UK: Akhmedov vs Akhmedova: The Super Yacht Saga – What Happened In Dubai

After 22 years, Mr and Mrs Akhmedova's marriage came to an end in 2015. This was a marriage like few others. It lasted two decades, it resulted in two children and during the course of their partnership, they built up vast wealth, including a plane, a helicopter and a 115m super yacht called Luna.

Regrettably, the divorce was bitter. Mr Akhmedov fought hard and dirty to avoid having to share any of the family wealth with his wife. It was found by the English High Court that he hid assets in a Bermuda Trust with the intention of evading his legal obligations to his wife and even went so far as to invent stories that they had already divorced in Russia, producing forged documents to the Court as 'evidence'.

Mr Akhmedov did not win. He was ordered to pay to his wife in excess of £350m plus the art collection worth, at the time, about £90m, an amount equivalent to 41.5% of the family's wealth. His Russian divorce was found to be a lie and the dispositions of assets and money into the Trust were set aside. The companies he had used to hide the family's assets were declared his "ciphers" and "alter egos" and any transfers to them were also set aside. Bank accounts and assets were frozen, pursuant to worldwide freezing orders obtained in England, Liechtenstein and the Isle of Man.

But Mr Akhmedov is not one to be deterred by something as trivial as the law. In defiance of the High Court judgment and in breach of the freezing orders, he transferred the family's money and artwork to Liechtenstein. He created debts to himself and his other alter ego companies from his asset holding companies. He sailed their super yacht, Luna, from Turkey to Dubai (possibly with the expectation that the Dubai legal system might offer a safe place of refuge).

It very quickly became clear that Mr Akhmedov was willing to play every trick in the book to avoid paying what he owed. He was even prepared to put himself in contempt of court to do so.

Piercing the corporate veil

Mr Akhmedov's prized asset is the family's 115m super yacht, the Luna, purchased from Roman Abramovich for €260m. At the time the court handed down its judgment, Luna was owned by a Liechtenstein Anstalt, 'Q', whose assets were the subject of the court's freezing order. In breach of that freezing order, and unbeknown to Ms Akhmedova or the judge, Mr Akhmedov had already transferred the Luna from Q to another Liechtenstein Anstalt, 'S'.

Realising that S was the new owner of Luna, Ms Akhmedova returned to the English High Court seeking (amongst other things) an order piercing S's corporate veil.

The court very rarely pierces the corporate veil to make a direct connection between the beneficial owner of a business and that business's assets, but can make orders to include those assets in an award. If Ms Akhmedova was successful in obtaining this order, it would make S directly liable and place its assets (namely, Luna) back on the table.

The court readily agreed to the order, stating that Mr Akhmedov had acted with "real impropriety" in deliberately seeking to evade his legal obligations by employing corporate devices to put legal obstacles in the way of enforcement of the judgment. Indeed, S's entire raison d'etre was evasion of the subsisting judgment. The order was clearly necessary in the interests of justice and the court gave judgment directly against S.

The DIFC court as a conduit jurisdiction

In the meantime, and prior to obtaining the judgment against S, Ms Akhmedova took steps in Dubai to ensure that the Luna could not be whisked away again.

Ms Akhmedova applied to the Dubai International Finance Centre ('DIFC') court for a freezing order against both Mr Akhmedov and S (which, at the time, was not a party to the English proceedings or any judgment). The intention was to use the DIFC court as a way into the Dubai Courts, which will recognise a DIFC court order on the basis of comity.

The DIFC court agreed with Ms Akhmedova and granted a freezing order over the assets of both Mr Akhmedov and S.

At a later hearing for the continuation of the freezing order, S sought to challenge the order on jurisdictional grounds. S defended saying, amongst other things, that it was not a party to any English court order that Ms Akhmedova was seeking to enforce and that, in any event, both S and Luna are outside the jurisdiction of the DIFC courts.

However, the DIFC court agreed with Ms Akhmedova, stating that, as a matter of "fundamental policy, the DIFC court, like any other court of justice, must be in a position to respond to fraud and deliberate evasion". It was not prepared to allow a known fugitive from justice to avoid enforcement of a judgment simply by placing his assets into a company located in a "secrecy" jurisdiction. Accordingly, the DIFC court confirmed that its jurisdiction to ratify and enforce foreign judgments extends to the making of orders against corporate entities such as S if it can be shown that they are ciphers or alter egos of the judgment debtor .

S subsequently appealed the finding against it to the DIFC Court of Appeal. However, since the English court had since both pierced the corporate veil and made S a judgment debtor, the Court of Appeal continued the freezing injunction in order to allow Ms Akhmedova to join S on that basis.

Enforcement in the Dubai court

Immediately after obtaining the DIFC court freezing injunction, Ms Akhmedova applied to the Dubai courts for a precautionary attachment of Luna. The Dubai courts, acting as a delegate of the DIFC court and on the basis of the DIFC freezing injunction, duly granted the precautionary attachment, detaining the Luna pending the outcome of the main proceedings.

What happens next...?

Running out of options, Mr Akhmedov has now filed a claim with the Joint Judicial Committee – a body set up to decide on potential conflicts of jurisdiction between the onshore Dubai courts and the DIFC courts. It is Mr Akhmedov's hope that he can persuade the JJC that his dispute with Ms Akhmedova is a matrimonial one and one which should therefore be determined by the Dubai courts in accordance with Sharia law. Ms Akhmedova's case is that this is a matter of pure enforcement of a judgment debt which is owed to her and it is therefore right that the case be heard by the DIFC Court .


The English High Court has welcomed and praised the DIFC court's willingness to assist a victim of the wrongdoings of a serial evader and fugitive from justice. By his words and actions, Mr Akhmedov has acted in contempt and open mockery of the English court.

In the meantime and while he still can, Mr Akhmedov elects for the self-defeating option of "letting the boat rot" rather than paying Ms Akhmedova what she is owed.

Withers is instructed by Ms Akhmedova to manage and coordinate the global enforcement efforts.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on

Click to Login as an existing user or Register so you can print this article.

In association with
Related Topics
Related Articles
Up-coming Events Search
Font Size:
Mondaq on Twitter
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Email Address
Company Name
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Registration (you must scroll down to set your data preferences)

Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice):

  • To allow you to personalize the Mondaq websites you are visiting to show content ("Content") relevant to your interests.
  • To enable features such as password reminder, news alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our content providers ("Contributors") who contribute Content for free for your use.

Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below.

Mondaq has a "free to view" business model. Our services are paid for by Contributors in exchange for Mondaq providing them with access to information about who accesses their content. Once personal data is transferred to our Contributors they become a data controller of this personal data. They use it to measure the response that their articles are receiving, as a form of market research. They may also use it to provide Mondaq users with information about their products and services.

Details of each Contributor to which your personal data will be transferred is clearly stated within the Content that you access. For full details of how this Contributor will use your personal data, you should review the Contributor’s own Privacy Notice.

Please indicate your preference below:

Yes, I am happy to support Mondaq in maintaining its free to view business model by agreeing to allow Mondaq to share my personal data with Contributors whose Content I access
No, I do not want Mondaq to share my personal data with Contributors

Also please let us know whether you are happy to receive communications promoting products and services offered by Mondaq:

Yes, I am happy to received promotional communications from Mondaq
No, please do not send me promotional communications from Mondaq
Terms & Conditions (the Website) is owned and managed by Mondaq Ltd (Mondaq). Mondaq grants you a non-exclusive, revocable licence to access the Website and associated services, such as the Mondaq News Alerts (Services), subject to and in consideration of your compliance with the following terms and conditions of use (Terms). Your use of the Website and/or Services constitutes your agreement to the Terms. Mondaq may terminate your use of the Website and Services if you are in breach of these Terms or if Mondaq decides to terminate the licence granted hereunder for any reason whatsoever.

Use of

To Use you must be: eighteen (18) years old or over; legally capable of entering into binding contracts; and not in any way prohibited by the applicable law to enter into these Terms in the jurisdiction which you are currently located.

You may use the Website as an unregistered user, however, you are required to register as a user if you wish to read the full text of the Content or to receive the Services.

You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these Terms or with the prior written consent of Mondaq. You may not use electronic or other means to extract details or information from the Content. Nor shall you extract information about users or Contributors in order to offer them any services or products.

In your use of the Website and/or Services you shall: comply with all applicable laws, regulations, directives and legislations which apply to your Use of the Website and/or Services in whatever country you are physically located including without limitation any and all consumer law, export control laws and regulations; provide to us true, correct and accurate information and promptly inform us in the event that any information that you have provided to us changes or becomes inaccurate; notify Mondaq immediately of any circumstances where you have reason to believe that any Intellectual Property Rights or any other rights of any third party may have been infringed; co-operate with reasonable security or other checks or requests for information made by Mondaq from time to time; and at all times be fully liable for the breach of any of these Terms by a third party using your login details to access the Website and/or Services

however, you shall not: do anything likely to impair, interfere with or damage or cause harm or distress to any persons, or the network; do anything that will infringe any Intellectual Property Rights or other rights of Mondaq or any third party; or use the Website, Services and/or Content otherwise than in accordance with these Terms; use any trade marks or service marks of Mondaq or the Contributors, or do anything which may be seen to take unfair advantage of the reputation and goodwill of Mondaq or the Contributors, or the Website, Services and/or Content.

Mondaq reserves the right, in its sole discretion, to take any action that it deems necessary and appropriate in the event it considers that there is a breach or threatened breach of the Terms.

Mondaq’s Rights and Obligations

Unless otherwise expressly set out to the contrary, nothing in these Terms shall serve to transfer from Mondaq to you, any Intellectual Property Rights owned by and/or licensed to Mondaq and all rights, title and interest in and to such Intellectual Property Rights will remain exclusively with Mondaq and/or its licensors.

Mondaq shall use its reasonable endeavours to make the Website and Services available to you at all times, but we cannot guarantee an uninterrupted and fault free service.

Mondaq reserves the right to make changes to the services and/or the Website or part thereof, from time to time, and we may add, remove, modify and/or vary any elements of features and functionalities of the Website or the services.

Mondaq also reserves the right from time to time to monitor your Use of the Website and/or services.


The Content is general information only. It is not intended to constitute legal advice or seek to be the complete and comprehensive statement of the law, nor is it intended to address your specific requirements or provide advice on which reliance should be placed. Mondaq and/or its Contributors and other suppliers make no representations about the suitability of the information contained in the Content for any purpose. All Content provided "as is" without warranty of any kind. Mondaq and/or its Contributors and other suppliers hereby exclude and disclaim all representations, warranties or guarantees with regard to the Content, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. To the maximum extent permitted by law, Mondaq expressly excludes all representations, warranties, obligations, and liabilities arising out of or in connection with all Content. In no event shall Mondaq and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use of the Content or performance of Mondaq’s Services.


Mondaq may alter or amend these Terms by amending them on the Website. By continuing to Use the Services and/or the Website after such amendment, you will be deemed to have accepted any amendment to these Terms.

These Terms shall be governed by and construed in accordance with the laws of England and Wales and you irrevocably submit to the exclusive jurisdiction of the courts of England and Wales to settle any dispute which may arise out of or in connection with these Terms. If you live outside the United Kingdom, English law shall apply only to the extent that English law shall not deprive you of any legal protection accorded in accordance with the law of the place where you are habitually resident ("Local Law"). In the event English law deprives you of any legal protection which is accorded to you under Local Law, then these terms shall be governed by Local Law and any dispute or claim arising out of or in connection with these Terms shall be subject to the non-exclusive jurisdiction of the courts where you are habitually resident.

You may print and keep a copy of these Terms, which form the entire agreement between you and Mondaq and supersede any other communications or advertising in respect of the Service and/or the Website.

No delay in exercising or non-exercise by you and/or Mondaq of any of its rights under or in connection with these Terms shall operate as a waiver or release of each of your or Mondaq’s right. Rather, any such waiver or release must be specifically granted in writing signed by the party granting it.

If any part of these Terms is held unenforceable, that part shall be enforced to the maximum extent permissible so as to give effect to the intent of the parties, and the Terms shall continue in full force and effect.

Mondaq shall not incur any liability to you on account of any loss or damage resulting from any delay or failure to perform all or any part of these Terms if such delay or failure is caused, in whole or in part, by events, occurrences, or causes beyond the control of Mondaq. Such events, occurrences or causes will include, without limitation, acts of God, strikes, lockouts, server and network failure, riots, acts of war, earthquakes, fire and explosions.

By clicking Register you state you have read and agree to our Terms and Conditions