Frozen Yachts & Sanctions: The 2025 Assessment

Four years have passed since the wave of asset freezes launched in March 2022. The year 2025 finally marked a shift in the situation of yachts frozen under international sanctions.

While European policy in this area still clearly lacks harmonisation, asset-management strategy and defined exit pathways, it nevertheless reflects a level of firmness with which the yachting industry must now contend.

I. Structuring judicial decisions: when courts dispel the offshore fog

The years 2024–2025 marked a far more assertive turn in the judicial treatment of yachts linked to international sanctions. Courts no longer confine their analysis to formal ownership or the apparent nationality of holding entities. They now focus on three core criteria:

• the effective control of the yacht,

• its actual use,

• and its economic and symbolic function.

  
  

United States – M/Y Amadea

The Amadea case is the most emblematic illustration of this shift. After three years of litigation, U.S. courts held that the yacht was controlled, through an intermediary structure, by a twice-sanctioned oligarch. Judicial recognition of the nominee arrangement opened the way to forfeiture (March 2025), followed by a public auction in autumn 2025 - the first such sale in the United States in the context of Russia-related sanctions.

United Kingdom – M/Y Phi

The decision handed down in July 2025 by the UK Supreme Court goes even further. Although the yacht’s beneficial owner had never been personally designated under sanctions, the detention was held to be lawful. The Court adopted an unprecedented line of reasoning: the yacht’s charter income and the prestige attached to it were deemed likely to objectively strengthen the position of its beneficiary within the Russian elite.

The asset thus becomes sanctionable not for what it is in legal terms, but for what it produces economically and symbolically. This ruling draws a clear line: under UK law, it is lawful to detain a superyacht connected to Russia, even where its beneficial owner is not personally designated. It sets a powerful precedent, revealing a British doctrine that is broader, more assertive, and now Supreme Court-endorsed - increasingly at odds with the more cautious European approach.

Finland – Divina Barbara

The Finnish decision relating to Divina Barbara confirms a parallel evolution on the European side. The court rejected a third party’s ownership claim due to the absence of proof of effective control. The nominee-owner theory was upheld, paving the way for formal confiscation of the yacht.

Key takeaway

Legal ownership is no longer a shield. Effective control, use and purpose of the yacht have become central to judicial assessment.

• Offshore structures that appear “clean on paper” no longer persuade courts.

• The substance over form doctrine prevails: who controls? who uses? who truly benefits?

• Resorting to a nominee owner is no longer sufficient to block - or reverse - a seizure process.

  
  

For owners, managers and authorities across Europe, the implications are significant: sanctions enforcement is no longer based solely on names appearing on lists, but on analysis of networks, plausible influence, and the real appearance of asset ownership.

II. Maintain or let deteriorate: maintenance as a legal act

Another clear fault line has emerged in cases involving frozen yachts: maintenance. In practice, maintenance - or the lack thereof - now produces major legal, economic and environmental consequences.

Yachts under active (minimum) management

Yachts such as Crescent, Amore Vero, S/Y A or Royal Romance are subject to active management despite being immobilised.

Practices vary between States:

• in France and Spain, maintenance costs remain borne by the sanctioned owner.

• in Italy, maintenance appears to be funded by the State, although no clear official communication has been issued.

• in Trieste, the mayor publicly denounced the annual maintenance cost of S/Y A (around €18 million per year), compared with the city’s difficulty in funding local public infrastructure projects.

• in Croatia, Royal Romance is supervised by Ukraine’s ARMA agency and underwent maintenance works in June 2025.

  
  

In these cases, asset value is broadly preserved, future options remain open (sale, restitution, transfer), and technical and environmental risks are contained.

Yachts left without maintenance

Conversely, other yachts illustrate the consequences of passive immobilisation. Phi has lost insurance and class status, while Luminosity is visibly deteriorating at berth, with crew reduced to the bare minimum.

Lack of maintenance leads to rapid destruction of value, increases pollution risks and complicates any future legal resolution.

Key takeaway

Failing to maintain a frozen yacht is not neutral. The absence of a maintenance strategy has - and will have - serious consequences, both for the asset and for the authorities responsible for it.

III. The long shadow of the United States: asserted extraterritorial reach

Even when physically immobilised in Europe, many yachts remain exposed to the decisive influence of the United States. The case of Tango, the first seizure initiated under U.S. impetus, illustrates this reality: although forfeiture has not yet been pronounced, the case remains under close scrutiny.

Royal Romance further illustrates the complexity of cross-border asset management involving Ukraine, Croatia and, in the background, U.S. authorities.

For professionals, one reality is now unavoidable: OFAC sanctions weigh on the entire sector, well beyond U.S. borders.

IV. Assets under surveillance: when movement becomes a criminal risk

Since 2024, authorities no longer limit their analysis to ownership or maintenance. They now closely monitor movements, particularly around the timing of sanctions announcements.

The case of M/Y Mrs L is revealing. Its abrupt departure from Cannes on 11 December 2025, followed by arrival in Tunisia just days before its owner’s designation, was interpreted as an attempt to anticipate asset freezing. The yacht itself was not sanctioned, but remains under close surveillance.

Key takeaway

Responsibility no longer stops with the owner or manager. Captains and technical operators may now face personal exposure, particularly in cases of characterised sanctions circumvention.

V. Compliance becomes a condition of market access

All of these developments have profoundly reshaped industry practices. In 2025, compliance is no longer a purely banking or transactional matter: it now structures the entire yachting value chain, including upstream project development.

Know Your Customer (KYC) checks and sanctions-related due diligence are becoming operational prerequisites, including for newbuild projects. Several major custom shipyards - including Lürssen - have strengthened their internal procedures, conditioning client onboarding or project continuation on identification of the ultimate beneficial owner, ownership-structure analysis and sanctions exposure.

This shift reflects a collective realisation: continuing a project later impacted by sanctions now exposes shipyards, managers and service providers to major legal and reputational risks. Offshore structures, nominee arrangements and corporate screens no longer provide protection.

Key takeaway

Compliance is no longer peripheral. It has become a condition of market access.

For yachting professionals, not knowing — or not wanting to know — is simply no longer an option.

Conclusion

Between 2024 and 2025, a line was crossed.Frozen yachts under sanctions are no longer “assets on hold”, but active legal objects, scrutinised, arbitrated and sometimes sacrificed.

Recent decisions reveal a clear convergence:

• formal ownership is receding, substance prevails.

• inaction costs more than action.

• and lack of compliance is no longer tolerated as a grey zone.

  
  

In this new landscape, every decision - to maintain, move, fund, refuse or cooperate - produces measurable legal consequences. Managing a frozen yacht is no longer neutral. It entails responsibility.

For yachting professionals, the framework is now set: risk no longer arises solely at the moment sanctions are imposed, but much earlier, in the way assets are structured, managed and assumed.

Those who have understood this are already adapting their practices. Others are discovering - sometimes too late - that the offshore fog has definitively lifted.

Contact

Emmanuelle VOTAT – Judicial Yacht Asset Manager (France) - Specialist in Seized Maritime Assets ev@yachting-legal-auction.com

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This article is based on publicly available facts, verifiable data, and an independent legal and strategic analysis. It does not, under any circumstances, constitute a definitive statement regarding the guilt or innocence of the individuals or legal entities mentioned, but rather forms part of a general-interest reflection on the management of frozen or seized assets in a complex geopolitical context. Any correction or right of reply may be submitted through the appropriate official channels and will be given due consideration. The author acts in full independence and in compliance with the right to information and the duty of professional restraint.