Executive Summary
- Dispute between Australian superyacht purchaser Chugga Chugg Pty Ltd and Lebanese holding company Privinvest Holding SAL over a delayed yacht construction contract with German shipbuilder Nobiskrug GmbH.
- Contract price €99.55 million for a 79.99m yacht; delivery delayed from August 2022 to September 2022 due to financial and management issues at Nobiskrug.
- Nobiskrug entered insolvency proceedings in Germany in April 2021; arbitration initiated but discontinued due to insolvency.
- Chugga Chugg counterclaimed for repayment of instalments paid; insolvency administrator accepted claims totaling €14 million.
- Contract and guarantee governed by English law; guarantee subject to English courts’ jurisdiction.
- Sanctions implications arise from involvement of German company Nobiskrug and Lebanese Privinvest, with UK and German geopolitical relevance.
Sanctions Highlights
- German company Nobiskrug GmbH, part of Privinvest Group, involved in contract and insolvency proceedings.
- Privinvest Holding SAL is Lebanese-based, potentially subject to EU and UK sanctions regimes.
- Guarantee issued by Privinvest for €9.955 million under English law; potential exposure under UK sanctions (notably BIS regulations).
- Insolvency and arbitration complications may be affected by sanctions compliance and cross-jurisdictional enforcement risks.
Emerging Risks
- Insolvency of Nobiskrug complicates contract enforcement and recovery of funds.
- Arbitration discontinued due to insolvency administrator’s withdrawal, increasing litigation uncertainty.
- Potential for further delays or non-performance due to financial instability of shipbuilder.
- Cross-border enforcement risks heightened by differing insolvency laws (Germany vs. UK).
- Sanctions compliance risk for parties dealing with Lebanese and German entities amid evolving geopolitical tensions.
Geopolitical Impact
- German insolvency proceedings highlight Germany’s role in European shipbuilding and legal frameworks.
- UK courts’ jurisdiction over guarantee reflects London’s continued importance in maritime and commercial dispute resolution.
- Lebanon’s Privinvest Group’s involvement underscores Middle Eastern business links to European maritime industry.
- UK and Germany’s sanctions policies may influence enforcement and financial flows in this case.
- Broader implications for international contracts involving parties from sanctioned or sensitive jurisdictions.
Economic Intelligence
- €99.55 million contract value with significant escrow and self-financing elements by Nobiskrug.
- Financial distress at Nobiskrug led to insolvency, impacting €14 million claims by Chugga Chugg.
- Injection of funds by Privinvest’s late CEO Iskandar Safa prior to his death in 2024.
- Delays and insolvency may affect supply chains and market confidence in luxury yacht construction.
- Potential financial exposure for Privinvest under guarantee and insolvency claims.
Strategic Recommendations
- Monitor UK and EU sanctions updates relating to Lebanon and German entities to assess enforcement risks.
- Evaluate insolvency proceedings in Germany for potential recovery strategies and creditor rights.
- Consider pursuing claims under English jurisdiction guarantee to mitigate insolvency risks.
- Engage with insolvency administrators to clarify claim status and maximize recovery.
- Assess reputational and compliance risks linked to dealings with Privinvest Group amid geopolitical sensitivities.
- Prepare for protracted cross-jurisdictional litigation and arbitration enforcement challenges.
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**Source Notes:**
*Sanctions Intelligence Digest*
[https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/585.txt](https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/585.txt)