KleptoCapture Goes Out with a Splash

Despite the Justice Department's dismantling of inter-agency cooperation to enforce sanctions and combat corruption, cases begun before the change of regime continue to wend their way though the courts.

March 10, The U.S. District Court for the Southern District of New York granted the government’s motion to strike the ownership claim of Eduard Khudainatov and Millemarin Investments Ltd. concerning the Motor Yacht Amadea.

The court determined that, despite holding legal title, the claimants lacked actual possession, control, or financial interest in the yacht after September 2021. This finding led the court to classify them as “straw owners,” thereby lacking standing to contest the yacht’s forfeiture.

The court’s decision aligns with the U.S. Department of Justice’s (DOJ) allegations that sanctioned Russian oligarch Suleiman Kerimov was the true beneficial owner of the Amadea.

The DOJ asserted that Kerimov acquired the yacht in 2021 through a series of transactions involving shell companies, aiming to conceal his ownership. The DOJ further alleged that Kerimov and his associates violated U.S. sanctions by conducting over a million dollars in maintenance and operational transactions for the yacht through U.S. financial institutions without proper authorization.

The Complaint alleged that the superyacht,  beneficially owned by  Kerimov, was improved and maintained in violation of applicable sanctions against Kerimov and those acting on his behalf. The Amadea is forfeitable based on violations of U.S. law, including the International Emergency Economic Powers Act (IEEPA) and money laundering violations.

According to allegations in the Complaint, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Kerimov as a Specially Designated National (SDN) in April 2018 under IEEPA due to Russia's actions in Ukraine, which were deemed an extraordinary threat to U.S. national security. Kerimov never sought a license from OFAC for any transactions related to the yacht. On September 30, 2022, OFAC redesignated Kerimov as an SDN.

In September 2021, after his designation, Kerimov arranged to purchase the Amadea, gaining beneficial ownership through a series of transfers between shell companies designed to obscure his connection to the yacht. Between July and September 2021, ownership of the Amadea was transferred from Nereo Management Ltd. to Millemarin Investments Ltd., a newly incorporated entity, before being further transferred to Errigal Marine Limited to further conceal Kerimov's beneficial ownership.

Between October 2021 and the yacht’s seizure by Fijian authorities in April 2022, Kerimov and/or his family members took multiple trips aboard the Amadea, planned extensive renovations, and assumed full liability for its upkeep and operational costs. During this period, individuals and entities acting on Kerimov’s behalf accrued U.S. dollar-denominated expenses for the yacht’s maintenance and sent payments through the U.S. financial system in violation of sanctions.

The Amadea is currently under the control of the U.S. government in San Diego, California. According to court filings, the yacht, which requires approximately $1 million per month in maintenance costs, has been kept in conditions below the required maritime standards, causing potential depreciation and risks.

Task Force KleptoCapture, established to enforce sanctions and counteract Russian aggression, played a pivotal role in this case. Co-Director of the task force, Michael Khoo, emphasized the extensive cooperation across the U.S. government and with foreign partners in gathering evidence to establish Kerimov's interest in the yacht. Despite its dissolution in February 2025, ongoing cases initiated by the task force, such as the Amadea forfeiture, continue progressing through the legal system.

Finding dated 10 March 2025 [Link] Case 1:23-cv-09304-DEH