CNBC suggested data it had reviewed showed “at least four massive yachts owned by Russian business leaders have been moving toward Montenegro and the Maldives in recent days.” While that’s not categorical proof that the owners are attempting to hide their assets or remove them from the reach of sanctioning countries (the Maldives is a popular destination for wealthy Russians), the report raises interesting questions about how asset freezing and confiscation orders are implemented.

Property – a common asset looked for in such situations – is relatively easy to identify and locate, superyachts pose a unique challenge, not least because they are a moving target.

Sanctions against Russian individuals have been brought by the UK, the US and the EU, among others, with a view to freezing their assets and, in some cases, seizing them. American President Joe Biden announced on Twitter that the US was “joining with our European allies to find an seize their [Russian oligarchs’] yachts, their luxury apartments, their private jets.” France has already announced the seizure of a yacht worth around £90m moored near Marseille.

The U.S. Department of Justice is assembling a dedicated task force to go after the crimes of Russian oligarchs.

We are joining with our European allies to find and seize their yachts, their luxury apartments, their private jets.

We are coming for their ill-begotten gains.

— President Biden (@POTUS) March 2, 2022

It’s all well and good seizing assets that are in plain sight in your own boatyard, and the job is made easier when an international task force is working towards the same goal. But what happens when the whereabouts of an asset is unknown and in lower-profile cases with fewer resources?

How does asset tracing work?

In these cases, the first step is to determine the asset profile of the subject of the order – identifying assets owned by the subject and by their close associates. In many cases, when an individual is trying to hide their wealth, they will distribute assets among their network, but these may still be seized if a link between the subject and the assets can be proven.

The process of identifying assets and estimating the value of those assets is known as asset tracing. Investigators – such as those at ESA Risk – use databases, deep web tools, open-source intelligence (OSINT) and human intelligence (HUMINT) to build a picture of an individual’s lifestyle and behaviours, and the assets they own or potentially own.

Superyacht tracing is no different, but it requires specialist knowledge and can rely heavily on industry connections. It’s an area where we have deep expertise and experience, with access to superyacht-specific tools and databases along with connections in the world of superyachts. Our industry knowledge enables us to identify yachts from intelligence sources such as social media posts and to provide a valuation for a yacht at the current market rate. We also have access to tools that can track the location of a registered vessel anywhere in the world and give information about the status of the yacht (anchored, berthed or under way).

Linking an asset to a subject is not always that simple, though, as is being shown in the case of one of the world’s largest superyachts (at 156m long, the fifth longest), the Dilbar, valued at nearly £450m. Widely ‘known’ to be owned by Russian businessman Alisher Usmanov, the yacht is actually owned through a holding company and it is registered in the Cayman Islands, “making it difficult to tie directly to Usmanov for the purpose of sanctions.” Forbes reported that the Dilbar superyacht had been seized by German authorities, but the outlet quickly published a correction clarifying that this was not the case. Instead, the German federal customs agency states that “no yacht leaves port that is not allowed to do so.”

It is in these cases that industry connections can be particularly useful in helping to ascertain who the ultimate beneficial owner of a vessel is.

Asset tracing services including superyacht tracing from ESA Risk

When it comes to tracing assets, we are the experts. ESA Risk’s team will deliver concise but comprehensive results which will enable you to make the decision on which way to proceed. With a network of trusted partners covering every part of the world, our investigation capability – and therefore yours – is truly international.

We have specialist knowledge of superyacht tracing, too. This can be particularly useful when investigating high-net-worth individuals.

To instruct us on an investigation or for more information on our asset tracing services, contact Mike Wright, Risk Management & Investigations Consultant at mike.wright@esarisk.com, on +44 (0)843 515 8686 or via our contact form.