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M/Y Royal Romance and the pitfalls of procedural fragmentation Administrative, customs and sanctions-based approaches: a pragmatic path to asset preservation The management of yachts frozen or immobilised under international sanctions raises a central question, often overlooked in public debate: should the asset be subjected to criminal proceedings, or should an administrative pathway be preserved to allow for controlled management and an orderly exit? Contrary to purely punitive reflexes, recent experience shows that premature criminalisation can paradoxically destroy value, expose States to extensive litigation, and turn a strategic asset into a long-term liability. In an interview given to the Ukrainian outlet UNN   on 13 January 2026 , the Office of the Prosecutor General of Ukraine  explained its position regarding the continued freeze of the superyacht Royal Romance. The case appears to be a complex entanglement of uncoordinated procedures involving the Ukrainian prosecution authorities, ARMA, and the Croatian criminal courts. Clarifying the case The Ukrainian Prosecutor General has publicly clarified the chain of responsibility: the seizure of the yacht and its transfer for potential sale have been carried out, and subsequent decisions no longer fall within the prosecutor’s remit. The legal turning point occurred on 5 May 2022 , when the seizure orders were formally transmitted to ARMA , which then became solely competent for the management and disposal of the asset, while the Prosecutor General’s Office was limited to international judicial cooperation. The article highlights a major procedural inertia: no sale procedure was initiated by ARMA before March 2024 , nearly two years after the seizure, leaving the asset without any operational exit strategy. At the same time, Croatia , as the host State, has consistently maintained that any definitive sale requires a final criminal confiscation order, while the main criminal proceedings remain ongoing. This requirement arises in an unprecedented context, as the seizure ordered by the Split District Court  — including the freezing of registration and the transfer of management to a foreign authority — constitutes a first in Croatian criminal law. This explains the extreme caution exercised by local authorities and the multiplication of mutual legal assistance exchanges. Finally, while EU sanctions , adopted in May 2024, prevent the yacht from leaving the Union, they do not override national criminal law requirements, leaving the final decision on any sale to the Croatian authorities. M/Y Royal Romance is therefore suspended in an unprecedented situation under Croatian criminal law. Even with the best intentions, Croatia will not assume such legal risk unilaterally. European courts are beginning to be seized of these issues, yet no consistent doctrine has emerged to date. What legal lessons can be drawn from this situation? Criminal seizure: a long timeline often incompatible with yachts The opening of criminal proceedings for money laundering or related offences entails immediate consequences: the freezing of the asset for the duration of the investigation, the subordination of any sale to a final judicial decision, the multiplication of appeal mechanisms, increased exposure to compensation and convention-based litigation. For a yacht — a mobile asset, technically sensitive, costly to maintain and carrying significant environmental risk — such extended timelines quickly become counterproductive. Criminalisation turns the asset into an object of procedure, rather than a property to be actively managed. Administrative and customs seizure: a logic of control By contrast, administrative seizure mechanisms, particularly customs-based conservatory measures (Article 389 of the French Customs Code, for example), offer an approach grounded in: risk neutralisation, value preservation, active asset management, and, where appropriate, a controlled early disposal. These mechanisms do not require a prior criminal conviction. They operate within a logic of control and conservation, fully compatible with international sanctions regimes. International sanctions: immobilising without confiscating Sanctions, particularly European ones, are powerful but often misunderstood tools. They allow for: the freezing of assets, the prohibition of making assets available, restrictions on use and transfer rights. However, sanctions do not amount to criminal confiscation. They do not, in themselves, transfer ownership. It is precisely this administrative nature that makes it possible, under strict conditions, to envisage: controlled management, or even a regulated sale,without waiting for the outcome of lengthy criminal proceedings. The risk of premature criminalisation Criminalising a frozen yacht too early presents several major risks: immobilising the asset for years, triggering irreversible technical degradation, creating environmental risk, exposing the State to restitution or compensation claims, ultimately weakening the credibility of the sanctions framework itself. In other words, in the context of frozen yachts, criminal law may protect moral principles, but administrative law protects value . An emerging doctrine: manage before judging A pragmatic approach is gradually emerging: managing the asset within a secure administrative framework, preserving its economic and technical value, ensuring a legally defensible exit, and reserving criminal proceedings for individuals, financial flows and personal liability — not for the asset itself. This separation between asset treatment and criminal repression constitutes a major strategic lever for States facing frozen maritime assets. Conclusion In the context of yachts frozen under sanctions, the issue is not to abandon criminal law, but to refuse to make it a systematic prerequisite for any decision concerning the asset. By way of comparison, the sale of M/Y Amadea was conducted on the basis of civil confiscation , not criminal confiscation. The combination of administrative or customs seizure + sanctions regime + active management  currently offers the most balanced path between legal certainty, economic efficiency and environmental responsibility. It is here, quietly but decisively, that the credibility of yacht asset-freezing policies is being shaped. Contact Emmanuelle VOTAT  – Judicial Yacht Asset Manager (France) - Specialist in Seized Maritime Assets ev@yachting-legal-auction.com Frozen Yachts & Sanctions – M/Y Royal Romance: One Step Away From Sale… and Splash??? Read the LinkedIn post 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.

Royal Romance: When frozen yachts expose Europe’s maritime justice and asset seizure failures Frozen under international sanctions, the superyacht Royal Romance has become a €20 million-a-year liability. Once meant to support Ukraine’s war effort, it now exposes Europe’s maritime justice failures and the legal vacuum surrounding frozen yacht confiscation. 92.5-m of sleek lines, a 12-m pool, hushed acoustic lounges, and transatlantic autonomy. Its name promised elegance: Royal Romance. A 2015 Feadship masterpiece (De Voogt), once privately owned by Kremlin ally Viktor Medvedchuk, and never available for charter. Estimated pre-seizure value: €200 million. Former MP and close Putin associate, Medvedchuk escaped house arrest in February 2022 and was re-arrested in April. In the meantime, his yacht discreetly left the harbour for “technical trials,” under watchful Croatian eyes, police and harbourmaster included. Seized in Rijeka, Croatia, since March 2022, M/Y Royal Romance is more than a luxury vessel. It has become the symbol of a waning oligarchic system - and now, a glaring challenge for Europe’s asset seizure efforts. Frozen under international sanctions, Royal Romance lies dormant, yet still incurs an estimated €20 million in annual maintenance. More importantly, it represents a legal quagmire and a political turning point: a call for a new, forward-thinking Europe ready to face its legitimate battles. A carefully maintained yacht, trapped in transnational legal loopholes - caught between symbolic hope of war funding and the paralysis of institutions. A EUROPEAN LEGAL ODYSSEY In May 2024, Ukraine made a bold wartime move: it publicly announced the upcoming sale of Royal Romance through the ARMA (Asset Recovery and Management Agency) to support the state budget.   A first!   But Europe’s legal machinery immediately seized up. THE LEGAL ROADMAP 2022 – Entering the Ice Age March–April 2022 : Following initial EU sanctions against Viktor Medvedchuk, M/Y Royal Romance, his 92.5m superyacht, is immobilised in Croatian waters (Rijeka or Trogir). In April, the Split County Court freezes the yacht at the request of Ukrainian prosecutors, with quarterly judicial reviews required. November 2022 : Croatian judge Dinko Mešin issues a search warrant authorising the FBI and local police to inspect the yacht (operation conducted on 19 November). ARMA, present on-site, performs only a visual and photographic inspection. The file collects evidence of concealed ownership transfers via offshore companies. 2023 – The Year of Stagnation Despite no criminal indictment in Ukraine, Croatian courts extend the freeze six times, up to May 2024. A legally framed limbo, with no real progress. 2024 – Symbolic Thawing In June, a symbolic blow:   the Split court lifts the seizure , ruling that the Ukrainian prosecutor failed to file an indictment within the legal timeframe. Despite extensive documentation from Ukraine, the case is transferred to a new judicial panel, leaving the sale suspended in uncertainty. 19 July 2024 – A New Ukrainian Counterattack The Pechersk District Court in Kyiv responds: a fresh seizure is ordered, citing new evidence of offshore structures concealing yacht ownership.   ARMA regains control of the case , but it’s now navigating a legal labyrinth with global stakes and institutional ambiguity. 2025 – The Institutional Clash Begins In January 2025, just as ARMA prepares to finalise the sale of Royal Romance via Boathouse Auctions, the High Anti-Corruption Court of Ukraine (HACC) deals a fatal blow: it refuses to validate the legal transfer documents - documents required for the buyer to legally take possession of the yacht. The refusal, based on procedural and documentation compliance issues, causes   a total administrative freeze . Without these acts, no sale can be executed. The Ukrainian state is left holding a legal ghost ship: not sold, not returned, and generating zero value. But in February 2025, ARMA strikes back. Frustrated, it refers the matter to NABU (Ukraine’s National Anti-Corruption Bureau), accusing certain judicial bodies of orchestrated   “voluntary obstruction. ” ARMA estimates the   financial damage at over €130 million   and warns that the yacht cannot be maintained indefinitely at public expense - nor kept as a floating piece of evidence. This unprecedented move by ARMA - taking action against fellow state institutions - exposes a deep institutional rift at the heart of Ukraine’s legal apparatus. What unfolds is a three-dimensional standoff: Judicial  - between prosecutors and judicial authorities, Political  - over the handling of Russian assets, Diplomatic  - as Ukraine had committed to liquidating or returning certain confiscated assets under international oversight. And now? Royal Romance on the move under armed escort Royal Romance has been quietly   transferred from the naval base in Split to a shipyard in Trogir for maintenanc e, under joint escort by Croatian police and a private security firm. Ukraine’s Asset Recovery and Management Agency (ARMA) has confirmed that the yacht will later be returned to Split, where it will remain under arrest pending the next phase of the asset realisation process. This transfer comes as   Ukraine adopts a major overhaul of its legal framework , aiming to unblock months of administrative and judicial paralysis in the management of seized Russian and Belarusian assets. Key aspects of the reform include: An  expanded mandate for ARMA  allowing it to liquidate foreign assets under sanctions The  introduction of clear deadlines  for prosecutors to transfer assets to the agency The appointment of  external managers via open public tenders  (Prozorro system) to strengthen transparency Mandatory quarterly reporting , an  external audit mechanism , and an  independent public oversight council The creation of a  dedicated reconstruction fund  for Ukraine, directly fed by proceeds from seized assets “This is a historic decision for the state,”   said ARMA’s head Olena Duma, describing a long-awaited turning point for civil society, international partners, and the armed forces alike. WHAT'S NEXT? Although the sale of Royal Romance has not yet been officially approved,   the recent reforms suggest a likely acceleration . Between the staggering maintenance costs (over €20 million per year), the increasing pressure of war, and the political will to monetise sanctioned assets,   a swift sale is becoming a far more realistic outcome . The Feadship remains under judicial authority for now, but   Kyiv finally has the tools to move forward , in close coordination with Croatian authorities. A WAR OF INSTITUTIONS Three years after its initial seizure, Royal Romance is no longer an asset - it’s a liability for the Ukrainian state,   an embarrassment for Croatia, and a nightmare for international cooperation.  While institutions await the perfect alignment of courts, diplomacy, and procedures, the yacht has become the emblem of a system unable to punish or to capitalise. On paper, it’s a gem. In practice, it’s a money pit. And out at sea, the legal storm shows no sign of calming. RESETTING THE COMPASS: SOLUTIONS MODE What if Royal Romance became the catalyst for a new model? It’s time to move from paralysis to action, from scattered efforts to a shared course: A European protocol that freezes assets with a  predefined objective A  multidisciplinary task force  (legal, maritime, strategic) to accompany the asset through its lifecycle An  influence-based diplomacy  - deliberate, operational, and transparent A  European harmonisation through soft law , preserving the sovereignty of each member state, yet united by a common goal These yachts are not just assets. They are   levers, symbols, opportunities . Frozen for over three years across Europe, their exorbitant maintenance costs are often borne by States. In the end, who is truly trapped in this so-called "virtuous freeze" - if it lacks both direction and consciousness? Frozen Yachts & Maritime Justice: Read the article on LinkedIn

Why? Because the chosen format ticks all the boxes for an effective sale. Boat International M/Y Amadea is the first seized yacht to be sold since the beginning of the war, and could become a reference point for the frozen yachts market. A format that attracts serious buyers Sale by sealed bid auction: confidentiality, professionalism, and   no public bidding wars . This process is reserved for motivated candidates, not the casually curious. A format that protects the seller and reassures the buyer The sale of the Amadea will be conducted on an   "As is, Where is"   basis, without warranty, with full transparency on the yacht’s legal status: free of any liens or mortgages, under the direct authority of the US Marshals.   Technical and operational inspections   are the responsibility of the candidates, which shortens deadlines and weeds out unprepared buyers.   The result: only committed actors capable of   closing quickly   remain in the race. A tight schedule From the official announcement to the closing of bids:  1 month flat This tight timing wouldn’t be possible without a  solid base of identified potential buyers A rigorous selection process To submit an offer: A deposit of  $10 million  before September 5 Signing a sales agreement and providing KYC documents Demonstrating the ability to pay the balance within less than a month A process that secures the seller 2nd and 3rd highest bidders are contacted immediately if the first withdraws Firm deadlines: 10 days for additional deposits, 28 days for full payment, 10 days for delivery For brokers The sale of the Amadea is also designed to attract serious intermediaries.   A   clear and advantageous commission   policy is in place: approved third-party brokers receive   50% of the gross commission , paid within two business days after the transfer of ownership. In summary:   Speed + Legal Security + Filtered Buyers = Guaranteed Success. This is the exact opposite of slow, legally uncertain, and poorly prepared judicial sales, to be forgotten, like the   Alfa Nero. It is also   a model to follow   for all judicial or sanctioned asset sales. What needs to be defended is a tailor-made process that guarantees speed, transparency, and legal security. This standard must be imposed in France   to make our country the European leader in the management and sale of seized yachts, with   a dedicated maritime asset team , professional methods, serious players, and concrete results. In short The Winning Recipe: High-end Marketing + Strict Selection + Speed + Legal Security for All Frozen Yachts Market : Read the article on LinkedIn

Two comparable yachts, two seizures, two doctrines When the judicial management of frozen or sanctioned yachts makes all the difference. Two exceptional yachts. Two seizures carried out in a comparable geopolitical context. Two radically different trajectories. The case of M/Y Phi , immobilised in London since March 2022, and that of M/Y Stefania , seized in France one year later and subsequently sold at auction, offer a striking comparative insight into the British and French approaches to the management of frozen, sanctioned or seized yachts. Two Comparable Yachts Length:  58.5 m (Phi) / 41 m (Stefania) Common naval architect Comparable year of construction  (2021–2022) Contemporary yacht designs  with high technological value Assets highly sensitive  in terms of maintenance, safety and environmental exposure From a technical and conceptual standpoint, Phi and Stefania are close cousins . It is precisely this similarity that makes the divergence in their respective trajectories so revealing. M/Y Phi – The British Counter-Example Immobilised brand new in March 2022 at Canary Wharf, in the heart of London, M/Y Phi  was immediately detained under the UK sanctions regime. Factual findings Immobilisation without a structured long-term maintenance plan Absence of a clear strategy to preserve asset value Progressive degradation of the vessel Loss of class, insurance and seaworthiness Proven technical and environmental risks To date, Phi remains in a state of quasi-operational abandonment , despite an initial estimated value of approximately €50 million . The prolonged detention — now upheld as lawful by the UK Supreme Court — has transformed an exceptional asset into a latent liability : financial liability, legal liability, environmental liability. M/Y Stefania – The French Counter-Model Seized in France more than one year after Phi, M/Y Stefania  followed a diametrically opposite path. Principles applied Proactive and centralised management of the seized asset Maintenance of class (RINA), ensuring continued insurability Secure and appropriate berthing arrangements Regular and controlled maintenance works Strict cost management Preservation — and subsequent enhancement — of patrimonial value Outcome Judicial sale successfully completed Asset preserved Valuation increased by approximately €2 million No major environmental risk Clear and definitive legal exit Two Doctrines, One Conclusion United Kingdom – Phi France – Stefania Approach Symbolic immobilisation Proactive management Maintenance Unstructured Organised and monitored Class / insurance Lost Maintained Value Erosion Preserved and enhanced Outcome Deadlock Judicial disposal The Phi / Stefania contrast demonstrates a fundamental reality: The success of a seizure is not measured by the act of freezing itself, but by the ability to manage the asset over time. France has developed a pragmatic, legally secure and economically rational approach , transforming seizure into a tool of control rather than a purely political gesture. A European Strategic Challenge Frozen and seized yachts now constitute: assets with high legal exposure, potential environmental risks, and a new field of economic and organised crime. Failing to structure their management means: destroying value, exposing States to litigation, weakening the credibility of sanctions regimes. Conclusion Phi and Stefania do not merely tell two yacht stories.They reflect two visions of public action . One freezes.The other organises, preserves and decides. Today, France has mastered the art of judicial maritime seizure .The remaining challenge is to turn this advantage into structured European leadership . Contact Emmanuelle VOTAT  – Judicial Yacht Asset Manager (France) - Specialist in seized maritime assets ev@yachting-legal-auction.com

The UK Supreme Court has now drawn a clear line: under UK law, a superyacht connected to Russia may be lawfully detained, even where its beneficial owner is not personally designated under sanctions. A new direction for frozen yachts under sanctions? Phi yacht delivered at Royal Huisman This ruling marks a turning point  in sanctions enforcement and for the yachting sector as a whole. Grounded in the Russia (Sanctions) Regulations 2019, it confirms the government’s wide margin of appreciation, allowing asset detention based on plausible economic connection and strategic impact , rather than strict individual designation. The Court expressly acknowledged the interference with property rights and private life under the European Convention on Human Rights. However, it held the detention to be proportionate , even in the face of documented deterioration, commercial loss, and environmental risk. Phi’s legal road in the UK ends here. The only remaining judicial avenue would now lie in Strasbourg, before the European Court of Human Rights. Beyond Phi itself, the decision sets a powerful precedent . It highlights the legal, operational and reputational exposure created by prolonged asset freezes in high-value, high-maintenance sectors such as yachting. More broadly, this Supreme Court-backed doctrine confirms a shift in the UK’s sanctions approach: broader, more assertive, and increasingly asset-centric , now standing in contrast with the more ownership-focused and conservative framework still prevailing across most EU jurisdictions. Key takeaway. Sanctions enforcement is no longer solely about names on lists. It is about networks, plausible influence, and the optics of ownership. For frozen maritime assets, this shift raises critical questions of value preservation, legal coherence, and environmental responsibility. Contact Emmanuelle VOTAT - Judicial Yacht Asset Manager (France) - Specialist in Seized Maritime Assets –  ev@yachting-legal-auction.com Frozen Yachts & Sanctions : Read the post on LinkedIn

Superyachts frozen under international sanctions are condemned to immobility and decay. This article outlines four concrete legal solutions to move beyond paralysis and transform frozen yachts into useful, responsible assets within a maritime justice framework. Frozen yachts maritime justic Here are four concrete avenues to move these frozen situations towards a form of confiscation that is useful, responsible… and meaningful. chts gelés justice maritime The yacht Amore Vero 85.6m / 280'10 | Oceanco | 2013 Building a legal bridge between sanctions and criminal law Today, freezing measures prevent use but do not transfer ownership. Criminal confiscation, by contrast, does. Why not open an autonomous investigation as early as the sanctions phase? Identifying the UBO (Ultimate Beneficial Owner), tracing the financing: if sufficient indicators exist, the path toward criminal seizure is open. Frozen yachts maritime justice Activating international criminal cooperation Offences are often transnational. A yacht frozen in Marseille could be confiscated in Milan, London or Paris, depending on which jurisdiction proves most effective — provided that investigative services, magistrates and judicial authorities cooperate without obstruction. Relying on non-conviction based confiscation (NCBC) This procedure exists in several countries and, since 2022, also in France. It allows the confiscation of assets of criminal origin even in the absence of a conviction of the owner. Yes, it is disruptive. But it is extremely effective in cases of economic and financial crime. When it is known that an asset is the proceeds of crime, must one really wait for an impossible conviction? Creating a specific judicial administration status Managing a yacht is not improvised. It is necessary to move away from the one-size-fits-all administration model — “seized car / Hermès bag / Rolex watch”: Create a 7th flag , under the supervision of the French International Register (RIF), to provide a legal framework for managing these “out-of-the-ordinary” vessels Establish a Department for Confiscated Maritime Assets Entrust management to yachting professionals , trained in seizure, administration… and disposal Conclusion Breaking the deadlock requires articulating criminal law, international cooperation and legal innovation. Behind every immobile hull lies a strategic value, ready to fund public, humanitarian or environmental policies. Still, one must dare to transform freezing measures… into active maritime justice . Frozen Yachts & Maritime Justice: Read the article on LinkedIn

Amadea: a Precedent Shaping Europe’s Frozen Yacht Market The sale of Amadea goes far beyond a prestige transaction. It marks a legal and operational turning point, proving that frozen yachts under international sanctions can be sold efficiently, transparently and in line with market standards. A precedent that could unlock a structured European frozen yacht market. Published in SuperyachtNews, 2025/10/24 Seasoned superyacht auctioneer, Emmanuelle Votat dissects the challenges and opportunities emerging from the latest development in the sanctions saga… 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, sale of frozen yachts, and has overseen landmark cases, including the sale of Stefania, which was confiscated in a major money laundering investigation. Crédit photo : The Department of Justice The sale of Amadea is far more than a prestige transaction. It marks a turning point for Europe, both legally and operationally. The chosen format - private sealed-bid auctions, “as is, where is” sale and a tight timeline, with no allowance for potential appeals or blockages - proved that luxury assets under international sanctions can be sold efficiently while meeting market standards and high-end buyer expectations. Sale of frozen yachts This precedent opens the door to a structured European frozen-yacht market, which is still largely dormant. Speed, transparency and operational rigour, combined with smart cooperation between justice authorities and brokerage professionals (Fraser Yachts), were key to the success. Amadea’s impact goes far beyond a single yacht. In France, Russian oligarch Suleyman Kerimov, the presumed owner, is facing a raid at Bercy as part of an investigation into real estate money laundering and suspicious tax schemes. According to Le Monde, the inquiry targets a portfolio of French Riviera villas valued at over €38 million, some linked to his daughter through complex corporate structures. The notable key figure is the €38 million in seized villas - a stark reminder that sanctioned yachts are not isolated cases, but part of a broader network of transnational financial investigations. This coordination of international sanctions and domestic law shows that Europe can now strike at the heart of opaque ownership structures, following the lead of the United States. Lessons for Europe While the Amadea sale sets a historic precedent, it is not a total victory. As noted in Superyacht News, the operation was executed efficiently, but uncertainties remain: the appeal by the presumed owner, Eduard Khudainatov, could delay legal closure and the sale price remains confidential, limiting transparency. The Amadea model is still replicable for Europe, where legal and operational gaps persist. This first transaction may be the first domino in establishing a functional frozen yacht market. The Khudainatov Web The case’s complexity is mirrored in Khudainatov’s links to other high-value yachts: • Sheherazade : 145-metre, Lürssen, $700 million, seized in Italy and linked to the Russian president by some anti-corruption activists. • Crescent : 135-metre “twin” Lürssen, seized in Spain and attributed to Igor Setchine. • Amore Vero : 86-metre Oceanco, frozen and also associated with Igor Setchine, the heart of the European issue. The French investigation into Kerimov highlights the direct connection between yachts and real estate, with the same networks, arrangements and cash flows crisscrossing both spheres. Freezes and confiscations are not a niche world, but they are part of the same fight against sprawling, opaque financial structures worldwide. Amadea , though not flawless, shows that operational courage exists and a path can be paved. The key question is who will successfully guide these frozen yachts to legal and financial safety, ensuring the precedent does not remain unfulfilled? Challenges and opportunities in Europe Challenges relate to an operational vacuum. Across Europe, proper structures are still missing. The fate of yachts like Phi or Luminosity illustrates that the risk of near-total value loss makes freezing measures almost pointless. In France and Spain, Russian owners can fund minimal upkeep despite sanctions. In Italy, the state bears responsibility for maintenance. The mayor of Trieste recently voiced frustration over Sailing Yacht A (€27 million frozen for 3 years), while the city struggles to maintain its historic tramway (€850,000 needed). The lack of harmonisation shows that the March 2022 freezes were reactive and improvised, without clear management, disposal strategy, or sustainable funding. European directives and initiatives Europe is already taking action, however. Directive (EU) 2024/1260 mandates that member states establish Asset Recovery Agencies (ARAs) by 23 November 2026. Their mission is to manage frozen assets, facilitate identification, seizure, and confiscation, and coordinate national and international efforts. Implementation, however, varies by country. Some states have yet to transpose the directive into law. The risk of administrative bottlenecks, maintenance delays, or counterproductive outcomes remains, highlighting the need for expert actors, as seen in the U.S., where yacht professionals are systematically involved. The French Example In France, concrete initiatives are emerging to manage and sell frozen yachts, aiming to secure their lifecycle while preserving value. This approach mirrors the proven Amadea model, ensuring transparency, neutrality and compliance with European directives. Such initiatives convert legal and operational gaps into market opportunities, reassuring stakeholders and protecting public interest. Amadea demonstrates that with organisation and determination, it can be done. But if Europe fails to adopt this approach, it risks being a mere spectator in a market where frozen yachts decay at the quay, local authorities are strained, industries suffer and sanctions lose their meaning. Amadea is the starting point. Europe must now set this standard. 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: AMADEA Builder: LÜRSSEN Launched: 2016 Delivered: 2016 Status: Delivered Length: 106.10m Beam: 16.80m Draught: 4.10m Gross Tons: 4402 Exterior Designer: Espen Oeino International

Another yacht sacrificed, despite a technically feasible transaction When frozen yachts under sanctions are left to deteriorate YachtHarbour The Echo of Phi  The UK judgment of July 29, 2025, in the   M/Y Phi case   sent a clear message:   freezing is not managing.   Immobilizing a technological jewel without a clear framework, without a dedicated team, and with no prospect of sale or value preservation is   no longer sustainable.  Another iconic vessel,   M/Y Luminosity,  has also been sitting idle in Tivat (Montenegro) since March 2022, stuck in a similar legal and political limbo. Luminosity, the glass megayacht forgotten by all Construction began in 2014: a 107.6-meter engineering challenge. With a nearly fully glazed superstructure (836 m² according to the shipyard, the largest surface area on any yacht), she was designed to create a unique space of light, air, and water. Originally valued at  €292 million , it was reportedly bought in 2022 by Russian oligarch Andrey Grigoryevich Guryev for €190 million  (LuxuryLaunches). She is frozen under international sanctions, yet without any formal judicial seizure. Phi & Luminosity:  Same immobilization without maintenance  Same judicial silence  Same loss in value for a practically new yacht When Luminosity arrived in Tivat in March 2022, her crew numbered around 30. But non-payment of salaries eventually reduced this to a minimal safety crew of around 5 people.   Freezing a yacht should not mean punishing its crew. And of course, 5 people can’t possibly maintain a 107-meter vessel. Luminosity is slowly dying: ceilings dismantled, hull rusting and overgrown with algae, chrome dulled, teak decks torn open. And let’s not forget the massive lithium batteries left unsupervised, posing   a very real safety risk. Sanctioning without structure = cascading deadlocks  There are currently three legal disputes before the Commercial Court in Montenegro involving Flying Cloud Overseas Ltd (the owning entity), facing claims from creditors, including an Italian marine supplier and Porto Montenegro Marina. These parties have obtained interim measures   blocking any sale or transfer of the yacht , as well as her departure from port ( Vijesti ).   Customs officials have even seized the official yacht documents to enforce these rulings. This tells us three things: The Luminosity   case proves that  a motivated sale can exist , even in parallel with legal blockages. But until litigation is resolved and sanctions are converted into a structured seizure framework, the yacht remains in limbo and  debt accumulates. And even a willing  buyer cannot proceed . From a political standpoint, this undeniably fuels criticism of sanctions as ineffective and even inhumane.  Luminosity illustrates, starkly, the counterproductivity of unmanaged sanctions. And yet, a transaction is possible What if, unlike Phi,  we anticipated ? What if, instead of waiting for chaos, we initiated a supervised transaction, aligned with the spirit of the   Asset Recovery Directive 2.0 ? Our goals:   Preserve the vessel’s value Legally structure the sale Guarantee transparency, neutrality, and efficiency Act in the public interest and for market stability Phi was left to deteriorate while waiting for judicial clarity,   which triggered a wave of anger from the yachting world . Luminosity could become a   constructive counter-example , a bridge between the authorities and the yachting industry.   And this industry is, in fact,   where the buyers for these frozen yachts exist. While sanctions aim to demonstrate strength, it is ironically an   administrative and legal laxity   that leaves these yachts rotting at dock, hemorrhaging value, and sinking further into spirals of debt. A structured solution is ready  A judicial sales framework for frozen yachts, compliant with the MOA and new EU directives, is ready. It details every step: from judicial ruling to ownership transfer, including surveys, documentation, liability releases, and escrow of proceeds. Luminosity could become the   first flagship case   of a smart, structured, extrajudicial sale, compliant with European law and economic common sense. The time to act is now Europe has spoken. So has the UK judiciary. It is now up to us to define a   responsible, ethical, and proactive path   for frozen yachts. Luminosity doesn’t need to rot at the dock. She can become a solution, and the symbolic launch of   Asset Recovery Directive 2.0 . To institutions, authorities, and professionals in the yachting world:   This is not a looming shipwreck, it’s an opportunity.   The Directive is waiting for us to bring it to life. And Luminosity to return to the sea. Contact Emmanuelle VOTAT - Judicial Yacht Asset Manager (France) - Specialist in Seized Maritime Assets –  ev@yachting-legal-auction.com   Frozen Yachts & Sanctions :   𝗠/𝗬 𝗟𝘂𝗺𝗶𝗻𝗼𝘀𝗶𝘁𝘆 - 𝟰 𝗬𝗲𝗮𝗿𝘀 𝗨𝗻𝗱𝗲𝗿 𝗦𝗮𝗻𝗰𝘁𝗶𝗼𝗻𝘀, 𝟰 𝗬𝗲𝗮𝗿𝘀 𝗼𝗳 𝗔𝗯𝗮𝗻𝗱𝗼𝗻𝗺𝗲𝗻𝘁 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.

The judicial management and sale of seized yachts require far more than passive immobilisation. By adopting an active, structured approach, France has turned asset seizure into a strategic tool, setting the foundations for a European model in maritime criminal asset management. Behind the media image of superyachts stranded in judicial limbo lies a far more demanding reality: managing a seized yacht is a complex technical, human and legal operation—one that few jurisdictions have truly chosen to confront. France has made that choice—and turned it into a lever for action. Gendarmerie Natiolale - 10 november 2023 in Antibes Managing a Seized Yacht: A Profession in Its Own Right The management of a seized yacht goes far beyond passive immobilisation or the mere payment of port fees. It involves preserving the asset’s value, anticipating substantial technical costs, mobilising specialised expertise, and integrating judicial timelines with the rhythm of the yachting market—all in strict compliance with criminal procedure. It is a profession in its own right . Long non-existent or underestimated, it is now structured in France as a full-fledged function, at the crossroads of criminal law, maritime law and international yachting market standards. From Immobilisation to Action The French approach breaks with the widespread practice of waiting for judicial outcomes, even if that means allowing yachts to deteriorate, lose value and generate mounting public costs. Here, seizure becomes an active process : qualification of the asset, valuation, coordinated technical and legal preparation, and disposal when the legal framework allows. The underlying logic is simple: seizure alone is not enough—assets must be managed and, when appropriate, sold. Stefania: A Case Study The sale of the yacht Stefania  illustrates this approach. It was based on rigorous valuation, coordinated preparation involving technical and legal experts , and a sales strategy aligned with the standards of the luxury yachting market. The outcome is not merely the successful disposal of an asset; it is a strong signal sent to both the market and international authorities, demonstrating that a seized yacht can be treated as a complex asset rather than an insoluble problem. A Revealing International Contrast Meanwhile, elsewhere in Europe, several emblematic cases remain stalled. Some yachts have become symbols of counterproductive immobilisation , others are mired in jurisdictional conflicts, while some remain suspended with no clear horizon. This contrast raises critical questions: inaction undermines asset value, weakens the effectiveness of sanctions, and imposes long-term burdens on public finances. Towards a European Model? The French experience opens a broader perspective: the emergence of a European model for the responsible management of luxury assets derived from criminal activity—not through excessive zeal, but through efficiency, respect for the rule of law and strategic vision. Ultimately, this is not only about yachts. It is about judicial sovereignty , international credibility, and the ability of States to transform procedural constraints into strategic action. In a world where asset flows move faster than judicial decisions, this capability may well represent one of the most tangible forms of public power.   Judicial Management and Sale of Seized Yachts: Read the post on LinkedIn