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Published in SuperYachtNews 14 Apr 2026 Public auction may satisfy transparency requirements, but will it work for a sanctioned yacht? Emmanuelle Votat explores… Emmanuelle Votat is a judicial auctioneer specialising in the management and sale of yachts seized in criminal proceedings. She is the founder of a pioneering programme for judicial yacht asset management in France and has overseen landmark cases, including the sale of Stefania , which was confiscated in a major money laundering investigation . After several years of deadlock and two failed attempts, the 92-metre Feadship superyacht Royal Romance is finally preparing for sale. Ukraine’s Asset Recovery and Management Agency (ARMA) has confirmed that it is working on the vessel’s valuation and defining a sale model, pending a decision from a Croatian judge. On the surface, the process appears to be moving forward. In reality, it remains structurally ill-suited, at this stage, to deliver a legally secure and operationally executable sale. A sale still suspended by a fragile judicial balance  The Royal Romance case illustrates a configuration that has now become typical in sanctioned yacht matters: overlapping jurisdictions with no true central authority. Ukraine, through criminal proceedings and the initial seizure decision; Croatia, through territorial jurisdiction and judicial control; and the European Union, through its sanctions regime; each produce autonomous legal effects without real coordination. The turning point came in May 2022, when asset management was transferred to ARMA. Since then, the agency has held a mandate for both preservation and sale. However, this mandate remains conditional upon Croatian judicial approval, in a context where no final criminal confiscation has yet been issued. This dependency has already led to two failures. The process initiated with Troostwijk Auctions in 2024 was abandoned due to a lack of operational structuring and timeline control. A second attempt, led the same year by Boathouse Auctions, validated by ARMA, was ultimately cancelled by the Croatian court due to the absence of a formally recognised criminal indictment. Even today, ARMA refers to “increased procedural resistance” from representatives of the beneficial owner, relying on appeals, procedural incidents and delaying strategies typical of such cases. The case is legally advanced, but it remains fundamentally unsecured and therefore unsellable under acceptable conditions. The persistent reflex of public auction  In this context, ARMA is considering a “transparent sales procedure through public mechanisms”. In practice, this points to a public auction model. While this approach meets transparency requirements, it reveals a structural mismatch between the tool and the asset. Royal Romance concentrates a set of constraints rarely seen together: a sanctioned asset, prolonged immobilisation in a foreign jurisdiction, the absence of a legally “clean” title at the time of sale, exposure to post-sale litigation, significant technical constraints (maintenance, class, crew, insurance) and annual holding costs estimated at around €20 million. At this stage, one may legitimately question whether such an approach is suited to an asset of this nature. In such a context, a public auction addresses only one variable: competition. It does not address the elements that determine the success of such a transaction, including the security of title transfer, the selection of buyers capable of meeting compliance and operational requirements, post-sale risk management, and the preservation of value within a narrow and highly specialised market. Transparency alone is not sufficient. In complex sanctioned asset cases, it can become a factor of fragility when not paired with effective control. A structural fragmentation of processes  The challenges observed in the Royal Romance case reflect a deeper fragmentation in the handling of multifaceted maritime assets. The case currently unfolds across overlapping frameworks: criminal in Ukraine, judicial in Croatia, regulatory at the European Union level, and operational through ARMA. These frameworks are neither hierarchical nor synchronised, which significantly limits the likelihood of an efficient outcome. The result is now evident: nearly two years of operational inertia, during which the asset’s value erodes, technical risks accumulate (corrosion, systems degradation, potential class issues), costs increase and the vessel progressively disconnects from its market. Amore Mio: the other side of the problem  At the same time, ARMA is working to locate a second yacht linked to the same economic environment: Amore Mio . Available elements suggest a recent delivery in 2023, registration under the Palau flag, a Russian customs entry in July 2023, links to Renaissance JSC, and an estimated value of $9.6 million. Unlike Royal Romance , this vessel does not suffer from excessive legal structuring, but from a lack of visibility. Its inclusion in Interpol’s stolen vessels database marks a turning point, enabling coordinated international monitoring. ARMA has confirmed it engaged Interpol, Europol and the International Maritime Organization to establish the vessel's whereabouts and, as of the time of writing, its location remains unknown. This case highlights another operational reality: assets can disappear within jurisdictional gaps and can only be tracked through specialised investigations capable of reconstructing their trajectories. Sanctions circumvention is now organised. In response, a new category of actors is emerging, those capable of tracing, documenting and controlling these flows. A full-scale stress test for European states  The Royal Romance case now goes far beyond a single vessel and instead represents a full-scale stress test of the current limits of European systems. States have strengthened their ability to identify assets, cooperate internationally and impose freezing measures. However, the disposal phase remains largely under-equipped, and often underestimated. There is still no sales engineering capable of handling assets of this level of complexity. The sale of Amadea demonstrated that such transactions are possible, but it has not yet established a replicable standard. In the case of Royal Romance, the issue is no longer seizure. It is the transformation of the asset into value. And that transformation requires sophisticated legal engineering, adapted sales structuring (off-market processes, targeted tenders, hybrid models), alignment with international standards, and an environment capable of absorbing residual risk. After four years of freeze, this is no longer about selling. It is about restoring marketability. Europe is at a turning point Beyond the Royal Romance case, the issue is now European. Directive (EU) 2024/1260 sets a clear timeline: by November 2026, Member States must establish reinforced structures capable not only of freezing assets but also of managing and disposing of them. The shift is underway. But it comes after several years of large-scale asset freezes, without the parallel development of appropriate disposal tools. The result is now observable: a growing stock of immobilised assets, sometimes held for over four years, steadily losing value. The framework exists, but it remains largely administrative. Assets such as yachts fall outside this logic. They require continuous technical management, a transnational legal approach, and sales models capable of integrating uncertainty and complexity. Creating structures will not be enough. A true doctrine of sale must emerge. The Royal Romance case is currently the most visible illustration of this gap. The process is moving forward, but cautiously. And in a market as demanding as yachting, error carries systemic consequences: a poorly executed sale today undermines the credibility of those that follow. Europe is entering a new phase. A phase where seizing assets is no longer enough. And where credibility will be measured by the ability to convert them into value, effectively, legally and operationally. Any views, thoughts and opinions expressed here are those of the author and are not intended to malign any particular individual or organisation and may not reflect the views, opinions, policies or positions of The Superyacht Group.  As an open-access platform, we offer an industry-wide invitation to anyone and everyone in our sector to share their knowledge, experience and opinions. So if you have an interesting and valuable contribution to make, and would like to join our growing community of guest columnists, share your ideas with us at newsdesk@thesuperyachtgroup.com

Meridian A: how frozen yachts expose the limits of EU sanctions Moored in Barcelona for over three years, the superyacht Meridian A sits in silence — a silence that reflects the ongoing tension between sanctions enforcement and the resilience of offshore financial structures. Google Earth, November 12, 2025 A yacht at the crossroads of investigations The yacht has been described in public investigations, notably by OCCRP, as being linked - at the time of earlier documented ownership structures - to Anastasia Ignatova , a Russian-language professor and daughter-in-law of Sergey Chemezov , head of the state-owned conglomerate Rostec, supplier of approximately 80% of Russia’s weaponry. (Source: OCCRP) More recent court proceedings, as reflected in The Kyiv Independent, indicate that she is likely no longer the formal owner of the vessel. Beyond this initial attribution, the investigation conducted by Alisa Yurchenko ( The Kyiv Independent, October 2025 ) focuses primarily on Sergey Chemezov and the network of relationships surrounding him. It describes what may be understood as a broader pattern: nominee ownership, offshore layering, and legal strategies deployed across jurisdictions. From KGB-era networks to offshore opacity The Kyiv Independent investigation refers to the yacht’s “alleged connection to Sergei Chemezov”, noting that the asset is “linked to” him and that he “may have actually controlled” it. Sergey Chemezov, a long-time associate of Vladimir Putin since their KGB years, has been subject to U.S. and EU sanctions since 2014, later extended to members of his family. At the time reflected in earlier investigations, the yacht was registered in the name of Anastasia Ignatova, “whose profession as a Russian-language teacher did not suggest that she had the means to purchase a $140 million yacht.”  (Source: OCCRP) Her university salary was estimated at approximately $2,200 per month. Behind this apparent discrepancy, OCCRP identified a layered offshore structure involving British Virgin Islands entities, including Sightview Consultants Ltd and Linkpoint Services Ltd, both revealed in the Panama Papers. (Source: OCCRP) Successive nominees Before Ignatova, the yacht - then named Valerie - was associated with Borys Kogan , an Odessa-based businessman involved in arms logistics. Following his death in 2017, Spanish tax records reportedly indicated a transfer of ownership to Chemezov’s daughter-in-law. (Source: The Kyiv Independent) The pattern that emerges is not unusual in such cases: one asset, multiple formal holders, and a continuity that remains structurally opaque. A backdated transaction? In 2021, Russian billionaire Albert Avdolyan appeared in connection with the yacht. Madrid judges reportedly identified inconsistencies between: a sale contract dated 2021 a bank transfer dated 2022 and documentation relating to beneficial ownership issued after sanctions were imposed Spanish authorities highlighted what they described as a “striking time gap” between these elements. According to the elements identified in the proceedings and as reported in public investigations, Avdolyan - a Russian businessman with major interests in the energy sector (coal and LNG), listed by Forbes - has been described as having business links to entities connected to Rostec. In this context, Spanish authorities reportedly questioned whether the transaction could reflect a “simulated sale” . The proceedings on this matter remain subject to judicial review. In February 2025, Avdolyan was added to the EU sanctions list. According to publicly available data from Equasis (IMO 1010624) , the yacht has been registered since January 2019 under Sulberg Services Ltd, a British Virgin Islands entity acting as both registered owner and commercial manager. However, such registries reflect formal ownership and management structures and do not, in themselves, determine the identity of the ultimate beneficial owner. In practice, judicial asset management and disposal processes require a systematic analysis of beneficial ownership, control, and source of funds - as formal registries alone are insufficient to assess legal risk, enforceability, or transferability. Legal offensives and parallel strategies From 2022 onward, legal challenges were initiated: in Spain, seeking to lift the seizure before the Court of Justice of the European Union, seeking removal from sanctions lists According to the investigation, these actions contributed to revealing further details regarding the ownership structure. Simultaneously, Chemezov reportedly engaged U.S. lobbying firms - Rathmell Short LLP and Stryk Global Diplomacy - for $2.6 million under FARA disclosures, funded via a Dubai-based entity (Yudisud Tjong Trading LLC). (Source: U.S. FARA filings) The objective appears twofold: testing legal pathways in more flexible jurisdictions potentially creating precedents usable in Europe Circumvent to contend As noted by Anastassia Fedyk (UC Berkeley): “There are several reasons why individuals like Chemezov may seek to lift sanctions in the U.S., even if most of their frozen assets are in Europe.” She adds: “If they believe the U.S. administration is currently more inclined to lift certain restrictions, they may later use it as a precedent to challenge EU sanctions.” To date, no confirmed easing of sanctions has been recorded. However, the proceedings have revealed additional layers of ownership and structuring. European freeze, legal paralysis Spanish authorities have pointed out a structural limitation: Circumventing sanctions is not, in itself, a criminal offense under Spanish law. This leads to a critical distinction: Freeze = asset immobilisation without transfer of ownership Confiscation = legal transfer enabling disposal The Meridian A case thus illustrates a systemic gap in European enforcement. By contrast, the United States - through the KleptoCapture Task Force - has seized assets such as M/Y Tango (linked to Viktor Vekselberg), although forfeiture remains ongoing. (Source: U.S. Department of Justice, April 4, 2022) Learning from Italy: reversing the burden of proof Where beneficial ownership dissolves into offshore opacity, traditional evidentiary frameworks reach their limits. The Italian Rognoni–La Torre law (Law No. 646/1982), now integrated into the Anti-Mafia Code (D.Lgs. 159/2011), provides an alternative: confiscation based on disproportionality between assets and declared income potential reversal of the burden of proof Strictly supervised by the judiciary, this mechanism allows intervention without waiting for a criminal conviction . Adapted at the European level, it could offer a decisive tool against concealed ownership structures. Why this case matters The Meridian A case highlights structural realities: nominee ownership remains central to sanctions evasion legal fragmentation weakens enforcement asset freezes often fail to produce operational outcomes As described by The Kyiv Independent, this creates a “legal fog of sanctions” : immobilized assets rising maintenance costs progressive loss of value What comes next The investigation by Alisa Yurchenko sheds light on the complexity of Russian asset structuring and the limitations of current frameworks. It confirms a simple truth: A yacht is never just a yacht. It is a financial vehicle, a legal construct, and sometimes a strategic instrument. France is now exploring structured approaches to the management and disposal of frozen maritime assets - combining legal rigor with operational efficiency. As long as ownership remains legally intact, enforcement remains structurally incomplete. In Short Freeze without confiscation is not enforcement. It is immobilisation without resolution. Contact Emmanuelle VOTAT - Judicial Yacht Asset Manager (France) - Specialist in Seized Maritime Assets –  ev@yachting-legal-auction.com Frozen Yachts & Sanctions : Read the article in the Kyiv Independent October 7, 2025 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.

The M/Y Alfa Nero case sharply illustrates the persistent fragilities in the management and disposal of seized superyachts in a sanctions context. An ongoing dispute Latest development: the daughter of Andrey Guryev, a sanctioned Russian oligarch also associated with M/Y Luminosity, has brought proceedings before U.S. courts seeking financial documents related to the sale of the yacht by Antigua and Barbuda, which she challenges. She alleges that the sale was tainted by fraud and corruption and seeks to support parallel proceedings abroad. In response, the Antiguan authorities maintain a clear position: the dispute does not concern the sale, but the legality of the initial seizure. Two opposing interpretations are at play. And the dispute is now spreading across multiple jurisdictions. Background: a seizure rooted in Russian sanctions Alfa Nero, an 81-meter seized superyacht, was linked to Andrey Guryev, targeted by international sanctions following the invasion of Ukraine in February 2022. In this context: the yacht was immobilised in Antigua and Barbuda, local authorities initiated proceedings under domestic law, the vessel was subsequently removed from the sanctions list to allow its sale. This step is critical: it marks the transition from a freezing regime to an asset liquidation approach. In 2023, a sale was organised through an international broker, with an offer of approximately USD 67 million, ultimately abandoned due to legal uncertainties surrounding the transaction. A first warning signal. The market had already identified the risk. A classic fault line: seizure vs. sale The current dispute highlights a fundamental distinction: the seizure , which relates to the legality of the initial measure, the sale , which involves transparency, traceability, and proper handling of proceeds. In the Alfa Nero case, this boundary is now being challenged. The claimant seeks to broaden the scope of the dispute to include: the conditions of the sale, the financial flows, and any subsequent irregularities. Conversely, the authorities aim to limit the dispute strictly to the validity of the seizure. This tension is structural. And it will determine the outcome of the case. A legally exposed sale Beyond the specific case, the matter highlights a key point: the sale of a seized yacht does not eliminate risk, it may shift it. In the absence of a clearly defined framework: the traceability of operations may be challenged, the transparency of the process questioned, the allocation of proceeds disputed. Most importantly: the potential buyer is exposed to delayed litigation risk. This has immediate consequences: withdrawal of offers, asset devaluation, loss of market attractiveness. Key takeaway: structuring the sale to secure the asset The Alfa Nero case confirms an operational reality: a sale cannot be secured after the fact - it must be built upstream. Three pillars are essential: an unquestionable legal basis , clearly detached from the initial constraint regime, a structured sale process ensuring competition and equal access, full traceability of financial flows , from bid to distribution of proceeds. Failing this, the sale itself becomes subject to challenge. Conclusion The Alfa Nero case is not an exception. It highlights a still insufficiently structured area of law and practice : the disposal of maritime assets under judicial or international constraints. A poorly managed seized yacht becomes a dispute. A poorly structured sale prolongs that dispute. In a fragmented international environment, only a rigorous, documented and anticipatory approach can preserve both asset value and legal certainty for all parties. Frozen Yachts & Sanctions - Alfa nero : The legal saga continues - Read the LinkedIn post Contact Emmanuelle VOTAT  – Judicial Yacht Asset Manager (France) - Specialist in Seized Maritime Assets ev@yachting-legal-auction.com

A port access denial with broad implications The refusal by Icelandic authorities to grant access to the port of Akureyri to a yacht identified as La Datcha, which changed flag in late 2022, marks a significant development in the operational enforcement of sanctions-related measures. The vessel, now sailing under the Panamanian flag, had previously operated under the Russian flag until September 2022. Despite its current legal status, access to port was denied. A rule… and its interpretation The decision is based on a rule applied within the European Economic Area (EEA): a vessel that has changed flag after 24 February 2022 may be denied access to ports. At first glance, this appears to be a technical criterion. In practice, it functions as an indicator of suspected sanctions circumvention. In other words: post-Ukraine flag change → suspicion suspicion → denial of access From legal status to risk perception This case highlights a major shift. The current legal status of the asset is no longer sufficient to guarantee its operability. Even where: the yacht is no longer under a Russian flag, the owner has distanced themselves politically, the asset remains exposed. Its historical footprint becomes decisive. The emergence of “historical risk” This case introduces a key concept in the analysis of maritime assets: historical risk . A yacht may be: legally compliant, yet operationally constrained. The consequences are immediate: denial of port access, increased scrutiny from insurers, caution from brokers and counterparties. Towards a preventive compliance approach The La Datcha case reflects a broader evolution: a shift from a strictly legal assessment to a preventive compliance approach . Authorities no longer limit themselves to assessing the current situation. They anticipate potential patterns of circumvention. This creates a more uncertain environment, in which: interpretation may vary, decisions may be discretionary, and risk becomes harder to quantify. Operational consequences for the market This shift is not theoretical. It directly impacts: navigation routes, insurance coverage, transactional due diligence, asset valuation. A yacht may remain legally valid, while losing its operational fluidity. Conclusion Changing flag is no longer sufficient to erase exposure. In a sanctions-driven environment, history matters as much as status. For operators, buyers and authorities alike, this implies: deeper analysis, stronger documentation, and a broader approach to risk. Frozen Yachts & Sanctions - Russian Yacht/ Iceland: Coast Guard denies access to the port of Akureyri - Lire le post sur LinkedIn Contact Emmanuelle VOTAT  – Judicial Yacht Asset Manager (France) - Specialist in Seized Maritime Assets ev@yachting-legal-auction.com

The M/Y Tango , a 78-meter superyacht built by Feadship , seized in Palma de Mallorca during a highly publicised FBI  operation, remains one of the most striking — and most costly — examples of a poorly anticipated seizure of a complex maritime asset. The operation, filmed as a trophy of financial warfare, was intended to demonstrate that international sanctions had finally gained teeth. Four years later, the symbol is still there… immobile, immaculate, and prohibitively expensive. When agents of the Federal Bureau of Investigation  boarded the superyacht Tango in Palma de Mallorca, following a transatlantic operation spanning nearly 5,000 nautical miles, the image was meant to leave a lasting impression. M/Y Tango, a 78-metre superyacht built by Feadship and valued at approximately USD 90 million , became the first major visible trophy of the US sanctions campaign against Russian assets. Filmed, widely publicised and extensively commented upon, the operation was designed to show that international sanctions could produce tangible and spectacular results. Nearly four years later, that symbol has turned into something very different: one of the most expensive stationary objects in the recent history of US economic criminal law enforcement. A seized yacht that has never been disposed of Since her seizure in Palma, Tango has neither been sold, nor chartered, nor repurposed for any alternative use. She has remained moored, almost entirely immobile, in one of the most expensive marinas in the Mediterranean, Club de Mar . Meanwhile, costs have continued to accumulate. As early as the beginning of 2025, the US press was already reporting more than USD 32 million spent on the custody and maintenance of the yacht. Over the following months, expenses continued to rise at a pace close to one million dollars per month. Today, the total bill exceeds USD 43 million , simply to preserve an asset whose original construction cost was only twice that amount. This is not a minor budgetary overrun. It is the direct result of the legal qualification chosen  and the manner in which the seizure was executed. Freeze or seizure: a distinction with major consequences In the vast majority of European sanctions cases, yachts are frozen , not confiscated. Legal ownership remains with the sanctioned individual, who continues to bear the associated financial burden: crew, insurance, maintenance, and regulatory compliance.The State blocks use and circulation, but it does not inherit the costs. Tango followed a radically different path. At the request of the US authorities, she was formally seized  and classified under Spanish law as incautado , rather than merely immobilised. This classification resulted in an immediate transfer of financial responsibility to the requesting authority — namely, the United States. The Spanish maritime press, notably Revista Mar , has been explicit on this point: the maintenance of Tango, ordered in the context of the seizure, is borne by the US taxpayer and represents approximately ten million euros per year. From political symbol to federal liability This status explains the relentless escalation of costs. Between February 2025 and January 2026 alone, nearly USD 11 million in additional expenses were incurred to keep the yacht operational. What was intended as a powerful symbolic enforcement action has hardened into a long-term public expense. The situation became even more complex with the dissolution of the KleptoCapture  task force, which had initiated the operation. Deprived of a dedicated institutional structure, the Tango file now finds itself in a form of legal and administrative limbo, with no clear ownership or governance, while expenses continue uninterrupted. A maritime asset is never inert A 78-meter superyacht cannot simply be “switched off” or abandoned without consequences. Even in semi-dormant condition, it requires qualified human presence, continuous technical monitoring, active insurance coverage, and strict compliance with safety and classification standards. Systems must operate continuously, generators must power installations, and safety equipment must remain certified, failing which rapid and sometimes irreversible deterioration will occur. Berthing costs add a further burden. In Palma, annual fees for a yacht of this size reach six-figure amounts, to which must be added crew salaries, class inspections, consumables, generator fuel, and the fees of specialised management firms. The annual budget quickly climbs into the millions. A technical and patrimonial paradox Technically, Tango remains an exceptional yacht. Exceeding 2,000 GT, powered by four MTU engines and capable of speeds in excess of 21 knots, she features an exterior design by Harrison Eidsgaard and an equipment level aligned with the highest standards: a counter-current swimming pool, spa, beach club, outdoor cinema, private owner’s deck, helipad, and custom tenders. Symbolically, she continues to carry significant weight. As the first yacht seized under the US sanctions campaign, she has remained visible at the heart of one of Europe’s premier yachting hubs, functioning for years as a floating billboard of Western resolve. Financially, however, she has become something else entirely: a precedent . A case study demonstrating that a poorly structured seizure can cost more than maintaining an asset under freeze, without producing either value or resolution. A lesson for future disposals of maritime assets Nearly four years after her boarding, Tango remains immaculate, immobile, and publicly funded. She embodies a particularly clear lesson for authorities tasked with managing frozen or seized maritime assets. A yacht is not an asset that can be stored indefinitely without strategy. The absence of a decision, far from being neutral, is often the most costly option. Without a robust legal, technical and financial framework , the seizure of a superyacht can become counter-productive, both in terms of value preservation and the credibility of sanctions policies themselves. The central question is therefore not merely whether to seize an asset, but how to manage and dispose of a seized yacht, within timeframes compatible with maritime realities and market conditions, while securing the legal process and limiting the financial impact on the public purse. Tango will likely remain a landmark precedent: that of a trophy turned liability, and of a floating asset transformed into a public burden due to the absence of a clearly defined disposal strategy. Frozen Yachts & Sanctions – Read the LinkedIn post Contact Emmanuelle VOTAT  – Judicial Yacht Asset Manager (France) - Specialist in Seized Maritime Assets ev@yachting-legal-auction.com Disclaimer This article is based on publicly available facts, verifiable data, and an independent legal and strategic analysis. It does not constitute any definitive assertion regarding the guilt or innocence of the individuals or legal entities mentioned, but 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 via official channels and will be reviewed with due care. The author acts independently and in compliance with the right to information and the duty of professional discretion.

The auction took place at the La Ciotat shipyards on 27 March 2025. The yacht was sold for EUR 11,952,000 (fees included). The superyacht Stefania, seized in the context of an international criminal investigation into money laundering linked to drug trafficking, was sold at public auction in France on 27 March 2025. This operation illustrates the ability of the French authorities to preserve the value of seized maritime assets while ensuring a rigorous procedure fully aligned with the standards of the luxury yachting market. It also lays the groundwork for the auction sale of seized yachts. t Stefania Superyacht Times The sale of M/Y Stefania  forms part of a broader framework governing the judicial sale of seized yachts , the legal, technical and operational mechanisms of which are analysed in detail in this reference article. Superyacht Times A landmark case of judicial maritime seizure M/Y Stefania , a 41-metre motor yacht built by Dynamiq, was seized as part of an international criminal investigation involving money laundering related to drug trafficking, arms trafficking and narcotics. Intercepted during a port call in Italy, the vessel was subsequently placed under the authority of the French judicial system. The French authorities established that funds of illicit origin were allegedly used to acquire both the yacht and a villa located on the French Riviera, with an estimated value of approximately EUR 10 million. This seizure followed the analysis of suspicious financial flows transiting through offshore jurisdictions, intended to conceal the origin of the funds. Superyacht Times Continuous judicial management prior to disposal The yacht was repatriated in November 2023 and then underwent nearly seventeen months of continuous judicial management , including the securing of the vessel, its maintenance, coordination between the competent authorities, and preparation for its disposal. The public auction took place on 27 March 2025, with an opening bid set at EUR 10 million, based on an estimated value ranging between EUR 10 and 12 million. The yacht’s technical and aesthetic features — notably its glass-inlaid railings and transparent flag mast — were highlighted as part of the judicial marketing process. Prospective bidders were required to register in advance and to pay a deposit of EUR 500,000  in order to participate in the auction. Superyacht Times A structuring operation for the practice of judicial yacht sales The sale of Stefania  demonstrates the ability of the French authorities and the appointed professionals to preserve the value of a seized maritime asset, while ensuring a transparent, legally secure procedure fully compliant with the standards of the international luxury yachting market. It now constitutes a reference case  for the auction sale of seized yachts, within a broader context of strengthened European mechanisms to combat illicit financial flows linked to luxury assets Superyacht Times Media coverage of the sale of the M/Y Stefania The sale of the superyacht Stefania received exceptional national and international media coverage, reflecting the public and institutional interest generated by this judicial maritime operation. Auction Sale of Seized Yachts:   Read the post by Pierre Chapon (Enchères Publiques) Sea trials - Stefania is back at sea: Read the post on LinkedIn Print media Agence France-Presse (AFP)  – économique et général (27 mars) La Provence  (26, 28 et 29 mars) Le Journal de la Haute-Marne  (26 mars) La Marseillaise  (28 mars) Le Figaro  (25 mars) Nice-Matin  (28 mars) Var-Matin  (28 mars et 27 mars) Ouest France  (28 et 27 mars) Monaco Matin  (28 et 27 mars) Le Progrès  (29 et 28 mars) La Croix  (27 mars) Sud Ouest  (27 mars) Challenges  (27 mars) Corse Matin  (27 mars) Le Parisien  (25 et 27 mars) L’Ardennais  (25 mars) Libération Champagne  (25 mars) L’Est-Éclair  (25 mars) Courrier Picard  (25 mars) La Dépêche  (25 mars) Online, broadcast and business media Radio France  (25 mars) France Info  (25 mars) France Bleu  (25 mars) France 3 – région Provence-Alpes-Côte d’Azur  (26 et 27 mars) France 24  (27 mars) TV5 Monde  (25 et 27 mars) BFM TV  (25 mars) BFM Business  (28 mars) CNEWS  (27 mars) Sud Radio  (27 mars) Le Figaro  (25 et 27 mars) Le Figaro Nautisme / Meteoconsult  (25 et 28 mars) Capital  (25 mars) Boursorama – Actu & Économie  (27 mars) Fortuneo.fr  (27 mars) Bourse Direct  (25 et 27 mars) Finance.Yahoo.com  (28 mars) Yahoo Actualités  (25 mars) MSN / MSN.com  (26 et 27 mars, dont reprise Le Parisien) 20Minutes.fr  (25 mars) 20Minutes.ch Actu.fr  (25 mars) Actu Marseille  (27 mars) Mediapart  (27 mars) Le Marin – Ouest-France  (27 mars) Africain.info  (25 et 27 mars) ÉconomieMatin.fr  (28 mars) 24Matins.fr  (25 mars) Mesinfos.fr  (26 mars) Nice-Presse  (25 mars) 42 Mag  (25 mars) Wargny.com  (25 et 27 mars) Portail Free (AFP)  (27 mars) Portail Orange.fr  (27 mars) Portail.free.fr  (25 mars)

Since the beginning of the conflict in Ukraine, the freeze of Russian assets has been a central pillar of the European Union’s sanctions regime. While this principle is now firmly established, its long-term effect - particularly on high-value non-financial assets such as yachts - remain insufficiently articulated. Since December 2025, the European Union has favoured legal stability over any declaratory shift. This deliberate prudence, however, leaves a significant blind spot: the management of immobilised private assets that are costly, degradable, and technically complex—first and foremost, yachts. What is the status of frozen yachts under sanctions? Assessment and outlook. I. Frozen Russian assets: assumed political stability, but no new doctrine Since December 2025, the European Union’s position has been clear on one point: the freeze of Russian assets is intended to last. European institutions have confirmed: the continuation of the freeze on Russian sovereign assets , without any predefined end date, the absence of restitution until a political and legal framework for reparations has been established, and the determination to avoid any decision likely to create a risky international precedent. However - and this is a crucial point - no new official declaration has been issued since December 2025 regarding the active management or disposal of high-value frozen asset s, whether sovereign or private . No harmonised and proactive doctrine has emerged with respect to: value preservation, the management of costs resulting from prolonged immobilisation, or structured exit mechanisms for non-financial assets. This status quo is deliberate : the EU currently prioritises legal robustness over any political announcement that could weaken the sanctions regime. II. Yachts: private assets that have become a blind spot in the freeze regime While no official methodology has emerged, frozen private yachts now occupy a singular position in technical discussions - so marginal that they have effectively become a blind spot in the asset-freeze regime. There are several reasons for this “oversight”. Frozen yachts are neither: sovereign assets protected by state immunity, nor passive financial assets. They are: private assets, technically complex, degradable , and costly to maintain . Since late 2025, in the absence of any formal public communication, a shared assessment has emerged in administrative and technical exchanges: prolonged immobilisation results in a measurable loss of value , it effectively transfers a financial burden to the custodial authority , it increases risks related to safety, seaworthiness, and the environment , and it exposes States to a simple but critical question: is inaction still a tenable position? To date, no institution has openly referred to “sales” in its official communications. Nevertheless, the notion of responsibility linked to the preservation of frozen technical assets is clearly gaining ground , particularly where high-value private property is concerned. The debate is shifting towards operational considerations, notably in light of documented cases of deterioration affecting several immobilised yachts, some of which have been the subject of public analysis and judicial decisions, such as Luminosity  (Montenegro) or Phi  (United Kingdom). (see UK sanctions on frozen yachts and the landmark decision upholding the legality of the detention of Phi, despite the absence of sanctions targeting its owner). III. A reasonable path forward: preserving value without lifting the freeze In this context, one equation is increasingly emerging as the only legally defensible and politically sustainable approach: Controlled sale + escrowed proceeds = freeze maintained, asset preserved This model rests on three clear pillars : 1. Do not undermine the freeze Proceeds from any sale remain fully escrowed , no enjoyment is restored to the sanctioned owner, the sanctions regime remains intact. 2. Base decisions on safety and technical integrity seaworthiness audits, system-related risks, degradation and obsolescence, port and environmental safety, costs borne by States, accelerated depreciation. These are factual findings , not political choices - and there is no shortage of supporting arguments. 3. Acknowledge economic reality each month of inaction results in asset depreciation , each month of inaction generates a tangible public cost , each month of inaction increases the risk of liability for host States . For instance, imagine a superyacht carrying 60,000 litres of fuel in its tanks , immobilised in the heart of a capital city such as London (purely hypothetically), which - due to the freeze and the absence of a conscious management strategy - has lost its class and insurance. Add to this several electrical cabinet fires and multiple attempted break-ins on board. Suppose a fire were to occur. Who would bear the cost of the total loss of the asset, its removal, and the resulting environmental and port damage? Although this scenario - based on documented facts - is intentionally theoretical, it reflects technical and legal risks that are well identified in the management of immobilised maritime assets. At this stage, doing nothing becomes a decision in itself - and potentially a liability-triggering one. Conclusion Since December 2025, clarity is essential: there is no new written European doctrine, there is no official declaration specifically addressing yachts, there are no audits or methodologies, and there is no harmonised framework for management or disposal, Yet there is a clear evolution in reasoning . The European Union no longer advances through slogans. It advances through pilot cases , evidence , and audited methodologies. Frozen private yachts - precisely because they are costly, technical, and degradable - are likely to become the natural testing ground for a more intelligent approach to managing assets under sanctions. In the current context, no option is legally neutral. Whether it involves: a controlled sale with escrowed proceeds, subsequent restitution, or prolonged immobilisation without a clear perspective, each of these paths now carries its own litigation risk . The key question is therefore no longer whether action is required, but how host States can arbitrate between options that all entail legal, economic, and environmental risks - and from what point inaction, when it leads to value destruction, public cost transfers, or heightened risk exposure, becomes an autonomous source of liability . Within the sanctions framework - and particularly with regard to frozen yachts - the real challenge is no longer to avoid risk, but to document it, prioritise it, and justify it. Contact Emmanuelle VOTAT – Judicial Yacht Asset Manager (France) - Specialist in Seized Maritime Assets ev@yachting-legal-auction.com

Sanctions: When European Courts Finally Pierce the Offshore Veil of Frozen Yachts A decision handed down in Finland in 2025 marks a quiet yet decisive turning point in the enforcement of European sanctions targeting superyachts linked to the Russian elite. The Pirkanmaa District Court refused to return the yacht Divina Barbara (Princess, 35 m), seized in 2022, despite the intervention of a Belgian-Swiss national claiming to be the vessel’s true owner. The court did more than dismiss the claim: it explicitly characterised the ownership structure as artificial, designed to conceal the yacht’s real beneficiary — sanctioned Russian oligarch Eduard Khudaynatov . This ruling is not an isolated event. It reflects a growing convergence in international case law aimed at neutralising nominee structures used to circumvent sanctions regimes. Divina Barbara: A Full-Scale Test for EU Sanctions Seized by Finnish authorities in the summer of 2022, Divina Barbara was considered from the outset to be an asset controlled by Eduard Khudaynatov, former Rosneft executive and close associate of Igor Sechin. The claimant asserted that he exercised effective control over the yacht through a complex chain of offshore companies spread across multiple low-tax jurisdictions. The court found this argument unconvincing. Judges concluded that the holding structure constituted “an unnecessarily complex web of shell and holding companies, indicative of an intention to conceal the true beneficial owner.” In other words: a classic sanctions-evasion scheme. With an estimated value of approximately €18 million, the ruling now clears the path toward effective confiscation and potentially a controlled sale of the vessel. Eduard Khudaynatov: One Name, Five Yachts, One Pattern The broader significance of the Finnish decision lies in its systemic reach. Divina Barbara is the smallest of the yachts associated with Eduard Khudaynatov. Western authorities and international investigations link his name to at least five superyachts, with a combined estimated value of USD 1.5 billion: Scheherazade  (Italy) – frequently attributed to Vladimir Putin Crescent  (Spain) – suspected to belong to Igor Sechin Amadea  (United States) – auctioned in 2025 after failed legal challenges La Perla Divina Barbara Across each case, the same mechanism emerges: Khudaynatov acts as the nominal owner, while control and beneficial use lie with directly sanctioned individuals. From Offshore Structures to the Courtroom: The End of Formal Illusions The Finnish ruling confirms a profound shift in judicial reasoning. Courts no longer limit their analysis to: registry entries, formal shareholding chains, or declarations of ownership. They now examine: who actually controls the asset, who bears its costs, who benefits from its use, and whether the structure was designed to circumvent sanctions. This substance-over-form  approach is now explicitly supported by evolving European guidance. A Radically Strengthened European Context The decision follows closely the adoption of the EU’s 19th sanctions package in October 2025, and above all the new EU directive criminalising sanctions violations and circumvention. This directive requires Member States to: criminalise sanctions circumvention, sanction the concealment of frozen assets, prosecute nominee owners and facilitators, including legal entities. The Khudaynatov case matches these targeted behaviours point for point: concealment of the beneficial owner, use of shell companies, misleading information provided to authorities. Finland has simply applied this new legal framework with precision. Amadea, Scheherazade, Divina Barbara: Judicial Coherence Emerges The Finnish ruling echoes: the U.S. federal validation of the confiscation and sale of Amadea, Italian measures concerning Scheherazade, Spanish proceedings involving Crescent, and the broader doctrinal evolution observed since Phi (UK, July 2025). Offshore façades that are “clean on paper” are no longer sufficient. Direct Implications for Frozen Yachts in Europe What is at stake goes far beyond Divina Barbara.The Finnish decision: significantly weakens nominee-based defence strategies, facilitates effective confiscations, opens the way to faster, legally robust outcomes for frozen yachts. The question is no longer: Whose name appears on the paperwork? But rather: Who actually controls the asset — and is the sanctions regime being circumvented? Conclusion: A Strong Signal — and Likely a Precedent What happened in Finland will not remain isolated. The Divina Barbara decision sends a clear signal to European courts: legal screens no longer protect luxury assets hidden behind artificial structures. For frozen yachts in Europe, a new phase is beginning — more coherent, more assertive, and above all oriented toward effective outcomes. To be watched very closely. Contact Emmanuelle VOTAT  – Judicial Yacht Asset Manager (France) - Specialist in Seized Maritime Assets ev@yachting-legal-auction.com Frozen Yachts & Sanctions – 💥⚖️ 𝗙𝗜𝗡𝗟𝗔𝗡𝗗 - 𝗔 𝗦𝗵𝗼𝗰𝗸𝘄𝗮𝘃𝗲 𝗳𝗼𝗿 𝗦𝗮𝗻𝗰𝘁𝗶𝗼𝗻𝘀 & 𝗦𝘂𝗽𝗲𝗿𝘆𝗮𝗰𝗵𝘁𝘀: 𝗞𝗵𝘂𝗱𝗮𝘆𝗻𝗮𝘁𝗼𝘃 𝗢𝘃𝗲𝗿𝗿𝘂𝗹𝗲𝗱 - Lire le post sur LinkedIn Advertissement 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.

She was built to conquer the sea. Sleek, powerful, and endlessly refined, Phi was meant to glide through the world’s most exclusive marinas, not languish behind a police cordon at Canary Wharf, now a frozen yacht under sanctions. In March 2022, just days after her delivery, the yacht was seized under the UK’s sanctions regime. Since then, this floating jewel has become a static symbol of legal gridlock and geopolitical symbolism. Her engines cold, her hull once immaculate, her future uncertain. Royal Huisman 29 March 2022 – M/Y Phi in London: a dramatic twist on the docks of Canary Wharf When Phi entered British waters in March 2022, she did not expect to become a political celebrity. It was her maiden voyage, or almost: freshly delivered by Royal Huisman, the yacht arrived in London for a prestigious event. She was scheduled to participate in the Superyacht London Show, held in the heart of the Canary Wharf business district ( The Guardian ).   But more than anything, Phi was there for far more logistical and trivial reasons: to refuel (60,000 liters), complete final provisioning, and embarking part of the crew. In short:   Phi was making her official debut into the international yachting scene . With her cutting-edge design and razor-sharp lines, she was turning heads on the Thames, far from blacklists and suspicion. A HIGHLY PUBLICIZED INTERVENTION On 29 March 2022, while the yacht was moored in one of the most heavily monitored areas of the UK, the authorities stepped in. No dramatic boarding. Just an administrative notification posted under the   Sanctions and Anti-Money Laundering Act 2018. The next day, Minister Grant Shapps took the media stage in a high-profile sanction’s announcement:   “Phi is owned by a Russian businessman and is now frozen - this magnificent £38 million superyacht won’t be going anywhere.” And just like that, Phi - dazzling, brand new -   was transformed into a politically symbolic asse t, taken in the context of the UK’s sanctions strategy. WHO OWNS M/Y PHI ? A DOUBLE IDENTITY Officially, M/Y Phi is owned by   Sergei Naumenko , a Russian real estate entrepreneur. He is the individual targeted by British authorities when the yacht was immobilized in London in March 2022 ( Financial Times ). He is also the one who has filed several appeals before UK courts,   arguing that he is neither sanctioned   nor close to the Russian regime, and that the seizure of Phi was nothing more than a “media stunt.” But the story doesn’t end there. Behind this name, several journalistic sources (including the   Financial Times, OCCRP, and Superyacht Fan ) point to another figure:   Vitaly Vasilievich Kochetko v , a Russian telecoms tycoon and founder of Motiv Telecom in the Urals. A discreet but influential profile, experienced in offshore ownership structures and luxury assets. He is also identified as the owner of the yacht Aurelia. This ambiguity reveals a structured ownership strategy:   Sergei Naumenko appears as the  registered owner , the name on the paperwork and the one leading the legal fight.  Vitaly Kochetkov, meanwhile, is said to be the  ultimate beneficial owner , the “real owner,” acting through offshore companies.  In this case, a company registered in Saint Kitts and Nevis: Portsmouth Maritime. In other words, Phi has two faces: one for the courts, and another for the economic reality. This dual ownership model creates a procedural challenge for Western jurisdictions, especially for seizure procedures. ARE THEY SANCTIONED? Sergei Naumenko? Not sanctioned   by the UK, the EU, or the United States. He is regarded as a non-listed Russian national, precisely the heart of his legal argument against Phi’s immobilization in London. He claims not to be close to the Kremlin and denies any ties to strategic Russian entities.   Result: Officially “clean,” making the seizure of Phi legally fragile and politically controversial. Vitaly Vasilievich Kochetkov? Also not sanctioned   to date by any Western authority. Yet his profile is opaquer and more sensitive:   Former CEO of a regional telecom operator (Motiv Telecom),  Experienced in offshore setups,  His name regularly appears in Russian luxury asset cases (Aurelia, Phi, London real estate...). But to date, there is no public evidence to justify sanctions. A TWO-HEADED YACHT Visible to the law under Naumenko’s name, formally unlinked through public registries from Kochetkov’s corporate presence. This ambiguity,  typical of oligarchic asset structures post-2022 , perfectly illustrates the limits of the UK’s sanctions doctrine: Immobilizing an asset, yes; reaching the real owner, no.   And that’s legally inconsistent. Yet Phi remains there, under the spotlight, in one of Europe’s most visible ports, the perfect symbol. THREE YEARS LATER, STILL NO ANSWERS Captain Guy Booth, responsible for the management of Phi, has repeatedly sounded the alarm, both publicly and through official channels. His words, as relayed by   SuperyachtNews , strike a sharp note: “The decision to maintain (Phi’s) detention was based on the government recommendation to seek further evidence. They’ve had three years to gather that evidence and they have nothing.”  While this quote reflects Captain Booth’s frustration, the UK authorities maintain that ongoing investigations are necessary before lifting the seizure. In short, Phi had the misfortune of   being too beautiful, too new, too Russian . And in the wrong place at the wrong time. Photo Superyacht Times COMPROMISED MAINTENANCE & THREATENED CLASSIFICATION : A JEWEL AT RISK Far from specialist shipyards and the temperate waters she was built for, M/Y Phi is now   trapped in the cramped urban dock   of East London, hardly suitable for wintering a 58.5-metre vessel. Immobilized since March 2022, the ultra-modern yacht designed by Cor D. Rover and built by Royal Huisman is slowly suffering the effects of prolonged inactivity. Lacking authorization to relocate, Phi could not be transferred to Southampton as initially planned for her annual classification inspection. Result:   the vessel’s classification has now lapsed , making her officially unseaworthy under Lloyd’s Register standards ( YachtsNL ). This loss of class triggers a domino effect: suspended insurance, invalid certification, and above all, serious technical and environmental risks. In practice, this means that in case of damage - fire, pollution, theft or sabotage -   no compensation can be claimed . The yacht now drifts in a legal and technical void. Among the incidents reported:   Several electrical fires in onboard control cabinets Faulty fire safety systems Malfunctioning fire doors Persistent humidity in the bilges causing slow but ongoing degradation of onboard systems and materials More worryingly,   around 60,000 liters of fuel remain on board , with no clear protocol in case of leakage or accident. In such a confined environment as Canary Wharf, even a minor incident could trigger an environmental disaster in the heart of London. As for registration, Phi remains listed under a shell company domiciled in Saint Kitts and Nevis, flying the Maltese flag, reinforcing confidentiality and limiting British authorities’ ability to act. This   legal complexity   contributes to the current stalemate:   No officially designated owner No clear management authority No suitable legal framework From an asset-management standpoint, this situation creates a double risk:   Wear and  loss of value  due to immobilization Possible  claims for compensation  if the owner proves that no formal legal measures were taken FRANCE vs UK : TWO SEIZURES, TWO APPROACHES Meanwhile, in France, M/Y Stefania, another marvel of Van Oossanen’s architects, seized one year after Phi, has already been sold at auction, in perfect maintenance conditions. ROYAL HUISMAN : EXCELLENCE AGAINST JUDICIAL INEFFICIENCY Built at the Vollenhove yard and delivered in winter 2021, Phi is   a technological jewel by Royal Huisman , the world-renowned Dutch shipyard specialized in ultra-large sailing yachts. With Phi, Royal Huisman made a noteworthy entry into the motor yacht market, offering a   perfect synthesis of performance, futuristic design, and artisanal excellence . For the yard, this project was a flagship in terms of innovation and global prestige. Interior design by Lawson Robb, exterior styling by Cor D. Rover, cutting-edge engineering... Phi was supposed to usher in a new era in custom yacht construction. But the dream quickly   turned into a nightmare . Since then, Royal Huisman has remained publicly silent, avoiding comment on the vessel’s fate. That silence, while likely aimed at shielding the yard from diplomatic or legal fallout, comes at a price: the image of both the yacht and Royal Huisman has been weakened. Seeing such a flagship decay in a city basin, with no clear plan for restitution or resale, casts a shadow over post-delivery support and shipyard follow-through. Many in industry are asking: Can a shipyard of this caliber stand idly by while one of its crown jewels is left abandoned to time and geopolitics? The Phi case also underscores the limits of the   ultra-confidential contract model   that governs high-end yachting. In shielding buyers’ discretion, some shipyards now find themselves exposed to repercussions beyond their control. PHI : AN ACCIDENTAL ICON OF A NEW GLOBAL CHALLENGE M/Y Phi is not just a yacht immobilized in a London port. She is a glaring symbol of the geopolitical, legal, and technical stakes we now face. Behind her futuristic lines and cutting-edge technology lies a complex reality:   a valuable asset trapped in an administrative, legal, and diplomatic maze. But this situation, however frustrating, is not hopeless. On the contrary, it reveals the   urgent need for a clear, strategic vision,   coordinated across states, European institutions, and yachting professionals. It’s time to awaken Phi from her limbo, to restore her asset value and, above all, to rebuild trust in the   responsible and transparent management of seized property . This challenge calls for a collective effort: legal rigor, technical expertise, and political courage. Because beyond titles and courtrooms, what’s truly at stake is Europe’s credibility:   a strong, coherent Europe , capable of upholding its principles while   protecting its industrial gems . It is no longer just a question of one yacht. It is the credibility of a whole system that now hangs in balance. Phi must become once again what she was meant to be:   a jewel of maritime innovation and a symbol of excellence. Contact Emmanuelle VOTAT - Judicial Yacht Asset Manager (France) - Specialist in Seized Maritime Assets –   ev@yachting-legal-auction.com Frozen Yachts & Sanctions : 𝗟𝗮𝗻𝗱𝗺𝗮𝗿𝗸 𝗷𝘂𝗱𝗴𝗺𝗲𝗻𝘁 𝗶𝗻 𝘁𝗵𝗲 𝗨𝗞: 𝗣𝗵𝗶’𝘀 𝗱𝗲𝘁𝗲𝗻𝘁𝗶𝗼𝗻 𝗿𝘂𝗹𝗲𝗱 𝗹𝗮𝘄𝗳𝘂𝗹, 𝗱𝗲𝘀𝗽𝗶𝘁𝗲 𝗶𝘁𝘀 𝗼𝘄𝗻𝗲𝗿 𝗻𝗼𝘁 𝗯𝗲𝗶𝗻𝗴 𝘀𝗮𝗻𝗰𝘁𝗶𝗼𝗻𝗲𝗱 Read the up-date post on LinkedIn 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.

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 Frozen Yachts & Sanctions - 👮😮 𝗣𝗹𝗲𝗮𝘀𝗲, 𝘁𝗮𝗸𝗲 𝗼𝗳𝗳 𝘆𝗼𝘂𝗿 𝘀𝗵𝗼𝗲𝘀 𝗯𝗲𝗳𝗼𝗿𝗲 𝗯𝗼𝗮𝗿𝗱𝗶𝗻𝗴/ 𝗳𝗿𝗲𝗲𝘇𝗶𝗻𝗴, 𝘄𝗶𝗹𝗹 𝘆𝗼𝘂 ? Read the post on LinkedIn 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.

Managing frozen and seized yachts can no longer remain a legal vacuum. Drawing on French judicial practice, this article calls for a European ethical and transparent framework to preserve asset value, reduce public costs and transform crime-linked yachts into public value. Published in SuperyachtNews, 9 june 2025 Emmanuelle Votat calls for a European framework to manage frozen and seized yachts ethically and transparently based on lessons from judicial practice in France… Emmanuelle Votat is a judicial auctioneer specialising in the management and sale of yachts seized in criminal proceedings. She is the founder of a pioneering programme for judicial yacht asset management in France and has overseen landmark cases, including the sale of Stefania, which was confiscated in a major money laundering investigation. In this article, she offers a complementary legal perspective on Russell Crump’s proposal for the sale of frozen vessels and outlines a European model for their ethical and strategic management. Crédit photo : Département de la Justice The article “Can frozen yachts be thawed?” raises a crucial question: What can be done with yachts immobilised by international sanctions? And beyond that, how do we sustainably manage nautical assets frozen by criminal or administrative proceedings? Russell Crump’s proposal, which I salute for its effort to challenge the status quo, deserves a broader discussion. While the yachting industry cannot indefinitely absorb the cost of these vessels lying idle, the solution cannot be purely commercial. Manage frozen and seized yachts As a judicial auctioneer specialised in the management and sale of yachts seized in criminal proceedings, I step in when a superyacht no longer symbolises luxury but crime: trafficking, corruption, money laundering. Recently, we successfully sold Stefania, a 41-metre yacht confiscated as part of a complex criminal case. Based on this experience, I’d like to offer a complementary perspective to the one proposed. I. Selling frozen yachts: a partial and problematic solution M. Crump outlines a legal mechanism by which a sanctioned yacht could be sold under strict compliance controls (source of funds, buyer’s identity), with proceeds held in escrow until sanctions are lifted. While this may seem pragmatic, it poses several legal and ethical challenges. Legal ambiguity between frozen and seized yachts A frozen yacht is not seized by a judge. It is blocked as an administrative measure. Ownership is not transferred, and the vessel legally still belongs to its owner. Sanctioned yachts fall under international public law and diplomacy, not criminal law. They are not legally available for sale. Selling such a yacht raises a paradox: how can one sell an asset whose owner has no rights to use it, yet remains its legal owner? Who receives the sale proceeds if sanctions are never lifted? Crump suggests a workaround: sell the yacht, hold the money. But this creates an economic purgatory with no clear legal outcome. Ethical contradiction Allowing the sale of a sanctioned yacht undermines the sanction’s intent, which is to restrict access to resources. The message becomes: “You can’t sail it, but you can cash out and wait.” This neutralises the sanction’s effect and introduces moral ambiguity. Ignoring criminal context The yacht is treated as a neutral economic asset to preserve the maritime ecosystem and industry. But some yachts are fruits of crime: tools of tax evasion, corruption or money laundering. Their circulation must be re-evaluated in that context. II. A European model for sustainable, ethical management What we need is a European framework for judicial management of yachts, drawing from France’s model but including frozen assets when confiscation becomes legally possible. Key pillars of this model: Transparency and traceability of yacht ownership and use Creation of a European Department for Seized Maritime Assets, including criminally linked and confiscated sanctioned yachts Protection of yacht value during legal proceedings Controlled sales and ethical use of proceeds, directed toward public funds, victim compensation or charitable causes This is not just a technical reform. It is a strategic response to three urgent issues: 1.     Preserving high-value assets 2.     Reducing public maintenance costs 3.     Proving that the State can turn crime-related assets into public good when sanctions lead to criminal confiscation In cases where sanctions evolve into criminal proceedings (as is possible in some jurisdictions), we need structures ready to take over: Technical management to avoid depreciation Rigorous vetting of buyers and fund origins   Transparent, lawful resale benefiting the State or victims Seized yachts are rising in number, due to trafficking, corruption and money laundering. If left too long in legal limbo, they become time bombs, both environmentally and financially. By establishing a European standard of judicial yacht management, integrated into sanction mechanisms when confiscation becomes viable, we can: Preserve asset value Limit public expenditure Restore confidence in institutions’ ability to handle criminal wealth This is what we are doing in France, and what I propose we scale to the European level through a pioneering programme of Judicial Yacht Asset Management. Not theory. Action already underway. Any views, thoughts and opinions expressed here are those of the author and are not intended to malign any particular individual or organisation and may not reflect the views, opinions, policies or positions of The Superyacht Group.  As an open-source platform, we offer an industry-wide invitation to anyone and everyone in our sector to share their knowledge, experience and opinions. So if you have an interesting and valuable contribution to make, and would like to join our growing community of guest columnists, share your ideas with us at newsdesk@thesuperyachtgroup.com Yacht: STEFANIA Builder: DYNAMIQ YACHTS Launched: 2021 Delivered: 2021 Status: Delivered Length: 41.00m Beam: 8.20m Draught: 1.80m Gross Tons: 299 Interior Designer: Dynamiq Yachts Naval Architect: VAN OOSSANEN NAVAL ARCHITECTS

When freezing an asset means freezing responsibility Frozen Yachts & Sanctions : the legal blind spot of EU sanctions The freezing of superyachts under European Union sanctions has become one of the most visible symbols of the geopolitical response to international conflicts. Yet behind the political messaging lies a largely unaddressed reality: frozen superyachts represent a growing environmental risk for the Mediterranean, and EU law currently provides no effective framework to manage it. M/Y Luminosity - November 2025 in Tivat, with my friend Captain Patrick Trouin A recent academic research paper has sounded the alarm. Its conclusion is unequivocal: the EU is navigating a legal blind spot , where environmental protection, asset freezing, and responsibility fail to intersect. Frozen yachts do not “sleep” A frozen yacht is not a dormant object. Even immobilised at berth, it remains a complex industrial system containing: fuel and lubricants grey and black water solvents and chemical products paint residues and antifouling compounds batteries, generators, and emission-producing systems Without proper maintenance, deterioration is inevitable. Corrosion accelerates, seals degrade, onboard systems fail, and pollution risks increase. A frozen vessel deteriorates — and deteriorates its environment. Yet once sanctions apply, proper maintenance often becomes legally, financially, or practically impossible. Thirteen frozen superyachts, over USD 2 billion at risk Across the Mediterranean, at least 13 frozen superyachts , representing more than USD 2 billion in value , remain immobilised in ports. Their environmental footprint is growing silently, while responsibility remains diffuse. This is not a hypothetical risk. It is an operational, technical, and ecological reality. The legal black hole: who pays if pollution occurs? The sanctions regime creates a paradox: The EU freezes the asset Member States immobilise and host the vessel The sanctioned owner no longer acts The yacht degrades But if pollution occurs, who is legally responsible? The sanctioned owner, who no longer operates the vessel? The Member State enforcing the freeze? The port authority hosting the yacht? Or no one at all? In the absence of a specific legal framework, liability risks falling entirely on the immobilising State , which cannot allow an environmental hazard to persist — yet lacks the legal tools to act decisively. EU sanctions law: freezing without environmental safeguards Regulation (EU) No 269/2014, which underpins the freezing of assets, focuses exclusively on economic neutralisation : preventing any benefit from flowing to sanctioned persons. What it does not  do: impose environmental maintenance obligations allocate responsibility for pollution risks provide mechanisms for preventive intervention or disposal In parallel, the Environmental Liability Directive  does not apply: there is no “economic activity” causality is legally untraceable the polluter-pays principle becomes inoperative The result is stark: EU law contains no mechanism to protect the environment from frozen superyachts. Environmental principles violated in practice The current regime undermines core environmental principles: Polluter-Pays Principle : inapplicable, as the sanctioned owner neither operates nor pays Preventive Principle : violated when maintenance is impossible Precautionary Principle : ignored despite the risk of irreversible damage Freezing an asset without managing its environmental impact is not neutral — it is negligent. Freezing without disposal: a structural failure The research demonstrates a fundamental flaw in the sanctions architecture: Freezing without a controlled exit strategy transforms an asset into a liability. States are left bearing: environmental risk reputational exposure financial burden All while the sanctioned owner bears none of the consequences. The only realistic solution: controlled disposal The conclusion is unavoidable. You do not freeze an environmental risk. You deal with it. The only viable answer is a controlled disposal or controlled sale , conducted under strict supervision, ensuring: environmental protection legal neutrality transparency of proceeds exclusion of any benefit to the sanctioned person Such mechanisms already exist in other legal contexts. They now need to be adapted and formalised at EU level for frozen maritime assets. Conclusion: act now — or bear the consequences The Mediterranean is not meant to become a cemetery of frozen superyachts . If the EU wishes to maintain the credibility of its sanctions policy while upholding its environmental commitments, it must close this legal gap — urgently. The debate is open. And it is long overdue. Reference Fabia Betschart , Environmental Damage Caused by Frozen Vessels under EU Sanctions , 24 November 2025 Frozen Yachts & Sanctions : Read the post on LinkedIn Contact Emmanuelle VOTAT  – Judicial Yacht Asset Manager (France) - Specialist in Seized Maritime Assets ev@yachting-legal-auction.com