To:
Norwegian Directorate for Export Control and Sanctions
Snarøyveien 36
1364 Fornebu
Norway
Dear Sirs,
I am writing on behalf of the ownership and management of TS SHTANDART, a traditionally-built sailing frigate (Call Sign E5U5236, MMSI 518999255), currently registered under the Cook Islands flag. We respectfully seek your clarification on whether this vessel falls within the scope of Norway’s implementation of Russia-related sanctions.
We understand that a question may have been raised previously by the Port of Kristiansand. Now, with full documentation and detailed legal background available, we hope this letter will assist your Directorate in confirming that TS SHTANDART is not subject to Norwegian or EU sanctions, as currently applied.
Clarification of Vessel Identity
Please be assured that this letter refers specifically to the wooden tall ship TS SHTANDART, constructed between 1994–1999 and launched in 1999. The ship bears no connection to the Russian-flagged yacht SHTANDART (IMO 9816828), reportedly owned by Mr. Alexey Miller, nor to any other motor yacht of similar name linked to sanctioned individuals.
1. Registration and Jurisdiction
As of 6 June 2024, the SHTANDART has been registered with the Maritime Administration of the Cook Islands, a sovereign and internationally recognized flag state not affiliated with the Russian Federation. This registration followed a formal transfer of ownership, notarized and validated by a French attorney, Maître Emmanuel Marchand, in La Rochelle. The change was completed well before the EU introduced its 14th package of sanctions expanding scope to include replicas of historical vessels under Russian flag.
We enclose:
- Certificate of Registration (Cook Islands)
- Legal validation of ownership transfer
- Declaration by legal counsel
2. Ownership and Management
The vessel is legally owned by Ms. Maria Martus, a Finnish citizen. Management is conducted by Martus TV GmbH, a German-registered company (HRB 119848), with headquarters in Hamburg. The company’s managing director, Mr. Vladimir Martus, has continuously resided in Germany since 2011, with all taxes and social obligations paid in Germany.
Martus TV GmbH is:
- Tax registered with Finanzamt Hamburg (Steuer-Nr. 48/741/01651)
- Not affiliated in any way with Russian state structures or sanctioned persons
- The sole manager of SHTANDART’s operations and finances since 2011
We can provide complete documentation verifying these facts, including Mr. Martus’ German residency permits from 2011 to present.
3. History and Legal Context
TS SHTANDART is a replica of the 1703 Russian imperial frigate, built entirely without state funding by volunteers in St. Petersburg from 1994–1999. From its inception, the project was completely independent from any governmental authority. A nonprofit organization, “Project Shtandart,” oversaw the ship’s educational mission until 2024, after which ownership was transferred due to increased geopolitical tensions.
Between 2007 and 2009, the ship was forcibly removed from Russian jurisdiction following pressure from business interests associated with Russian state authorities. Since that time, SHTANDART has not returned to Russian territorial waters and has conducted its missions exclusively in European waters.
The ship’s traditional wooden construction and purpose led both French and Spanish maritime authorities to confirm, in writing, that SHTANDART does not fall under standard definitions of “vessels” subject to sanctions (see attached letters in Annexes 5–7).
We acknowledge that certain port authorities, such as in Brest, may have adopted alternative legal interpretations. These have been formally challenged in both the French Supreme Courtand the European Court of Justice. We await final rulings.
It is our respectful position that the application of sanctions to the SHTANDART under Regulation 833/2014 as amended in June 2024 is not legally grounded for three core reasons:
- The flag change occurred prior to the regulation’s amendment.
- The provision cannot be applied retroactively.
- The change was conducted legally and transparently under existing EU and international guidance.Please seee attached ANNEX – LEGAL STATEMENT on this subject.
4. Cultural Mission and Peaceful Role
Since its launch, TS SHTANDART has:
- Visited more than 175 ports in 19 countries
- Trained nearly 10,000 young people from over 50 nations
- Actively promoted intercultural dialogue, maritime skills, and tolerance
The vessel has never displayed Russian state symbols, nor expressed any support for the unlawful war in Ukraine. On the contrary, its leadership and crew have consistently condemned the aggression of the Russian state, both in 2014 and in 2022.
We invite you to explore TS SHTANDART’s public communications on this subject:
- Instagram: https://www.instagram.com/frigate_shtandart/
- Facebook: https://www.facebook.com/Frigate.Shtandart
TS SHTANDART remains a unique symbol of peace, youth development, and international friendship. The general public in ports such as Dublin, Cherbourg, and Brest have warmly welcomed her, as reported in the Irish Times and other international media (Annex 12).
5. Legal Standing and Interpretative Space
We are aware that national authorities must act in accordance with their own interpretations of sanction regulations. However, we believe that in this specific case, the spirit and letter of Norwegian and EU sanction policy both support an exemption for the TS SHTANDART.
In the meantime, all parties retain the right to uphold their interpretation without violating the law.
We trust that your interpretation will reflect a commitment to proportionality, factual review, and the principle of non-retroactive enforcement.
Request
In light of the documentation and legal background enclosed, we respectfully request that your Directorate:
- Confirm that TS SHTANDART does not fall within the scope of Russia-related sanctions applicable in Norway;
- Clarify whether any additional documentation is required to ensure the vessel’s continued access to Norwegian ports.
We appreciate your time and consideration, and remain fully available for further questions.
With best regards,
Capt. Vladimir Martus
President & Managing Director
Martus TV GmbH
Hamburg, Germany
+49 (0)151 6703 1703
All ANNEXES are available for downloading here:
https://drive.google.com/drive/folders/1DwAb3R0HRgmgHwMhuapkc8nqH1aS-Med?usp=sharing
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