When execution succeeds but certainty fails Part III: The Sale of the yacht Amadea & the Case Several superyachts seized or immobilised since 2022 have now been sold. Buyers exist, even for vessels with a complicated past. Whether those sales hold over time, in other jurisdictions and against later challenges is a separate question. This series looks at three of them: Alfa Nero, Axioma and Amadea. All three were sold, and none offers a model that can simply be reused. Read together, they show a market that completes sales more easily than it secures them. Amadea differs from both Alfa Nero (link to Part I) and Axioma (link to Part II). The sale was organised, completed and, since June 2026, upheld by the US courts. It does not show a failure of title. The question it raises comes after the sale: how far a title transferred in one country is recognised elsewhere. A state-led sale Amadea was seized in Fiji in 2022 at the request of the US Department of Justice, as part of the US response to Russia's invasion of Ukraine, and taken to San Diego. In October 2023 the government filed a civil forfeiture complaint, alleging that the yacht belonged to Suleiman Kerimov, who is subject to US sanctions. Eduard Khudainatov, a former head of Rosneft, and his company Millemarin Investments, which held legal title, claimed ownership. In March 2025 the district court found that they were straw owners without standing to contest the forfeiture, and that the evidence pointed to ownership by members of Mr Kerimov's family. A judgment of forfeiture followed, and the court refused to suspend it pending appeal. The US Marshals Service then sold the yacht in 2025, by sealed bids and on an 'as is, where is' basis, with the support of Fraser Yachts. The sale was completed in the autumn. The Marshals confirmed it but did not disclose the buyer or the price. The yacht has since been registered in the Cayman Islands. Seen from the outside, the process had what a sale needs: a clear procedure, identified parties, an engaged market and a completed transfer. Litigation after the sale Mr Khudainatov's lawyers called the sale improper and premature, and appealed. On 1 June 2026 the Court of Appeals for the Second Circuit upheld the district court, holding that legal title alone did not give standing to contest the forfeiture. The appellate ruling substantially strengthened the legal position of the US authorities, although its precise procedural consequences must be distinguished from recognition of the sale abroad. His counsel had said they would keep fighting until the yacht was returned. Whether they will try elsewhere is not known. To our knowledge, no action outside the United States has been reported to date. The real issue: how far the title travels This is where Amadea matters. A sale can produce a valid transfer under the law of the country that ordered it without that transfer being recognised everywhere. A US forfeiture judgment binds US courts. Other countries decide for themselves, under their own rules, whether to give it effect. For a buyer, the risk is no longer that the sale fails. It is having to defend it again later: a claim brought in another jurisdiction, an attempted arrest in a foreign port, an insurer or a registry that hesitates. The Cayman Islands registration is an encouraging sign: a registry accepted a transfer made under US law. It remains the decision of one jurisdiction, not a recognition by all. Three fault lines Alfa Nero showed a sale that did not settle the question of title. Axioma showed a sound sale that still yielded about half of the value commonly attached to the yacht. Amadea shows a sale upheld in the country that ordered it, whose effects abroad have not yet been tested. The US appeal decision reduces the risk considerably. It does not remove it, because the questions that remain are not for the US courts to decide. The Beijing Convention A mechanism designed for this problem now exists. The United Nations Convention on the International Effects of Judicial Sales of Ships, known as the Beijing Convention, entered into force on 17 February 2026. It addresses a familiar difficulty: a vessel validly sold in one country whose buyer then faces challenges elsewhere, problems with deregistration, new arrests or parallel litigation. Its central tool is the certificate of judicial sale. The sale itself must confer clean title under the law of the state where it takes place. The certificate, issued once the Convention's conditions have been met, gives that sale the same effect in the other states parties. They may refuse recognition only where it would be manifestly contrary to their public policy. Its reach is still limited. The states parties are Barbados, El Salvador, Spain and Panama, the world's largest flag state, joined by the European Union within its areas of competence from 15 December 2026. Most signatories have not ratified. The United States is not a party, so Amadea could not have benefited. Whether sales following civil forfeiture proceedings fall within the Convention's scope depends on the legal structure of the sale and, in particular, whether its proceeds are made available to creditors as required by the Convention. The Convention does not yet answer the question Amadea raises. It points in a direction: a sale whose effects are recognised beyond the country that ordered it. Until that becomes the norm, these three cases leave the same question open: can a sale be considered complete if its effects do not travel with the vessel? Contact Emmanuelle VOTAT – Judicial Yacht Asset Manager (France) - Specialist in Seized Maritime Assets ev@yachting-legal-auction.com 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.

When execution succeeds but certainty fails Part II: The Sale of the yacht Axioma & the Case Several superyachts seized or immobilised since 2022 have now been sold. Buyers exist, even for vessels with a complicated past. Whether those sales hold over time, in other jurisdictions and against later challenges is a separate question. This series looks at three of them: Alfa Nero, Axioma and Amadea. All three were sold, and none offers a model that can simply be reused. Read together, they show a market that completes sales more easily than it secures them. Axioma is a very different case from Alfa Nero (link to Part I). The sale was completed, the title was not seriously contested, and the legitimacy of the process was never really in question. The interest of the case lies elsewhere, in what happened to the price within a procedure that worked. A creditor's sale in a sanctions context Axioma is often described as the first superyacht linked to a sanctioned Russian businessman to be sold after the invasion of Ukraine. That is correct, but it leaves out the legal basis of the sale, which was not the sanctions regime itself. The yacht, linked to Dmitry Pumpyansky, was detained in Gibraltar in March 2022, as asset freezes targeting Russian interests came into force. The sale was sought by JPMorgan. In December 2021, the bank had lent €20.5 million to Pyrene Investments, a company registered in the British Virgin Islands and owned through Furdberg Holding by Mr Pumpyansky, who guaranteed the loan. Axioma formed part of the security. According to JPMorgan, the sanctions put the loan in breach, as the bank could no longer lawfully accept repayments. It therefore enforced its security over the yacht. The sanctions made repayment impossible, and the mortgage gave the lender a route to recovery through the courts. A clear procedural framework This explains why Gibraltar could move quickly where other cases stalled. The yacht was arrested on an admiralty claim before the Supreme Court of Gibraltar and placed under the authority of the Admiralty Marshal. There was an identified creditor, a documented claim, a mortgage over the vessel and a court familiar with this kind of proceeding. Questions arose about the position of other authorities, the yacht being registered in Malta. The court ordered the sale to go ahead. Nothing here resembles the debate around Alfa Nero. Nobody disputed the status of the yacht, the validity of the law applied or the identity of the owner. The question was a practical one: how to sell a detained yacht in order to repay a secured creditor. The sale The court ordered the sale in the summer of 2022. The auction, by sealed bids, closed on 23 August and was run for the Admiralty Marshal by the broker Howe Robinson. It attracted 63 bids, and the broker spoke of a late surge of interest from buyers around the world. The leading bidders went through enhanced due diligence, and the sale was completed on 27 September 2022 for $37.5 million. The buyer's identity was not disclosed. The price was paid into court for distribution according to the ranking of claims. JPMorgan was expected to claim only the sum it was owed, and any surplus due to the owner was likely to remain frozen. The sale has not been challenged since. The yacht was refitted, returned to the charter market in 2025 and has since been offered for sale. The second fault line: price Before the sale, the figure most often quoted for Axioma was $75 million, the price at which she had been listed for sale some years earlier. Against that figure, $37.5 million represents a discount of about 50%. The comparison needs care. A former asking price is not a valuation at the date of the sale. And some observers expected far less: the lawyer who had represented the yacht before her detention predicted a price well below €20 million. Against those expectations, the result was a good one. Even so, a yacht sold through a sound procedure, with real competition and no dispute over title, fetched about half of the value commonly attached to her. The procedure secured the sale. It did not shield the price from the conditions of the sale: the need to sell, the political context, media attention, the association with a sanctioned name and the timetable of a court sale. What happened next After a refit carried out in La Ciotat in 2024 and 2025, Axioma is now offered for sale at €88.5 million. An asking price is not a sale price, and the refit had a cost. The difference is striking, although the current asking price cannot establish either the yacht's market value or the financial return achieved by its owner. The Axioma lesson Read alongside Alfa Nero, Axioma shows a different limit. In Alfa Nero, the difficulty lay in the title. In Axioma, the title passed without difficulty, and the question was the price. A legally robust procedure is not necessarily neutral in economic terms. It can secure the transfer without necessarily achieving a price comparable to that expected in an ordinary market transaction. When a sale has been completed and its title is secure, a further question remains: whether the yacht can move freely across borders afterwards. That is where Amadea offers a third perspective. Contact Emmanuelle VOTAT – Judicial Yacht Asset Manager (France) - Specialist in Seized Maritime Assets ev@yachting-legal-auction.com 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.

When execution succeeds but certainty fails Part I: The Sale of the yacht Alfa Nero & the Case Several superyachts seized or immobilised since 2022 have now been sold. Buyers exist, even for vessels with a complicated past. Whether those sales hold over time, in other jurisdictions and against later challenges is a separate question. This series looks at three of them: Alfa Nero, Axioma and Amadea. All three were sold, and none offers a model that can simply be reused. Read together, they show a market that completes sales more easily than it secures them. The three did not follow the same procedure. Axioma was sold by order of a court at the request of a secured creditor, Amadea after civil forfeiture proceedings in the United States. Alfa Nero was sold by the government of Antigua and Barbuda under a port law amended for the purpose. The word "judicial" covers all three only loosely, and the differences matter. Alfa Nero: a sale that did not close the case Of the three, Alfa Nero is the case where the public account is hardest to follow. The yacht was sold, yet the litigation went on. After the first buyer withdrew in 2023, the questions shifted from whether a sale could be completed to whether the title was sound, how the process was run and where the money went. From sanctions to sale Alfa Nero has been in Falmouth Harbour, Antigua and Barbuda, since February 2022, when she was held while the authorities checked whether her ultimate owner was subject to sanctions. The US Treasury identified the Russian businessman Andrey Guryev as the owner, which he denies. In early 2023, Antigua and Barbuda amended its Port Authority Act to allow vessels to be declared abandoned or hazardous, then taken and sold by the state. Alfa Nero was declared abandoned in March 2023 and the government took ownership in April. The US Treasury lifted the sanctions on the vessel to allow her sale. At the auction held on 16 June 2023, Eric Schmidt made the highest bid, about $67.6 million. Warren Halle came second, with $66 million. The first sale collapses The sale was never completed. Schmidt withdrew within weeks, as the sale became the subject of litigation. Several reports attributed his decision to the impossibility of obtaining a secure title. Two challenges were under way. Yulia Guryeva-Motlokhov, Andrey Guryev's daughter, claimed ownership through the structures that held the yacht, contested the declaration of abandonment and challenged the constitutionality of the 2023 amendment. Warren Halle sued the government, arguing that under the auction rules the yacht should have passed to him once Schmidt failed to pay within the time allowed, and claimed about $5.7 million in damages. The second sale In July 2024, the government sold Alfa Nero by private treaty for about $40 million. Northrop & Johnson represented the buyer, later reported to be the Turkish businessman Ali Riza Yildirim. The sale ended a costly layup for Antigua and allowed the crew's outstanding wages to be paid. According to the government, the proceeds were also to cover other debts linked to the yacht and part of the country's budget shortfall. The yacht has since been refitted and returned to the charter market. Litigation since the sale In Antigua, the High Court has heard the constitutional challenge to the 2023 amendment. As of spring 2026, judgment had not been delivered. In the United States, Ms Guryeva-Motlokhov has relied on 28 U.S.C. § 1782, which allows discovery in support of foreign proceedings, to seek banking records that she says would show how the sale proceeds were used. On 30 March 2026, the Court of Appeals for the Second Circuit upheld the quashing of subpoenas served on two US financial institutions, finding the intended use of the evidence too speculative. The court did not rule on the allegations themselves. A separate application has since been granted in Florida, where the proceedings are still open. The Antiguan government and the officials concerned contest these allegations. No court has found any wrongdoing. Three fault lines The first concerns title. Ownership is still contested, and the constitutionality of the law under which the yacht was taken has yet to be decided. The second concerns price. The difference between $67.6 million and $40 million is often read as the cost of legal uncertainty. Other factors played a part: another year of layup, maintenance costs, and a seller under pressure. The buyer's broker said himself that the yacht was worth more and that the government needed to sell. The third concerns the proceeds. Their use has been questioned in the US filings. These are allegations, and they have not been tested on the merits. The legal questions that remain Anyone contesting the sale has several possible arguments. The yacht may not have been genuinely abandoned, in which case the seizure itself is open to question. The 2023 amendment may be found unconstitutional, which could raise further questions about the legal basis of the seizure and sale. The gap between the two prices may be used to argue that the sale did not achieve fair value. And the lack of a detailed public account of the proceeds may be used to question how the process was managed. None of these arguments has so far led to a ruling against the sale. As long as they are pending, the case stays open. What Alfa Nero shows A sale can be completed without giving the market the legal certainty it expects. Alfa Nero has changed hands and is working again. The questions raised in 2023 are still before the courts. Their outcome may have implications for the legal assessment of the original seizure and sale, although the consequences for the current owner remain uncertain. What was missing was a framework recognised beyond Antigua, able to secure the transfer and limit challenges after the sale. The Beijing Convention on the international effects of judicial sales of ships, in force since February 2026, sets out to provide one. Antigua and Barbuda is not a party. And a sale by private treaty without the approval of a court, as in July 2024, would not have met the Convention's definition of a judicial sale in any case. The same weakness appears in other cases, in other forms. With Axioma, it bears less on title than on how the price was formed. That is the subject of the second part of this series. Contact Emmanuelle VOTAT – Judicial Yacht Asset Manager (France) - Specialist in Seized Maritime Assets ev@yachting-legal-auction.com 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.

Published in SuperyachtNews. Emmanuelle Votat reveals how a trophy has turned liability in the absence of a clearly defined exit strategy… Conor Feasey for SYN M/Y Tango, a 78-metre Feadship superyacht seized in Palma de Mallorca during a highly publicised FBI operation, remains one of the most striking and costly examples of a poorly anticipated seizure of a complex maritime asset. Seized in 2022 as a symbol of enforcement, Tango remains officially in service, yet key technical indicators suggest a growing disconnect between legal status and operational reality. A US seizure executed in Spain On 4 April 2022, Tango was seized as part of a joint operation between the FBI and Spanish authorities, at the request of the US Department of Justice (DoJ). The seizure was carried out pursuant to a warrant issued by a US federal court and forms part of a civil forfeiture proceeding. The yacht was targeted not only due to the status of its beneficial owner, Viktor Vekselberg – a Russian oligarch under US sanctions – but also in connection with alleged bank fraud, money laundering and sanctions evasion. This proves the process works, enabling the effective capture of a complex asset within an international framework. Filmed as a financial war trophy, the operation was intended to demonstrate that sanctions had real teeth. It also triggered an immediate consequence: responsibility for the asset’s upkeep shifted. Apparently still in service, according to Equasis Data from Equasis now provides a direct and factual snapshot of Tango. The yacht remains registered under the Cook Islands flag, with an unchanged status of ‘in service/commission’ since 2011. Tango’s particulars were last updated on 2 July 2025 and its management structure remains in place, with operations handled from Palma and ownership recorded through Arinter Management Inc. Taken in isolation, these elements describe an administratively active, identified and monitored asset, but this reading is incomplete. Equasis also indicates that the vessel’s classification with Lloyd’s Register has been withdrawn since 11 March 2022. The last renewal survey dates back to 23 April 2021, with the next one scheduled for 14 July 2026. Tango is not simply a seized yacht that is expensive to maintain, it’s a yacht which, while still officially ‘in service’, is moving away from the system designed to certify its value. In reality, a vessel without classification The loss of class does not necessarily imply that the vessel has deteriorated, it may result from administrative or contractual decisions. This point is central: for a yacht of this scale, it fundamentally alters how the asset is understood. Without active class, compliance becomes harder to assess, insurability may be more constrained, and any return to operation or sale requires enhanced technical due diligence. The P&I cover, reinstated in 2026, confirms that the vessel remains insurable. It also raises a more subtle question: under what conditions can an asset without active classification continue to be covered and at what cost? Tango is therefore not simply a seized yacht that is expensive to maintain, it’s a yacht which, while still officially ‘in service’, is moving away from the system designed to certify its value. A prolonged seizure with no clear exit Since its seizure, Tango has remained immobile, moored in one of the most expensive marinas in the Mediterranean, Club de Mar. Nearly four years later, this symbol has become something else entirely: one of the most costly cases of asset immobilisation in recent US economic enforcement history. This situation is not necessarily the result of a strict legal deadlock. Under US law, an early sale is possible. Courts may authorise an interlocutory sale, particularly where maintenance costs are high or the asset is likely to depreciate. However, the recent experience of M/Y Amadea shows that this option remains tightly constrained. In that case, a request for early sale was rejected in 2024, with maintenance costs deemed inherent to the nature of the asset. Only after significant developments regarding ownership was a sale ultimately authorised in March 2025. The fact that Tango has not yet been sold does not mean that the yacht cannot be; it suggests instead that several factors make such a decision difficult. The question of beneficial ownership, structured through offshore entities, remains central. The legal proceedings are still ongoing. A sale would not automatically resolve all operational frictions, there is also the risk that, should the case fail, the value of the asset would need to be returned. Finally, the political dimension reinforces caution. Tango is a US seizure executed outside US territory. It is a visible, emblematic and politically sensitive case of international cooperation. In principle, nothing prevents a sale but, in practice, everything works against it. The system allows early sale, although this rarely happens. Tango’s maintenance, ordered as part of the seizure, is borne by US taxpayers and amounts to approximately €10 million per year. From political symbol to federal liability In civil forfeiture proceedings, responsibility for maintaining the asset lies with the seizing authority. In Tango’s case, this means the United States must bear the cost. Several sources suggest cumulative costs exceeding €40 million since 2022. These figures should be treated with caution, but their scale is consistent with the maintenance requirements of a yacht of this category, originally valued at around €85 million. At the request of US authorities, the yacht was formally seized and classified under Spanish law as incautado [confiscated], rather than merely frozen. This classification resulted in an immediate transfer of financial responsibility to the requesting authority, the United States. Spanish maritime press, including Revista Mar, has been explicit: Tango’s maintenance, ordered as part of the seizure, is borne by US taxpayers and amounts to approximately €10 million per year. Who ultimately bears the cost? The question of final allocation remains open. If confiscation is granted, the proceeds of the sale will revert to the state and may, in theory, offset part or all of the costs incurred. This assumes, however, that the yacht’s value at the time of sale remains sufficient. If the proceedings fail, or are partially overturned, the situation becomes more uncertain. In such a case, it cannot be excluded that part of the costs will ultimately remain borne by the public. In practice, there is no guarantee that the expenses incurred will be fully recovered. A mismatch between legal time and maritime reality The case of Tango highlights a structural misalignment. Legal timelines unfold over extended periods, shaped by complex proceedings and appeals. The technical life of a yacht, by contrast, is continuous and governed by cycles of maintenance, certification and validation. When these timelines diverge, uncertainty emerges, not necessarily in the form of immediate deterioration, but over time in the form of reduced technical clarity, diminished asset value and declining market confidence. Nearly four years after its seizure, Tango continues to be funded with public money. It offers a clear lesson for authorities dealing with seized or sanctioned maritime assets A technical and patrimonial paradox Technically, Tango remains an exceptional yacht. Exceeding 2,000gt, powered by four MTU engines and capable of speeds above 21 knots, it fully meets the high standards of the Feadship market, with exterior design by Harrison Eidsgaard and a comprehensive specification including a counter-current pool, spa, beach club, outdoor cinema, owner’s deck, helipad and custom tenders. These characteristics continue to define Tango’s market positioning, but its value depends on what is not visible. Symbolically, Tango retains strong significance. Among the first yachts targeted under the US seizure campaign, it remains exposed at the heart of one of Europe’s leading yachting hubs, a floating billboard of Western enforcement. Financially, however, the yacht has become a precedent. A case study showing that a seizure not followed by a proactive, sale-oriented management strategy may cost more than leaving an asset frozen, without generating value or resolution. A lesson for future maritime asset sales Nearly four years after its seizure, Tango continues to be funded with public money. It offers a clear lesson for authorities dealing with seized or sanctioned maritime assets – a yacht is not an asset that can be stored indefinitely without strategy; it cannot simply be left at the back of a port. Inaction is rarely neutral, it is often the most expensive option. Without a robust legal, technical and financial framework, the seizure of a superyacht may become counterproductive, both in terms of value preservation and the credibility of sanctions enforcement. The real question is not whether such assets should be seized, but how they should be managed and sold within timelines that reflect maritime and market realities, while ensuring legal certainty and limiting the financial burden on the public. Tango may ultimately stand as a defining precedent: a trophy turned liability in the absence of a clearly defined exit strategy. Read the article in SuperYacht News : https://www.superyachtnews.com/owner/motoryacht-tango-out-of-system-but-still-in-service Contact Emmanuelle VOTAT – Judicial Yacht Asset Manager (France) - Specialist in Seized Maritime Assets ev@yachting-legal-auction.com 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.

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

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

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

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

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

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

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

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