**Exhibit 14**

 

**CODE OF ETHICS FOR THE CHIEF EXECUTIVE OFFICER,CHIEF FINANCIAL OFFICER AND CHIEF ACCOUNTING OFFICER**

 

ThisCode of Ethics for the Chief Executive Officer, the Chief Financial Officer andthe Chief Accounting Officer (this “Code of Ethics”) governs the conduct of theChief Executive Officer, the Chief Financial Officer and the Chief AccountingOfficer of Transmeridian Exploration, Inc. (the “Company”). This Code of Ethicsis designed to deter wrongdoing and to promote ethical and legal behavior bythe Company’s Chief Executive Officer, the Chief Financial Officer and theChief Accounting Officer.

 

TheChief Executive Officer, the Chief Financial Officer and the Chief AccountingOfficer are responsible for:

 

a)Acting with honesty and integrity, and avoiding actual or apparent conflicts ofinterest involving personal and professional relationships. A “conflict ofinterest” exists when an individual’s private interests interfere or conflictin any way (or even appear to interfere or conflict) with the interests of theCompany;

 

b)Ensuring that the Company’s disclosure controls and procedures functionproperly and providing information that is full, fair, accurate, timely, andunderstandable for Securities and Exchange Commission filings and in other publiccommunications made by the Company;

 

c)Complying with applicable laws, rules, and regulations of all U.S. and non-U.S.governmental entities, as well as other private and public regulatory agenciesto which the Company is subject;

 

d)Acting in good faith and, responsibly with due care, competence and diligence,without misrepresenting material facts or allowing independent judgment toviolate this Code of Ethics; and

 

e)Reporting illegal or unethical conduct by a director, officer or employee thathas occurred, is occurring or may occur, including any potential violations ofthis Code of Ethics.

 

Violationsof this Code of Ethics shall be reported to the Chairman of the Audit Committeeof the Board of Directors whether the violations are of a financial ornon-financial nature. The waiver of any duty or responsibility set forth inthis Code of Ethics must be made by the Board of Directors of the Company. ThisCode of Ethics will be an Exhibit to Form 10-K for the year ended December 31,2004, and posted to the Company website.

 

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Acknowledgment

 

Thisis to acknowledge receipt of the Code of Ethics for the Chief ExecutiveOfficer, the Chief Financial Officer and the Chief Accounting Officer. Iunderstand that failure to adhere to the principles and responsibilities setforth in this Code of Ethics may result in disciplinary action, includingreprimand, warnings, suspension, demotion, salary reduction, restitution and/ordischarge, as well as possible legal penalties.

 
| Name:  Lorrie T. Olivier  |
|---------------------------|
| Chief  Executive Officer  |
|                      |
|                      |
| Signature:                | /s/:  Lorrie T. Olivier |   |
| Date:  March 14, 2005     |
|                      |
| Name:  Earl W. McNiel     |
| Vice  President           |
| Chief  Financial Officer  |
|                      |
|                      |
| Signature:                | /s/:  Earl W. McNiel |   |
| Date:  March 14, 2005     |
|                      |
|                      |
| Name:  Charles J. Campise |
| Chief  Accounting Officer |
|                      |
|                      |
| Signature:                | /s/:  Charles J. Campise |   |
| Date:  March 14, 2005     |

 

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