Year 2017 was notable in the occupied Crimea for the fact that the boss of the so-called “Ministry of Agriculture of the Republic of Crimea” Andrey Ryumshin realized that fish farming and fishery products can be food. Previously, such obvious thoughts did not occur to the Crimean “officials” due to the existence of the State Program of the Russian Federation “Development of the Fisheries Complex”, from which the corresponding “Program for the Development of Fisheries of the Republic of Crimea for 2015-2017” was financed, and “ARC” wrote already about the disappeared two billion of this “plan” [1]. But when federal funds ceased to be allocated, the occupation “authorities” urgently reapproved their “Program” for a new term, changing its “jurisdiction and sources of funding”. However, despite the fact that the invaders’ financial resources diminished, the order of their use remained the same. Andrey Chvalyuk, Candidate of Legal Sciences, will tell in more detail about the next two-way laugh of the occupants’ assimilation of “targeted programs” money.

The first thing that should be paid attention to is the hasty approval of the “departmental target program” “Development of the Fish Farming and Fishing Industries” (hereinafter – “DTP”) [2]. The rules of the budgetary process prescribe first to draw up and consider the final report on the implementation of the previous similar program (in this case, the “Program for the Development of the Fisheries of the Republic of Crimea for 2015-2017”) and only then, taking into account the achieved (unreached) results, consider the feasibility of allocating new “budgetary funds”. But these rules are observed only in civilized democratic states, where the priority is to achieve maximum results for minimal funds. “Governing” the occupied Crimea, the aggressor State established its own rules, which the semi-criminal occupation “government” has distorted even more, and now the main goal of the “targeted programs” is to effectively steal the allocated funds. We have already written earlier [3] that the reports on the implementation of the “Program for the Development of the Fisheries of the Republic of Crimea for 2015-2017” were hidden from the public, so it is not worth hoping that they will form the basis of the new “DTP”.

The second feature of the “DTP” is its inclusion since 2017 into the “State Program for the Development of Agriculture and Regulation of Agricultural Products, Raw Materials and Food Markets of the Republic of Crimea” (hereinafter – “Program”), as “Subprogram No. 5” “Development of the Fishery Complex” (Hereinafter – “Subrprogram”). The “Program” [4] was adopted on October 29, 2014 and it has undergone changes several times. Having the opportunity to compare its latest, at the moment, edition with the “order of the Minister of Agriculture of the Republic of Crimea” No. 607 of August 22, 2017, which “approved the DTP”, we can state a serious discrepancy between the tasks set in the “Subprogram” and the tasks of the “DTP”.

The “subprogram” carries declarative goals and only one clearly defined measure: “reimbursement of part of the cost of interest on loans received from Russian credit institutions for the development of commercial aquaculture (commercial fishing), including commercial aquaculture of sturgeon species”. In simple words, they planned to persuade Crimean fishermen and fish farmers to take loans, exclusively from Russian banks, most likely belonging to certain individuals or business structures engaged with the invaders’ “government” or their Kremlin curators. In the opinion of the compilers of the “Subprogram”, the implementation of this measure should have led to “ensuring the conservation, reproduction and rational use of aquatic biological resources; ensuring the competitiveness of goods and services produced by fishery enterprises”. Also, the “Subprogram” has a reference to the “DTP”, the activities from which, as conceived by the compilers of the “Program”, were supposed to contribute to the implementation of the abovepointed tasks.

“DTP”, in its turn, also contains two tasks: “increasing and maintaining the optimal level of extraction (catch) of aquatic biological resources, production of commercial aquaculture, and commercial fish food products; the organization of industrial methods for the cultivation of aquaculture objects; organization of production of freshwater aquaculture and mariculture facilities; construction, reconstruction and (or) modernization of fishery facilities, as well as the purchase of equipment for fish farming and (or) fishing”.

For each task, the “DTP” prescribed its own main event, the essence of which was to reimburse part of the costs of catching, selling, building (reconstruction), and so on. What part of the costs will be reimbursed was not specified. However, it was indicated that the procedure for providing funds for “state” support in the form of subsidies, directions of support and the list of recipients are determined by the “Council of Ministers of the Republic of Crimea”, on the terms determined by the same pseudo-state “body”. This interpretation leaves a wide margin for the “manual” distribution of funds between the “necessary” recipients and, accordingly, for large-scale corruption. The referential way of indicating the main activities, and the inconsistency of the tasks of the “DTP” with the “Subprogram”, the “integral part” of which it was declared, is also unusual for such budget documents, but, as we have already indicated above, for the “Republic of Crimea” this is a common practice.

“Funds from the federal budget” for this “DTP” were not allocated, funding was provided from the “budget of the Republic of Crimea” and from “extra-budgetary sources”, and the latter prevailed. The implementation period of the “DTP”covered the period from 2017 to 2020. In the “passport of the DTP”, the volumes and sources of financing were indicated in the form of bare numbers, without specifying the units of measurement and the type of currency, however, “Appendix 2” detailed that in the annual context, the volume of financing for the “DTP” is: in 2017 – 91.187 million rubles; 2018 – 143.614 million rubles; in 2019 – 99.82 million rubles; in 2020 – 60.95 million rubles. “Ministry of Agriculture of the Republic of Crimea” was the only “responsible executor” of the “Program” and “DTP”.

As we can see, in the absence of “federal funding” we are no longer talking about billions of rubles, but the amounts are still impressive. The “reports” on the implementation of the “Program”, are also in the public domain which means that it is possible to compare whether the results obtained corresponded to the resources spent on their achievement and which of the activities were implemented and which were not.

Let’s start with the main prescripts of the “Program”. As it was already mentioned, it was planned to carry out an action to reimburse part of the cost of paying interest on loans received from Russian credit institutions for the “development of the fishery complex”. But the cunning plan of the invaders’ “officials” did not work, in 2017-2019 the economic enterprises of the peninsula refused to take loans from Russian banks. Either the interest for the use of loans was clearly extortionate, or the “subsidies” for their partial repayment were very scanty, but the fact remains that in 2019 “due to the lack of demand for this direction of support” the event was excluded from the “Program” [5]. We believe that in this case there was a simple scheme based on kickbacks for obtaining cheap loans. If any real compensation were really planned, then the “budget of the Republic of Crimea” would annually allocate funds for such compensation. But the tables of “reports” for 2017-2019 indicate the opposite: provided by the “state program” – 0.0; provided in the “budget” – 0.0; de-facto – 0.0 [6; 7; 5]. It is impossible to spend what is absent, but, nevertheless, the compilers of the “Program” have provided for backup options for their “earnings”, namely the activities of the “DTP”.

For the implementation of the main activity “DTP” “Reimbursement of part of the costs per unit of grown (caught) and sold marketable fish products)”, substantial sums were allocated annually. “Budget funds” were used in full, by 100%, while “extra-budgetary funds” were attracted even in larger volumes than originally planned. Hence the “overfulfillment of the plan” appeared.

The volume of aquaculture facilities produced (grown) in 2017 amounted to 1,799.0 tons or 179.9% of the “plan” [6]. This increase formed the basis for the indicator “Information on the implementation (non-implementation) of activities and justification of the feasibility of terminating the implementation of activities” and in this case “justified further allocation of funds to the DTP”. As we expected, the invaders’ “authorities” overlapped with one growing indicator all other unrealized or even unprofitable measures of the “Program”.

This is most clearly seen in the “report” for 2018 [7], when “grown 2,121 tons of commercial fish and other industrial fish farming objects” appeared in different variations in three events out of four, justifying, among other things, the missing partial refunds on loans. The compilers of the “report” showed high rewriting and synonymizing skills, but it was not sufficient to mask the same numbers. Thoughtful analysis easily shows that under the words “marketable fish and aquaculture objects” one and the same product is hidden and it does not become more of it from the substitution of synonyms. It also raises doubts about the reliability of these figures, since the report contains a postscript that the indicator is based “on the statistical reporting of users engaged in aquaculture”. It is based not on the actual amount of products that entered the market of the peninsula, but on the figures that the producers themselves deigned to provide, they are the recipients of “subsidies”.

Fish on a plate and fish on paper are completely different fish, but for a beautiful report aimed at laundering subsidies, it will do just fine. In 2019, the volume of extracted (caught) aquatic biological resources amounted to 18559.4 tons (113.9 % of the “plan”). The volume of aquaculture facilities produced (grown) in 2019 amounted to 2,628 tons (138.3 % of the “plan”) [5]. As we can see, in 2019, the compilers of the “report” reduced the number of events in the “Program”, leaving only the “Development of fish farming and fishing industries”, without detailing. While the production data, for more informational content, it was decided to divide it into catch and cultivation.

Construction, reconstruction and (or) modernization of fishery facilities, as well as the purchase of equipment for fish farming and (or) fishery, too, for the first time, allegedly went ahead of schedule. In 2017, 4 mussel-oyster farms were allegedly commissioned, 133% of the plan. In 2018, 2 fish breeding facilities were allegedly commissioned, 100% of the plan. In 2019, 7 objects of the fishery complex were allegedly modernized, 350% of the plan.

So, were the goals of the “Program” achieved or were the funds once again spent ineffectively? The 2020 report shows this. It is noteworthy that information about the “implementation of the DTP” was not displayed in it in a general table, as was done in previous years, but it was hidden in the middle of the “report” in the form of text. Apparently, to make it easier to make excuses for the numerous disruptions of the “plans”, but first things first.

“Execution of the DTP” in 2020 allegedly amounted to 135,712,728 thousand rubles, 140.1% of the plan, including from the “budget of the Republic of Crimea” – 32,559,456 thousand rubles, 100%, from “extra-budgetary funds – 103,153,272 thousand rubles, 160,4 %. According to the compilers of the “report,” the “target figure” was allegedly fulfilled: the volume of produced (grown) aquaculture facilities amounted to 4,656.0 tons, 175.7 % of the plan. Within the framework of the “DTP” “Development of the Fisheries Industries”, out of the three implemented measures, according to the compilers of the “report”, “target indicators” were allegedly achieved in two. Implementation of the main “measure” “Reimbursement of a part of direct costs for the production of aquaculture facilities sold in the subsidized period” in 2020 amounted to 39,088 thousand rubles, 186.6% of the plan, including from the “budget of the Republic of Crimea” – 8,377.56 thousand rubles, 100 %, from extra-budgetary funds – 30,710.469 thousand rubles, 244.4%.

The indicator was obtained due to a noticeable increase in the cultivation of pond fish, as well as mari production. 8 companies specializing in the cultivation of aquaculture facilities became participants in the support. More than 300 tons of marketable fish products have been “subsidized”. Separately, the report highlights the mussel and oyster farms: “Donuzlav-Aquaculture”, where 800 tons of mussels and oysters were allegedly grown, and “Chernomorstroyindustriya” LLC, where 123.7 tons of mussels and oysters were allegedly grown. Thus, it is obvious that the “blockades of the North Crimean Canal” did not prevent the “administration” from laundering money in the Crimean fish farming.

Among fish farms, the “report” mentions entrepreneur Y. Polchenko, who allegedly raised 540.43 tons of carp, silver carp, grass carp and catfish, entrepreneur Galstyan’s farm, engaged in sturgeon breeding. The latter allegedly grew 73 tons of products in 2019, and in 2020 there are already more than 150 tons, and from 2020 the farm began to grow only sturgeon. Also, the company “Fishing Collective Farm named after Crimean Partisans” in 2020 put into operation an incubation shop with a capacity of 500 million pieces of white-footed shrimp per year, which allowed the enterprise to start its own production of shrimp fry. According to the statistical reports of users engaged in aquaculture production, in 2020, commercial fish and other industrial fish farming facilities were grown – 3,116 tons and the production of fish seed – 1540 tons. These figures, even taking into account their exaggeration for the purpose of “utilizing subsidies”, make it possible to state that freshwater fish farming in Crimea is doing well without water being supplied by the North Crimean Canal.

But a completely different situation has developed in maritime fisheries. Here, the implementation of the main event “Reimbursement of a part of direct costs for the extraction (catch) of aquatic biological resources sold in the subsidized period” in 2020 also increased. It amounted to 66 092.645 thousand rubles, 132.5 % of the plan, including 12 473.527 thousand rubles from the “budget of the Republic of Crimea”, 100%, from “extra-budgetary funds” – 53 619.118 thousand rubles, 143.3 %. But here, with all the additions, the “target” was not fulfilled, the volume of extracted (caught) aquatic biological resources amounted to 11,432.732 tons, that is, 61.1% of the “plan”. The compilers of the “report” justify the decrease in the volume of production (catch) of aquatic biological resources in the Black Sea by 39.35 % and in the Azov Sea by 36.5 % “due to changes in climatic conditions, a decrease in commercial reserves, repair of one of the most productive fishing vessels”.

Nevertheless, “subsidies” were naturally “assimilated”. 5 companies, engaged in the extraction of aquatic biological resources, became participants in the “support”. It was “subsidized” 4.5 thousand tons of extracted and sold aquatic biological resources. Of the large fishing enterprises of the “Republic of Crimea”, the “report” mentions LLC “MK Trans-service”, which produced 2,863,121 tons in 2020, which is 38.4 % of the total volume of production by “Crimean enterprises” in the Black Sea. At the same time, it is noted that “long-term repair of the vessel of this enterprise” is one of the reasons for the decline in fishing indicators in 2020. Also, among the fishing enterprises, there are LLC “Yugrybresurs” with a production volume of 1,452.151 tons and LLC “Yugrybtrans”, with a production volume of 754.019 tons. It is noteworthy that this active exploitation of marine biological resources of the Black and Azov Seas has not yet received an appropriate response from Ukraine or other Black Sea states.

The execution of the main measure “Reimbursement of part of the cost of purchasing equipment for fisheries purposes” in 2020 allegedly amounted to 30,532,054 thousand rubles. The number of “modernized fisheries facilities at the expense of equipment purchased and put into operation” was allegedly in 8 units.

7 business entities took part in money laundering. Thus, the purchase of 21 pieces of equipment, fishing gear, pumps and other equipment used for the extraction of aquatic biological resources was “subsidized”, and 41 pieces of equipment were allegedly repaired for the same purposes, due to the commissioning of new equipment, 5 vessels were modernized from four fishing companies and one workshop for fish processing. In 2020, the vessels of “Yugrybresurs” LLC, “Trans-Service Marine Company” LLC, “Kerch-Ryba” LLC and “Yugrybtrans” LLC were allegedly modernized. The company “Fishing Collective Farm named after Crimean Partisans” allegedly modernized the incubation shop for spawning and rearing shrimp fry. LLC “Kerchkholod” and entrepreneur Goikalov allegedly purchased new equipment used for fish processing [8].

As we may see from the “final report” of the “Program”, the percentage of growth in the cultivated commercial aquaculture facilities is completely offset by the decline in the maritime fish caught, which preserves the status quo in the industry. And if the fishing enterprises, which received “licenses” from the Russian invaders, continue to use predatory methods of extraction, the production volumes will continue to fall. Of course, this can be used in the future to master the “subsidies”, but the crisis in the communications industry will not be able to be corrected. We also do not share the optimism of the invaders’ “officials” who have high hopes for aquaculture farming. Do not forget about the pandemic, due to which the rate of oyster cultivation continues to decline. These products are delicious and perishable, the oyster cannot be stored frozen. Previously, the products of Crimean oyster farms were purchased by Moscow, St. Petersburg and Sochi restaurants, which were closed for most of 2020 [8].

We got our hands on the “Consolidated annual report on the implementation and evaluation of the effectiveness of state programs of the Russian Federation at the end of 2018”, but there is little trust in this document. There is a suspicion that the data in it was drawn “according to the Ceiling’s method”, that is, they were taken from the ceiling for the sake of beautiful numbers. In pursuit of the metric, the compilers of the summary report often forgot to read the textual description of the metric before drawing 100 % of the actual implementation. The result is comic situations. Here is one of them.

In the “report on the implementation of the state program” “Development of the fishery complex on the territory of the Republic of Crimea and the city of Sevastopol”, the share of scheduled inspections carried out on time, in the total number of planned inspections, according to the “plan” was 96.8%, and de-facto – 100% [9, p. 225]. In addition to the increase in inspections, probably due to which the physiologically substantiated annual demand of the Crimean population for fish and other seafood should have again risen to the normal level of 22 kilograms per capita, the “report” appears in other “important” indicators. For example, the share of “Crimean” “state civil servants of the Federal Agency for Fisheries”, with advanced training over the past 3 years at the level of 93% [9, p. 226]. However, it is not known whether this “most important” indicator has been achieved, since there is a dash in the corresponding column “de-facto”.

In conclusion, we would like to note that it is extremely difficult to understand the statistics, published by the aggressor State, since different departments provide figures that differ at times. And on the websites of the Federal Fisheries Agency and its regional subdivision, the Azov-Black Sea Territorial Administration, there are no sections with statistical data at all, departments only sometimes, very irregularly, mention this in the news. The data “Fresh or chilled freshwater fish, which is a product of fish farming” are not published at all “in order to ensure the confidentiality of primary statistical data received from organizations”, in accordance with Article 9 of the 2007 Federal Law No. 282-FZ “On official statistical accounting and state statistics in the Russian Federation” [10].

It is possible that the data on the production of sea fish will also be classified soon, so as not to frighten the public with low numbers. And they will definitely be, because after the seizure of the peninsula, Russian fishing enterprises rushed to its shores. “In accordance with Russian legislation,” “fishing plots” were raffled off at the “auctions”, and the water resources of the Crimea began to be dug, literally, to the bottom. “ARC” has already reported about a predatory method of prey, when Russia-controlled seiners walk in a ledge, cleaning the coastal waters from all living things [11]; [12]. This means that the volume of fish catches will continue to fall and the targeted “programs” of the Russian invaders’ “authorities” will not be able to improve this situation in the long term.






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7. _za_2018_god_o_khode_realizatsii_i_otsenke_effektivnosti_gosudarstvennoi_programmy_razvitiia_selskogo_khoziaistva_i_reg

8. _za_2020_god_o_khode_realizatsii_i_otsenke_effektivnosti_gosudarstvennoi_programmy_razvitiia_selskogo_khoziaistva_i_reg

9. e49d8c/Doklad_itogi2018.pdf



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