Re-checked 2026-08-24: all 24 quoted passages behind this document are still present in the 6 primary records. What was checked
Bottom line. The disclosed loan is signed, but grant effectiveness, awards, mobilisation and the operating case remain open. The borrower is wholly state-owned and under trust management, on the record. The EUR and USD financing records are narrowed to two dated approvals and still not connected by a disclosed record.
Up to €35m, 10-year multicurrency EBRD loan; project status shown as Signed.
[1]Up to €10m is stated under APIF. Signature or effectiveness is not established by the reviewed public records.
[1]The works tender closed for responses on 17 April 2026; the consultancy tender carried a 28 August 2026 response deadline. Award and mobilisation remain open in the reviewed records.
[4, 5]The board report dates the US$20m approval to 20 September 2023; the project page carries an approval date of 23 July 2025. Two dated approvals under one Project ID fit the records better than a data error, but nothing disclosed connects them.
[1, 3, 6]What the primary records support
| Item | Public evidence | Status |
|---|---|---|
| Borrower | National Company Aktau Sea Commercial Port JSC. | Verified [1] |
| EBRD facility | Loan of up to €35m equivalent; 10-year; multicurrency; project status Signed. | Verified [1] |
| Use of proceeds | Reconstruction of berths 3 and 12 and acquisition of two ship-to-shore cranes. | Verified [1] |
| Total project cost | €55m. | Verified [1] |
| EU grant statement | The project page states that a capital grant of up to €10m will be provided under the EU Asia Pacific Investment Facility. | Verified source statement [1] |
| EUR summary residual | At the stated maxima, €55m − €35m − €10m = €10m not allocated to a named source in the EUR project summary. This is an unreconciled residual, not proof of a funding gap. | Calculation [1] |
| Procurement plan | Works for berths 3 and 12; equipment and machinery; construction supervision and implementation support. | Verified [2, 3] |
| Earlier client contribution statement | The December 2025 notice says the client will pay applicable taxes, including VAT. It does not provide a complete sources-and-uses reconciliation. | Verified [2] |
| Later funding statement | The May 2026 notice states a senior loan of up to US$20m and US$5m internal cash for Project ID 53786 and the same three planned contracts. | Conflict [3] |
| Works tender | A two-stage tender for reconstruction of berths 3 and 12 was published on 4 February 2026 and closed for responses on 17 April 2026. | Verified [4] |
| Consultancy tender | A tender for construction supervision and project implementation support was published on 14 July 2026, with a response deadline of 28 August 2026. | Verified [5] |
| Environmental and social | Category B; ESAP, Non-Technical Summary and Stakeholder Engagement Plan were prepared and agreed. The summary also identifies contractor oversight, fire and electrical safety, and dredging-related monitoring needs. | Verified [1] |
“Signed” is the project status shown on the EBRD page. It does not by itself establish that the stated grant is signed or effective, that procurement contracts have been awarded, that works are underway, or that the operating case can service debt.
What remains open for the reviewer
| Risk area | What the public pack does not establish | Document needed next |
|---|---|---|
| Sources and uses | Relationship between the EUR and USD financing records; grant signature and effectiveness; amounts committed or disbursed; complete counterpart contribution and treatment of taxes/VAT. | Approved financing plan; signed facility and grant records; the board report for the 23 July 2025 approval, which is not published on the project page; amendment, refinancing or supersession record. |
| Demand and revenue | Historical container series, customer concentration, contracted volumes, tariff schedule, base case or downside case. | Operator demand pack and lender operating model. |
| Currency and debt service | Debt currencies, drawdown mix, grace period, repayment profile, revenue currencies and hedging. | Facility term summary and revenue-currency bridge. |
| Procurement and delivery | The works and consultancy packages have tender notices. The reviewed records do not establish the equipment tender, contract awards, mobilisation, completion protections or PIU delivery capacity. | Current ECEPP package records, award notices, signed contracts and implementation schedule. |
| Ownership and integrity | The chain and the manager are disclosed. What the EBRD's integrity due diligence found is redacted, and the public pack establishes nothing about the parties below the borrower: contractors, suppliers and their beneficial owners are not named in the reviewed records. | The unredacted integrity record through the reviewer's own channel; contractor and supplier identities once awards are made, with beneficial ownership for each. |
| E&S implementation | Current ESAP status, contractor controls, monitoring of associated dredging and closure of recorded safety gaps. | Latest ESAP monitoring report and lender/independent audit updates. |
Who owns the borrower
Before a reviewer asks whether the numbers work, they ask who stands behind the counterparty. The EBRD board report answers that in a disclosed annex, so this screen states the chain from the record instead of describing it.
| Layer | What the record states | Label |
|---|---|---|
| Borrower | JSC National Company Aktau Sea Commercial Port. | Verified [6] |
| Immediate shareholder | JSC NWF Samruk-Kazyna holds 100 per cent. | Verified [6] |
| Ultimate owner | The Republic of Kazakhstan holds 100 per cent of Samruk-Kazyna. The borrower is wholly state-owned through two layers, with no private tier disclosed in the record. | Verified [6] |
| Operational control | The borrower sits under trust management of JSC National Company Kazakhstan Temir Zholy, itself 100 per cent held by Samruk-Kazyna. Ownership and day-to-day control are not in the same hands, and a reviewer who reads the shareholder alone would miss the manager. | Verified [6] |
| Public-list name check | A possible-string-match check of the borrower, Samruk-Kazyna and Kazakhstan Temir Zholy against a dated snapshot of four public lists — OFAC SDN, OFAC consolidated non-SDN, the EU consolidated list and the UK Sanctions List — returned no match on any of the three names. | Checked 24 August 2026 |
| Integrity due diligence | Section 6.2 records that integrity due diligence was carried out with the EBRD's Office of the Chief Compliance Officer on the company, its senior personnel, its shareholder and its manager under the trust management agreement, and that the actions required for money laundering, terrorist financing and sanctions were taken. What that diligence found is redacted. | Redacted [6] |
The name check is a possible string match against a dated list snapshot. It is not identity verification, ownership resolution, a determination under the 50 per cent rule, or sanctions clearance, and a clean result on three names says nothing about any other party to the project. The redaction in section 6.2 is what a reviewer should carry forward: the bank states that it looked and that its procedures were satisfied, and does not disclose the finding. Neither the chain nor the clean name check is a statement about the conduct of any person or company.
Source conflict that must not be hidden
The EBRD page contains one block with a €35m loan and €55m total project cost and a second block with a US$20m senior secured loan and US$25m total project cost. A General Procurement Notice published on 26 May 2026 for the same Project ID 53786 and the same three contract packages states a US$20m loan plus US$5m internal cash.
One side of the conflict now has a governing record. The disclosed board report shows the Board of Directors approving a senior loan of up to US$20m, stated as €18.3m equivalent, on 20 September 2023. That is the USD block. The same project page carries an approval date of 23 July 2025, which the €35m block does not contradict, and the two blocks also differ on a descriptive field — stated annual cargo handling capacity of 11.8m tonnes against more than 17m tonnes — which two tranches of one facility would not.
The reviewed records therefore support two dated approvals under one Project ID more readily than a data error, but they do not establish it. No disclosed record connects the two, and no board report for a 2025 approval is published on the project page. The figures are still neither added together nor treated as independent facilities.
Narrowed, not closed [1, 3, 6]What would close this first screen
- Reconcile the financing records. Obtain a complete sources-and-uses table, the governing facility and grant records, and the amendment or supersession record connecting the EUR and USD disclosures.
- Confirm procurement reality. Match all three packages to their current notices, awards, contracts and mobilisation status without inferring status from a missing public notice.
- Test the operating case. Connect historical volumes, tariffs and contracted or concentrated traffic to the forecast used for debt service.
- Size FX exposure. Match facility currencies and repayment dates to the port's revenue currencies and any hedge or conversion mechanism.
- Update implementation controls. Review PIU capacity, construction schedule, ESAP progress, contractor safety and dredging monitoring.
Claim-to-source audit excerpt
| ID | Material claim | Label | Exact public locator |
|---|---|---|---|
| AK-01 | Current project status is Signed. | Verified | [1] Project timeline |
| AK-02 | Current loan is up to €35m, multicurrency and 10-year. | Verified | [1] EBRD Finance Summary |
| AK-03 | Total project cost is €55m. | Verified | [1] Total Project Cost |
| AK-04 | EU APIF grant is stated as up to €10m. | Verified | [1] Technical Cooperation and Grant Financing |
| AK-05 | Maximum named loan plus grant is €10m below stated total cost. | Calculation | €55m − €35m − €10m |
| AK-06 | Three procurement packages were planned. | Verified | [2] and [3], Other Information, Contracts 1-3 |
| AK-07 | The works tender was issued and closed for responses. | Verified | [4] Publication and closing dates |
| AK-08 | The consultancy tender was issued with a 28 August 2026 response deadline. | Verified | [5] Publication and closing dates |
| AK-09 | The May 2026 notice states a US$20m loan plus US$5m internal cash for Project ID 53786. | Conflict | [3] Funding Details |
| AK-10 | Contract award and mobilisation status is Unknown in the reviewed records. | Unknown | Not established by sources [1-5] |
| AK-11 | Demand sufficiency for debt service is Unknown in the reviewed records. | Unknown | No demand or debt-service model in sources [1-6] |
| AK-12 | The Board approved a senior loan of up to US$20m, stated as €18.3m equivalent, on 20 September 2023. | Verified | [6] Cover page and Board Decision Sheet |
| AK-13 | The borrower is 100 per cent held by Samruk-Kazyna, which is 100 per cent held by the Republic of Kazakhstan. | Verified | [6] Annex 2, shareholding structure |
| AK-14 | The borrower is under trust management of Kazakhstan Temir Zholy. | Verified | [6] Annex 2 and section 3.1 |
| AK-15 | Integrity due diligence was carried out with OCCO on the company, its shareholder and its manager; the finding is redacted. | Redacted | [6] Section 6.2 |
| AK-16 | The project page states an approval date of 23 July 2025, later than the board report it publishes. | Conflict | [1] Approval Date |
| AK-17 | The three named parties returned no match against a dated snapshot of four public sanctions lists. | Checked 24.08.2026 | Possible-string-match check, not a determination |
What this sample demonstrates
Input
A named project, the decision to support, an audience and a bounded source pack.
Output for human ownership
A decision-specific first draft, financing table, material risk gaps, claim-to-source audit and a short list of documents to obtain next.
This is an illustrative workflow output. It is not a client engagement, an external benchmark or evidence of market adoption. The responsible project professional must verify, revise and sign the deliverable before use.
Sources
- EBRD. Aktau Port Modernisation, Project ID 53786. Project summary last updated 8 October 2025; retrieved 31 July 2026. Primary record for status, facility, cost, scope, grant and E&S information.
- EBRD Client E-Procurement Portal. Aktau Port Modernisation: General Procurement Notice. Published 23 December 2025; retrieved 31 July 2026. Primary record for the earlier funding description, planned packages and stated tax contribution.
- EBRD Client E-Procurement Portal. Aktau Port Modernisation: General Procurement Notice. Published 26 May 2026; retrieved 31 July 2026. Primary record for the later USD funding description and the same three planned packages.
- EBRD Client E-Procurement Portal. Design and Build Works for Aktau Port Berths Reconstruction. Published 4 February 2026; retrieved 31 July 2026. Primary record for the works tender and response deadline.
- EBRD Client E-Procurement Portal. Construction Supervision and Project Implementation Support. Published 14 July 2026; retrieved 31 July 2026. Primary record for the consultancy tender and response deadline.
- EBRD. Aktau Port Modernisation: Board Report (PDF, 25 pages). Approved by the Board of Directors on 20 September 2023; disclosed under the EBRD Directive on Access to Information and partly redacted; retrieved 24 August 2026. Primary record for the approved facility, the shareholding structure in Annex 2, and the integrity due diligence statement in section 6.2.