Cases:
- US v. M/Y Amadea, 23-cv-09304, US District Court, Southern District of New York (Manhattan).
- Dalston Projects Ltd and others v Secretary of State for Transport UKSC/2024/0055

When the United States, United Kingdom, and other governments started to impose sanctions on Russian individuals in the wake of the Russian invasion of Ukraine in 2022 – to pressure the Russian government to cease actions in Ukraine – it would have been hard to imagine that one asset would prove to have seminal consequences on the foreign policy tool: the superyacht. This was the case in January 2025, where court proceedings on both sides of the Atlantic took place pertaining to Russian-owned vessels impounded by the US and UK authorities, respectively – the former with the intention of selling the seized yacht and directing the proceeds toward the cause, and the latter detaining the asset to send a message to “Putin and his cronies.” The court hearings illustrated the effectiveness of the sanctions measures put in place by the jurisdictions in question, how the changes in political regimes play a role, and who really paid the price.
AMADEA: Who’s to Keep?
In New York, the opening arguments for a mini trial-style hearing took place for Amadea, the 106-meter superyacht seized in Fiji in April 2022. The government took to the court to argue on the yacht’s proprietorship, a roadblock in the authorities’ plight to sell the vessel. However, the US remains resolute about the owner of the yacht: sanctioned Russian businessman Suleiman Kerimov. However, the issue lies with the involvement of another Russian businessman battling the U.S and proclaiming to be the true ultimate beneficial owner ever since he commissioned the yacht: Eduard Khudainatov.
Khudaintov, not sanctioned by the US, is the “straw owner” of Amadea, the Justice Department argues, to cover for Kerimov’s ownership status – although they explain that he should be responsible for its hefty fees – and has no legal grounds to fight for possession of the vessel. The Government believes that the yacht was sold to Kerimov in September 2021 through intermediaries, while Khudainatov only held the title of the yacht due to Kerimov’s previous sanction designation in 2018. Meanwhile, Khudainatov’s lawyer, Adam Ford, contends that the sale was never completed, but the agreement between the businessmen was on a loan.
Phi: Detained, Not Seized
Where the US is taking to court to prove who owns Amadea, there is no confusion on who exactly the proprietor of the 60-meter superyacht Phi is. The Dutch-built yacht was the subject of a recent Supreme Court Hearing in the UK; a Russian businessman who was never a UK sanctions target. Sergei Naumenko’s vessel has been imprisoned in London’s Canary Wharf since then UK Secretary of State for Transport (SST) Grant Shapps pursued a detention decision order in March 2022. Though Naumenko has not been designated under any sanctions lists, Shapps relied on the Russia (Sanctions) (EU Exit) Regulations 2019, which states that a mere connection with Russia in any way would constitute a detention. It was section 57D(1)(a) that has given Mr. Shapps the authority to exercise this decision. Since Phi is frozen, not seized, it can’t be sold, moved, or have its ownership transferred to the authorities.

What ensued in the next 3 years were long, unsuccessful attempts by Dalston Projects Ltd, the yacht’s company, to overturn the detention decision at the High Court and Court of Appeals. Naumenko contested the legality of the detention by leaning on the crutch of infringement of Article 1 of the first protocol to the ECHR, in addition to citing the decision as irrational under public law grounds. The Court of Appeal found there to be a lawful exercise of the SST’s power and a lawful, proportionate interference with Naumenko’s right to enjoyment.
Now, Naumenko turns to the UK’s highest judicial authority for a final chance at freeing the vessel. At the Supreme Court proceedings, lawyers representing Naumenko defended their belief that the decision to detain Phi was not exercised on solid evidence but was a “mere assumption” of Naumenko carrying ties to the Russian regime, while the UK Government defended the decision with the belief that Naumenko’s continued “economic activity” contributed to the Russian regime – a form of tacit acceptance. Naumenko was a “pawn” in Western Nation’s retribution against Russia, his lawyers remarked.
Stuck in the interregnum
Consequential to the fate of the yachts in question and the overall direction of the respective sanctions policies is the regime changes of both nations. In the US, Amadea’s seizure was exercised under the Biden Administration, who, at the time of enforcement, stated, “The United States and our Allies and partners around the world are ready to impose powerful sanctions on [and] export controls..” Fast forward to 2025, it stands to be seen how the US sanctions measures will be affected by the election of President Donald Trump. “I want to use sanctions as little as possible,” Trump stated as he is expected to review the effectiveness of the sanctions measures with scrutiny, according to the New York Times.
Over at the docklands, the state of Phi started to physically deteriorate due to the lack of maintenance on the vessel and its unfavorable location. Implorations to the relevant authorities to move the yacht to another marina in the UK fell on deaf ears. As the yacht risks falling out of class and losing insurance, the owner’s team has spent two years pleading with the UK government to move the yacht to another marina in the UK, South Hampton, a request hindered by changes in the Department of Transport, owing to the 2024 general election and appointment of the Labour Party, Captain Guy Booth told BOAT International back in November. and One question was raised on both Phi and Amadea. was who was handling the costs of maintaining these vessels.
Footing The Bill
Whether the vessel in question is currently imprisoned in London or San Diego, one crucial similarity arises: the taxpayer’s role in shouldering the mounting maintenance costs to keep these vessels afloat. For Amadea, these costs hover around the $600,00-750,000 range per month, according to various reports. The fees rack up to a total of $30 million thus far – an argument used by the US to request permission to sell the yacht in June 2024, a request denied by Judge Dale Ho, stating that these are the costs for an asset of this magnitude.“The government has not established that the Amadea’s maintenance costs are excessive so as to justify.”
The British taxpayer, meanwhile, is not currently burdened with the running costs as Naumenko is still liable for mooring and maintaining the yacht, costs that total around £3 million, according to The Times. However, given Phi’s dilapidated state, if Naumenko successfully challenges the detention decision, he will be able to recoup the expenses paid for the yacht, along with the price of the damage caused and loss of charter earnings, which, according to Booth, has climbed up to “tens of millions of pounds.” Responsible for these costs, coming from the Treasurey, will be the British taxpayer. While the taxpayer is free from Phi’s financial upkeep, they may feel the effects of the imprisonment in other ways: Phi may pose ecological hazards and environmental ramifications if not attended to. The yacht, unable to obtain protection and indemnity insurance due to the detention decision, would cause irreparable harm to its Canary Wharf surroundings should she catch fire or a leakage in the engine room transpire, said Captain Booth.
The Russian Buyer: Error 404
The deployment of the sanctions undoubtedly impacted the superyacht industry and the place of Russian buyers, hitherto a demographic that held a large share of yachts. As of 2024, according to The Superyacht Times Monaco Report, Russian buyers account for 7.1% of buyers for yachts 30 meters and above, a sizable drop from 8.7% of yachts owned in 2021. Their absence was quickly filled by other nationalities, according to Raphael Sauleau. “ “When the sanctions were imposed on Russian nationals and residents, we saw an influx of newcomers to the industry, which alleviated the fact that Russians were not able to transact any longer. That was largely compensated by the U.S. customer base and, to some extent, European and Middle Eastern customers.” Also affected were brokers who have relied on Russian clientele, Sauleau adds. “Companies that were predominantly dealing with Russian customers saw a big hit and struggled to recover, whilst others who have, and had, a healthy mix of clientele were not so impacted.“ Sauleau does not foresee a return to Russian individuals anytime soon.
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The Next Steps
Closing arguments for Amadea’s hearing will be held in February 2025, while the Supreme Court is expected to publish its ruling on the legality of Phi’s arrest in the coming weeks. The team behind Phi is already preparing their next course of action. “If we lose this case, then we’re already preparing all our options, including taking it to the European Court of Human Rights (ECHR),” Captain Booth told Superyacht News. Whether Phi gets to sail off the Thames or the US government is successful in proving Amadea’s owner, the objectives of these governments to deploy economic siege on Russia were undisputably felt, but perhaps not by the main target.