian airbase
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Infographic for Dahua counter-drone weapon
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HAF Pilot Training in Syria
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Infographic for KBP RPO-A Shmel
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Infographic for Dassault Mirage 2000-9
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Infographic for “Wagner” armoured vehicle
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Infographic for MIC VPK Tigr-M APV
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Infographic for T-62 main battle tank upgrade
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Infographic for ML-8 anti-lift initiator
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Infographic for interdiction of 4x4 vehicles in Malta
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Infographic for PMN-2 anti-personnel mine (APM)
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Infographic for 96L6/E C-Band acquisition radar
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Training at RMC Jordan (16 September 2020)
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Infographic for POM-2R anti-personnel mine (APM)
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Infographic for G5 155mm / 45 calibre gun howitzer
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Infographic for 128m Morava 128mm multi-barrel rocket system

(LRSCM)
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Infographic for Xiamen Mugin 4450 unmanned aerial vehicle (UAV)
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Infographic for WP Warmate loitering munition
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Airbridge non-compliance profile indicators
1. The Panel has developed a set of profile indicators of suspicious activities and
documentation that when considered collectively, cogently indicate, that an aircraft is almost
certainly carrying illicit cargo (see table 75.1). This annex summarises these indicators and
provides one case study to show their implementation.
Table 75.1
Profile indicators of airbridge
# Activity Details Remarks

1 Flight volume The number of unscheduled flights ▪ For example, over 110 flights over a three
on a previously little used route. month period indicates a centrally
organized supply chain.
2 Flight timings The majority of flights are planned ▪ Disguises the nature of cargo being
so that the cargo aircraft are offloaded from onlookers in areas where
unloaded during darkness. access is difficult to control.
3 Flight routing The flights often take off from a ▪ Civilian cargo aircraft require time in
civilian airport, then land at a civilian airports where the appropriate
military airbase before departing servicing and maintenance capabilities
on a flight track directly towards exist.
Libya. ▪ Indicative of the loading of military
related equipment.
4 Flight safety Signals from the aircraft ADS-Ba ▪ Airline captains sometimes “go dark”
transponders are not visible on when approaching Libyan airspace as a
open source ADS-B monitoringb counter-measure against being targeted by
shortly after entering Egyptian air defence systems, but usually not for
airspace. the majority of the flight.
▪ Deliberately switched off due to the
covert nature of these flights.
▪ Other legitimate flights (for example the
scheduled Afriqiyah Airlines A320 from
Benghazi to Alexandria always displays
ADS-B data).
5 Flight safety On 10 April 2020 the signals from ▪ MLAT mode transmits aircraft code,
the two aircrafts’ ADS-B heading, altitude and speed but NOT
transponders was switched to current location.
MLAT (multi-lateration) mode for ▪ Jenis Air UP-I7646 and UP-I7652.
the whole flight.
6 Flight transparency Signals from aircraft ADS-B ▪ Airlines have utilised a “blocking” service
transponders are not available for provided by some of the open source
all flights. ADS-B monitoring providers.
▪ A deliberate attempt by the airline to
avoid scrutiny and disguise covert or
illicit flights.
7 Aircraft documentation The use of fake Air Operating ▪ The Panel has identified the use of at least
Certificates (AOC). one fake AOC used to justify an ADS-B
signal blocking service.
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# Activity Details Remarks

8 Flight documentation The submission of incomplete or ▪ Fake consignees listed.
inaccurate Cargo Manifests and Air ▪ Fake consignors listed.
Waybills. ▪ Used to disguise the true nature of the
actual cargo.
▪ Customs value listed as zero.
The lack of detailed flight
▪ Failure to supply, for example: 1) Flight
documentation submitted.
Plan; 2) Aircraft Technical Log Book; 3)
Journey Flight Log; 4) Weight and
Balance Report; 5) Takeoff and Landing
Balance; and 6) General Declaration.
9 Air operator transparency Limited, inaccurate or no ▪ Indicative of covert or illicit activity.
information provided to requests
for information.
10 Air operator web presence Lack of corporate website. ▪ A reputable cargo aircraft company would
have an easily sourced online presence as
part of the company marketing strategy.
11 Cargo agency web presence Lack of corporate website. ▪ A reputable cargo agent would have an
easily sourced online presence as part of
the company marketing strategy.
12 Air operator’s relationships Corporate links ▪ Change of ownership or operating
conditions for aircraft between linked
companies.
2. In the main body of the report the Panel used one particular aircraft, IL-76TD (MSN#
1023414450) (HEX Code 600024), to illustrate the tactics, techniques and procedures (TTP) used
by aircraft owners and operators to circumvent arms embargos (repeated at figure 75.1).
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Figure 75.1
Infographic for Ilyushin IL-76TD (#1023414450)
3. As an example, table 75.2 shows the use of profile indicators against documentary evidence
obtained by the Panel for Flight Number FSQ1110 on 24 September 2020 by the then Kyrgyz
Republic registered EX-76004 operated by FlySky Airlines. The documents have not been
included for reasons of space but are available from the Panel on request.
Table 75.2
Profile indicators for flight FSQ 1110 (24 September 2020)
# Activity Details Source / Remarks

2 Flight timings Take Off Time: 23:45 hours ▪ Journey Flight Log.
Landing (+1): 04:45 hours ▪ Aircraft Technical Log Book.
▪ Night unloading.
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# Activity Details Source / Remarks

3 Flight routing Depart: Abu Dhabi ▪ Journey Flight Log.
Arrive HE40 (Sidi Barani) military air ▪ Aircraft Technical Log Book.
base ▪ Indicative of the loading of military related
equipment.
4 Flight safety No signals from the aircraft ADS-Ba ▪ “Go Dark” counter-measure to disguise route.
transponders shortly after entering
Egyptian airspace.
6 Flight transparency Signals from aircraft ADS-B ▪ A deliberate attempt by the airline to avoid
transponders blocked from showing on scrutiny and disguise covert or illicit flights.
open source ADS-B monitoring
providers.
8.1 Documentation Air Waybill incomplete ▪ Cargo customs value zero.
▪ Shipper and Consignee (Khalifa Foundation,
Abu Dhabi) almost certainly fake.
▪ Issued by the previous air operator, Azee Air
LLC and not FlySky LLC the current operator.
Demonstrates link between companies.
▪ Cargo only 27,000kg against max load of
48,000kg.
▪ Unsigned and unstamped.
8.2 Documentation Cargo Manifest incomplete ▪ Goods listed as Foodstuffs and Medicines with
no detail.
▪ Issued by FlySky LLC and not the issuer of the
Air Waybill (Azee Air LLC).
▪ Unsigned and unstamped.
8.3 Documentation General Declaration ▪ Date inaccurate as shows 25 not 24 September
2020.
▪ Destination inaccurate as shows Alexandria,
Egypt not HE40.
▪ Officially stamped by UAE officials, thus
demonstrating their acquiescence to covert
nature of flight.
8.4 Documentation Flight Plan ▪ Accurate as filed by Aircraft Crew.
8.5 Documentation Journey Flight Log ▪ Accurate as Aircraft Captain responsible.
8.6 Documentation Weight and Balance Log ▪ Accurate as Aircraft Captain responsible.
8.7 Documentation Takeoff and Landing Balance ▪ Accurate as Aircraft Captain responsible.
9 Air operator Zero ▪ Failed to respond to Panel enquiries.
transparency
10 Air operator web No social media presence ▪ Unusual for a commercial charter air company
presence not to have a customer point of contact to
attract business.
▪ Indicative of covert or illicit activity.
12 Air operator’s Close links to arms violating air operator ▪ Cargo Manifest shows Azee Air LLC.
relationships Azee Air LLC
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4. The documentary analysis completed at table 75.2 above shows 18 separate indicators of
suspicious activity that a legitimate commercial air cargo flight would not show, and thus it beyond
any reasonable doubt that this flight was illicitly moving cargo to an airfield known to be part of
the airbridge supplying military materiel to HAF. That cargo originated in a State known to be a
military supporter and supplier to HAF. The Panel thus finds that this flight was a violation of the
arms embargo and that the air operator, FlySky LLC, were responsible for the violation.
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Project Opus PMC operation
A. Introduction
1. In June 2019 the Panel identified a well-funded private military company (PMC)117
operation designed to provide armed groups affiliated to Khalifa Haftar (HAF) with: 1) a maritime
interdiction capability to target the sea line of communication (SLoC) supplying weapons from
Turkey to the Government of National Accord (GNA) in Tripoli;118 2) an assault rotary wing
capability to identify and strike land targets, and terminate and/or kidnap high value targets; 3) an
airborne intelligence, surveillance and reconnaissance (ISR) capability; 4) a Fusion and Targeting
Cell (FATC) with a cyber capability to be based at Benghazi (Benina) international airport; and 5)
an unmanned aerial vehicle (UAV) group.119 A timeline for ease of reference, and which helps
explain the operation is at appendix A.
2. The operational planning was well advanced until the procurement of the original aircraft
for the operation from the Government of Jordan (GOJO), which included two AH-1F Cobra and
five MD530 attack helicopters, was disrupted. This necessitated the emergency procurement and
deployment of six civilian registered, but originally ex-military, unarmed helicopters from South
Africa for the operation to continue. A commercial Antonov AN-26 transport aircraft, a unique
Pilatus PC-6 intelligence, surveillance and reconnaissance (ISR) aircraft and a specialist Light
Attack and Surveillance Aircraft (LASA) T-Bird were also rapidly procured for the operation from
companies controlled by Erik Dean Prince (USA).120
3. The initial deployment of the maritime and rotary wing aviation components took place from
Amman, Jordan (on, or about, 25 June 2019), Valetta, Malta (26 June 2019) and Gaborone,
Botswana (28 June to 2 July 2019). The maritime and assault rotary wing aviation phase of the
operation was suddenly aborted on the evening of 29 June 2019. This resulted in twenty private
military operatives making a 36-hour, 350 nautical mile sea crossing from Benghazi in the two
‘special forces’ specification rigid hulled inflatable boats procured for the operation; one of which
was abandoned on route. The single RHIB arrived in Valetta, Malta at approximately 13:00 hours
1 July 2019. The decision to evacuate made by the Ground Team Leader, Steven John Lodge
(South Africa), was taken due to the adverse reaction of Khalifa Haftar when he realised that the
aviation assets deployed (the South African helicopters) were not those that had been promised
during the planning stage of the alleged US$ 80 million contract.
4. The PMC operation involved at least thirty-one individuals from six Member States (Australia,
France, Malta, South Africa, the United Kingdom, and the United States). Planning, procurement,
logistic support and/or operational activities took place in eight countries (Angola, Botswana, Jordan,
__________________
117
Which the Panel will refer to as “Project Opus”. Two deployments have now been identified, which will be
referred to as Project Opus A and Project Opus B.
118
This would be consistent with the announcement of a, then, forthcoming naval blockade made by HAF naval
commander Faraj al-Mahwadi on 20 May 2019. https://www.janes.com/article/88731/lna-announces-naval-blockade-
of-western-libya, 23 May 2019.
119
The Panel is still investigating the FATC and UAV capabilities.
120
Erik Dean Prince was previously named in relation to with violations of UN arms embargoes in paragraph 61 of
S/2012/544, the 2012 Somalia report of the Monitoring Group on Somalia and Eritrea submitted in accordance with
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Libya, Malta, South Africa, the United Arab Emirates and the United States). Three United Arab
Emirates based companies were primarily used for the planning, management and finance of the
operation: 1) Lancaster 6 DMCC, 2) L-6 FZE; and 3) Opus Capital Asset Limited FZE. These
companies were directly controlled and managed by Christiaan Paul Durrant (Australia) and
Amanda Kate Perry (UK),121 with Steven Lodge having contract representative rights.
B. Background
5. This section has been included to show that Erik Prince, a close associate and friend of
Durrant, has maintained a keen interest in the deployment of a private military capability to Libya
since at least 2013, when he first developed a proposal to help “stabilise eastern Libya”.122 This
was named Operation Lima and included the deployment of aviation assets and a maritime
capability very similar to that proposed for Project Opus A. The proposal did not find any backers
prepared to take the risks such an operation presented.
6. In early 2015 Erik Prince supplied the use of a private jet123 to Khalifa Haftar through the
auspices of Frontier Services Group (FSG), of which he was then the Chairman. This aircraft made
flights with timings and itineraries that coincided with Khalifa Haftar’s rise to Head of the LNA.124
7. During 2015 Erik Prince repackaged the Operation Lima proposal and developed a joint
concept with Khalifa Haftar for a private military operation to counter the illegal migrant
trafficking from Libya. This project was similar in concept to that used for Project Opus. He failed
to attract funding from “the EU (…) and Libyan Investment Authority money frozen in European
banks“ and his project to introduce a private military capability into Libya was again stalled.125
8. Following an Op-ed on Libyan border security in the Financial Times126 on 3 January 2017
Erik Prince appeared in a CNN interview127 to publicize his idea for a public/private partnership
to deploy a private military intervention to counter illicit migration from Libya. This concept,
repackaged as a private police force, was then proposed by Erik Prince in an interview with Italian
media, Corriere de la Sera, on 29 November 2017.128 It was also reported129 that he was to meet
__________________
121
Although Durrant confirmed to the Panel during an interview on 16 September 2019 that he was the Managing
Director of all three companies, the Panel obtained documentary evidence signed by Amanda Kate Perry as Managing
Director. Also the UAE company documentation shows her as the legal Managing Director of, at least, L-6 FZE. The
title of Managing Director/CEO seems to have been adopted by whichever individual was negotiating or signing
contracts.
122
https://theintercept.com/2016/03/24/blackwater-founder-erik-prince-under-federal-investigation/, 24 March 2016.
123
9H-PAL owned by FSG Aviation and operated by a Maltese company..
124
Confidential source (CS4 and CS30). Letter from air operator dated 20 January 2021.
125
1) https://theintercept.com/2016/03/24/blackwater-founder-erik-prince-under-federal-investigation/, 24 March
2016; and 2) https://libyafiles.com/chapter-nine-the-kingmaker/ (un-numbered paragraph 14).
126
https://www.ft.com/content/d95057a2-c907-11e6-9043-7e34c07b46ef, 3 January 2017.
127
https://edition.cnn.com/videos/world/2017/01/18/erik-prince-blackwater-anderson-intv-ctw.cnn, undated.
128
1) https://www.corriere.it/esteri/17_novembre_24/re-guerra-privatae-suo-piano-la-libia-0d5f8d1c-d08a-11e7-90be-
0a385e484c27.shtml, 23 November 2017; and 2) https://www.independent.co.uk/news/world/middle-east/blackwater-
migrants-libya-europe-enter-private-police-force-us-committee-hearing-a8084346.html, 30 November 2017.
129
https://www.theguardian.com/world/2017/nov/30/blackwater-founder-pitches-plan-to-quell-libya-migrant-crisis-
with-private-police?CMP=share_btn_tw, 30 November 2017.
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Libyan Prime Minister Fayez Serraj in the White House on 1 December 2017 to propose his plan.
Although no reports emerged that such a meeting ever took place with Prince, the visit of Prime
Minister Serraj to the White House that day has been confirmed.130
9. On 11 January 2017, Erik Prince held a meeting in the Seychelles with Kirill Dmitriev, the
Chief Executive Officer of Russia’s Sovereign Wealth Fund. During the meeting he made it clear
that “Libya was off the table” and that the US government could not accept any Russian
involvement in Libya.131 The Panel has not established whether Erik Prince was authorized to
speak on behalf of the US government at that meeting.
10. In S/2017/416132 the Panel reported on the presence of AT-802i light attack and surveillance
aircraft at Al Khadim airbase in Libya in early 2017 as a violation of the arms embargo. These
aircraft were initially supplied to the United Arab Emirates, who have never responded to the
Panel’s requests regarding the supply chain to Libya. During 2017 open sources133 reported that
companies134 controlled by Erik Prince had supplied the foreign mercenary pilots for these attack
aircraft. The supply of mercenaries would be violation of paragraph 9 to resolution 1970 (2011)
and Panel investigations continue into this matter.
11. It is thus clear that Erik Prince has been attempting to deploy a small scale aviation and
maritime private military capability into Libya since 2013. The scale, organization and systems
proposed were all similar to those deployed on the private military operation Opus in eastern Libya
that is the main focus of this investigation.
C. Operational planning for Opus A

12. The PMC referred to this operation as “Operation Regain Libja”.135 Figures 76.1 to 76.4 are
extracts from a PowerPoint presentation136 used to explain the operational plan. Sources have
indicated that Erik Prince verbally briefed the operation to Khalifa Haftar in Cairo, Egypt on, or
about, 14 April 2019,137 but the PowerPoint presentation may not have been used at that meeting.
The presentation makes it very clear that the plan involved the deployment of a kinetic strike and
assault capability, with the intention to make “hot dynamic” attacks on high value targets (HVT).
__________________
130
https://www.whitehouse.gov/briefings-statements/readout-president-donald-j-trumps-meeting-prime-minister-fayez-
al-sarraj-libya-2/. Accessed 10 November 2020.
131
US Department of Justice updated version of Report On the Investigation Into Russian Interference in the 2016
Presidential Elections. “Mueller Report”, pp 153 - 154. Accessed through
https://assets.documentcloud.org/documents/20401632/updated-mueller-report-leopold-foia-11220.pdf. Accessed 8
November 2020.
132
Paragraphs 126 to 128.
133
1) https://www.intelligenceonline.com/pdf/corporate-intelligence_the-red-line/2017/01/11/erik-prince-to-uae-s-
rescue-in-libya,108196431-art, 11 January 2017; 2) https://sofrep.com/news/erik-princes-mercenaries-bombing-
libya/, 14 January 2017; and 3) confidential source.
134
Reflex Responses (R2) then probably Frontier Resource Group Limited (https://frontierresourcegroup.com/#1) or
a linked company.
135
Libja is the Maltese spelling for Libya. Christiaan Durrant was resident in Malta at the time of planning, which
may explain the use of this spelling.
136
Confidential source (CS4).
137
From one confidential source present at the meeting (CS27), and from one confidential source with knowledge of
the meeting (CS4 from CS8).
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Only one of these HVT has the initials ‘DNT’ standing for Do Not Terminate after their name, which
suggests that the others could be killed or captured. The Panel considers it likely that the HVT list
was provided as an example by the Opus A team and was not developed by HAF as they would be
unlikely to include two targets that were then known by them to be non-resident in Libya.
Slide 2: Executive Summary Slide 11: Kinetic Operations – Strike Package Cobra

Slide 12: HVT Extraction – MD530 Slide 17: HVT (Hot, Dynamic)
13. A copy of a second similar PowerPoint presentation138 was used during the briefing of the
private military operatives prior to their deployment. There are significant differences between the
two presentations, which are summarised in appendix B. The Panel notes that in the alternative
pre-deployment presentation made to the PMC operatives the HVT list was not included, and only
the term “HVT extraction” rather than “HVT termination” was mentioned. Similarly, the use of
AH-1 Cobra or MD530 attack helicopters is not mentioned in the presentation slides for the PMC
__________________
138
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operatives. The PMC operatives’ presentation also reassuringly covers the aeromedical and search
and rescue capability in some detail.139
14. The Panel obtained a copy of an Opus report dated 18 June 2020,140 which then confirmed
much of the content of the presentations. The veracity of this document is not in doubt and its
authenticity was confirmed by Christiaan Durrant during his interview with the Panel on 16
September 2020. The Panel has a full authenticated transcript, which provides clear evidence as to
the true purpose of Project Opus A.
15. In summary this document confirms many of the details of the PowerPoint presentations
above and:
(a) Reports that a Cyber team, and a Satellite team were already active and targeting in
Libya. The Fusion and Targeting Cell (FATC) and an Unmanned Aerial Vehicle
(UAV) team were to join them at Benghazi airport;
(b) States that the Government of Jordan (GOJO) had cancelled clearances for the
deployment of equipment from Jordan to Benghazi, which included air ammunition,
ground weapons, ground ammunition and night vision;
(c) Makes it clear that, although Opus personnel had inspected the GOJO owned
COBRA attack helicopters and MD530F helicopters, and had selected weapons, that
the GOJO had blocked the sale and movement of these attack aviation assets;
(d) Explained that the deployment of the AS 332141 Super Puma and Gazelle helicopters
had to be by IL-76 cargo aircraft from Botswana due to aircraft noise restrictions in
South Africa;
(e) Reported that an ISR aircraft was being deployed, via Amman, to support a vessel
board search and seizure (VBSS) capability;
(f) Reported that the Marine Strike Group of two high speed special forces RHIBs were
ready in Malta awaiting the Advance Team arrival in Benghazi. The vessels to be
modified with 7.62 Bow Mount142 and ready for operations within 2 days of arrival;
and
(g) Explained the impact of the withdrawal of GOJO support to the operation and that
they were now executing their contingency plan for lack of GOJO support.
16. The Panel has confirmed with a senior military officer in Jordan143 that the activities of the
Project Opus team in Jordan raised suspicions at the highest levels of the Jordanian Armed Forces
as to the legitimacy of the operation. That officer met with Christiaan Durrant in mid-June 2019,
__________________
139
Christiaan Durrant claimed to have no knowledge of the presentations during his interview with the Panel on
16 September 2020, claiming that they used specifically USA military language, which as an Australian he would
not use. He did not respond when it was pointed out to him that in his introduction, he had admitted to spending
some time as an exchange officer with the Pentagon, whilst serving in the RAAF, and would thus be highly
knowledgeable of such linguistics as a result.
140
141
These are the Super Puma helicopters procured from Starlite Aviation Group (see later).
142
Purpose being to mount a 7.62mm medium machine gun.
143
Confidential source (CS10). See extracts of exchange between this individual and the Panel at appendix C.
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during which Christiaan Durrant introduced himself to the officer using a false name “Gene
Rynack”.144 Christiaan Durrant informed him that they had “clearances from everywhere” and that
the operation was cleared at the “highest level”. This did not satisfy the senior military officer who
raised the issue with his superiors, the result of which was that instructions were issued at the
highest level of the Royal Jordanian Armed Forces to provide no GOJO support and to close the
operation down. At a second meeting with Christian Durrant on, or about 11 July 2019, the senior
military officer instructed him to leave Jordan at the earliest possible opportunity with all his
equipment and aircraft.
D. Procurement
17. The Panel was initially informed by a confidential source in late June 2019 that recruitment
for a PMC intervention into Libya was taking place in South Africa.145 Soon after, on 29 June 2019,
social media reports and imagery emerged of three white-painted Super-Puma helicopters being
transported on low-loaders through the Eastern Rand in Guateng heading for the Botswanan border
(see figure 76.5). A Member State subsequently confirmed to the Panel that the helicopters passed
through the Tiokweng Border Checkpoint (BCP) from South Africa into Botswana on 28 June 2019.
Figure 76.5
Three Super-Puma helicopters being transported to Sir Seretse Khama International Airport (SSKIA),
Gaborone, Botswana (27 June 2019) a
a
https://m.facebook.com/story.php?story_fbid=10156741412697620&id=323811752619&__tn__=-R, 29 June 2019.
b
Also reported in www.vryeweekblad.com/nuus-en-politiek/2019-08-09-sa-huursoldate-gewaarsku-oppas-vir-di-
operasie-in-libi/, 9 August 2019.
__________________
144
The Australian actor Mel Gibson plays Gene Ryack in the film Air America about a private CIA funded airline.
145
Confidential source (CS1). Confirmed on 2 August 2019 when Eeben Barlow, Head of STEPP International
(www.sttepi.com) warned that his company was being used as a “false flag” to recruit private military operatives for an
operation in Africa (www.facebook.com/eeben.barlow.7, 2 August 2019). Subsequent investigations by the Panel
established that this was for a PMC operation being tendered for by the same company for a separate PMC intervention
in a Southern African country. 1) https://www.defenceweb.co.za/aerospace/military-helicopters/unmarked-gazelle-
helicopters-spotted-in-mozambique/, 12 August 2019; and 2) https://www.africaintelligence.com/ion/corridors-of-
power/2019/09/06/erik-prince-makes-up-for-army-shortcomings,108371379-art, 6 September 2019.
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1. SA341 Gazelle Helicopters

18. Three SA341 Gazelle light utility helicopters (LUH) (ZU-HFV Serial #1797, ZU-RNO
Serial #WA1999 and ZU-ROF Serial #1210) were procured from Fulcrum Holdings Limited
(UAE) on 17 June 2019 by Steven John Lodge representing L-6 FZE. The purchase price of
€1.95M was settled from an Opus Capital Asset FZE bank account.146 (Relevant documentary
evidence is at appendix D). Steven Lodge told the company that the helicopters were to be used in
Mozambique.147
2. AS332L Super Puma Helicopters

19. Three AS332L Super Puma medium utility helicopters (MUH) (Serial # 2032, 2154 and
2161) were procured on, or about, 20 June 2019 by L-6 FZE from Starlite Aviation (RSA).148
Christiaan Durrant participated in these negotiations.149 The helicopters were deregistered with the
Civil Aviation Authority of South Africa with transfer to Jordan declared as the reason. The
purchase price of approximately US$10.9M150 was settled from an Opus Capital Asset FZE bank
account. Starlite Aviation were informed by Amanda Perry, signing as Managing Director of L-6
FZE, that the helicopters were being procured for a ‘geological survey contract in Jordan’ (see
Cover Stories later). (Relevant documentary evidence is at appendix E).
E. Logistics
20. The helicopters were moved from South Africa to Botswana on low-loader transporters
between 26 and 27 June 2019.151 The ground logistics were arranged by Willie van den Stoep152
through Panzer Logistics (Proprietary) Limited.153
21. The ‘Single Administrative Document’ necessary for the import into, and export from,
Botswana of the three SA341 Gazelle helicopters listed: 1) the Consignor as Aviator at Work
__________________
146
The Panel has yet to establish if this was from an Opus Capital Asset Limited FZE or Opus Capital Assets DMCC
bank account.
147
Confidential source with close knowledge of the sale (CS3). This source also mentioned that Opus and L6 “were
Erik Prince”. This source also identified Christiaan Durrant as the “Head of Operations for OPUS”.
148
www.starliteaviation.com.
149
150
At US$1 = ZAR 14.1269 on 28 June 2019. Data from customs declaration.
151
Interview with confidential source of 4 December 2019.
152
Willie van den Stoep was an employee of Stephen John Lodge in his company Umbra Aviation (Proprietary)
Limited (#K2017168000). 110 Bronkhorst Street, Greonkloof, Pretoria, Guateng 0181, South Africa and Imboneni
Helistop, 4 Barber Road, Imbonei Industrial Park, Shakas Rock, Kwa-Zulu Natal, South Africa. www.umbra-
aviation.com. Website closed in late 2019. The Panel has documentary evidence that UMBRA Aviation is also a private
military company, that unsuccessfully bid for an assault rotary wing aviation contract in Mozambique in 2019 code
named the “MNGWA Program”. The Umbra Aviation proposal was similar in design to that of Project Opus A, and
proposed utilising the same aircraft types. Steven Lodge and Christiaan Durrant are 50% Shareholders and Directors of
UMBRA.
153
http://chelwood.bloombiz.com/, accessed 25 January 2020. The company engaged legal representation and insists it
will only cooperate with the Panel in face to face meetings. COVID-19 has stopped Panel travel to South Africa for this
interview. .
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(Proprietary) Limited (South Africa);154 2) the Cargo Agent as Speedway Freight (Proprietary)
Limited (Botswana);155 and 3) falsely listed the Consignee as Jordan Aeronautical Cargo Company
(Jordan) and destination as Amman, Jordan.156 (See appendix F).
22. The ‘Single Administrative Document’ for the three AS332 Super-Puma helicopters listed:
1) the Consignor as Starlight Maintenance JHB (South Africa); 2) the Cargo Agent again as
Speedway Freight (Proprietary) Limited (Botswana); and 3) falsely listed the Consignee again as the
Jordan Aeronautical Cargo Company (Jordan) and destination as Amman, Jordan. (See appendix G).
23. The helicopters were transported by air from Gaborone international airport (FBSK) in
Botswana to Benghazi, Libya (HLLB)157 by two Ilyushin IL-76TD aircraft. The IL-76TD aircraft
could not fly the helicopters direct from South Africa as their engine emissions did not comply
with the South African aircraft carbon emission regulations, hence the use of Gaborone (FBSK).
The six helicopters were flown from Gaborone (FBSK), via Angola (FNLU) to Benghazi (Benina)
international airport (HLLB) on 29 June, 1 July and 3 July 2019 respectively (see table 76.2). The
airlines used were: 1) Sky AviaTrans LLC,158 operating an Ilyushin IL-76TD (registration number
UR-COZ);159 and 2) ZetAvia LLC,160 operating an Ilyushin IL-76TD (registration UR-CIB).
Table 76.2
IL-76TD (UR-COZ and UR-CIB) aircraft flights from Gaborone (FBSK) to Benghazi (HLLB) a
Departure Date # Flight # From To Remarks

29 Jun 2019 UR-COZ KTR7722 Gaborone Benghazi ▪ Dismantled AS332L Super-Puma
(FBSK) (HLLB) helicopter (Serial# 2161)
29 Jun 2019 UR-CIB ZAV9002 FBSK HLLB ▪ 3 x dismantled SA341 Gazelle helicopters
(Serial #1797, WA1999 and 1210)
1 Jul 2019 UR-CIB ZAV9004 FBSK HLLB ▪ Dismantled AS332L Super-Puma
helicopter
3 Jul 2019 UR-CIB ZAV9006 FBSK HLLB ▪ Dismantled AS332L Super-Puma
helicopter
a Member State.
__________________
154
The company is actually called Aviation at Work Limited at the same address, Wonderboom Airport, Hangar 76,
Tswane, South Africa. The company was offered an opportunity to respond on 23 January 2020 but has yet to make
contact with the Panel. The Panel cannot be sure whether the spelling error for the name on the documentation was
accidental, or a deliberate ploy to make tracing more difficult should there be an investigation.
155
http://www.speedwayfreight.net/. The company was offered an opportunity to respond by Panel letter of 23 January
2020 and are content with the information contained regarding their company.
156
No such company is traceable on any aviation databases or company lists of Jordan consulted by the Panel. A Panel
letter was sent to the Member State on 16 September 2019. A response is still awaited.
157
Four letter International Civil Aviation Authority (ICAO) codes identify specific airports.
158
www.skyaviatrans.com.ua/about-us/. The company was informed of the Panel’s findings at a meeting in Kiev,
Ukraine on 6 November 2019. They made no comment.
159
IL-76TD UR-COZ also illicitly flew military materiel into Misrata, Libya for use by the GNA between 3 – 6 July
2019 and 21 July 2019. It was destroyed in Misrata on 5 August 2019. See paragraphs 117 and 119, table 7 and annex
27 to Panel report S/2019/914.
160
www.zetavia.net/en/. The company was informed of the Panel’s findings at a meeting in Kiev, Ukraine on 6 November
2019. They made no comment.
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24. The Air Waybill for the flight on 29 June 2019 by the Sky AviaTrans LLC IL-76TD (UR-
COZ) (KTR7722) listed the consignee as Steven Lodge, Opus Capital Asset LLC, with the correct
destination of Benghazi (see appendix H). The Air Waybills for the flights on 29 June, 1 July and
3 July 2019 the ZetAvia LLC IL-76D (UR-CIB) flights falsely declared the consignee as a Jordanian
company in Amman in an attempt to disguise the final destination (see appendix J), but all the aircraft
flight logbooks clearly showed the real destination as Benghazi (see appendix K).
25. The Panel has established that the Air Waybills were prepared by the Cargo Agent,
Speedway Freight (Proprietary) Limited (Botswana), but that during the preparation of the
documents they were personally instructed as to the consignee in Jordan by a Mr Franco Mariotti,
who left a business card stating he was from Global Africa Aviation South Africa and
Zimbabwe.161 This intervention was approved by Willie van den Stoep, who had also arranged the
charter of the IL-76 through the auspices of International Worldwide Air Services Inc (UAE)
(IWAS) (see appendix L). IWAS sub-contracted the charter to Reem Style Travel and Tourism
LLC (UAE).162
26. The logistics surrounding the transfer of the helicopters to Libya were complex and opaque
and are summarised at figure 76.6.
__________________
161
http://www.globalaa.net/. The individual was offered an opportunity to respond by Panel letter of 27 January 2019 to
his company. He has yet to respond.
162
www.reemtravel.com.
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Figure 76.6
Summary of helicopter transfer logistics
3. Antonov AN-26B aircraft

27. On 22 July 2019, L6-FZE officially completed the procurement of an Antonov AN-26B
aircraft (registered UR-MDA) from FSG Aviation Limited, Bermuda, which is an Erik Prince
controlled company.163 The Panel notes that the transfer of funds (EUR 650,000) to FSG Aviation
Limited was made from a Lancaster-6 DMCC bank account on 28 June 2019, three weeks before
the official completion of sale documentation, and a day after the arrival of the aircraft in Jordan
on 27 June 2019. This is indicative of: 1) a need to deploy an asset very quickly; and 2) rapid
decision making within the upper echelons of a company to approve a sale without normal due
diligence. The Panel also has evidence that Christiaan Durrant was marketing the use of this
aircraft for a potential medevac mission in Libya in May 2019 and thus, although officially owned
by FSG Aviation at the time, was operationally available for Lancaster6 DMCC to market and use.
He used his serge@l-6group.com email address and made it clear that “our AN26” was available
“but about to go on contract”.164
__________________
163
FSG Aviation (Bermuda #48669) is 100% owned by Frontier Services Group (Bermuda #48669) (www.fsggroup.com)
of which Erik Prince is the Executive Director and Deputy Chairman. The Panel has copies of the Certificates of
Incorporation and List of Directors and Shareholders. Source: Member State.
164
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28. The Panel further identified that L-6 FZE took action to dispose of this asset on 28 December
2019, based on a bill of sale dated 11 November 2019. This is after the Panel made first contact with
individuals involved in Project Opus A and the first letter received from their common legal counsel
on 7 October 2019. Company bank accounts had also been closed.165 An infographic summarising
the procurement activities surrounding this aircraft and documentary evidence is at appendix M.
4. Pilatus PC-6 B2-H4 aircraft (serial #790)
29. On 22 May 2019, TST Humanitarian Surveys LLC (USA) (TST) (Delaware #5112541) sold
a Pilatus PC-6 aircraft (serial #790) (registered in USA as N354AK) to Airborne Technologies
GmbH (Austria), who then registered the aircraft in the Netherlands on 22 May 2019 as PH-ABT.
The aircraft was subsequently observed at the Cycloon Holland B.V. (www.cycloonholland.nl)
facility in Maastricht-Aachen Airport undergoing maintenance work. On, or about, 24 June 2019
the aircraft was then sold by Airborne Technologies GmbH to Lancaster6 DMCC, although the
new owner was declared as L-6 FZE. On 25 June 2019166 the aircraft deployed to Libya via Cyprus
piloted by Travis Alden Maki (US).167 On 27 June 2019, the Netherlands authorities were
informed that ownership of the aircraft had changed to L-6 FZE. The aircraft was deregistered by
the Netherlands authorities on 3 July 2019 purportedly on transfer to the UAE Civil Aviation
Authority registry.
30. The Panel notes that this aircraft had been previously used by Bridgeporth Limited (UK)
whose documentation was used for the first cover story of Project Opus A (see Cover Stories). The
Panel also identified that this aircraft was owned by Xe/Greystone prior to sale to TST in early
2012. The Panel has copies of Emails168 relating to the sale of the aircraft from Xe to TST between
John Hazebrouk Palen III (Director of TST), Don M Lansky169 (family lawyer of Erik Prince) and
Erik Prince regarding the initial purchase and operation of this aircraft by TST. This demonstrates
Erik Prince has maintained control over this aircraft for quite some time.
31. The PC-6 ISR aircraft (serial #790) was retro-fitted by Airborne Technologies GmbH with
a self-contained aerial reconnaissance (S.C.A.R) pod under each wing.170 The port S.C.A.R pod
contains a FLIR Ultraforce 350 High Definition multi-spectral, multi-imagery sensor surveillance
system.171 The high definition and thermal imagery optical systems are optimized for covert
airborne security, combat, patrol, surveillance and reconnaissance operations. The product is
specifically advertised as having no US sourced components meaning it is not in itself subject to
__________________
165
Letter from Opus legal counsel of 19 June 2020. It did not provide dates of closure. Opus legal counsel have stated
that some accounts were forcibly closed but did not provide details. When asked about specific bank accounts relating
to the operation, they only responded that they had been closed, implying by the account holding company.
166
Statement by Stephen Lodge to Panel of 13 September 2020 and letter from the Opus legal counsel (regarding
Travis Maki) dated 12 November 2020.
167
Letter from Opus legal counsel dated 15 December 2020.
168
Dated 5 July 2012.
169
https://couzens.com/attorneys/donald-m-lansky/. Accessed 11 October 2020.
170
See the imagery at https://www.airbornetechnologies.at/platforms/fixed-wing/pilatus. Accessed 29 December
2020.
171
https://www.flir.co.uk/products/ultraforce-350-hd/. Accessed 14 June 2020.
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US International Traffic in Arms Regulations (ITAR) controls.172 This FLIR system is

manufactured in Sweden.173 The Panel was informed by the Swedish National Inspectorate of
Strategic Products174 that, the system is a dual use product subject to export controls. It is classified
under European Council Regulation (EC) 428/2009175 as 6A003.b.4 ‘imaging cameras‧
incorporating "focal plane arrays"’.
32. It allows for the download of real time video imagery linked to geo-coordinates. Aside from
search and rescue, there are no real commercial operations requiring such a capability, particularly
when paired with a synthetic aperture radar. As can be seen from the manufacturers example
imagery at figures 76.7 and 76.8 it is an ideal system for the identification and targeting of high
value targets (HVT).
Manufacturers FLIR Image (Day) Manufacturers FLIR Image (Thermal)
33. The starboard S.C.A.R pod contains a Thales I-Master lightweight surveillance synthetic
aperture radar176 for the detection of ground targets (vehicles >35km and persons >15km) and
maritime targets (large vessels > 100km). It can survey up to 800 km2 an hour, in any one of four
modes: 1) Ground Moving Target Indicator to detect movement; 2) Synthetic Aperture Radar for
all weather detection (see figures 76.9 and 76.10); 3) Coherent Change Detection to highlight
changes over time (see figure 76.11; and 4) Maritime Moving Target Indicator (> 56 nm). The
Panel accepts that this system may have wider roles such as deforestation identification, pollution
control or monitoring, but there is no commercial demand for such roles in Libya at the moment.
The system is primarily deployed on military equipment, such as the UK Watchkeeper ISR UAV.
__________________
172
It may still be subject to US jurisdictions when in the possession of a US citizen and would certainly require
authorization to re-transfer to a foreign person in Libya. It would then fall under Bureau of Industry and Security
Category 6A003.b.4.a ‘Cameras, systems or equipment, and “components” therefor’.
https://www.bis.doc.gov/index.php/regulations/export-administration-regulations-ear, Category 6, page 14.
173
Email from FLIR corporate HQ of 20 January 2021.
174
www.isp.se. Email of 21 January 2021.
175
Council Regulation (EC) No 428/2009 of 5 May 2009 ‘setting up a Community regime for the control of exports,
transfer, brokering and transit of dual-use items’. https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32009R0428, Annex I.
176
https://www.thalesgroup.com/en/countries/europe/united-kingdom/markets-we-operate/defence/air-systems-uk/isr-
air/imaster. Accessed 14 June 2020.
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Figure 76.9 Figure 76.10 Figure 76.11

SAR Image SAR Activity Change CCD Past Activity
34. In view of this combination of dual-use technology, and the only credible operational
requirement for such a pairing on one platform, the Panel finds that this aircraft is military
equipment under the auspices of paragraph 9 to resolution 2011(1973).
35. This L-6 FZE owned PC-6 ISR aircraft (#790) deployed to Libya on 25 June 2019.177 The
Panel finds that this in itself was a transfer of military equipment and thus a violation of paragraph
9 of resolution 1970 (2011) by L-6 FZE and their pilot, Travis Maki.178
36. The Panel has identified a Pilatus PC-6 aircraft fitted with underwing pods operating
throughout eastern Libya between 19 September 2019 and 29 December 2020.179 The PC-6 has a
unique design, which means that photogrammetry can be used to confirm the specific aircraft type
against the limited resolution commercial imagery available to the Panel.180 The dimensions are
then confirmed by an overlay used for check comparison.
37. An infographic summarising the procurement activities surrounding this aircraft and details
of operational sightings is at annex N. In a response to a Panel enquiry for a copy of the current
registration certificate for the aircraft the legal representative of L-6 FZE stated that their client
“does not hold this document or equivalent “. The Panel does not find this response credible as
either: 1) this is a key document relating to the operation and history of the aircraft; or 2) the
aircraft is flying unregistered, which is in itself illicit.
38. The deployment of this Pilatus PC-6 ISR asset provides the Opus FATC with a highly
capable ISR asset to support its operational work. The Panel wishes to emphasise that a FATC,
partnered with an on-call Pilatus PC-6, is a force multiplier for the operational aviation assets
available to HAF. It is, perhaps, one of the most significant components of the Opus contribution
to HAF, and that contribution should not be discounted purely due to the failure of the aviation
and maritime component in 2019. The Panel is still investigating this ongoing operation.
__________________
177
(1) Letter from Opus legal counsel dated 15 December 2020; and (2) Statement by Stephen Lodge to Panel of 13
September 2020.
178
Letter to Panel from Opus legal counsel (regarding Travis Maki) dated 12 November 2020.
179
Last sighted on satellite imagery at Al Jufra airbase.
180
Using Aircraft Length/Main Wingspan ratio of 0.69, and Aircraft Length/Tail Wingspan ratio of 1.91. The tail wing
also has a unique profile as a further identification feature.
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5. LASA T-Bird (YU-TSH)

39. On or about 19 June 2019, L-6 FZE acquired a converted 2SR H80 Thrush 510G
(construction number H180-161DC) aircraft, which was during the deployment phase of Project
Opus A. This aircraft was formerly in the possession of the Light Attack and Surveillance Aircraft
(LASA) Engineering company of Bulgaria (http://lasaeng.eu). The aircraft was registered by the
San Marino Aircraft Registry181 as T7-SAX (2014 to 2015), and then by the Bulgaria Directorate
General Civil Aviation Administration182 as LZ-SAX (2015 to 2018). In August 2018 the aircraft
was registered by the Civil Aviation Directorate of Serbia183 as YU-TSH, with the operator listed
as GAS-Aviation d.o.o.184
40. In 2014/2015 Erik Prince arranged for the militarization185 of the aircraft by Airborne
Technologies GmbH of Austria (https://www.airbornetechnologies.at/). Christiaan Durrant was
the Project Director.186 A nose-mounted S.C.A.R pod containing an imagery sensor surveillance
system,187 and six removable weapon hard points under the wings were fitted.188 Extensive
engineering work inside the aircraft took place to fit the targeting and weapons release systems.
This modified aircraft was then marketed as the LASA T-Bird at the 2017 Paris Air Show (see
figures 76.12 and 76.13).189
__________________
181
https://www.caa-mna.sm.
182
https://www.caa.bg/en.
183
http://www.cad.gov.rs/en/.
184
http://smederevskapalanka.privredaturizam.com/index.php?option=com_content&view=article&id=116%3Agas-
aviation-doo&catid=35%3Aprivreda&lang=en, accessed on 17 June 2020.
185
Included the fitting of: (1) armoured glass cockpit; (2) armoured engine block; (3) anti-explosive mesh in fuel tank; (4)
specialised weapon targeting and control wiring loom.
186
(1) https://theintercept.com/2016/04/11/blackwater-founder-erik-prince-drive-to-build-private-air-force/; and (2)
https://theintercept.com/2020/02/20/erik-prince-fbi-investigation-trump-barr/. Accessed 29 December 2020.
187
The Panel has not identified if the S.C.A.R pod contains the FLIR Ultraforce 350 High Definition multi-spectral,
multi-imagery sensor surveillance system or the Thales I-Master lightweight surveillance synthetic aperture radar.
Either system is subject to dual use export controls, for which their deployment to Libya would not be approved by the
appropriate Member State export control agencies.
188
Opus legal counsel have claimed that “fake” weapons were fitted for the Paris Air Show. The Panel cannot verify
this but consider it highly unlikely that the internal engineering necessary to target and deploy the weapons were
removed. Thus, it was still a military aircraft.
189
1) https://www.ainonline.com/aviation-news/defense/2017-06-21/lasa-shows-t-bird-paris, 21 June 2017; and 2)
https://www.militaryfactory.com/aircraft/detail.asp?aircraft_id=1844, 12 July 2017.
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LASA T-Bird at Paris Air Show a b Inside LASA T-Bird cockpit
a
Note the starboard underwing weapons fitment (from L to R) of: 1) UB 16-57mm Rocket Pod; 2) UB 32-57mm Rocket Pod;
and 3) UBK-23 gun pod fitted with twin 23mm cannon inside, (all Soviet era and readily available in Eastern Europe). This
weapons array is repeated under the port wing.
b
The S.C.A.R pod is nose mounted.
41. The Panel identified that this aircraft was deployed to Amman, Jordan in late June 2019,
until on 11 July 2019 when Jordan instructed Christiaan Durrant to remove all Project Opus A
assets. A flight plan was submitted for the LASA T-Bird to fly to Larnaca, Cyprus on, or about,
22 July 2019. This flight plan likely been inaccurate as Cyprus air traffic control have no records
of the aircraft landing there. An infographic summarising the procurement activities surrounding
this aircraft and full details are at appendix P.
6. Central control of aviation assets
42. The Panel finds it almost certain that all three aircraft were under the control of Erik Prince
prior to the Opus A operation. Only he was in the position to approve the sale and/or transfer of
all three aircraft to support the operation in such a short time frame (see figure 76.14). These
aircraft were sold, transferred and deployed in days, with no time for the appropriate due diligence
checks normally undertaken for aircraft sales. One quick transfer could be explained, but not three
from different companies, all under the effective control or influence of one individual.
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Figure 76.14
Prince influence over specialist aircraft transfers
7. MRC-1250 Rigid Hulled Inflatable Boats (RHIB)
43. On 20 June 2019, Steven Lodge, acting as a representative of Opus Capital Asset Limited
FZE, charted two “special forces” specification MRC-1250 RHIBs (Manta-1 and Manta-2) from
Sovereign Charterers Limited, Malta.190 Charter fees were EUR 2,500 per day each for a ninety-
day period from 20 June to 17 September 2019 (total of EUR 240,000 per RHIB). The two standard
BIMCO191 contracts specifically included a delivery fee of EUR 15,000 for each RHIB (see
__________________
190
www.sovereigncharterers.com/. Accessed 14 September 2019. Company registration number C67113.
191
Baltic and International Maritime Council (www.bimco.org).
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appendix Q).192 The account was settled from a Lancaster6 DMCC bank account. The two vessels
were delivered to Benghazi, Libya on 27 June 2019 by a crew of four staff members of Sovereign
Charterers Limited and two private military operatives of Opus Capital Asset Limited FZE
(Andrew Scott Ritchie (UK) and Sean Callaghan Louw (UK)).193
44. Sovereign Charterers Limited is part of Unified Global Services Group,194 and is under the
sole control of James Fenech.195 The vessels were then advertised on the Sovereign Charterers
website196 as being “special forces RHIBs … hardened for maritime security operations”,197 but
this description was removed after Fenech’s arrest by the Maltese authorities.
45. James Fenech informed the Panel198 that he was told that the vessels were “required for
evacuation purposes as a number of Oil and Gas and other Multinational companies would require
solutions to evacuate their personnel speciﬁcally for Insurance purposes”. Considering James
Fenech’s known close linkages to private military companies through the auspices of his other
business, (e.g. Fieldsports Limited, Malta (C54571)), and his knowing, the individuals and
organizations involved in the charter of the vessels, the Panel considers it unlikely that he found
this to be a credible explanation. The Panel finds them to be military equipment under the ambit
of paragraph 9 to resolution 1970 (2011).199
46. The Panel finds James Fenech and Sovereign Charters Limited (Malta) in technical non-
compliance with paragraph 9 of resolution 1970 (2011) for the provision and transfer of military
equipment to a private military company supporting an armed group in Libya. The Panel wishes
to emphasise that James Fenech cooperated fully with the Panel and acceded readily to all
information requests during the investigation. The Panel considers that James Fenech was probably
unaware that the transfer of an unarmed vessel, albeit to military specifications, would be a non-
compliance of the sanction measures.
47. The Panel finds Andrew Scott Ritchie and Sean Callaghan Louw in violation of paragraph 9
of resolution 1970 (2011) for the provision and transfer of military equipment to a private military
company supporting an armed group in Libya. They were participants in the operation and almost
certainly knew that the operational plan was to arm the vessels for maritime interdiction
operations.200
__________________
192
The payment of the delivery fee is important as this is evidence of the intent to transfer to Libya.
193
Member State.
194
http://unifiedglobal.com.mt/. Accessed 14 September 2019. Company registration number C66837.
195
https://registry.mbr.mt/ROC/index.jsp - /ROC/companyDetailsRO.do?action=involvementList&companyId=C
67113. Accessed 14 September 2019, (requires registration as user). Also owns www.fieldsportsmalta.com.
196
http://www.sovereigncharterers.com/MRC-1250. Accessed 15 September 2019.
197
Supported by definitions in Common Military List of the European Union. ML9.(a).1. “ (…) other surface vessels.
Vessels (…) modified for military use (…) regardless of whether or not they contain (…) weapon delivery systems”.
198
Letter to Panel of 28 October 2019..
199
Mr Fenech was offered an opportunity to reply on 17 January 2020, and his lawyer responded on his behalf on
3 February 2020. Further information on this Panel finding is contained within Mr Fenech’s response to the
opportunity to reply offered by the Panel at appendix W.
200
These two individuals were offered an opportunity to respond, through the Opus legal counsel, on 29 December
2020 but they declined to engage with the Panel.
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F. Deployment to Libya
48. One individual who participated in the operation201 informed the Panel that he was recruited
by Steven Lodge for a Search and Rescue (SAR) role supporting a geological survey in Jordan. It
was only after he arrived in Jordan, on or about 22 June 2019, that he was told that the real operation
was a private military operation in Libya. He confirmed that the full team of “up to twenty”
operatives deployed to Libya from Jordan on a chartered IL76 civil aircraft. He admitted that once
he was aware of the true purpose of the operation he should have refused to go further, but that he
was motivated by the US$ 900 per day for a guaranteed three-month contract (US$ 81,000).
49. A team of at least seventeen PMC operatives202 deployed to Benghazi, Libya from Amman,
Jordan on board a commercial IL-76 cargo aircraft on, or about, 25/26 June 2019.203 They were
accommodated in a large compound to the south of Benghazi in two buildings (described to the
Panel as being like “something out of the film Thirteen Hours in Benghazi (sic)”).204 The PMC
team and compound had local security provided by a Libyan armed group.
50. On 27 June 2019 they were joined by the four-man Maltese RHIB delivery crew from
Sovereign Charterers and the two PMC operatives (Sean Louw and Andrew Ritchie). The four
Maltese individuals only stayed one night and departed Benghazi on one of the few available
commercial routes, Afriqiyah Flight # 8U606 to Amman, Jordan on 28 June 2019 and onward to
Malta on Flight # FR8975 on 29 June 2020.
51. The Panel requested copies of their Libya visas from Steven Lodge and Travis Maki, who
both responded that they did not need them as they would obtain them on arrival. The Panel has
confirmed that only Jordanian and Tunisian citizens may enter Libya without a visa. The lack of a
visa for these individuals can only mean that their entry into Libya was facilitated by the Haftar
administration, or they entered illegally.
G. Evacuation from Libya

52. The maritime and assault rotary wing aviation phase of the operation was suddenly aborted
on the evening of 29 June 2019. This resulted in twenty private military operatives making a thirty-
six-hour, 350 nautical mile sea crossing from Benghazi in the two ‘special forces’ specification
rigid hulled inflatable boats procured for the operation; one of which was abandoned on route due
to engine problems and loss of steering. The single RHIB arrived in Valetta, Malta at
approximately 13:00 hours 1 July 2019.
53. The decision to evacuate was taken by the Ground Team Leader (Steven Lodge) due to the
adverse reaction of Khalifa Haftar when he realised that the aviation assets deployed (the South
African helicopters) were not those that had been promised during the planning stage of the alleged
__________________
201
Confidential source (CS22) who participated in the operation.
202
The Panel has identified that the majority had previous military service and had subsequently been employed by a
range of private military and security companies.
203
Confidential source (CS22) who participated in the operation.
204
The actual 2016 film title is 13 Hours: The Secret Soldiers of Benghazi.
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US$ 80 million contract.205 Steven Lodge feared violent repercussions against his team when
Haftar realised that the promised capability was never going to be delivered.
54. A lawyer was engaged in Malta at short notice by Opus Capital Asset FZE but was paid from
a Lancaster6 DMCC account. In the event his services were not required. The cover story provided
to the Maltese Police was that the RHIB occupants were from an oil field operation and needed to
leave Libya quickly because of deteriorating security concerns. The Panel notes though that the
UN Security and Safety reporting mechanism for that period assessed the security situation in
Benghazi area as being reportedly “calm and stable” during this time period.206 The occupants of
the RHIB only stayed in Malta for a few days before leaving the island (appendix R).
55. A RHIB was later found abandoned off the coast of Libya near Zueitina in late July 2019.207
Imagery and geo-referencing (see appendix S) confirms that it was an MRC-1250 RHIB with
Maltese Registration ON-17388, named Manta-2, and owned by Sovereign Charterers Limited.
H. Financial analysis
56. The Panel has obtained information and records relating to some of the financial transactions
for this operation, (summarised in table 76.3). The involvement, and interchangeable use of the
shell companies, is also clearly identifiable within table 76.3. This list is far from exhaustive and
does not include legal fees, other equipment procured, logistics fees etc. HAF allegedly paid US$
80M to Opus for the capability, yet only approximately US$ 20M can be accounted for to date.
Unless the UAE allows the Panel access to the various bank accounts specified at table 76.4 little
further progress is likely unless L-6 FZE, Lancaster6 DMCC or Opus Capital Asset Limited FZE
significantly improve their cooperation with the Panel.
Table 76.3
Summary of financial information obtained by the Panel
Date Item purchased Invoiced by Contracted by Paid by Value (US$)b

17 Jun 2019 3 x SA341 Gazelle Fulcrum Holdings L-6 FZE Opus ** 1,950,000
Helicopters Limited (UAE) Capital
Asset
FZE
19 Jun 2019 2 x MRC-1250 RHIB Sovereign Charterers Opus Capital Lancaster ** 541,505
Hire and Delivery Limited (Malta) Asset FZE 6 DMCC
19 Jun 2019 Purchase of LASA T- LASA Engineering, L-6 FZE ** 3,364,500
Bird (H80-161DC) Bulgaria
20 Jun 2019 3 x AS332 Super- Starlite Aviation L-6 FZE Opus ** 4,210,636
Puma helicopters Group Limited Capital ** 3,257,068
(RSA) Asset ** 3,417,911
FZE b c
__________________
205
Confidential source who was at the meeting. (CS27 through CS4).
206
The only incident of note being two civilians injured by low velocity gunfire from a drunken man in the carpark of the
Tebisti Hotel in the early hours of 1 July 2019.
207
https://arabic.rt.com/middle_east/1035381-‫ليبيا‬-‫شرق‬-‫سواحل‬-‫على‬-‫الغامض‬-‫زورق‬-‫على‬-‫العثور‬/. Accessed 15 September 2019.
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Date Item purchased Invoiced by Contracted by Paid by Value (US$)b

20 June 2019 Arrange charter of 4 x International World L6-FZE Lancaster 1,200,000
IL-76 flights from Air Services (UAE) d 6 DMCC
Botswana to Libya
28 Jun 2019 Purchase of Antonov FSG Aviation L6-FZE Lancaster ** 766,770
AN-26B (serial # 6 DMCC
7198)
4 Jul 2019 Freight forwarding in Speedway Freight Panzer Logistics Panzer 8,500
Botswana (Proprietary) Limited (RSA) Logistics
(Botswana) (RSA)
3 Jul 2019 Purchase of Pilatus Airborne L-6 FZE Lancaster ** 1,068,900
PC-6 (serial # 790) Technologies GmbH 6 DMCC
3 Jul 2019 Legal Fees Malta Lawyer Lancaster6 DMCC Lancaster < 5,000
6 DMCC
4 Jul 2019 Accommodation Radisson Hotel, www.expedia.com 6,000
Malta
8 Jul 2019 Marine Fuel and Sovereign Charterers Opus Capital ** 68,954
Search Operation for Limited (Malta) Asset FZE
lost RHIB
22 Jul 2019 Marine Safety Fieldsports Limited Lancaster6 DMCC Lancaster ** 30,003
Equipment (Malta) 6 DMCC
1 Aug 2019 MRC-1250 RHIB Sovereign Charterers Opus Capital Lancaster ** 497,534
Manta-2 Loss Limited (Malta) Asset FZE 6 DMCC
Compensation
Jun – Sep PMC Operatives Opus 1,620,000
2019 salaries x 20 for three Capital
months e Asset FZE
Approximate Total (US$): 19,593,271
a
The Panel has documentary evidence for those items preceded with **. The others are from source information with first-hand knowledge
of the costs.
b
Converted into US$ rate on the date stated on the receipts or contract date using www.xe.com historical data.
c
At US$1 = ZAR 14.1269 on 28 June 2019. Data from customs declaration.
d
IWAS then paid Reem Style and Travel Tourism (UAE), who then paid the Ukrainian airlines.
e
One participant was being paid $900 per day for a six-month contract, and Panel a single confidential source said they were kept on
payroll for three months. So an estimate only.
57. The Panel has identified the bank accounts in table 76.4 that have been used by Opus during
this operation. Note that payments made by one company are for equipment contracted for another
company, thus increasing the opacity of the operation.
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Table 76.4
Bank accounts related to OPUS procurement and payment activities
Company Bank Account # / Transfer # Paid / Received Contracted by

Lancaster 6 Noor Islamic AE14052000241096278XXXX ▪ FSG Aviation ▪ L6-FZE
DMCC Bank, Dubai (Bermuda) ▪ Opus FZE
▪ Sovereign Charters
Limited (Malta)
Lancaster 6 Emirates Islamic AE36034000370745605XXXX ▪ Sovereign Charters ▪ Opus FZE
DMCC Bank PJSC, Limited (Malta)
Dubai
L-6 FZE Noor Islamic AE17052000241096627XXXX ▪ RECEIVED ▪ Paid by
Bank, Dubai ▪ Expedition
Aviation FZE
Opus Capital Emirates NBD AE30026000101546753XXXX ▪ Starlite Aviation ▪ L-6 FZE
Asset Limited Bank PJSC (South Africa)
FZE
Opus Capital ▪ Fulcrum Holdings ▪ L6-FZE
Asset Limited Limited (UAE)
TBC Noor Islamic AE840520000110563690XXXX ▪ Team Members a ▪ Opus
Bank, Dubai
a
This is from unresolved payment advice for an iaccount payment .
I. Damage limitation
58. After the airing of a documentary208 by Australia Broadcasting Corporation on Monday 14
September 2020, the PMC operatives were contacted on Tuesday 15 September 2020 by an
individual still under investigation by the Panel, who was trying to determine where the leaks to
the media were originating from. On Wednesday 18 September 2020, Erik Prince personally called
at least one of the Opus PMC operatives to ask why he and some colleagues were in the USA at
that time.209
59. The Panel also noted that in the written statement by Steven Lodge of 13 September 2020,
and the opportunity to respond interview with Christiaan Durrant on 16 September 2020, that both
made a specific point, without any prompting from the Panel, that although Erik Prince was known
to them, he had no role in the planning or execution of the Opus operation, nor was he financially
involved in any of the companies involved. It appeared to the Panel as if this was a coordinated
response.
60. Federal Advocates Inc (USA), a lobbying firm, disclosed on 17 September 2019 that were
engaged by Opus Capital Asset Limited FZE on 1 July 2019 to provide lobbying services. The
LD1 Disclosure Form described Opus Capital Asset Limited FZE as a “geopolitical national
security firm” and that the general lobbying issue area was “DEF” (defence). On 16 October 2019,
an LD2 Disclosure Form was submitted in which the declared general lobbying area issue code
__________________
208
https://www.abc.net.au/4corners/soldiers-of-fortune/12662570.
209
Confidential source (CS27 through CS4).
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had changed to “FUE” and with a specific lobbying issue area of “oil and gas logistic services”.210
This was changed on 16 October 2019 to “Oil and gas logistics service – providing educational
background to the administration. The company failed to cooperate with the Panels’ requests for
information and clarification.211
J. Cover stories
61. The Panel obtained a copy of the documentation used to justify and support the movement
of the helicopters from Gaborone (FBSK) to Jordan that was shown to the Botswanan customs
authorities. This consisted of a comprehensive technical response to a Request for Proposal (RfP)
for an Airborne Geophysical and Hyperspectral Surveys (Kingdom of Jordan) purportedly issued
by a company called Confidence Security Consulting.212 The Panel was unconvinced of the
veracity of this documentation, which was badly laid out and an obvious “cut and paste” document.
62. The artwork on the base of the document is identical to that of AustinBridgeporth213 (figures
76.15 and 76.16).214 AustinBridgeporth is a teaming partnership between Austin Exploration Inc
(USA)215 and Bridgeporth Limited,216 a UK based professional geosciences company.217
Bridgeporth Limited initially confirmed verbally to the Panel that the document is a copy of a
‘boilerplate proposal’ the company uses, and that the company had no recent or planned
operational engagement with Jordan for surveys.218
63. The Panel notes that Travis Maki, the pilot of the Pilatus PC-6 in Libya, was named on the
Bridgeporth website219 as their Vice President of Aviation. Bridgeporth Limited told the Panel that
“the company had let him go earlier”. The Panel requested documentary evidence to confirm this
and is still awaiting a response.
__________________
210
1) https://projects.propublica.org/represent/lobbying/301022812; and 2) LD1 and LD2 Disclosure Reports in the
possession of the Panel.
211
1) Panel letters of 26 December 2019 and 3 February 2020; 2) Panel communication of 23 January 2021.
212
Confidence Security Co, 7 Floor, Office 702A, Kamala Tower 2, Al Had Street, Al Khalidiyah, Abu Dhabi, UAE.
+971 2 6760660. The Panel has not elicited a response to this number.
213
www.austinbridgeporth.com/.
214
Bridgeporth UK is linked to Bridgeporth Holdings (Gibraltar) Limited in which FRG Partners I Master Fund LP
(Cayman Islands # 56264) has a 93.3% shareholding. The CEO of Bridgeporth Limited, Dr Mark Davies, is also the
CEO of AustinBridgeporth (http://www.austinbridgeporth.com).
215
www.austininc.com.
216
www.bridgeporth.com.
217
In 2019 Bridgeporth Limited (UK) was majority owned by Bridgeporth Holdings Limited (Gibraltar), which in
turn was 92.3% owned by FRG Partners | Master Fund LLP (Caymans), which was owned by FRG Partners | LP
(Caymans), which was owned by Frontier Resource Group Limited (Caymans), which was 80% owned by Frontier
Holdings Limited (Caymans), which was 100% owned by Erik Dean PRINCE. This is indicative of the complex
multi-shells that Erik Dean Prince uses to disguise his control over, and benefits from, trading companies.
218
Initial panel discussion in confidence by phone with company CEO, Dr Mark Davies, and the subsequent Email
on 5 December 2019. After requesting supplementary information the Panel was informed that on 5 January 2020
that “given the serious nature of the allegations (…). Someone from the ownership group will be in touch with you
shortly”.
219
http://www.bridgeporth.com/our-team/, accessed 5 December 2019. Subsequently removed by 19 January 2020.
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Bridgeporth Limited artwork from company website Artwork from F-6 FZE / OPUS RFP response to tender
64. The Panel finds that this document was counterfeited with deliberate intent to disguise the
true purpose for the requirement to transport the helicopters out of Botswana. Notwithstanding its
status as a counterfeit document, the perpetrators had to use real names to lend it authenticity and
credibility should spot checks be made. It lists the Managing Director of Opus Capital Asset
DMCC, as Amanda Kate Perry whose name appears on the legitimate purchase documentation for
the three Gazelle LUH. Appendix T summarizes the counterfeit issues in the document, and
contains extracts referring to Opus Capital Asset DMCC and Amanda Kate Perry.
65. This document was used to support the cover story of a “Geophysical and hyperspectral survey
of Jordan” (Cover Story 1 of June 2019). Jordan has confirmed that no such survey was either
planned nor approved.220 Bridgeporth Limited (UK) denied all involvement221 and on 24 January
2020 the Panel received a letter from Matthew L Schwartz of Boies Schiller Flexner (BSF), New
York (www.bsfllp.com) regarding their enquiries. Matthew Schwartz also represents Erik Prince,222
and the Panel considered it unusual at the time that a small, specialist British geosciences company
would be utilizing the services of a New York based legal counsel were it not for the Erik Prince
connection between the two. BSF initially failed to respond to two letters from the Panel regarding
the use of Bridgeporth documentation in Cover Story 1,223 but made contact with the panel again in
November 2020.224 Further research established a commercial arrangement involving the Pilatus
PC-6 aircraft between Erik Prince and Bridgeporth Limited (UK) dating back to at least 26 January
2012 (see appendix U). On 23 November 2019 a letter from the UAE based legal representative for
the individuals and companies involved in Opus informed the Panel that they were consulting with
Mr Schwartz but did not provide a reason for such a consultation.
66. The use of Bridgeporth Limited (UK) and “Oil and Gas Survey” as part of a cover story was
used before in a 2014 proposal by Frontier Services LLC, controlled by Erik Prince. The proposal
was code named Project BROOKLYN and its aim was to kill or capture Joseph Kony and the
Lords’ Resistance Army leadership group in South Sudan.225 One slide contains the text “Cover
__________________
220
Letter to Panel of 6 April 2020.
221
Email to Panel of 5 December 2019.
222
1) https://www.reuters.com/legal/article/us-usa-trump-russia-prince/house-panel-seeks-justice-department-probe-of-
trump-backer-prince-idUSKCN1S61MI, 30 April 2019; and 2) https://www.law360.com/articles/1275426/blackwater-
founder-targets-intercept-with-defamation-suit, 20 May 2020.
223
Panel letters of 3 February and 18 September 2020.
224
BSF letter to Panel of 12 November 2020. The Panel’s latest letter to BSF on 12 November 2020 remains unanswered.
225
The Panel has a copy of this nineteen slide Concept of Operations presentation but has agreed not to publish at this
stage to preserve a confidential source (CS8) relationship.
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for status/action: Oil and gas survey company (Bridgeporth Ltd, Milton Keynes (UK)”. Indeed the
overall Project BROOKLYN proposal was very similar to that proposed by Opus to HAF, and
indeed many others that Erik Prince has been directly responsible for or involved in.226 Gregg
Smith who, as the Chief Executive Officer of Frontier Services Group Limited (FSG) from 2014
to 1 May 2016,227 worked closely with Erik Prince when he was Chairman of FSG, stated to the
Panel228 that the cover story for the operation would be “oil and gas security” or “oil and gas
survey” as “that was what Prince had always used”. Gregg Smith repeated this publicly in an
interview with www.narativ.org on 17 September 2020. 229 Gregg Smith also claimed that it was
implausible that Erik Prince did not control Lancaster6. Gregg Smith went on to explain that, in
his experience, Erik Dean Prince protected himself from litigation by not owning or controlling a
company through debt ownership, he would receive material or financial benefits in other ways
67. After failure of the Opus A deployment, the response to the Panel’s enquiries to the
individuals and companies involved, through their legal counsel in January 2020,230 was to
introduce a second cover story that Project Opus A was providing technical support services for
an “oil and gas project in Libya” (Cover Story 2 of April 2020).231 The Panel requested the sight
of contractual documentation to support the claim in order to deconflict any such project, if it
existed, from the PMC operation, but no details were provided to the Panel. The Panel was thus
unconvinced of the veracity of this second “cover story”. In September 2020 a third cover story
was then provided to the Panel232 that Opus FZE were establishing a logistic hub in Western Libya
at their own financial risk (Cover Story 3 of September 2020).
68. In his interview of 16 September 2020 Christiaan Durrant claimed that the Opus operations
were self-funded at company risk but was reluctant to identify the source of funding. The Panel
has identified that approximately US$ 20M was committed to the operation just for the funding of
the equipment and private military operatives’ salaries. These salaries continued for at least three
months after the failure of the operation.
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226
Subsequent examples of this “Army in a Box” concept proposed by Erik Prince include Somalia PMFP 2010
(deployed), DRC 2014 (proposal failed), South Sudan 2014 (deployed), Mali 2014 (proposal failed), Azerbaijan
2015 (proposal failed), Libya 2015 (HAF anti-migration) (failed), Afghanistan 2017 (proposal failed), Mozambique
2019 (proposal failed), Mozambique 2020 (negotiations ongoing at time this document was prepared).
227
https://www.marketscreener.com/quote/stock/FRONTIER-SERVICES-GROUP-L-6165919/news/Frontier-
Services-1-RESIGNATION-OF-AN-EXECUTIVE-DIRECTOR-2-GRANT-OF-SHARE-OPTIONS-3-RESIGNAT-
22268951/, 29 April 2016.
228
Panel interview of 30 March 2020.
229
https://narativ.org/2020/09/17/prince-of-proxy-china/, 17 September 2020. (12min 30 sec to 13min 35 sec).
230
https://www.hfw.com/Abu-Dhabi. Accessed 20 July 2020.
231
HFW letters to Panel of 7 and 31 January 2020.
232
Interview with Christian Durrant of 16 September 2020 and Statement by Lodge of 13 September 2020 (see
annex S).
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K. Opportunities to respond
1. Christiaan Paul Durrant
69. The Panel provided Christiaan Durrant with an opportunity to respond during an interview233
on 16 September 2020 at 10:00 hours (UTC). The interview lasted for two hours. A legal advisor
from the Opus legal counsel was present, and a second Opus legal counsel legal advisor and his
communications advisor, Ian Twine of Harrup Advisory Limited234 participated by the MS Teams
media platform. The Panel agreed that the Opus legal counsel may record the interview, whilst the
Panel took contemporaneous notes. A Panel summary of the interview based on these notes is at
appendix V.
70. During his interview Christiaan Durrant provided no evidence to his claims, little substantive
detail and no rebuttal evidence to any of the findings of the Panel to date. His response to subsequent
written supplementary questions was to claim he was being co-operative with the Panel, yet he
supplied no substantive nor detailed responses to any of the questions presented to him.
2. James Fenech
71. James Fenech was offered an opportunity to reply on 17 January 2020. His lawyer responded
on his behalf on 3 February 2020, and the full statement, together with appropriate explanatory
notations by the Panel is at appendix W.
3. Steven John Lodge

72. The Panel provided Steven Lodge with an opportunity to respond interview,235 which he
declined, preferring to submit a written statement to the Panel on 13 September 2020. The Panel
requested clarification of some points in a letter dated 17 September 2020, to which the Opus legal
counsel responded on his behalf on 29 September 2020. The full statement, together with appropriate
explanatory notations by the Panel is at appendix X. The Panel analysed the content of this statement,
and identified corroboratory and contradictory evidence, which was then considered during the
preparation of this report. The Panel considers that Steven Lodge provided no documentary evidence
to support any of his responses, provided little detailed information and his responses contained no
proven rebuttal evidence to any of the findings of the Panel to date.
4. Travis Alden Maki

73. The Panel requested an interview with Travis Maki on 17 September 2019 but were told by
the Opus legal counsel on 29 September 2019 that he was unavailable. The Panel then offered
Travis Maki an opportunity to reply in a letter to his legal counsel of 29 October 2019. He admitted
to piloting the PC-6 ISR aircraft into Libya on 25 June 2019 but did not know who owned the
aircraft. He specifically refuted that he was a private military contractor or that he was engaged to
__________________
233
In London. One Panel member present, the other participated by MS Teams media platform.
234
https://harrupadvisory.com. Accessed 20 September 2020.
235
Panel EMail to HFW of 17 August 2020.
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perform military company operations designed to provide military support to one of the parties to
the conflict in Libya.
5. Amanda Kate Perry

74. The Panel remotely interviewed236 Amanda Kate Perry on 20 July 2020 at 08:00 hours
(UTC). The interview lasted 45 minutes. The Opus legal counsel, and her communications advisor,
Ian Twine of Harrup Advisory Limited237 were present and the Panel agreed that they may record
the interview. The Panel took contemporaneous notes. She was asked detailed questions
concerning the corporate structures of L-6 FZE, Lancaster 6 DMCC and Opus Capital Asset
Limited FZE. On the advice of the Opus legal counsel she declined to provide any information,
citing concerns about confidentiality of information provided to the Panel. It was explained to her
that the Panel only provided information directly to the Sanctions Committee or Security Council;
she still declined to provide the information. Amanda Perry was then asked detailed questions
regarding her knowledge of activities for which the Panel had evidence of her involvement in the
form of signed contracts for the purchase of equipment (one LASA T-Bird aircraft) and logistic
support to the operation (air freight agent). Amanda Kate Perry’s responses were consistent
throughout the interview in that she either: 1) had no knowledge of the activity; 2) could not
remember; or 3) only acted as a corporate service provider and had no knowledge of those
companies’ operations. She explained that the intrusive media coverage of the issue had been
devastating for her personal reputation and business, which was now on the state of collapse. The
Panel did not find her explanations at all convincing. Her failure to provide any detailed rebuttal
evidence and her lack of cooperation in providing corporate, financial or transaction information
means that the evidence supplied in this document by the Panel is submitted unexplained and
unchallenged by Amanda Perry.
6. Erik Dean Prince

75. In a letter to Erik Prince dated 18 November 2020238 the Panel requested details of his
operational involvement in Opus A and B, and also that he clarify his business and financial
relationships with Bridgeporth Limited (UK), Bridgeporth Holdings Limited (Gibraltar), Austin
Bridgeporth Limited L-6 FZE (UAE), Lancaster 6 DMCC (UAE), Opus Assets Limited FZE
(UAE), Opus Capital Asset Limited DMCC (UAE), Frontier Services Group Limited (Bermuda),
Frontier Holdings Limited (Bermuda), FSG Aviation Limited (Bermuda), TST Humanitarian
Surveys LLC (USA), ULL24 GmbH (Austria), Airborne Technologies GmbH (Austria), LASA
Engineering Limited (Bulgaria), Unified Global Services Group Limited (Malta) and PBM
Limited (Malta). No response was received by the requested date of 7 December 2020. A reminder
__________________
236
Using the Zoom platform.
237
https://harrupadvisory.com. Accessed 20 July 2020.
238
Sent to two known E Mail addresses of Erik Dean Prince. Copies were sent by UPS courier to his Virginia and
Wyoming residences. UPS tracking confirmed delivery to his Virginia address on 4 December 2020
(1ZF333A30311197514) and to his Wyoming address on 10 December 2020 (1ZF333A30311197523). The Panel did
not consider it appropriate to send such a communication to Mr Prince via the three lawyers known to be used by him,
as the Panel could not know which lawyer Mr Prince may choose to instruct to represent him on this matter, if at all.
An Email reminder was sent to Mr Prince on 16 December 2020 with UPS courier copies to his Virginia and Wyoming
addresses (1ZF333A30211201420 and 1ZF333A30311201437 respectively).
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letter was sent on 16 December 2020 and no response was received to that letter either.239 His
failure to cooperate with the Panel means that the evidence supplied in this document is submitted
unexplained and unchallenged by Erik Prince.
L. Opus B operation
76. The Panel has evidence that a second Opus operation (Opus B) was launched into Libya in
April/May 2020, and investigations continue to achieve the evidential standards necessary for
reporting. It involved at least four or five of the individuals connected with the first Opus
operation.240 Indeed, the Panel believes that some of the components of Opus A, or directly derived
from that operation, still continue to be active in Libya. Examples being the Fusion and Targeting
Cell and the PC-6 ISR aircraft.
M. Summary of violations
77. Although there is much still to learn about Project Opus, that Panel has achieved the
necessary evidential standards to allow it to make the following findings (tables 76.5 to 76.6) for
entities and individuals that have:
(a) Violated paragraph 9 to resolution 1970 (2011):
Violating, or assisting in the evasion of, the provisions of the arms embargo in Libya
established in resolution 1970 (2011) by the direct (…) supply (…) to the Libyan Arab
Jamahiriya (…) of (…) related materiel of all types, including military (…) equipment,
(…), and other assistance, related to military activities (…).
and/or
(b) Are in non-compliance with paragraph 13 to resolution 2509 (2020) by failing to:
(…) supplying any information at their disposal on the implementation of the Measures
decided in resolutions (…) in particular incidents of non-compliance (…).
Table 76.5
Entities violating resolution 1970 (2011) and/or in non-compliance with resolution 2509 (2020)
Violation of para.9 Non-compliant with

to resolution 1970 para.13 to resolution
Entity (2011) 2509 (2020) Specific
Bridgeporth Limited ✓ ▪ Failure to provide information at their
(UK) disposal regarding other assistance relating
to military activities to an armed group.
Federal Advocates Inc ✓ ▪ Failure to provide information at their
(USA) disposal regarding other assistance relating
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239
UPS courier copies also sent to his Virginia and Wyoming addresses (1ZF333A30211201420 and
1ZF333A30311201437 respectively).
240
Including confidential source (CS27).
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Entity (2011) 2509 (2020) Specific
L-6 FZE ✓ ✓ ▪ Arranging the transfer of military equipment
(United Arab Emirates) and providing other assistance relating to
military activities to an armed group in Libya.
Lancaster 6 DMCC ✓ ✓ ▪ Failure to provide information at their
(United Arab Emirates) disposal regarding other assistance relating
Opus Capital Asset ✓ ✓
Limited FZE
(United Arab Emirates)
Panzer Logistics ✓ ▪ Failure to provide information at their
(Proprietary) Limited disposal regarding other assistance relating to
(South Africa) military activities to an armed group.
Sky Avia Trans LLC ✓ ▪ Transfer of equipment by air to a private
(Ukraine) military company providing other assistance
relating to military activities to an armed
group in Libya.
Sovereign Charterers ✓ ▪ Transfer of military equipment by sea to a
Limited private military company providing other
(Malta) assistance relaying to military activities to
an armed group in Libya.
Zet Avia LLC ✓ ▪ Transfer of equipment by air to a private
(Ukraine) military company providing other assistance
relaying to military activities to an armed
group in Libya.
Table 76.6
Individuals violating resolution 1970 (2011) and/or in non-compliance with resolution 2509 (2020)

Individual (2011) 2509 (2020) Specific
Durrant ✓ ✓ ▪ Arranging the transfer of military equipment and
Christiaan Paul providing other assistance relating to military
(Australia) activities to an armed group in Libya.
▪ Failure to provide information at his disposal
regarding other assistance relating to military
activities to an armed group.
Fenech ✓ ▪ Arranging the transfer of military equipment and
James providing other assistance relating to military
(Malta) activities to an armed group in Libya.
Lodge ✓ ✓ ▪ Arranging the transfer of military equipment and
Steven John providing other assistance relating to military
(South Africa) activities to an armed group in Libya.
Louw ✓ ▪ The transfer of military equipment by sea to a
Sean Callaghan private military company providing other
(UK) assistance relating to military activities to an
armed group in Libya.
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Individual (2011) 2509 (2020) Specific
Maki ✓ ▪ Transfer of military equipment by air to a private
Travis Alden military company providing other assistance
(USA) relating to military activities to an armed group in
Libya.
Mariotti ✓ ✓ ▪ The transfer of military equipment by air to a
Franco private military company providing other
(Global Africa assistance relating to military activities to an
Aviation) armed group in Libya.
Perry ✓ ✓ ▪ Arranging the procurement and transfer of
Amanda Kate equipment intended for a private military company
(UK) providing other assistance relating to military
activities to an armed group in Libya.
▪ Failure to provide information at her disposal
Prince ✓ ✓ ▪ At the least facilitated the transfer of military
Erik Dean equipment to a private military company
(USA) providing other assistance relating to military
activities to an armed group in Libya.
Ritchie ✓ ▪ The transfer of military equipment by sea to a
Andrew Scott private military company providing other
(UK) assistance relating to military activities to an
armed group in Libya.
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Appendix A to Annex 76: Timeline of events
Table 76.A.1
Timeline of events241
Date Event Responsible Remarks
12 Jul 2018 RJAF list 17 x AH-1F Cobra attack helicopters for RJAF ▪ Cobra attack helicopters mentioned in Opus
sale. confidential document.
01 Nov 2018 Antonov AN-26 (UR-MDA) insured by FSG Aviation ▪ Later sold to L-6 FZE for US$ 650,000.
for US600,000. Insurance not revoked or transferred.
9 Apr 2019 OPUS PowerPoint [1] was written. ▪ From Metadata.
14 Apr 2019 Erik Prince meets Haftar in Cairo, Egypt and briefs Erik Prince ▪ Probably no PowerPoint. This was either sent
him on PMC intervention prior to Haftar meeting with or briefed previously.
President Sisi. Khalifa Haftar
14 Apr 2019 Erik Prince has planning meetings in Paul Café, Erik Prince ▪ http://paularabia.com/en/
Taggamu Al Khamis, Cairo.
16 May 2019 Lodge flies from Aberdeen to London Heathrow and Steven Lodge ▪ Highly probably Project Opus A planning.
then on to Dubai on Flight# BA0105.
19 May 2019 Lodge flies from Dubai to London Heathrow then on to Steven Lodge ▪
Aberdeen on Flight# BA0106.
20 May 2019 HAF naval commander Faraj al-Mahwadi announces HAF ▪
that HAF is mobilising its naval forces to impose a
total blockade on western ports, especially regarding
Turkish vessels.
22 May 2019 Ownership or control of Pilatus P-6 aircraft ▪ Aircraft re-registered from N354AK (USA) to
(serial#790) transferred from TST Humanitarian PH-ABT (Netherlands).
Surveys LLC to Aircraft and More GmbH, Austria. ▪ Sold by Aircraft and More for EU948,000.
__________________
241
Some dates relating to deployment dates may be +/1 day, as little substantive information has been provided by the perpetrators during interview, and the
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Panel has had to determine dates from documentary evidence and/or confidential sources (some of whom could only recollect approximate dates of movements).
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27 May 2019 Lodge flies from Aberdeen to London Heathrow and Steven Lodge ▪ Highly probably Project Opus A planning.
then on to Dubai on Flight# BA0107.
30 May 2019 Lodge flies from Dubai to London Heathrow then on to Steven Lodge ▪
Aberdeen on Flight# BA0106.
1 Jun 2019 Lodge flies to Amman, Jordan (AMM) from Aberdeen, Steven Lodge ▪ Flight KL1444
UK (ABZ) via Amsterdam (AMS).
2 Jun 2019 RJAF list six MD530F helicopters for sale. RJAF ▪ MD530F helicopters mentioned in Opus
confidential document.
5 Jun 2019 Pilot recruitment and use of false name to disguise Christiaan Durrant ▪ www.pprune.org
identity and/or covert nature of operation. ▪ Use of Christine Davidson as cover name.
Christiaan Durrant places advert on professional pilot’s

website stating urgent need for pilots.
6 Jun 2019 Discuss charter of AN-26 for Medevac charter in Christiaan Durrant ▪ To Mohamed AL XXXC, XXX Air, Libya.
Libya. ▪ The AN-26 was still owned by FSG Aviation
at this time.
Call made from Christiaan Durrant ’s mobile phone
(+356993XXX).
13 Jun 2019 Opus A planning Christiaan Durrant ▪ To Vince Gordon, Opus legal counsel
▪ The Opus legal counsel stated they had
Calls made from Christiaan Durrant S mobile phone.
represented Opus Capital Asset FZE since (…)
end of June 2019 and under terms of that
engagement represent (…) Mr Christiaan
Durrant (…).242
14 Jun 2019 Lodge flies from Amman, Jordan (AMM) to Aberdeen, Steven Lodge ▪ Flight BA0146
UK (ABZ) via Amsterdam (AMS).
14 Jun 2019 Christiaan Durrant travels to Amman, Jordan from Christiaan Durrant ▪
Austria.
__________________
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Letter from HFW dated 31 August 2020.
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14 Jun 2019 Contract for sale of 3 Gazelle helicopters signed by Fulcrum Holdings ▪ Signed in Lagos, Nigeria
vendor.
On or about Christiaan Durrant Introduces himself to Jordanian Christiaan Durrant ▪ The Australian actor Mel Gibson playsGene
15 Jun 2019 representative as Gene Rynack. Claims that all his Ryack in the film Air America about a private
activities are cleared at the “highest level”. CIA funded airline.
After consultation with the highest levels in Jordan ▪ Most Durrant communications in Jordan used
Christiaan Durrant is instructed by the Jordanian the WICKR platform where he is Charlie
representative to make plans to leave Jordan. Tango.
16 Jun 2019 Opus A planning Christiaan Durrant ▪ Multiple calls to WhatsApp link number.
▪ The team made much use of such mechanisms
Calls made from Christiaan Durrant’s mobile phone. to disguise communications relating to
operation.
16 Jun 2019 Lodge flies to Dubai, UAE (AMM) from Aberdeen, Steven Lodge ▪ Flight BA0107
UK (ABZ) via London (LHR).
17 Jun 2019 Procurement contract for 3 x SA341 Gazelle light L-6 FZE ▪ Signed in Dubai, UAE
utility helicopters (LUH) from Fulcrum Holdings UAE Steven Lodge ▪ Purchaser is L-6 FZE (Opus Capital Assets –
was signed. Operating Company)
17 Jun 2019 Invoice raised for hire of 2 x MRC-1250 RHIB Manta Sovereign Charterers ▪ Invoiced to Opus Capital Asset Limited FZE
1 and Manta 2
18 Jun 2019 Government of Jordan officially stops RJAF sale of Government of Jordan ▪
military aircraft and helicopters.
18 Jun 2019 Confidential documentation refers to Opus executing Opus 1 ▪

their contingency plan. Opus 2
18 Jun 2019 Opus A planning (LASA T-Bird) Christiaan Durrant ▪ Bulgaria Number no longer active. Probably
related to LASA T-Bird.
Calls made from Christiaan Durrant’s mobile phone. ▪ To Vince Gordon, Opus legal counsel.
18 Jun 2019 Transfer of US$ 1,950,000 from Opus Capital Asset to Opus Capital Asset DMCC ▪
Fulcrum Holdings for purchase of 3 x Gazelle SA341 Amanda Perry
helicopters.
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19 Jun 2019 SIGNED purchase order for one 2SR H80 Thrush L-6 FZE ▪ The aircraft was reported as landing at
510G (YU-THS) (construction# H80-161DC).243 Amman, Jordan for ‘maintenance checks’ in
Amanda Perry late-June 2019.
(LASA T-Bird).
▪ Referred to Perry as Managing Director in
contract documentation and signed by Perry as
CEO.
▪ EU 3M from IBAN AE
17/05200/02410966270016
19 Jun 2019 Transfer of EUR 480,000 from Lancaster 6 DMCC to Lancaster 6 DMCC ▪ Contract with Opus Capital Asset FZE, but
Sovereign Charterers, Malta for charter of 2 x MRC- Amanda Perry payment from Lancaster 6 DMCC account with
1250 “Special Forces” RHIB and delivery fees to Noor Bank.
Benghazi, Libya. ▪ Account# 000241096278XXXX
19 Jun 2019 Opus A Planning (3 x Super Puma helicopters). Starlite ▪ From Starlite Aviation, South Africa. The
Call received by Christiaan Durrant’s mobile phone. supplier of the three Super Puma helicopters.
19 Jun 2019 Opus A Planning (3 x Super Puma helicopters). Christiaan Durrant ▪ To Starlite Aviation.
Call made by Christiaan Durrant’s mobile phone.
20 Jun 2019 Confirmation sent to Starlite Aviation that the Super L-6 FZE ▪ Transfer of 3 x Super Puma MUH to Libya
Puma helicopters were to be used to ‘support a confirmed.
Amanda Perry ▪ Signed by Perry as Managing Director.
geological survey’ in Jordan.
20 Jun 2019 Charter signed for 2 x MRC-1250 “Special Forces” Opus Capital Assets FZE ▪
RHIB (Manta-1 and Manta-2) from Sovereign Steven Lodge
Charterers Limited, Malta.
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243
Member State.
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20 Jun 2019 Contract signed by L-6 FZE with International International Worldwide ▪ Contract value commercial in confidence.
Worldwide Air Services Incorporated, UAE for hire of Air Services (UAE) Estimated to be in region of US$ 3M.
2 x IL-76. ▪ Sub-contracted to Reem Style and Leisure.
Reem Style Travel and ▪ 2 x IL76TD used to move the six helicopters
Tourism (UAE) from Gaborone, Botswana to Benghazi, Libya.
22 Jun 2019 Opus A Planning (3 x Super Puma helicopters). Christiaan Durrant ▪ To Willie van der Stoep. Arranged logistics for
Call made by Christiaan Durrant’s mobile phone. move of helicopters from South Africa to
Libya.
22 Jun 2019 Contract signed by L-6 FZE with International L6-FZE ▪ Paid by wire transfer from a Lancaster6 DMCC
Worldwide Air Services (UAE) for charter of IL-76TD Steven Lodge bank account. SWIFT/BIC CITIUS33XXX
for route Gaborone to Benghazi. used to transfer from or through Citi Bank New
York.
22 Jun 2019 Private military operatives arrive in Amman, Jordan. ▪ Some flew in on Royal Jordanian #RJ112.
24 Jun 2019 Confidential documentation refers to Opus expecting Opus 1 ▪

arrival of a UAV in Amman, Jordan. Opus 2
24 Jun 2019 Application from Meridian Air for Jordan Landing Meridian ▪
Permit for the Antonov AN-26 (UR-MDA) shows L-6 FZE
departure flight planned to Benghazi on 1 July 2019.
25 Jun 2019 Opus A Planning (3 x Super Puma helicopters). Christiaan Durrant ▪ To Willie van der Stoep.
25 Jun 2019 Durrant leaves Jordan to destination not yet confirmed. Christiaan Durrant ▪ Next identified as being in the United Arab
Emirates on 29 June 2019.
25 Jun 2019 Funds transfer for advance salary to at least one team Opus ▪ Approx $20,900.
member.
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25 Jun 2019 Pilatus PC-6 (aircraft serial # 790) arrives in Libya ▪ Stephen Lodge admitted PC-6 deployed in his
statement of 13 Sep 20.
▪ Maki confirmed arrival date and he was pilot in
the Opus legal counsel letter of 12 Nov 20.
25 or 26 Jun Charter flight for PMC operatives from Amman, ▪ Possibly Sigma UP-I7601.
2019 Jordan to Benghazi, Libya.
27 Jun 2019 Antonov AN-26 (UR-MDA) arrives OJAM at 00:18 FSG Aviation Limited ▪ FSG Aviation are still officially owners.
hours. ▪ Landing Permit OJAM/M/0143.
27 Jun 2019 Ownership of Pilatus PC-6 (serial# 790) transferred L6 FZE ▪

from Airborne Technologies GmbH to L6-FZE.
27 Jun 2019 Delivery of 2 x MRC-1250 “Special Forces” RHIB Sovereign Charterers ▪ Four-person Sovereign delivery crew.
(Manta-1 and Manta-2) by Sovereign Charterers Limited, Malta ▪ Ritchie and Louw from PMC transited to
Limited, Malta. James Fenech Benghazi on RHIBs.
▪ Customs clearance was gained on 26 June
2020.
27 Jun 2019 Invoice SO002625 for EUR 26,7248 raised from Sovereign Charterers, ▪ Paid 22 July 2019 from a Lancaster6 bank
Sovereign Charterers, Malta to Lancaster 6 DMCC to Malta account.
for Marine Safety Equipment James Fenech
27 Jun 2019 Three Super Puma helicopters seen in Eastern Rand Panzer Logistics ▪
moving towards Botswana border. (Proprietary) Limited,
RSA
27 Jun 2019 Opus A Planning (3 x Super Puma helicopters). Christiaan Durrant ▪ To Chief, Air Traffic Control, Jordan
28 Jun 2019 Inaccurate Single Administrative Document raised for Panzer Logistics ▪ Shows consignee as Jordan Aeronautical Cargo
transfer of three Gazelle helicopters into Botswana. (Proprietary) Limited, Company, Amman, Jordan. Company does not
RSA exist.244
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There is an unrelated company, Jordan Aeronautical Systems Company Limited (JAC) (www.jac.com.jo).
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28 Jun 2019 Inaccurate Single Administrative Document raised for Panzer Logistics ▪ Shows consignee as Jordan Aeronautical Cargo
transfer of three Super-Puma helicopters into (Proprietary) Limited, Company, Amman, Jordan. Company does not
Botswana. RSA exist.
28 Jun 2019 Three Super-Puma helicopters cross Botswanan border Panzer Logistics ▪
at the Tiokweng Border Checkpoint (BCP). (Proprietary) Limited,
RSA
28 Jun 2019 IL-76 TD (UR-CIB) deploys to Gaborone, Botswana ZetAvia LLC ▪

from Amman, Jordan for move of helicopters to
Benghazi, Libya.
28 Jun 2019 IL-76 TD (UR-COZ) deploys to Gaborone, Botswana SkyAviaTrans LLC ▪

from Amman, Jordan for move of helicopters to
Benghazi, Libya.
28 Jun 2019 14:30 hours. Four-person Sovereign delivery crew left Sovereign Charterers, ▪
Benghazi on Afriqiyah Flight # 8U606 to Amman, Malta
Jordan on 28 June 2019 and returned to Malta on James Fenech
Flight # FR8975 on 29 June 2020.
28 Jun 2019 Funds transfer to FSG Aviation Hong Kong bank FSG Aviation ▪ Ownership and aircraft physically transferred
account for purchase of Antonov AN-26B-100 by L6 FZE / Lancaster6 on 22 Jul 2019.
Lancaster6 DMCC. DMCC ▪ Transfer documentation in name of L-6 FZE.
▪ EU 650,000 instead of US$ 650,000 so balance
Christiaan Durrant was recredited to Lancaster6 DMCC.
29 Jun 2019 Unregistered 2SR-H80 Thrush 510G (ex T7-SAW) ▪

refused take-off permission at Nakasangolo Airport,
Uganda.
29 Jun 2019 00:48 hours. IL-76 TD (UR-CIB) flight ZAV9002 ZetAvia LLC ▪ False cargo manifest and air waybill submitted
transports 3 x Gazelle helicopters to Benghazi, Libya to Botswanan customs authorities. Prepared by
from Gaborone, Botswana via Luanda, Angola. Speedway Freight (Proprietary) Limited,
Botswana at personal direction of Franco
Mariotti of Global Africa Aviation.
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29 Jun 2019 10:36 hours. IL-76 TD (UR-CIB) flight ZAV9002 ZetAvia LLC ▪
arrives at Benghazi, Libya at 10:36 hours.
29 Jun 2019 17:10 hours. IL-76 TD (UR-COZ) flight KTR7722 SkyAviaTrans LLC ▪ Consignee listed as Steven Lodge, Opus Capital
transports 1 x Super Puma helicopter (S/N 2161) to Asset LLC, Geological Forward Base,
Benghazi, Libya from Gaborone, Botswana via Benghazi
Luanda, Angola.
29 Jun 2019 21:30 hours. 2 x MRC-1250 “Special Forces” RHIB Steven Lodge ▪ Emergency evacuation ordered by Lodge for
(Manta-1 and Manta-2) leave Benghazi Harbour for allegedly security reasons. 20 private military
Malta. operatives on board.
30 Jun 2019 06:50 hours: IL-76 TD (UR-COZ) flight KTR7722 SkyAviaTrans LLC ▪
arrives at Benghazi, Libya.
30 Jun 2019 MRC-1250 RHIB At Sea. ▪
30 Jun 2019 Calls made from Lodge’s mobile phone. Steven Lodge ▪
(+447387946343) to an individual in Jordan
Aeronautical Systems Company, who were managing
the logistics for the AN-26B aircraft whilst in Jordan.
1 Jul 2019 13:00 hours. 1 x MRC-1250 RHIB (Manta-1) arrives in Steven Lodge ▪ 1 x MRC-1250 RHIB (Manta-2) abandoned
Malta from Benghazi Harbour. during voyage.
▪ Voyage of 39.5 hours @ 9knots.
1 Jul 2019 16:22 hours. IL-76 TD (UR-CIB) flight ZAV9004 ZetAvia LLC ▪ False cargo manifest and air waybill submitted
transports 1 x Super Puma helicopter to Benghazi, to Botswanan customs authorities. Prepared by
Libya from Gaborone, Botswana via Luanda, Angola. Speedway Freight (Proprietary) Limited,
1 or 2 Jul 2019 Maltese lawyer appointed to represent PMC operatives Opus Capital Asset ▪ Not required.
in Malta if required. Limited FZE ▪ Account settled by bank transfer from a
Lancaster6 DMCC account.
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1 Jul 2019 Post-operation calls made regarding entry visas and Steven Lodge ▪ To CS. Works for Global Services Unified
logistics in Malta. Group. A Fenech employee . (Four times).
▪ To Transport Malta. (Four times).
▪ To Malta Post State Control. (Twice).
1 Jul 2019 Post-operation calls received to arrange entry visas and Steven Lodge ▪ To CB. Delivered RHIB to Benghazi. A
logistics in Malta. Fenech employee. (Twice).
▪ To CS.
▪ Inactive UK “Burner Phone 1”.
1 – 4 Jul 2019 Opus A team accommodated in Radisson Hotel, Saint Steven Lodge ▪ Bill paid through www.expedia.com.
Julians, Malta.
Steven Lodge covered the bill for room extras in cash
for the other team members. He used his Mastercard as
guarantee for the hotel.
2 Jul 2019 02:30 hours. IL-76 TD (UR-CIB) flight ZAV9004 ZetAvia LLC ▪
arrives at Benghazi, Libya.
2 Jul 2019 Post-operation calls made from Steven Lodge’s mobile Steven Lodge ▪ To Malta Police.
phone regarding entry visas and logistics in Malta. ▪ To LX. A Maltese policeman who also has an
interest in www.buzzflying.com. (Thirteen
calls).
2 Jul 2019 Post-operation calls received on Steven Lodge’s Steven Lodge ▪ To LX.
mobile phone.to arrange entry visas and logistics in
Malta.
3 Jul 2019 Ownership or control of Pilatus P-6 aircraft ▪ Aircraft re-registered from PH-ABT
(serial#790) transferred from Aircraft and More (Netherlands) to A6-???..
GmbH, Austria to L-6 FZE.
3 Jul 2019 20:09 hours. IL-76 TD (UR-CIB) flight ZAV9006 ZetAvia LLC ▪ False cargo manifest and air waybill submitted
transports 1 x Super Puma helicopter to Benghazi, to Botswanan customs authorities. Prepared by
Libya from Gaborone, Botswana via Luanda, Angola. Speedway Freight (Proprietary) Limited,
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4 Jul 2019 06:07 hours. IL-76 TD (UR-CIB) flight ZAV9006 ZetAvia LLC ▪
arrives at Benghazi, Libya at 06:00 hours.
4 Jul 2019 Lodge flies from Valetta, Malta (MLA) to Aberdeen, Lodge ▪ Flight KL1445
UK (ABZ) via Amsterdam (AMS)
8 Jul 2019 Invoice 00002424 for EUR 61,560 raised from Sovereign Charterers, ▪ For search and recovery mission for abandoned
Sovereign Charterers, Malta to Opus Capital Asset Malta RHIB.
Limited FZE for Marine Fuel and Crew Costs
11 Jul 2019 Durrant’s second meeting with Jordanian Christiaan Durrant ▪

representative. Still purporting to be Gene Rynack
and that his operation was “cleared at the highest
levels”.
Durrant is instructed by the Jordanian representative to
leave Jordan at the earliest possible opportunity.
17 Jul 2019 Antonov AN-26B aircraft AN-26B (serial# 7108) (UR- Christiaan Durrant ▪ Declared as a maintenance visit.
MDA) files flight plan for Moldova
11 Jul 2019 Lodge flies from Aberdeen to Amsterdam on Flight# Steven Lodge ▪
KL1440 and then on to Johannesburg.
17 Jul 2019 LASA T-Bird (YU-THS) files flight plan for Larnaca, Durrant ▪
Cyprus.
22 Jul 2019 Retrospective purchase agreement signed for sale of FSG Aviation ▪ Funds transferred on 28 June 2019.
Antonov AN-26B aircraft AN-26B (serial# 7108) (UR- L6 FZE ▪ Agreement dated 9 July 2019.
MDA) by FSG Aviation to L6-FZE. ▪ Signed by Durrant as Managing Director L-6
Christiaan Durrant FZE, while still in Jordan.
▪ Aircraft still in Jordan.
22 Jul 2019 Antonov AN-26 (UR-MDA) departs OJAM at 16:10 L6-FZE ▪ Departure Clearance OJAM/GA/0114.
hours on flight plan to LTBU, Turkey.
22 Jul 2019 Transfer of EUR 26,748 from Lancaster 6 DMCC to Lancaster6 DMCC ▪ Payment from Lancaster 6 DMCC account with
Fieldsports Limited, Malta for marine safety Amanda Perry Emirates Islamic Bank PJSC.
equipment. ▪ Account# 000370745605XXXX
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26 Jul 2019 1 x MRC-1250 “Special Forces” RHIB (Manta-2) HAF / NOC ▪

found abandoned off the coast of Libya near Zueitina.
1 Aug 2019 Transfer of EUR 449,760 from Lancaster 6 DMCC to Lancaster 6 DMCC ▪ Payment from Lancaster 6 DMCC account with
Sovereign Charterers, Malta for loss of MRC-1250 SF Amanda Perry Emirates Islamic Bank PJSC.
RHIB. ▪ Account# 000370745605XXXX
2 Aug 2019 Eeben Barlow, of STTEP, warns of “false flag” ▪

recruitment of PMC operatives for a PMC operation in
North Africa.
17 Sep 2019 US LD-1 Disclosure Form for Federal Advocates Opus FZE ▪ Lobbying activities with US government or
representation of Opus FZE. representatives unknown.
7 Oct 2019 Holman Fenwick Willan MEA LLP (the Opus legal HFW ▪ Mr Vince Gordan is legal representative.
counsel) (HFW) first engaged with Panel to inform ▪ HFW letters received on. a regular basis each
Panel that HFW represented a client. time Panel approach an individual or entity
linked to the PMC operation.
▪ Proves a coordinated response from an obvious
team.
11 Nov 2019 Antonov AN-26 (UR-MDA) sold to Expedition L6 FZE ▪ Sold for loss of $70,000.
Aviation FZC from L-6 FZE for $580,000. Christiaan Durrant ▪ Disposal of project assets begins.
23 Nov 2019 HFW informed the Panel that they were also consulting HFW ▪ In response to Panel letter of 14 Nov 2019,
with a Mr Matthew Schwartz of Boies Schiller Flexner which clarified modus operandi of the Panel.
LLP (BSF). ▪ Panel unaware of why BSF informed of their
interest.
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17 Dec 2019 Letter from HFW stating that: HFW ▪ In response to specific Panel questions in letter
1) Mr Lodge “worked for a company called Opus Steven Lodge of 9 December 2019.
▪ (1) No information on this alleged contract was
Capital Asset Limited FZE during 2019 (…)
principally for oil and gas clients (…) involved in a sent to Panel by HFW despite follow up
project in Libya in summer of 2019 (…) project had to requests.
▪ (2) Panel notes that Lodge signed three
be abandoned”.
contracts for L-6 FZE of which two were
2) Mr Lodge “has never been Aviation Manager, or settled from a Lancaster6 DMCC account.
authorised to sign contracts on behalf of, any company Panel also notes he stated he was Aviation
called or having a name materially similar to Manager of Lancaster6 on a visa application to
“Lancaster 6”” a Member State in October 2018, with an L6-
Group email contact for the company.
9 Jan 2020 HAF announcement that ships approaching Khums or HAF ▪

Misrata ports will be regarded as legitimate military
targets.
24 Jan 2020 Boies Schiller Flexner LLP (BSF) first engaged with BSF ▪ Mr Matthew L Schartz is legal representative.
Panel to inform Panel that HFW represented a client.
3 Feb 2019 Mr Fenech submits response to the OTR offered to him James Fenech ▪ See appendix W.
by the Panel.
9 Feb 20 Update 1 sent to SCAD for processing. Panel ▪
10 Feb 20 Weavind and Weavind inform Panel they represent Van Dyl ▪
Messrs Stoep and Panzer Logistics.
12 Feb 20 HFW inform Panel they now represent Smit and Bam. HFW ▪
6/7 Mar 20 Opus 2 Team make way to a hotel in Dubai to wait for ▪ Individual 2 arranges $15K payment for each
further instructions on Project Opus 2. person to go to Dubai for briefing.
15 Mar 20 Individual 1 briefs Opus 2 team in a hotel in Abu ▪ Individual 2 subsequently arranges payment of
Dhabi. The Panel is also aware of the flight details for funds to team members for operation.
this individual’s return to their home base. ▪ Meeting may have been on 16 Mar 2020.
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20(?) Mar 20 Project Opus 2 Team possibly fly to Egypt. ▪ Othman Air Base, Egypt (29°33'15.20"N,
25°35'14.74"E).
▪ Cell phones exchanged for “burners”.
2 Apr 2020 Pilatus PC-6 with self-contained aerial reconnaissance L-6 FZE ▪ Arrived on 30 Jun / 1 Aug 19.
(S.C.A.R) pods fitted under wings first identified at
Benghazi (Benina) airport.
6 – 10 Apr 20 Project Opus 2 team deploy to Benghazi (Benina). ▪ Plan to be operational by 20 – 24 Apr 20.
Same base location as Project Opus 1 team.
10 Apr20 Pilatus PC-6 with self-contained aerial reconnaissance L-6 FZE ▪ Position different to 2 Apr 20 siting suggesting
(S.C.A.R) pods fitted under wings identified at movement of aircraft.
13 Apr 20 Project Opus 2 Close Protection (CP) Team left Libya ▪ Project Opus 2 staff used as Close Protection
(Al-Wattiya) on Beech King Air to Uthman Air Base, for UAE teams while waiting for flying tasks to
Egypt. Just before base surrounded by GNA-AF. start.
20 Apr 20 Project Opus 2 CP team and Beechcraft aircraft now in ▪ Project Opus 2 team operations on hold until
Cairo. Air Defence Ground Environment (ADGE) is
more suitable surrounding Tripoli.
▪ Project Opus 2 team refused to fly to UAE,
preferring to stay in Cairo.
23 Apr 20 Pilatus PC-6 with self-contained aerial reconnaissance L-6 FZE ▪ Position different to 10 Apr 20 siting
(S.C.A.R) pods fitted under wings identified at suggesting movement of aircraft.
25 Apr 20 Pilatus PC-6 with self-contained aerial reconnaissance L-6 FZE ▪ Aircraft moved from Benghazi.
(S.C.A.R) pods fitted under wings first identified
operating out of Al Jufra.
28 Apr 20 Pilatus PC-6 with self-contained aerial reconnaissance L-6 FZE ▪ Aircraft moved from Al Jufra.
(S.C.A.R) pods fitted under wings identified at
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15 May 20 Project Opus 2 team paid off. ▪ Paid extra $15K above agreed contract amount
on closure.
20 May 20 Pilatus PC-6 with self-contained aerial reconnaissance L-6 FZE ▪

9 Jun 20 HFW inform Panel that they now also represent Allen, ▪ Only Quintan Charl Paul of the original ‘Malta
Baker, Du Preez, Hogan, Greyvenstein, Jobert G, 20’ is now not legally represented by HFW.
Joubert J, Louw, Ritchie and Schutte.
7 Jul 20 Pilatus PC-6 with self-contained aerial reconnaissance L-6 FZE ▪ No position change since 20 May 20.
20 Jul 20 Panel remotely interview Amanda Perry in presence of ▪ OTR interview

her lawyers.
10 Sep 20 Andrew Furness and Ryan Hogan declined OTR ▪

interview with Panel.
13 Sep 20 Panel receive statement from Steven Lodge’s lawyers ▪ OTR statement
in place of offered OTR interview.
14 Sep 20 Australia Broadcasting Company Four Corners ▪

programme on Durrant broadcast.
15 Sep 20 Gordon contacts all Opus 1 team members and ▪ Confidential source
requests they travel to Dubai, UAE to agree a common
position.
16 Sep 20 Panel interviews Durrant in London in presence of his ▪ OTR interview

lawyer.
29 Sep 20 Travis Maki declined OTR interview with Panel but ▪

agreed to answer written questions.
▪
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Appendix B to Annex 76: Comparison of PowerPoint presentations
# Presentation to HAF Presentation to PMC team Remarks

1 SAME ▪
2 SAME ▪
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3 ▪ Air platforms different.
▪ No mention of Cobra
Attack Helicopter to
team.
▪ No use of word
“Termination” for HVT
in team version.
▪ The Bell 407 MRH is a
variant of the Bell
407GX modified for the
UAE by NorthStar
Aviation LLC of Abu
Dhabi, and delivered in
2016.245
4 SAME ▪
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https://www.airforce-technology.com/projects/nsa-407mrh-multi-role-helicopter/, accessed 3 May 2020.
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5 ▪ Air platforms different.
▪ No mention of Cobra
Attack Helicopter to
team.
6 SAME ▪
7 SAME ▪
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8 ▪ Weapon platforms
slightly different
9 SAME ▪
▪ B407 helicopter on teams

10 rather than MD530
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11 ▪ B407 helicopter on teams
rather than Cobra attack
helicopter
12 ▪ Different air frames.

▪ No mention of HVT
“termination” on teams
13 VIRTUALLY SAME ▪
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14 SAME ▪
15 SAME ▪
16 ▪ More emphasis on aero

medical evacuation on
teams.
▪ EP Slide 16 appears as
CD slide 18
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17 ▪ Presentation to HAF
provides the High Value
Target (HVT) list using
terms “Hot” and
“Dynamic”.
▪ CD presentation to team
again more reassuring
about Aeromed and
Search and Rescue
(SAR).
▪ Note DNT after Usama
Al-Juwali on HVT list
meaning “Do Not
Terminate”. Assumes
then that “Termination”
is the preferred option or
an acceptable option for
all other HVT.
18 ▪ Same as HAF Slide 16
▪ No time frame or
financials presented to
team.
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19 NO SLIDE ▪
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Appendix C to Annex 76: Identification of Durrant and OPUS/GOJO action

Figure 76.C.1 Figure X76C.2
Screenshot of response from confidential source after Screenshot of response from confidential source
being sent picture of Durrant by Panel after being sent phone number of Durrant by
Panel
Figure 76.C.3 Figure 76.C.4 Figure 76.C.5

Screenshot of Message from Durrant on, Screenshot of Message from Screenshot of message from
or about 11 Jul 2019 with proposed flight Durrant on, or about 11 Jul Durrant to confidential source
246
plan for AN-26 on expulsion by GOJO (1). 2019 with proposed flight plan
for AN-26 on expulsion by
GOJO (2).
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246
Durrant made it very clear to the confidential source that End User Certificates could be provide showing Tunisia
if this would be “helpful” to obtaining release of the equipment.
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Appendix D to Annex 76: Sale for SA341 Gazelle helicopters (signed by

Lodge)
Figure 76.D.1
Extract (first and last page) of deed of sale
Figure 76.D.2
Extract from bank confirmation of funds transfer
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Appendix E to Annex 76: L-6 FZE confirmation of use for AS332L Super-
Puma helicopters (signed by Perry)
Figure 76.E.1
L-6 FZE letter to Starlite falsely claiming helicopters for use in Jordan
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Appendix F to Annex 76: Botswana Single Administrative Document for three

Gazelle helicopters
Figure 76.F.1
Botswana Single Administrative Document (28 June 2019) (Gazelle helicopters)
Source: Member State
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Appendix G to Annex 76: Botswana Single Administrative Document for

three Super Puma helicopters
Figure 76.G.1
Botswana Single Administrative Document (28 June 2019) (Super Puma helicopters)
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Appendix H to Annex 76: Air Waybill for SkyAviaTrans LLC flight KTR7722
by IL76TD (UR-COZ)
Figure 76.H.1
Airway Bill (UR COZ) (29 June 2019)
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Appendix J to Annex 76: Air Waybills for ZetAvia LLC flight ZAV9002 -
9006 by IL76TD UR-CIB
Figure 76.J.1
False Air Waybill (UR-CIB) (29 June 2019)
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Figure 76.J.2
False Air Waybill (UR-CIB) (1 July 2019)
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Figure 76.J.3
False Air Waybill (UR-CIB) (3 July 2019)
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Appendix K to Annex 76: Extracts from ZetAvia LLC operated IL-76D (UR-
CIB) flight logbooks
Figure 76.K.1
Flight logbook for ZetAvia LLC operated (UR-CIB)
(29 June 2019) Botswana (FBSK) to Benghazi (HLLB)
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Figure 76.K.2
Flight logbook for ZetAvia L.L.C. operated (UR-CIB)
(1 July 2019) Botswana (FBSK) to Benghazi (HLLB)
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1. Figure 76.K.3 shows one Super-Puma MUH being offloaded from a ZetAvia IL-76TD at
Benghazi (Benina) international airport on 1 July 2019 as further proof of delivery
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Figure 76.J.3.
AS332 Super-Puma helicopter being unloaded at Benghazi (Benina) international airport
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Figure 76.K.4
Flight logbook for ZetAvia L.L.C. operated (UR-CIB)
(3 July 2019) Botswana (FBSK) to Benghazi (HLLB)
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Source: Member State.
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Appendix L to Annex 76: Charter of IL76 from Gaborone to Libya
Figure 76.L.1
IWAS air charter documentation for L-6 FZE (signed by Lodge)
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Appendix M to Annex 76: Procurement of Antonov AN26 (UR-MDA)
Figure 76.M.1
Procurement of Antonov AN-26B (UR-MDA) by L-6 FZE
Source: Panel analysis.
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Figure 76.M.2
Extract from Purchase Agreement by L-6 FZE (22 July 2019)
Note that this is 25 days after the deployment of the aircraft to Jordan, and that the funds were transferred from
Lancaster6 DMCC, not L-6 FZE the purchaser stated here.
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Figure 76.M.3
Credit advice for purchase of AN-26B by Lancaster 6 DMCC (28 June 2019)
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Figure 76.M.4
Copy of Email from Durrant offering AN-26B aircraft for charter (1 May 20219)
This indicates that the AN-26B aircraft was made available to Lancaster6 DMCC by FSG Aviation Limited prior to
the formal sale. The only linkage between FSG Aviation and Lancaster6 DMCC are Erik Dean Prince and Christiaan
Paul Durrant.
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Figure 76.M.5
Subsequent purchase agreement between Expedition Aviation FZE and L-6 FZE
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Appendix N to Annex 76: Procurement of Pilatus PC-6 (#790)
Figure 76.N.1
Procurement of Pilatus PC-6 (#790) by L-6 FZE
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Figure 76.N.2
NL CAA registration of Pilatus PC-6 (#790) as PH-ABR
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Figure 76.N.3
Pilatus PC-6 (#790) as PH-ABR at Cycloon Holland A.B
Source: http://www.aircraft-and-more.com/acadp_listings/pilatus-pc6-b2-h4/, accessed 14 June 2020.
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Figure 76.N.4
Used aircraft purchase agreement (extract) for sale of Pilatus PC-6 (#790) to Lancaster 6 DMCC
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Source: Opus legal counsel.
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Figure 76.N.5
NL CAA record of change of ownership of Pilatus PC-6 (#790) to L-6 FZE
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Figure 76.N.6
NL CAA de-registration of Pilatus PC-6 (#790) as PH-ABR (3 July 2019)
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Figure 76.N.7
Pilatus PC-6 (#790) deployed in Libya (June 2019 to Date)
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Figure 76.N.8
Photogrammetry comparison for Pilatus PC-6 (#790) deployed in Libya
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Appendix P to Annex 76: Procurement of LASA T-Bird (YU-THS)
Figure 76.P.1
Procurement of converted 2SR H80 Thrush 510G (construction number H180-161DC) by L-6 FZE
Source: Panel analysis
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Figure 76.P.2
Dry lease of converted 2SR H80 Thrush 510G (construction number H180-161DC) FSG Aviation to LASA
(extract). 10 June 2015
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Figure 76.P.3
Sale of converted 2SR H80 Thrush 510G (construction number H180-161DC) FSG Aviation to ULL24
(extract). 7 December 2016
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Figure 76.P.4
Sale of converted 2SR H80 Thrush 510G (construction number H180-161DC) ULL24 to LASA (extract). 25
January 2017
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Figure 76.P.5
Sale of converted 2SR H80 Thrush 510G (construction number H180-161DC) LASA to L-6 FZE (extract)
19 June 2019
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Appendix Q to Annex 76: BIMCo charter documentation for MRC-1250

RHIB (Manta-1 and 2)
Figure 76.Q.1
BIMCo Charter for RHIB Manta-1 (Signed by Steven John Lodge)
Source: Sovereign Charterers
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Figure 76.Q.2
BIMCo Charter for RHIB Manta-2 (Signed by Steven John Lodge)
Source: Sovereign Charterers
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Appendix R to Annex 76: Dispersal details of PMC operatives from the RHIB
1. Full biometric details for these individuals are available from the Panel on request.
2. All individuals stayed at the Radisson Blu Resort Hotel, Saint Julian’s 247 whilst in Malta. All rooms were booked, and accommodation paid for
via the www.expedia.com website.
Table 76.R.1
Accommodation and dispersal for individuals in Malta from RHIB Manta-1 (1-3 July 2019)
Departed
Room
Code # Names Nationality Date Destination / Routing Remarks
A Steven John Lodge RSA / 4 Jul 2019 MLA > AMS > UK (ABZ) ▪ Mastercard used as
UK guarantee for hotel extras,
but paid cash
B David Cyrus Button UK 4 Jul 2019 MLA > AMS > PTY > Columbia (MDE) ▪
Sean Arthur Baker RSA 4 Jul 2019 MLA > FRA > South Africa (JNB) ▪
C Andrew Gordon Furness UK 4 Jul 2019 MLA > UK (EMA) ▪ Taxi paid by Visa.
D Sean Callaghan Louw UK 4 Jul 2019 MLA > UK (LGW) ▪ Hotel extras covered by
Andrew Scott Ritchie UK 4 Jul 2019 MLA > UK (LGW) Mr Steven John Lodge
Abel Daniel Schoeman Smit RSA 4 Jul 2019 MLA > FRA > South Africa (JNB)
E Michael Barry James Hardy Allen RSA / 4 Jul 2019 MLA > LCA > Dubai (DXB) ▪ Mastercard used as
UK guarantee for hotel extras.
Lucas Cornilius Schutte RSA 4 Jul 2019 MLA > FRA > South Africa (JNB) ▪
F Matthew Coughlin AUS 4 Jul 2019 MLA > CDG > Dubai (DXB) ▪ Paid hotel extras in cash.
Quintan Charl Paul RSA 4 Jul 2019 MLA > FRA > South Africa (JNB) ▪
G Richard Milton Parish AUS ▪ Paid hotel extras in cash.

H Travis Alden Maki USA 4 Jul 2019 MLA > LCA > Dubai (DXB) ▪ Paid hotel extras in cash.
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Departed
Room
Code # Names Nationality Date Destination / Routing Remarks
J Ryan Hogan RSA 4 Jul 2019 MLA > UK (LGW) ▪ Paid one night with
Mastercard.
K Andre Melt greyvenstein RSA 4 Jul 2019 MLA > LCA > Dubai (DXB) ▪ Paid hotel extras in cash.
Christian Nicolaas Gerhardus du RSA 4 Jul 2019 MLA > FRA > South Africa (JNB) ▪
preez
L Giliam Ferdie Joubert RSA 4 Jul 2019 MLA > FRA > South Africa (JNB) ▪
Hendrick Johannes Bam RSA 4 Jul 2019 MLA > FRA > South Africa (JNB) ▪
M Rudi koekemoer RSA ▪
Joseph Benjamin Joubert RSA ▪
Source. Confidential (CS5)

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Appendix S to Annex 76: MRC-1250 RHIB in Zuetina, Libya
Figure 76.S.1
MRC-1250 RHIB recovered to Zueitina
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Appendix T to Annex 76: Counterfeit document used to support air

transportation
Figure 76.T.1
Extract from counterfeit document used to support air transportation
Source: Member State.
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List 76.T.1
Discrepancies identified by the Panel
1. No company registration number, URL address or EMail addresses for either Confidence
Security Consulting nor Opus Capital Assets DMCC appears anywhere in the documentation.
2. No name for the Confidence Security Consulting signatory appears in the documentation.
3. Opus Capital Assets appears as a DMCC company throughout the document, but as an FZE
company on the cover page.
4. No post nominals appear after the Confidence Security Consulting name anywhere in the
document to indicate where the company is registered (e.g, F.Z.E, P.J.S.C, plc, etc).
5. Although the RfP does include the fact that three AS332 Super-Puma and three SA341 Gazelle
are to be used in the survey, the image of the Super-Puma displays a registration number N7801F.
This particular aircraft was listed as belonging to Heligroup Puma L.L.C in Missoula, MT, USA on
12 June 2018, and then sold to Air Centre Helicopters, Burleston, Texas and registered as N830AC.248
The aircraft is currently (as at 10 September 2019) assisting the Hurricane Dorian relief operations in
the Bahamas, and is almost certainly not owned by Opus Capital Assets DMCC.
6. The document also shows an image of an Antonov AN-26 with the registration UK-MDA. That
registration prefix is used by Uzbekistan. The image is that of a Ukrainian registered aircraft, UR-
MDA, which flies with a Frontier Services Group logo on the fuselage.249 The aircraft is owned by
FSG Aviation Limited (Bermuda)250 and operated by Meridian Aviation Enterprise of Special Purpose
PJSC. (Ukraine).251
7. The document is poorly laid out and an obvious “cut and paste” fake. It is nowhere near the
quality of an RfP been professionally prepared for a contract listed at US$ 85 million in the document.
__________________
248
www.helis.com/database/cn/25955/. Accessed on 9 September 2019.
249
www.jetphotos.com/photo/8157762. Accessed on 15 September 2019.
250
www.atdb.org. Search on 14 September 2019.
251
Ibid.
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Appendix U to Annex 76: Email thread linking Bridgeport, PC-6 and Prince
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Appendix V to Annex 76: Christiaan Paul Durrant’s response to the Panel’s

opportunity to reply
PANEL NOTE: This summary is based on contemporaneous notes taken by both Panel members
during the interview in London on 16 September 2020.
1. The Panel explained the appropriate Security Council resolutions to Christiaan Paul Durrant and
explained the mandate and working methods of the Panel. The Panel also explained the timelines and
subsequent status of the final mandated report of the Panel. Christiaan Paul Durrant was offered the
opportunity to make an initial opening statement, in which he covered:
(a) His concerns about the leaks to the press of the Panel’s updates to the Committee and press
access to documentation.
(b) That the investigation was politically motivated and that Erik Prince was obviously the target of
the investigation. He emphasised that whilst Erik Prince was a personal friend he was not involved
with the operation;
(c) He expressed concerns about the wide number of violations and hoped the Panel were pursuing
all with equal zeal; and
(d) He denied any violations of the Libya arms embargo.
2. The Panel responded by explaining:
(a) That the Panel was equally concerned by press leakages as it was not helpful to the wider
investigations of the Panel if witnesses thought the Panel leaked. Christiaan Paul Durrant was assured
that the leaks were not from the Panel nor the UN Secretariat, but were wider than that;
(b) The Panel explained that its investigations were carried out strictly in accordance with: 1) the
best practices and methods recommended by the Informal Working Group of the Security Council on
General Issues of Sanctions (see S/2006/997); 2) Annex III to Experts’ Terms of Reference Building
a Statement of Case for Security Council Sanctions Regimes (Version of 26 January 2017; and 3)
Appendix B to Annex 3 of Panel report S/2019/914. The Panel emphasized that their investigations
were not politically motivated and that they purely “followed the evidence”. The Panel expressed
surprise that Erik Prince was again being linked to this operation by statements from HFW clients,252
as this name had not been used by the Panel in any updates or requests for information; and
(c) The Panel informed Christiaan Paul Durrant that whilst it would be inappropriate to share details,
that the Panel was investigating a wide variety of cases with similar due diligence, which would
become apparent on publication of the Panel’s final report in early 2021.
3. The Panel then asked Christiaan Paul Durrant a wide range of detailed questions which he was
reticent to reply demanding to know their relevance to sanctions violations in Libya. The Panel
__________________
252
First mentioned in written statement by Steven Lodge dated 13 September 2020.
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explained that they were trying to get an overall view of the operation, and that his answers may
verify, or otherwise, information already in the possession of the Panel. The questions and answers
below are of relevance:
(a) When asked about the company structure of L-6 FZE, Lancaster6 DMCC and Opus Capital
Assets FZE Christiaan Paul Durrant explained that: 1) L-6 FZE acted as an “asset holding company”;
2) Lancaster6 DMCC as a “consulting company”; and 3) Opus Capital Assets FZE as a “logistic
services provider. Christiaan Paul Durrant stated that he was Managing Director of all three
companies, which were established using his personal capital.
(b) When asked about Opus Capital Asset DMCC Christiaan Paul Durrant said that he had meant
DMCC in his previous answer and that he had no knowledge of the FZE company. This is contrary
to statements previously provided by his legal counsel that the Opus DMCC company was nothing
to do with their clients and they did not represent that company.
(c) On each question relating to a company, Christiaan Paul Durrant specifically and voluntarily
advised that Erik Prince was not involved with that particular company.
(d) He was reluctant to tell the Panel who the authorized signatories were to the companies’ bank
accounts mentioned by the Panel,253 but stated that they had all now been closed.
(e) Christiaan Paul Durrant explained that he had resigned as a Director of Umbra Aviation,
although was still a 50% shareholder. When asked why South African official records showed him
as a Director he had no credible explanation.
(f) Christiaan Paul Durrant stated he was aware of the company Confidence Security Consultancy
(CSC), which was Lebanese owned and based in the UAE. He explained that Opus had a contract
with them for an Oil and Gas Survey of Jordan, and that the proposal had used background
information on Jordan obtained through a commercial agreement with Bridgeporth. Bridgeporth had
previously denied any contractual agreements with Opus.254 In response to a further enquiry by the
Panel255 regarding CSC he stated256 that they were prevented by confidentiality obligations from
supplying this information. CSC did not respond to the Panels request for information.257
(g) Christiaan Paul Durrant then explained that the Jordan contract fell through in late June 2019 so
he instructed that the helicopters from South Africa be diverted from Jordan to Libya. He could not
be specific on the date. The Panel has evidence to the contrary in that the initial contract on 20 June
2019 for the charter of the IL-76 aircraft clearly stated the charter was from Gaborone, Angola to
Benghazi, Libya.
__________________
253
Lancaster6 DMCC: Noor Bank (000241096278XXXX) and Emirates Islamic Bank (000370745605XXXX). Opus
Capital Assets FZE or DMCC: Emirates NBD Bank (101546753XXXX).
254
EMail to Panel of 5 December 2019. The Panel sent a further letter on 18 September 2020 to Bridgeporths’ lawyers,
Boies, Schiller, Flexner LLP (BSF), New York, but has yet to receive a response. The Panel notes it is unusual for a UK
based company to use the services of a US legal firm.
255
Panel letter of 25 September 2020.
256
Opus legal counsel letter of 9 October 2020.
257
Confidence Security Co, 7 Floor, Office 702A, Kamala Tower 2, Al Had Street, Al Khalidiyah, Abu Dhabi, UAE.
+971 2 6760660. The Panel has not elicited a response to this number.
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(h) Christiaan Paul Durrant then explained that the Opus A team in Jordan from 1 June 2019 was
there to inspect Royal Jordanian Air Force helicopters for sale on behalf of other clients. When
pressed he could not name any clients and the Panel wrote258 asking for evidence of this statement.
HFW responded on 9 October 2020 that at the 16 September 2020 meeting Christiaan Paul Durrant
had “indicated that there was a special permission in place from the Jordanian Government (…).
There is no engineering data (…) in our client’s possession”.
PANEL NOTE: The Panel is not convinced by this statement as: 1) the 18 June 2019 SITREP, which
Christiaan Paul Durrant accepts came from his team makes it clear what his presence in Jordan was
really for; and 2) the Jordanian Government informed the Panel that it does not have any relationship
with (…) private military operation under investigation”259 and that “the individuals (…) are not
known to the Jordanian authorities and they have not dealt with them”.260
(i) Christiaan Paul Durrant explained that the operation in Libya was to establish a logistic hub as
he had evidence of such a market requirement.
PANEL NOTE: The Panel notes that this is now a variation of previous “cover stories”, and refer to
it as ‘Cover Story 3’.
(j) Christiaan Paul Durrant was unaware of the purchase costs for the three ‘Super Puma’
helicopters and could not provide even a rough estimate.
PANEL NOTE: The Panel is unconvinced by this response, as it is highly unlikely that the Managing
Director of a personally funded company would not know the value of the company’s major assets,
particularly as his lawyer had already informed the Panel that company assets in excess of 15M
USD261 were abandoned in Libya.262
(k) Christiaan Paul Durrant agreed that a normal purchase for an aircraft would be to inspect and
receive an aircraft before transferring funds. He could not explain why the procurement process for
the Antonov 26B was so truncated, nor why the documentation was signed two weeks after L-6 FZE
took possession of the aircraft in Jordan.
(l) When asked about the LASA T-Bird Christiaan Paul Durrant emphasized that it wasn’t
weaponized and that it deployed to Jordan without the ISR sensor. When asked what the point of the
deployment was then, he explained that the sensor was due to arrive separately and that there was a
legal case outstanding with LASA Engineering in Bulgaria over this issue.
PANEL NOTE: The Panel accepts that it is possible the aircraft deployed without any wing mounts
for weapons but notes they could be carried internally or shipped separately and easily retrofitted
anyway. The Panel is totally unconvinced that the aircraft was not weaponized, in that all the
armoured seats, explosion protected mesh fuel cell, internal cabling, targeting computers, sensor
__________________
258
Panel letter of 25 September 2020.
259
Letter from Jordan dated 6 April 2020.
260
Letter from Jordan dated 10 August 2020.
261
As the only know assets abandoned were the three Gazelle and three Super Puma helicopters, and the three Gazelle
were purchased for an estimated USD2M, then the Super Puma were probably purchased for USD4M each.
262
HFW letter of 7 January 2020.
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controls, weapon release controls that were fitted in 2015/2016, when Christiaan Paul Durrant was
the Project Manager for the LASA development, were almost certainly not removed prior to this
deployment. Christiaan Paul Durrant claims not to know the name of the pilots or crew of any of the
aforementioned aircraft; this the Panel finds highly unlikely considering the small size of the
companies concerned and Christiaan Paul Durrant’s history with this particular aircraft.
(m) In the written supplementary questions from the Panel of 25 September 2020, Christiaan Paul
Durrant stated that; 1) was unable to supply information on the crew of the AN-26B owned and
operated by his company at that time; 2) provide the location of the LASA T-Bird – a major asset
owned by his company; 3) provide the current registration for the Pilatus PC-6 owned and operated
by his company and operating in Libya from late June 2019 to date.
PANEL NOTE: The Panel considers it highly unlikely that he did not know this information, nor had
access to it.
(n) Christiaan Paul Durrant was not prepared to answer any questions relating to the US lobbying
firm, Federal Advocates Inc, contracted by Opus FZE on 17 September 2019.
PANEL NOTE: Federal Advocates Inc (USA) disclosed on 17 September that they had been engaged
to provide lobbying services relating to Defence Fuel/Gas/ - Working with the Administration on
geopolitical issues. This was changed on 16 October 2019 to “Oil and gas logistics service –
providing educational background to the administration. The company failed to cooperate with the
Panels’ requests for information and clarification.
(o) Christiaan Paul Durrant finally explained in his interview that all the work in Libya was
unfunded by external sources, there were no contracts for the deployment and that all the risk was
self-insured. Again, the Panel is unconvinced of this explanation.
(p) In his response to the written supplementary questions from the Panel of 25 September 2020,
Christiaan Paul Durrant stated that the PowerPoint presentations at appendix B to annex 76 were
being “falsely attributed to Opus” and were the “property and work of other unrelated groups looking
to be active in Libya”. He claimed to have “substantial amounts of information” which he would only
share if “satisfied that the investigative process is being conducted in accordance with internationally
accepted standards relating to due process and which also affords proper protection to individuals
who offer their cooperation”.
PANEL NOTE: As the Opus legal counsel have been informed on a number of occasions as to the
mandate, working practices and processes of the Panel, it is difficult to see what would persuade
Christiaan Paul Durrant to release this “relevant information” such as it exists. Indeed, based on the
evidence to date linking him to the Opus A operation, his lack of cooperation at a substantive and
detailed level, and the fact that three ‘cover stories’ have now been used, the Panel considers that
Christiaan Paul Durrant’s offer is just another delaying tactic. However, in order to follow due process
at that stage of an ongoing investigation, the Panel wrote to Christiaan Paul Durrant a final time 263
requesting that any further information be released to the Panel. His response of 12 November 2020
was again to refuse to share this “relevant information”.
__________________
263
Panel letter of 15 October 2020.
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Appendix W to Annex 76: James Fenech and Sovereign Charters’ legal response
to the Panel’s opportunity to reply
PANEL NOTE: The original version of this document was submitted by Email to the Panel at 12:19
hours on 3 February 2020. The Panel certifies that this is a true copy of the content, style and layout
of the original document received by the Panel on 3 February 2020.
I’ll start off by reproducing the part of your email which is of particular concern to us.
“The Panel will very likely include your client’s name, and his company Sovereign Charters
Limited (Malta), in the forthcoming update to the Sanctions Committee as having being
in technical non-compliance with paragraph 9 of resolution 1970 (2011) for the provision
and transfer of military equipment to a private military company supporting an armed group
in Libya. The Panel will emphasise that Mr Fenech cooperated fully with the Panel and
acceded readily to all information requests during the investigation. The Panel also
considers that Mr Fenech was unaware that the transfer of an unarmed military vessel would
be a non-compliance of the sanctions measures, and will reflect this in their update. Please
not the use of the word Technical as opposed to deliberate.
The two RHIB vessels his company chartered to Opus Capital Asset FZE are advertised on
the Sovereign Charterers website as being “special forces RHIBs … hardened for maritime
security operations”. The Panel thus finds them to be military equipment under the ambit of
paragraph 9 to resolution 1970 (2011). This finding is supported by the definition in
Common Military List of the European Union. ML9.(a).1. “ (…) other surface vessels.
Vessels (…) modified for military use (…) regardless of whether or not they contain (…)
weapon delivery systems”.”
We trust you appreciate that including my client’s name and his company’s name in an update to the
Sanctions Committee could potentially have devastating consequences on him personally and on his
company’s business and future. We understand the distinction you make between being “technically”
non-compliant and “deliberately” non-compliant. The latter form of non-compliance has been
correctly discarded by your good self and we will therefore not go into the matter.
We respectfully point out that we are gravely concerned by the fact that your conclusions regarding
technical non-compliance are founded on a serious misconception regarding the RHIBS in
question. This misconception stems from the fact that it is evident to us that your conclusions
regarding the military nature of the RHIBS rely solely on the description given on the Sovereign
Charterers website. We concede that the description on the website, which is intended solely for
business purposes, may be misleading.
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PANEL NOTE: The Panel’s finding of the military nature of the vessels does not rely solely on
Sovereign Charterers description on their website. Indeed, the Panel finds that description to have
been accurate, rather than as is now claimed “misleading”. The Panel notes that the description has
changed subsequent to the Panel’s first showing interest in this matter to Mr Fenech and Sovereign
Charterers Limited.
We therefore request that, prior to reaching a conclusion that could potentially have dire consequences
for client and his company, we would like to invite you in physically examine the RHIBS to remove
any doubts that you may have as to their military nature. One of these vessels is in client’s possession
and we are at your disposal to make it available for proper examination and inspection.
The other vessel has been reported lost at sea. From the initial data provided by the charterer, Manta
2 hit a rock during the evacuation procedures soon afterwards the vessel systems started to fail and
water started to flood the vessel following the single catastrophic event. Client personnel had no
choice but to go on board the other Rhib abandon the vessel and continue towards Malta. From media
reports the vessel was visibly submerged but floating indicating the charterers version of events.
PANEL NOTES: (1) The other vessel is not lost at sea, but is in Zuetina harbour, Libya. (2) This
statement contradicts that of Mr Gordon, Opus legal counsel’s response to the Panel of 31 January
2020 to an OTR to his clients, in which he states that “the vessel did not suffer any incident other
than that it was possibly unsuitable for the voyage being undertaken at such short notice”.
Apart from this we are attaching a number of documents that will evidentiate the misunderstanding
resulting from an exclusive reading of the description given on the website.
One document that we are attaching is a survey report dated 29th January 2020 drawn up by Engineer
Paul D. Cardona. This report, which was drawn up for registration and classification purposes in
compliance with national regulatory requirements, refers to surveys carried out in the years 2017 and
2018, i.e. prior to the incident in question. It is also evident from this report that no modifications on
the vessels were carried out. The report also includes a list of installations on one of the vessels,
which installations were carried out by the client in order to try and upgrade the vessel classification
from “pleasure” to “commercial” which are mandatory at law.
We invite you to contact Ing. Paul D. Cardona in order for him to confirm his findings.
Another document that we are attaching relates to the technical specifications of the RHIBS in
question. This document was drawn up by the manufacturers New Madera RIBs B.V. It is also
evident from this document that the RHIBS in question were not manufactured with any special
material, design and/or equipped with any equipment which is required for Military applications. The
same RHIBS can be procured by private individuals or companies without the need of any licences,
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End User Certificates and other pertinent legal requirements for purchase of new military Naval
Vessels.
PANEL NOTE: The Panel has consulted with New Madera RIBs B.V regarding this issue. The
companies own website lists virtually identical vessels under their military section rather than civilian
section as shown in figures 76.W.1 to 76.W.4 for comparison. The company also confirmed to the
Panel that it rarely, if ever, sold all black RHIBs with all black engines, to other than military or
security clients. Vessels destined for rescue, passenger or commercial work were usually coloured.
The Panel finds that specifications alone are not necessarily the definitive criteria as to a vessel’s
intended function and use.
Figure 76.W.1 Figure 76.W.2

Madera MR-1250 Commando from manufacturers website a Sovereign Charterers MRC-1250 Manta-1 and 2 b
Figure 76.W.3 Figure 76.W.4

Madera MR-1250 Cargo from manufacturers website b Sovereign Charters MRC-1250 Manta-1 or 2 d
a
Image 2/12 from https://www.m-ribs.eu/boat/mr-1250-commando/, accessed 3 February 2020.
b
c
Image 1/7 from https://www.m-ribs.eu/boat/mr-1250-cargo/, accessed 3 February 2020.
d
Another document/s we are attaching are Certificates of Survey issued by Transport Malta, dated
2nd March 2017, wherein the vessels are clearly classified as “Pleasure Boat[s]”.
PANEL NOTE. The Panel accepts that the vessels were probably used in a pleasure or commercial
capacity when in Malta.
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We also attach, for all intents and purposes, a letter from Dr Nicholas Valenzia whose law firm Mamo
TCV Advocates was engaged by client to draft the charter party agreements. In this letter it is stated
that client requested a due diligence exercise to be carried out on Opus Capital Asset Limited FZE
which exercise resulted in the negative.
PANEL NOTE: It is not for the Panel to comment on the effectiveness of a due diligence exercise
conducted by a third party.
It is evident that client had undertaken reasonable steps to ensure that the charterer was neither
identified with illegal activities (through background checks) nor was intending or permitted under
the terms of the charter agreement to commit such illegal acts. Instead, client understood that the
vessels were chartered for the exclusive purpose of evacuation.
PANEL NOTE: Considering Mr Fenech’s known close linkages to private military and security
companies, and their operatives through the auspices of his other businesses, (e.g. Fieldsports
Limited, Malta (C54571), PBM (Precision Ballistic Munitions) Limited, Malta (C78445) (who also
own Blackwater Ammunition, Malta)), the Panel finds it unlikely that he found this to be a credible
explanation considering the individuals and organizations involved in the charter of the vessels.
We request that in your review of the original charter contract you take note that client had expressly
stated that responsibility for any and all actions subsequent to delivery lied solely with the chartering
party. This to the extent that the charterer is expressly indemnified by the chartering party and the
charterer dissociated from any consequent actions or inactions until the point of return of the
vessel. Such steps as could be taken to understand the background of the charterer, and to
contractually prevent them from undertaking any illegal activity were taken by client. In such
circumstances we feel that it would be unreasonable to name my client in your report. We also feel
it unreasonable to directly or indirectly associate client with whatever actions may have been
undertaken by the chartering party.
PANEL NOTE: As above.
We trust that an examination of all the attached documents together with an examination of the
RHIBS in questions will eliminate any doubt you may have regarding technical compliance.
Once again client kindly requests that your queries be made in writing and reiterates his intention to
cooperate fully with your investigation.
Regards
Steve
416/548 21-01654
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Dr. Steven Tonna Lowell
a: 206, Wisely House, Level 2, Old Bakery Street, Valletta VLT 1451, Malta
t: +356 21224276 m: +356 79010797
Confidentiality Note:
This email may contain privileged, confidential, copyrighted, or other legally protected information and is for the sole
use of the intended recipient(s). The information contained in this message including any attachments is proprietary
of Dr. Steven Tonna Lowell. The information is intended to be conveyed only to the designated recipient(s) of the
message. If the reader of this message is not the intended recipient or the responsible party to deliver it to the intended
recipient, you are hereby notified that any dissemination, use, distribution or copying of this communication is strictly
prohibited and may be unlawful.
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Appendix X to Annex 76: Statement by Steven John Lodge in response to the

Panel’s opportunity to reply (13 September 2019)
PANEL NOTE. The original .pdf version of this statement was converted into .docx format to
allow for the Panel to make appropriate notations in response to Lodge’s comments. The Panel
certifies that this is a true copy of the content, style and layout of the original document received
by the Panel on 13 September 2020. The Panel sent a letter on 17 September 2020 with
supplementary questions and Mr. Lodge’s responses (dated 29 September 2020) are included
under Panel Notes below, as appropriate.
PRIVATE AND CONFIDENTIAL
STATEMENT TO THE PANEL OF EXPERTS FOR LIBYA ("PANEL"),

UN SECURITY COUNCIL SANCTIONS COMMITTEE ("UNSC")
by STEVEN LODGE
1. I am providing this voluntary statement on the basis that the information is provided subject to
absolutely confidentiality being provided by the Panel and the UNSC. It is also solely provided to the
Panel and the UNSC for the purposes stated below and may not be provided to, or relied upon, by
any other party or entity.
PANEL. The Panel has asked Mr. Lodge if he wishes any redacted version to be included in the final
public Panel Report. Mr. Lodge is content for this Statement to be included in full in the final public
report to the Committee.
2. I am providing this voluntary statement so as to cooperate with the Panel and specifically to
respond to their requests for information. It would be incorrect accordingly for the Panel to consider
or report that I have failed to cooperate with the Panel and I am replying by this statement to their
offer of an opportunity to reply. It would also be incorrect and fail due process for the Panel to base
its reporting on information it otherwise may hold without taking into account this statement.
3. I am providing this voluntary statement so as to clarify various aspects of your investigation
and show that my actions were not in contravention of or non-compliance with Paragraph 9 of UNSC
4. I have not directly or indirectly supplied arms and related materiel or technical assistance,
training, financial or assistance related to military activities or the provision, maintenance for use of
any arms in related materiel, including the provision of arms or mercenary personnel.
5. I have not violated, or assisted in the evasion of, the provisions of the arms embargo in Libya
established by UNSC resolution 1970 (2011). I should not be named or recommended for designation
in any Panel or UNSC report.
6. I have not been provided any evidence or proof to the contrary or shown any evidence that is
the basis of any allegations to the contrary. As expressed previously, I have significant concerns about
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engaging with the Panel’s requests for co-operation in its investigations, particularly where I have
had no fair opportunity to review or respond documents, whilst the investigation is ongoing, and I
therefore remain unable to comment in any substance.
PANEL. Mr. Lodge would have had some documentary evidence explained to him during a formal
OTR interview, which he declined. The Panel was not prepared to share any copies of the
documentary evidence with him at that time as this evidence also applies to other individuals who
would be forewarned of the case against them. This was a legitimate Panel decision to protect the
integrity of their investigation. The decision was taken under the ambit of paragraph 2 (b) (v) of
Appendix B to Annex 3 of Panel Report S/2019/914 “for any other reason that can be clearly
demonstrated as reasonable and justifiable in the prevailing circumstances”. The Panel shared
appropriate documentation relating to this case with his legal counsel on 22 December 2010.
7. What I do want is for misinformation to be cleared up and for a fair enquiry to be conducted by
the Panel.
PANEL. The investigation has been carried out strictly in accordance with: 1) the best practices and
methods recommended by the Informal Working Group of the Security Council on General Issues of
Sanctions (see S/2006/997); 2) Annex III to Experts’ Terms of Reference Building a Statement of
Case for Security Council Sanctions Regimes (Version of 26 January 2017; and 3) Appendix B to
Annex 3 of the Panel’s Interim Report to the Committee.
8. I note that the Panel’s previous confidential report was leaked following its presentation to the
UNSC, and that the contents of the report have now been widely circulated in the media. I have been
hounded by the press as a result of this. Aside from prejudicing the investigation itself, the apparently
wide circulation of the Panel’s report has been highly prejudicial to my private life and business
interests.
9. My trust and confidence in the investigative process has been seriously undermined by the
disclosures made to the media. I am justifiably concerned that any further engagement with the
Panel’s investigation would lead to the same outcome.
PANEL. The leak is unfortunately also exogenous to the Panel. As indicated, the Panel conducts its
investigations following the best practices and methods above indicated and maintains absolute
confidentiality about its investigations.
10. I ask that I be given an opportunity to respond or to comment on anything that is proposed to
be included in any reports, because clearly once it is in a report, whether or not it is confidential or
subsequently appears elsewhere, it is too late once the report has been provided. Given the potential
adverse consequences for me, it is incredibly important that I be given a real opportunity to understand
the allegations and it would be completely inappropriate for the allegations to be included in your
reports to the UNSC without having my informed reply.
PANEL. Mr. Lodge was offered an opportunity to reply interview (Email of 20 July), he initially
accepted but then had to delay due to family circumstances (E Mail of 29 July 2020). He was offered
a later date (in an Email of 17 August 2020) but declined (Email of 2 September 2020). He was again
offered a later date (Email of 2 September 2020), which he again declined preferring instead to make
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this written statement. Mr. Lodge has stated that he has provided a “detailed and substantive”
statement. The Panel will comment on this later in this document.
11. Finally, I put to the Panel whether they are pursuing all alleged participants in the current Libya
conflict with the same zeal which they are pursuing me and these events – it is not at all clear why
the "non- events" that I was involved with in June 2019 are being singled out in this way when every
day there seems to be reporting of activities which are much more clearly in breach of the arms
embargo which the Panel is entrusted with monitoring.
PANEL. His legal counsel was informed prior to the interview with Mr. Durrant on 16 September
2020, that whilst it would be inappropriate of the Panel to share details, that the Panel was
investigating a wide variety of cases with similar due diligence, which would become apparent on
publication of the Panel’s Final Report in early 2021. It is reasonable to assume that this information
would have been passed on to Mr. Lodge.
12. In addition, I would like to know if an internal investigation of the Panel and UNSC members
has been undertaken by an independent external authority to determine who is responsible for the
leaks for the reports to the media. If none has been actioned then I wish to know why not.
PANEL. His legal counsel was informed immediately prior to the interview with Mr. Durrant on 16
September 2020, that they could be assured that neither the Panel nor Secretariat were the sources of
any leaks. Beyond that it would be inappropriate for Panel to comment further. Mr. Lodge was
informed that this is a matter which is not within the purview of the Panel’s mandate or work and
hence the Panel is unable to comment further. Mr. Lodge subsequently requested details of where
breaches of confidentiality are most appropriately referred to at the United Nations. He was informed
in October 2020 that this was a matter which is not within the purview of the Panel’s mandate nor
work and hence the Panel is unable to comment further.
13. By submitting this statement I do not waive any of my rights (and expressly reserve them) or
any applicable privilege or protection. I continue to request that the Panel and UNSC keeps this matter
confidential and does not make public the fact that it is in contact with me. This includes in respect
of journalists and the media.
Background
14. The following background is provided with intent to assist your greater understanding of the
narrative of the events under investigation.
15. I am an aviation professional, specialising in helicopter services.
16. I was approached and engaged on a pilot's rate in April 2019 regarding assisting with a project
to establish a logistics hub involving helicopters in Middle East/North Africa Region.
PANEL. Mr. Lodge was subsequently asked in a letter of 17 September 2020 to provide documentary
evidence of this in the form of contracts and bank statements. Mr. Lodge responded that such
documents were not managed or handled by him and were outside his scope of work. This is not
consistent with the statement of Mr. Durrant who stated that there were no such documents, as the
venture into Libya was purely speculative, and was taken at financial risk to the company.
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PANEL. The Panel was informed on 17 December 2019 that Opus was involved in a project in Libya
in Summer 2019, and that Opus provide oil and gas support services. On 31 January 2020 the Panel
was then informed that Opus was to provide oil support services for a contract initially in Jordan, and
then the helicopters were diverted for a project in Libya. This statement is the first mention of the
establishment of a logistics hub. The Panel does not consider, for example, that a PC-6 aircraft fitted
with two ISR pods, or a LASA T-Bird aircraft with internal fitments to target and deliver weapons,
are the sort of aircraft required for a logistic support hub.
17. My role was to manage logistics and assemble the helicopters when they arrived.
18. I gathered with other personnel in the middle of June 2019 in Amman, Jordan. This was a small
team of approximately 20 personnel who, like me, were aviation and logistics specialists.
PANEL. This is incorrect as the Panel has flight record evidence that Mr. Lodge first flew to Jordan
on 1 June, leaving on 16 June 2020. His return date from Dubai to Jordan prior to deployment to
Libya is not known. Mr. Lodge was subsequently asked to provide flight and accommodation details.
He could not remember the accommodation used in Jordan, nor the flight details as he had not booked
them.
PANEL. Mr. Lodge was subsequently asked for a copy of his entry and exit Visas for Jordan. He
responded that he was not required to gain an entry visa for Jordan. This is contrary to the information
supplied by the Government of Jordan (http://www.dirco.gov.za/foreign/bilateral/jordan.html),
which advises that although visas are available on arrival it is recommended they are obtained in
advance.
PANEL. Mr. Lodge was subsequently asked for a copy of his entry Visa for Libya. He responded that
he assumed he could get an entry visa on arrival; however this did not occur. The Panel has confirmed
that only Jordanian and Tunisian citizens may enter Libya without a visa. The lack of a visa for Mr.
Lodge can only mean that his entry into Libya was facilitated by the Haftar administration, or he
entered illegally.
19. This team was tasked to travel from Amman to Benghazi via chartered IL76 in late June. We
took in no military equipment. Our loads were principally water, MREs (meals ready to eat), tents
and camp cots.
PANEL. The Panel asked for details of the IL-76 cargo aircraft (registration # and flight #), and also
why an aircraft with a payload of 50 tonnes was needed for such a small deployment. Mr. Lodge
provided no substantive comment and stated he was not responsible for the cargo manifest or air
waybill for that flight.
20. The deployment of assets and personnel to Libya resulted in aircrew, engineers, medics,
technical and security staff being deployed from Jordan to Libya. Security staff were provided to
secure the project's assets and personnel; they had NO weapons with them.
21. We were instructed to establish a camp and helicopters for the purpose of providing logistics
services.
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PANEL. The Panel subsequently requested the geo-coordinates of the Opus camp, and also contact
details for their Libyan interlocuters. Mr. Lodge responded that he could not be certain of the location
as their driver took an indirect route. The Panel is unconvinced of this response, as: 1) if Mr. Lodge
did not know where the camp was, how could he know an indirect route was used; and 2) as a former
professional military officer it would be second nature for him to be aware of his location at all times,
if only for security reasons.
22. No helicopters arrived during the period we were there. i.e. the helicopters arrived after our
personnel had departed.
PANEL. Mr. Lodge was asked to reconsider this statement as the Panel is aware that the three Gazelle
helicopters arrived at 10:36 hours on 29 June 2019 (Flight KTR7722), eleven hours before the stated
time of departure. The air waybill for this flight had Mr. Lodge’s name and cell phone number as the
contact point on arrival. Mr. Lodge stood by his initial statement. Again the Panel is unconvinced of
the veracity of this response.
23. After we had been on the ground in Benghazi for a short period, I became concerned for the
safety of our personnel. There were multiple un-identified military personnel around where we were
located, which increased steadily. I was approached by various individuals who seemed to be
associated with military organizations there who started insisting that the helicopters (which were yet
to arrive) be used for illegal tasks.
PANEL. The Panel subsequently requested details of these organizations and individuals and where
such approaches took place. Mr. Lodge did not provide any further substantial detail as they spoke
Arabic and he didn’t. The Panel has information from a confidential source within the operation that
local armed guards were provided to guard the Opus team. It would be reasonable to presume that
they assisted Mr. Lodge in his communication with the unidentified military personnel.
24. They did not heed my insistence that the helicopters did not and would not have any military
capability to do what they requested. Understanding that this would be illegal and in breach of
international sanctions and not the reason why we were there; I was not prepared to undertake this
work and became concerned as to our security and continued safety in these circumstances. We let
Mr. Christiaan Durrant know this and he agreed with the decision, including the decision to evacuate.
The evacuation plan was set in motion under my direction, and all personnel and no Libyans were
harmed at any stage.
PANEL. This statement is inconsistent with Mr. Lodge’S response above, as it is obvious from this
statement that he could communicate with at least some of the unidentified military personnel. Also,
if as stated Mr. Lodge has not seen any helicopters on arrival, then how would these unidentified
military personnel have connected the Opus team with the helicopters?
25. The RHIBs on which we were evacuated were not engaged for any military purpose but for
emergency support for helicopters.
PANEL. The Panel requested clarification of why a helicopter would require the emergency support
of a RHIB with a maximum speed of less than 25% of that of the helicopters. Mr. Lodge responded
that this required for an emergency response in remote coastal areas, which he stated is a normal
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practice for any aviation task in a coastal area. The Panel has communicated with other aviation
professionals who do not support this statement of Mr. Lodge, stating that it would be much more
effective to respond using another aviation asset. Unless there was an aviation incident directly on
the coastline a RHIB could provide little practical support, even if it could be communicated with
and was in the immediate area of the emergency.
26. Notwithstanding some promotional marketing as to their capabilities, the RHIBs were not
militarised or had any military items in any sense and should be considered as commercial vessels
which were registered in Malta as pleasure craft.
PANEL. The Panel disagrees and has made a finding otherwise. The Panel’s finding of the military
nature of the vessels does not rely solely on Sovereign Charterers description on their website that
the vessels are special forces (…) hardened for maritime security operations. The panel consulted
with the original manufacturer New Madera RIBs B.V regarding this issue. The company’s own
website lists virtually identical vessels under their military section rather than civilian section. The
company also confirmed to the Panel that the company rarely, if ever, sold all black RHIBs with all
black engines, to other than military or security clients. Vessels destined for rescue, passenger or
commercial work were usually coloured. The Panel finds that specifications alone are not necessarily
the definitive criteria as to a vessel’s intended function and use.
27. I was advised that a Maltese lawyer was engaged to assist the evacuees with immigration
matters on their arrival in Malta, as many did not (and had not contemplated the need to) have visas
for arriving in Malta. None of the evacuees used the lawyer as it was not required, and the Maltese
Police were very efficient, polite and sorted out visas for those who did not have. A RHIB was lost
during the evacuation (noting the vessel did not suffer any incident other than it was probably
unsuitable for the voyage being undertaken at short notice).
28. I was not involved in the engagement of or payment for the RHIBs.
PANEL. This is incorrect as demonstrated by the 20 June 2019 BIMCO Time-Charter Contracts,
which had Mr. Lodge’s electronic signature affixed to them.
Specific comments on aircraft
29. For clarity, I have the following comments regarding the aircraft referred to in this statement.
30. I was not authorised to sign for L-6 for IL76 services such as transaction for helicopters to be
transported between Botswana and Jordan; and was not involved in arranging any payment for such
services. I am not aware of where those IL76 aircraft now are.
PANEL. This is incorrect as demonstrated by the 20 June 2019 IWAS IL-76TD charter document for
the flights from Gaborone to Benghazi, which had Mr. Lodge’s electronic signature affixed to it.
31. There seems to be confusion regarding the three Gazelle helicopters and three Super Puma
helicopters. All of these helicopters were registered as civilian aircraft and in particular the Gazelles
were classified as demilitarized or non-military items in South Africa.
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32. I understand that all of the Helicopters were registered with the South African Civil Aviation
Authority ("SACAA") as civilian aircraft. Further, we understand that ARMSCOR (South Africa's
Department of Defence acquisition agency) confirmed to the SACAA as part of those registrations
that the Gazelle helicopters were demilitarized. Regarding the Super Pumas, we understand and have
knowledge that these were registered and operated by their prior owners as civilian aircraft. All
aircraft were painted white as far as I am aware.
33. I am not aware of where the three Gazelle helicopters are, who owns them or what registration
they are on. They had not arrived before I had evacuated Benghazi.
PANEL: This is incorrect as Mr. Lodge’s electronic signature was affixed to the bill of sale with
Fulcrum Holdings UAE on behalf of L-6 FZE. Indeed the owner of Fulcrum is a past private military
associate of Mr. Lodge and a personal friend of his. These particular helicopters had arrived before
he left Benghazi, see paragraph 22 above.
34. I was not involved with the purchase or charter of a PC-6 aircraft. This type of aircraft is a
purely civilian aircraft, best used for surveillance and survey purposes. A PC-6 did arrive shortly
before our departure from Benghazi as a survey aircraft, with one crew member, who evacuated with
the rest of the personnel. It was white in colour.
PANEL. This corroborates the deployment of the PC-6 to Libya in late June/early July 2019. From
his comment that the aircraft was white in colour it can be reasonably concluded that he either saw
the aircraft at Benghazi airport, or had previous knowledge of it and thus its capabilities.
35. I am not aware of the current location of the PC-6 aircraft.

36. I was not and have not been involved with any Antonov AN-32 purchase.
37. I do not know where the Antonov AN-32 aircraft is now.
38. I was not involved with any purchase or contract relating to a T-Bird.
39. I am not aware of the current location of the T-Bird aircraft.
40. There was no UAV capability or components thereof with myself or the logistics personnel.
41. I re-iterate that I had no involvement or knowledge of contracts or payments relating to the
above aircraft.
Specific statements
42. I have had the opportunity to review the queries you have asked in letters to our lawyers,
together with the queries that were put to Ms. Amanda Perry in her interview with you on 20 July
2020. In light of those queries I provide the following statements.
43. I have no business or social connections with Erik Prince. He is not a shareholder, director or
working with me in any context.
PANEL. The Panel was surprised to see a reference to a Mr. Erik Prince in the statement as the Panel
has not mentioned a Mr. Erik Prince in any request for information to Mr. Lodge or his lawyers. Mr.
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Lodge was subsequently asked to clarify why he included a Mr. Erik. Prince in his statement? Mr.
Lodge responded that it was because he had seen Mr. Prince’s name in media reports linked to the
Opus operation. The Panel still considers his reference to Mr. Prince unusual.
44. I am not aware of a proposal made to Confidence Security Consultancy and had not heard of
this name prior to the Panel raising the question.
PANEL. This is contrary to the evidence provided by Mr. Durrant in his interview of 16 September
2020, in which he admitted to knowing the company and was aware of a contract with them. As Mr.
Lodge was clearly involved in the planning of the operation it could be reasonably concluded he was
aware of the company named as the initial client in Cover Story 1.
45. I do not know about a proposal submitted to Bridgeporth Limited. I only became aware of this
name through media reports.
PANEL. This is contrary to the evidence provided by Mr. Durrant in his interview of 16 September
2020, in which he stated that Bridgeporth Limited had provided background information for the
project proposal to Confidence Security Consulting, which was used as a document to support the
movement of helicopters from Gaborone to Benghazi. Lodge having affixed his electronic signature
to the contract for that charter.
46. I know Slade Thomas at Starlite Aviation and was aware that they wanted to sell three civilian
specification Super Pumas.
47. I knew the sellers of the three Gazelle helicopters, which was Fulcrum. These helicopters were
confirmed as demilitarized helicopters on a civilian registration.
PANEL. Lodge fails to mention that he purchased these three Gazelle helicopters representing L-6
FZE on behalf of Opus.
48. I am not aware of the relationship between Opus and L6.

PANEL. The Panel subsequently asked Lodge to clarify the exact company names. He responded L-
6 FZE and Opus Capital Asset FZE, but that the company names were of no consequence to him as
he is unaware of any relationship between them. The Panel again is unconvinced by the veracity of
that response, when compared to Mr. Durrant’s statement that L-6 FZE was an asset holding company
(whom Lodge had represented), Opus Capital Asset Limited FZE was the service delivery company
(whom he was Libya country team leader for, and from whom his salary was most probably paid as
other team members were paid from this account) and Lancaster 6 DMCC was a consulting company
(who he admitted had employed him before (see paragraph 50)).
49. I was never employed as Aviation Manager of L-6 FZE.

50. I was employed by Lancaster6 DMCC from 1 September to 30 November 2018 as Aviation
SME (Subject Matter Expert). I did not hold that position beyond that period. During that period no
proposals or contracts in connection with the events the subject of the Panel's investigation were
executed by me.
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PANEL. Mr. Lodge had signed official documentation during that period stating he was the Aviation
Manager of Lancaster 6, not the Aviation SME.
51. I was never Aviation Manager for Lancaster 6 (registered in Malta as #C76128). I understand
that this company has no connection with the events the subject of the Panel's investigation.
52. I was never Aviation Manager for L6 Group Holdings Limited (registered in the British Virgin
Islands as #1910176). I understand that this company has no connection with the events the subject
of the Panel's investigation.
53. I am not aware of any other companies with a similar sounding name to L-6, L6, Lancaster6 or
Lancaster 6 which have any connection with the events the subject of the Panel's investigation.
54. Regarding Opus Capital Asset Limited FZE, I have not signed any contracts for it in any
capacity.
PANEL. This is incorrect (see paragraph 28 regarding BIMCO contracts).
55. I never acted as a contract representative for L-6 FZE, nor have signed any contracts for it in
any capacity.
PANEL. This is incorrect. See paragraph 30 regarding IL-76TD charter and paragraph 23 for the
Deed of Sale for the three Gazelle helicopters.
56. I was aware that two RHIBS for safety support were contracted as they arrived in our location.
PANEL. Lodge contracted them (see paragraph 28).
57. I am not aware of any previous business relationship between Mr. James Fenech and L-6 FZE,
Lancaster6 DMCC or Opus FZE.
58. I do not know the relationships between Opus, Lancaster6 or L-6.
PANEL. See Panel response to paragraph 48.
59. I do not consider the personnel I worked with in regard to the events being investigated by the
Panel as private military operatives.
PANEL. The Panel has evidence to the contrary in that many of the personnel on this operation were
commonly known to be private military operatives, with some having operational experience of
working with Mr. Lodge before.
60. I do not know about bank accounts or which bank accounts were used to make any payments.
61. I did recommend Mr. Willie van Der Stoep as a reliable person to arrange the movement of
helicopters from South Africa to Jordan but was not involved in the contracting nor payments.
62. I do not know about the preparation or use of customs documentation for the movement of
helicopters from South Africa to Jordan or Libya.
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63. I was not involved in the negotiation, preparation or execution of airway bills for transport
between South Africa/Botswana and Jordan.
64. No helicopters had arrived in Benghazi prior to our group's departure from Benghazi.
PANEL. This is incorrect. See Panel response to paragraphs 25 and 33.
65. One of the RHIBs was mechanically unsound and that is why it was lost.
66. I am not aware of where the second RHIB is now.
67. I was not involved in any lobbying in any country.
68. Umbra Aviation has no connection with the events being investigated by the Panel. That
company has been a dormant corporate entity since approximately July 2018.
PANEL. The dormancy claim is incorrect as the Panel has evidence of a proposal made by Umbra
Aviation to the Government of Mozambique in 2019.
69. No military items were brought into Libya by this team.

70. The only documents that I authorised my signature to be used for on an electronic basis was for
personnel contracts, and I have no issue if that occurred. My signature was not authorised by me to
be used for any other purpose.
PANEL. This is incorrect, as two individuals with knowledge of the contract documentation
confirmed that Mr. Lodge had sent documents with his signature and initials affixed. Mr. Lodge was
in Dubai at the time all the relevant documentation for the purchase of the helicopters, logistic
agreement with IWAS and BIMCo charter documents etc were contractually agreed. The Panel
considers that the balance of evidence supports a finding that Mr. Lodge affixed an electronic copy
of his signature to these documents as individuals/entities have confirmed that he emailed the
documents to them.
Steven Lodge
13 September 2020
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ChVK Wagner in Libya
A. Introduction
1. The Panel has identified the presence of private military operatives from ChVK Wagner being
in Libya since October 2018. ChVK Wagner has been providing technical support for the repair of
military vehicles, participating in combat operations and engaging in influence operations.
2. Background information on ChVK Wagner, which operates using an opaque shell of similarly
named and interlinked shell companies as cover for the organization’s activities to disguise the direct
involvement of Yevegeny Prigozhin, is at appendix A for information.
3. Information obtained by the Panel demonstrates that the working relationships between HAF
and their PMC counterparts were initially strained, and that even after a year of deployment there
were still tensions between the two groups.
B. Contacts between Khalifa Haftar and Yevegeny Prigozhin

4. Khalifa Haftar and senior representatives from his organization have maintained regular
engagement and contact with Russian interlocuters since at least 29 November 2016.264 Such contacts
including a meeting in Moscow on 7 November 2018 with Defence Minister Sergei Shigu and
Yevegeny Prigozhin (see figures 77.1 and 77.2),265 and visits to Benghazi by Prigozhin on 11 and 15
January 2019.266
__________________
264
https://www.theguardian.com/world/2016/nov/29/libyan-general-khalifa-haftar-meets-russian-minister-to-seek-help,
29 November 2016 All footnote URL in this document accessed on 7 March 2020 unless otherwise stated. Flight details
for visits are at appendix B.
265
https://ria.ru/20181110/1532510417.html, 10 November 2018. Russian officials stated that Prigozhin was only
present in his capacity as caterer. The Panel notes it would be highly unusual for a caterer to be sat at the primary table
during an official meeting. Also see https://novayagazeta.ru/articles/2018/11/09/78517-na-etoy-kuhne-chto-to-
gotovitsya, 9 November 2018; and https://jamestown.org/program/moscow-laying-groundwork-for-deeper-military-
involvement-in-libya/, 13 November 2018.
266
https://www.africaintelligence.com/mce/business-circles/2019/01/31/russia-s-wagner-group-offers-to-help-khalifa-
haftar-in-the-fezzan,108342715-eve, 31 January 2019. Supported by flight records of PRIGOZHIN’s private jet aircraft
(also see appendix B).
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Prigozhin and Haftar (7 November 2018) Prigozhin at 7 November 2018 meeting
a
Extracted from video imagery at https://ria.ru/20181110/1532510417.html, 10 November 2018.
5. The Panel has confirmed that during 2019 and early 2020 a senior HAF liaison officer to the
Russian Federation PMC entities present in Libya is Colonel Khalifa abu Sheigar (a.k.a.: 1) Abou
Chaigar; and 2) Abou-Shweier).267 The Panel spoke to Colonel Sheigar by phone on 30 January 2020,
when he confirmed that Russian nationals were present repairing military equipment, but he referred
all other enquiries to HQ HAF.
C. Influence operations
6. The Stanford Internet Observatory268 identified the use of an extensive social media campaign
by a ChVK Wagner linked entity, designed to support Haftar and his ground operations.269 Social
media was used in late 2018 to spread a thematic message suggesting that only Haftar would bring
‘security and peace’ to Libya and that HAF operations were justified. On 30 October 2019, the social
media company Facebook removed content pages of influence networks targeting Libya that
Facebook stated were linked to Yevegeny Prigozhin controlled entities. Facebook removed 468 pages
of content supporting Haftar, which was submitted by Facebook User ID 207521970189143 from
IPv4 IP Address 157.240.22.35.270
__________________
267
Contact details being: 1) +21891411XXXX; 2) +218 914 1XXXX (IMEI 6060101093XXXX); and 3) +218 926
69XXXX. The IMEI number was untraceable on www.imei.info, but the initial digits (616 01) are those used by the Al
Madar Libya mobile network.
268
https://fsi-live.s3.us-west-1.amazonaws.com/s3fs-public/29oct2019_sio_-
_russia_linked_influence_operations_in_africa.final_.pdf, p7, 29 October 2019.
269
A similar complementary social media operation, backed up by opinion surveys and the refurbishment of an old TV
broadcast unit, was used to engender political support for Saif Al-Islam Qadhafi (LYi.017). Although this operation was
in support of a designated individual, the Panel does not consider that political lobbying activities fall under the
auspices of the designation criteria listed at paragraph 11 to resolution 2213 (2015) as they are unrelated to the specific
sanctions measures and provide no direct financial benefits. Facebook removed at least 572 pages of content, which
were submitted by Facebook User ID 100040574768873 from IPv4 IP Address 157.240.22.35. This content covered the
period 25 December 2018 to 9 October 2019. This is the same IP address as used for the influence operations.
270
The content covered the period 27 December 2018 to 14 October 2019. Source: Dr Shelby Grossman, Stanford
Internet Observatory.
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7. The Panel considers this activity falls under the military category of ‘psychological
operations’271 in that they were designed to convey information to selected target audiences with the
aim of influencing their objective reasoning and ultimately their behaviour in regard to HAF. As such,
the deployment of this capability is a non-compliance with paragraph 9 of resolution 1970 (2011) in
that it falls under “technical (…) or other assistance” to wider HAF operations.
D. Path to military engagement

8. The Panel noted open-source information272 relating to alleged ChVK Wagner engagement in
Libya. The information is based on a tranche of internal communications between Prigozhin linked
organizations in Libya and Saint Petersburg.273 The Panel fact-checked a significant percentage of
that information relating to specific events against other independent sources and finds the
information to be credible.274
9. This documentation proves the presence of ChVK Wagner in Libya and that they were reporting
on wide military issues to their Headquarters in Saint Petersburg. The information of relevance to the
Panel’s mandate is summarised in table 77.1, with extracts from the original communications and
official UN translations at appendix C.
Table 77.1
Summary of information relevant to ChVK Wagner involvement and sanctions measures
Date Author Summary of content Remarks

20 Mar 2019 Bychkov a Confirms military technical support for vehicle ▪ See paragraph 11.
repair and refurbishment.
Reports that Khalifa Haftar will not allow
Russian specialists to work, provides an
example on 18 January 2019 of a travel ban.
Reports that Khalifa Haftar has imposed
restrictions on information sharing with
Russians, and that Russian experts have been
deliberately misinformed on occasions.
28 Mar 2019 Bychkov A graphic in Appendix 1 to a ChVK Wagner ▪ See figure 77.3 for
Libya Situation Report of that day reflects the graphic.
presence of 6 x Military Experts and 23 Repair ▪ See paragraph 11.
Unit Specialists. Also contains identical data on
military vehicles inspected and repaired.
__________________
271
Psychological operations are one core component of ‘Information Operations’, which includes complementary core
components of: 1) electronic warfare; 2) computer network operations; 3) military deception; and 4) operational
security. Derived from the Journal of Information warfare. https://www.jinfowar.com.
272
1) http://www.interpretermag.com/on-the-situation-in-libya/. 12 September 2019; 2)
https://www.thedailybeast.com/russias-WAGNER-mercenaries-have-moved-into-libya-good-luck-with-that, 12 September
2018 (updated 29 September 2018); and 3) https://www.proekt.media/investigation/prigozhin-libya/, 12 September 2018.
273
https://dossier.center/, accessed 10 December 2019.
274
The Panel compared statements in the reports against reported or subsequent events using a range of sources,
including UNSMIL reports, open source media and confidential sources.
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Date Author Summary of content Remarks

6 Apr 2019 SITREP b Reported an appeal to Kholzakovc from HAF ▪ This was in response to
for access to Russian unmanned aerial vehicles the use of 155mm Laser
(UAV) for intelligence, surveillance and Homing Projectiles (LHP)
reconnaissance (ISR) tasks which was denied.d by HAF.e
10 Apr 2019 Bychkov Confirms refusal by the Russian Ministry of ▪ False plates removed by
Defence on 2 April 2019 to provide Khalifa ChVK Wagner staff in
Haftar with official Russian military support. Libya.
Khalifa Haftar spread false information on 3
April 2019 about presence of 300 ChVK
Wagner operatives.
Placed false Russian “112” number plates on
Kamaz trucks.
22 Apr 2019 “Ivan” Mentions an “enormous consumption of ▪ Not clear if Russian
ammunition” by HAF requiring three IL-76 supplied weapons or
resupply sorties of Russian weapons from the weapons procured from
UAE via Jordan. Russia by UAE and then
Covers a request by HAF for the Russian HQ supplied to HAF.
to relocate to Jufra or Gharyan and provide air
defence capability by MANPADS.
14 May 2019 “Ivan” Reported that a C-17 cargo aircraft delivers ▪ Links to 22 April 2019
ammunition from Egypt daily. “Ivan” report above.
States that indiscriminate ammunition
consumption requires resupply by 2 x IL-76
aircraft from Egypt but does not specify
delivery airfield.
a
Pyotr Bychkov, an employee of the Prigozhin-linked Fund for the Defense of National Values.
b
WAGNER organization initiated Situation Report. The Panel has seen SITREPS covering the period from 16 March to 22 April
2019.
c
Reported to be Lieutenant General Andrei Vladimirovich Kholzakov. Formerly a Deputy Commander of Russian Airborne
Assault Forces (VDV275).276
d
In S/2019/914 , para.122 and annex 51 the Panel reported on the unexplained presence of a Russian Federation manufactured
Orlan-10 ISR UAV, which was downed on 29 April 2019.
e
In S/2019/914 , para.95 and annex39 the Panel reported on the presence of 155mm high-explosive laser-homing projectile GP6
round in the possession of HAF.
__________________
275
Vozdushno-Desantnye Royska Rossii.
276
https://www.rand.org/content/dam/rand/pubs/research_reports/RR3000/RR3099/RAND_RR3099z1.app
endixes.pdf, p153.
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Figure 77.3
Appendix 1 to ChVK Wagner Situation Report of 28 March 2019
Source. Dossier Centre (https://dossier.center), received 11 December 2019.
E. Military logistic support to HAF

10. Although ChVK Wagner is well funded by companies and organizations under the control of
Yevgeny Prigozhin, it does not have indigenous logistic resources to allow the organization to operate
independently on major deployments. It requires external hybrid commercial and military logistic
support, in particular aviation and maritime assets, to deploy and sustain its operations.
F. Land service equipment repair and maintenance

11. A 23-person repair team277 from ChVK Wagner was deployed to Libya from 17 October 2018
and 12 March 2019 to inspect, make damage assessments of, and overhaul of reportedly over 500
armoured vehicles and field artillery of HAF.278
12. This military technical support activity was confirmed in a statement by the HAF spokesperson
Major General Ahmed al-Mesmari on 23 November 2019, in which he said: “if there are Russians, I
will tell you for the first time, in your channel, I’ll tell you frankly, there might be one or two technical
teams on tanks and artillery, to repair and re-engage some parts in the combat, especially because
__________________
277
Some individuals identified in a list of Wagner personnel obtained by the Panel..
278
Source: Dossier Centre (https://dossier.center). See figure 3 at paragraph 9.
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all those weapons are Russian (…)”.279 The reported full list of equipment280 and details of nine of
the technical specialists known to have deployed to Libya are at appendix D.281
G. Air Line of Communication

13. An Air Line of Communication (ALoC)282 was put in place between the Russian Federation
and Eastern Libya, with the majority of cargo flights routing through the Russian military airbase
(Hmeymim)283 co-located with Latakia (Bassel al-Assad) international airport (OSLK) in Syria.
14. The Panel identified that Tupolev TU-154M aircraft of the Russian Federation Ministry of
Defence 223rd Flight Detachment (registration numbers RA-85041 and RA-85155) have been
previously used for air transport by ChVK Wagner and its affiliates on other operations.284 The Panel
notes that two flights made by the TU-154M RA-85155 into Libya were made in the same time period
as the deployment of the technical specialists (October 2018) (see paragraph 11). Flights of TU-154M
aircraft, including RA-85155, from the 223rd Flight Detachment to Benghazi then recommenced in
January 2020 (see table 77.2).
Table 77.2
TU-154M flights (Libya)
Date From To Aircraft # Flight # Remarks

17 Oct 2018 Khartoum Benghazi RA-85155
(HSSS) (HLLB)
17 Oct 2018 Benghazi (HLLB) Latakia (OSLK) RA-85155 En route to Moscow
(UUMS).
22 Oct 2018 Khartoum (HSSS) Benghazi RA-85155
(HLLB)
22 Oct 2018 Benghazi (HLLB) Moscow RA-85155
(UMUU)
4 Jan 2020 Latakia (OSLK) Benghazi RA-85042 RFF77a
(HLLB)
4 Jan 2020 Benghazi (HLLB) Latakia (OSLK) RA-85042 RFF78
6 Jan 2020 Latakia (OSLK) Benghazi RA-85042 RFF77b
(HLLB)
__________________
279
https://www.youtube.com/watch?v=jYaNjlHVybA&feature=youtu.be, 23 November 2019.
280
1) https://www.proekt.media/investigation/prigozhin-libya/1, 12 September 2019; and 2) Binnie J.A. Leaked
document says Russians are repairing LNA heavy equipment. Janes Defence Weekly. 13 September 2019.
281
282
A Line of Communication (LoC) is the route that connects an operating military unit with its supply base.
283
https://tass.com/defense/926348, 20 January 2017. Centred on 35°24'27.07"N, 35°57'8.00"E.
284
For example Agreement # B218/04/119 dated 30 July 2018 between M-INVEST L.L.C. and the 223rd Flight
Detachment was for eight flights at a budgetary cost of RUB 56 million (approx. US$900,238 from www.xe.com
database). M-INVEST L.L.C. is a company engaged in exploitation of mineral resources owned by Yevegeny
Prizoghin, and is used as cover structure for ChVK Wagner operations in Sudan.
(https://www.fpri.org/article/2019/10/diplomacy-and-dividends-who-really-controls-the-wagner-group/, 4 October
2019). An M-INVEST L.L.C. subsidiary, M-LOBAYE, is used for ChVK Wagner operations in the Central African
Republic. Confidential source.
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Date From To Aircraft # Flight # Remarks

6 Jan 2020 Benghazi (HLLB) Latakia (OSLK) RA-85042 RFF78
12 Jan 2020 Benghazi (HLLB) Latakia (OSLK) RA-85155 via Cairoc
14 Jan 2020 Benghazi (HLLB) Latakia (OSLK) RA-85155
24 Feb 2020 Benghazi (HLLB) Latakia (OSLK) RA-85155 RFF8062d
Source: Confidential source

a
https://www.itamilradar.com/2020/01/04/russian-af-tu-154-landed-in-benghazi/, 4 January 2020.
b
https://www.itamilradar.com/2020/01/06/russian-af-tupolev-again-in-benghazi/, 6 January 2020.
c
https://twitter.com/YorukIsik/status/1215987251466903553, 12 January 2020.
d
https://twitter.com/Gerjon_/status/1232017012110626818, 24 February 2020.
15. Since Khalifa Haftars’s meeting in Moscow on 7 November 2018, Russian Federation military
cargo aircraft flights into Libya have become routine (see appendix A to Annex 55). The Panel has
requested information285 from the Member State concerning the flight manifests and air waybills for
the flights and is awaiting a response.
16. Analysis of the cargo capacity for the initial Russian Federation military cargo flights shows
three peak delivery periods in 2018 and 2019. The first period being during November and December
2018, immediately after the deployment of the ChVK Wagner technical support team. The second
period being September 2019, covering the period of open-source information concerning ChVK
Wagner training and combat operations (see paragraphs I to 26). The rationale for the third peak
period of December to January 2020 has yet to be fully identified by the Panel but is possibly to
provide support for the increased private military operatives deployed.
H. Post-deployment training
17. The Panel received copies of maps used by ChVK Wagner. These regarded the location of a
temporary training camp that was established in the Jabal al Nuqqay area286 of south-east Libya from
approximately 1 October to 20 November 2019 (see figures 77.4 and 77.5).

Marked PMC map in Russian language Marked location on PMC map
Source: Dossier Centre (https://dossier.center/). Note names are in cyrillic text.

__________________
285
Panel letter of 6 April 2020.
286
Centred around 22°27'44.14"N, 19°32'56.83"E.
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18. The Panel obtained commercial satellite imagery of this location dated 3 November 2019 and
8 January 2020 that clearly shows a new low structure of approximately 4m x 5m, and at least nine
vehicles. The number of vehicles on the satellite imagery (nine) correlates with the nine vehicles
mentioned by the source(s).287 See figure 77.6. Satellite imagery of the same area taken on 2 October
2019 showed no objects of interest at all.
Figure 77.6
Satellite analysis
Source: Confidential source and Panel analysis.
19. The training team were deployed and recovered using an Antonov AN-26 (registration reported
as #25 SAI LY).288 This registration number is not in the format used by any Member States’ civil
aircraft register. The Panel searched the details for all 851 AN-26 recorded as still being operational
and could not find any immediate matches.289 The Panel noted that the prefix 25 format was used by
the then Soviet Air Force for aircraft placed in long term storage and there are three AN-26 with this
__________________
287
1) Two armed vehicles; 2) One armoured ‘Technical’ 4x4: and 3) Four utility 4x4 vehicle
288
The Panel requested clarification from the confidential source twice as to this number, which was confirmed.
289
https://rzjets.net/aircraft/?reg=330385, accessed 4 February 2020.
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prefix recorded as now being back in operational use. It is also possible that a fake registration number
was painted on the aircraft for this operation.290
20. Communications were via a satellite Broadband Global Area Network (BGAN) terminal (IMEI:
35844405004270)291 (Inmarsat Sat# 901112112615812). The manufacturer sold the device to
Morsviazsputnik292 of the Russian Federation on 5 December 2014; the same company also being
the communication provider. The Panel has confirmed293 that this system was operational within
Libya between 1 April and 31 December 2019, and more specifically was operational in the area of
the field training camp between 1 October to 18 November 2019. As it is a BGAN terminal it has not
yet been possible to identify the contact details of individuals or entities that the BGAN terminal
connected with.
I. Combat operations (Land)

21. On 12 September 2019, a media source released documentation stating that approximately 300
ChVK Wagner operatives had been deployed to Libya in support of HAF.294 On 25 September 2019,
the media then reported that more than 100 ChVK Wagner operatives were deployed to Libya as
reinforcements to the ongoing operation.296
22. The Panel was provided details of 122 ChVK Wagner operatives of whom many are highly
probably operational, or have been operational, within Libya.297 Of these, 39 are from the ChVK
Wagner specialist sniper group and open sources have reported on the tactical impact of the recent
presence of skilled Russian snipers on the frontlines.298 The remaining 83 operatives are from the
ChVK Wagner 1st Attack and Reconnaissance Company or other combat units.
23. There were increasing social media and open-source reporting of the engagement of Russian
based private military operatives in combat operations during 2019, but details were not always
verifiable at that time. Although there have been efforts to spread false information on this issue, the
__________________
290
An AN-26 aircraft operating in support of HAF was destroyed on the runway at Tarhuna air strip (32°20'01.5"N,
13°34'49.7"E) on 5 April 2020. There is no evidence yet this is the same aircraft, and this is reported for information
purposes only at this stage.
291
From www.imei.info this traces as an EXPLORER710 Thrane and Thrane BGAN Terminal. TAC: 358444 FAC: 05
Serial #: 004270 CD 2.
292
https://www.marsat.ru/en/enterprise, accessed 8 January 2020. Morsviazsputnik is administered by the Russian
Federal Agency of Maritime and River Transport (http://www.morflot.ru/).
293
294
https://www.thedailybeast.com/russias-wagner-mercenaries-have-moved-into-libya-good-luck-with-that?ref=home.
12 September 2019.
296
https://www.bloomberg.com/news/articles/2019-09-25/-putin-s-chef-deploys-mercenaries-to-libya-in-latest-
adventure. 25 September 2019. In the article HAF denied the deployment of any Russian personnel, which is contrary
to their later statement (see paragraph 11).
297
According to confidential source. The commander of these individuals, who appears on the list, has subsequently
been confirmed as injured in Libya (see paragraph 38). The Panel is in possession of the list.
298
Including, for example, https://www.nytimes.com/2019/11/05/world/middleeast/russia-libya-mercenaries.html, 5
November 2019.
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Panel finds some of this reporting credible and convincing. This is summarized at table 77.3 and
illustrated at figures 77.6 to 77.8:
Table 77.3
Open source and social media reporting of Russian based private military operatives on combat operations299
Date Location Event Remarks
9 Sep 2019 Souk al-Sabat a Reports of seven Russian based private military ▪
operative casualties due to GNA strike. b
19 Sep 2019 Espiaa c Russian private military operatives seen with LNA ▪
forces. d
19 Sep 2019 Tarhuna Bodies of 15 Russian based private military ▪ Initially thought to
operatives killed in air strike between Tarhuna and be Libyan
Bani Walid received at Benina (Benghazi).e casualties.
22 Sep 2019 Imagery of alleged ChVK Wagner operatives appear ▪

on social media.f
23 Sep 2019 Espiaa Reports of three Russian “mercenaries” killed by ▪ Sebha front line
GNA air strikes on HAF operations room. g
25 Sep 2019 Qasr bin Deployed with HAF 106 battalion. j ▪ Supporting imagery
Ghashir h is at figure 77.7.
13 Oct 2019 Espiaa Russian military operative’s equipment captured by ▪

GNA-AF.
17 Oct 2019 Nesma Reports of Russian military operatives transiting ▪

through the area on return from the Tripoli Area of
Operations (AO). k
30 Nov 2019 Qasr bin GNA statement on 2 December 2019 referring to ▪

Ghashir destruction of a “mercenaries” operations room. l
11 Jan 2020 Tripoli GNA Commander, Nasir Ammar, stated that Wagner ▪
Group fighters had begun to withdraw from the front
lines, and were being flown to Jufra air base by
helicopter.m He further stated that there were then
over 500 Russian mercenaries on Salah Al-Deen,
Yarmouk, Khallatat, and Abu Salim frontlines.n
25 Feb 2020 Tripoli o Imagery published of Russian private military ▪ Supporting imagery
operatives using a mini UAV. at figure 77.8.
a Centred on 32°28'39.00"N, 11°53'30.80"E.

b 1) https://twitter.com/TvFebruary/status/1171098768734916609, 9 September 2019; 2)
https://www.libyaobserver.ly/news/foreign-mercenaries-fighting-alongside-haftars-forces-killed-airstrikes-southern-tripoli,
9 September 2019.
c Centred on 32°33'2.71"N, 13°10'37.02"E.
__________________
299
Many of these are reported as “Russian” private military operatives. The Panel can only confirm those from ChVK
Wagner where specifically stated in the table. As other Russian based PMC are now known to be present, it is possible
that individuals belong to those organizations.
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d https://twitter.com/sky_wael/status/1174718985482440705, 19 September 2019.

e Confidential source (CS3).
f https://www.libyaobserver.ly/news/libyas-army-advances-strategic-frontlines-southern-tripoli-pushing-away-haftars-
forces, 22 September 2019.

g
1) https://www.libyaobserver.ly/news/libya-airstrikes-libyan-army-kill-senior-leaders-haftars-forces-russian-mercenaries, 23
September 2019; and 2) https://www.iol.co.za/news/africa/russian-mercenaries-senior-rebel-leaders-killed-in-libya-air-strikes-
33502754, 24 September 2019.
h Near 32°41'13.79"N, 13°11'1.39"E.
j https://twitter.com/emad_badi/status/1176976694323949568. 25 September 2019. See figure 6 for the “more evidence”
referred to.
k Confidential source .
l https://www.marsad.ly/en/2019/12/02/libyan-army-destroys-mercenaries-run-operation-room-for-haftar/, accessed 4
December 2019.
m https://www.dailysabah.com/africa/2020/01/11/number-of-russian-mercenaries-withdraw-following-call-for-libya-cease-fire-
gna-commander-says, 11 January 2020.

n https://www.libyaobserver.ly/news/army-official-russian-wagner-group-mercenaries-have-started-pulling-out-tripoli-
frontlines, 12 January 2020.

o Geo-located to 32°47'27.73"N, 13°13'5.04"E. https://twitter.com/il_kanguru/status/1232382687526244354, 25 February
2020.
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Figure 77.6
Reported sightings of Russian PMC operatives in Libya (September 2019 to December 2020)300
__________________
300
Table 3 refers.
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Figure 77.7
a, b, c
Imagery of alleged ChVK Wagner PMC operatives in Qasr bin Gashir (25 September 2019)
a Extracted from https://twitter.com/Apgybape11/status/1176980085318070278, 25 September 2019. On other imagery
from that source the insignia of the HAF 106 battalion can clearly be identified on the bonnet of the 4x4 vehicle. A video
subsequently released on social media includes the individuals shown in this imagery:
https://m.facebook.com/126130904224556/videos/570051700235111/?refsrc=https%3A%2F%2Fm.facebook.com%2Fstor
y.php&_rdr, 27 December 2019.
b Russian voices can be clearly heard on further video imagery released on social media of the same event: 1)
https://twitter.com/LostWeapons/status/1211218269417246721, 29 December 2019; 2)

https://twitter.com/LostWeapons/status/1211219397274042374, 29 December 2019; and 3 December 2019)
https://twitter.com/LostWeapons/status/1211219797519687682, 29 December 2019.
c Geo-located at 32°36'56.40"N, 13° 8'11.69"E by https://twitter.com/il_kanguru/status/1210709236096946182, 27
December 2019.
Figure 77.8
Imagery of alleged Russian PMC operatives in South Tripoli (25 February 2020) a, b, c
a https://twitter.com/Libyancitizen6/status/1232288849256120320/photo/1,25 February 2020.

b https://twitter.com/Oded121351/status/1232608402364411905, 26 February 2020.
c Geo-located to 32°47'27.73"N, 13°13'5.04"E, near Emad al-Elm school.
https://twitter.com/il_kanguru/status/1232382687526244354, 25 February 2020.
24. On 29 September 2019, a GNA-AF source stated to Libya Al-Ahrar TV that Al-Wattiya
airbase301 was then under the control of “Russian Forces”, and that a Sukhoi Su-22 fighter ground
attack (FGA) aircraft had been based there.302 The Panel notes though that the HAF air operations
already had access to an Su-22 FGA, which had recently been used to deliver explosive ordnance
against Zuwarah airport on 15 and 16 August 2019. The Panel finds it highly probable that a HAF
__________________
301
Centred on 32°28'39.00"N, 11°53'30.80"E.
302
https://www.libyaobserver.ly/inbrief/government-source-russian-military-forces-take-control-al-wattiyah-airbase.
29 September 2019.
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Su-22 FGA had been made airworthy again, with foreign technical support (see paragraph 12),303
rather than a Russian Air Force Su-22 being deployed there. The airbase was captured by GNA-AF
in May 2020 and no longer available for HAF use.
25. In a GNA report dated November 2019,304 the GNA Ministry of Interior stated that in
September 2019 Russian mercenaries entered the Tripoli military operations area, particularly in the
areas of Airport Road, Wadi al-Rabia and Sabea (extract from full report at annex 8). This correlates
to the locations in table 77.3.
26. On 3 December 2019, an interview appeared on the Al Aan social media channel of an
individual from ChVK Wagner.305 The Panel has consulted with confidential sources who consider
the interview as credible. A Panel summary of the interview content is appendix 6.306
27. On 11 January 2020, it was reported that ChVK Wagner operatives had been withdrawn from
the frontlines, and that this was linked to a meeting in Istanbul on 8 January 2020 between Presidents
Erdogan and Putin that discussed a ceasefire.307 A confidential source reports that 400 ChVK Wagner
operatives and 200 RSB operatives308 withdrew from the front lines to Al Jufra.
J. Land (Syrian foreign fighters)

28. On 7 January 2020, the first reports emerged of Syrian foreign fighters being recruited by a
Russian PMC to fight in Libya in support of HAF.1309 More detail was provided by 14 February 2020
with reports that the fighters were being recruited from Douma in eastern Ghouta, Syria on a salary
of US$ 800 per month for a three-month contract.310 This report also stated that transfer to Libya was
by Cham Wings Airlines from Damascus. On 19 February 2020, an open source reported that Syrian
fighters were being recruited by ChVK Wagner through the auspices of the Syrian National Youth
__________________
303
https://twitter.com/hunter224466/status/1183956547124236289, 14 October 2019. This alleges that a Sukhoi SU-22
FGS was repaired at Jabal Abdul Nasser air base in Tobruk, before being deployed to Al-Wattiya air base for operations.
304
Titled, “The full report on the violations perpetrated by the forces of the war criminal Haftar - November 2019”. The
full 170 page report was prepared by the team of the counsellors of the Media Bureau of the Minister of Interior.
305
https://www.youtube.com/watch?time_continue=7&v=i5Qb5hjfUJk&feature=emb_logo, 3 December 2019.
306
On 27 December 2019, the Panel received a video containing testimony from a junior LNA fighter, Meftah Massib
Idriss Ehmeida, in which he refers to the use of Russians with laser guidance equipment being used to “clear paths” for
the LNA. The testimony lacked detail so it is not relied on by the Panel as a primary source of information. Consulted
CS4.
307
https://lenta.ru/news/2020/01/11/gone/, 11 January 2020.
308
This is the first report seen by the Panel that RSB operatives had deployed in a combat capability rather than the
technical support capability reported at paragraph 15.
309
https://www.aa.com.tr/en/africa/russia-sends-fighters-to-up-haftars-forces-in-libya/1694935, 7 January 2020.
310
1) https://aawsat.com/english/home/article/2130986/russia-sends-syrians-fight-libya-clashes-reach-misrata, 14 February
2020; and 2) https://t.me/new_militarycolumnist/28316, 14 February 2020. Also stated in
https://aawsat.com/english/home/article/2172357/exclusive-erdogan-‘infiltrates’-idlib-haftar-‘strolls’-damascus, 10 March
2020.
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Party in Suweida. Further open-source information on 5 March 2020 supported this statement, also
claiming that salaries of between US$1,000 to US$1,500 per month were available.311
29. In a statement on 20 March 2020, the GNA stated that it had evidence that Cham Wings Airlines
were transferring Syrian foreign fighters specifically with links to ChVK Wagner. The Panel has
requested more detail from the Libyan authorities and awaits a response. The Panel has identified
regular flights from Damascus to Benghazi by aircraft operated by the Syrian company Cham Wings
Airlines since the start of the current conflict in Libya on 4 April 2019 (see Annex 55). On 17 July 2019
the Panel requested information from the Syrian Arab Republic regarding the initial flights,312 and was
informed by the Member State313 that the flights were to provide transportation for civilian passengers,
particularly those Syrians living in Libya. The Panel is unconvinced of the veracity of that response, as:
1) it was not possible to book a flight on that route on the airline’s web portal;2314 and 2) Benghazi does
not appear as a scheduled destination on Cham Wings Airlines web portal, even after an announcement
that scheduled flights would begin on 11 October 2019.315 There is also a body of evidence of Cham
Wings Airlines acting in support of ChVK Wagner operations in Syria,316 and there have been multiple
and credible open source reports alleging that Russian private military operatives and fighters recruited
in the Syrian Arab Republic317 have arrived in Benghazi and Misrata from the Syrian Arab Republic.
30. The Panel has subsequently identified 33 flights by Cham Wings Airlines since 1 January 2020
(see Annex 55), which would allow for the potential transfer of approximately 4,950 passengers. It is
estimated from ground sources that the number of Syrian foreign fighters supporting HAF operations
is less than 2,000. Subsequent open-source reporting places the number of Syrian fighters present in
Libya to be nearer 5,000,318 but this almost certainly includes those fighters recruited by Turkey in
support of the GNA.319
31. The Cham Wings flights reportedly left from the military terminal at Damascus and not the
civilian airport, and many of the passengers are dressed in military attire.320 The Panel has analysed the
__________________
311
1) https://syrianobserver.com/EN/news/56150/wagner-mercenary-group-recruits-syrians-to-fight-in-libya-
report.html, 19 February 2020: updated by 2) https://www.libyaobserver.ly/news/le-monde-syrians-mostly-druze-are-
fighting-haftar-libya, 5 March 2020.
312
17 July 2019.
313
21 October 2019.
314
http://www.chamwings.com/. Attempts to book flights show “no flights available” for a random range of booking
dates. Attempts made between 15 November to 31 December 2019. Also see
https://twitter.com/Balzawawi_ly/status/1212038209426866179, 31 December 2019.
315
https://www.eanlibya.com/‫في‬-‫مستمرة‬-‫الشام‬-‫أجنحة‬-‫عثمان‬-‫بن‬-‫نعمان‬/, accessed on 12 December 2019.
316
https://www.reuters.com/investigates/special-report/russia-flights/, 6 April 2018.
317
1) https://twitter.com/BurkanLy/status/1176594585361027073, 29 September 2019; 2)
https://aawsat.com/english/home/article/2130986/russia-sends-syrians-fight-libya-clashes-reach-misrata, 14 February
2020; and 3) https://www.libyaobserver.ly/news/le-monde-syrians-mostly-druze-are-fighting-haftar-libya, 5 March
2020.
318
https://aawsat.com/english/home/article/2172357/exclusive-erdogan-‘infiltrates’-idlib-haftar-‘strolls’-damascus,
10 March 2020.
319
More details in Panel update to the Committee of 26 January 2020 (S/AC.52/2020/PE/OC.36).
320
https://arabicpost.net/30 ,/‫عادات‬-‫ستتغير‬-‫كيف‬-‫الكورونا‬-‫زمن‬-‫في‬-‫رمضان‬/2020/04/08/‫شارحة‬-‫ تحليالت‬March 2020.
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ADS-B data321 for flights made by Cham Wings aircraft since 12 April 2019. Common features which
indicate covert activity include: 1) flights are timed to primarily land at Benghazi at night (there is no
common schedule); 2) ADS-B data disappears at a consistent point before the aircraft change track by
900 South to Benghazi (note for flight at figure 77.8 that the pilot was late in stopping ADS-B
broadcasts, and on figure 77.9 an inadvertent single transmission was made); 3) the aircraft tracks out
of Damascus closely follow the Flight Information region (FIR) boundaries in order to try and avoid
reporting to either FIR; and 4) the flights are recorded as non-scheduled or special flights with air traffic
management systems. Examples of data analysis for three flights are at figures 77.8 to 77.10, on which
the yellow dots represented an ADS-B reporting point.322
Figure 77.8
Cham Wings YK-BAB flight of 6 September 2019
Figure 77.9
Cham Wings YK-BAB flight of 24 September 2019
__________________
321
With data analysis technical support from C4ADS (www.c4ads.org). Report LY20200109.
322
The Panel has a single source reporting that ChVK Wagner private military operatives are also transferred on tourist
charter flights on Nordwin Airlines (www.nordwin.ru/en) from Rostov-on-Don (URRP) via Monastir (DTMB) Tunisia.
This route is still under investigation.
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Figure 77.10
Cham Wings YK-BAB flight of 8 November 2019
Sources for figures 13 to 15: 1) www.flightradar24.org: 2) http://www.c4ads.org/; and 3) Panel.
K. Weapons
32. The GNA-AF captured 30mm VOG-17M grenades designed for use with the AGS-17 and AGS
30, 30mm automatic grenade launchers (see figures 77.11 and 77.12), and a VOG-25 40mm grenade
(figure 77.13) designed for use with the 6T17 GP-25 ‘Bonfire’ under-barrel grenade launcher. These
systems have not been identified as being used by either GNA-AF or HAF in Libya to date and are
typical of the weaponry observed being used by ChVK Wagner operatives elsewhere in eastern
Ukraine and the Syrian Arab Republic.323
Figure 77.11 Figure 77.12 Figure 77.13
VOG-17M 30mm grenades a VOG-17M 30mm grenades b VOG-25 40mm grenade c
a
Extracted from https://twitter.com/februarychannel/status/1182713833678409729?s=12, 11 October 2019.
b
https://twitter.com/Oded121351/status/1183349955983020033/photo/3, 13 October 2019.
c
Extracted from https://twitter.com/Oded121351/status/1183349955983020033/photo/4, 13 October 2019.
__________________
323
For example, 6T 17 GP25 ‘Bonfire” clearly identified in group images of Wagner operatives in: 1) Ukraine,
https://112.international/conflict-in-eastern-ukraine/militants-of-wagner-group-may-arrive-in-donbas-over-next-few-
days-sbu-28526.html, 15 May 2018; and 2) Syria
(https://diyaruna.com/en_GB/articles/cnmi_di/features/2019/02/21/feature-01, 21 February 2019.
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33. The Panel received imagery from a confidential source of Range Cards recovered from
defensive positions south of Tripoli. The range cards were in Russian, thus confirming the
deployment of Russian Federation private military operatives to these locations
Figure 77.14
Range Card
Contractual issues
34. On 17 October 2019, a single pro-GNA open source324 published a report that a ChVK Wagner
component325 had temporarily withdrawn from the Tripoli frontlines. This component explained their
rationale326 for withdrawal to the HAF General Command as being due to:
(a) Failure to receive instructions from HAF or support forces;
(b) Lack of HAF experience and discipline on the battlefield;
__________________
324
https://www.facebook.com/2Libya17/posts/482402469043233, 17 October 2019. Similar information was conveyed
by a confidential source to the Panel.
325
The component allegedly consisted of: 1) 12 x consultants; 2) 22 x technicians; 3) 19 field commanders; 4) 26
snipers; and 5) 11 x signallers.
326
The reasons listed were also corroborated by other confidential sources,
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(c) Lack of effective coordination with HAF forces, leading to intermittent “friendly fire”
incidents;
(d) Air strike targeting errors, and failure to pre-warn of strikes;
(e) Alcohol use in HAF units;
(f) Area of Responsibility (TAOR)327 allocated being too large for available ChVK Wagner
forces;
(g) Enemy intelligence techniques are facilitating the targeting of ChVK Wagner positions;
and
(h) Enemy reinforcements after ChVK Wagner progress are made in any sector.
35. On 17 October 2019, the above source information was supported by a social media report328
that eight High Mobility Vehicles (HMV) and two armoured vehicles carrying Russian private
military operatives had been observed withdrawing from the Tripoli area of operations moving east
towards Benghazi.
36. On 17 October 2019, social media reports329 also emerged that the six-month contract between
HAF and ChVK Wagner had expired on 15 October 2019. By this time HAF had allegedly only paid
53.2% (US$ 92.5 million) of the contracted US$ 173.9 million. The Panel continues to investigate
this issue.
L. Casualties
37. Table 77.4 summarizes the reported “Russian” private military operative casualties reported to
date in open-source media.
Table 77.4
Russian private military operative casualties
Date Location Event # Fatalities # Wounded

a
9 Sep 2019 Souk al-Sabat GNA airstrike. 7b
23 Sep 2019 Sabea front line GNA airstrike.c 15+
30 Nov Qasr bin Destruction of a “mercenaries” operations 9
2019 Ghashir room.c
a 1) https://twitter.com/TvFebruary/status/1171098768734916609, 9 September 2019; 2) https://www.libyaobserver.ly/news/foreign-

mercenaries-fighting-alongside-haftars-forces-killed-airstrikes-southern-tripoli, 9 September 2019.
b Total fatalities and wounded combined.
c 1) https://www.libyaobserver.ly/news/libya-airstrikes-libyan-army-kill-senior-leaders-haftars-forces-russian-mercenaries, 23
September 2019; and 2) https://www.iol.co.za/news/africa/russian-mercenaries-senior-rebel-leaders-killed-in-libya-air-strikes-

__________________
327
A TAORhttps://en.wikipedia.org/wiki/Tactical_area_of_responsibility - cite_note-1 is a prescribed area in a
theatre of combat which has been assigned to a unit commander who is responsible for, and has the authority to act on,
the development and maintenance of installations and the conduct of tactical operations, area defence, coordination of
support, and for conducting patrols.
328
https://twitter.com/madaNea14/status/1184792229442981888, 17 October 2019.
329
https://www.facebook.com/2Libya17/posts/482402469043233, 17 October 2019.
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33502754, 24 September 2019.

d https://www.marsad.ly/en/2019/12/02/libyan-army-destroys-mercenaries-run-operation-room-for-haftar/, accessed 4 December
2019.
38. The casualties from the 23 September 2019 air strike included the Commander of ChVK
Wagner 1st Attack and Reconnaissance Company, Aleksandr Sergevich Kuznetsov (“Ratibor”).330
He was evacuated to a Saint Petersburg military hospital due to the seriousness of his injuries. On 8
January 2020, open-source media reported331 on the admission of injured ChVK Wagner private
military operatives, including Kuznetsov, to the Sogaz International Medical Centre, Saint
Petersburg.332
39. A list of confirmed ChVK Wagner operative fatalities to date and the supporting evidence was
published on the Meduza investigative journalism website on 2 October 2019333 (see summary at
appendix G). The Panel finds this evidence credible. To date, and unlike previous conflicts, the death
certificates and military decorations have not been forwarded to the families.
__________________
330
https://www.lepoint.fr/monde/ces-miliciens-russes-morts-en-libye-qui-embarrassent-moscou-08-10-2019-
2340022_24.php, 8 October 2019.
331
https://www.reuters.com/article/us-russia-putin-mercenaries-exclusive/exclusive-russian-clinic-treated-
mercenaries-injured-in-secret-wars-idUSKBN1Z61A7, 7 January 2020.
332
https://www.sogaz-clinic.ru. Accessed 8 January 2020.
333
https://meduza.io/en/feature/2019/10/02/a-small-price-to-pay-for-tripoli. Accessed 3 October 2019.
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Appendix A to Annex 77: Background on the ChVK Wagner organization
1. Initially ChVK Wagner did not officially exist and was a shadow organization named after the
callsign for Dimitry Valeriiovych Utkin who now leads the organization and plans the operations.334
On 9 December 2016, Utkin was presented with an award, together with Alexandr Kuznetsov (M-
0271) who was subsequently injured fighting in Libya, in Saint Georges Hall, Kremlin.335 On 14
November 2017 Utkin took over as Chief Executive Officer (CEO) of the Yevegeny Prigozhin owned
Concord Management and Consulting company.
2. ChVK Wagner is now assessed as being over 5,000 individuals strong, with expertise available
within it across the full spectrum of military specialities.336 Membership also includes citizens of
Belarus, Moldova, Serbia and Ukraine, although it is predominantly still staffed by Russians. The
organization has allegedly operated in the Central African Republic, Mozambique (2019), Ukraine
(2014>), Sudan, and the Syrian Arab Republic (2015>).
3. ChVK Wagner operatives have been identified using equipment typically reserved for the
Russian Federation Armed Forces, such as the BPM-97 Vystrel all-terrain vehicle.337 ChVK Wagner
operatives also train at a GRU compound in Molkino, southwestern Russia.338 It is noteworthy that
during Summer 2018 a chapel was erected to commemorate ChVK Wagner operatives killed in the
Syrian Arab Republic near the town of Goryachy Klyuch,339 20km from Molkino. The construction
works were undertaken by another Prigozhin enterprise OOO Megaline (see table A.77.1).340
4. In order to place ChVK Wagner on a more legitimate footing within Russia The Federal Law
on Military Duty and Military Service was amended to allow a citizen on the mobilization reserve
__________________
334
Utkin was formally the Commander of the 700th Special Forces Detachment, 2nd Spetsnatz Brigade, Russian Military
Intelligence Directorate (“GRU”).
335
1) https://meduza.io/en/news/2017/08/21/vladimir-putin-posed-for-a-banquet-photo-with-a-mercenary-previously-
convicted-of-kidnapping-and-robbery; 2) http://tass.ru/politika/3875744; and 3)
https://www.rbc.ru/politics/15/12/2016/585278bb9a7947efc948945b. Also presented with awards at this ceremony were
Oleksandr Serhiiovych KUZNETSOV (M-0271) and Andrei Mychailovich Bogatov (M-1601).
336
Confidential source . Specialities include Special Operations, Offensive Operations, Cyber Operations, Armour,
Artillery, Communications, Combat Engineering, Training, Logistics, Equipment Maintenance and Finance.
337
http://euromaidanpress.com/2018/06/22/new-footage-shows-russian-pmc-WAGNER-involved-in-crucial-2015-
debaltseve-battle-in-ukraine/, 22 June 2018.
338
https://www.fpri.org/article/2019/10/diplomacy-and-dividends-who-really-controls-the-WAGNER-group/, 4 October
2019. GRU 10th Special Forces Brigade compound is located at 44°47'38.22"N, 39°13'22.47"E (centre point).
339
Town centred on 44°38'6.14"N, 39° 8'6.26"E.
340
https://jamestown.org/program/russian-pmcs-in-the-syrian-civil-war-from-slavonic-corps-to-wagner-group-and-
beyond/, 18 December 2019.
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(…) to participate in activities to maintain or restore international peace and security or to suppress
terrorist activities outside the territory of the Russian Federation.341
Table A.77.1
ChVK Wagner command structure
ID a Forename Surname Callsign Role

b
M-0209 Dimitri Valeriiovych Utkin Wagner Commander
M-2010 Alexander Eermolaev Deputy Commander (Morale)
Elizarovich
Andrei Mykolayvych Troshev Siedoy Chief of Staff
M-0971 Sergei Borisocivh Kim Deputy Chief of Staff
M-1364 Viktor Antonovich Rehman Deputy Chief of Staff (Armaments)
M-1511 Konstantin Timerman Chief of Training Branch
Anatoliyevech
M-0271 Aleksandr Sergeevich Kuznetsov c Ratibor Commander, 1st Attack and Reconnaissance
Company
M-1601 Andrei Mychailovych Bogatov Brodiaga Commander, 4th Attack and Reconnaissance
Company
M-5658 Valeriy Nikolaevich Zakharov Head, M-FINANCE L.L.C. Security Services
(CAR)
Olena Anatoliivna Kochina Head, M-FINANCE L.L.C.
Source: Confidential source.
a All ChVK Wagner operatives have a unique four-digit identification number preceded by the letter M (M-XXXX).
b Previously Head of Security for Prigozhin.
c Seriously injured in Libya and confirmed evacuated to Saint Petersburg military hospital in September 2019.
__________________
341
Article 37 as amended by the Federal law of 28 December 2016 No512-FZ – Compilation of the Legislation of the
Russian Federation, 2017, No1, Article 53. On 8 October 2017 a Presidential Decree allowed for the involvement of
foreigners in Russian Federation military operations outside its territory. On 3 September 2018, by Presidential Decree
506 information about employees hired by the foreign intelligence agencies of the Russian Federation to perform
reconnaissance missions who are not staff members of those agencies was classified as a state secret.
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Appendix B to Annex 77: Aircraft flights for Russian interlocuters to eastern

Libya
1. The Panel has identified the following flights between the Russian Federation and eastern Libya
made by civilian aircraft strongly linked to, or owned by, ChVK Wagner or related companies (table
B.77.1).
Table B.77.1
Libya related flights by ChVK Wagner linked aircraft
Date A/C # From To

a
15 Aug 2018 M-VITO Beirut (OLBS)b Misrata (HLMS)
15 Aug 2018 M-VITO Misrata (HLMS) Khartoum (HSSS)c
15 Sep 2018 M-VITO Beirut (OLBA) Misrata (HLMS)
d
13 Dec 2018 VP-CSP Tunis (DTTA) El Beida (HLLQ)
13 Dec 2018 VP-CSP El Beida (HLLQ) Moscow (UUEE)
14 Dec 2018 VP-CSP Moscow (UUEE) El Beida (HLLQ)
16 Dec 2018 VP-CSP El Beida (HLLQ) Saint Petersburg (ULLI)
20 Dec 2018 VP-CSP Saint Petersburg (ULLI) Benghazi (HLLB)
22 Dec 2018 VP-CSP Benghazi (HLLB) Beirut (OLBA)
27 Dec 2018 VP-CSP Moscow (UUEE) Benghazi (HLLB)
27 Dec 2018 VP-CSP Benghazi (HLLB) Moscow (UUEE)
29 Dec 2018 VP-CSP Benghazi (HLLB) Saint Petersburg (ULLI)
10 Jan 2019 M-VITO Beirut (OLBA) Benghazi (HLLB)
10 Jan 2019 M-VITO Benghazi (HLLB) Beirut (OLBA)
22 Jul 2019 VP-CSP Saint Petersburg (ULLI) Benghazi (HLLB)
22 Jul 2019 VP-CSP Benghazi (HLLB) Sochi (URSS)
23 Jul 2019 VP-CSP Sochi (URSS) Benghazi (HLLB)
23 Jul 2019 VP-CSP Benghazi (HLLB) Saint Petersburg (ULLI)
9 Aug 2019 VP-CSP Benghazi (HLLB) Beirut (OLBA)
Source: Confidential source .
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a Hawker 800XP (Serial # 258812) owned by Beratex Group Limited (Seychelles). Beratex (Moscow) controlled by
Anastasia SAUTINA, who was CEO of the Prigozhin owned Concord Management and Consulting Limited until 2017,
when replaced by Dimitri UTKIN (M-0209) Head of WAGNER organization.342 Registered in Isle of Man until the
registration was withdrawn on 4 April 2019. Now registered in Russia as RA-02791. The name of catering company
linked to Prigozhin is VITO-1,343 surely not a coincidence as VITO was specifically requested as the registration # from
the Isle of Man aircraft registry.345
b The aircraft flew from Damascus, Syria to Beirut. WAGNER are known to be operating in Syria.
c 1) WAGNER are known to be operating in Sudan; and 2) the aircraft then flew to Bangui, Central African Republic,
where WAGNER are also known to be operating. https://www.businessinsider.com/russia-WAGNER-group-mercenaries-
where-operate-2018-4?r=US&IR=T, 19 November 2019.
d A British Aerospace 125-800B VP-CSP (Serial # 258210) allegedly owned by Springline Limited, Moscow.
2. The Panel has identified the following flights, to and from Libya to the Russian Federation,
made by aircraft known to have been, or strongly suspected to have been chartered by HAF (tables
B.77.2 and B.77.3).
Table B.77.2
HAF related Russia flights (P4-RMA)
Date A/C # From To Remarks

a Haftar confirmed as a passenger.
5 Nov 2018 P4-RMA Moscow (UUEE) El Beida (HLLQ)
Dates of meeting with
Prigozhin.
8 Nov 2018 P4-RMA Moscow (UUEE) El Beida (HLLQ) Return flight to collect Haftar.
b
24 Aug 2019 P4-RMA Moscow (UUEE) Benghazi (HLLB)
a
Dassault Falcon 900 owned by Sonnig International Private Jet Limited (Hong Kong, China) and operated by
Golden Eagle Trading F.Z.E. (UAE).
b
Haftar reported as being in Moscow from 20 to 24 August 2019.
https://www.africaintelligence.com/mce/corridors-of-power/2019/08/29/khalifa-haftar-makes-anti-g7-trip-to-
moscow,108370080-art.
Table B.77.3
HAF related Russia flights (P4-BAA)
Date A/C # From To Remarks

a
12 Apr 2019 P4-BAA Moscow (UUEE) El Beida (HLLQ)
20 Apr 2019 P4-BAA El Beida (HLLQ) Beirut (OLBA) En-route to Moscowb
26 Apr 2019 P4-BAA Beirut (OLBA) El Beida (HLLQ)
30 May 2019 P4-BAA Moscow (UUEE) El Beida (HLLQ)
15 Jul 2019 P4-BAA Moscow (UUEE) El Beida (HLLQ)
__________________
342
https://www.uawire.org/WAGNER-group-commander-becomes-ceo-of-putin-s-friend-s-catering-business,
16 November 2017.
343
https://www.occrp.org/en/27-ccwatch/cc-watch-briefs/11051-putin-s-chef-to-pay-meager-compensation, 4
November 2019.
345
The Panel has copies of all the appropriate registration and deregistration documentation, as well as the
comprehensive flight records regarding flights to and from Libya.
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a Dassault Falcon EX50 operated by Falcon Wings LLC (www.falconwings.com) (UAE). This is a new aircraft of interest to
the Panel and investigations as to its provenance continue.
b Kheiri Al TAMIMI, Military Aide to Khalifa Haftar attended Conference on International Security in Moscow on 24
April 2019. https://uk.reuters.com/article/uk-russia-security-conference/aide-to-libyan-commander-haftar-visits-moscow-

idUKKCN1S01WX, 24 April 2019.
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Appendix C to Annex 77: Summary of Chvk Wagner communications of

relevance to sanctions measures (2019)
1. Bychkov Report (Extract) 20 March 2019
RUSSIAN ORIGINAL
О ситуации в Ливии
После визитов Халифы Хафтара в Москву 07.11.2018 и Сочи 25-26.11.2018 им были

подтверждены запросы о военно-технической поддержке и помощи в установлении диалога с военно-
политическими группами Ливии, а также о разработке стратегии его предвыборной кампании в
президенты Ливии. При этом, он гарантировал передачу РФ нефтяных и других экономических активов
на подконтрольной ЛНА территории.
Большинство запросов Хафтара российская сторона выполнила: проведен политологический

анализ ситуации, разработаны рекомендации для усиления политического влияния Маршала в Ливии,
включая рекомендации по работе со СМИ и социальным сетям, запущена газета «Голос Народа» тиражом
в 300000 экз., осуществляется консультирование телеканала Аль-Хадас, проведены переговоры и
налажено тесное сотрудничество с основными военно-политическими группами Ливии (А. Салех, Х.
Мишри, представители племен туареги, амазиги, тубу и городов Мисурата, Бани-Валид, Тархуна),
организованы переговоры Х. Хафтара и С. Каддафи, осуществлена военно-техническая поддержка
(осмотрено 536, отремонтировано и восстановлено 125 ед. техники).
Со стороны Хафтара встречных шагов по сотрудничеству нет, экономических проектов не

предложено, более того фиксируется недружественная позиция по ряду ключевых позиций:
1. Российские специалисты не допускаются к реальной работе, обсуждению

важных решений. Например, Хафтар отказал в разрешении на вылет
18.01.2019 г. самолета, направлявшихся по его же просьбе на переговоры с
Сейфом Каддафи.
2. Ввел ограничения на доступ к информации о своей деятельности и

действиях ЛНА. Советники маршала специально дезинформируют
российских специалистов по ряду вопросов.
3. Получает финансовую помощь от ОАЭ. Например, за 20 млн долларов,

полученных от ОАЭ, была куплена лояльность крепости Себха. В отличие
от отношений с Россией, в обмен ОАЭ получили контракты на управление
портом Бенгази и подряды на восстановление города.
OFFICIAL UN TRANSLATION
The situation in Libya
After visiting Moscow on 7 November 2018 and Sochi on 25 and 26 November 2018, Khalifah Haftar
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reiterated his requests for military and technical support and assistance in establishing a dialogue with the various
political and military groups in Libya, and with regard to developing his campaign strategy for the presidential
elections in that country. He also gave assurances that oil and other economic assets in territory controlled by
the Libyan National Army would be transferred to the Russian Federation.
Russia has met most of Haftar’s requests: it has conducted a political analysis of the situation; made
recommendations on how to boost the General’s political influence in Libya, including through the media and social
networks; launched a newspaper, The Voice of the People, with a print run of 300,000 copies; carried out
consultations, which are ongoing, with Al-Hadath television channel; held talks and initiated close cooperation with
the main military and political groups in Libya (Aqilah Salah, Khalid al-Mishri, representatives of Tuareg, Amazigh
and Tabu tribes and the authorities of the cities of Misrata, Bani Walid and Tarhuna); organized negotiations
between Khalifah Haftar and Saif al-Islam Qadhafi; and provided military and technical support (maintenance
checks were carried out on 536 military vehicles, 125 of which were repaired).
No reciprocal moves on cooperation have been forthcoming on Haftar’s part, nor have any economic projects
been proposed. Indeed, his response has been less than amicable on a range of key issues:
1. Russian specialists are not permitted to do any meaningful work or participate in key decision-
making. For example, on 18 January 2019, Haftar denied clearance for an aircraft to depart with
personnel heading, at his request, to participate in talks with Saif al-Islam Qadhafi.
2. He has placed restrictions on access to information about his activities and the movements of the
Libyan National Army. The General’s advisers deliberately misinform Russian specialists on
various matters.
3. He is receiving financial backing from the United Arab Emirates. For example, he used $20 million
provided by that country to buy the loyalty of the Sabha citadel garrison. In return, unlike Russia,
the United Arab Emirates received contracts to manage the port and rebuild the city of Benghazi.
2. Situation Report (Extract) 6 April 2019
RUSSIAN ORIGINAL
Справка по ситуации в Ливии по состоянию на 06.04.2019, 09.00
1) Вечером 05.04 7-ая бригада получила от Хафтара денег и оружие и согласилась принять участие в
штурме Триполи. ЛНА контролирует Тархуну, Гарьян, Сабрату, Сарман, на половину Зинтан. ЛНА
заявляет:
• высадке Спецназа ВМФ ЛНА на базе морской пехоты Сиди-Билал, в 17 км

к западу от Триполи (численность не известна).
2) По мнению экспертов, сил ЛНА недостаточно для взятия Триполи:
• 04.04.2019г., с направления Зинтан (точное место неизвестно), силами

подконтрольными Командующему «Западным военным округом» (ПНС)
генералу-майору Усаме аль Жуайли, был нанесен арт. удар высокоточными
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снарядами по силам ЛНА. Использовали арт. орудие калибром 150 мм

(производство ОАЭ). Два орудия и высокоточные боеприпасы, а также
средство подсветки (БЛА с целеуказателем) были поставлены в Ливию во
время правления М.Кадаффи. В результате нанесенного удара был
уничтожен пикап одним выстрелом. Потери л/с до 4-6 убитых и раненых.
Представители ЛНА обратились к Командующему группировки РФ г/л-ту
Халзакову А.В. с просьбой, выделить расчет БЛА от РФ, для выявления
место положения этих орудий и дальнейшего захвата или уничтожения их,
силами ЛНА в чем им было отказано.
Update on the situation in Libya as at 9 a.m., 6 April 2019
1. On the evening of 5 April, the 7th Brigade received money and weapons from Haftar and agreed to join the
assault on Tripoli. The Libyan National Army now controls Tarhuna, Gharyan, Sabratah, Surman and half of
Zintan.
• According to the Libyan National Army, a group of its navy commandos has taken
the Sidi Bilal marines base, 17 km west of Tripoli. The number of personnel
involved in the operation is unknown.
2. Experts have concluded that the Libyan National Army forces are insufficient to capture Tripoli.
• On 4 April 2019, forces controlled by Brigadier Usamah al-Juwayli, Commander

of the western military district under the Government of National Accord, carried
out precision shelling of Libyan National Army positions from the Zintan area
(exact position unknown). They used 155mm artillery manufactured in the United
Arab Emirates. Two such artillery pieces, along with high-precision rounds and
battlefield illumination equipment (drones equipped with target designators) were
delivered to Libya when Muammar Qadhafi was in power. One pick-up truck was
destroyed by a single round in the shelling, and losses amounted to between four
and six combatants killed or wounded. Libyan National Army representatives
approached the commander of a Russian Federation group of combatants, Major
General A. V. Kholzakov, with a request for a full breakdown of the whereabouts
of drones supplied by the Russian Federation, with a view to seizing or destroying
them. The request was turned down.
3. Bychkov Report (Extract) 10 April 2019
RUSSIAN ORIGINAL
Возможные мотивы визита Х.Хафтара в РФ
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3. После отказа 02.04.2019 предоставить официальную поддержку военной операции МИД РФ и участия
российских военных для в ней, разместил в СМИ и соцсетях фотографии колонны ЛНА, включающей
«белых» военнослужащих европейской внешности. Напечатанные на бумаге госномера 112 региона РФ
разместил на военной технике и грузовиках Камаз, часть этих номеров удалось снять представителям
Компании.
Таким образом, Хафтар намеренно демонстрирует политическим игрокам внутри Ливии и

заинтересованным международным силам свои тесные отношения и военное сотрудничество с РФ, дабы
повысить свою значимость («стоимость») и устрашить соперников.
Possible motives for Khalifah Haftar’s visit to the Russian Federation
3. After the refusal on 2 April 2019 by the Ministry of Foreign Affairs of the Russian Federation to officially
support his military operation or provide Russian troops, Haftar released photos of a Libyan National Army
convoy with “white” soldiers of European appearance to media and social media outlets. Paper number plates
from 112 districts in the Russian Federation were affixed to military vehicles and KAMAZ trucks. Company
officials managed to remove some them.
Haftar is attempting to bolster his standing and intimidate rivals by showing off his close ties to and military
cooperation with the Russian Federation to political figures in Libya and international forces with a stake in the
country.
4. “Ivan” report 22 April 2019
RUSSIAN ORIGINAL
руководителю
Информационное сообщение по итогам встречи 22.04.19 с российским военным аналитиком на

территории
2. Очевидно, что противник значительно превосходит ЛНА по подготовленности, боеспособности и

опытности личного состава. Несмотря на огромный расход боеприпасов (ежедневно совершается три
самолето/вылета ИЛ-76 для доставки российского оружия из ОАЭ через Иорданию, также идут поставки
из Египта), ЛНА так и не добилась никаких значимых военных успехов, и уже теряет завоеванные
позиции. О качестве боевого управления в ЛНА можно судить хотя бы то следующему факту: в армии
фактически неофициально признались в том, что сами по ошибке сбили недавно собственный самолет
(две ракеты в самолет, принятый за самолет противника, запустили бойцы батальона «Тарик ибн Зияд»,
которым командует сын ХХ Саддам).
5. Командование ЛНА постоянно обращается с просьбами к российским военным в Ливии предоставить

оружие и средства навигации и контроля (РЛС, комплексы «Игла» и др.), а также передислоцировать
российский штаб в Джуфру или Гарьян (и обеспечить его для защиты с воздуха российскими ПЗРК) для
консультаций операции на западе страны. Рефреном звучит фраза «помогайте нам как в Дерне». Однако
никаких действий сейчас российская сторона не предпринимает, объясняя это невозможностью какого-
либо участия в боевых действиях без санкции вышестоящего командования.
С уважением, Иван
22.04.2019
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To the Director
Report on the outcome of the meeting held on 22 April 2019 with a Russian military analyst on the ground
2. The opponent’s forces are clearly superior to the Libyan National Army in terms of training, battle-readiness
and experience. Despite the vast amounts of military supplies expended (Ilyushin IL-76 aircraft supply Russian
weaponry from the United Arab Emirates via Jordan three times daily and deliveries from Egypt are also under
way), the Libyan National Army has achieved no significant military success and is already losing ground it had
taken. The quality of its combat command may be judged by a single incident: the Libyan National Army has
more or less officially admitted that it recently shot down one of its own aircraft by mistake (combatants of the
Tariq bin Ziyad battalion, commanded by Saddam Haftar, fired two missiles at the aircraft, wrongly identified
as belonging to the opponent).
5. Libyan National Army commanders are continually pestering the Russian military in Libya for weaponry and
navigation and control equipment (such as radar and Igla surface-to-air missile systems). They also keep
requesting the redeployment of the Russian base, equipped with MANPADS for air defence, to Jufra or Gharyan
for the purpose of advising them on operations in the west of the country. “Help us the way you did at Derne,”
they say. The Russians, however, have thus far refrained from taking any action, explaining that they cannot
become involved in hostilities without the go-ahead from senior commanders.
Yours sincerely, Ivan

22 April 2019
5. Benghazi Mission Report 14 May 2019
RUSSIAN ORIGINAL
Руководителю
Отчёт о деятельности миссии в Бенгази

в период 5 – 13 апреля 2019 г. (состав миссии с 31.03.19 – 2 чел.)
Приложение 8
Информационное сообщение о ситуации по состоянию на 11.04.19
По итогам встречи с российским военным аналитиком на территории
11. Силы ПВО армии ХХ фактически равны нулю. Системы «Квадрат», по оценке нашего
собеседника – по факту нерабочие. ЛНА обратилось к российским военным с просьбой о подготовке 10
военнослужащих для использования ПЗРК. Также ЛНА просит о предоставлении беспилотников.
12. О «профессионализме» бойцов ЛНА говорит огромный расход боеприпасов («палят без
разбора»). Есть сведения о том, что для бригад 106 и «Тарик Бензият» самолетом С-17 на аэродром Харуб
ежедневно доставляются боеприпасы из Египта (эти бригады используют вооружение, к которому
подходят только патроны американского производства). Также с 6.04. ежедневно совершается два
самолето/вылета ИЛ-76 для доставки российского оружия из ОАЭ через Иорданию. Каждый самолет
доставляет до 500 тонн боеприпасов. Также есть сведения, что 9.04. в аэропорт Бенин (Бенгази) прибыл
с боеприпасами транспортник С-130 «Геркулес» ВВС Франции.
13. 10.04. ХХ отбыл в Москву со списком требований о поставках оружия на 4-х страницах. Вместе
с ним в Россию отправились советник Нурии Абдела Али и пресс-атташе Хейсам Касруддин Аль-Башир.
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The Director
Report on the mission to Benghazi
from 5 to 13 April 2019 (mission composition as at 31.03.19 - 2 persons)
Annex 8
Information on the situation as at 11.04.19
Following a meeting with the Russian military analyst on the ground
11. The anti-aircraft capabilities of the XX Army are effectively non-existent. In the view of our
interlocutor, the Kvadrat systems are de facto not operational. The LNA has requested the Russian military to
train 10 soldiers to use man-portable air defence systems. The LNA is also asking for drones.
12. The "professionalism" of the LNA fighters is evidenced by a huge consumption of ammunition ("they
fire indiscriminately"). There are indications that C-17 aircraft make daily deliveries to Harub airfield of
ammunition from Egypt for the 106th Brigade and the Tariq Ibn Ziyad Brigade (these brigades use weapons that
can only use American-made cartridges). In addition, since 6.04 there have been two daily IL-76 departures to
deliver Russian weapons from the United Arab Emirates via Jordan. Each aircraft delivers up to 500 tons of
ammunition. There is also information that on 9.04 a French Air Force C-130 Hercules transporter arrived at
Benina Airport (Benghazi) with ammunition.
13. On 10.04 XX departed to Moscow with a four-page list of weapons needs. Accompanying XX to Russia
were Nouri's adviser Abdel Ali and press attaché Haysam Kasruddin Al-Bashir.
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Appendix D to Annex 77: HAF military vehicle repairs
1. The reported list of ChVK Wagner specialists is shown below in table D.77.1.346
Table D.77.1
ChVK Wagner technical specialists deployed to Libya347
WAGNER
# ID Forename Surname Date of Birth Cell #
R1 M-1017 Enver Erstemovich Didichev 26 Nov 1967
R2 М-1359 Yury Eliseevich Eliseev 3 May 1955
R3 M-1014 Nikolai Mikhailovich Gorbanev 10 Dec 1958
R4 М-1357 Valery Meruzhanovich Manasyan 18 Oct 1951
R5 М-1598 Igor Vasilevich Murin 5 Jan 1964
R6 М-1361 Dmitry Leonidovich Shinkerenko 21 Apr 1983 +79615140XXX
R7 М-1801 Rinat Khabibyanovich Suleimanov 18 Oct 1971 +79024799XXX
R8 М-1358 Aleksei Anatolevich Uskov 20 Oct 1980 +79284262XXX
R9 М-2158 Oleg Pavlovich Volobuev 7 May 1970
Source: Confidential source.
2. The reported list of armoured vehicles and artillery assessed by ChVK Wagner specialists is
shown below in table D.77.2.348
Table D.77.2
HAF military vehicles assessed by ChVK Wagner specialists349
Damage
# Vehicle Inspected assessments Minor repairs Overhauls
1 T-55 MBTa 100 67 16 31
2 T-62 MBT 35 31 4 9
3 T-72 MBT 10 7 1
b
4 BMP-1 IAFV 77 57 14 4
5 BТR-60 APC c
210 126 32
6 BTR-80 APC (Brem) 21 9 3
d
7 BRDM-2 CRPV 41 30 3 1
8 2S1 122mm Howitzer (Gvozdika) 20 11 1 6
__________________
346
347
Official UN translation 1919341E. 12 November 2019.
348
349
From official UN translation 1919341E of figure 4.2. 12 November 2019.
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Damage
# Vehicle Inspected assessments Minor repairs Overhauls
e
9 BM-21 122mm MBRL (Grad) 6 3
10 Tactical vehiclef 5
11 MT-LB MPAAV (Izdeliye)g 10 4
12 2SЗ 152mm Howitzer (Akatsia) 1
Total 536 345 73 52
a Main Battle Tank

b Infantry Armoured Fighting Vehicle
c Armoured Personnel Carrier
d Combat Reconnaissance Patrol Vehicle
e Multi-Barrel Rocket Launcher
f Type not known.
g Multi-Purpose Amphibious Armoured Vehicle
3. The restored vehicles were handed over to HAF in accordance with handover certificates and
were available for use from 12 March 2019. The Panel noted the movement of apparently refurbished
2S1 122mm self-propelled artillery on 16 October 2019 near Suq Al Ahad (figure D.77.1).
Figure D.77.1
Apparently refurbished 2S1 122mm self-propelled artillery during road movement (16 October 2019) a
a Near Souk Al Ahad. Source. 20 October 2019.
4. Spare parts were procured for the T-55, BMP-1 and 2S1 military vehicles at a cost of RUB
6,712,796 (US$ 102,166).350 Heaters for the T-55, T-72 and BMP-1 military vehicles were also
purchased and delivered at a cost of RUB 12,125,000 (US$ 184,538).
__________________
350
At www.xe.com mid-market rate of 12 March 20-19. US$1.00 = RUB 65.74.
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Figure D.77.2
Original document (12 March 2019) a
a Source: Dossier Centre (https://dossier.center/).
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Appendix E to Annex 77: Ministry of Interior report (November 2019)
Figure E.77.1
Original351
OFFICIAL UN TRANSLATION [1921162E]
[Document entitled: “Gharyan capture The report.pdf”]

[Notation at bottom of all pages in this document:]
“Prepared by the advisor team in the Media Office of the Ministry of the Interior”
[Page 5 of original]
B. The situation with regard to the use of Russian mercenaries
Beginning in September 2019, it was observed that Russian mercenary forces were arriving in the military operations
area around Tripoli, and in particular the airport road, Wadi Rabi` and Sabi‘ah. Those forces accompanied the Haftar
forces in carrying out certain special operations. Leaving aside the eyewitnesses who observed the presence of those
mercenaries directly, we have been able to obtain photographs of those Russian mercenaries at while they were present
at those battlefronts. There is evidence that the President of the Wagner Group, which is supplying Haftar with
__________________
351
Extracted from “The full report on the violations perpetrated by the forces of the war criminal Haftar - November
2019”. The full 170 page report was prepared by the team of the counsellors of the Media Bureau of the Minister of
Interior.
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mercenaries, was present at a meeting between Haftar and Russian officials in Moscow. There have also been personal
photographs uncovered. The background of the mercenaries was also confirmed by one mercenary's telephone.
Some journalistic evidence has confirmed that around 35 Russian mercenaries have been killed on the outskirts of
Tripoli.352, 353
__________________
352
https://www.themoscowtimes.com/2019/10/03/dozens-of-russian-mercenaries-killed-in-libya-meduza-a67569, 3
October 2019.
353
https://www.thetimes.co.uk/article/airstrike-kills-kremlin-mercenaries-backing-libyan-strongman-khalifa-haftar-
nbq0szmhz, 4 October 2019.
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Appendix F to Annex 77: Panel summary of ChVK Wagner operative’s

interview on Al Aan TV (3 December 2019)
1. The following is a Panel translation of the cover page for a TV interview that was broadcast on
www.youtube.com on 3 December 2019 by Al Aan TV.354
Individuals undergoing military training, deploy on secret missions and receive direct
financial and technical support from Russia. This is part of the reality of the role of Russian
ChVK Wagner mercenaries in conflict and civil war areas. From Syria to the two dams, Libya
has the same presence and goals. Igor Kulikov, a fighter of Russian ChVK Wagner
mercenaries, returned home after being hit on Russian soil where we met him, but he insisted
on hiding his face for fear of being identified. Igor Kulikov says that ChVK Wagner is
deployed in Benghazi and Tripoli, but he took it upon himself not to talk about his role in
Libya and what he was doing. Kulikov described ChVK Wagner as a commercial company
and said that he had supervised group training in Libya. He noted that his motivation for
joining ChVK Wagner was money, especially as they paid relatively good money. What
Kulikov said refutes much of the talk and denials about the presence of ChVK Wagner
mercenaries in Libya and their military and combat role there. It categorically proves their
heavy military presence and the goal of obtaining financial may justify any act or violation
committed.
2. The following is a Panel summary of the key points made in the interview:
▪ A few months ago he was fighting in Benghazi and Tripoli, although mainly Tripoli.
▪ He was an instructor training groups on fighting in built up areas (FIBUA).
▪ He is from a village in Siberia and is ex-military , in the ‘Serdekov’. ChVK Wagner
offered him a job.
▪ He stated that financial and technical support came from Russia.
▪ He was once injured in Libya and was transferred to Russia for treatment, and then
returned to Libya as he was still under contract.
▪ He and his colleagues do not care who is dealing with who in this conflict. He affirms
being a mercenary and considers it a job, as do his colleagues.
▪ He added that any member of the group who commits ‘violations’ or ‘crimes’ are laid off
and never contracted again.
▪ He was keen on keeping his identity secret but the TV channel indicates that his name is
Igor KOLIKOV (the Panel cannot corroborate this).
__________________
354
https://www.youtube.com/watch?time_continue=7&v=i5Qb5hjfUJk&feature=emb_logo, 3 December 2019.
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Appendix G to Annex 77: Confirmed ChVK Wagner casualties
Table G.77.1
ChVK Wagner casualties a
Date Forename Surname Date of Birth Remarks

b
7 Sep 2019 Vadim Bekshenev ▪ Confirmed by recovered
Sherbank Visa Card (4276
xxxx xxxx 2738) (Expires
08/22) found in area of
operations.
7 Sep 2019 Ignat Borichev ▪ a.k.a. “Benya”
c
7 Sep 2019 or Arytom Nevyantsev 30 Apr 1981 ▪ a.k.a. “Hulk”
12 Sep 2019 Alexseevich ▪ 2nd Chechyen War and
Ukraine “Steop” Task Force.
Sep 2019 Gleb Zverev d 1 Aug 1992 ▪
Aleksandrovich
Not known Denis ▪ a.k.a. “Vector”
▪ From Kushchevskaya
Not known ▪ a.k.a. “Academician”
27 Jan 2020 Vladimir Skopinov e ▪ a’k’a’ “Marin”
▪ Donbass veteran from Saint
Petersburg.
▪ Deployed on 7 December
2019.
▪
a Primary source: https://meduza.io/en/feature/2019/10/02/a-small-price-to-pay-for-tripoli. Accessed 3 October 2019.

b https://citeam.org/wagner-mercenaries-on-the-frontline-in-libya/?lang=en. Accessed 27 October 2019.
c https://myrotvorets.center/criminal/nevyancev-artem-alekseevich/. Accessed 12 December 2019.
d https://twitter.com/CITeam_en/status/1186282467550027776. Accessed 27 October 2019. And multiple other sources.
e https://m.vk.com/memorial_dnr. 07:47pm, 27 January 2020.
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Figure 10.1 Figure 10.2 Figure 10.3 Figure 10.4

Vadim Bekshenyov a Sergei Yurevich Gleb Zverev c Vladimir Skopinov d
Golubenko b
a https://twitter.com/CITeam_en/status/1186282467550027776. 27 September 2019. Original posted 2 March 2016.

b https://myrotvorets.center/criminal/golubenko-sergej-yurevich/. 28 March 2017.
c https://twitter.com/CITeam_en/status/1186282467550027776. 27 September 2019.
d https://m.vk.com/memorial_dnr. 07:47pm, 27 January 2020.
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Member States and regional organizations responses during 2020 to

arms embargo violations
1. Some Member States and regional organizations have taken a range of unilateral actions during
2020 in response to non-compliances with the arms embargo by entities based or registered within
their territories (see table X.1).
Table 78.1
Member State responses
Date Perpetrator Equipment Reference Member State Response
21 Apr 20 Azee Air LLC, IL-76TD (UP- Kazakhstan ▪ AOC suspended for
Kazakhstan I7650) (UP-I7651) 6 months on 21 Apr
(UP-I7654) 2020.
▪ AOC not renewed
29 May 20 Sigma Airlines, IL-76TD (UP- S/2019/914, Kazakhstan ▪ AOC suspended for
Kazakhstan I7602) (UP-I7645) annexes 28 6 months on 29 May
(UP-I7655) and 52 2020.
B-747 (UP- ▪ AOC removed on
B4702) 23 Sep 2020.a
A-300 (UP-
A3003)
20 Jun 20 HAF AN-32B (EY- Tajikistan ▪ Deregistered aircraft

332) on 20 Jun 2020.
2 Jul 20 Jenis Air LLC, IL-76TD (UP- Kazakhstan ▪ AOC suspended for
Kazakhstan I7646) (UP-I7652) 6 months on 3 July
(UP-I7656) 2020.
▪ AOC not renewed
21 Sep 20 Sigma Airlines, As above S/2019/914, European ▪ Assets freeze

Kazakhstan annexes 28 Union
and 52
21 Sep 20 Avrasya MV Cirkin European ▪ Assets freeze

Shipping, Union
Turkey
21 Sep 20 Med Wave, MV Bana European ▪ Assets freeze

Shipping, Jordan Union
and Lebanon
14 Oct 20 Yevgeny ChVK Wagner European ▪ Entry ban and assets

Prigozhin Union freeze
a https://www.barrons.com/news/kazakhstan-suspends-three-airlines-for-breaking-un-libya-embargo-01600847703. 23
September 2020.
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Oil blockade
1. On 17 January 2020, purportedly spontaneous demonstrations by the local population in

Zueitina355 called for a blockade of the oil and gas export terminals in the East. Citizens were
allegedly protesting against a Turkish intervention against HAF in the country. The spokesman for
the HAF, Ahmad al-Mismari, indicated that "the closure of the fields and the terminals is purely a
popular decision. It is the people who decided this".356
2. The Panel however ascertained that the demonstrations were not spontaneous and independently
confirmed that senior representatives of the Petroleum Facilities Guards (PFG) for the Central and
Eastern Region, led by Major General Nagi al-Moghrabi, verbally ordered the heads of the NOC
subsidiaries in eastern Libya to halt export operations and enforce the closure of facilities.
3. As result of the above, NOC was compelled to declare force majeure on 18 January 2020 in the
five crude oil and gas export terminals in the East357, and on 20 January 2020 on the Sharara358 and
Al Feel359 oilfields. Force majeure was declared to minimize losses and limit Libyan state contractual
liabilities. While it affected all operations in these ports, it did not affect operations in other eastern
commercial ports. Oil product vessels continued discharging both imported and domestically refined
products in Benghazi and Tobruk, following a planned schedule.
4. Force majeure was gradually lifted between September and October 2020360 as result of an
agreement between the GNA and HAF. At the centre of this agreement is the issue of the distribution
of the oil revenues. The lifting was possible after both parties agreed that the oil revenues will remain
frozen in the NOC’s account in the Libyan Foreign Bank, where revenues are deposited, as an
exceptional and temporary measure until a more durable economic arrangement is negotiated. To
date, USD 2.35 billion of oil revenues remain frozen.
__________________
355
Located at 30°53'56.2"N 20°04'22.1"E.
356
‘UN Libya mission 'concerned' over threats to block oil exports’, Al Jazeera, 18 January 2020,
https://www.aljazeera.com/news/2020/01/libya-national-oil-company-warns-export-blockade-200118062412807.html.
357
These are: Sidra (30°38'08.7"N 18°22'02.9"E); Ras Lanuf (30°29'06.2"N 18°34'55.9"E); Brega (30°24'52.5"N
19°35'27.2"E): Zueitina (30°53'56.2"N 20°04'22.1"E): and 5) Hariga (Tobruk) (32°03'43.9"N 23°59'31.8"E).
358
Centred at 26°34'36"N, 12°13'05"E.
359
Centred at 26°02'08"N 11°58'33"E.
360
In Brega and Hariga (Tobruk) export terminals on 19 September 2020; in Zueitina export terminal on 22 September
2020; in Sharara oilfiled on 11 October 2020; in Sidra and Ras Lanuf export terminals on 23 October 2020; and in Al
Feel oilfield on 26 October 2020.
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Letters from eastern authorities challenging the NOC legitimacy
Figure 80.1
Official translation of communications received from the Chairman of the eastern National Oil Corporation
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Figure 80.2
Official translation of a communication from the parallel ministry of foreign affairs in Al Baida
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New Board of Directors of Brega Petroleum Marketing Company
Figure 81.1
Official translation of the decision of the Board of Directors of Brega Petroleum Marketing Company
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Attempts to illicitly export crude oil
Figure 82.1
Contract extension for a crude oil sale and purchase agreement
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Figure 82.2
Allocation certificate of 1 million barrels of crude oil
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Attempts to illicitly export condensate
Figure 83.1
Email exchange after vessel was nominated for a condensate export
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Establishment of the ‘Joint Forces’ to fight fuel smuggling
Figure 84.1
Official translation of the decision establishing the ‘Joint Forces’.
Libyan Army Subject: Referral of decision

Office of the Chiefs of Staff Date: 10 Dhu’lqa‘dah A.H. 1441
Joint Operations Room, Western Region Corresponding to 1 July 2020
No.: ghayn ayn ghayn /167/357
To:
10605 Staff Brigadier General Khalifah Salim Gharabil
We hereby forward to you our Decision No. 1 of 2020 establishing a force and appointing
you as its commander, so that you may carry out the Decision’s contents.
Please take appropriate measures.
Annexes: Copy of the decision
(Signed) Usamah Abdulsalam Juwayli

General
Commander of the Joint Operations Room, Western Region
cc:
Department of military intelligence / for information
General file / for records
Decision of the Commander of the Joint Operations Room, Western Region
No. 1 of 2020
concerning the creation of a force and the appointment of its commander
Having considered:
The interim Constitutional Declaration of 3 August 2011 and amendments thereto;
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The political agreement signed on 17 December 2015;

Act No. 40 of 1974 concerning military service and amendments thereto;
Act No. 43 of 1974 concerning retirement from the military and amendments thereto;
Act No. 35 of 1977 concerning the reorganization of the Libyan army (formerly the armed
forces);
Act No. 11 of 2012 concerning the authorities of the command levels of the Libyan Army;
Commander-in-Chief Decision No. 37 of 2019 concerning the establishment of a Joint
Operations Room in the Western Region;
And the best interests of the public,
It is decided as follows:
Article 1
A force shall be formed consisting of units that took part in repelling the aggression
against the city of Tripoli (operation Volcano of Anger). There will units of 500 personnel for each
region. It shall be called the Joint Force.
Article 2
Staff Brigadier General Fayturi Khalifah Salim Gharabil (No. 10605), shall be appointed
commander of the force.
Article 3
The force shall be charged with the following tasks:
1. It will secure the entrances and exits to the Western Region and control the movement of
vehicles and weapons.
2. It will evacuate public and private premises where groups are stationed in violation of the
law, and hand them over to the official authorities.
3. It will apprehend armed gangs that threaten public and private institutions, and confiscate
vehicles and weapons.
4. It will combat fuel and food smuggling, illegal immigration and related activities.
5. It will support the competent authorities in dismantling informal buildings and preventing
encroachment on public lands.
6. It will perform any other tasks it is charged with by the Commander of the Joint Operations
Room in the Western Region.
Article 4
This decision shall enter into force on the date of its issuance. The relevant parties shall
be required to implement all activities related to it.
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(Signed) Usamah Abdulsalam Juwayli

General
Commander of the Joint Operations Room, Western Region
Issued on: 10 Dhu’lqa‘dah A.H. 1441

Corresponding to 1 July 2020
---------------------------
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The case of M/T Jal Laxmi
1. On 21 May 2020 the Panel informed the Committee that the Gabon-flagged tanker, M/T Jal
Laxmi (IMO 9213222), intended to call at Tobruk port to load a cargo of Libyan bunker fuel including
heavy fuel oil (HFO) and marine gasoil (MGO).
2. The operation, which eventually did not take place, was based on two agreements: 1) between
the Military Investment Authority (MIA) of the LNA and the parallel Eastern Brega (see paragraph
139 of S/2019/914); and 2) between the MIA and EMO Investment, Trading and Marketing of Oil
and Derivatives LLC, a company based in Abu Dhabi, United Arab Emirates, that had chartered M/T
Jal Laxmi (IMO 9213222) (see figure 60.1).
3. By virtue of these agreements, M/T Jal Laxmi (IMO 9213222) would have been performing
the role of a supplier and marketer of bunker fuels (HFO and MGO) to vessels outside port limits, for
vessel consumption and not bulk quantities. A description of the illicit export scheme can be found
in figure 85.1.
Figure 85.1
Scheme to illicit export refined petroleum products from Tobruk, Libya
Source: Panel of Experts
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Figure 85.2
Unofficial translation of the agreement between the MIA and EMO Investment, Trading and Marketing of Oil
and Derivatives LLC
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Figure 85.3
Legal translation of the agreement between the MIA and the Eastern Brega
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The case of M/T Gulf Petroleum 4 and M/T Royal Diamond 7
M/T Gulf Petroleum 4

4. On 13 March 2020, a Liberian-flagged tanker, M/T Gulf Petroleum 4 (IMO 9439345)
discharged 10,954 metric tonnes of Jet A-1 aviation fuel at Benghazi port, Libya. The products tanker
had departed Emarat Oil Terminal number 18, Sharjah port, UAE, on 27 February 2020. The vessel
left Benghazi on 16 March 2020 heading west.
5. On 19 March 2020, the tanker suffered a fire and/or explosion while in the Gulf of Surt, outside
Libyan territorial waters, that resulted in one crew member injured. At 15:31 hours of 22 March 2020
a distress call was received and a few hours later, the GNA announced that the vessel had been seized
by the authorities.361 The tanker was escorted to Qasr Ahmed port, Libyan Iron and Steel terminal,
Misratah,362 where it remains to date.
6. According to the documentation obtained by the Panel, the declared shipper and consignee of
the cargo are Afrifin Logistics FZE, with offices in Saif Zone, Sharjah, UAE, and Libyan Express
Airlines,363 with offices in Benghazi Seaport, Libya, respectively (see figure 86.1). The tanker is
operated by Gulf Shipping Services FZE,364 a company registered in UAE that manages no other
vessels. The Panel continues investigating the individuals and organizations that are involved in this
illicit importation.
__________________
361
1) Libya's navy forces seize ship transporting aviation fuel to Haftar, The Libya Observer, 23 March 2020.
https://www.libyaobserver.ly/inbrief/libyas-navy-forces-seize-ship-transporting-aviation-fuel-haftar; and 2)
https://twitter.com/emad_badi/status/1241804110132842496, 22 March 2020.
362
Moored at 32°20'57.10"N, 15°14'53.00"E.
363
A Company that has no relation with “Libyan Express” (www.libyan.express), which is based in Tripoli with offices
in Misrata.
364
Gulf Shipping Services FZC, Gate 4, Land C1-3A, Ajman Port, Ajman Free Zone, Ajman, UAE. Fax: +971 6 740
9982. E-mail: gulf.petroleum@hotmail.com.
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Figure 86.1
Bill of Lading of the Jet A-1 aviation fuel illicit importation
Royal Diamond 7
7. On 8 September 2020, the Panel received specific information indicating that the Marshall-
Island flagged M/T Royal Diamond 7 (IMO 9367437) was expected to call at Benghazi port on 10
September 2020. The tanker departed on 26 August 2020 from Emarat Oil Terminal number 18,
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Sharjah port, UAE. It is relevant to note that M/T Royal Diamond 7 (IMO 9367437) was loaded and
departed from the same terminal as M/T Gulf Petroleum 4 (IMO 9439345).
8. On 9 September 2020, the EU NAVFOR Operation IRINI naval asset, FGS Hamburg (F-220)
conducted several hailings of M/T Royal Diamond 7 (IMO 9367437). The Master of the vessel
declared that the tanker was transporting 10,249 metric tonnes (air) of kerosene in bulk, but was
reluctant to confirm the exact specification of the fuel and no clear answers were given regarding the
final consignee in Bengahzi. Jet A-1 aviation fuel is a form of kerosene. The cargo manifest that was
initially provided was suspicious in its lack of detail regarding the specific cargo type and the final
consignee. See figure 86.2.
Figure 86.2
Cargo manifest on board M/T Royal Diamond 7 (IMO 9367437)
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9. At 07:12 hours (UTC) on 10 September 2020 the EU NAVFOR Operation IRINI FGS Hamburg
F-220 boarded M/T Royal Diamond 7 (IMO 9367437) under the ambit of paragraph 4 to resolution
2292 (2016) as most recently extended by resolution 2526 (2020). During this boarding, a second
cargo manifest was provided, in which the description of the cargo is “Jet Kerosene” (see figure 86.3).
After this inspection, EU NAVFOR Operation IRINI seized the tanker and its cargo under the ambit
of paragraph 5 to resolution 2292 (2016) as extended by resolution 2526 (2020).
Figure 86.3
Second cargo manifest on board M/T Royal Diamond 7 (IMO 9367437)
10. On 10 September 2020, the Libyan focal point pursuant resolution 2146 (2014) reiterated to the
Panel that the NOC neither ordered nor approved the import of the cargo carried by M/T Royal
Diamond 7 (IMO 9367437). The focal point also provided a letter from Brega Petroleum Marketing
Company, the NOC subsidiary in charge of fuel distribution, stating that company was also not
involved with the import of the cargo on this vessel cargo (figure 86.4)
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Figure 86.4
Letter from Brega Petroleum Marketing Company denying any relationship with the cargo carried by M/T
Royal Diamond 7 (IMO 9367437)
Source: National Oil Corporation.
11. M/T Royal Diamond 7 was escorted by Operation IRINI naval assets to Agios Georgios,
Greece, where the cargo was formally seized on 25 September 2020 by the Central Port Authority of
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Lavrio under the ambit of paragraph 9 of resolution 1970 (2011), as modified by subsequent
resolutions.
Aviation fuel distribution in Libya
12. The NOC is the single legitimate entity authorized to export and import petroleum products in
Libya, including Jet A-1 aviation fuel. Any import of refined products into Libya conducted outside
the scope of the NOC is considered to be illicit under Libyan law. Distribution in Libya is done solely
by the NOC’s marketing wing, Brega Petroleum Marketing Company.
13. Since 2011, NOC has not imported military grade aviation fuels365 for jet engines. In its
composition, Jet A-1 and military grade aviation jet fuels are very similar. Military jet fuels contain
particular additive packages to enhance safety, stability and performance under hardship
conditions.366
14. The Panel analysed the Jet A-1 aviation fuel consumed in Libya by the armed forces and air
companies over the last 3 years (see table 86.1). Consumption of Jet A-1 fuel by the armed forces in
the East has increased in relation to the conflict dynamics. Although commercial aviation activity
drastically reduced in the whole country, particularly in 2019, the distribution of Jet A-1 fuel to air
companies also increased.
Table 86.1
Armed forces and air companies Jet A-1 aviation fuel consumption (metric tonnes)a
East and Percentage over Percentage over

Year Centre previous year (%) West and South previous year (%)
2018
Armed Forces 12,925 2,801
Air Companies 17,092 90,936
2019
Armed Forces 46,564 (+) 260,2 906 (-) 67,6
Air Companies 22,048 (+) 28,9 106,518 (+) 17,1
2020 b
Armed Forces 31,802 (-) 31,7 2,712 (+) 199,3
Air Companies 9,403 (-) 57,3 20,156 (-) 81,07
a Source: National Oil Corporation.

b Data as of August 2020.
__________________
365
The most common being JP-5 (NATO Code F-44) and JP-8 (NATO Code F-34).
366
Chapter 15: Fuels, Oils, Lubricants and Petroleum Handling Equipmen.t NATO Logistics Handbook, October 1997.
https://www.nato.int/docu/logi-en/1997/lo-15a.htm. Last accessed, January 2021.
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15. The Panel considers that unilateral and illicit imports of aviation fuel fall under the ambit of
“military materiel” and are therefore in non-compliance with paragraph 9 of resolution 1970 (2011).
In addition, the Panel further considers that transfer of such products to entities under the control of
HAF falls under the ambit of “other assistance, related to military activities”, also in non-compliance
with paragraph 9 of resolution 1970 (2011). The Panel finds that such imports or attempts to import
constitute a threat to the integrity of the NOC.
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Subsidiaries
Grounds for considering the application of sanctions to subsidiaries
1. Most of the assets are not held directly by the parent company but by the subsidiaries. For
instance, the total declared assets of LIA are approximately USD 65 billion, of which roughly USD
20 billion is in cash, much of it at the Central Bank of Libya. Investment in associates and subsidiaries
is roughly USD 25 billion, which is 38% of the total assets, or more than 50% of the assets if cash is
excluded. A similar situation applies at LAIP, itself one of the LIA’s subsidiaries and a designated
entity, where the amounts invested in and loaned to subsidiaries comprise some 50% of its original
paid in capital. Consequently, the assets freeze is likely to be materially impaired and easy to
circumvent if it is not maintained for all subsidiaries as well as the designated entities themselves.
2. Currently there is a lack of transparency of activities, assets and financial position of the
subsidiaries, of which there may be more than 500. LIA has not produced any financial statements in
recent years, in contravention of Law No. 13, which sets out the applicable Libyan law. In fact, the
LIA current proposal is to prepare separate financial statements for the holding company for 2019
and 2018, with 2017 opening balances. Consolidated financial statements would be the usual way of
reporting for an entity of its size and with its resources and would probably be considered best
practice. The suggested financial statements are therefore likely to be in breach of principle 11 of the
Santiago Principles for Sovereign Wealth Funds, to which the LIA was a signatory and to fail to meet
the requirements of Law No. 13. The LIA’s inability to account properly for all of its subsidiaries is
indicative of a serious lack of transparency.
3. The Panel has seen evidence that many of the subsidiaries have made or are making substantial
losses, both in absolute terms and as a proportion of the money invested as capital or loans. The scale
of the losses suggests that the prudent course of action would be to ensure that the assets freeze is
rigorously applied to the subsidiaries while explanations are sought for the losses and proper
accounting and financial controls are put in place.
4. The designated entities have 100% shareholdings in most of their subsidiaries. Consequently
they nominate the Boards of Directors of the subsidiaries and play a major role in the decision making
and governance of the subsidiaries. Considering the degree of control that the parent companies exert
on the subsidiaries, they are responsible for monitoring and ensuring proper accounting and financial
controls.
5. The current lack of transparency means that there is more risk of dissipation of assets, as there
is limited visibility of transactions involving or carried out by the subsidiaries. For example, in 2015
LAIP transferred its interest in one of its own subsidiaries (LAP GreenN) to another company.
6. In many jurisdictions, the concepts of beneficial ownership and control are relevant when
determining application of the assets freeze. If the ultimate beneficial ownership of an entity rests
with a designated person, then all entities that are part of the ownership chain are subject to financial
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sanctions. This approach is prevalent in most jurisdictions where the designated entities or their
subsidiaries operate. Hence, guidance in IAN 1 notwithstanding, subsidiaries controlled by the
designated entities, are also subject to the assets freeze.
7. Many of the subsidiaries do not appear to be performing well and consequently require
ingestion of large sums of money from the parent companies. Most are in the form of loans and
current accounts which have remained outstanding, at least over the last nine years. One such case is
that of LAICO, which was receiving funds from LIA apparently for the debt payments of the hotels
under its management.
8. There could be a conflict of interest when a director in the main managing body of a holding
company often occupies an important position in a subsidiary company monitored by that very
holding company. To deal with just such a conflict the LIA claimed in August 2019 to have
introduced new rules, by amendment of its articles of association, whereby a member of its Board of
Directors cannot also serve on the board of any of its affiliates. Three LIA Board members were,
however, subsequently appointed as directors of the British subsidiary, LIA Advisory Services (UK)
Limited, on 30 June 2020 and the Chairman of the LIA joined the subsidiary board on 14 September
2020. This emphasises the need for the LIA to adopt clear and consistent policies with regard to
conflicts of interest and to implement and enforce them. In the absence of clear policies that are
implemented and enforced there is an evident need to enforce the financial sanctions on the
subsidiaries whose assets are put at risk by the lack of appropriate policies.
9. There is frequently a lack of clarity concerning the beneficial ownership, legal ownership and
the control of investments within the LIA group. Assets may be owned by one entity but controlled
by another. The three Upper Brook Funds are each beneficially owned by the LAIP, the LIA and the
LFB (for ESDF) but their directors were appointed and controlled solely by the LIA. This is a recipe
for uncertainty, lack of accountability and conflict. It emphasizes the need for consolidated accounts,
so that the same asset cannot be claimed as beneficially owned by two or more entities and for the
asset freeze to be maintained and enforced on subsidiaries and their assets while ownership and
control of those assets are clear.
The LIA, LAIP and subsidiaries
10. The Panel provides further details about the two designated entities, LIA and LAIP, in the
context of management of subsidiaries.
11. It was already clear, when the sanctions were first imposed, that the designated entities had
been subject to mismanagement and fraud on a large scale. The Société Générale367 case is one of
many examples. The asset freeze was imposed to make it harder to misappropriate the LIA’s assets
against a background of political uncertainty.
__________________
367
https://www.lesechos.fr/04/05/2017/lesechos.fr/0212037699698_litiges---societe-generale-verse-pres-d-un-milliard-
au-fonds-souverain-libyen.htm#
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Accounting Information
12. LAIP provided financial statements for the years ending 31 December 2012 and 2018. It is
greatly to LAIP’s credit that, in difficult circumstances, it was able to produce a set of audited and
(mostly) consolidated financial statements for 2012. The financial statements for 2018 are only in
draft form, have not been consolidated and there is no audit report. While this represents a less
satisfactory state of affairs than for 2012, there was nevertheless effort made to provide the Panel
with meaningful information. This is in contrast to the LIA, which has only provided two pages of
unaudited and unconsolidated accounts for 2012. The Panel considers that its findings in relation to
the LAIP financial statements would very likely apply to the LIA financial statements when provided.
13. The LAIP controls several holding companies such as LAIP Mauritius, OLA Energy Holdings
Ltd. (Mauritius), Libyan African Holding Company for Industry and Mining (UAE), Libyan African
Agricultural Holding Company (UAE), Aklal Holding N.V. (Curacao) and Libyan African
Investment Company (LAICO) (Libya) (appendix A). For example:
(a) LAICO has 32 companies (of which two are stated to be under liquidation) in which it holds
shares of varying percentages. In nineteen of these, LAICO is the sole shareholder.
(b) LAIP Mauritius has a further five subsidiaries, of which one, OLA Energy Holdings Ltd.
(also incorporated in Mauritius), has several subsidiaries and joint ventures. There were two
other subsidiaries of LAIP Mauritius – Libya Oil Aviation Ltd. and Libya Oil Lubes Ltd.,
both of which were wound up in July 2017. Most of these companies are incorporated in
Mauritius.
14. The LAIP 2012 financial statement was partially consolidated and the basis for consolidation
was indicated as follows:
“Where the Portfolio has the power to govern the financial and operating policies of another
entity or business so as to obtain benefits from its activities, it is classified as a subsidiary.
Consolidated financial statements present the results of the Portfolio and its subsidiaries as
if they formed a single entity. Intercompany transactions and balances between group
companies are eliminated.
15. This means that the performance of all the companies are linked and this has a bearing on
revenue and losses. Total revenue in 2012 was USD 5.7 billion, the major amount of USD 5.6 billion
being from oil and gas related activities. This information is not available for 2018 as a standalone
financial statement was submitted.
16. The principal company, LAIP, has limited activity. The subsidiaries are the ones with the
biggest operations as evident, for instance, from the revenues yielded by oil and gas services in 2012.
Without the consolidated accounts for 2017 and 2018, the complete picture cannot be seen. LAIP has,
however, confirmed that Oil Libya/Ola Energy and FM Capital are the major revenue generators.
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The Proportion of assets invested in subsidiaries

17. The report mentions, without going into detail, that the LAIP had invested a considerable part
of its net worth in subsidiaries or other entities within the LIA “group”. The numbers, excluding
associates and joint ventures and before write-downs, as at 31 December 2018 were as follows:
Table 87.1
LAIP investments in subsidiaries as at 31 December 2018
USD billion
Cost of investment in subsidiaries 1.116
Due from related parties, before write-downs 1.424
Total 2.540
Net assets of LAIP 2.828
Total investments in and loans to related parties as a 89.8%
proportion of LAIP’s net assets
18. A significant proportion of LAIP’s net assets are invested in, or advanced to, their subsidiary
companies. Unless all these companies are captured within the asset freeze shell, the sanctions are
ineffective and easily circumvented. The Libyan people’s money is at risk.
Group losses
19. The LAIP financial statements show significant losses arising in some (unspecified)
subsidiaries (see table 87.2). These indicate widespread mismanagement and illustrate why protective
sanctions are required.
Table 87.2
LAIP financial losses
Investments USD million
Cost of investment in subsidiaries 1,116 100%

Provisions for losses (430) 39%
Investment after provisions 686 61%
Loans
Due from related parties, before write-downs 1,424 100%
Provisions for losses 1,008 71%
Net amount due, after provisions for losses 416 29%
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Financial support to LAIP subsidiaries

Figure 87.1
Examples of LAIP financial support of subsidiaries
20. Loans, interest and current accounts of subsidiaries went up from USD 0.4 billion in 2012 to
USD 1.4 billion in 2018, of which over a billion went to LAICO, LAIP Mauritius, and Rascom Star
QAF (RSQ). Below are examples of requests by LAIP to use frozen funds to ensure the business
continuity of its subsidiaries (not acceded to).
Table 87.3
Examples of LAIP requests to use frozen funds to support subsidiaries as at 31 December 2018
Subsidiary Parent Company(ies) LAIP action

RSQ LAIP To pay liabilities of a direct subsidiary
AKLAL B.V. AKLAL N.V., LAIP To pay 2016 to 2018 taxes of a subsidiary of a subsidiary
LAP Suisse Malta LAP Suisse, LAIP To pay 2018 taxes of a subsidiary of a subsidiary of a subsidiary
Branch Mauritius, LAIP
21. If the subsidiary's financial position is not available for examination, it is not clear as to whether
it had (or did not have) the capacity to pay these dues and whether reliance on the assets of designated
entities was warranted.
Transactions Involving the Sale or Transfer of Subsidiaries
22. The main report refers to the 2015 transfer of LAP GreenN by LAIP to the Libyan Post,
Telecommunications and Information Technology Holding Company, often known as LPTIC.
Hidden in the "notes forming part of the financial statements" is information regarding the paid in
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capital of LAIP, which was originally USD 5 billion but has been reduced to USD 4.25 billion. This
reads:
“Pain-in-Capital (sic)
The aggregate equity resources allocated for the Portfolio against capital are USD 5 billion.
On Aug 2015 the prime minster Of Libya, issues a resolution to reduce the Capital of Laip
with the amounts were invested in Lap Green, and to transfer the ownership of Lap Green to
the Libyan Telecommunication Holding Company”
23. Rather than reflecting the transfer of LAP GreenN as a USD 0.75 billion loss in the income
statement as per common accounting practices, LAIP reduced its capital by a similar amount. This
conceals the loss from layperson readers of the accounts. A loss of this size is obviously a cause for
concern, both as an absolute number and as a proportion of the net assets of the LAIP. The transfer
also had the effect of moving LAP GreenN out of the control of a designated entity (LAIP) and into
the control of an entity that was not subject to the asset freeze (LPTIC). Such transfers are in non-
compliance with the assets freeze, as already pointed out in the report.
Uncertainty concerning ownership and control
24. The transaction involving LAP GreenN also raises questions about decision-making within
LAIP and the LIA. The Prime Minister is, ex officio, Chairman of the Board of Trustees of the LIA.
The Board of Trustees appoints a Board of Directors of the LIA, which in turn appoints a Board of
Directors of LAIP, the latter being a 100% subsidiary of the LIA. It is thus unclear how the Prime
Minister could authorise a transfer of LAP GreenN from LAIP and specify a non-standard accounting
method within the LAIP's financial statements, when, as the audit report in the 2012 accounts states,
"Management is responsible for the preparation and fair presentation of these consolidated financial
statements". This lack of a clear line of responsibility reinforces the need for the sanctions to be
rigorously applied throughout the LIA group, including all of its subsidiaries.
25. The situation regarding the ownership and control of the Libya Oil group of companies is
another example of an unclear and therefore unsatisfactory situation. The LAIP 2012 financial
statements reflect ownership of the Libya Oil group. For example, the employee benefits payable by
the various Libya Holdings operating companies are shown within the LAIP consolidated financial
statements. This would suggest that Libya Oil was a subsidiary of LAIP at 31 December 2012.
However, the 2012 financial statements also refer to Libya Oil Holdings as a "fellow subsidiary" of
the LIA together with LAIP. The Libya Oil group has since rebranded itself as "OLA Energy". It is
not clear where the ownership and control of OLA Energy now lies. This is a matter of concern in
itself and may leave the assets and future cashflows of at risk of misappropriation.
26. The above should provide sufficient information to underline the need to apply the assets freeze
to all subsidiaries within the LIA group. In recent months, the management of the LIA has claimed
in various press announcements to have made great progress. This has not yet been reflected in any
information supplied to the Panel. These claims are often accompanied by LIA requests for a "smart
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sanctions” regime. Yet its inability to produce anything close to meaningful financial statements
would suggest that it is premature to start to change the regime. It is more important to ensure that
the existing regime is effectively implemented and not being circumvented.
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Appendix A to Annex 87: Opportunity to respond
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Appendix B to Annex 87: Panel’s comments on the LIA’s response
1. The Panel will monitor the implementation of the LIA's transformation strategy, once it
commences, and notes that these necessary reforms can take place even in the event of additional
assets freeze.
2. As for loans to the subsidiaries, the Panel agrees with the LIA's assessment that the subsidiaries
are suffering financially. This highlights concerns over bad governance. LIA loans to subsidiaries
have remained outstanding for years, and to the Panel's knowledge, there has been no apparent effort
to review or streamline the performance of these subsidiaries. There is no evidence that losses have
been reduced, performance has improved, or that the underperformance of subsidiaries is the
consequence of the UN sanctions regime. The only case brought to the Panel's attention was LAICO,
a company subject to EU sanctions but not to UN sanctions. Simply put, the constant financial support
from LIA implies the non-viability of the subsidiaries and would result in the dilution of the assets of
the parent companies. The case of LAP GreenN highlights this point and illustrates an instance of
non-compliance as it involved the transfer of assets of LAIP, a designated entity.
3. For its analysis the Panel relied solely on the financial statements available to highlight the risk
of dissipation of assets. The Panel has explained the legal basis for its position and has shown the
large outlay of funds from parent companies, wherever this information was provided by the
designated entities. The Panel has also made it clear in this and in previous reports that any 'adverse
consequences' were minimal. The LIA's stated concern over forfeiture of long leases, confiscation of
real estate‚ etc., grossly misrepresents the effect of the UN sanctions, which do not envisage forfeiture
or confiscation. The Panel is aware that in certain cases such situations arose because of disputes
between LIA and its joint venture partners or sovereign governments, or because the subsidiaries
were incurring losses. The OLA Energy case cited in the reply presumes the company will not have
access to its funds at all, which is not the case as there are derogations built into the resolutions.
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Appendix C to Annex 87: LAIP organigram
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Source: LAIP
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Documentation regarding LAP GreenN transfer
Figure 88.1
Cabinet resolution related to the transfer of shares
The Interim Government

Prime Ministry Bureau
Resolutions
Cabinet Resolution # (384) of (2015)
Enforcing some provisions related to the transfer of shares
To the Libyan Post Telecommunication & Information Technology Holding Company
The Cabinet After reviewing:

The interim constitutional declaration issued on August 3rd 2011 and amendments thereof.
The fiscal system of the State, balance sheet, accounts, and stocks law and amendments
thereof.
Law No. 12 of 2010 on issuance of the business relationships law and its internal regulations.
Law No. 13 of 2010 on establishing the Libyan Investment Authority.
Law No. 23 of 2010 on commercial activities and amendments thereof.
Parliament resolution No. 22 of 2014 appointing the prime minister of the Interim Libyan
Government.
Parliament resolution No. 24 of 2014 declaring confidence in the interim government.
The resolution of the General People's Committee \ previously No. 63 of 2005 on establishing
the Libyan Post Telecommunication & Information Technology Holding Company.
The resolution of the General People's Committee \ previously No. 15 of 2006 on establishing
Libya Africa Investment Portfolio (LAIP).
Cabinet resolution No. 644 of 2013 amending resolution No. 345 of 2013 delegating its
mandate to the prime minister.
Cabinet resolution No. 6 of 2014 on endorsing the organizational structure and establishing
the administrative body of the Prime Ministry's bureau.
Cabinet resolution No. 374 of 2015 on permitting withdrawal of a cash amount.
The minutes of the general assembly's meeting of the Libyan Post Telecommunication &
Information Technology Holding Company held on Wednesday 25/02/2015.
The minutes of the Libyan Investment Authority's board of trustees meeting held in
AlBaidha'a city on Saturday 08/08/2015.
The Cabinet resolved the following:
Article (1)
All shares owned by Libya Africa Investment Portfolio (LAIP) in LAP GreenN shall be transferred
to the Libyan Post Telecommunication & Information Technology Holding Company, including all
of its associated assets and liabilities. Providing that the value of funds invested in LAP GreenN;
consisting in equities, outstanding balance of the current account, and the outstanding balances of
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loans granted to the earlier are deducted at the same value on the date of the transfer from the funds
of Libya Africa Investment Portfolio.
Article (2)
The Libyan Post Telecommunication & Information Technology Holding Company shall be
permitted to take the legal actions necessary to appraise LAP GreenN Telecommunication's assets in
order to determine the fair value of the company and to record the same in the appropriate books.
Article (3)
The Libyan Post Telecommunication & Information Technology Holding Company shall be
empowered to take the legal actions necessary to purchase foreign currencies to ensure its conformity
with Cabinet resolution No. 374 of 2015 which allows the withdrawal of a cash amount to maintain
sound management of LAP GreenN Company.
Article (4)
This resolution shall enter into force as at the date of issue and shall supersede and render void any
other conflicting provisions. All competent authorities shall enforce the resolution immediately upon
its publication in the official gazette.
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Figure 88.2
Decision of the Board of Directors
Decision of the Board of Directors of Libya Africa Investment Portfolio

Decision No. 15 (2015)
Concerning the implementation of a decision
Having considered:
• Act No. 13 (2010) concerning the organization of the Libyan Investment Authority and the
decisions adopted pursuant thereto;
• General People’s Committee (defunct) decision No. 15 (2006) concerning the
establishment of Libya Africa Investment Portfolio;
• General People’s Committee (defunct) decision No. 197 (2006) concerning the adoption of
the statutes of the Libya Africa Investment Portfolio;
• General People’s Committee (defunct) decision No. 136 (2009) approving certain
provisions relating to the Libya Africa Investment Portfolio;
• Libyan Investment Authority decision No. 2 (2015) concerning the establishment of the
Board of Directors of Libya Africa Investment Portfolio;
• Prime Ministerial decision No. 384 (2015) concerning the conveyance of LAP Green to
the Libyan Post, Telecommunications and Information Technology Holding Company.
Decision
Article 1
The executive management of the Portfolio is authorized to implement Prime Ministerial
decision No. 384 (2015) (copy annexed) concerning the conveyance of its entire share, including all
assets and liabilities, in LAP Green to the Libyan Post, Telecommunications and Information
Technology Holding Company, and to take all measures required to complete the conveyance
process.
Article 2
The present decision shall enter into force on the date of its issuance, and the relevant parties
shall be required to implement it.
(Signed) [signature illegible]
Board of Directors of the Portfolio
Issued on 15 October 2015
_______________
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Palladyne/Upper Brook Case
1. The Panel has considered the following statements of the LIA:

(a) LIA commented on the difficulties faced when the two Directors of the Palladyne/Upper
Brook funds (the ‘Funds’) (appointed in 2014) refused to recognise Ali Mahmoud’s authority.
According to the LIA, following the successful conclusion of the authority dispute, a limited
dialogue has been possible and cooperation among the directors has improved;
(b) LIA is now funding the litigation in the Dutch proceedings. The four directors of the Funds
worked together in ensuring necessary filings could be made on behalf of the Funds in
relation to the fees of Palladyne International Asset Management (PIAM). Subsequently, a
fifth director was appointed; and
(c) LIA stated that PIAM continues to generate monthly performance reports of the Funds,
which include a statement that the Net Asset Value (NAV) set out in those reports has been
independently audited by the fund administrator. The Panel notes that this occurred after the
Panel’s observations in S/2019/914, paras. 184 to 192.
2. The Panel’s preliminary findings, on examination of documents provided by LIA and
discussions with relevant interlocutors, are:
(a) LIA has neither visibility nor control over the assets (originally valued at USD 700 million).
The Monthly Performance Reports only indicate the asset class allocation, geographical
region and sector distribution, without specifying the companies in which the funds are
investing.
(b) PIAM, as investment manager, has conducted very little investment activity since 2011.
Significant amounts were retained in cash.
(c) On 16 August 2012, PIAM, the fund managers, established Palint Stichting, a Dutch
foundation. The directors of Palint Stichting are also company officers of PIAM. The
relationship, therefore, does not appear to be at arm’s length.
(d) The three Funds were gradually divested of their control of the assets. Each fund had signed
the custodian agreement with Fortis Bank, in 2007. In 2008, when the assets were then
transferred to State Street Bank, only PIAM signed the custody agreements. In November
2012, PIAM appointed the Deutsche Bank as the new custodian of 98.5 percent of the assets.
The Panel noted that Palint Stichting entered into custody agreements with Deutsche Bank.
(e) In 2014, Deutsche Bank withdrew from the custodian agreement. It, however, continues to
hold the assets for safekeeping as PIAM/Palint Stichting did not withdraw them.
PIAM/Palint Stichting initiated litigation in the Netherlands to contest the termination of the
custodian agreement. In September 2019, the Court found that the Deutsche Bank custodian
relationship was validly terminated and that the bank owes no continuing obligation to
provide custodian services to Palin Stichtingt/PIAM (other than safekeeping).
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(f) In 2016, the Upper Brook (I) fund initiated litigation in the Netherlands to stop payment of
management fees to PIAM. In 2017, a Dutch Court ruled in favour of Upper Brook (I), which
initiated action for recovery of management fees paid to PIAM since 2014. In December
2020, Upper Brook (A) and (F) joined the Dutch lawsuit to similarly recover fees paid to
PIAM.
(g) Palint Stichting still maintains full control of the assets but has given PIAM the Power of
Attorney to operate the bank accounts. The Upper Brook funds have no agreement with
Palint Stichting and are therefore unable to give them any instructions.
(h) PIAM continues as the fund manager. Their management fees are considered to be excessive,
although one fund did manage to get a reduction in fees in 2013, after intervention of its
subscriber (LAIP). The two other funds appear content to continue paying the higher rate
despite ongoing litigation with the fund manager.
(i) The LIA has made no effort to regain control of the assets or to ensure that Palint Stichting
no longer has ownership of the assets.
Figure 89.1
Timeline showing the gradual divesting of the Upper Brook Funds of control over the assets
3. The Panel requested LIA’s comments on the Upper Brook case. The LIA offered the following:
(a) With regard to the observation on efforts “to regain control of the assets”, LIA stated that
the assets belong to the Upper Brook Funds, of which the LIA is shareholder/beneficial
owner, and not to the LIA directly. It is unclear what further steps the Panel considers the
LIA should be taking in that capacity. LIA has further listed out the concrete steps taken in
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order to maintain effective oversight and control of the Upper Brook Funds, such as
appointment of new directors of the three Funds, funding litigation in the Netherlands and
appointing a company to undertake forensic review of the Funds’ assets.
(b) With regards to the control of the assets by Palint Stichting, LIA repeats the general
statement that such structures are legitimate investment vehicles for the express purpose of
separating functions of ownership and control. It admits that the rationale for the use of such
a structure is unclear.
4. LIA is now stating that the forensic audit is not yet complete. The Panel was clearly informed
in late 2020 that the audit was completed but the results could not be shared as the AGO had not
permitted it. The LIA is now making an attempt to distinguish between the Upper Brook Funds and
the LIA, emphasising that it only provides assistance to the boards of the Funds. This is an attempt to
distance itself from direct involvement, in contradiction to previous actions of LIA. In January 2019,
the LIA had taken direct action by removing the two directors (appointed in 2014) of the Upper Brook
Funds and reappointing PIAM as the director of these Funds. The resolutions were withdrawn in April
2019 (S/2019/914, paras 185 and 189). The LAIP has confirmed that it has given the authority to the
LIA to handle issues relating to the Funds.
5. Moreover, as sole shareholder of one fund, the attorney-in-fact for the second fund and the sole
shareholder of LAIP (the subscriber to the third fund), the LIA cannot distance itself from the
management of the assets which ultimately belong to it and to the LAIP. The shareholder is the legal
owner of the company. This is relevant in the context of preservation of assets for the Libyan people.
6. Considering that USD 700 million of the Libyan people’s money is under the control of Palint
and that the Funds have no control over this substantial sum since 2013, it is surprising that no
concrete steps have been taken to regain control. An investigation at this belated stage is only
delaying matters further. The LIA has never categorically stated what action it will take to regain
control of the assets, despite all the litigation. These, in the Panel’s opinion, are dilatory tactics. The
LIA is shirking responsibility by repeatedly saying that the boards of the Funds and their legal
advisors are actively considering this issue and that the LIA will provide any further assistance
requested by the boards.
7. All the statements now being made are thus at variance with the LIA’s actions and the undue
haste with which PIAM was given back control of the funds in January 2019 by the LIA Board of
Directors itself
8. The Panel notes the varying approaches of Member States with regards to the application of
sanctions in the case of the Palladyne/Upper Brook Funds, and consequently the licensing
requirements. The Panel would like to highlight the risk this carries of dissipation of assets:
(a) The three Cayman Islands incorporated Funds were frozen in terms of The Libya (Financial
Sanctions) Order 2011 and The Libya (Restrictive Measures)(Overseas Territories) Order
2011. In the Cayman Islands, the UN sanctions were given effect by The Libya (Restrictive
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Measures)(Overseas Territories) Order 2011. PIAM obtained licences from the UK and the
US authorities for managing the assets of the Funds.
(b) PIAM moved 98.5% of the total assets from State Street Bank to Deutsche Bank in 2013
under a licence from OFAC for transfer of the funds. The licence was issued in March 2013
and the assets were transferred to Deutsche Bank in or about August 2013.
(c) In January 2013, the Deutsche Bundesbank informed PIAM of the following view
concerning investment funds that are not listed (in Annex II of the Council Regulation (EU)
2011/204), but whose shares are owned by listed entities. Per the Panel’s understanding,
Deutsche Bundesbank took the position that Council Regulation (EU) 2011/204 applied to
fund shares, but did not apply to the assets belonging to the fund, which are legally
autonomous. As such the German authorities determined that there was no licensing
requirement in the case of Palladyne, despite the fact that the funds were frozen in the UK
jurisdiction.
(d) The Panel was informed that PIAM never sought any licences from the Dutch authorities. In
support thereof, PIAM relied on a circular dated 11 March 2011 issued by De Nederlandsche
Bank which stated that “…we are informed by the Ministry of Finance, the assets of legal
persons and entities who are controlled by the listed natural and legal persons, entities and
bodies do not need to be frozen; business operations may continue, subject to conditions.
Such legal persons and entities may not, however, make assets and economic resources
available to the listed persons and entities, nor may the interests of the listed entities be
expanded or reduced.” On 14 March 2011, the Dutch Authority for the Financial Market
(AFM) also apparently conveyed a similar position to PIAM. The latter stated that it did
inform the AFM of its activities in relation to the funds.
(e) The German authorities have since confirmed their position stated above. According to them,
the assets freeze does not automatically apply to subsidiaries and they referred to a court
ruling in the EU on the strict interpretation of designation. On the application of guidelines
on ownership and control, the German authorities stated that the Upper Brook Funds being
distinct legal entities, they needed more details to make the determination.
(f) The Panel awaits further clarifications from the Dutch authorities.
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LTP as a separate entity
1. In 1986, the Libyan Arab Foreign Investment Corporation (LFIC) (LYe.001) (a.k.a. LAFICO)
sold its 15% stake in Italian company FIAT for USD 3 billion in 1986. The LAFICO Board of
Directors later decided to allocate these funds to a newly created portfolio called the Long Term
Portfolio (LTP), in order to manage these funds in international bonds, stocks and commercial real
estate. No specific company was created for this portfolio and it did not have a separate legal status.
It was under the control of the Investment Department at LAFICO. All of its assets were in the name
of LAFICO when the assets freeze was imposed. This is still the case, in particular regarding the
assets held by Euroclear and the corresponding custodian banks, ABC Bahrain and HSBC, UK.
2. The LIA has relied on two Qadhafi era decisions (see appendix A) that aimed to separate LTP
funds from LAFICO accounts. The Panel has determined these decisions were never implemented as
the funds remain in LAFICO’s name.
3. The LIA also stated that LTP became a subsidiary of LIA in 2007 (Article 7 of Decision 125
of 2007) and that this new affiliation of LTP is reflected in Article 16 of Law 13 (2010). The Panel
finds that LTP may well have been under the control of LIA as a portfolio but not as an independent
company, as discussed below.
4. After 2011, a steering committee was formed for LTP but it was never registered as a separate
company. Former LIA Chairmen had recommended the integration of LTP into LIA, but this was not
done. Gradually, the steering committee began to act independently of LAFICO even though the
assets were in the latter’s name and LTP still did not have a separate legal status.
5. In 2014, the then Chairman of the Steering Committee of LTP, Sami Mabrouk, moved his office
to Jordan, with the permission of the then Chairman of LIA, Hassan Bouhadi. Finding difficulties in
registering in Jordan, in the absence of any registration as a commercial independent company in
Libya, LIA approved LTP Articles of Association on 10 May 2015 and LTP was registered in Bayda
on 11 May 2015. On the basis of the registration in Bayda, LTP obtained a registration certificate of
a non-operating foreign company in Jordan, on 6 August 2015. At that time, there was no registration
in Tripoli, the declared headquarters of LTP (see appendix D).
6. The 2015 LTP Articles of Association do not mention a separate board of directors for the
Portfolio. Article 9, however, explicitly mentions a Portfolio Management Committee to be appointed
by the LIA BoD. The Panel is in possession of a February 2017 official correspondence from LTP to
Etihad Bank, submitted on LAFICO letterhead with Sami Mabrouk signing as the "Chair of the Long
Term Investment Portfolio Management Committee" (see appendix F).
7. In 2017, the LIA Board of Directors issued a decision that created a "Board of Directors" for
LTP. The newly created LTP "Board of Directors" had to register in Tripoli in order to take control
of the funds and the representative office in Jordan. The LTP was eventually registered in Tripoli on
27 January 2018. The Jordanian authorities accepted the Tripoli registration showing the paid-in
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capital in USD after having rejected an initial registration erroneously filed in Libyan dinars (see
appendices D and E).
8. The LIA provided the Panel with an amended statute of the LTP, prepared pursuant to a 25
August 2019 extraordinary meeting of the LTP General Assembly. Article 1 of the amended statute
describes the LTP as a legal person and separate financial entity, subject to the provisions of the
Commercial Activity Act. It goes on further to stipulate the functions of the "Board of Directors".
There is no evidence to show how the transition (if any) from a Management Committee to a "Board
of Directors" took place.
9. The Panel's view is that the LIA's insistence on the LTP being a separate corporate entity is not
supported by the facts on record. The LTP General Assembly cannot simply declare the Portfolio to
be a separate legal and financial entity from LAFICO. The Panel finds that this Portfolio continues
to be a division of LAFICO, which remains the legal owner of the funds. The LIA's insistence that
LTP is a separate company might result in dissipation of assets.
10. LTP's structure and management practices run counter to all modern management principles of
transparency, best practices, and accountability for sovereign wealth funds. Allowing LTP to operate
independently without proper oversight and controls, as has been happening since the 2014
establishment of the Jordan office, would risk the considerable funds at its disposal.
Analysis of financial statements
11. The paid-in-capital of LTP is USD 4.5 billion. Shares in subsidiaries, and affiliated and publicly
traded corporations, amount to approx. USD 0.69 billion.
12. The case of one company, Sabtina Limited, highlights the confusion the LIA created by
maintaining that LTP is an independent entity. Sabtina is declared in LTP's financial statement as a
direct subsidiary. In the UK sanctions list, however, Sabtina is shown as a subsidiary of LAFICO.
Sabtina's 2019 financial statement also confirms that it is indeed a subsidiary of LAFICO. An
incorrect picture is therefore being presented in LTP's financial statements to reinforce its unfounded
claim of legal independence.
13. Shares in Arab Banking Corporation in Bahrain and Bank El Etihad in Jordan are also held in
LAFICO's name. LTP falsely claimed in its financial statement, however, that it holds the shares in
Bank El Etihad.
14. In its financial statements, LTP includes accounts and term deposits, totalling approx. USD 2
billion, in several banks, of which 50% is held in the Libyan Foreign Bank (LFB). This account is in
the name of LAFICO. The status of the funds held by LFB (approx. USD 1 billion) is under
examination as these may not be in Libya. If held in accounts outside of Libya, the funds will have
to be frozen.
15. There is no clarity on the provenance of the funds used to establish the Jordan office. The former
Chairman of the Management Committee, Sami Mabrouk, informed the Panel that in June 2013, he
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created a new portfolio from interest and dividends. This was used to buy 97 million USD worth of
shares in Safwa Bank.
16. The LTP office in Jordan, having access to funds regarded as not being subject to the assets
freeze, was often a source of funding for LIA and other companies. There was a transfer of 20 million
euros to LIA Malta in 2015. In 2017, LIA Malta demanded another transfer of 2 million euros. A
current account was opened in Bank El Etihad, Jordan, in the name of LIA. These amounts were for
the LIA Malta office administrative expenses. According to the Libyan Audit Bureau, the LTP Jordan
office disbursed a total of 2.5 million euros in 2015 to cover expenditures for LIA's Malta office. That
amount rose to 3.6 million euros in 2016. After the 2017 audit, the Audit Bureau observed that it was
not able to gain access to statements for the LIA's current account in Bank El Etihad.
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Appendix A to Annex 90: The 1992 decision of the Peoples Committee on

LAFICO, LTP and LAFICO’s consequential
communication
Figure 90.A.1
Official translation of the decision
In the name of God, the Merciful, the Compassionate

The Libyan Arab Foreign Investment Company
No democracy without People’s Congresses
Date ______ MWR ___ Corresponding to ________ 19__ Ref. No.:
Decision of the Secretary of the People’s Committee

No. 44 (1992)
concerning separation of the funds of the Libyan Long-Term Portfolio
Having considered:
- Act No. 6 (1981 concerning the establishment of the Libyan Arab Investment Company
- General People’s Committee Decision No. 767 (1991) concerning the establishment of the Long-
Term Investment Portfolio
- The presentation of the Director of the General Investment Department on the inventory of the
total value of the funds of the Long-Term Investment Portfolio as of 30 September 1991.
We hereby decide as follows:
Article I
The Portfolio’s net assets as of 30 September 1991, amounting to $3,634,141,929.51 are to be
separated as follows:
United States dollars
2 826 086 070.00 Funds of the Long-Term Investment Portfolio
808 055 859.51 Funds of the Libyan Arab Foreign Investment Company
Article 2
The funds of the Long-Term Investment Portfolio shall be separated from the accounts of the
Libyan Arab Foreign Investment Company’s in the amount of the share provided for in article 1.
Article 3
The directors of the General Investment Department and the General Finance Department shall
execute this decision and act on it as of 30 September 1991.
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(Signed) Muhammad Ali al-Hawij

Secretary of the People’s Committee
Done on 15 Shawwal A.H. 1401

Corresponding to 18 April 1992
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Figure 90.A.2
Decisions of LAFICO
Umar Mustafa al-Muntasir

Chair of the Board of Directors of the Libyan Long-Term Portfolio
Sir,
I write in reference to General People’s Committee Decision No. 601 (1993) issued on 15
Safar MWR 1403, corresponding to 4 August 1993, amending Decision No. 767 (1991) establishing
the Long-Term Investment Portfolio.
We hereby inform you that the Libyan Arab Foreign Investment Company will prepare a
statement of financial position of the funds of the Portfolio on the date that it received of the above-
mentioned resolution, which was 12 August 1993, in preparation for procedures for your Board to
take delivery of said funds.
As of 12 August 1993, the executive management of the Libyan Arab Foreign Investment
Company shall no longer be legally authorized to conduct any financial transactions with Portfolio
funds, unless temporarily authorized otherwise by you, until the Portfolio takes final delivery of the
funds.
(Signed) Muhammad Ali al-Hawij

Chair of the Board of Directors
______________
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Appendix B to Annex 90: 2015 Articles of Association of LTP
Figure 90.B.1
LTP articles of association
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Appendix C to Annex 90: LTP registration in Bayda and first registration in Tripoli
Figure 90.C.1
Official translation of LTP registration in Bayda

Transitional Government of Libya
Ministry of Economic Affairs
Department of Corporations and Commercial Registration Entry number: 4211-35-05
Commercial Register Office, Jabal al-Akhdar Date: 11 May 2015
Commercial Register Extract
Trade name: Long-Term Investment Portfolio Legal structure: public share company
Established pursuant to decision No. 767 (1991) Duration: 50 years* Start date: 29 September 1991 End date: 29
September 2041
Headquarters address: Tripoli Branch: Facsimile: 021478155 E-mail: info@ltp.fund
Object of company: As in attached statutes
Subscribed capital: 4.6 billion United States dollars
Information regarding business owner, members of the board of directors or general partners:
No. Name Card No. Nationality Title Date of Place of Address
appointment residence
01 Sami Muhammad al- ******** Libyan
Mabruk
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02 Bashir Abu al-Qasim ******** Libyan

Ma‘tuq
03 Mustafa Muhammad al- ******** Libyan
Salih
04 Ahmad Faraj al-Farajani ******** Libyan
05 Ahmed Huwaydi ******** Libyan
Ammush
Legal representative:
01 Sami Muhammad al- ******** Libyan Chair of the 13 June 2012 Tripoli Tripoli
Mabruk Board of
Directors
Branches or agencies:
01 ------------- ----- ----- ----- ----- ----- -----
02 ------------- ----- ----- ----- ----- ----- -----
03 ------------- ----- ----- ----- ----- ----- -----
04 ------------- ----- ----- ----- ----- ----- -----
Comments:
The Board of Directors was appointed pursuant to decision No. 2 (2012). One member was added and another removed pursuant to
decision No. 30 (2013).
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Fees paid per receipt No.: Date:
Validity: One year from date of issuance*
Done at: Bayda’ Date: 11 Month: May Year: 2015 Time: 10.40 a.m.
Document void if marked or altered in any way
Signature of the competent official

Name: Abdulsalam Abdulrahim Jalid
Position: Head of Office
Signature:
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Figure 90.C.2
Official translation of LTP first registration in Tripoli
State of Libya Entry number: 83821

Ministry of Economic Affairs Date: 27 January 2018
Tripoli Economic Control
Commercial Register Extract

Trade name or name of company: Long-Term Investment Portfolio Type: Share company
The company was established pursuant to General People’s Committee (defunct) decision No. 767 (1991)
Duration: 50 years Start date: 29 September 1991 End date: 29 September 2041
Headquarters: Andalus neighbourhood, Tripoli P.O. Box 4538 Facsimile: +218 (21) 5541874
E-mail: info@ltp.ly Tel: +218 (21) 4781452
Object of company: Grow the funds allocated to it by the Libyan State for investment or any other funds for the benefit of third parties,
and to reinvest such by repurchasing, selling, managing, operating and financing various economic, service and financial enterprises
outside the country.*
Subscribed capital: 4.6 billion Libyan dinars Paid-up capital: 4.6 billion Libyan dinars In-kind: —
Members of the Board or partners
# Name Nationality Title Date of Personal Place of Address
appointment identification residence
No.
01 Atif Maylud Umran al- Libyan Chair of the 5 December F97K3RC8 Tripoli Tripoli
Bahri Board of 2017
Directors
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__________________
*
Translator’s note: The translator made his best effort with this line, parts of which are practically illegible.
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# Name Nationality Title Date of Personal Place of Address

No.
02 Miftah Ali Sulayman Libyan Member of the 5 December KZFNKR7F Aryan Aryan
Abdullah Board of 2017
Directors
03 Abdulsattar Muhammad Libyan Member of the 5 December KO69RLOF Sabha Sabha
Sayf al-Nasr Sayf al-Nasr Board of 2017
Directors
04 Hasan Khalifah Khamis Libyan Member of the 5 December JYZ9K68I Gharyan Gharyan
Abu Hasan Board of 2017
Directors
05 Salim Ali Miftah al- Libyan Member of the 5 December J8938740 Tubruq Tubruq
Kadiki Board of 2017
Directors
Idris Abu Bakr Mas‘ud Libyan Member of the 5 December PPNRPZKZ Benghazi Benghazi
Umar Board of 2017
Directors
No. Imad Hasan Khalifah al- Libyan Member of the 5 December P33JHOK5 Tripoli Tripoli
Shaybani Board of 2017
Directors
Legal representative
No. Name Nationality Title Date of Personal Place of Address
No.
01 Atif Maylud Umran al- Libyan Chair of the 5 December F97K3RC8 Tripoli Tripoli
Bahri Board of 2017
Directors
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[Translator’s note: page 3 is completely illegible and was not translated]

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Appendix D to Annex 90: LTP second registration in Tripoli

Figure 90.D.1
Official translation of the second registration showing USD

Government of National Accord Entry No.: 83821
Bureau of the Ministry of Economy Date of entry: 17 January 2018
Extract from the Local Commercial Register of Tripoli
Commercial name of company / partnership: The Long-Term Investment Portfolio company Type: Joint-stock
Company / partnership established by: (Former) General People’s Committee Decision No. 767 of 1991
Company duration: 50 years Starting on: 29 September 1991 Ending on: 29 September 2041
Headquarters: City of Tripoli, Andalus neighbourhood, P. O. box 4538 Fax: 002018215541874
Email: info@ltp.ly Telephone: 002018214781452
Purpose of company / partnership: To manage funds allocated to it by the Libyan State for investment or any funds it administers on
behalf of a third party, and to repurchase, sell, manage, operate and finance various economic, service-related and financial activities
outside the country
Capital: $4,600,000,000 Paid up: Cash: $4,600,000,000 In kind: 0.000
Board members or partners

appointment confirmation residence
no.
01 Atif Maylud Imran Al-Bahr Libyan Chairman of 05 December F97K3rc8 City of Tripoli Tripoli
the Board 2017
02 Miftah Ali Sulayman Libyan Board 05 December jim/Kzfnkr7 City of Aryan Aryan
member 2017 f
03 Abdulsattar Muhammad Sayf al- Libyan Board 05 December jim/K069rl0 City of Sabha Sabha
Nasr Sayf al-Nasr member 2017 f
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04 Hasan Khalifah Khamis Abu Al- Libyan Board 05 December jim/jyz9k68j City of Gharyan
Hasan member 2017 Gharyan
05 Salem Ali Miftah Al-Kadiki Libyan Board 05 December jim/j893874 City of Tobruk Tobruk
member 2017 0
06 Idris Abu Bakr Mas’ud Umar Libyan Board 05 December jim/ppnrpzk City of Benghazi
member 2017 z Benghazi
07 Imad Hasan Khalifah Al- Libyan Board 05 December jim/p33jhok City of Tripoli Tripoli
Shaybani member 2017 s
08 *** *** *** *** *** ***
Legal representative
appointment confirmation residence
no.
0 Atif Maylud Imran Al-Bahr Libyan Chairman of 05 December F97K3rc8 City of Tripoli Tripoli
1 the Board 2017
Branches
No. Address Date established Commercially Registration no.
registered office
01
02
03
04
05
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Proceedings Amendments
Amendment/reconstitution of the Board of Directors of the

Long-Term Investment Portfolio in accordance with Libyan
Investment Authority Board of Directors Decision No. 20
(2017) adopted at its fifth meeting held on 5 December 2017.
Note: In violation of the provisions of article 24 of Act No. 23 (2010) on commercial activity, and article 2 of the Statute of the
Investment Portfolio adopted by the Libyan Investment Corporation with its Decision No. 11 (2015), the Long-Term Investment
Portfolio was previously given an entry in the Commercial Register on 11 May 2015 under registration number 05-35-4211.
Note: Based on the provisions of articles 24, 491 and 495 of Act No. 23 (2010) on commercial activity, the Long-Term
Investment Portfolio was registered with Tripoli Commercial Registry Office (the correct jurisdiction) under entry No. 8382.
Note: Commercial registration No. 4211, issued on 11 May 2015 issued by Bayda’ Commercial Register, which oversees
economic activity in the Jabal al-Akhdar region, was cancelled by judicial order of the Presiding Judge of the Tripoli Court.
Fee payment no.: 8779598 Date: 14 July 2019

Prepared on: 05 July 2019 Month: July Year: 2019 Time: 1130 hours
Validity: 15 July 2020
Seal: Competent official

Name: Miftah al-Sanusi Abdulkarim
Position: Chief of the Local Commercial Register of Tripoli
Signed: (signature)
______________
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Appendix E to Annex 90: Chronology of the legal status of the LTP
Figure 90.E.1
Chronology prepared by LIA
Translated from Arabic\
Chronology of the legal status of the Long-Term Investment Portfolio
On 29 September 1991, the defunct General People’s Committee adopted decision No. 767
(1991) establishing the Long-Term Investment Portfolio as a long-term investment vehicle, in
order to expand the economic base, diversify sources of income and create additional sources of
foreign currency. The principal amount invested in the Long-Term Investment Portfolio was set at
$2,826,086,070, pursuant to article 3 of that decision.
From 30 September 1991, the accounts of the Long-Term Investment Portfolio were separated
and placed in independent ledgers, pursuant to article 8 of General People’s Committee decision
No. 767 (1991) and decision No. 44 (1992) of the Secretary of the People’s Committee for the
Libyan Arab Foreign Investment Company concerning separate ledgers for the assets of the Long-
Term Investment Portfolio.
The Long-Term Investment Portfolio Management Committee was formed pursuant article 4
of General People’s Committee decision No. 767 (1991) of 29 September 1991. In accordance
with the provisions of the aforementioned decision and its amendments, the Management
Committee exercised its authority by adopting regulations, setting investment policies and
objectives, establishing general technical standards for internal and external investment,
prioritizing investment objectives in the light of prevailing conditions in international financial
markets, issuing executive decisions, following up regularly on business results, evaluating
performance and comparing it against market standards, and reviewing investment policies and
objectives periodically in the light of economic variables and prospects in the international
financial markets and of the possibilities for movement.
Pursuant to a decision taken by the Chair of the Portfolio Management Committee on 16
September 1993, the Libyan Arab Foreign Investment Company continued to manage the funds
invested in the Long-Term Investment Portfolio through its technical body until 12 June 2004, in
accordance with the objectives and investment policies adopted and the decisions taken by the
Management Committee. Accordingly, all the assets of the Long-Term Investment Portfolio are
registered in the name of the Libyan [Arab] Foreign Investment Company.
Several committees that were formed pursuant to article 4 of General People’s Committee
decision No. 767 (1991) of 29 September 1991 were responsible for managing the funds of the
Long-Term Investment Portfolio. They all exercised their authority in accordance with the
provisions of the aforementioned decision and its amendments.
On 28 August 2006, the Libyan Investment Authority began managing and investing the
assets of the Long-Term Investment Portfolio pursuant article 5 of General People’s Committee
decision No. 205 (2006) establishing the Libyan Investment Authority.
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On 10 March 2007, the Long-Term Investment Portfolio became subordinate to the Libyan
Investment Authority pursuant to article 7 of General People’s Committee decision No. 125 (2007)
concerning the reorganization of the Libyan Investment Authority.
Article 16 of Act No. 13 (2010), concerning the organization of the Libyan Investment
Authority, provides that the Long-Term Investment Portfolio is subordinate to the Libyan
Investment Authority.
Accordingly, the legal status of the Portfolio can be summarized as that is entity that is
subordinate to the Libyan Investment Authority in the form of an investment portfolio that it is
both financially independent and a legal person under the law and pursuant to the aforementioned
decisions.
_______________
544/548 21-01654
S/2021/229
Appendix F to Annex 90: Shares at Bank al Etihad, Jordan

Figure 90.F.1
Letter from LAFICO for membership of the Board of Directors
The Libyan Foreign Investment Company

a Libyan joint-stock company
with a capitalization of 2 billion Libyan dinars
Date: A.H. / / Corresponding to: 9 February 2017 Ref.: 049 mim ayn 2017
The Honourable Chair of the Board of Directors

Bank al Etihad
Amman, Jordan
Subject: Assumption by the Libyan Foreign Investment Company of membership of the

Board of Directors of Bank al Etihad
Sir,
Please take the measures necessary to appoint Mr. Idris Muhammad al-Uhaymir al-Warfali as
a member of the Board of Directors of Bank al Etihad for Savings and Investment, Amman,
representing the Libyan Foreign Investment Company, as of this date.
Thank you for your cooperation.
Sami Muhammad al-Mabruk

Chair of the Long-Term Investment Portfolio Management Committee
21-01654 545/548
S/2021/229
Sirt Securities International NV

Registered in the Netherlands - Antilles - Registration No. 52972.
11 February 2017
Mr. Isam Salfiti

Chair of the Board of Directors of Bank al Etihad
Amman, Jordan
Sir,
Subsequent to the transaction transferring Bank al Etihad shares owned by Sirt Securities
International NV to the Libyan Foreign Investment Company (LAFICO), we hereby inform you
that the Sirt company has resigned from the Board of Directors of Bank al Etihad.
Please take the appropriate measures, and accept my best wishes for your success.
Accept, Sir, the assurances of my highest consideration.
Samir Imhammad Abu Rawi

Sirt Securities International
546/548 21-01654
S/2021/229
Access to frozen funds
1. In accordance with paragraphs 19 and 21 of resolution 1970 (2011) and paragraph 16 of

resolution 2009 (2011) Member States are required to notify the Committee of their intention to
authorise access to frozen funds.
2. . The Panel has noted two specific cases, one in 2018 and another in 2019 where this was
not done. The Member State has since clarified that this was due to procedural oversight.
3. The regulatory authorities in some Member States, including the United Kingdom, have
informed the Panel that they do not hold information on earnings on frozen funds. In one case, the
Panel requested details of any funds of designated entities held in two financial institutions. The
request was refused on the grounds that these financial institutions themselves are not designated
entities and there is no evidence that suggests those financial institutions are non-compliant with
the sanctions regime. The fact that the information was being sought regarding funds of designated
entities was overlooked. The fact that there is very limited oversight by the regulatory authorities
in several countries, and their reliance and acceptance of the accuracy of reports provided by
financial institutions, is a strong indicator to the Panel that implementation of the assets freeze may
not be very effective.
4. In S/2018/812, para. 227 and S/2019/914, para. 211, the Panel reported on the lack of
accurate financial data being made available by some Member States. Replies to detailed
information requests by the Panel include: (1) the information is not at the disposal of the
authorities; (2) Member States’ reliance on information provided by the financial institutions; (3)
data of earnings on frozen funds could not be provided on the grounds that financial institutions
are not required to provide this information to the Member State regulatory authority. Only in-
depth detailed analysis of financial data can identify cases of non-compliance and allow for
recommendations on a more effective implementation of the assets freeze measure.
Points raised by designated entities:
5. The LIA representatives pointed out their inability to access frozen funds for all their various
expenses. They did accept that the exemption provisions in the resolutions do not cover many of
their essential disbursements. This undermines the LIA’s ability: (a) to meet its established
commitments to third parties (to pay for sums as they fall due); and/or (b) to enter into relationships
with third parties given the difficulties in making payments promptly. The LIA would struggle to
meet payments for business-critical services; plan its expenditure and budgets or to service its
financial obligations.
6. They requested that the main principle behind the assets freeze, viz., the protection of
Libyan assets, be kept in mind.
7. Some of the cases cited were partial payments to be made to professional service firms,
including audit and accountancy firms and payments required for oil exploration and production
21-01654 547/548
S/2021/229
agreements. If the LIA cannot meet its contractual obligations, it becomes liable for significant
penalty payments and may lose its allocated participation rights in the exploration and production
of oil.
8. After documentary analysis and examination of the exemption provisions in the resolutions,
the Panel does not support the arguments of LIA for access to the frozen funds for such payments.
9. The LIA therefore requested further guidance from the Sanctions Committee regarding
which expenses fall within the ‘basic expenses’ and ‘extraordinary expenses’ exemptions; and that
the scope of the exemptions be amended to enable the LIA to make payments of the nature
described above.
10. The LIA has represented that due to delays in obtaining licences from the regulatory
authorities of Bahrain it does not have the operational funds available to make payments for critical
services such as: (1) independent auditing services; (2) staff training; (3) staff insurance; and (4)
essential institutional reform. Outstanding invoices hinder the LIA’s ability to implement its
transformation strategy. The lack of a confirmed time frame is delaying the filing of seven
applications, and a decision is awaited on three applications. The LIA position is that these
unexplained, long delays have placed the LIA in an impossible position vis-à-vis a number of its
contractual requirements.
11. The LIA also faces problems with banks even after obtaining the relevant permissions from
the Sanctions Committee. In a case where the funds had to be withdrawn from a dollar account to
make payments in Libyan dinars, the bank asked for an OFAC licence. The LIA also highlighted
the procedural delays in obtaining OFAC licenses, sometimes even up to six months.
12. Similarly, the LFIC has explained that a lack of response from the UK regulatory authorities
regarding licences for handling frozen assets is now impacting their ability to manage their funds.
The United Kingdom clarified that it has no record of LFIC ever pursuing a formal complaint with
the regulatory authorities. Priority is given to urgent and humanitarian licence applications that
involve a risk of harm or a threat to life and otherwise the authorities commit to engage with licence
applications within four weeks. An applicant is expected to provide clear justifications for why a
case is urgent. Applicants are also responsible for taking independent legal advice and performing
due diligence to ensure compliance with financial sanctions.
LIA concerns over attachments:
13. Further to para. 171 in the main report, the LIA has emphasized that both the LIA and LFIC
are separate entities from the State of Libya, incorporated by Libyan Laws, with their own legal
capacity and financial independence. The LIA also stated that it cannot be liable for the debts of
the State of Libya.
548/548 21-01654

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United Nations S/2021/229

Security Council Distr.: General

Letter dated 8 March 2021 from the Panel of Experts on Libya

The Panel of Experts on Libya established pursuant to Security Council

(Signed) Lipika Majumdar Roy Choudhury

21-01654 (E) 150321

Final report of the Panel of Experts on Libya established pursuant

1. The present report, provided to the Security Council Committee pursuant to

B. Cooperation with stakeholders and institutions

4. A list of Member States, organizations and individuals consulted can be found

II. Acts that threaten the peace, stability or security of Libya or

B. International terrorist groups and individuals

1. Islamic State in Iraq and the Levant-Libya (QDe.165)

2. Organization of Al-Qaida in the Islamic Maghreb (QDe.014)

3. Case of Mohamed Bahrun (Al Far)

C. Foreign armed groups and fighters

1. Chadian opposition groups

3. Sudanese Rapid Support Forces in Libya

4. Case of the Black Shield Security Services company

D. Acts that may lead to or result in the misappropriation of Libyan

E. Acts that obstruct or undermine the successful completion of the

F. Attacks against any air, land or seaport in Libya

26. As reported in paragraphs 40 to 42 of S/2019/914, Tripoli Mitiga airport, the

G. Attacks against State institutions or installations in Libya

H. Acts that violate applicable international human rights law or

1. Forced displacement of civilian population

2. Arbitrary detention, torture and extrajudicial killings

3. Human trafficking and migrant smuggling

the Ministry of Interior also stepped up its contribution to hinder migratory

4. Attacks using explosive ordnance

Tripoli military academy

Qasr Bin Ghashir

III. Implementation of the arms embargo

B. Impact on conflict dynamics 43

C. Maritime violations and interdictions

Ana 7369118 Albania ✓ ✓ 8 • Renamed in March 2020 as

Abbreviation: IMO, International Maritime Organization.

Gulf 9439345 Liberia ✓ 5 • Jet A-1 as combat supplies

Abbreviation: IMO, International Maritime Organization.

Vessel Flag Owner a Operator a Transfer to entity Remarks

Vessel Flag Owner a Operator a Transfer to entity Remarks

D. Arms embargo import violations by Member States

Date identified Type Equipment/Activity Responsible Annex Remarks

23 October Transfer of Aselsan Koral electronic Turkey N/A • Confidential sources

Date identified Type Equipment/Activity Responsible Annex Remarks

Date identified Type Equipment/Activity Responsible Annex Remarks

advisers and mentors in

Date From To Regarding

Date identified Type Equipment/Activity Responsible Annex Remarks

Date identified Type Equipment/Activity Responsible Annex Remarks

10 February Transfer of Transfer of at least 9 United Arab Annex 57 • Violation for

Date identified Type Equipment/Activity Responsible Annex Remarks

8 June 2020 Transfer of Russian Federation- N/A • Found in old

Date identified Type Equipment/Activity Responsible Annex Remarks

16 November Transfer of 155mm Howitzer gun, Annex 71 •

Date identified or of activity Type Equipment/Activity Annex Remarks

E. Arms embargo export violation by a Member State

Note: Map developed by C4ADS, with Panel input.

G. Private military and security company involvement

1. “Project Opus” private military intervention

3. Rossiskie System Bezopasnosti Group

4. SADAT International Defense Consultancy

H. Responses to arms embargo violations