The data is ‘public’. For the past four years, the Finnish NGO Centre for Research on Energy and Clean Air (CREA) has been tracking Russian hydrocarbon flows. Tanker by tanker. And what they have been showing since the start of the year is striking: the ‘Unknown’ category – shipments of Russian crude leaving Primorsk or Ust-Luga with no declared destination – has, in a matter of weeks, become the dominant component of Russian maritime exports, pushing total volumes to levels close to the peaks seen in early 2022. At the same time, declared shipments to India have plummeted by 19%, a direct consequence of the US sanctions imposed in October 2025 on Rosneft and Lukoil.

Oil doesn’t disappear: it simply changes its identity. A tanker leaves the Baltic with no destination, transfers its cargo to a second vessel in the Mediterranean, and the second vessel arrives at its destination with a cargo whose Russian origin cannot officially be traced. In February 2026, the Crea estimated the volume of Russian crude oil at sea with no known buyer at 6.9 million tonnes – worth €2.3bn.

It is against this backdrop that the conflict in the Gulf has accelerated everything. Since the US-Israeli strikes on Iran and the effective closure of the Strait of Hormuz, Urals crude has returned to price levels not seen since the start of the invasion of Ukraine. The historic discount on Russian oil – which had allowed it to remain attractive despite the sanctions – has automatically narrowed as buyers sought substitutes for Gulf crude.

In the first fortnight of March 2026, Russia generated around €372m a day in oil revenues, a 14% increase on its February average. This floating stock of Russian crude with no destination was partially legalised by the US Office of Foreign Assets Control on 5 March, which temporarily authorised its delivery to India on the grounds of an energy emergency. Moscow, which had been selling at a relative loss for two years, suddenly finds itself in a position of strength.

Russian export volumes are 6% higher than before the war in Ukraine

The cumulative figures since 24 February 2022 are staggering. Russia has exported over €1trn worth of fossil fuels – including crude oil, gas and coal. The European Union has financed €227bn of this. Despite four years of sanctions, the volumes exported by Russia have remained 6% above pre-invasion levels. China, India and Turkey absorbed 93% of Russian crude exports during the fourth year of the invasion. Hungary and Slovakia, meanwhile, increased their imports of Russian oil by 11% during the first ten months of 2025, in defiance of the spirit of the European sanctions, but in the name of pragmatism: to heat their populations. What the four years of pressure have managed to reduce is the price, not the quantity – until the Gulf changes the game.

In the face of soaring prices, calls for a return to Russian oil in Europe were heard from the very first days of the conflict. Viktor Orbán called on the European Union to suspend its sanctions. Robert Fico called for the Druzhba pipeline to be reopened. Vladimir Putin himself stated that Russia was ready to resume deliveries to Europe – before threatening, a few days later, to turn off the taps himself without delay. Ursula von der Leyen described any return to Russian hydrocarbons as a “strategic mistake”, the two heads of the Luxembourg government, Luc Frieden and Xavier Bettel, in line with this approach. However, Russia’s war budget, based on a price of $59 per barrel for Urals crude, automatically increases with every rise in the market: at $90 per barrel, the potential additional revenue for 2026 is estimated at between $20bn and $55bn. This is enough to sustainably fund a military effort whose official cost accounts for around 5% of Russia’s GDP.

Rosneft under supervision in Germany

This is where Luxembourg’s local story intersects with the bigger picture. On 3 April, Rosneft European Holdings formalised a change in its board of directors. Kirill Molodenkov, a Russian national resident in Singapore – one of the key hubs for trading Russian crude oil outside the sanctions regime – replaces Alexey Solovyev on the board, with a term running until 2030. This limited company, based at 16 Allée Marconi, is the formal shareholder of Rosneft Deutschland GmbH and RN Refining & Marketing GmbH – the two German subsidiaries over which Berlin, Brussels and Washington have just imposed indefinite supervision.

Kirill Molodenkov is no stranger to the group’s Luxembourg structure: public records show that he has previously served on the board of directors of Rosneft Holdings LTD SA, the group’s other Luxembourg holding company. This director of business development at Rosneft previously worked for BP, then for TNK-BP International, the Russian-British joint venture acquired by Rosneft in 2013 – a career in Western organisations that makes him less of an apparatchik and more of a specialist in oil assets operating under international regulatory pressure. His appointment on 31 March 2026 as head of Rosneft European Holdings marks a return, at the very moment the new legal structure is being put in place. His profile – an operational executive well-versed in offshore structures, domiciled in an Asian jurisdiction not subject to sanctions – deliberately contrasts with that of a political leader.

It is worth reconstructing the sequence of these coordinated decisions. On 19 February, the European Commission approved indefinite supervision of Rosneft’s German assets, bringing to an end the six-monthly renewal mechanism that had been in place since September 2022. On 28 February, Berlin formalised the new permanent administration of the PCK Schwedt, Miro and Bayernoil refineries – accounting for around 13% of Germany’s refining capacity. On 5 March, the US OFAC published General Licence 129A, which removed the expiry date of 29 April 2026 set out in the previous licence, making the sanctions waiver indefinite as well. Within 15 days, three jurisdictions had aligned their measures to bring lasting stability to a situation that had been in a state of uncertainty for four years. And on 31 March, Rosneft appointed a new administrator in Luxembourg.

Luxembourg holding companies are restructuring

This is because the group has two holding companies in the Grand Duchy, both located at the same address but of a different nature. Rosneft European Holdings is the formal direct shareholder of the German subsidiaries under its control. Rosneft Holdings LTD, founded in 2006 with a subscribed capital of $1.743bn, is owned by LLC RN-Foreign Projects, a separate Moscow-based entity – an additional layer in the chain of ownership. Its current director, Igor Bokov, is domiciled in Bertrange, Luxembourg. Two structures, two governance models, one address. A local resident for the most capitalised holding company, an international executive based in an Asian trading hub for the entity that directly holds the strategic assets.

The parent company is not in hibernation. Its 2024 annual accounts, filed with the LBR in December 2025, confirm this. The balance sheet total stands at €66.8 million, of which €64.2m are net financial assets – the shareholdings in RDG and RN R&M, recorded at historical cost of €221m after deducting €156.7m in accumulated impairments since 2022. Significantly, the 2024 financial year saw a reversal of impairment losses amounting to €14.3m: the directors considered that the recoverable amount of these assets had improved. This accounting decision was taken prior to the conflict in the Gulf. Yet it accurately anticipates the scenario currently unfolding. The notes to the accounts specify that the sole shareholder – PJSC Rosneft Oil Company – undertakes to cover any liquidity shortfall. A subsequent event is also noted there: on 18 April 2025, the company sold its shares in Colmati International LLC, a wholly impaired subsidiary. We clean up, we consolidate, we wait.

The legal scope of the structure is strictly defined – at least in theory. GL 129A does not cover Rosneft European Holdings: only RDG and RN R&M benefit from the US exemption. The Luxembourg holding company remains a blocked entity under US sanctions. Its voting rights in RDG are frozen for the duration of the indefinite receivership. According to the Centre for Oriental Studies in Warsaw, Rosneft never had any real intention of selling its German assets, merely going through the motions of negotiations. The Qatar Investment Authority has withdrawn from the discussions. KazMunayGas has made no progress. Berlin fears Russian retaliation and the legal disputes that a formal expropriation would entail. The indefinite receivership is less a solution than a crystallised deadlock – comfortable for all parties in the short term.

But PCK Schwedt, in which Rosneft European Holdings is the formal shareholder via RDG, is technically configured to handle Urals crude. If this crude were to officially return to Europe – and the pressure for its return has never been stronger since 2022 – it is this infrastructure that would be the first to receive it. The Luxembourg-based holding company would be in the front row. And it would be Kirill Molodenkov, from Singapore, who would sign the deal.