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July 17, 2014 SANCTIONS INTELLIGENCE UPDATE GENNADY TIMCHENKO & VOLGA GROUP adapting BUSINESS FOLLOWING U.S. & Canadian sanctions Overview In March and April, the US government sanctioned Russian businessman Gennady Timchenko, his Luxembourg-registered holding company Volga Group, and ten related subsidiaries. Timchenko was identified as a “member of the Russian leadership’s inner circle,” whose involvement in the energy sector was “directly linked to [President] Putin.” To date, Canada has sanctioned Timchenko, Volga Group, and nine Volga Group subsidiaries. The European Union has not acted against Timchenko or Volga Group. Since the announcement of US and Canadian sanctions, Timchenko and Volga Group- controlled firms have announced new projects in Asia, Europe, and Syria with reported financing from Chinese and Russian banks, including institutions sanctioned by the US on July 16. Financial institutions engaged in global business should consider the implications for AML and sanctions risk management. Timchenko’s post-sanctionS business ventures in China In late April 2014, President Putin appointed Gennady Timchenko to lead the Russia-China Business Council (RCBC), a body created in 2004 to expand partnerships between the two countries. Timchenko told reporters after President Putin’s RCBC announcement: “You know what Putin said? He introduced me by As head of RCBC, Timchenko is advancing Volga Group interests in saying Mr. Timchenko is the head of our business council. In other China. words – it is my words here – he is our main man for China.” • In late May 2014, Volga Group is constructing a terminal for announced a joint-venture with coal and iron ore shipments in the state-owned China Harbour Russia’s Far East. Sakhatrans Engineering Co (CHEC) to expand is sanctioned by the US and coal production capacities in Canada. Russia’s far east. CHEC manages Timchenko’s Volga public infrastructure projects Group companies Volga Group is also involved in an globally, including in the Middle operate in the energy, Arctic gas project with international East, United States, Caribbean, transportation, energy majors through a 23 percent Central America, South Asia, and stake in publicly-traded Novatek. infrastructure, and West Africa. On July 16, the US applied sanctions beverage sectors, with that restrict new financing for • The joint-venture will grant CHEC interests and partners Novatek. minority stakes in two Volga in Europe, Russia, Asia, subsidiaries: Kolmar, a coal mining The Yamal LNG onshore natural and North America. company that has not been gas project in the Russian Arctic is sanctioned; and Sakhatrans, a joint venture formalized in early a Volga Group-controlled 2014 between Novatek (60%) and transportation company that two European and Asian energy conglomerates. los angeles • washington d.c. • www.camstoll.com • (424) 234-8440 2 Yamal LNG project site • In May 2014, Timchenko CJSC Stroytransgaz (A.K.A. ZAO told reporters during the St. Stroytransgaz). Stroytransgaz Petersburg International Group is sanctioned by the US Economic Forum that Chinese and Canada, whereas CJSC banks were willing to finance up Stroytransgaz is not sanctioned. to $20 billion of the $27 billion Novatek is Russia’s project cost of the Yamal LNG second largest natural • CJSC Stroytransgaz relies on project. Timchenko also stated gas producer. Novatek a variety of North American that Volga Group would invest in and European equipment sells and distributes China’s LNG storage and pipeline manufacturers to support its infrastructure. hydrocarbon products operations, according to its in southeast Asia, China, website. • On May 20, 2014, a Yamal LNG Brazil, and Europe. press release announced that • CJSC Stroytransgaz currently a Chinese development bank holds contracts with as well as Moscow-based Stroygazmontazh, the energy Vnesheconombank (VEB) construction firm controlled by and Gazprombank signed a Putin inner circle member Arkady memorandum agreement Rotenberg. Stroygazmontazh to complete project financing CJSC Stroytransgaz and Arkady Rotenberg are for Yamal LNG in the fourth projects include all sanctioned by the US and quarter 2014. On July 16, the US Canada. applied sanctions that restrict of Russia’s strategic new financing forVEB and pipeline projects, In May 2014, CJSC Stroytransgaz Gazprombank. according to the won a $4.8 billion tender to company’s website. construct the Bulgarian section of Volga Group the $38 billion South Stream gas company pursues pipeline. The South Stream pipeline South Stream aims to connect Russian gas pipeline supplies with Eastern Europe while bypassing Ukraine. The tender Timchenko’s Volga Group owns was issued by South Stream 63% of Stroytransgaz Group, Bulgaria, a 50/50 joint-venture which in turn owns a 50% stake in between Gazprom and Bulgarian oil and gas construction company Energy Holding. los angeles • washington d.c. • www.camstoll.com • (424) 234-8440 3 The South Stream pipeline route • In August 2013, CJSC On June 8, Bulgarian Prime Stroytransgaz opened offices in Minister Plamen Oresharshki Bulgaria, Serbia, and Slovenia – all announced that the government countries involved in the South suspended construction of Stream project. the South Stream pipeline at the request of EU officials who • As of late 2013, French and want to investigate the process Dutch financial institutions were for awarding South Stream coordinating financing for the Bulgarian Prime Minister, contracts for the Bulgaria South Stream project. Plamen Oresharshki section. The main opposition to the Oresharski government has indicated it wants to cancel the CJSC Stroytransgaz contract and reopen the bidding process if elected. As of mid-July, the Oresharshki government planned to resign and schedule elections for autumn 2014. Bulgarian section of South Stream pipeline under construction los angeles • washington d.c. • www.camstoll.com • (424) 234-8440 4 Source: Washington Post Volga Group Currently in the planning Feodosiya Enterprise oil terminal minority-owned phase, the Kerch Strait in Feodosiya, Crimea, due to the firm pursues bridge would be the lack of a land route to Crimea. first overland route bridge connecting • Gazprombank and another Russia to Crimea connecting Russia Russian financial institution issued mainland and the multi billion ruble credit facilities In April 2014, SK MOST announced Crimea peninsula across to SK MOST in recent years. its intention to bid for the the Kerch Strait. With construction of the Kerch Strait motor and rail capacity Stroytransgaz bridge. SK MOST specializes in bridge and tunnel construction. SK planned, the Kerch Strait Agrees to MOST is not sanctioned; however, Bridge will enhance Irrigation Stroytransgaz Group, which is cargo and petroleum Development sanctioned, owns 25% of SK MOST. transport capacity Project with between the territories – Syrian Government • SK MOST manages public further integrating the infrastructure projects primarily In late June, the Syrian state Russian and Crimean in Russia, according to its news agency reported that website. The company handled economies. “Stroytransgaz” signed an construction of major rail and agreement with the Syrian road projects for the 2014 Sochi government’s General Commission Winter Olympics. on Water Resources to complete The Camstoll Group a $2 billion irrigation project in • SK MOST planned to bid for advises on sanctions, northeastern Syria. the Kerch Strait bridge project illicit finance, national together with Mostrotest – a security, and regulatory The project was reportedly initiated construction firm in whichArkady matters. Our research at the directive of President Bashar Rotenberg and his son Igor are intensive approach for al-Assad. significant minority investors. financial institutions, Arkady Rotenberg is sanctioned multinationals and by the US government. governments is Contact Howard Mendelsohn. designed to generate To subscribe • As of mid-April 2014, oil imports insights and options to the from Russia to Crimea were for complex policy, Sanctions routed via maritime transport regulatory or Intelligence to the US and EU sanctioned competitive challenges. Update, contact: insights@ camstoll.com los angeles • washington d.c. • www.camstoll.com • (424) 234-8440 5.
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