Fiji and the United States are embroiled in a court case over a superyacht allegedly belonging to a sanctioned Russian oligarch.
However, questions over who owns the Amadea — worth some $454 million — remain.
The fate of the luxury vessel is due to be determined by a judge in Fiji on Tuesday. Here's what we know:
Yacht has live lobster tank and helipad
According to Boat International, the Amadea is 106-metres long and features a stainless steel albatross that extends off its bow and weighs more than 5 tonnes.
It also boasts a live lobster tank in the galley, a 10-metre pool, a hand-painted Pleyel piano and a large helipad.
The Amadea travelled from Mexico for 18 days across the Pacific, entering Fijian waters on April 13, but it didn't have customs clearance.
Almost immediately, the United States sought to seize the yacht and sent a formal request for legal assistance to Fiji to prevent the vessel from leaving the Pacific Island's waters.
The High Court in Suva ordered the yacht not leave Fiji until the merits of the US warrant to seize it were determined.
A High Court hearing took place in Fiji last week behind closed doors, so media were barred from covering it.
For now, the yacht continues to sit in a Fijian harbour, with its crew of about 25 rotating on and off the vessel, while a police officer remains on board to ensure it stays put.
Which oligarch owns it?
Good question.
The US alleges it's owned by Russian oligarch Suleiman Kerimov.
According to Forbes, he is worth more than $US14.3 billion (almost $20 billion).
Mr Kerimov, who was not on board, is a politician and businessman, and a close ally to Russia's President Vladimir Putin.
He's been sanctioned by the US since 2018 for alleged money laundering and has faced further sanctions from Canada, Europe and Britain after Russia invaded Ukraine.
However, defence lawyers dispute the ownership, saying the yacht belongs to Eduard Khudainatov, the former chairman and chief executive of Rosneft, a state-controlled Russian oil and gas company.
Importantly, Mr Khudainatov does not appear to be facing sanctions.
Why is yacht ownership so murky?
Many luxury yachts are linked to Russian oligarchs, but ownership is often veiled in secrecy, and they are often registered through multiple, offshore companies or trust funds.
One expert interviewed by the ABC used the analogy of an onion: The more layers an onion has, the longer it takes to peel.
In case of the Amadea, the ship is flagged in the Cayman Islands in the Caribbean, and its registered owner since 2021 is a company called Millemarin Investments (sometimes spelled Millemarine), according to the online site Equasis.
However, that fact alone does not give us many clues as to who the actual owner is.
Defence lawyers have claimed Millemarin is the legal owner of the vessel and that the company is linked to the real, or beneficial, owner, Mr Khudainatov.
However, US authorities have claimed that, behind all the various fronts, the real owner is Mr Kerimov.
Hamish Fletcher — a partner at the New Zealand law firm Oceanlaw — said superyachts often had multiple registrations because it was "just another layer of searching that someone would have to do".
"If someone is interested to try to find out who owns a vessel, they will search that register," he said.
"And then you have it in another country and then … you will probably not find out who the real, beneficial owner is, because you will just see what's on the register, which won't necessarily be the true owner."
Professor Donald Rothwell — an international and maritime law expert at the Australian National University — agreed that ship ownership was often a complex web.
That, he said, added to the "complexity of any law enforcement".
Many superyacht owners also use multiple registrations for tax benefits.
While many Russian yachts are still at large — and moored in countries such as the Maldives or parts of the Middle East, to escape sanctions — others are on the move.
How can US jurisdiction stretch all the way to Fiji?
Professor Rothwell said the United States could be seeking to seize the yacht under the United Nations Convention against transnational organised crime, which both Fiji and the US are a party to.
If that is the case, he said, then "Fiji, as a party to the convention, has an obligation to assist the United States in those processes".
Professor Rothwell said Fiji could detain the vessel until the US sought to commence additional legal proceedings.
He said they could do so against the owner of the yacht or against the vessel itself.
"The way to think about this is that the sanctions provide the overarching framework for how the United States is seeking to possibly seize this vessel," Professor Rothwell said.
"But the actual technical aspects that the United States is relying on to enforce aspects of the sanctions, in this instance, are really relying upon the UN Convention.
Fiji has also condemned Russia's invasion of Ukraine.
"Fiji has voted in the United Nations to condemn what Russia is doing, and we stand by any sanction by the global community against the Russians and what they are doing in Ukraine," Fiji's Opposition Leader, Viliame Gavoka, said.
According to the Fiji Sun, the prosecution has argued ownership of the Amadea is not an issue for the Fiji court, and the ownership question could be handled by the US jurisdiction.
The defence argued that there was no evidence the Amadea was a proceed of crime and that the Fiji court must be satisfied the yacht was "tainted property", not simply because the US said it was.
As to whether US authorities can seize the luxurious superyacht, a judge is expected to rule on that decision on Tuesday.
ABC/AP
