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

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.