INDEPENDENT VERDICT
Oceanic Hedge Fund is unusual because its latest Form D should not be read literally as evidence that the fund has no capital. The September 18, 2026 amendment reports an indefinite Rule 506(b) offering, five investors, a $50,000 minimum and a first sale dating to November 1, 2009, yet Item 13 reports $0 as the amount sold. The same zero-dollar / five-investor pattern also appears in recent annual amendments, while the original 2010 Form D reported $295,741,031 sold to 44 investors. At the same time, Oceanic Investment Management Limited reports approximately $332 million of regulatory AUM in its March 2026 Form ADV and continues to file substantial Form 13F portfolios. Those facts make the latest $0 figure a disclosure feature that requires explanation rather than a defensible proxy for fund NAV. FilingDossier therefore treats the current Form D as evidence that the U.S. exempt offering remains active, not as evidence that Oceanic Hedge Fund has zero assets.
THE FUND'S REAL DIFFERENTIATOR IS A PHYSICAL-SHIPPING DATA ENGINE RATHER THAN A GENERIC ENERGY-EQUITY SCREEN
Oceanic describes itself as a shipping and energy specialist with roots extending more than 30 years into shipping, offshore oil and gas management and investment. It says Oceanic Hedge Fund itself was established in 2002 and invests across global equities, commodities, freight and bonds in the maritime and energy sectors. The most distinctive part of the investment process is TRACS, a proprietary vessel-tracking system Oceanic has developed since 2011. TRACS ingests AIS location, speed, heading, destination, draft and timestamp data, combines it with vessel and port databases, and tracks more than 40,000 ships and offshore assets across tankers, dry bulk, LPG, LNG, containers, vehicle carriers, drilling rigs and support vessels. That gives Oceanic a potentially differentiated real-economy information set for estimating shipping activity, seaborne trade, fleet utilization and freight conditions before relying solely on company financial statements.
THE Q2 2026 13F SHOWS THAT THIS SHIPPING DATA IS BEING TRANSLATED INTO A HIGHLY ACTIVE ENERGY-AND-MARITIME EQUITY BOOK
Oceanic Investment Management's June 30, 2026 Form 13F reported roughly $77.93 million of U.S.-reportable securities, down about 34% from roughly $117.96 million at March 31. Its largest disclosed positions included Halliburton at approximately $10.8 million, Genco Shipping & Trading at roughly $10.1 million, Expand Energy around $8.9 million and Antero Resources around $6.9 million. Halliburton was nearly doubled during the quarter, Genco was increased materially and Teekay Tankers — worth approximately $14 million in the prior quarter — was exited completely. This is exactly the type of rotation one would expect from a strategy that tries to express changing freight, energy-cycle and commodity views through listed securities. But the 13F remains only one window into the strategy: Oceanic's official mandate also includes commodities, freight and bonds, none of which is fully captured by Form 13F.
THE HISTORICAL FORM D RECORD CREATES A RARE CAPITAL-DISCLOSURE DISCONTINUITY
Oceanic's first U.S. Form D in September 2010 reported approximately $295.74 million sold to 44 investors from an indefinite offering, with the U.S. first sale dated November 1, 2009. More recent amendments, however, report five investors and $0 sold rather than carrying forward that historic cumulative amount. Because the issuer CIK remains 0001501332, the legal issuer name remains Oceanic Hedge Fund and the investment manager remains Oceanic Investment Management Limited, this is not a simple case of an entirely different new fund replacing the old one. Nor does a $0 figure reconcile naturally with five current investors, $332 million of adviser RAUM and continuing investment activity. Investors and researchers should therefore avoid calculating fundraising growth from this Form D series without obtaining the offering records or manager explanation for how Item 13 is now being populated.
THE MANAGER HAS DUAL REGULATORY EVIDENCE IN THE UNITED STATES AND ISLE OF MAN
Oceanic Investment Management Limited is registered with the SEC under CRD 160287 and SEC file 801-73687, with U.S. adviser registration effective March 23, 2012. Its current March 2026 Form ADV reports approximately $332 million of regulatory AUM across five client accounts and directly confirms Oceanic Hedge Fund as a private-fund relationship. Separately, Oceanic's official website states that the investment manager is registered in the Isle of Man under company number 019211V and licensed by the Isle of Man Financial Services Authority to conduct investment business. These are two distinct regulatory layers: Isle of Man authorization governs its local investment-management business, while SEC registration establishes its U.S. adviser status. Neither should be described as governmental approval of the fund's investment performance.
THE STRATEGY IS ALSO MORE COMPLEX THAN SIMPLY BUYING SHIPPING STOCKS
Oceanic says its shipping process combines cyclical valuation with the impact of tightening environmental standards. That matters because emissions rules can change vessel economics through fuel costs, retrofit requirements, operating speeds, scrapping decisions and effective fleet supply. In energy, the manager says it looks for long/short opportunities in upstream energy from both structural and cyclical perspectives, focusing on companies with strong technological and market positions. TRACS can then provide a separate physical-data layer: vessel movements and offshore activity may help test whether management commentary about demand, exports, inventories or drilling activity is consistent with observable shipping flows. This interaction between bottom-up securities analysis and proprietary physical-market data is the clearest differentiator from a conventional energy long/short hedge fund.
FINAL ASSESSMENT
Oceanic Hedge Fund has an unusually differentiated evidence set: it dates back to 2002 at the sponsor level and has a U.S. first sale dating to 2009; its original Form D reported $295.74 million sold to 44 investors; the latest Form D instead reports $0 sold despite five investors; Oceanic Investment Management is a fully SEC-registered adviser with approximately $332 million of 2026 regulatory AUM; it is also licensed by the Isle of Man Financial Services Authority; its official strategy spans shipping, energy, freight, commodities and bonds; TRACS tracks more than 40,000 vessels; and its latest 13F shows active rotation among Halliburton, Genco, Expand Energy, Antero and other cyclical names. The central diligence question is therefore not whether Oceanic has a real investment operation — the regulatory filings, proprietary data system and active securities portfolio make that clear. The unresolved question is how the current fund capital structure maps onto a Form D that now reports zero dollars sold.
SEC SNAPSHOT
Issuer: Oceanic Hedge Fund CIK: 0001501332 SEC Form: Form D/A Accession No.: 0000902664-26-003872 File No.: 021-147903 Filing Date: September 18, 2026 Jurisdiction: Cayman Islands Principal Address: c/o Oceanic Hedge Fund, Ugland House, P.O. Box 309, Grand Cayman, Cayman Islands KY1-1104 Telephone: 44-1624-643155 Industry: Pooled Investment Fund Fund Classification: Hedge Fund Investment Company Registered: No Investment Company Act Exclusion: Section 3(c)(7) Offering Exemption: Rule 506(b) Security Type: Pooled Investment Fund Interests Offering Amount: Indefinite Amount Sold: $0 Investors: 5 Minimum Investment: $50,000 First Sale: November 1, 2009 Offering Duration Over One Year: Yes Business Combination Transaction: No Sales Commissions: $0 Finder's Fees: $0 Management Fee Exists: Yes Exact Management Fee in Form D: Not disclosed Investment Manager: Oceanic Investment Management Limited Signer: Anthony Haynes Signer Title: Authorized Signatory
FORM D HISTORY PENETRATION
Original September 2010 Filing: Offering Amount: Indefinite Amount Sold: $295,741,031 Investors: 44 Minimum Investment: Historical terms should be checked against contemporaneous filing First U.S. Sale: November 1, 2009
2022 Amendment: Current filing series continued Investors: 5
2023 Amendment: Investors: 5
2024 Amendment: Investors: 5
2025 Amendment: Amount Sold: $0 Investors: 5
2026 Amendment: Amount Sold: $0 Investors: 5
Same CIK Since Original Filing: YES
Same Issuer Name: YES
Same General Investment Manager: YES
2010 $295.74M Automatically Represents Current NAV: NO
2026 $0 Automatically Means Current Fund Assets Are Zero: NO
Reporting Discontinuity Requires Explanation: YES
MANAGER / REGULATORY PENETRATION
Investment Adviser: Oceanic Investment Management Limited
CRD: 160287
SEC File No.: 801-73687
SEC Registration Effective: March 23, 2012
Latest Reviewed ADV Filing: March 30, 2026
2026 Regulatory AUM: Approximately $332 million
Client Accounts: 5
Oceanic Hedge Fund Confirmed as Adviser Private-Fund Relationship: YES
Principal Office: St. George's Court Upper Church Street Douglas Isle of Man IM1 1EE
Isle of Man Company Number: 019211V
Licensed by Isle of Man Financial Services Authority: YES
License Scope Stated by Manager: Investment Business
SEC Registration and Isle of Man License Are the Same Regulatory Regime: NO
STRATEGY / RESEARCH PENETRATION
Official Strategy Focus: Shipping Energy
Asset Classes: Global equities Commodities Freight Bonds
Approach: Long/short Cyclical Bottom-up valuation Structural industry analysis
Shipping Research Inputs: Fleet supply Freight conditions Environmental regulation Vessel operating economics Port and shipping flows
Energy Research Inputs: Upstream energy Technology positioning Market positioning Structural cycle Commodity cycle
TRACS PENETRATION
System: TRACS
Development Began: 2011
Years of Data: More than a decade
Data Source: AIS vessel transmissions Vessel databases Port databases Predictive analytics
Update Frequency Described by Oceanic: Hourly
Assets Tracked: 40,000+
Tracked Categories: Tankers Dry bulk vessels LPG carriers LNG carriers Container vessels Vehicle carriers Offshore drilling rigs Offshore support vessels
AIS Variables Include: Location Speed Direction Destination Draft Timestamp
Potential Investment Uses: Fleet utilization analysis Trade-flow estimation Freight-cycle analysis Port congestion analysis Commodity-flow monitoring Short-term equity positioning Freight forward agreement positioning
TRACS Guarantees Investment Alpha: NO
13F PENETRATION
Reporting Manager: Oceanic Investment Management LTD
CIK: 0001438258
13F File No.: 028-13625
Q2 2026 Reporting Date: June 30, 2026
Q2 Filing Date: August 13, 2026
Q2 Reported Value: Approximately $77.93 million
Q2 Reported Positions: Approximately 27
Q1 2026 Reported Value: Approximately $117.96 million
Quarter-over-Quarter Change: Approximately -34%
Selected Q2 2026 Holdings:
Halliburton: Approximately $10.8 million Portfolio Weight: Approximately 13.9% Quarterly Change: Position materially increased
Genco Shipping & Trading: Approximately $10.1 million Portfolio Weight: Approximately 13.0% Quarterly Change: Position increased
Expand Energy: Approximately $8.9 million Portfolio Weight: Approximately 11.5% Quarterly Change: Reduced
Antero Resources: Approximately $6.9 million Portfolio Weight: Approximately 8.9% Quarterly Change: Reduced
Teekay Tankers: Q1 2026 Value: Approximately $14.0 million Q2 2026 Position: Exited
New Q2 Positions: 13 reported by third-party 13F analysis
Exited Q2 Positions: Approximately 30 reported by third-party analysis
13F Equals Full Hedge-Fund Portfolio: NO
13F Includes Freight Forward Agreements: NO
13F Includes Physical Commodities: NO
13F Includes All Bonds: NO
13F Includes Complete Short Book: NO
CAPITAL METRIC SEPARATION
Latest Oceanic Hedge Fund Form D Amount Sold: $0
Original 2010 Form D Amount Sold: $295.74M
Oceanic Investment Management 2026 Regulatory AUM: Approximately $332M
Q2 2026 U.S. 13F Value: Approximately $77.93M
These Figures Measure the Same Thing: NO
Form D: Issuer-level exempt-offering disclosure
ADV RAUM: Adviser-wide regulatory assets
13F: Specified reportable securities only
Historic Form D: Past cumulative U.S. offering sales, not current NAV
Simple Addition: Not appropriate
GOVERNANCE PENETRATION
Current Fund Director: Philip Dickie
Current Related Executive: Alf Cato Brahde
Investment Manager Executive: Anthony David Haynes
Additional Investment Manager Executive: Cassandra David Powell
Investment Manager Listed as Promoter: YES
Earlier Fund Directors Included: David Luu William Walmsley Andreas O. Ugland in older filing history
Governance Has Changed Over Long Fund Life: YES
That Alone Establishes Manager Change: NO
RELATED FUND / PLATFORM PENETRATION
Confirmed Adviser Relationship: Oceanic Hedge Fund
Other Historically Associated Oceanic Vehicles Include: Oceanic Opportunities Fund Ltd Oceanic Opportunities Master Fund, L.P.
Current Form ADV Confirmation for Those Additional Vehicles: Not independently established from reviewed sources
Therefore: Do not aggregate them into Oceanic Hedge Fund without current manager documentation.
HISTORICAL OPERATING DEPTH
Oceanic Investment Group Roots: More than 30 years according to official site
Oceanic Hedge Fund Founded: 2002 according to official site
U.S. First Sale: 2009
TRACS Developed Since: 2011
SEC Adviser Registration: 2012
Current 13F Reporting: Active in 2026
Long Operating Continuity: Strongly supported
WEBSITE / ENTITY PENETRATION
Official Website: oceanicim.com
Official Shipping / Energy Strategy Confirmed: YES
Official TRACS System Confirmed: YES
SEC Adviser Registration Confirmed: YES
CRD 160287 Confirmed: YES
SEC 801-73687 Confirmed: YES
Isle of Man Investment-Business License Confirmed by Official Manager Disclosure: YES
Oceanic Hedge Fund SEC Issuer Confirmed: YES
Q2 2026 13F Confirmed: YES
Current Fund NAV Publicly Confirmed: NO
Complete Long Book Publicly Confirmed: NO
Complete Short Book Publicly Confirmed: NO
Commodity Positions Publicly Confirmed: NO
Freight Forward Agreement Positions Publicly Confirmed: NO
Bond Portfolio Publicly Confirmed: NO
Current Auditor Independently Confirmed: NO
Current Administrator Independently Confirmed: NO
Prime Broker Independently Confirmed: NO
Custodian Independently Confirmed: NO
CORE INVESTOR QUESTIONS
Why does the 2026 Form D report $0 sold despite five investors Why did the original 2010 Form D report $295.74 million sold Did Oceanic change the basis on which Item 13 is reported What is the current NAV of Oceanic Hedge Fund How much of Oceanic Investment Management's approximately $332 million RAUM belongs to Oceanic Hedge Fund What other client accounts make up the adviser's five reported accounts What is current gross long exposure What is current gross short exposure How much capital is allocated to equities How much is allocated to freight derivatives How much is allocated to commodities How much is allocated to bonds Does Oceanic trade FFAs directly What leverage is permitted What is the maximum single-name equity exposure How is TRACS data converted into trade signals How is AIS spoofing or missing vessel data handled How are environmental regulations incorporated into vessel valuations How does Oceanic stress-test cyclical shipping downturns What management fee applies What performance fee applies What liquidity and redemption terms apply Can redemptions be gated or suspended Who is the current administrator Who is the current auditor Who are the current prime brokers and derivatives counterparties What explains the Q2 2026 reduction in the 13F book from approximately $118 million to $78 million How much of that change reflects sales versus price movements or capital reallocation into non-13F instruments
PRIMARY EVIDENCE REVIEWED
SEC Form D/A for Oceanic Hedge Fund filed September 18, 2026. Original SEC Form D for Oceanic Hedge Fund filed September 17, 2010. Historical Form D amendments from 2022 through 2025 used to identify the persistent five-investor / zero-dollar reporting pattern. SEC Investment Adviser Public Disclosure record for Oceanic Investment Management Limited, CRD 160287 / SEC 801-73687. Oceanic Investment Management March 30, 2026 Form ADV-derived regulatory data. Oceanic Investment Management official website. Oceanic official Shipping and Energy investment-philosophy materials. Oceanic official TRACS vessel-tracking description. SEC Form 13F-HR for Oceanic Investment Management for quarter ended June 30, 2026. SEC Form 13F-HR for quarter ended March 31, 2026 used to analyze portfolio rotation. Isle of Man regulatory / corporate disclosures and Oceanic's official license statement used to cross-check the manager's local regulatory status.
IMPORTANT FORM D NOTICE
Oceanic Hedge Fund's September 18, 2026 Form D/A reports $0 sold while simultaneously reporting five investors and a first sale dating to November 1, 2009. The original 2010 Form D reported $295,741,031 sold to 44 investors, while Oceanic Investment Management's latest available 2026 adviser data reports approximately $332 million of regulatory AUM. These records clearly should not be interpreted as interchangeable measures of current fund size. The latest $0 Form D figure may reflect the way the issuer now completes Item 13, but the public filing does not explain the change, so FilingDossier does not substitute a guessed current fundraising number. Form D, SEC adviser registration, Form 13F reporting and Isle of Man licensing are regulatory disclosures and do not constitute SEC, Isle of Man FSA or other governmental approval of Oceanic Hedge Fund or its investment strategy.