Have you ever wondered how to navigate the complex world of sanctions, and what it means for you as a yacht owner or yachting professional? Join us as we shed light on the implications of US, EU, and UK sanctions against Russia and Russian citizens. With Michael Moore's deep knowledge in maritime law, we discuss the importance of staying informed about sanctions lists, and how to handle situations involving sanctioned individuals or superyachts.
Dive deeper into the legalities surrounding sanctions and the crucial role of understanding the Fifth Amendment and its relation to due process. We delve into the challenges faced when dealing with an ultimate beneficial owner or a yacht on a sanctions list, and how to avoid potential legal consequences. Learn from real-life examples of navigating sanctions and the importance of carefully evaluating a client's situation, such as those of Bernie Madoff and Alfa Nero. Don't miss this informative and engaging conversation that will leave you better prepared to navigate the murky waters of sanctions and their implications in your world.
Have a yacht law question? Email it to info@megayachtnews.com or michael@moore-and-co.com for your chance to have it answered on our podcast. All requests for confidentiality and/or anonymity are respected.
Hiring a lawyer is a big decision. Visit Moore & Company for the legal team's qualifications and experience. And, to learn the latest about superyacht launches, shipyards, designs, and destinations, visit Megayacht News.
Have you ever wondered how to navigate the complex world of sanctions, and what it means for you as a yacht owner or yachting professional? Join us as we shed light on the implications of US, EU, and UK sanctions against Russia and Russian citizens. With Michael Moore's deep knowledge in maritime law, we discuss the importance of staying informed about sanctions lists, and how to handle situations involving sanctioned individuals or superyachts.
Dive deeper into the legalities surrounding sanctions and the crucial role of understanding the Fifth Amendment and its relation to due process. We delve into the challenges faced when dealing with an ultimate beneficial owner or a yacht on a sanctions list, and how to avoid potential legal consequences. Learn from real-life examples of navigating sanctions and the importance of carefully evaluating a client's situation, such as those of Bernie Madoff and Alfa Nero. Don't miss this informative and engaging conversation that will leave you better prepared to navigate the murky waters of sanctions and their implications in your world.
Have a yacht law question? Email it to info@megayachtnews.com or michael@moore-and-co.com for your chance to have it answered on our podcast. All requests for confidentiality and/or anonymity are respected.
Hiring a lawyer is a big decision. Visit Moore & Company for the legal team's qualifications and experience. And, to learn the latest about superyacht launches, shipyards, designs, and destinations, visit Megayacht News.
Welcome everyone. You know, ever since Michael and I started this podcast, we have talked a lot about how the maritime world has been upended by Russia's invasion of Ukraine. We've discussed how the United States government, the EU and the UK have all imposed sanctions against Russia and Russian citizens, and how these governments have arrested Yats owned by oligarchs. But what we haven't yet discussed is what you need to know about sanctions to stay out of trouble and what to do if you're dealing with a YAT or an ultimate beneficial owner who is on a sanctions list. So, michael, you and your team are familiar with these situations, how to navigate them, etc. And I realize that us trying to cover every aspect of this would probably take hours, but maybe what we can do is walk through some of the basic need to know information for people.
Speaker 2:Absolutely. It is a very serious thing. It comes under some laws that are draconian in nature, that strike right out the heart of the foundation of law in the world, the English world, starting with the Magna Carta, going through the English history of 1215 forward until it came to the United States in the 1700s. But there's a little thing called the Fifth Amendment, which is not about self-incrimination It's about that but it's also about taking without due process. And so you get into a government that is not only taking this property without due process, but it's also serving notice on all citizens that if you violate this law, you will be subject to the harshest sanctions, including incarceration. And the short answer is you have to be extremely careful in dealing with sanctioned individuals, sanctioned aircraft or sanctioned vessels. They actually have. all three have their little individual categories. Vessels is the one that we are mostly focused on Right.
Speaker 1:So why don't we start with really the most basic question, because some people have even asked me what it actually means? What does it mean to be under sanctions? when a person or a yacht is under these sanctions, what is it preventing them from doing?
Speaker 2:Okay. So, fundamentally, if you're trying to determine if someone is under this mysterious thing called sanctions, it seems that, as much we know, the government, in our view, takes the position that if you're on the list, no one can do business with you. If you're a vessel or an aircraft or a person or a corporation, they try to put it down to the personal level And with the yachts, whose names change frequently through the name of the yacht. So you're either on the list or you're not on the list. The problem is there are at least three lists in the world that seem to count. I know of no others, but they are. you know. you are either on the list or you're not on the list. So if you're trying to determine as a person, a just a citizen or a lawyer or a bank, you really have to go to the list The Office of Foreign Asset Control website are the same parallel sites in the UK or the EU and try to make a determination. I would like to think that you're going to be protected down the road if something is not on that list, but if it is on the list any of those three lists you're going to have a problem. What does it mean? So basically, it means that in all of these sanctioned activities around the world and there's a lot of them doing business with Cuba, doing business with Belarus, burma, afghanistan, all of these places are. it's another area to think about and worry about. These are places that there's many places around the world where you simply cannot do business with, the into any country that's on that list.
Speaker 2:We've tried to be a little more focused in terms of vessels and the Russian oligarch situation, but the truth is there's. you know, nicaragua. I mean I got in trouble one time back in the day I bought a bunch of lobster for a client did, from a intermediary, that the United States said no, they're a front for the government of Nicaragua. And so next thing, you know we're just kind of backpedaling and begging for mercy. But you know the gold standard, the lodestar, the thing you've got to understand how to get to is the sanction, the sanction programs that have to do with vessels, people, aircraft, our countries And if you're, if you've got a country, one of those entities on the list, the, the, the, the window has shut.
Speaker 2:You cannot even call the country or the sanctioned individual and discuss are you on the list? Do you think you'll get off the list. Are you wrongly on the list? Are you rightfully on the list? Do you think you are you? are you close to having yourself or your vessel removed from the list? Do you think you're gaining ground in that regard? Do you have a pending hearing? You know, you know you can't do that. They don't want you to have any interaction at all. I mean just zero. So if you become, you're sort of in this black box and you kind of have to guess what you know openings, you might have to do business with one of these entities that are on the the sanctions, the countries that use it, some of the sanctions list.
Speaker 1:So then, if a um, if an individual or an entity, say a yacht or an airplane, is on one of these lists, it sounds like the United States, the EU and the UK, from what you were saying before, really the the primary lists. So if there is someone or something on one of those lists, does that mean that each of these countries or each one of these regions is enforcing the other ones lists?
Speaker 2:Yeah, that's a. That's a very good question And, frankly, the answer to that is a little bit, in my view, a little bit nebulous, and it's it's worth. It's worth noting a couple of things that I think can get you in deep trouble, and we hope the listeners will stay out of trouble. If you um, there are 200 people that work in OFACT. It's not just some amorphous idea, it's 200 living human beings, and those people are broken into different sections. Some are in the section that is enforcement of sanctions and others in a section of granting of licenses. You want to do something, you apply for a license and you're granted a license. You either have a general license or a specific license, but you, frankly, should have a fairly clear record that documents your belief that you have a license If it's a general license, and if it's a specific license, you better have something in writing.
Speaker 2:But the United States OFACT department has actually advised us that they really don't care. This is strange to me, but they don't care if a vessel to stay focused on the Yacht Law podcast turf. They don't care if they're on the EU list and on the UK list but not on the US list. What OFACT says is if it's on our list, we care, and you can't do business with it. We don't really get into who is or is not on the list run by these other countries, in the case of the UK, or group of countries, in the case of the EU.
Speaker 1:Okay. So then this may sound like a pretty obvious question, but I think it's something that people would want to know the answer to. If they're not enforcing each other's lists, then why is it important to check each of the lists? Because, just to give a scenario, let's say there's a US shipyard that wants to bid on a refit, if the yacht itself is not under sanctions, or if the owner is under sanctions in the United States but is under sanctions, say, in the EU, would that pose a problem for them?
Speaker 2:Well, i'm going to mention two or three scenarios here that I think will help answer that question, and the fundamental answer is, i believe you just have to do everything you can do and try to seek guidance as to what you can do going forward, and let me give you a couple of examples that I think will be helpful. Like so many things, there are now groups popping up that you can pay money to and they will tell you if something is on the list or not. In their view, the problem with that is that you can't delegate your criminal activity and say well, you know, i didn't kill her, you know that guy over there killed her. I mean, i'm not sure if that's a good analogy, but the point I'm making is that if the other guy gives you bad information and you violate the sanctions, you will be in trouble. This is a non-delegable duty that you have to make sure that every citizen is charged with knowing who they're doing business with. Is, you know, not on the sanctions list? This is across the board, and you can get into dooku trouble if you don't do your homework. And now I think lawyers, you know, are a little different, because they respond to their clients, they have malpractice insurance and they can certainly get into trouble and they can beg for mercy. You know after informing their Arizona admissions policy underwriter that there's an oops situation But it's a non-delegable thing. So to pay some stranger over the internet that says if you give me money I will give you an answer on whether Joe Blow is on the list or not, is a very dangerous thing to do. That's number one. Number two inside of OFACT itself, you will get different, if not different, opinions, you will get different. Certainly you will get different attitudes. Okay, so I remember and I have, i do have proof and I don't want to get them mad at me because I have to work with them, but I get a lot of people mad at me as an attorney, so it just kind of goes with the turf.
Speaker 2:But we had a call at a three o'clock that came in after a call that was at one o'clock, both with OFACT, different groups of people. So we're confronted as a law firm with having a call with OFACT at one o'clock and with another call at three o'clock and it just seemed to me, based on human nature, that we would have a kind of a problem. It'd be like you know, you've talked to other, can't think of an analogy here. But you talk with your girlfriend at one o'clock and then at three o'clock you have another girl. She's not really your girlfriend kind of thing, but you're in touch with her. You're just going to have a problem if you don't sort of hit, you know, deal with that situation up front. So we told the one o'clock call. We called them, said, oh, by the way, is there any? what should we be? you know, we just want to make sure you're aware that we have this meeting at three o'clock today with these other people here, the three names. Oh, thank you so much for giving us this information. We will get back to you. That's diplomatic speak, meaning we had no clue that you were on the same vessel having a meeting at three o'clock today.
Speaker 2:The one o'clock person who I can envision that she's I know she's a nice person, she's got a beautiful attitude, she enjoy working with her. She's one of those persons. She got back to us and said we'll be combined the two meetings, okay. I said, okay, that, because that doesn't make sense, right, one o'clock, three o'clock one, i'd have one. So she says, oh, the other people will be joining us on the one o'clock call Also translation. They were not aware that we were having this meeting, meaning that the 200 people, people down the hall don't know what the people of the hall are doing. We got on the call.
Speaker 2:The people that were on the three o'clock call were hostile, just angry, hostile. Do not screw with us, we will mess with you. You have no idea of what kind of trouble we can bring to your doorstep, which is kind of like that's kind of a bad attitude, in my view, for the American government telling American citizen that they're going to rain hellfire down on them if we somehow screwed this thing up. But the first person, this lady, was very nice and very helpful, very, in my view, appropriate. But the point of that story is don't assume that one side of the house knows what the other side of the house is doing. So you've got differences of opinion, but you also have differences of opinion inside the same house And you don't and for God's sakes don't rely on some vendor in the marketplace.
Speaker 2:Get a law firm that has a malpractice policy. There is an advice of counsel defense which you could have some. It does get some credibility with some courts. The lawyer told me to do it and the lawyer says yes, i told him to do it and it's documented. So I think that answers I think hopefully that kind of answers your question about how do you navigate. But I will tell you that fundamentally, within that envelope of doing business with OFAC, they do not want you to have any interaction period in where they sanctioned individual or sanctioned vessel period. They just believe that that could lead to troubles for them in the ultimate effort which is the war effort that they're a part of.
Speaker 1:Right right, and your answer definitely addressed part of the question. To get to a scenario that we often see in yawning, though, is there a good reason to check all of the lists simultaneously, using the example of, say, a foreign flag yacht that's owned by a European entity coming into the United States, where the US doesn't have the vessel or the owner under sanctions, but the EU might, or the UK might?
Speaker 2:even We've actually had that situation And the difficulty the answer kind of becomes. Sometimes your answers come in a way that it's the ancillary or related things. So this particularly just very, very engaging captain, very open, you can tell that Manus, trying to do his best for his owner and his vessel, was not for sure, for sure, for sure, not on the United States list. However, the vessel was in fact on the UK list and there was no mistake about it. It was the vessel, the name and the beneficial owner identified on the UK list. Now, if you took OFAC at its word, you would at least the person we talked to. This is the problem. You could do business with this person And, by the way, the circumstances confronted and the answer, the final answer, rather flies in the face of maritime law that goes back for hundreds of years, not thousands of years, and that is, you know, the whole idea of any port in a storm.
Speaker 2:When you have a vessel that is in danger, it's got some deficiency. It has. In this particular case, it had some shaft and engine issues. It was not safe to navigate And that particular vessel wanted to come to a USER to have the problem with the shafts and the engines addressed. Now he's in a holding pattern somewhere and completely undisclosed location, but somewhere on the other side of the Panama Canal, on the south side of the Panama Canal. Panama Canal runs north to south, so he was somewhere on the south side trying to make a decision Do I go to some second tier situation in South America or do I go down the canal or up to Canal, and should I enter the United States and have a proper yard take care of my problem?
Speaker 2:Well, in the course of this conversation he says well, we're not going to be moving anyway because the insurance is canceled. So now we have an answer, at least a prohibition on the policy on the problem The boat's not going to move, it's got no insurance. It would be catastrophic if the boat were to sank or have a collision or some kind of grounding or some kind of major major casualty. So basically he just says we know I'm locked in now, so I'm just going to have to stay low here And so basically that was the end of the inquiry. But we were always trying to get on a humanitarian ground an exception to doing business with this person. But we needed to get a clearance from the UK sanctions list people And we were not able to get it. The United States sanctions list he's on our list, so we don't care, but the reality is we just simply could not come in and said the boat, as far as I know, is still sitting out there someplace trying to get engines and taking care of it.
Speaker 1:So that really does underscore why it's important to have a maritime lawyer, because you would know how to no pun intended navigate the system versus the average person who means well and can read well but doesn't know all the nuances and doesn't know the right connections.
Speaker 2:Exactly, and you're really in a A very difficult situation. One of the things that happens is a very simple transfer of a vessel's ownership from buyer to seller. It can be catastrophic, of course, if you buy a sanctioned yacht and now you're going to lose the money you paid for the yacht and you're going to lose the yacht as well, and you're talking that's a catastrophe. And again, on the issue of, i know we're talking oligarchs and the Russians, and that's the power curve right now, because it's popping up all over the place. We'll talk about it in depth at some point. In Fiji there's a case, and in Germany there's a case, and in the UK there's a case. Here's an example of a situation where everyone in the yachty world needs to know. You can't just you know. You're charged with knowledge. It's like you're charged with knowing the law, but I think you're kind of charged with using your common sense.
Speaker 2:A vessel called equanimity comes to mind, and equanimity was a man that was going around. He's kind of a high profile guy. His name is Zolo Not to be confused with JLo, but Zolo And he was actually got himself on the front page of the New York Times, i think, having bought, you know, not one bottle, but 50 bottles of champagne for Lindsey Lohan. But where was his money coming from? You know, something that in the yacht world, we see more and more these days is the Know Your Client rules and all that which is virtually ubiquitous in the yacht world. It turns out his money was coming from something called the Malaysian Development Fund. Well, this, to me, would be an example of someone that probably could, should be, and ultimately did, end up on a sanctions list under the kleptocracy laws. This is a law. These are the laws the United States government is getting very, very good at enforcing, where governments steal from their own people. In this particular case, the Malaysian Development Fund was stealing money, or money was being stolen from it by the Confederates, the people that Zolo had compromised And that he would receive, you know, billions, and then he would kick back hundreds of millions. A lot of those people went to jail, and that's another long story, but it's a story of use your common sense.
Speaker 2:Why is there a $400 million boat being sold for $200 million? You've got to ask yourself that question. You can't. It's just not a good deal.
Speaker 2:The every, every, every scam, every fraud, every situation that's akin to that. You know, aponsie scam, et cetera has been something where, if not immediately in the middle of it, looking back it was evident that there was something wrong with that picture. Okay, i mean Bernie Madoff came to the law firm. They wanted to sell these two boats. You know, red flag number one two boats being sold at once. That's rare. You don't buy two boats, you don't sell two boats, you sell one boat. Why is he selling two boats? Is it a catastrophic financial situation? Well, you go on the internet and you see that he's under a cloud. So we took a pass and we didn't get involved and the two yachts owned by Mernie Madoff went someplace else and the people that tried to buy them lost their money and got into a lot of trouble.
Speaker 2:Equanimity same thing Now Zholos. Now he's absconded, he's now living in China, said to be living in China. Equanimity has been seized. It's now the property, i think, of the Malaysian government or somebody. But the United States facilitated all of that.
Speaker 2:All of this is kind of sanction-sanction-related stuff under the kleptocapture department of the Department of Justice, right under Merrick Garland, the Attorney General, the next level down, very high level kleptocapture laws that interface very directly with the OFAC laws in terms of trying to keep order in the world and going after what we might imagine, or if we call the bad guys But they love yachts and they love yachts and like yachts are like it's like a honey to a bear or something. Right, it doesn't matter what you do, how many people you kill. If there's a yacht in there, it's going to be in the story. It's something we should probably talk about in future podcasts about the image of yachting or something I'm not sure what we would talk about in terms of legalities I guess defamation But yeah, it's related to trying to hold the world together as governments see things. Who are the good guys, who are the bad guys? I read this morning and I didn't start to go a little bit of field, but maybe for future discussion.
Speaker 2:Diane, the Chinese are now set to be opening up a listening post like an intelligence gathering post in Cuba. Cuba is 90 miles from Key West. We like Cuba. We have a million Cubans in Miami and the law right now that says you can't go there. It's on the sanctions list. You can't go there. You can't do business there. I get this every day. Can I go to Cuba? No, and if you go, it doesn't matter if you're a US citizen or what the United States government says, no, if you go to Cuba. So we're concerned. You've broken US law and the US law has a long arm. And I read this thing, and I think it was this morning. I said well, there's Cuba, it's going to be on the back burner again for a while.
Speaker 1:Right, right. So for someone who is not a lawyer, is there a way for them? I realize it is the right thing to do to have a lawyer on your side if you need to do business with someone or who's on a sanctions list or if you have questions about whether someone or something is on the sanctions list. But is it possible for a yacht buyer? is it possible for a shipyard CEO? is it possible for a supplier to check the OFAC list? and what about the EU list and the UK list? Are these publicly available websites, for example?
Speaker 2:Absolutely Very good question and say it's right up there in front of us. I should have mentioned this at the very beginning. But yes, if you go onto Google and search, you do this for any of the three entities we mentioned the EU, the UK and the United States. Frankly, i don't know of any other country in the world that presumes to have this kind of reach, but these are pretty powerful group of countries. This is the secret of the American power is allies. We have allies. We have UK allies, we have German allies, we have Japan allies. That's the secret of our power, is the reach of the allied network.
Speaker 2:But yes, you go, you Google Office of Foreign Asset Control, department of Treasury, i think this Foreign Asset Control and there is a button that says sanctions list and it pops up. It's user friendly. It says search sanctions list. You go there and you pick one of the categories that you want to search and it will tell you. It'll pop down and it'll say results one and you'll see the name of the Russian you're looking into. You've got to be very careful because of the misspellings of the original lettering of their name and the Russian language may not be perfectly analogous, but you have to just do your homework and maybe have a separate I do know in some cases two different names with kind of the same person. But generally do your best to identify the individual you want to do business with and maybe you'll be okay. And I'd like to just say I think that even with all of that, the lawyer thing is extremely important not to be shamelessly promoting the hiring of lawyers.
Speaker 2:But one of the organizations that is another example in other exhibit A was an example was a guy named Addis Salmarclopaz-Bella. He's not every day you meet someone named Salmarclopaz-Bella And it's kind of an unusual first name. Is he Salmarclopaz or is he Salmarclopaz-Bella, but his name is for sure, for sure, salmarclopaz-bella. And so that particular thing is kind of the end stage of what happens in the maritime world. And Mr Bella had been unable to pay 27 different categories of people and vendors that served a certain yacht. And I think this is kind of important because this is how we all make our livelihood, your readers, with mega yacht news and lawyers on the same footing. But 27 different entities had been unpaid. Some were contractors, some were suppliers of necessaries, some were suppliers of fuel, most were crew members, but all unpaid. So hopefully this will be helpful. It's kind of where the lawyer comes in.
Speaker 2:We sort of did a research and we found a case that involved something called the Stansel I call them the Stansel Planish because it was a group of Planish And that group had lost relatives in Columbia fighting the federated armed forces of Columbia, which was a rebel group. And so you know you're on to something, because now you've figured out that this man with this name has a connection to Park. It turns out that he's Venezuelan. Well, both Venezuela Venezuela, more so than Columbia is on the sanctions list. But the point is is that this Venezuelan is doing business with Park, and so he's now in a lawsuit in front of a very good federal judge named Robert Scola.
Speaker 2:Robert Scola, being a better than average judge, not an excellent judge, i think he's an excellent judge said well, look these maritime claims, all these yacht claims. They trump all these other claims. It's maritime law, it's admiralty law, it's in the federal system. Those lanes exist on this vessel right now. It doesn't matter what's happening at Park in Venezuela and Columbia, these maritime claims. We've got to deal with these first, because that's what the law says we have to do. It's the federal preemption doctrine, and how admiralty law is written into the United States Constitution, article 3.
Speaker 2:And ocks and can't straight the law in that case and that the Nationalessed是這樣 law is the one of it. He said so let's get these maritime cases handled. And they were all handled, dispensed with and the boat was sold for $27 million actually a bit more than that, but roughly $27 million And the lane payments were paid and the balance of the money would have gone to the Stansel Planets. Except that an appeal was taken and Judge Scholar was reversed. The Eleventh Circuit said you just can't take people's property. On the evidence that was before you that day, we're going to acknowledge the maritime claims. That's okay. Those people get paid, they can go away, have a nice day. But we need to kind of undo what you did with respect to the taking of the yacht itself. So we're now ordering some of the money to be put back in the red show. I'm not sure that never happened, by the way.
Speaker 2:Anyway, i tell you that, diane, i see we've kind of got to the end of our time limit on the recording And you and I tend to get weeds in some of these things, but it's kind of important. I get a lot of calls, when people say to me you know I handled them not so long ago for this young man, but as he's in the doorway he says, well, i wish I had known you. When this happened to me, i said, well, come back, sit down. And we ended up collecting on that particular matter for him as well, because that is just something that you know. Maritime law is a wonderful law in the sense that generally it has a very strong superior type interest. It kind of comes out of global commerce and the things moving around between nations and so forth, so it's kind of a very strong superior position.
Speaker 1:Right, right, because we have about maybe a minute or two left. I do want to make sure we cover one other thing for everybody. We want to help people stay out of trouble, even inadvertently, when they try to do the right things, they may feel like they've dotted all the eyes and crossed all the T's, but something gets missed. Is there any kind of behavior that could get somebody into trouble unwittingly, and what would the consequences be? Could you give an example of something that has happened in the industry?
Speaker 2:Oh, without a doubt, i think that the unwitting part is somewhere between intent and lack of intent is, you know, just lack in knowledge.
Speaker 2:You don't really have intent but you're.
Speaker 2:You just kind of screw up.
Speaker 2:And I know the recent example in the sanctions world, specifically in the Russian oligarch sanctions world, where the government of a sanction vessel, the government that had possession of a sanction vessel, was basically putting out throughout the entire world that they were taking bids, they wanted to sell it off. They had the right to do it, their Congress had met, the Congress had passed, the boat would be sold at a legitimate auction and the sale would be valid and so forth, but that when one particular bidder tried to transfer funds to an account that referenced the vessel by name, the funds were seized. So the sender of the funds had no knowledge at all that he was violating any laws. He's a completely law abiding citizen. Great American, on every level, would never even dream of breaking the law. Very simply, it was oblivious to the fact that he was breaking the law. But because of the little spiders of the internet, they see the name of this vessel and they see his money, which was in the nine figure, in the 10 figures actually Not nine, but 10.
Speaker 1:Not insubstantial.
Speaker 2:Yeah, so the funds were grabbed and just frozen. They weren't seized, they weren't taken away. They were taken away for that moment, but they were frozen. But that's an example of someone who has the best of intentions but suffers this sort of shock of where are my funds and whether I've been seized. Why? because of the violation of the sanctions.
Speaker 2:So it is one of those things you have to be very much aware of what's going on. I think that, in my experience, when you really get into trouble is usually, however, when the government somehow becomes aware of that. You do know, or you knew or should have known, that you were breaking the law, and the government will often go steps further to find a whistleblower or a witness or a mole or someone. That's going to make it clear, when the time comes, that you knew you were breaking the law, you were facilitating this, and that's when you're going to pay a very heavy penalty.
Speaker 2:We got a lot of calls from people because we're in Florida, we're in Miami, we got a lot of calls on Cuba, and it's fun to get people trying to work around and not by this and not this. But I have two passports and I live in London. I'm a US citizen. They try to get through these various things they think will allow them to enjoy Cuba, but it's a very dangerous gamble because of the way the United States, in this particular case, interprets the law. So all I can say is look for the red flags, use your common sense, and that way you can stay out of trouble. Most of the time, it's over the water that's qualified in the area that you're needing advice.
Speaker 1:Right, right. Well, everybody, you hopefully have learned a lot from this conversation. I certainly have. There were certain things that I even already knew going into this conversation and found out a heck of a lot more about for sure. So, michael, once again, this has been very eye-opening and very informative, so thanks for your insight.
Speaker 2:It's my pleasure. I look forward to speaking with you about other related events for the art world and the art law as we go forward and have our next podcast. Thanks, then.
Speaker 1:Yeah, definitely Everyone. Once again, if you have a question that you would like us to address on an upcoming episode of the Art Law Podcast, you can contact Michael or me directly. Our emails are in the show notes. We can also keep you anonymous if you so wish. There's no need to have your name used, whether you are a yacht owner, a crew member or a representative in the industry, or even just somebody who wants to learn more about the world of yachting, we are here to help you become better educated. That's all for this episode of the Art Law Podcast. Until next time, i'm Diane Byrne. Michael, why don't you sign off?
Speaker 2:Thanks very much. It's been a pleasure and I hope all of you have a wonderful day.
Speaker 1:Thanks everyone.