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https://www.justice.gov/usao-sdny/media/1320711/dl

Sanctions were too late being implemented. US Sec. of State Antony Blinken actually waived sanctions that had been mandated by the US Congress on Russia’s NordStream 2 pipeline. Blinken’s considered the prime architect of the Obama Administration’s failed reaction to Russia’s 2014 invasion of Ukraine. Even in Soviet times, the British, Europeans and Americans were involved in gold mining in the USSR. Without western technology and expertise, the Soviets weren’t able to get gold or oil out of the ground: “After 1925, gold began to assume its key role in Soviet development as a major earner of the foreign exchange required to pay for imports of foreign equipment and technology utilized in the industrialization program. Gold mining was, consequently, put in the vanguard of the Soviet mineral exploitation program: an effort characterized by Shimkin as ‘the merciless and insatiable Soviet quest for gold.’” (pp.92-94 Western Technology and Soviet Economic Development, 1917-1930, Antony Sutton). At the forefront of pushing for trade with the USSR was US Sec. of State Antony Blinken’s stepfather and mentor, Samuel Pisar. Antony Blinken’s been a blight on US foreign policy, in the White House and the US Senate, since the Clinton years. His stepfather, Samuel Pisar, was involved in the manipulation of US (and French) politicians and trade policy from ca 1960.

The son of Suleiman Kerimov, Said “Kerimov transfers his stake in Polyus to Foundation for Support of Islamic Organizations: Polyus ranks first among the world’s gold mining companies in terms of gold reserves and fourth in terms of production 13 MAY 2022, 18:37 MOSCOW, May 13. /TASS/. Said Kerimov transferred 100% of Wandle Holdings Limited, through which he owned 46.35% of Polyus gold mining company, to the Foundation for the Support of Islamic Organizations…” Read more here: https://archive.is/bpNhl
This was apparently done to allow continued trade on the London Stock Exchange. However, Polyus itself was sanctioned ca May 19, 2023, too, but people were given until August 17, 2023, to “wind down” purchases made prior to the 19th of May: https://ofac.treasury.gov/recent-actions/20230519 See Polyus under Russian sanctions: https://ofac.treasury.gov/selected-general-licenses-issued-ofac

“Payouts From Top Russian Gold Miner to Fund Islamic Charity After Sanctioned Billionaire Exits: Sanctioned Kerimovs gave Polyus stake to Islamic foundation: Foundation to use dividends for charity, repay debt… 19 May 2022, Bloomberg: “Created 10 years ago to support Islamic education, mosque construction and other causes, it will use payouts from the miner to repay debt…” https://www.bloomberg.com/news/articles/2022-05-20/russian-gold-miner-payouts-fund-islamic-charity-as-tycoon-exits

Excerpt from: “Treasury Sanctions Global Russian Military Supply Chain, Kremlin-linked Networks, and Elites with Western Fortunes, November 14, 2022:
SULEIMAN KERIMOV’S NETWORK

On September 30, 2022, OFAC designated Suleiman Abusaidovich Kerimov (Kerimov) pursuant to E.O. 14024 for being or having been a leader, official, senior executive officer, or member of the board of directors of the Government of the Russian Federation (GoR). OFAC had previously designated Kerimov on April 6, 2018 pursuant to E.O. 13661 for being an official of the GoR. Kerimov has also been sanctioned by Australia, Canada, the EU, Japan, New Zealand, Switzerland, and the United Kingdom (UK).

In June 2022, OFAC issued a Notification of Blocked Property to Heritage Trust, a Delaware-based entity in which Kerimov has a property interest. https://home.treasury.gov/news/press-releases/jy0841 As of June 30, 2022, Heritage Trust held assets valued at over $1 billion. OFAC’s extensive enforcement investigation revealed that Kerimov used a network of relatives, advisers, and opaque legal entities to invest in the United States and utilized a complex series of legal structures and front persons to obscure his interest in Heritage Trust. In May 2022, Fijian law enforcement executed a seizure warrant freezing the Motor Yacht Amadea, a 348-foot luxury vessel owned by Kerimov. https://www.justice.gov/opa/pr/300-million-yacht-sanctioned-russian-oligarch-suleiman-kerimov-seized-fiji-request-united

Today’s action targets a broad network of Kerimov’s family members, associates, and facilitators. These designations should serve as another warning that those who support sanctioned Russian persons risk being sanctioned themselves. 

KERIMOV’S FAMILY
Today OFAC designated Kerimov’s immediate family, including his wife Firuza Nazimovna Kerimova (Firuza), daughters Gulnara Suleymanovna Kerimova (Gulnara) and Amina Suleymanovna Kerimova (Amina), and son Said Suleymanovich Kerimov (Said) pursuant to E.O. 14024 for being a spouse or adult child of Kerimov. Said has also been sanctioned by the EU, Switzerland, and the UK.

OFAC also designated four France-based real estate companies belonging to Gulnara: Service Immobiliere Antibes SAS, Service Immobiliere et Gestion SAS, VH Antibes SAS, and Villa Lexa Estates SAS. All four companies were designated pursuant to E.O. 14024 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Gulnara. 

Relatedly, OFAC designated Swiss national Laurin Katz (Katz), who serves as president of all four of Gulnara’s France-based companies. Katz was designated pursuant to E.O. 14024 for having acted or purported to act for or on behalf of, directly or indirectly, Gulnara.

Additionally, Alstone Investment AG (Alstone), a Switzerland-based firm formerly known as Swiru Holding AG, was designated pursuant to E.O. 14024 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Katz. 

Beyond Kerimov’s immediate family, OFAC also designated Kerimov’s nephew Nariman Gadzhievich Gadzhiev (Gadzhiev), a Russian national residing in Switzerland. Gadzhiev is a primary financial facilitator for Kerimov. Gadzhiev was designated pursuant to E.O. 14024 for having acted or purported to act for or on behalf of, directly or indirectly, Kerimov.

OFAC also designated United Arab Emirates-based holding company Constellation Advisors Ltd for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Gadzhiev.

ALEXANDER-WALTER STUDHALTER NETWORK
Swiss national Alexander-Walter Studhalter (Studhalter) has been a key player in Kerimov’s financial network, including managing Kerimov’s companies. Studhalter has also allegedly laundered significant amounts of money on Kerimov’s behalf. Studhalter was designated pursuant to E.O. 14024 for operating or having operated in the management consulting sector of the Russian Federation economy.

OFAC also designated eight entities across six countries associated with Studhalter. These include: 
* MG International AG (MG International), a Studhalter-owned, Switzerland- and Russia-based management consultancy firm of which Kerimov used to be a shareholder and where Gulnara was previously employed;
* Studhalter International Group AG (Studhalter Group), a Switzerland-based financial company;
* Swiss International Advisory Group AG (SwissIAG), a Switzerland-based accounting and tax consultancy firm; 
* Papa Oscar Ventures GmbH (Papa Oscar Germany), a Germany-based holding company;
* Eurimo Holding SA (Eurimo), a Luxembourg-based holding company;
* Papa Oscar Ventures SE SL (Papa Oscar Spain), a Spain-based holding company; 
* Swiss International Real Estate Portfolio AG (SwiREP), a Switzerland-based real estate firm; and
* SCI AAA Properties (SCI), a France-based real estate firm. 

MG International was designated pursuant to E.O. 14024 for operating or having operated in the management consulting sector of the Russian Federation economy. Studhalter Group, SwissIAG, Papa Oscar Germany, Eurimo, Papa Oscar Spain, SwiREP, and SCI were all designated pursuant to E.O. 14024 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Studhalter.

Studhalter’s sons, Jeremy Eric Camille Studhalter and Hugo Ange Christophe Studhalter were both designated pursuant to E.O. 14024 for being or having been leaders, officials, senior executive officers, or members of the board of directors of SwissIAG, an entity whose property and interests in property are blocked pursuant to E.O. 14024.

MURAT ALIEV NETWORK
Additionally, OFAC designated Russian businessman and investor Murat Magomedovich Aliev (Aliev), a former executive at a Kerimov investment firm, who has links to Studhalter. 
For example, Aliev’s Moscow-based investment firm Limited Liability Company Bonum Capital (LLC Bonum Capital) is located in the same Moscow building as MG International’s Russian branch. Swiss national Inga Rettich (Rettich) is another link between Studhalter and Aliev. Rettich, who manages the family office at SwissIAG, is also a director at Bonum Capital Cyprus Ltd (Bonum Cyprus), an Aliev-owned Cyprus-based holding company.
 
Aliev was designated pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy. LLC Bonum Capital was designated pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy and for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Aliev. Bonum Cyprus was designated pursuant to E.O. 14024 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Aliev. Rettich was designated pursuant to E.O. 14024 for being or having been a leader, official, senior executive officer, or member of the board of directors of Bonum Cyprus, an entity whose property and interests in property are blocked pursuant to E.O. 14024.

OFAC also designated the following five companies associated with Aliev:
* Bonum Capital Investors Corp (Bonum BVI), a British Virgin Islands-based holding company;
* Limited Liability Company Bonum Management (Bonum Management) and Limited Liability Company Bonum Investments (Bonum Investments), Russia-based financial services companies; 
* Limited Liability Company RB-Esteit (RB-Esteit), a Russia-based real estate firm; and
* Limited Liability Company Aviakompaniya Dalnevostochnaya KSM (KSM), a Russia-based air freight company.

Bonum BVI, Bonum Investments, and KSM were all designated pursuant to E.O. 14024 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Aliev. Bonum Management was designated pursuant to E.O. 14024 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Bonum Cyprus. RB-Esteit was designated pursuant to E.O. 14024 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Bonum Investments.

KERIMOV-LINKED LUXURY AVIATION COMPANY
Malta- and Russia-based aircraft management company Emperor Aviation Ltd (Emperor Aviation) has coordinated luxury travel for Kerimov’s immediate family, including Gulnara, even after Russia launched its full-scale invasion of Ukraine on February 24, 2022. 

Emperor Aviation was designated pursuant to E.O. 14024 for operating or having operated in the aerospace sector of the Russian Federation economy and for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Gulnara. 

OFAC identified eight aircraft as blocked property in which Emperor Aviation, the operator of the luxury planes, has an interest:
* 9H-AMN, a Bombardier BD-700-1A11 (Manufacturer’s Serial Number (MSN) 9324)
* 9H-ARK, a Bombardier BD-700-1A10 (MSN 60011)
* 9H-EAA, a Cessna Citation XLS+ (MSN 6170)
* 9H-MAO, a Bombardier BD-700-1A10 (MSN 9223)
* 9H-OKO, a Gulfstream G650 (MSN 6356)
* 9H-SIS, a Bombardier Challenger (MSN 6050)
* 9H-SSK, a Gulfstream G650 (MSN 6195)
* 9H-TIO, a Bombardier BD-700-1A10 (MSN 9813)
Concurrent with the designation of Emperor Aviation, OFAC issued General License (GL) 40C.  

GL 40C authorizes certain transactions involving blocked entities, including Emperor Aviation, that are ordinarily incident and necessary to the provision, exportation, or reexportation of goods, technology, or services to ensure the safety of civil aviation, provided that the aircraft is registered solely outside of the Russian Federation and the goods, technology, or services provided, exported, or reexported are for civilian aviation purposes…” Read more here: https://home.treasury.gov/news/press-releases/jy1102

“The Yacht Collector: Russian Tycoon Linked to ‘Putin’s Yacht’ Fights Straw-Owner Claim In U.S. Court  January 09, 2024 15:19 GMT By Maja Zivanovic and Carl Schreck RFERL https://www.rferl.org/a/russia-superyachts-tycoon-putin-straw-owner-amadea-khudainatov/32767397.html

The Amadea is a $325 million super yacht docked in the U.S. Pacific coast port of San Diego, seized by the U.S. government as the property of sanctioned Russian billionaire Suleiman Kerimov.

Now, another Russian tycoon is fighting in U.S. federal court to recover the luxury vessel, claiming that he is the Amadea’s real owner.

A Manhattan federal court on January 10 is set to hold an initial pretrial conference in the U.S. government’s civil forfeiture action against the Amadea, which Eduard Khudainatov, a former CEO of the Russian state oil giant Rosneft, has filed an ownership claim to in the case.

An FBI affidavit describes Khudainatov as a proxy used to conceal Kerimov’s ownership, and a central issue in the action will be determining which of the two is the luxury vessel’s actual owner.

The Amadea is not the only super yacht for which Khudainatov, who has been sanctioned by the European Union but not the United States, is alleged to be a straw owner. Khudainatov also says he owns a $700 million yacht, the Scheherazade, impounded in Italy that Russian opposition activists allege is really owned by Russian President Vladimir Putin.

In addition, the 63-year-old tycoon says he owns the Crescent, a 135-meter super yacht that has been described as the Scheherazade’s “sister ship.” That yacht was seized in Spain and is alleged to belong to Kremlin-insider and current Rosneft CEO Igor Sechin.

A spokesman from Vermillion Advisors, a U.S. strategic communications firm that Khudainatov has hired, told RFE/RL its client is the true owner of all three impounded super yachts. https://efile.fara.gov/docs/7338-Exhibit-AB-20231022-1.pdf

The case comes amid efforts to punish Russia’s ruling elite by targeting assets they control in the West — often through complex legal structures and proxy owners — that the United States and EU members have ramped up following Putin’s full-scale invasion of Ukraine in February 2022.

‘A Clean, Unsanctioned Straw Owner’

The Amadea was handed over to U.S. authorities in June 2022 following a court ruling in Fiji, which had seized it two months earlier. It was transported to San Diego, where it has remained ever since. https://www.justice.gov/usao-sdny/pr/civil-forfeiture-complaint-filed-against-300-million-superyacht-amadea-involved

The vessel is described by the website SuperYachtFan as “among the largest yachts globally” with “unparalleled luxury and comfort for up to 18 guests.” With a crew of 36, the Amadea boasts a helicopter pad, a pool, a jacuzzi, and “a stunning winter garden on the sun deck.”https://www.superyachtfan.com/yacht/amadea/

Despite Khudainatov’s claims to ownership, the U.S. government argues the luxury vessel in reality belongs to Kerimov, who has close ties to Putin and was hit with U.S. sanctions in 2018 in response to Russia’s “malign activity around the globe.”https://home.treasury.gov/news/press-releases/sm0338

While the Manhattan federal court case focuses on the 106-meter Amadea, U.S. authorities have cited Khudainatov’s alleged role as a straw owner of a second super yacht linked to Putin himself.

https://x.com/CharterWorld/status/1248185151064072192

That vessel, the Scheherazade, was seized by Italy in May 2022 and remains docked there. “The fact that Khudainatov is being held out as the owner of two of the largest super yachts on record, both linked to sanctioned individuals, suggests that Khudainatov is being used as a clean, unsanctioned straw owner to conceal the true beneficial owners of these vessels,” an FBI affidavit filed in the Fiji court proceedings stated.

In addition, a June 2022 investigation by the Organized Crime and Corruption Reporting Project and Forbes magazine concluded that Khudainatov was also the straw owner of a 135-meter super yacht called the Crescent that is allegedly owned by Sechin, one of Putin’s closest associates since the president’s days in the St. Petersburg mayoral administration in the 1990s. https://www.forbes.com/sites/giacomotognini/2022/06/13/meet-the-russian-billionaire-whos-the-proxy-owner-of-vladimir-putin-500-million-yacht-eduard-khudainatov/

The $600 million Crescent was impounded in Spain in March 2022. https://www.nytimes.com/2022/03/16/world/europe/russian-oligarch-yacht-spain.html

‘More Than $1 Billion’

Khudainatov has long been associated with Sechin, and Forbes last year estimated he was worth “at least $2 billion,” attributing the origins of his wealth to “decades-long relationships with Putin and Sechin.”https://www.forbes.com/sites/giacomotognini/2022/06/13/meet-the-russian-billionaire-whos-the-proxy-owner-of-vladimir-putin-500-million-yacht-eduard-khudainatov/?sh=1dc733561a53

In October 2023, U.S. federal prosecutor Damian Williams and the Justice Department’s unit tasked with enforcing sanctions imposed after Russia’s February 2022 full-scale invasion of Ukraine filed a civil-forfeiture complaint against the Amadea.

The complaint alleged the yacht was improved and maintained in violation of applicable sanctions against Kerimov and those acting on his behalf. https://www.justice.gov/usao-sdny/pr/civil-forfeiture-complaint-filed-against-300-million-superyacht-amadea-involved

Khudainatov, however, argues he and his British Virgin Islands-based company Millemarin Investments Ltd. are the Amadea’s real owners. His spokesman told RFE/RL that he commissioned the design and construction of the yacht in 2012.

An FBI affidavit submitted in the Fiji proceedings, however, stated that based on the interviews within the yacht-brokerage community, an inspection of the Amadea was arranged for Kerimov in late 2020 or early 2021, and Kerimov toured the yacht personally. https://web.archive.org/web/20230405175032/http://interactive.cbs8.com/pdfs/Affidavit-of-Timothy-Bergen-filed-on-25-04-2022-Copy.pdf

Several Amadea crew members identified Kerimov as the true owner of the yacht, and others described seeing Kerimov’s family using it on multiple occasions, the FBI affidavit stated.
The affidavit alleges the Amadea was the subject of a 2021 sale to Kerimov by a company with a history of “concealing yacht ownership behind nested shell companies and listing a straw, unsanctioned individual as the beneficial owner behind the shell companies, in order to conceal the true beneficial owner.”

The FBI special agent said in the affidavit that he believes Khudainatov became a straw beneficial owner of the Amadea in order to conceal Kerimov’s ownership.

Khudainatov’s lawyers claimed in a court filing that the Amadea had been rented to Kerimov’s daughter, Gulnara Kerimova, but that her father was not present during these trips. They also described Khudainatov’s “investments” in “over $1 billion in megayachts alone” as “a fraction of his overall wealth.”

The Scheherazade And The Crescent

Evidence attached to the FBI affidavit in the Fiji proceedings shows the Amadea was managed by the Monaco-based Imperial Yachts, which was hit with sanctions last year by the U.S. Treasury Department. The department said the company “provides yacht-related services to Russia’s elites, including those in President Putin’s inner circle.” Washington also imposed sanctions on the Russian CEO of Imperial Yachts, Yevgeny Kochman.

Imperial Yachts also oversaw the construction of the 140-meter Scheherazade, which the team of imprisoned Russian opposition politician Aleksei Navalny claimed belongs to Putin. https://www.rferl.org/a/putin-superyacht-scheherazade-sanctions/31838117.html

In August 2023, Maria Pevchikh, the investigations director of Navalny’s Anti-Corruption Foundation, published a series of posts on Twitter (now called X) about a yacht called the Graceful, an 82-meter, $100 million vessel in which, according to U.S. authorities, Putin “has an interest.” In a photo purporting to show Putin’s office aboard the Graceful, she identified a model on a shelf in the background as a representation of the Scheherazade. https://twitter.com/pevchikh/status/1694355373182886225 https://home.treasury.gov/news/press-releases/jy0802

When it was impounded in May 2022, the Scheherazade was owned by a Khudainatov-controlled company in the Marshall Islands called Bielor Asset Ltd.

Eduard Khudainatov

Imperial Yachts told RFE/RL in March 2022 that it “has no relationship with Bielor” and that the company’s involvement with the Scheherazade ended with its delivery in June 2020. https://www.rferl.org/a/putin-yacht-investigation-kremlin-links/31767345.html
A spokesman for Khudainatov told RFE/RL that the Russian tycoon “owns the Scheherezade.”

The spokesman said Khudainatov “does not have any relationship” with Putin. The Kremlin did not respond to a request for comment.

An earlier RFE/RL investigation found that a senior Russian crew member on the Scheherazade previously worked for a Russian yachting company that secured millions of dollars in contracts from the Federal Protection Service (FSO), the agency responsible for Putin’s personal security and whose officers have allegedly served on the crew of the yacht. https://www.rferl.org/a/putin-yacht-investigation-kremlin-links/31767345.html

While impounded, the Scheherazade is being refitted by an unnamed, but sanctioned, owner, according to an August 6 report by the Financial Times. https://www.ft.com/content/8b2061da-cbb7-43b9-87f5-64ef97c3e35c
RFE/RL’s Todd Prince contributed to this report
Maja Zivanovic 
Maja Zivanovic is an investigative journalist based in Prague.
Carl Schreck 
Carl Schreck is an award-winning investigative journalist who serves as RFE/RL’s enterprise editor. He has covered Russia and the former Soviet Union for more than 20 years, including a decade in Moscow. He has led investigations into corruption, cronyism, and disinformation campaigns in Russia and Central Asia, as well as on poisoning attacks against Kremlin opponents and assassinations of Iranian exiles in the West. Schreck joined RFE/RL in 2014.
Copyright (c) 2024 RFE/RL, Inc. Reprinted with the permission of Radio Free Europe/Radio Liberty” https://www.rferl.org/a/russia-superyachts-tycoon-putin-straw-owner-amadea-khudainatov/32767397.html

Excerpt from Kerimov Wikipedia article: “As markets around the world began to tighten in 2007, Kerimov and his associates expected that Russia would suffer more than the West from the impending economic crisis.[9] A concerted effort was thus made to build closer ties with Western banks. Kerimov decreased his stakes in Gazprom and other Russian blue chips and approached Wall Street, proposing to invest the vast majority of his fortune to defend the institutions from short-sellers.[9] In return, it was expected that Kerimov would receive favorable lending terms for future loans.[9] In 2007, Kerimov invested billions in Morgan Stanley, Goldman Sachs, Deutsche Bank, Credit Suisse and other financial institutions.[42] Though neither Kerimov nor the Western banks have disclosed the exact size of his investment, it was sizeable enough for Kerimov to receive a call from the United States Treasury during the darkest days of the economic crisis imploring the Russian oligarch not to sell his stakes.[43]”https://en.wikipedia.org/wiki/Suleyman_Kerimov
Reference 42: “Suleiman Kerimov & family” $10.7B Real Time Net Worth as of 5/23/24
#204 in the world today https://www.forbes.com/profile/suleiman-kerimov-family/

Polyus: https://en.wikipedia.org/wiki/Polyus_(company)

https://web.archive.org/web/20230207145004/https://polyus.com/en/media/press-releases/changes-in-shareholder-structure-and-board-composition/

“PRESS RELEASE
Civil Forfeiture Complaint Filed Against $300 Million Superyacht Amadea Involved In Sanctions Evasion
Monday, October 23, 2023
For Immediate Release
U.S. Attorney’s Office, Southern District of New York
Complaint Seeks Forfeiture of Amadea Superyacht Owned by Sanctioned Russian Oligarch Suleiman Kerimov
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.
*                *                *
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.

[1] As the introductory phrase signifies, the Complaint and the description of the Complaint set forth herein constitute only allegations, and every fact described should be treated as an allegation.

Updated October 23, 2023
Attachment: U.S. v. Amadea Civil Forfeiture Complaint [PDF, 584 KB] https://www.justice.gov/usao-sdny/media/1320711/dl
Topic
ASSET FORFEITURE
Component
USAO – New York, Southern
Press Release Number: 23-364” https://www.justice.gov/usao-sdny/pr/civil-forfeiture-complaint-filed-against-300-million-superyacht-amadea-involved

“Yacht docked in US port symbolizes struggle to convert seizures into cash for Ukraine May 22, 2024 3:38 PM By Matthew Kupfer, Oleksii Kovalenko, Natasha Mozgovaya
EVERETT, WASHINGTON/WASHINGTON, DC — 
When a superyacht worth $230 million pulled into the port of Everett, Washington, for repairs last month, it made a big splash in the city of 110,000 residents.

The 106-meter luxury behemoth known as the Amadea is currently in possession of the U.S. government, which alleges the yacht belongs to sanctioned Russian oligarch and politician Suleyman Kerimov, an ally of Russian President Vladimir Putin.

Looking out over the port, Everett resident Bob Templeton wondered who was paying for the superyacht’s upkeep. “They ought to sell it to somebody and get a lot of money,” he told VOA with a laugh.

Easier said than done. Templeton’s offhand remark cuts to the core of a dilemma faced by the United States as it attempts to use sanctions to rein in Russian aggression against Ukraine.

The U.S. government has moved to take ownership of the Amadea through a legal procedure called civil forfeiture. The end goal is to sell the vessel and transfer the proceeds to Ukraine.

But another Russian businessman, who is not under sanctions, has challenged that move, claiming that he is the Amadea’s true owner.

As the courts try to sort out the yacht’s ownership, U.S. taxpayers are footing the bill: over half-a-million dollars a month for maintenance.

And the complex legal battle could drag on for a long time, increasing the costs for the U.S. and delaying any benefit to Ukraine from the yacht’s seizure, according to Stefan Cassella, a former U.S. federal prosecutor and expert in civil forfeiture.

“Nobody who is a sanctioned oligarch owns anything in his own name,” he said. “You have an entire zoo of third parties who claim they own the property.”

Kerimov did not respond to a request for comment. The U.S. Department of Justice declined to comment.

Kleptocapture win

In May 2022, just months after Russia launched its full-scale invasion of Ukraine, law enforcement in Fiji seized the Amadea at the request of the U.S. government.

That was a major victory for Task Force Kleptocapture, a unit of the U.S. Department of Justice created in the wake of the Russian invasion to enforce sanctions.

But completing the job has proved more complicated.

Since the 1980s, civil forfeiture has been the Department of Justice’s go-to tool for targeting drug dealers, the mafia and money laundering operations, according to David Smith, a former DOJ prosecutor who pioneered the practice.

It allows law enforcement to seize assets without convicting their owner of a crime. All that prosecutors must prove is that the assets were used in a crime, profited from a crime or resulted from criminal activity.

But when that crime is a sanctions violation, proving the asset is owned by a sanctioned person is critical.

Lawyers representing the company that owns Amadea have claimed the yacht actually belongs to Eduard Khudainatov, a former CEO of the Russian state oil company Rosneft, who is not subject to sanctions.

He and his legal team say the seizure is unlawful and based on a “misleading” FBI affidavit.
“Eduard Khudainatov is, and always has been, the rightful owner of the Amadea. The Biden Administration’s unconstitutional seizure of the vessel was based on demonstrable falsehoods that we will establish in court,” his spokesperson said in a statement to VOA. “The government asserts factual and legal theories that are divorced from forfeiture sanctions and money laundering laws, and unsupported by the cases interpreting those laws. This boondoggle is nothing more than political theater that has cost American taxpayers more than $20 million to date.”

The U.S. government disagrees, referring to Khudainatov as a “straw owner” of the Amadea.
According to prosecutors, Khudainatov is “supposedly the beneficial owner of at least eight yachts or yacht projects” — a fleet valued at over $1 billion. They include a yacht that prosecutors state is actually owned by Igor Sechin, the sanctioned incumbent CEO of Rosneft and a Putin ally.

Journalists have linked another one of the superyachts, the Scheherazade, to Putin himself. In May 2022, it was impounded in Italy. https://www.npr.org/2023/08/07/1192548262/superyacht-tied-to-putin-russian-president-scheherazade-italy-who-paying

While Khudainatov’s lawyers were unable to prevent the Amadea’s transfer to the United States, they are currently fighting forfeiture in a New York court.

The DOJ states that Kerimov purchased the yacht in 2021, three years after he was added to sanctions list. Prosecutors allege that the oligarch or his proxies routed dollar transactions through U.S. financial institutions to maintain the Amadea, which would constitute a sanctions violation.

But proving Kerimov’s ownership — and disproving Khudainatov’s claim — is no simple task.
Assets like superyachts are often owned through a series of proxy owners, offshore companies and trusts. These entities are often registered in jurisdictions chosen for their secrecy.

Cassella, who has studied the case, says that Khudainatov’s legal team is dragging out proceedings, while the U.S. government is trying to compel him to answer questions and provide documentation that would prove he is not the Amadea’s owner.

“This is civil forfeiture defense 101 for anybody who’s got an infinite amount of money to pay lawyers to oppose the forfeiture,” Cassella said.

Expensive process

While the legal battle goes forward, the U.S. government is paying to keep the Amadea running.

According to court filings, upkeep of the yacht costs roughly $600,000 a month. Insurance costs another $144,000 monthly, and there are other periodic expenses.

In a February filing, an official of the U.S. Marshals Service stated that the Amadea was also scheduled to undergo drydocking in March, which appears to have been delayed.

That procedure, which involves removing a vessel from the water to conduct repair work, was estimated to cost $5.6 million — although the government negotiated not to pay the other monthly costs during that period, the official noted.

In recent months, however, the U.S. government has taken steps to decrease the cost.
In February, it petitioned the court to sell the Amadea, citing the excessive costs of maintaining the yacht. Such a sale would effectively convert the yacht into cash, but not settle the ownership question.

In a filing opposing the sale, Khudainatov’s legal team stated that he had consistently offered to cover the cost of maintaining the Amadea.

On May 17, the U.S. government also submitted a motion to reject Khudainatov’s ownership claim, stating that he lacks standing to contest forfeiture.

If a judge agrees, that could allow the forfeiture to proceed.

Controversial, challenging strategy

While confiscating the assets of Russian oligarchs and top officials may not face fierce opposition from most Americans, civil forfeiture is controversial in the United States.
Advocacy organizations, both liberal and conservative, have criticized the practice, arguing that it allows law enforcement to seize private property without convicting the owner of a crime.

Smith, the former DOJ prosecutor, says the burden falls hardest on low-income Americans who struggle to pay for a lawyer.

This was one of the reasons why eight members of the U.S. House of Representatives in April 2022 voted against a bill calling for the Biden administration to seize sanctioned Russians’ assets to fund Ukraine. https://www.yahoo.com/news/aoc-defends-lonely-vote-against-192600353.html

Smith believes applying civil forfeiture to oligarchs is “arbitrary” and he is unsure whether the U.S. will be able to seize enough assets from oligarchs to make a meaningful difference for Ukraine.

“I would rather spend the money [subsidizing forfeiture investigations and proceedings] on other things than trying to forfeit these yachts,” he said. “And who knows how many will ultimately be forfeited.”

That concern is not unfounded. The Kleptocapture Task Force is working to forfeit or restrain around $700 million, but, so far, the United States has been able to transfer forfeited assets to Ukraine in only a handful of cases. https://www.justice.gov/opa/pr/task-force-kleptocapture-announces-array-new-charges-arrests-and-forfeiture-proceedings

In May 2023, U.S. Attorney General Merrick Garland authorized sending $5.4 million to Ukraine that the U.S. had seized from sanctioned Russian oligarch Konstantin Malofeyev. It represented the first such transfer of forfeited funds to Ukraine.

SEE ALSO: US Sends Ukraine Cash Seized From Russian Oligarch https://www.voanews.com/a/ukrainian-nuclear-operator-warns-of-worker-shortage-at-russia-occupied-plant/7086693.html

Later that year, the U.S. transferred over a million rounds of ammunition to Ukraine after seizing them en route from Iran to Yemen. https://www.justice.gov/opa/pr/over-one-million-rounds-ammunition-seized-en-route-iran-yemen-transferred-ukrainian-armed

In February 2024, the U.S. government, after breaking up a scheme to illegally procure military-grade technology for Russia, transferred $500,000 in forfeited Russian funds to Estonia to provide aid to Ukraine. https://web.archive.org/web/20240218220741/https://www.justice.gov/opa/pr/justice-department-transfers-approximately-500000-forfeited-russian-funds-estonia-benefit

In April, the U.S. transferred another shipment of weapons seized from Iran to Ukraine. https://www.dhs.gov/hsi/news/2024/04/12/seized-weapons-hsi-washington-dc-investigation-transferred-ukrainian-forces
Those transfers put funds and ammunition in the hands of the Ukrainian government, but they were also of a significantly lower value than the Amadea.

Bigger cases involving oligarch assets may prove more difficult.

“It wouldn’t surprise me if it took 10 years to resolve some of these cases,” said former prosecutor Cassella.

Natasha Mozgovaya reported from Everett, Washington. Matthew Kupfer and Oleksii Kovalenko reported from Washington, D.C.” https://www.voanews.com/a/yacht-docked-in-us-port-symbolizes-struggle-to-convert-seizures-into-cash-for-ukraine-/7622986.html

Russia:
“5.2 High-profile Muslims
5.2.1 Little information could be found on this subject.
5.2.2 However, in August 2019, The Moscow Times reported:
‘A Russian media outlet has for the first time compiled a ranking of the country’s 100 most influential Muslims, with UFC lightweight champion Khabib Nurmagomedov featured alongside tycoons, government officials and spiritual leaders.
‘Russia’s grand mufti, or Muslim spiritual leader, Ravil Gainutdin topped the inaugural ranking of influential Muslims…
‘Mintimer Shaimiyev, Tatarstan’s first leader after the Soviet collapse, placed second, ahead of Dagestan’s Nurmagomedov. Tatarstan’s current leader Rustam Minnikhanov and Chechen leader Ramzan Kadyrov closed out the top-5…
‘Billionaires Alisher Usmanov and Suleiman Kerimov… placed sixth and eighth, while Moscow’s deputy mayor in charge of urban development Marat Khusnullin ranked ninth…
‘The new index compiled by Business Online, published on the religious holiday of Kurban Bairam, or Eid al-Adha, was based on expert surveys.
‘The news outlet said that its rating includes public figures “who don’t publicly demonstrate their religiosity, but influence the Muslim community, lobby on its behalf or are considered its pride.”’[footnote 74]” Excerpt from: https://www.gov.uk/government/publications/russia-country-policy-and-information-notes/country-policy-and-information-note-muslims-russia-november-2022-accessible Footnote 74 ‘Top 100 Influential Russian Muslims’ Ranking Released…” https://www.themoscowtimes.com/2019/08/14/top-100-influential-muslims-russia-ranking-released-local-media-a66848

“Diversifying the super-rich – Forbes-listed Russians from a Muslim background” By Catherine Suart (Creative Commons article) https://socialsci.libretexts.org/Bookshelves/Political_Science_and_Civics/Socialism_Capitalism_and_Alternatives_(Duncan_and_Schimpfossl)/2%3A_Part_I_-_Capitalism_in_Action/2%3A_Diversifying_the_super-rich_-_Forbes-listed_Russians_from_a_Muslim_background

“Profile: Support Fund for Islamic Organizations is the beneficiary of Wandle Holdings Limited.

Affiliates

* First-born
* GRUPPA AKROPOL
* Grachev Pavel Sergeevich
* Kerimov Said Suleimanovich
* Lenzoloto
* Palankoev Akhmet Magomedovich
* Polyus
* Polyus Finance (SPV)
* Polyus Gold International Limited
* Polyus Krasnoyarsk

* FOND PODDERZhKI ISLAMSKIH ORGANIZACII
* Organization status Operating organization
* Registration form Public fund
* Region Moscow
* Address 129090, Moscow, per. Vypolzov, 7
* Phone (495) 681-49-04
* Small and medium-sized enterprises category Not SME
* Activity code for reporting of insurance companies of the Russian Federation 03

Codes
* TIN 7702471420
* IEC 770201001
* PSRN 1127799024748 on 29/11/2012
* OKPO 11493313” https://archive.is/BrRZS

Named as an affiliate, above:
“Organization: First-born 
TIN 3802008546, PSRN 1023800732889

ORGANIZATION NAME
JSC First-born

COUNTRY NAME
Russia

COUNTRY OF REGISTRATION
Russia

INDUSTRY
Precious Metal Mining

BOND DEBT
-Affiliates
* FOND PODDERZhKI ISLAMSKIH ORGANIZACII
* GRUPPA AKROPOL
* Grachev Pavel Sergeevich
* Kerimov Said Suleimanovich
* Lenzoloto
* Palankoev Akhmet Magomedovich
* Polyus
* Polyus Finance (SPV)
* Polyus Gold International Limited
* Polyus Krasnoyarsk
* Semianskikh Maksim Aleksandrovich
* Vostokov Alexey Alexandrovich
* Wandle Holdings Limited

Licenses
Codes
* TIN 3802008546
* IEC 380201001
* PSRN 1023800732889 on 19/11/2002
* OKPO 46696768”
https://archive.is/YKkHP

According to Antony Sutton: “Russia has excellent gold ore reserves. In tsarist times the Lena River gold mining area in Siberia, reputedly one of the richest in the world, measured by both extent of reserves and metal content of the ore, was operated by concessionaires. In 1913 there were 39 foreign and Russian companies operating 770 mines in the Lena River area; of these 121 were actually producing gold and employed over to,ooo workers. ‘These mines had excellent equipment, full electrification and large hydroelectric installations . … ‘
(…)
The departure of the Western owners with the Revolution significantly reduced Russian gold production. There was a catastrophic decline in the condition of the Siberian gold fields
(…)
Shortly thereafter, the 1920 decree which had forbidden private interests from mining gold was replaced by a decree authorizing special concessions for gold and platinum operations
(…)
In mid-1923, a French mining expert, Professor E. N. Barbot-de-Marni, was hired by the Soviets to make a report on the Siberian mines, including those in the prewar Lena group.
(…)
Barbot-de-Marni’s recommendation was for state assistance to get development under way. In mid-1923, thirty-four leasing contracts were made with private individuals and enterprises in the Lena-Vitim area. There were seventeen contracts in the platinum mining areas of Semipalatinsk. Nine mines were leased in the Northern Yenessei and five in the Southern Yenessei district, together with eleven gold mines in the Altai Mountains.8
(….)
After 1925, gold began to assume its key role in Soviet development as a major earner of the foreign exchange required to pay for imports of foreign equipment and technology utilized in the industrialization program. Gold mining was, consequently, put in the vanguard of the Soviet mineral exploi-tation program: an effort characterized by Shimkin as ‘the merciless and insatiable Soviet quest for gold.’” Excerpts from pp.92-94 “Western Technology and Soviet Economic Development, 1917-1930”, by Antony Sutton: https://archive.org/details/AnthonySuttonTriologyOfWesternTechnologyAndSovietEconomicDevelopment1917To19301930To19451945To1965/page/n105/mode/2up

US Sec. of State Antony Blinken’s mother, became a member of the Russian Academy of Arts in late 2012, when Putin had just been re-elected President, and is still listed as a member: Judith Pisar, October 23, 2012: https://web.archive.org/web/20240430203745/https://eng.rah.ru/the_academy_today/the_members_of_the_academie/member.php?ID=54144

At the time, Blinken was Deputy Assistant to the US President and National Security Advisor to the Vice President. His stepfather, Samuel Pisar, was also a member of the Russian Academy of Arts, probably from 2012, as well.

Blinken was reportedly the prime architect of Obama’s failed Ukraine policy, including refusal to arm Ukraine, after Russia’s first recent invasion in 2014; he waived the US Congressionally mandated sanctions against Nord Stream 2 pipeline, which many consider acted as a green-light to Russia’s 2022 invasion.

Blinken grew up in the lap of luxury in Paris with a Russophile stepfather, Samuel Pisar, who made an apparent fortune promoting European and American business deals with the USSR-Kremlin-Russia, and who worked for Robert Maxwell and with or for Jeffrey Epstein. Pisar may have been a KGB agent.

Blinken was back in Paris working as a lawyer after law school (between 1988 and 1993) in the period when his stepfather was Robert Maxwell’s Paris based lawyer and confidant, so Blinken himself may have worked for and with Maxwell and/or the USSR.

Among other activities, Pisar was a courier in Armand Hammer’s attempts to restore diplomatic relations between the Soviet Union and Israel. Blinken was on vacation when Kabul fell to the Taliban. Etc. ad nauseam. Blinken has had business dealings with Epstein-connected Ehud Barak, who has been trying to overthrow Netanyahu’s government, as well. Israel shouldn’t trust him, either. The US certainly should not!