Clarification regarding applicability of UK Russia-related sanctions

To:
Transport Sanctions Team
Department for Transport
Great Minster House
33 Horseferry Road
London SW1P 4DR
United Kingdom

Dear Sirs,

11 July 2025

I am writing on behalf of the ownership and management of the vessel TS SHTANDART, a traditionally-built sailing frigate (Call Sign E5U5236, MMSI 518999255), registered under the Cook Islands flag, to seek clarification on the ship’s legal status under the UK’s sanctions regime against the Russian Federation.

We presume that you may have already reviewed this vessel in response to a request from Aberdeen Harbour. We respectfully urge you to reconsider the situation, now with the benefit of the full supporting documentation enclosed.

We sincerely hope that, upon review, you will recognize that TS SHTANDART is not affiliated with the Russian Federation and does not fall under the scope of UK sanctions. Consequently, we hope you will permit her participation in Tall Ships Races and allow future port calls in the United Kingdom.

Clarification of Vessel Identity

Please ensure we are discussing the correct vessel: TS SHTANDART, a sailing frigate bearing MMSI 518999255. We are aware that at least one other vessel named Shtandart (IMO 9816828 / MMSI 273397290) reportedly belongs to Mr. Alexey Miller, who is subject to UK sanctions. We are also aware of a luxury motor yacht carrying the same name, believed to be linked to Russian oligarchs.

We emphasize that TS SHTANDART is a completely unrelated ship: a wooden sailing ship built in 1999, with no connection to these other vessels or their owners.

1. Flag State and Legal Jurisdiction

Since 6 June 2024, TS SHTANDART has been registered in the sovereign registry of the Cook Islands, a jurisdiction entirely independent of the Russian Federation. Under international maritime law and the jurisdiction of the Cook Islands flag, TS SHTANDART is not subject to any direct or indirect Russian control and thus should not fall under UK sanctions targeting Russian entities or interests.

(Please refer to Annex 1 – Certificate of Registry, and Annex 2 – Radio License.)

2. Ownership and Management

The vessel is owned by a Finnish citizen. All legal and financial operations—management, funding, and operational agreements—are conducted through Martus TV GmbH, a company registered in Hamburg, Germany since 2011, within the jurisdiction of the European Union. Neither the owner nor the company appears on any UK sanctions list.

The captain and managing director of Martus TV GmbH is Mr. Vladimir Martus, who has resided in Germany since 2011, pays taxes there, and is covered by German pension and healthcare systems. He does not reside in, nor conduct business with, the Russian Federation. We are ready to provide full supporting documentation, including German residence permits and proof of permanent residential address since 2011.

(Please refer to Annex 4 – Declaration by Vessel Manager.)

3. Operational History and Purpose

Since its launch in 1999, TS SHTANDART has served as an educational and cultural vessel, funded exclusively through non-Russian sources.
In 2009, following threats and attempts to seize the vessel by individuals connected to the Russian administration, the ship was forced to leave Russian territorial waters under tow—and has never returned since.
Official correspondence from French and Spanish maritime authorities confirms that this traditionally built wooden vessel is exempt from SOLAS and other maritime conventions. It is therefore not subject to conventional sanction criteria. (See Annexes 5, 6, and 7.)
The maintenance of this historic replica requires significant funding. As an example, we include a bank statement from Martus TV GmbH (Annex 8) showing income received from participation in maritime festivals—income taxed and documented within the EU.
The re-registration under the Cook Islands flag was conducted with full legal oversight by French attorney Emmanuel Marchand, La Rochelle. His legal opinion confirming the legitimacy of the vessel’s documents and ownership is available upon request.
There have been no voyages to or from ports in Russia or Crimea, nor any transit through Russian-controlled maritime zones. No goods or cargos from the Russian Federation have been handled on board.

4. Relevance to UK Sanctions Policy

According to the UK Sanctions and Anti-Money Laundering Act 2018, sanctions enforcement targets specific persons and entities affiliated with the Russian Federation. Transport controls (civil penalties or license denials) apply to vessels owned or controlled by designated individuals or entities. No such affiliation exists in the case of TS SHTANDART.

5. Legal Challenge to EU Sanctions Language

We enclose an excerpt from a legal filing before the European Court of Justice, which challenges the broad and vague language of recent EU sanction documents that inadvertently restrict the rights of the vessel owner. This case underscores our commitment to achieving justice through legitimate European legal channels.

(See Annex 9 – Legal Filing (ECJ excerpt).)

6. Cultural and Educational Significance

Over the years, the ship has visited more than 175 ports across nineteen countries and welcomed some 9,700 trainees from over 50 different nationalities. Each visit brings educational outreach, multicultural celebration, and local camaraderie. This grassroots diplomacy—far removed from governmental agendas—naturally promotes mutual understanding and respect to all cultures.

Since 2001, TS SHTANDART has been an active participant in the Tall Ships Races (formerly the Cutty Sark Tall Ships Races), whose core mission is fostering intercultural exchange and understanding among youth from both sides of former geopolitical divides.

Sail Training International, the organizer of said events, has recently initiated a petition to the participating ports in this year’s Tall Ship Race, requesting support of the Shtandart by extending their welcome to the ship (see Annex 10). After a careful consideration of the facts, the Norwegian port of Kristiansand has already replied with their warm invitation to Shtandart and her captain (Annex 11)

Today, Shtandart’s peaceful mission of education and heritage continues. We invite you to explore TS SHTANDART’s public communications:

Instagram: https://www.instagram.com/frigate_shtandart/
Facebook: https://www.facebook.com/Frigate.Shtandart

These platforms promote seamanship, intercultural dialogue, and inclusion. What they do not contain are symbols of the Russian Federation or support for the unlawful war initiated by President Putin against Ukraine.

We were recently featured in an article on the front page of the Irish Times following our brief anchorage outside of Dublin. The article discusses the controversy surrounding the ships legal standing, but also attests to the fact that Shtandart was enthusiastically received by the general public.:

(See Annex 12 – Press Coverage.)

Not only is Shtandart innocent of sanction violations —it embodies our highest shared values as global citizens. Its international crew, volunteer‑driven governance, and unwavering commitment to intercultural exchange make it a vessel of hope. Far from fostering division, its voyages bring communities together, bridge language and heritage, and sow seeds of peace and friendship across borders.

Request

In light of the above, we respectfully ask the Department for Transport to:

Confirm that TS SHTANDART is not subject to UK Russia-related sanctions and is permitted to access UK ports.
Advise what additional documentation (if any) may be required to fully clear the vessel for future operations within UK jurisdiction.

We would greatly appreciate your timely response and are fully prepared to supply any further materials as needed.

Very best regards,

Capt Vladimir Martus

TS Shtandart

+49 1516 703 1703 mobile, Whatsapp & Telegram