Civil Forfeiture Complaint Filed Against $300 Million Superyacht Amadea Involved In Sanctions Evasion

Damian Williams, the United States Attorney for the Southern District of New York, and Michael Khoo and David Lim, Co-Directors of Task Force KleptoCapture, announced today the filing of a civil forfeiture complaint against the Motor Yacht Amadea, a 348-foot luxury vessel reportedly worth over $300 million.  The Complaint alleges that the superyacht, which is beneficially owned by Russian oligarch Suleiman Kerimov, was improved and maintained in violation of applicable sanctions against Kerimov and those acting on his behalf.  The Complaint alleges that the Amadea is forfeitable based on violations of U.S. law, including International Emergency Economic Powers Act (“IEEPA”), and money laundering violations.  

U.S. Attorney Damian Williams said: “The filing of this complaint exemplifies that the United States takes sanction evasion seriously and will use all tools at its disposal to ensure that sanctioned individuals are held accountable for their crimes.  I thank our partners with Task Force KleptoCapture as well as the dedicated prosecutors of this office for their important work holding Russian oligarchs responsible and aiding our allies in Ukraine.”

Co-Director of Task Force KleptoCapture Michael Khoo said: “The United States brings this action today after a careful and painstaking effort to develop the necessary evidence showing Suleiman Kerimov’s clear interest in the Amadea and the repeated misuse of the U.S. financial system to support and maintain the yacht for his benefit.  Getting to this point required extensive cooperation across the U.S. government and with foreign partners.  It underscores our resolve to undertake challenging, cross-border investigations and to send a message to Russian oligarchs and their enablers: if you flout the rule of law, you can expect to pay real and meaningful consequences.”

According to the allegations in the Complaint filed in Manhattan federal court today:[1]

On April 6, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated Kerimov as a Specially Designated National (“SDN”) under IEEPA in connection with its finding that the actions of the Government of the Russian Federation in Ukraine constituted an unusual and extraordinary threat to the national security and foreign policy of the United States.  In imposing sanctions, OFAC determined that Kerimov benefited from the regime of Vladimir Putin, President of the Russian Federation, and played a key role in advancing Russia’s malign activities.  As alleged, Kerimov never sought a license from OFAC authorizing any transactions including any transactions in connection with expenditures related to the yacht.  On or about September 30, 2022, OFAC redesignated Kerimov as an SDN.

In September 2021, following Kerimov’s designation by OFAC, Kerimov arranged to purchase the superyacht Amadea, contracting with the seller to receive use rights to the vessel even before Kerimov had completed payment or obtained title to the vessel.  Kerimov gained beneficial ownership of the vessel in or about September 2021 through a series of transfers between shell companies conducted in a manner designed to conceal his ownership of the yacht.  Between in or about July 2021 and in or about September 2021, beneficial ownership of the Amadea was transferred from the former title holder, Nereo Management Ltd., to Millemarin Investments Ltd., which was incorporated approximately 30 days before the sale.  Ownership of the Amadea was then transferred to Errigal Marine Limited, another newly incorporated company, which was used to obscure Kerimov’s beneficial ownership of the Amadea.  Beginning in October 2021 through the date the yacht was seized by Fijian authorities in April 2022, Kerimov and/or his family members took multiple trips aboard the Amadea, planned extensive renovations to the Amadea, made long-term plans for the Amadea’s travel schedule, and assumed all liability and responsibility for the Amadea’s upkeep and running costs.

During that time period, individuals and/or entities acting on Kerimov’s behalf accrued U.S. dollar-denominated costs necessary for the upkeep of the Amadea and sent or caused to be sent through the U.S. financial systems payments in satisfaction of those expenses, in violation of applicable sanctions.

The Amadea is currently under the control of the U.S. Government in San Diego, California, pursuant to a seizure warrant issued by the U.S. District Court for the District of Columbia, which was enforced by a court order issued by the Republic of Fiji following a request from the United States.  The United States is deeply grateful to the Fijian police and prosecutors whose perseverance and dedication to the rule of law made this action possible.

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Mr. Williams praised the outstanding investigative work of the FBI New York Field Office’s Eurasian Organized Crime Task Force.  Mr. Williams further thanked the Justice Department’s Office of International Affairs, as well as the U.S. Marshals Service, U.S. Embassy Suva, and the Department of State’s Diplomatic Security Service, for their assistance and cooperation in this investigation.

On March 2, 2022, the Attorney General announced the launch of Task Force KleptoCapture, an interagency law enforcement task force dedicated to enforcing the sweeping sanctions, export restrictions, and economic countermeasures that the United States has imposed, along with allies and partners, in response to Russia’s unprovoked military invasion of Ukraine.  The Task Force will leverage all the Department’s tools and authorities against efforts to evade or undermine the economic actions taken by the U.S. government in response to Russian military aggression.

This case is being handled by the Office’s Money Laundering and Transnational Criminal Enterprises Unit in partnership with the Criminal Division’s Money Laundering and Asset Recovery Section and the National Security Division.  Assistant U.S. Attorney Sarah Mortazavi and Trial Attorneys Joshua L. Sohn and Andrew D. Beaty are handling the investigation.

A civil forfeiture complaint is merely an allegation that money or property was involved in or represents the proceeds of a crime.  These allegations are not proven until a court awards a judgment in favor of the United States.