According to the allegations in the Complaint filed in Manhattan federal court:
In April 2018, 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.
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.
“The AMADEA is a highly complex motor yacht that requires specialized product knowledge for its sophisticated systems, and costs approximately $1 million USD monthly to maintain to proper standards,” according a petition filed by one of the putative owners in April.
“Petitioner understands that the AMADEA has been docked in San Diego for nearly the past year and maintained in a manner below the required maritime standards, which is causing significant risks and depreciation,” the petition reads.