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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