** PRIVATE BRIEFING DOCUMENT **

UK Connection to $30 Million From the Magnitsky Case

March 2016 1 In 2007, $230 Million of Hermitage’s Taxes ** PRIVATE BRIEFING Were Stolen DOCUMENT **

Hermitage Fund’s Russian companies were stolen and a group of corrupt officials and organised criminals stole $230 million of the Hermitage Fund’s Russian taxes

The Fraud against HSBC and Hermitage

HSBC PRIVATE BANK HSBC PRIVATE BANK OOO Pluton, (Guernsey) LIMITED (Guernsey) LIMITED (Kazan, Tatarstan)

HSBC Wiped off the Hermitage Fund Vehicles Trustee to Hermitage Fund Trustee to Hermitage Fund Shareholder Registry of Re-Registered in the Name Hermitage Fund Vehicles of Pluton in Tatarstan 100% 100% 100% 100%

Corporate HSBC MANAGEMENT Corporate Corporate HSBC MANAGEMENT Corporate Director (Guernsey) LIMITED Director Director (Guernsey) LIMITED Director GLENDORA KONE GLENDORA KONE 100% 100% 100% HOLDINGS Corporate Director HOLDINGS HOLDINGS Corporate Director HOLDINGS LTD LTD LTD LTD Cyprus Cyprus Cyprus Cyprus

100% 100% 100% 100% 100% 100%

V.Kurochkin V.Markelov V.Khlebnikov General Director General Director General Director General Director General Director General Director OOO RILEND, OOO PARFENION, OOO MAKHAON, OOO RILEND, OOO PARFENION, OOO MAKHAON, OOO RILEND, OOO PARFENION, OOO MAKHAON, Moscow Moscow Moscow Moscow Moscow Novocherkassk Novocherkassk Novocherkassk

Intercommerz Universal Bank Universal Savings Bank Savings Bank

Hermitage companies Perpetrators paid stole $230 m Budget of $230 m Russian Federation in capital gain taxes to in capital gain taxes from the Russian budget the Russian budget February December 2006 2007 2 Hermitage’s Russian Lawyer ** PRIVATE BRIEFING Discovered the Crime and Testified Against the DOCUMENT ** Officials Involved

Testimony to the Russian Investigative Committee 5 June and 7 October 2008

“Taxes paid [by Hermitage Fund companies] were significant which apparently caused an interest from the police bodies.” “... [T]he premises of Firestone Duncan’s affiliate...were searched by forces of 30 police officers. Several minutes later I received a call from the affiliate of Hermitage Capital...and was told that the office of their affiliate was also searched, and that the person in charge was A.K. Kuznetsov…I informed about the search the company’s lawyer... [Lawyer] arrived to the office of Firestone Duncan, however, he was not allowed in... I know that police officers had lists with names of about 20 companies, including OOO Rilend, Parfenion and Makhaon, and that they were seizing all the documents related to the companies from their list.” Sergei “The facts stated above evidence that the powers of attorneys issued by legitimate directors of [Hermitage Fund companies] …were used to protect the interests of Magnitsky the companies… and to expose the theft of budget funds in the amount exceeding 5 (five) billion roubles [US$230 million], which was clearly committed by the same group of persons who used the illegal re-registration of OOO Parfenion, Makhaon and Rilend and claims against these companies as an instrument to perpetrate the theft of budget funds.”

Source: Magnitsky Testimony, 5 June and 7 October 2008- http://russian-untouchables.com/docs/D64.pdf; http://russian-untouchables.com/docs/D65.pdf 3 ** PRIVATE Magnitsky Was Subsequently Arrested by the BRIEFING Same Officials and Was Tortured for 358 DaysDOCUMENT **

Order to Arrest Sergei Magnitsky Magnitsky Arrested at His Home 21 November 2008 24 November 2008

“Hereby I order Lt Col Kuznetsov to arrest Magnitsky” Signed: Investigator Oleg Silchenko

Magnitsky’ spent 358 days in detention 24 Nov 2008 - 16 Nov 2009

Lt Col Artyom Kuznetsov

Krechetov Droganov Tolchinsky

Source: Decree by Oleg Silchenko to Appoint Kuznetsov to arrest Magnitsky, 21 November 2008 http://russian-untouchables.com/rus/docs/D296.pdf 4 ** PRIVATE On November 16, 2009, Sergei Magnitsky BRIEFING Was Killed in Police Custody DOCUMENT ** On 16 November 2009, a team of 8 riot troopers placed him in an isolation cell, handcuffed him to a bed and beat him with rubber batons

Report on Use of Handcuffs On 16 November 2009 Dr Kornilov, a civilian Magnitsky was beaten emergency doctor, was finally let into the cell where in an isolation cell on Magnitsky was beaten to find him dead on the floor, 16 November 2009 with bruises from handcuffs on his wrists

Signed by: O.G. Kuznetsov Sanctioned: F. Tagiev Report on Use of Rubber Baton

“I was shocked to find the Signed by: D.F. Markin [sic], patient not in a hospital Witnesses: A.E. Larin, P.V. Borovkov room, but in a regular cell, Sanctioned: F. Tagiev on the floor dead”

Source: Reports on use of handcuffs and rubber baton, 16 November 2009, Moscow Public Oversight Commission Report, Testimony by Dr Kornilov, Civilian Emergency Doctor (8 Dec 2009) 5 ** PRIVATE Officials Involved in His Arrest and BRIEFING Persecution Were Subsequently Promoted DOCUMENT ** Officers Silchenko, Karpov and Kuznetsov were promoted to higher police ranks Oleg Silchenko Pavel Karpov Artem Kuznetsov

Lt Colonel Lt Colonel Lt Colonel

Major Major Major Source: http://www.mvd.ru/news/show_77869/ 6 ** PRIVATE Some of the Same Officials Were Given BRIEFING State Honours DOCUMENT ** On April 25 2013, Russian Interior Minister Kolokoltsev personally met and thanked officials involved in the $230 million fraud and persecution of Sergei Magnitsky

Lt. Colonel Silchenko and Lt. Colonel Vinogradova meet and shake hands with Interior Minister Kolokoltsev

Lt. Colonel Kuznetzov and Lt. Colonel Karpov meet and shake hands with Interior Minister Kolokoltsev

Source: http://m.ntv.ru/novosti/573637/; http://www.1tv.ru/news/polit/231852 7 ** PRIVATE There Was No Possibility of Getting BRIEFING Justice in DOCUMENT ** So Hermitage sought justice outside of Russia

8 ** PRIVATE Who Benefitted From the Crime? BRIEFING DOCUMENT **

Hermitage focused its efforts on finding the recipients of the stolen $ 230 million that Sergei Magnitsky exposed

$230 Million

9 ** PRIVATE The First Break Came from Russian BRIEFING DOCUMENT ** Whistleblower, Alexander Perepilichnyy In July 2010 Alexander Perepilichnyy contacted Hermitage, offering his help to find the stolen money

“Magnitsky’s death was shocking. Every Russian accepts corruption but torturing an innocent man to death is crossing the line”

Statement made by Alexander Perepilichnyy to Jamison Firestone at the Westbury Hotel Bar in London, summer 2010

Alexander Perepilichnyy 10 ** PRIVATE Perepilichnyy Provided Swiss Bank Documents BRIEFING Showing Who Allegedly Benefitted From the CrimeDOCUMENT ** The documents showed that Olga Stepanova, the tax officer who approved the illegal tax refund, received $11.7 million at Credit Suisse US$230 million fraud

Olga Stepanova, tax official who approved part of the fraudulent US$230 million tax refund

Vladlen Stepanov, Swiss bank husband of Olga accounts Stepanova

Source: Criminal Complaint filed by Hermitage with the Swiss authorities http://russian-untouchables.com/rus/docs/MicklethwaiteLetterJan282010.pdf 11 ** PRIVATE In 2011, the Swiss Authorities Froze the BRIEFING Stepanov’s Accounts at Credit Suisse DOCUMENT ** In response to the criminal complaint filed by Hermitage, the Swiss authorities opened an investigation and froze US$11.7 million in bank accounts related to Vladlen Stepanov, the former husband of Russian tax official, Mrs Olga Stepanova

The Office of Attorney General in Switzerland

Source: Barron’s, 16 April 2011, Crime and Punishment in Putin's Russia, http://online.barrons.com/article/SB50001424052970204569604576259313266852054.html; Russian Accounts Frozen at Credit Suisse, 5 May 2011, http://online.barrons.com/article/SB50001424052970203390704576305372800050168.html 12 In 2012, the Swiss Authorities Took Conflicting** PRIVATE BRIEFING Statements from Stepanov and Perepilichnyy DOCUMENT **

In mid-September 2012, the Swiss Prosecutor questioned Vladlen Stepanov and found his testimony contradictory to Alexander Perepilichnyy’s. To see who was telling the truth, the Prosecutor ordered a confrontation between them

Alexander Perepilichnyy Vladlen Stepanov

Source: Swiss Proceedings 13 ** PRIVATE On November 10, 2012, Alexander BRIEFING Perepilichnyy Was Found Dead in Surrey DOCUMENT ** Before the confrontation could be arranged, Alexander Perepilichnyy was found dead on a road near his house in Surrey, UK. He was 44 years old.

Alexander Perepilichnyy

Source: Reuters distributed image, http://www.standard.co.uk/news/crime/security-services-aid-police-in-russian-death-probe-8368247.html; http://www.bbc.co.uk/news/uk-20526631; http://www.dailymail.co.uk/news/article-2239608/Russian-supergrass-Alexander-Perepilichnyy-44-dead-outside-leafy-Surrey-mansion.html 14 Further Investigation Traced Some of the ** PRIVATE BRIEFING Stolen Money to the US DOCUMENT **

The US Department of Justice traced stolen funds to multi-million dollar properties in Manhattan, owned by companies belonging to the son of a Russian government official

Son of High ranking official Pyotr Katsyv

Source: United States of America v. Prevezon Holdings Ltd. et al, 1_13-cv-06326, No. 174 First Amended Complaint (S.D.N.Y. Nov. 5, 2014) and second Amended complaint (S.D.N.Y. Oct. 23, 2015) 15 ** PRIVATE In September 2013, the US Department of BRIEFING Justice Froze $14 Million of Assets DOCUMENT ** On 10 September 2013, the US District Court, Southern District of New York issued a freezing order for over $14 million in Manhattan property and bank accounts, allegedly linked to the $230 million theft uncovered by Sergei Magnitsky

Source: http://www.justice.gov/sites/default/files/usao-sdny/legacy/2015/03/25/U.S.%20v%20Prevezon%20et%20al.%20Complaint.pdf; https://www.occrp.org/documents/Prevezon_Restraining_Order_signed_by_court_9_11_13.pdf 16 In 2015, Authorities in France, Luxembourg and ** PRIVATE BRIEFING Monaco Froze a Further $10 Million Allegedly DOCUMENT ** Connected to the Magnitsky Case

$10 Million Were Frozen

Monaco Luxembourg Source: Council of Europe Report, 27 January 2014, “Refusing Impunity for the Killers of Sergei Magnitsky” 17 ** PRIVATE In Total - Eleven Countries Have Opened BRIEFING Money Laundering Investigations DOCUMENT ** In response to criminal complaints filed by Hermitage Capital, eleven countries opened investigations into money laundering

$230 Million

Cyprus Estonia Latvia Moldova Lithuania Poland

Switzerland Spain France Luxembourg USA

Source: Following The Magnitsky Money, by OCCRP, https://reportingproject.net/occrp/index.php/en/ccwatch/cc-watch-indepth/1619-a-convoluted-money-trail 18 In the Spring of 2016 Hermitage Discovered ** PRIVATE BRIEFING a Further $30 million Flowing into the UK DOCUMENT **

Information from criminal cases in other countries has unearthed a further $30 million of funds that flowed to the UK, believed to be linked to the crime uncovered by Magnitsky $30 Million

United Kingdom

19 ** PRIVATE On 21 March 2016 Hermitage Filed a Criminal BRIEFING Complaint with the National Crime Agency DOCUMENT ** The details of these transactions were filed in a new criminal complaint with the UK National Crime Agency on 21 March 2016, requesting that the NCA opens a criminal money laundering investigation “The preliminary overview above demonstrates that the UK has been used by KOCG as a hub for registering intermediary money laundering shell companies, as a source for nominee directors who turned a blind eye to the illicit activity on those corporate accounts, and as a destination for laundering illicit proceeds through purchases of industrial equipment, luxury goods, real estate and yachts.”

“We respectfully request that you consider this application and commence a thorough and effective investigation, gather available evidence, and bring to prosecution those responsible for money laundering offences in the UK jurisdiction.”

20 ** PRIVATE Of $30 Million That Flowed into the UK, $2 Million Came from BRIEFING Companies Allegedly Connected to Dmitry Klyuev DOCUMENT **

$2 Million

Dmitry Klyuev United Kingdom

21 ** PRIVATE BRIEFING Who is Dmitry Klyuev? DOCUMENT **

Dmitry Klyuev is the head of the Klyuev Organised Crime Group (KOCG) and the suspected mastermind of $230 million tax theft. He is on the US OFAC Sanctions list (subject to the ) and is an ex-convict in Russia Convicted in Russia (12 July 2006)

Dmitry Klyuev

22 Dmitry Klyuev Was Also the Owner of the Universal ** PRIVATE BRIEFING Savings Bank, the Main Conduit for the Stolen $230 DOCUMENT ** million Until 2008, when the Universal Savings Bank was dissolved, Dmitry Klyuev was believed to be the beneficial owner of the bank

Universal Savings Bank Dmitry Klyuev

Green boxes show corporate accounts with Universal Savings Bank, owned by Dmitry Klyuev, Head of Klyuev Organized Criminal Group (“KOCG”) 23 ** PRIVATE BRIEFING Where Did the Money Go in the UK? DOCUMENT **

Between December 2011 and January 2013, $176,084 were spent to hire private jets

Amount: $176,084 Private Jet Chartering Bank: Lloyds 113-117 Oxford St, London, W1D 2HW

Payee: Oxygen Aviation Ltd Foundry Court, Foundry Lane, West Sussex, RH13 5PY

Date: Dec 2011 – Jan 2013

Question to the Police: Who chartered these jets?

Source: http://www.oxygenaviation.com/ 24 ** PRIVATE BRIEFING Where Did the Money Go in the UK? DOCUMENT **

In April 2012, a payment of $192,963 was sent to an exclusive yacht and home interior design company in Chelsea

Amount: $192,963

Bank: HSBC 76-78 Kings Road, London SW3 4TZ

Payee: HB Interior 30 Redburn St, London, SW3 4BX “From London to Singapore, via Date: April 2012 Moscow, Australia and Bahrain, HB realizes projects all over the world” Question to the Police: Who was the owner of the yacht? Source: http://www.superyachttimes.com/designers/company/id/2808/; http://www.jennifertheriault.com/portfolio/files/hbi-london-pied-a-terre.pdf; https://uk.linkedin.com/in/helene-benhamou-405b0144; http://www.superyachtdesign.com/features/1086/my-troyanda-refit 25 ** PRIVATE BRIEFING Where Did the Money Go in the UK? DOCUMENT **

In March 2012, $20,792 was paid for the tuition of a student at an exclusive private school, Queen Ethelburga’s Collegiate

Amount: $20,792

Bank: Lloyds 8-11 Cambridge Cres, Harrogate , HG1 1PQ

Payee: Queen Ethelburga’s Collegiate Thorpe Underwood Hall, Thorpe Green “Top independent co-educational day and boarding school in England, Queen Ethelburga's Collegiate Foundation Lane, York comprises four schools and a kindergarten, each with its YO26 9SS unique qualities, but all sharing a common purpose of providing students with a first class education and the Date: March 2012 opportunity to work towards higher education and a successful career.” Question to the Police: Whose tuition was paid? Source: http://www.qe.org/ 26 ** PRIVATE BRIEFING Where Did the Money Go in the UK? DOCUMENT **

In 2009, payments totalling $41,436 were made to a couture wedding dress designer in Chelsea

Amount: $41,436

Bank: NatWest 314 Chiswick High Rd, Greater London, W4 5TA

Payee: Phillipa Leplev 48 Fulham Road, A luxury couture wedding dress designer Chelsea, London, “Phillipa Lepley is undoubtedly one of London's leading bridal couture designers known for her SW3 6HH impeccable style and taste... Over the past twenty years, Phillipa has created dresses for many Date: June – October 2009 discerning brides. Discretion is key for Phillipa.”

Question to the Police: Who was the beneficiary of the wedding dress?

Source: http://www.phillipalepley.com/ 27

** PRIVATE BRIEFING Where Did the Money Go in the UK? DOCUMENT **

In 2008, payments totalling $295,622 were made to the Glamour Credit Card (an elite credit card with no spending limit) SBS Glamour Card Amount: $295,622

Bank: RBS 1 Lockey House, St Peters Street, St Albans, AL1 3LR May-June 2008

Payee: SBS Glamour Card “Introduced to cater for the wealthiest Ladies 55 Bryanston Street, worldwide, the Glamour Card offers members London, access to a privileged and luxurious service the W1H 7AA likes of which have never before existed. Strictly by invitation only. Date: May – June 2008 No spending limit”

Question to the Police: Whose credit card was this and how was the money spent? Source: http://www.sbsws.com/glamour.html; http://www.insignia.co/insignia-cards/ 28 ** PRIVATE BRIEFING Where Did the Money Go in the UK? DOCUMENT **

In March – May 2012, two payments totalling $259,532 were sent to an individual with connections to an expensive property in Surrey

£5 million estate with tennis court, Amount: $259,532 swimming pool, 7 bedrooms, 5 reception rooms, 6 bathrooms Bank: Barclays 78 Turners Hill, Cheshunt, Hertfordshire, EN8 9BW

Payee Name: MI Quintero-Arbelaez

Payee’s Address: Wildcroft, Bourneside, Virginia Water, Surrey, GU25 4LZ

Date: March – May 2012 Question to the Police: Who were the beneficiaries behind these payments? Source: http://www.zoopla.co.uk/property/wildcroft/bourneside/wentworth/virginia-water/gu25-4lz/10015059; http://www.rightmove.co.uk/house- prices/detailMatching.html/svr/1122;jsessionid=85526A0257BB60CFF1606EF9DC730590?prop=22828044&sale=37568681&country=england 29

** PRIVATE BRIEFING Where Did the Money Go in the UK? DOCUMENT **

In February - August 2012 there were multiple payments to a tire manufacturer, totalling $819,351

Amount: $819,350

Bank: Lloyds Bank “Our great range of car, 4x4, winter and Bristol City Centre, high performance tires has been designed Unit 44-45, George and developed to match the high White Street, Bristol, specification established by today’s motor BS1 3BA manufacturers.”

Payee: Cooper Tire & Rubber Co Ltd Bath Road, Melksham Wiltshire, SW12 8AA

Date: Feb – Aug 2012

Question to the Police: Who was the recipient of these tires? Source: http://www.coopertire.co.uk/; http://business-directory.autosport.com/company/6844/cooper-tire-rubber-company-europe-ltd?cid=183; https://www.youtube.com/watch?v=2gRRBqIEKbA; http://www.jcsmuffler.com/auto-repair/tires-for-sale/ 30 ** PRIVATE BRIEFING Where Did the Money Go in the UK? DOCUMENT **

On 15 March 2010, $19,559 was spent in a fashion boutique La Petite S*****

Fashion boutique Amount: $19,559 “La Petite S***** is renowned for its Bank: Lloyds Bank sophisticated, strong identity with a 399 - 405 Oxford St, healthy dose of sex appeal.” London , W1C 2BU

Payee: La Petite S***** 39 Marischal Road London SE13 5LE

Date: 15 March 2010

Question to the Police: Who were the beneficiaries ?

Source: http://www.la-petite-s.com/pages/about-us 31

** PRIVATE Where Did the Other $28 Million of Funds Go in BRIEFING the UK? DOCUMENT ** In 2010, a payment of $240,000 was sent to an account with Saxo Bank, for a yacht

Amount: $240,000

Cor Bank: Deutsche Bank AG 6-8 Bishopsgate, EC2N 2DB, London

Beneficiary Bank: Saxo Bank AS Account: GB98**************5608

Payee: Unknown

Date : 22 December 2010

Details: for yacht

Question to the Police: Who chartered or purchased this yacht?

Source: Hermitage Criminal complaint (wire transfer) 32 Where Did the Other $28 Million of Funds Go in ** PRIVATE BRIEFING the UK? DOCUMENT **

$100,000 went to an award-winning luxury architect and interior design firm for “provisional design.”

Amount: $100,000 Bank: Barclays PALL MALL Leicestershire, LE87 2BB, Leicester, England

Payee: David Collins Studio 74 Farm Lane London SW6 1QA Account: GB83BARC20********0822

Date: 17 Feb 2012

Details: Project Deposit – Advance

Question to the Police: Who this project was for?

Source: http://www.davidcollins.com/projects/residential/arts-crafts-family-home-london-uk 33 Where Did the Other $28 Million of Funds Go in ** PRIVATE BRIEFING the UK? DOCUMENT **

€75,470 went to Peters & May Limited for yacht transporting services and logistics

Amount: €75,470 Bank: Bank of Scotland plc Bishopsgate Exchange, 155 Bishopsgate, London, EC2M 3YB, England

Payee: Peters & May Limited Unit 9,Goodwood Road Eastleigh, Southampton UK, SO50 4NT

Account: GB65BOFS12********0001

Date: 14 April 2008

Details: For Transport Service

Question to the Police: Whose yacht was transported and where from/to?

Source: http://www.petersandmay.com/gallery/photo-gallery 34 Where Did the Other $28 Million of Funds Go in ** PRIVATE BRIEFING the UK? DOCUMENT **

In September 2009, a payment of £115,315 was sent to Harrods Estates, a luxury London property agent

Amount: £115,315 Bank: NatWest City of London Office

Payee: Harrods Estates Limited 82 Brompton Road Knightsbridge, London SW3 1ER

Account: GB85NWBK60********1689

Date: 7 September 2009

Details: For Equipment

Question to the Police: Who was the tenant of this luxury property?

Source: http://www.harrodsestates.com/property/lettings/KNI150217/trevor-place-knightsbridge-sw7 35 Where Did the Other $28 Million of Funds Go in ** PRIVATE BRIEFING the UK? DOCUMENT **

On 26 March 2008, a payment of £2,500 was made to Quintessentially, a Personal Concierge

Amount: £2,500 Bank: RBS PLC LONDON,CAVENDISH SQUARE

Payee: Quintessentially (UK) LTD 29 Portland Place London, W1B 1QB

Account: GB70RBOS16********3475

Date: 26 March 2008

Details: For Travel Services

Question to the Police: Who was the recipient of these services? Source: https://www.quintessentially.com/ 36 Where Did the Other $28 Million of Funds Go in ** PRIVATE BRIEFING the UK? DOCUMENT **

In 2010 - 2012, several payments totalling £18,470 were made for Vera Basharatyan designed fashion items

Amount: £18,470 Bank: Barclays WESTMINSTER ABBEY, LONDON

Payee: Basharatyan V SAPPHIRE HOUSE, 73 LONDON, N20 9LD

Account: GB31BARC20********8612 GB56BARC20********6193

Date: 03 December 2010 – 11 January 2012

Details: Fashion items Question to the Police: Who were the beneficiaries? Source: http://nymag.com/thecut/fashion/shows/2012/fall/milan/rtw/basharatyan-v.html 37 Where Did the Other $28 Million of Funds Go in ** PRIVATE BRIEFING the UK? DOCUMENT **

On 6 April 2010, £19,500 was paid to Lane Fox (Residential), owned by Strutt & Parker, for property rental

Amount: £19,500 Bank: NatWest BERKELEY SQUARE, LONDON

Payee: Lane Fox (Residential) Ltd 15 Half Moon Street London, W1J 7AT

Account: GB20NWBK60********7339

Date: 6 April 2010

Details: Rent Demand

Question to the Police: Who was the tenant of this luxury property?

Source: As of August 3, 2007, Lane Fox Residential Limited was acquired by Strutt & Parker LLP. Lane Fox Residential Limited operates as a property consultant company. It specializes in the sale and letting of residential and agricultural properties. http://www.struttandparker.com/ http://www.bloomberg.com/research/stocks/private/snapshot.asp?privcapId=35013947 38 Where Did the Other $28 Million of Funds Go in ** PRIVATE BRIEFING the UK? DOCUMENT **

Between 2008 – 2011, various payments totalling $7,592,109 were made for IT solutions & services to Hewlett Packard

Amount: $7,592,109 Banks: Citibank NA CANARY WHARF, E14 5LB LONDON

JP Morgan Chase Woolgate House, Bournemouth

Payee: Hewlett Packard Europe BV

Account: GB39CITI18********4474 & GB52CHAS6********30402

Date: 2008 - 2011 Details: For Construction & Services Question to the Police: Who received these goods or services? Source: http://store.hp.com/UKStore/Default.aspx http://www.bloomberg.com/research/stocks/private/snapshot.asp?privcapid=6561749 39 ** PRIVATE The British Law Enforcement Agencies Have a BRIEFING Duty to Investigate This Money Laundering DOCUMENT ** It is connected with two high profile deaths

Death of Sergei Magnitsky Death of Alexander Perepilichnyy

16 November 2009 10 November 2012

40 ** PRIVATE Investigating the Crime is in the UK BRIEFING National Interest DOCUMENT ** The money flowed into the UK for the benefit of a known Russian criminal leader and money laundering network

Funds connected to Money Laundering Network $30 Million

41 ** PRIVATE Twelve Banks With Operations in the UK Were BRIEFING Conduits or Recipients of the $30 Million DOCUMENT ** Nearly every major UK bank has been used by the money laundering network $8,515,098 $465,694 $4,135,827

$2,781,766 $723,614

$2,265,875

$567,556 $451,394

$1,991,732 $406,346 $1,229,281

$1,562,047

42 ** PRIVATE British Citizens Seem to Be Involved in the BRIEFING Money Laundering Network DOCUMENT ** Directors of companies allegedly involved in the Money laundering Damian Calderbank, born 1964 director of Kareras Limited, and 708 companies (including 430 UK companies), resident in Dubai

Andrew Stuart Moray, UK, born 1957 director of Forres Limited, UK listed as nominal director of 214 BVI companies, 36 UK companies, 43 Irish and 4 New Zealand companies

Matthew Charles Stokes, UK, born 1977 director of Rosina Limited, UK listed as nominal director of 248 BVI companies, 8 UK companies, 668 Irish and 332 New Zealand companies

Nomirex Trading Limited (UK), US$66mln illicit funds turnover Reported: Dormant accounts 2007-2009 http://www.theguardian.com/uk/datablog/2012/nov/26/offshore-secrets-companies-sham-directors , Companies House, UK 43 ** PRIVATE Are We Confident that the UK Authorities BRIEFING Will Investigate? DOCUMENT ** No. Hermitage’s UK lawyers have filed numerous complaints to investigate criminal offences and money laundering in the UK, and no cases have been opened.

2010 NO ACTION

2012 NO ACTION

2012 NO ACTION

2013 NO ACTION

2015 NO ACTION

44 ** PRIVATE BRIEFING 2010 – Metropolitan Police – No Action DOCUMENT **

In 2010 Hermitage filed complaints with the Metropolitan Police (MPS), highlighting the UK nexus of the Klyuev group’s criminal activity. However, MPS replied that “responsibility to investigate the fraud does not lie with the MPS.”

Metropolitan Police reply (May 2010)

“In considering the issues that concern you I am of the view that jurisdictional responsibility to investigate the fraud and money laundering to which you refer does not lie with the MPS.”

Hermitage request with MPS to investigate money laundering in the UK (1 March 2010)

45 ** PRIVATE BRIEFING 2012 – SOCA – No Action DOCUMENT **

In 2012 Hermitage filed a complaint with the Serious Organised Crime Agency (SOCA), requesting an investigation into the UK connections to the $230 million fraud. However, SOCA replied that it was not an “appropriate body” for the job.

SOCA’s reply (Feb 2012) “I can confirm that we have accepted your letter ... as other suspicious activity reports [SAR]..., however, ... SOCA ... neither confirm[s] nor deny whether a particular SAR has led to an investigation. To the extent that your client is a victim of crime and wishes to make a formal crime Hermitage request with SOCA report, SOCA is not the to investigate money laundering in the UK (Jan 2012) appropriate body for this.”

46 ** PRIVATE BRIEFING 2012 – SFO – No Action DOCUMENT **

In 2012 Hermitage filed complaints with the Serious Fraud Office (SFO), further highlighting the financial crimes which had occurred in the UK jurisdiction. However, SFO refused to do anything, because “Matters ... do not fall within the offences that the SFO is permitted to investigate.” The SFO’s reply (April 2012) “Matters which you have raised in your letter of 20 January 2012 do not fall within the offences that the SFO is permitted to investigate ... There is nothing that the SFO can do to assist.... There is no doubt that the matters you have raised are serious” Hermitage request with the SFO to investigate money laundering in the UK (Jan 2012)

47 ** PRIVATE BRIEFING 2013 – HMRC – No Action DOCUMENT **

In 2013 Hermitage filed a complaint with HMRC, seeking a review of the UK company formation agent which facilitated the Klyuev group’s money laundering in the UK; however, HMRC cited “confidentiality” to disguise the lack of investigation. HRMC’s reply (June 2013)

“You will be well aware for reasons of confidentiality HMRC neither provides feedback ... nor we disclose any information ... and this includes progress reports or the results of any enquires made.” Hermitage crime report to HMRC to investigate money laundering in the UK (May 2013)

48 ** PRIVATE BRIEFING 2015 – NCA – No Action DOCUMENT **

In 2015 Hermitage filed a complaint with NCA, outlining the flow of money from the $230 million fraud to the UK; however, the NCA replied that “a domestic criminal investigation relating to money laundering in the UK is not the most effective way forward.” NCA’s reply (Dec 2015) “At this stage a domestic criminal investigation relating to money laundering in the UK is not the most effective

Origin Company Name Origin Account No EUR GBP USD ABACOS INTERTRADE LTD. LT037010000009603292 € 1,184,482.05 £698,951.82 $2,077,691.18 way forward.” DELICO CORPORATION LT067010000019603162 € 611,805.26 £986,881.76 $9,681,858.67 DEMOLUX BUSINESS S.A. LT947010000027603981 € 10,000.00 £18,000.00 $191,435.00 EASTERN CAPITAL SECURITIES INC. LT367010000010603932 € 17,744.95 £4,512.05 $505,394.00 ENERPRO GMBH CORP. LT407010000019603617 X X $381,066.00 EVIAC HOLDING, LTD. LT897010000030603699 € 561,132.49 £174,100.14 $277,820.03 HILLROY MARKETS LTD. LT527010000015603897 X X $600,000.00 ITAN INVEST CORP. LT037010000009603777 X £52,318.05 X MONOVITA CORP. LT317010000027603563 X X $108,251.50 NATSILANE SERVICES, INC. LT317010000027603563 X X $80,000.00 NEOPARK VENTURES CORP. LT527010000027603379 € 5,435.25 £3,051.69 $302,820.30 ORNADO COMMERCIAL LTD. LT587010000009603757 € 25,591.27 £26,164.64 $2,839,913.51 PROTECTRON COMPANY INC. LT047010000024603160 € 102,894.00 £102,894.00 $425,132.68 VANTEREY UNION INC. LT817010000020603434 € 51,698.89 £10,575.40 $311,826.60 VENTA PRODUCTIONS CORPORATION LT047010000008603786 € 396,596.09 £26,636.53 $80,492.28 ZARINA GROUP INC. LT527010000022603902 € 1,450,609.92 £91,529.55 $655,009.03 TOTAL € 4,417,990.17 £2,195,615.63 $18,518,710.78

Hermitage crime report to NCA to investigate money laundering in the UK (June 2015)

49 ** PRIVATE The UK Authorities Should Investigate this BRIEFING Case DOCUMENT **

Source of funds to the UK: Money stolen from the Russian Treasury, uncovered by Sergei Magnitsky

Senders of funds to the UK: Companies connected to Dmitry Klyuev, leader of the Russian organised crime group, and exposed by whistleblower Alexander Perepilichnyy

Intermediary senders of funds to the UK: Dormant UK companies, nominally owned by British citizens, which filed zero or minimal financials while transacting large sums of money on bank accounts in Russia, Latvia and Lithuania

Date of wires to the UK: Continued from 2008 to 2013

Criminal conspiracy: Operational since 2001, ongoing, transnational in scope

Public interest: None of the wires from the illicit sources have been detected by UK authorities, despite red flags raised Multinational corporations accepting significant amounts of suspicious funds raises further red flags of corruption and kickbacks 50 ** PRIVATE BRIEFING DOCUMENT **

APPENDIX

51 ** PRIVATE BRIEFING Where Did the Money Go in the UK? DOCUMENT **

Details of wire transfers sent from Altem Invest Ltd and Zibar Management Inc to the UK from 2008 – 2013 (1 of 2)

52 ** PRIVATE BRIEFING Where Did the Money Go in the UK? DOCUMENT **

Details of wire transfers sent from Altem Invest Ltd and Zibar Management Inc to the UK from 2008 – 2013 (2 of 2)

53 ** PRIVATE Where Did the Other $28 Million Go in BRIEFING the UK? DOCUMENT ** Summary recipients: wire transfers from Lithuanian Ukio bankas accounts to UK accounts in 2008 – 2012 (1 of 14)

Source: Hermitage Criminal Complaint 54 ** PRIVATE Where Did the Other $28 Million Go in BRIEFING the UK? DOCUMENT ** Summary recipients: wire transfers from Lithuanian Ukio bankas accounts to UK accounts in 2008 – 2012 (2 of 14)

Source: Hermitage Criminal Complaint 55 ** PRIVATE Where Did the Other $28 Million Go in BRIEFING the UK? DOCUMENT ** Summary recipients: wire transfers from Lithuanian Ukio bankas accounts to UK accounts in 2008 – 2012 (3 of 14)

Source: Hermitage Criminal Complaint 56 ** PRIVATE Where Did the Other $28 Million Go in BRIEFING the UK? DOCUMENT ** Summary recipients: wire transfers from Lithuanian Ukio bankas accounts to UK accounts in 2008 – 2012 (4 of 14)

Source: Hermitage Criminal Complaint 57 ** PRIVATE Where Did the Other $28 Million Go in BRIEFING the UK? DOCUMENT ** Summary recipients: wire transfers from Lithuanian Ukio bankas accounts to UK accounts in 2008 – 2012 (5 of 14)

Source: Hermitage Criminal Complaint 58 ** PRIVATE Where Did the Other $28 Million Go in BRIEFING the UK? DOCUMENT ** Summary recipients: wire transfers from Lithuanian Ukio bankas accounts to UK accounts in 2008 – 2012 (6 of 14)

Source: Hermitage Criminal Complaint 59 ** PRIVATE Where Did the Other $28 Million Go in BRIEFING the UK? DOCUMENT ** Summary recipients: wire transfers from Lithuanian Ukio bankas accounts to UK accounts in 2008 – 2012 (7 of 14)

Source: Hermitage Criminal Complaint 60 ** PRIVATE Where Did the Other $28 Million Go in BRIEFING the UK? DOCUMENT ** Summary recipients: wire transfers from Lithuanian Ukio bankas accounts to UK accounts in 2008 – 2012 (8 of 14)

Source: Hermitage Criminal Complaint 61 ** PRIVATE Where Did the Other $28 Million Go in BRIEFING the UK? DOCUMENT ** Summary recipients: wire transfers from Lithuanian Ukio bankas accounts to UK accounts in 2008 – 2012 (9 of 14)

Source: Hermitage Criminal Complaint 62 ** PRIVATE Where Did the Other $28 Million Go in BRIEFING the UK? DOCUMENT ** Summary recipients: wire transfers from Lithuanian Ukio bankas accounts to UK accounts in 2008 – 2012 (10 of 14)

Source: Hermitage Criminal Complaint 63 ** PRIVATE Where Did the Other $28 Million Go in BRIEFING the UK? DOCUMENT ** Summary recipients: wire transfers from Lithuanian Ukio bankas accounts to UK accounts in 2008 – 2012 (11 of 14)

Source: Hermitage Criminal Complaint 64 ** PRIVATE Where Did the Other $28 Million Go in BRIEFING the UK? DOCUMENT ** Summary recipients: wire transfers from Lithuanian Ukio bankas accounts to UK accounts in 2008 – 2012 (12 of 14)

Source: Hermitage Criminal Complaint 65 ** PRIVATE Where Did the Other $28 Million Go in BRIEFING the UK? DOCUMENT ** Summary recipients: wire transfers from Lithuanian Ukio bankas accounts to UK accounts in 2008 – 2012 (13 of 14)

Source: Hermitage Criminal Complaint 66 ** PRIVATE Where Did the Other $28 Million Go in BRIEFING the UK? DOCUMENT ** Summary recipients: wire transfers from Lithuanian Ukio bankas accounts to UK accounts in 2008 – 2012 (14 of 14)

Source: Hermitage Criminal Complaint 67 ** PRIVATE BRIEFING DOCUMENT **

Disclaimer

Some of the information herein is based on data obtained from publicly available sources, which have not been independently verified by Hermitage Capital Management Limited, or any of its respective associates or affiliates (“Hermitage”). Furthermore, as a result of the difficulty in obtaining reliable data in Russia, Hermitage does not represent this information to be accurate and complete, and Hermitage does not accept any responsibility for the reasonableness of any conclusions based upon such information.

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