Kroll 2

I Kroll_
22 March 2018
Project Tenor II -
Confidential Working
Papers Part I to the
Detailed Report
Detailed tracing analysis
Privileged and Confidential

I Kroll Project Tenor 11, Confidential Working Papers Part I to Detailed Report
(Detailed Tracing Analysis)
Privileged and Confidential
Rest ricted Use Warn ing
This confidential working paper to the Detailed Report, provided to the National Bank of Moldova (the "NBM"
or the "client") on 22 March 2018, was prepared by Kroll at the request of the client. Kroll has agreed to the
client's request that a copy of this confidential working paper may be submitted to the Moldovan General
Prosecution Office, the Anti-Corruption Prosecution Office and the Agency for Recovery of Criminal Assets
(the "Moldovan Authorities") only subject to the Moldovan Authorities maintaining this confidential working
paper as strictly confidential. The client and the Moldovan Authorities agree that this confidential working
paper to the Detailed Report is strictly confidential and is intended solely for the use of the client. Any other
use is strictly prohibited and the client and the Moldovan Authorities have agreed that no such use will occur.
Any communication, publication, disclosure, dissemination or reproduction of this confidential working paper
to the Detailed Report or any portion of its contents to third parties is subject to the advance written consent
of Kroll. Kroll assumes no direct, indirect or consequential liability to any third party or any person other that
the client for the information contained herein, its interpretation or applications, or for omissions, or for reliance
by any such third party or other person thereon. To the extent information provided in th is confidential working
paper to the Detailed Report is based on a review of publicly-available records , such information , as
presented, relies upon the accuracy and completeness of those records, which have not been corroborated
by Kroll. Statements herein concerning financial, regulatory or legal matters should be understood to be
general observations based solely on Kroll's experience as risk consultants and may not be relied upon as
financial, regulatory or legal advice, which Kroll is not authorized to provide . All such matters should be further
corroborated through appropriate legal channels with appropriately qualified advisors in these areas.
i'·:-rivi/egac! 2n d Con/i'c!entiaf
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, Kroll Project Tenor 11, Confidential Working Papers Part I to Detailed Report
Contents
1. Introduction to detailed tracing analysis .. ................... ................. ............................. ......... 6
1.1 Caveat.. ............... ............. .. ......... ..... .. ....... .. .......... ......... ......... ............ .... .......... ........... .. .. .. ................... 7
2. Individual Moldovan beneficiaries/ transit accounts .. ...... ...... .. .. ............ .......... ................. 8
3. Transactions with corporate accounts linked to individuals ................................. ........... 17
3.1 Accounts linked with Plahotniuc .. .. ............ .. ......... .... ............... .... .. ........ ............ .... .... .. .... ... .................. 17
3.1.1 Longford Partners (USO 24.5 million) ....................... ... ..................... ............... .......... .. .... ............... 17
3.1.2 Rastel European Trade Corp (USO 5.3 million) .... .. ...... ... .. ............ .... ... ........ ..... .... .. ........... ... ... ...... 18
3.1.3 Rowallan Overseas S.A. (USO 0.5 million) .... ........... ............... .... ..... .... .............. .. .............. .. ..... ..... 18
3.1.4 Borgh Traders Corp (secondary I Jinked company) ...... .. .............. .. .. .. .. ................... .. ..... ........ .... ..... 19
3. 1.5 Tukumaan Limited (secondary I linked company) ........................................................................... 19
3. 1. 6 Example of funds from loans flowing through Plahotniuc companies ...... ... ........................... ..... ..... 20
3.1.7 Finpar Invest SRL /CS .. ........ .... .... .............................. ............. ... .... ....................... .... .. ........... ........ 22
3.1.8 OT/V Prime Holding a. V. .................................................... .. .... ............ .. ... .. .............. .... .... .. ........... 23
3. 1.9 Gemeni SA Casa de Comert ("Gemeni'J .................................................................................... .... 23
3.1.10 Prime Management SRL .............................. ...... ........ ..... ....... .. ......... .... .......... ............................... 23
3. 1. 11 /CS Prime TV ............................... ........ ........... ... ........ ...... ......................... .......... .. .......... .... .. ..... .... 24
3.1.12 Basconslux SRL.. .................. ............... .... ... ......... ........ .. .. ....... .... ..... ..... .. .. ...... ... .. .. ........... .... ...... ... 24
3.1.13 Credit cards - individuals_linked to Plahotniuc companies .... .... .... .. ..... ....................................... .... 25
3.2 Accounts linked to Vlad Fila!... ...... ............... .............................................. .......... ...... ......... ......... ........ 26
3.2. 1 Rodos Overseas Ltd (USO 7. 3 million) ................................... ........ ... ................... ........... .... ...... .. ... 26
3.2.2 Business Estate Investments SRL (USO 6.4 million) ........... ......... ... ...................... ... .... ........ .. ..... ... 27
3.2.3 Overseas Property Solutions Ltd (USO 4.0 million) ...... .... .......... ..... ... ..... .. .. .... ..... .. .... ...... ............... 27
3.2.4 Caravita SRL (USO 1.5 million) .... .. ............... ...... ........ ................ ................... ......... .. ..... ... ..... .. ...... 27
3.2.5 Aldgate Trading LP (USO 0.5 million) ... .... .. .... ........ .. ....... ............ ..... .. .... .. ..... .. ........ .... ....... ... ......... 28
3.2.6 East Global Business SRL (USO 1.4 million) .. .... .. ..... ... ....... ...... ... .. .... ..................... ..... ... .... ... ........ 28
3.2.7 Next Estate Investment SRL (USO 0.6 million) ........... .................................... ... ........... .... ....... ...... 29
3.2.8 Timbuktu Resources LP (secondary I linked company) ... .. ................. .. ................................ .......... 29
3.2.9 Ferenta Commerce LLP (secondary I linked company) ....... .. ................. .. ...... .. ..... .... ... .. .... ..... ... .... 30
3.2.10 Credit cards linked to Fi/at ..................................... .. .. ......... .... .............. .. ....... ........ .... ................... .. 30
4. Individuals involved in the suspected fraud mechanisms - Russian accounts ............... 33
5. Analysis of accounts that received suspected fraud funds from further tracing .............. 38
5.1.1 Latvia (USO 302. 1 million) ...... ............. ............ ................ .......... ......... ... .......... ... .. ... .. .. ..... ...... ... ..... 38
5.1.2 Moldova (other Moldovan banks) (USO 169.3 million) ................. .. .... ...... ..... .. .. .. .. .. ........ .... .... ........ 38
5.1. 2.1 Amounts paid to Victoriaban/( (USO 106. 9 million) ....... ........... .............. ........... .... .... .. 39
,0 tivile~rar.l f1nd Conliclentiaf

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~ Kroll Project Tenor II, Confidential Working Papers Part I to Detailed Report
5. 1.2.2 Amounts paid to Moldindconbank (USO 50.5 million) ............... .... ... ........ ...... .. ..... ...... 40
5. 1. 3 Cyprus (USO 112.4 million) ............................. ... .. ..... ... ......................... .............. .. .... .. .. .... ....... ...... 41
5. 1.4 China (USO 83.3 million) ........ .... ...... .. ... .... .. .......... ... ..... ..... .. .... .... ....... ...... ................. ... ...... .......... . 43
5.1.5 Russia (USO 79.5 million) ........... .... ...... ...... ........ ......... .... .... ... ....... ... ...... ....... ........... .. .. ....... .......... 48
5.1.6 Estonia (USO 51.4 million) .... ... .... ....... .... .............. .. .. .... ....... ..... ..... .. ...... .. .... .... ........ .... .... ............. 49
5.1.7 Switzerland (USO 42.8 million) ......... ........... ... ....... .... ..... ... ........ ..... .. ..... ............. ... .... .... .. .. .. ........ .. 50
5.1.8 USA (USO 25.5 million) .......... ... .. ..... ....... .. ...................... .................... ........ ....... .. .... .. ........ ........ .. .. 51
5.1.9 Hong Kong (USO 22.6 million) .......... ................... .. ..... ...... .... ........ ............... ....... ........... ... .. ... ......... 53
5.1. 10 Italy (USO 16. 8 million) .. .. ..... .... .. ....... ........ ...... ...... ... ............ .. ..... ... .... ......................... ................ 54
5.1.11 Romania (USO 15.8 million) ................. .... .... .... ... ..... ..... .. ..... .. .. ...... .. ...... .... ... .. ....... ............. ..... .... . 55
5.1. 12 Germany(USO 11. 1) ..... ................................... .. .... ....... ..... ...... ...... .... ..... .... ... ...... ..... ..... ................ 55
5.1. 13 Turkey (USO 10.4 million) ..... ..... ... .... ... ...... ... .... .............. .... ... .......... ............. .... .. ... .... ... ..... .. .. ....... 57
5.1.14 Netherlands (USO 8. 6 million) .. .. .. .. ................................. .. ..... ..... .. ................. ............ .... ... ......... .. .. 58
5. 1.15 United Arab Emirates ("UAE'J (USO 6.8 million) .. ... ... ..... ....... .... .. .. .... ... :... ... .... ... .. .. ..... ................... 59
F)rivifega cl and Contir:.'enUe.!

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~ Kroll. Project Tenor 11, Confidential Working Papers Part I to Detailed Report
List of Figures and Tables

Figure 1 - Fund flow example linking loans to the Three Moldovan Banks to companies linked to
Plahotniuc ..... ....... ....... ......... .. .. ...... .. ...... ........ .... ... ...... .. .. ......... ......... .. ... ... ... ..... .... ..... .. ...... ... .... 21
Figure 2 - Screenshot from bizzer.md - showing links between Plahotniuc and Prime
Management ........ ............ ...... .... ... ...... ... ... .... .. ... .... .... .. ...... .... .................... .... ................... ... ... .. 24
Figure 4: Sequence of transactions made in Gotha Club between 30 July and 1 August 2014 .... 30
Figure 5: Post by @maxcremers placing Filat at Goth a Club in the relevant period ... ..... .. .. .. .. .... 30
Figure 6: Photograph of Luka Filat and @maxcremers in Gotha Club .. ............... ... ... ..... ...... ... ... 31
Figure 7: Transactions in St Tropez in June 2014 - Luka Filat... ... ...... .. ...... .. ............... .. .... .. .. ..... 32
Figure 8: Social media link to transactions in St. Tropez ....... .. .... ...... .. .... ... .. ..... .... ... ...... ............ 32
Table 1 - Summary of individuals in receipt of funds in part derived from the fraud ........ .............. 8
Table 2: Individuals identified in Section 7 of the Detailed Report ....................... ... ...... .. ..... .. ... .. . 15
Table 3: Alef Bank accounts in the name of individuals transacting wih ABLV and Privatbank
accounts (links to Shor Group or other high profile Moldovan figures) .... .... .... ... .. .... ... .. .. .. ..... ..... 34
Table 4: Alef Bank accounts in the name of individuals transacting wih ABLV and Privatbank
accounts (no identified links to Shor Group or other high profile Moldovan figures) .... .. ... ... .. .... .. 37
Table 5: Summary of transfers to accounts at Victoriabank .. .. .... ....... ...... .... ... .... ..... .. .... .. .. ........ . 39
Table 6: Summary of transfers to accounts at Moldindconbank .. ...... .... .... .. ..... .. .. .......... ..... .. ..... .40
Table 7: Overview of transfers to Cyprus ........... .. ......... ....... .. ..... ............ ... .... ... .. ........ .. .. .. ... .... .. . 41
Table 8: Overview of transfers to China .. .. ...... ...... ... ...... .. ............................... ... .... ....... .... ... ..... . 43
Table 9: Overview of transfers to Austria (USO 56.1 million) .... .. ..... .. ........ .... .... ... ....................... 49
Table 10: Overview of transfers to Switzerland ... ... ..... ..... .... .... ... .... ... ... .. .... .. ..... .. ..... .. ... .. .. .. .. .. ... 50
Table 11: Overview of transfers to USA .... ............. ... ... .... ... .... .. .. ...... .. .... .. ... ...... ... ..... ... ... .... ... .... 51
Table 12: Overview of transfers to Hong Kong ........ ...... .. ... .. .. ..... .... ..... ............ ...... .................... 53
Table 13: Overview of transfers to Italy ... .... ..... ....... .. ... .. .. .. ...... ... .. ... ....... ....... .. .. ...... ..... .. .... ...... . 54
Table 14: Overview of transfers to Romania ... .... .. ..... .. ......... .... .. ....... .... ............. .. ... ... .. ..... .. ....... 55
Table 15: Overview of transfers to Germany ..... .. .. .... ... .... ... .. .. ... .. .... .... ....... ............. .. .. .. ............ 55
Table 16: Overview of transfers to Turkey .. .. ..... .. ... .. .. .. ... ... .. .... .. ....... ................ .. .. ...... .. .... .. ..... .. 57
Table 17: Overview of transfers to Netherlands .. .... ... ... .. .. .... .. .... ...... ..... ..... .... ...... ... ..... ...... .... .... 58
Table 18: Overview of transfers to UAE .. .. ...... ............... .... ...... .... .. ........... ... ....... ....... ... ....... ....... 59
Privileg scJ anc/ Conficlentiat

5
~ Kroll Project Tenor 11, Confidential Working Papers Part I to Detailed Report
1. Introduction to detailed tracing analysis

This document (the "Detailed Tracing Analysis") is the first part of the Confidential Working Papers
("Confidential Working Papers Part I") to the Detailed Report, issued as a final version on 22 March
2018 , in accordance with the Letter of Engagement dated 8 December 2017 (the "8 December
LoE") . It provides further extended analysis of the tracing of fund flows which originate in full or in
part from the suspected fraudulent loans issued to the Three Moldovan Banks during the Review
Period . A second part of the Confidential Working Papers ("Confidential Working Papers Part II")
includes the details of tracing analysis for a sample of individuals listed in Table 1 below.
As shown in the Detailed Report, tracing has identified that the majority of funds from the suspected
fraudulent loans which were not used to repay existing loans were transferred to corporate accounts
in multiple jurisdictions. Kroll has not been able to confirm who was in control and who benefited
from the majority of the transactions involving accounts in foreign jurisdictions. However, from the
documents which Kroll has reviewed to date, Kroll has identified a number of transactions involving
Moldovan individuals who appear to have received funds which were at least in part derived from
the fraud, were connected to accounts which received funds from the fraud , or who were involved
in the administration of the fraud. This document provides a summary of these transactions as well
as further details of the fund flows identified to accounts in jurisdictions outside Moldova, which
may be beneficial for future legal actions .
The Detailed Tracing Analysis focusses on the following areas:
• A summary of Moldovan individuals who have been identified during the review of
transactional data as having received benefit which was at least in part derived from loans
issued by the Three Moldovan Banks documented in the Detailed Report.
• A summary of transaction flows to companies that were found to be associated with two
high profile Moldovan individuals , Vladimir Plahotniuc ("Plahotniuc") and Vlad Filat ("Filat")
that, according Kroll's analysis, appear to have received funds which originated in part or
in full from fraudulent loans made by the Three Moldovan Banks during the Review Period .
• Details of other individuals who appear to have been involved in the mechanisms which
allowed the perpetration of the fraud, and the roles of these individuals to the extent which
can be determined from information currently available. This section focusses on accounts
identified at Russian banks in the name of Moldovan individuals, which appear to have
been used to further disguise the flows of funds . Funds transferred from the Russian
accounts in the names of individuals were dissipated to other destinations. The funds were
F'1} 1.1iiegsd 2nd Cordiderdia/

6
l Kroll Project Tenor II, Confidential Working Papers Part I to Detailed Report
then repaid to the Russian banks from funds originating from loans at the Three Moldovan
Banks.
• A glossary of company accounts in multiple jurisdictions which, according to Kroll's analysis,

received the proceeds of suspected fraudulent loans made by the Three Moldovan Banks
during the Review Period; and
• Three detailed examples of traces of funds from loans to individual beneficiaries. These
examples are intended to provide the Moldovan Authorities with examples of the nature of
documents which Kroll has reviewed in order to reach its conclusions. While these have
not been produced at this stage for all individuals named in the Detailed Tracing Analysis ,
Kroll can extend this work as instructed in. future stages of investigative work.
1.1 Caveat
This Detailed Tracing Analysis is based on documentation which was made available to Kroll
through its engagement with the NBM and the Three Moldovan Banks, including overseas bank
statements and bank account documentation obtained through arrangements between NBM and
foreign regulators, NBM analysis and regulatory reports. This has been supplemented where
possible by Kroll's public record research and analysis of electronic data sets from a select group
of custodians in the Three Moldovan Banks. Kroll makes no representation as to the authenticity
or completeness of the documentation provided by the NBM or other regulators . There may be
additional documentation or information to which Kroll has not had access which could contradict
or challenge conclusions drawn from the documentation reviewed to date.
t'ri"iie9ecl ancl Conric!enNa i

7
IKroll Project Tenor II, Confidential Working Papers Part I to Detailed Report
2. Individual Moldovan beneficiaries / transit

accounts
This section details fund flows which, according to Kroll's analysis, originated at least in part from
suspected fraudulent loans issued by the Three Moldovan Banks and which were transferred to the
accounts of Moldovan individuals, from the Core Laundering Accounts 1 or through a number of
intermediary accounts following the Core Laundering Mechanism. 2 It should be noted that a number
of the individuals identified in the table below were found to have links 3 to either llan Shor ("Shor")
or Plahotniuc.
A summary of the total of payments of more than USO 100,000 to individuals which were made
from accounts involved in the Core Laundering Mechanism is shown below. Due to the complexity
of the blending and of funds through multiple accounts, Kroll has not traced the values in the table
in their entirety to specific loans issued by the Three Moldovan Banks during the review period.
This has been performed on a sample basis in order to confirm links to the fraud. The list of names
is intended to provide scope for possible further investigations by the Moldovan Authorities.
Sections 7 .1 and 7 .2 of the Detailed Report include the fund flow diagrams of funds traced to the
Moldovan accounts linked to shareholders of the Three Moldovan Banks. These are not repeated
in this section.
In many instances , the transfers to the individual accounts did not constitute the end destination of
funds, and the funds were later transferred on to other destinations.
Table 1 - Summary of indiv iduals in receipt of funds in part derived from the fraud
Name Summary of transactions and details of individual Total of

payments
identified
(USD
Equivalent)
Analysis in the Detailed Report identified Shor and his
associates as the key driver behind the mechanisms of
llan Shor the suspected fraud. His involvement was instrumental in 13,019,934
all of the key stages of the administration of the fraud,
from gaining control of the banks through a series of
1
This is detailed in section 8 of the Detailed Report.
2
Ibid.
3
Links were identified through documents or via public record research
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I Kroll Project Tenor II, Confidential Working Papers Part I to Detailed Report

payments
identified
(USD
Equivalent)
linked nominee shareholders, to controlling and directing
the internal processes of the banks , to the establishment
of a series of companies working in concert to increase
the lending by the Three Moldovan Banks to a point
where they were no longer sustainable. Shor has also
been linked to the set up and management of the network
of UK companies holding Latvian bank accounts which
appear to have laundered the funds used to purchase the
shares of the banks, as well as to disguise the movement
of the proceeds of the loans.
Shor received funds which originated in part from the

loans issued at the Three Moldovan Banks.
The USD 13.0 million was made up of 35 transactions

between September 2009 and June 2014. The majority
of these fund flows were made in 2014. One of the 35
transactions was a payment of EUR 7.6 million (USD
10.1 million) could be traced to a loan to Shor company
Apropo-Com, issued by UB on 18 December 2013. This
payment was transferred to an account in the name of
Shor at Gazprombank in Russia, having first been
transferred through a number of intermediary companies.
Further detail of this fund flow is set out in the example
fund flow trace included in Confidential Working Papers
Part II.
Cojocaru was listed as an administrator for two ABLV

Ion Cojocaru
corporate bank accounts which were used to launder 4,971,226
("Cojocaru")
funds. 4 In addition, the analysis identified an ABLV
4
See Exhibit 14.1 , which shows that Ion Cojucaru is listed as an "Authorised Person" for Zonitech Properties Limited and
Torprom Universal LP.
F'rfi 1f!eqe d and (;onli•:lentia i

9

payments
identified
(USD
Equivalent)
account in his name, which was classified as a Core
Laundering Account in Section 8 of the Detailed Report.
This account was used frequently to make transfers to
and from other Core Laundering Accounts . It appears
that the main use of this account in the Core Laundering
Mechanism was as a conduit for the transfer of funds to
other individuals, as the funds were frequently
transferred on in quick succession .
An ABLV account in the name of Cojocaru received funds

totalling USO 4,971,226 across 133 transactions. The
funds were received from ABLV bank accounts in the
name of two individuals and seven entities . The majority
of these funds were received from Branch Marketing Ltd
(USO 2,903,357) and Plus Operations Ltd
(USO 1,891,127), both Core Laundering Accounts as
defined in the Detailed Report.
Ilona Sh or's ABLV bank account was classified as a Core

Laundering Account in Section 8 of the Detailed Report.
This account was used frequently to make transfers to
and from other Core Laundering Accounts . It appears
that the main use of this account in the Core Laundering
Mechanism was as a conduit for the transfer of funds to
Ilona Shor 3,139,615
other individuals. Of the USO 3,139,615 received into the
account in her name, Kroll identified transfers of USO
172,448 to a credit card account in her name.
Ilona Shor received a total of USO 2.5 million from the

account in the name of Cojocaru.
Privi.!egad and Con{ic/Gniie, I

10
l Kroll Project Tenor II , Confidential Working Papers Part I to Detailed Report

payments
identified
(USD
Equivalent)
Bondarciuc became a shareholder of UB in 2012. She
was also the public notary who, according to media
reports, notarised a number of documents relating to
Plahotniuc's business interests. 5
The majority of funds were received from two accounts
Olga Bondarciuc
held by Harrogate Consulting LP (USO 1,086,050), 1,456,447
("Bondarciuc")
defined as a Core Laundering Account in the Detailed
Report.
Further detail is set out in the example fund flow traces

included in Confidential Working Papers Part II.
Lupov was a shareholder in UB, who received funds from

Alef Bank, which were later repaid through loans from the
Three Moldovan Banks . As shown in the Detailed Report,
the funds which originated from Alef Bank appeared to
be repaid by loans from the Three Moldovan Banks and
Veaceslav Lupov
were treated as proceeds of the suspected fraud for the 526 ,535
("Lupov")
purposes of analysing onward fund flows .
Funds received by Lupov totalled USO 526 ,535. These
funds were remitted to Lupov in ten payments from Ion
Cojocaru (USO 301,535) and one payment from La
Costa Trade LLP (USO 225,000).
Negru was affiliated with Shor in a number of media
reports and was also a shareholder of UB.
Tudor Negru Negru received funds from ABLV bank accounts held in
1,351 ,322
("Negru") the name of Fairmac LLP (USO 1,203,957) and Ion
Cojocaru (USO 147,365) involving two and ten
transactions respectively.
Sergiu Pavluscenco Internet research has identified a possible link between
1,189,850
("Pavluscenco") an individual named Sergiu Pavlicenco, the husband of
5 https ://ww1,v.ri se. rnd/arti col/plaholniucleaksihttps ://1,w:w.rise.mdiarlicol/plahotniucleaks/
F•r_ivilegeo' :.1;11] 00i?rtcienfia/

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lKroll Project Tenor II, Confidential Working Papers Part I to Detailed Report

payments
identified
(USO
Equivalent)
Vitalia Pavlicenco, the head of the National Liberal
Party. 6 Pavluscenco received USO 408,500 in 61
instalments into an account held at Wells Fargo Bank NA
Philadelphia, transferred from Ilona Shor.
The ABLV account held by Pavluscenco received
USO 1,189,850 from four bank accounts , all held at
ABLV, through 225 transactions. The payers were the
corporate entities: IT Log Alliance LLP (USO 223,500),
Parselot Ltd (USO 488,450) and Tomton Trade
Corporation (USO 199,300); and a personal account held
by Ilona Shor (USO 278,600).
According to media reports, Irina Ulianovschi is the
daughter of the former president of the Moldovan Court
of Appeal, and is a presenter at PRIME TV, a station
reportedly owned by Plahotniuc.7
Ulianovschi's ABLV bank account received funds of
lrinia Ulianovschi USO 437,080 across 20 transactions, all from other
437,080
("Ulianovschi") accounts held at ABLV Bank. The majority of these funds
were received from three entities: Tukumaan Limited
(USO 308,560), Newline Commerce Ltd (USO 114,998)
and Rastel European Trade Corporation (USO 13,457).
All of these companies have been linked to Plahotniuc
(see section below) .
llan Shor's head of administration and BS shareholder. 8
Maria Gutuleac All funds paid to Gutuleac were received across nine
336,412
("Gutuleac") transactions from an ABLV bank account held by Ion
Cojocaru.
6
hti p://pn l. md/? p= 1367
7 https://www. rise .md/imagini-vlad imir-p lahotniuc-monitorizat-in -strainat ale-2/
8
www.mold-s tree t. com/?oo =news&n=3446 Report titled: INVESTIGATION: The Lords of the Banks in Moldova dated 17
December 2014.
F:,rivffeger.l anc;f Confideni'iaf

12

payments
identified
(USO
Equivalent)
Pankova was reportedly the General Director of
000 Victoria Trade, a company incorporated in Russia
Anastasia Pankova I in 2012. 9 Pankova was the General Director between
304,171
("Pankova") 28 April 2012 and 19 September 2013 . She received
USO 304,171 in four transactions from Ion Cojocaru
between March 2013 and December 2014.
A Moldovan millionaire, president of Stati & Co, and
owner of the club FC Davia Chisinau. 10 He had a number
of credit cards linked to the company Atlanta Traders Ltd
which were funded at least in part from loans from the
Three Moldovan Banks . Media articles have reported
that Shor stated that Stati was one of his close friends
Gabriel Stati and only business partner in Moldova. 11
235,687
("Stati'') Stati's credit card account with ABLV received funds from
three other ABLV accounts held by: Atlanta Traders Ltd
(USO 157,887), Tom ton Trade Corporation
(USO 22,200) and Zonitech Properties Limited
(USO 55,600). The funds originated from 396
transactions with all but three payments received from
Atlanta Traders.
Lasco is listed as the director of lnfoton-Com, 12 a Shor
group company that received numerous loans from the
Vasile Lasco
Three Moldovan Banks. 180,278
("Lasco")
All 13 identified payments to Lasco were received from
an ABLV account held by Ion Cojocaru.
9
See Exhibit 14.2 Extract from 000 Victoria Trade public record review (page 5).
10 http://arliiva.vipmagazin.md/top-_
mold oveni/detalii/Anato l %C5%9Fi Gabriel Stati. Tat%C4%83I %C5%9Fi liul %C3%AE%C5%9Fi unesc afacerile %
C3%AEntr-un imperiu linanciar comun/
11 http://gzt.md/article/%OO%B1 %O0%BE%O0%B3%O0%B0%D1 %82%D1 %8 B%D0%B5 %00%82 %D0%8D%D0%B8
%0 1%89%O0%B5%O0%B9 %01 %8 '1%D1 %82%D1 %80%O0%B0%O0%BO%O0%B5/1553/

12 http://www.bizzer.md/entitate/c%C4%83uta re?parle=La%C5%9Fco%20Vasile
Privileged &nd Ccni'icie ntial

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IKroll Project Tenor 11, Confidential Working Papers Part I to Detailed Report

payments
identified
(USD
Equivalent)
Maclovici was the registered director of Shor Group
company Asigromex SRL. 13 Further details can be found
of the fund flows in the detailed fund flows example.
Alexandr Maclovici
Fourteen payments were made to Maclovici from 179,891
("Maclovici")
Ion Cojocaru totalling USO 179,891.
Further detail is set out in the example fund flow traces
included in Confidential Working Papers Part II.
Olesea Munteanu, a Moldovan Businesswoman, 14
received USO 109,191 to the credit card account linked

to Newline Commerce. In addition, Kroll identified a
payment of USO 39,364 made to a CIC Banque (France)
Olesea Munteanu
account in her name from Rowallan Overseas SA. 148,825
("Munteanu")
The majority of payments received into Munteanu'sABLV
account were made from ABLV account held by
Tukumaan Limited (USO 109,060) and Rowallan
Overseas S.A. (USO 39,634).
Mester was the founder and director of Moldclassica
International, a Shor Group company which received
loan proceeds from the Three Moldovan Banks. 15
Mester was also director and owner of Apropo-Com SRL
Moisei Mester in July 2015, according to corporate records published in
135,575
("Mester") the media by Renato Usatii, the Chairman of Our Party
and a left-wing populist party. 16
The total amount of USO 135,575 received into Mester's
ABLV account was remitted by Ion Cojocaru across 14
payments.
TOTAL 17 27,612,848
13
https ://www.rise.md/foto-s h or-hol ding-proiecte-im ob iii are-schitate-I a-m oscova-2/
14
Munteanu was photographed with Plahotniuc at the Business Association of Moldova
15
http:/ /www. bizze r.mdientitate/1128 "I 03/societatea-cu-r%C4 %83 spundere-limi tat%C4 %83 -moldclassica-intem aiional
16
http ://www .rea Iit ate a. m d/ultirna-ora-ren ato -us ati i-f ace-I1 oi-d ezva Iuiri- i n-d os arul-m iii a rdul ui-fura t-d oc-vid eo 2 7 65 6.htm I
17
This total includes some double counting, as it represents the transfers to the individuals' accounts. A proportion of
these funds were then transferred to other individuals' accounts, particularly from Cojocaru and Ilona Sher's accounts.
1cii~ 1ifegec! a,7c! Cont"ic!ential

14
I Kroll Project Tenor II, Confidential Working Papers Part I to Detailed Report

payments
identified
(USO
Equivalent)
In addition to the individuals listed above, Section 7 of the Detailed Report also identified that
transfers were made to a number of Moldovan accounts of shareholders- or linked to shareholders-
of the Three Moldovan Banks . These transfers were used in the purchase of shares. The individuals
identified in Section 7 are listed below:
Table 2: Individ uals identif ied in Section 7 of the Detailed Report
Aurel Marinescu Alexandr Zavarzin Veaceslav Jardan
Lilya Pleskachevskaya Arina Corsicova Veronica Gorgas
Marina Tauber18 Anton Hariton
Nani Abashidze CazacAlla
Olga Bondarciuc 19 Elena Marinova
Petru Lucinschi Ivan Kostianko
Reghina Apostolova Natalia Gojina
Rita Tvic Oleh Stepanets
Roman Grinco Olga Nikitaeva
Tudor Negru 20 Sergey Merkulov
Veaceslav Lupov 21 Sergeii Andriichuk
Viorel Melnic Svetlana Petrenko
18
An Alef Bank account in Marina Tauber's name was also identified, see Section 4
19
Olga Bondarciuc was also identified in Table 1 above.
20
Tudor Negru was also identified in Table 1 above. An Alef Bank account in Tudor Negru's name was also identified ,
see Section 4.
21
Veaceslav Lupov was also identified in Table 1 above . An Alef Bank account in his name was also identified, see
Section 4 .
.Oriviieyed and Com'ic/Gnliaf

15
lKroll Project Tenor II , Confidential Working Papers Part I to Detailed Report
IVladimir Novosadiuc ITetiana Boiko
Pri~1i!eg30' ancf Co.·1 fic!entia /

16
, Kroll Project Tenor II, Confidential Working Papers Part I to Detailed Report
3. Transactions with corporate accounts linked to

individuals
The following section provides details of fund flows which originated at least in part from suspected
fraudulent funds, which were traced through the Core Laundering Mechanism to accounts for
companies which, from analysis of fund flows, could be linked to two high profile individuals ,
Plahotniuc and Vlad Filat ("Filat"), the former Prime Minister of Moldova.
Kroll has identified the links through p~blic record and media research or through transactional
analysis. The rationale or the purpose of the transactions and the end destination of funds requires
further investigation.
3.1 Accounts linked with Plahotniuc

Kroll identified funds in excess of USO 30 million , in part traced to the suspected fraudulent loans,
which was transferred to bank accounts held at Latvian banks as_~9ci~te_d with Plahotniuc. These
amounts were received from the Core Laundering Mechanism into accounts at ABLV held by:
• Longford Partners Ltd ("Longford") (USO 24.5 million);
• Rastel European Trade Corp ("Rastel") (USO 5.3 million); and
• Rowallan Overseas SA ("Rowallan ") (USO 0.5 million) .
Additional accounts are listed below which also transacted with these accounts or which appeared
to have some other involvement in the suspected fraud as intermediary bank accounts which moved
money to Plahotniuc related businesses .
3.1.1 Longford Partners (USD 24.5 million)

An ABLV bank account in the name of Longford received a total of USO 24.5 million from the Core
·-
Laundering Mechanism which could be linked to fraudulent loans from the Three Moldovan Banks .
It acted as a transit account for these funds and transferred USO 12 million on to Rowallan - see
below, which transacted directly with accounts in the name of Plahotniuc. The account also appears
to be linked to the administration of Plahotniuc linked businesses as low value administration
payments were made to the public notary Olga Bondarciuc, who, according to documents obtained
from media sources, has notarised a number of contractual documents relating to Plahotniuc and
is also a shareholder of UB .22
22 htlps ://w,.wi.rise.md/a rticol/p lahotniucleaks/https://m1.rise.111d/articol/olahotniucleaks/
,':)rf,:ifegtJci enci Conficlential

17
lKroll Project Tenor II, Confidential Working Papers Part I to Detailed Report
The Longford ABLV bank account had incoming transfers of USO 101 million between April 2009
and October 2014. Analysis has identified that Longford transferred a significant proportion of the
funds to a company account held at Hellenic Bank in Cyprus, in the name of Lazomar Trading Ltd .23
No further information has currently been obtained regarding this company.
3.1.2 Rastel European Trade Corp (USD 5.3 million)

The Rastel ABLV bank account had incoming transfers of USO 35.5 million between August 2013
and November 2013. Of this, USO 5.3 million of funds were identified as originating from the
suspected fraud . This account appears to be associated with Plahotniuc, due to the large volume
of transfers with other Plahotniuc accounts. This, along with other credits received was almost
entirely transferred directly to an ABLV bank account held in the name of Tukumaan Limited (see
section 3.1.5).
3.1.3 Rowallan Overseas S.A. (USD 0.5 million)

Rowallan was registered in the BVI with the address "lntershore Chambers, Road Town, Tortola,
PO Box 4342". Between the period 28 June 2006 and 24 September 2015, the account had
incoming receipts of USO (Equivalent) 646 million . During the Review Period (between 2012 and
November 2014), this account in the name of Plahotniuc received USO 8.0 million from this account.
The payments had the description "Agreement 21 .10.08 ." While these funds have not been linked
directly to the loan funds, the movements provide an indication that this account was used as a
transit account for business enterprises associated with Plahotniuc.
The USO 0.5 million in funds which were received into Rowallan directly from the Core Laundering
Mechanism accounts were predominantly transferred to an account in the name of Finpar Invest
SRL, a company which can be linked to Plahotniuc.2~
Additionally, in June and July 2013, Rowallan received USO 12.5 million which can be linked in
whole or in part to the fraudulent loans. The funds were received from Panaroom Management LLP
(part of the Core Laundering Account, see above) and through Longford Partners Ltd (see 3.1.1 ).
The funds were then transferred to Tukumaan Limited (see 3.1.5) which transferred USO 9 million
to Otiv Prime Holding B.V., another company linked to Plahotniuc. 25 These funds were then further
23
A summary of receipts for Lazomar Trading is included in section 5.1.3
24
https ://www.rise.md/ena li sh/p lahotniucleaks-2/
25
In November 2014 there was a court judgement in the Netherlands relating to a joint claim against Otiv Prime Holding
and Plahotniuc in relation to raider attacks on Victoriabank . htt p://i urnal.md/en/oolitici2014i11/26/assets -oi-70-mln-euro-
of-pl a hotniuc-s ei zed -bv-111 e-d utch-i us ti ce-d oc/
http :i /wwvv. i urn al.md/ en/po li tic/20 ·14/ '1112 7/un rn as ked -i n-e n qi a nd-i nves tig atecl-i n-ihe-n ethqrla ncl s-t he-in tern atio·n al -
i us ti ce-d oes n-t-look-at-p l ahotni uc-s-p ape rs/
Privifeger.: an c! Gonficten:'ial
18
split between other companies which can be linked to Plahotniuc - Otiv Prime Real Estate B.V., 26
Prime Management SRL and Otiv Prime Media B.V. 27 Prime Management SRL is the only company
listed on a statement of wealth for Plahotniuc which was completed in 2014. 28 The fund flows
relating to these transactions are shown in Figure 1 in this document.
Rowallan received another USD 3 million on 10 January 2014 from Longford Partners, which came :1
from Frances Trading (a Core Laundering Account). '
,:
3.1.4 Borgh Traders Corp (secondary/ linked company)

Borgh Traders Corp ("Borgh Traders") is registered in the BVI with the address "Pasea Estate,
Road Town, Tortola, BVI". Between July 2005 and December 2009, the ABLV bank account in the
name of Borgh Traders had incoming transfers of USD 197 million. Between August__?00Land July
_2-_~~2_ payments were made from the Borgh Traders ABLV bank account to accounts in the name of
Vladimir Plahotniuc at ING Bank Switzerland totalling USD 10.6 million. The company also
transacted frequently with both Rowallan and Longford Partners. Although Borgh Traders Corp was
in operation prior to the review period of the investigation to date, as it appears that the fund flows
associated with the fraud in the Three Moldovan Banks were linked to previous loans from
Victoriabank and Moldindconbank.
3.1.5 Tukumaan Limited (secondary/ linked company)

Tukumaan Limited ("Tukumaan") is registered in the Marshall Islands and similar to Longford,
Tukumaan appears to have acted in a group of companies with Rowallan, Longford and Rastel
Trade. It did not receive suspected fraud funds directly but channelled funds from Longford and
--·- -------- -·-··- .
_Rc1stel. It was active from November 2012 until October 2014 and during this time the account had
incoming transfers of USO 93 million . Approximately USD 30 million of this went to Otiv Prime
Holdings and Rowallan, both linked to Plahotniuc. It also made significant payments to a company
called Asiana Development Limited at Garanti Bank (totaling USO 3.4 million) and at Raiffeisen
Bank (totaling USD 0.3 million) in Romania, and at Hellenic Bank in Cyprus (totaling USO 2.2
million) .29
26
According to corporate registry searches, Otiv Prime Real Estate B.V . is wholly owned by Otiv Prime Holding B.V. See
Exhibit 14.3_Extract of public record documents - Prime Management SRL, Otiv Prime Media B.V. and Otiv Prime Real
Estate B.V.
27
According to corporate registry searches, Otiv Prime Media is owned by Olive Prime Management B.V. See Exhibit
14.3 _Extract of public record documents - Prime Management SRL, Otiv Prime Media B.V. and Otiv Prime Real Estate
B.V.
28
See Exhibit 14.4 Extract of Plahotniuc's statement of wealth
29
A summary of receipts to accounts in Cyprus is detailed in 5.1.3 and Romania is detailed in 0.
t 'rivifegGni an-:f (:;on/icler:tiai

19
3.1.6 Example of funds from loans flowing through Plahotniuc companies

The figure below shows an example of fund flows which originated from loans to eight Shor Group
companies issued by Unibank in June 2013. These funds were transferred through a number of
Latvian bank accounts in the names of Division Top LLP, Wang and Lee LP, Visseti (PTY) Ltd ,
Ekovold Projects Ltd, Bluefontein LP, Elma Union LLP, Hanlay Solutions LLP and Frances Trading
LP, before being mixed together in the account of Panaroom Management LP. From there, the funds
were transferred to the account of Longford, on to Rowallan and Tukumaan, before being
distributed to Otiv Prime Holding B.V, Otiv Prime Real Estate B.V and Otiv Prime Media B.V, which
are associated with Plahotniuc.
/=•rfvi.!eged and (~o, 1fic!~niiaf

20
Figu re 1 - Fund flow example linking loans to the Three Moldovan Banks to companies linked to Plahotniuc
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21
, Kroll Project Tenor II, Confidential Working Papers Part I to Detailed Report,
Details of some examples of the links identified between the recipients of these funds and
Plahotniuc are provided below:
3.1.7 Finpar Invest SRL ICS
Kroll identified a media article 30 which shows links between Finpar Invest SRL ICS and Plahotniuc.
Attached to this media article is a letter which the article indicates is from the Ministry of Justice of
Moldova. This letter summarises the ownership history of Finpar Invest SRL ICS (previously known
as Minor SRL) 31 as follows :
• On 31 July 1998 Childescu Oxana became a 90% shareholder in Minor SRL. Oxana's
share was subsequently increased to 95% on 18th September 1998. Oxana is reported in
numerous articles 32 to be the wife of Plahotniuc.
• In April 2003 Vera Morozan became a 95% shareholder in Minor SRL. Morozan is reported
in numerous articles 33 to be the sister of Plahotniuc.
• In 2008 Minor SRL became Finpar Invest SRL.
• On 14 May 2010 the ownership structure of Fin par Invest SRL was changed to the following:
o FIN PAR VICTORIA LIMITED (Cyprus) 34 - 88.91 %
o POWER INVESTMENT, LLC (USA) - 11.09%.
• Additional reports claim that Plahotniuc is the owner of Finpar Victoria Limited 35
• On 21 December 2010 the sole shareholder of Finpar Invest SRL was noted as OTIV
PRIME REAL ESTATE B.V. (Netherlands).
• On 17 June 2013 changes were made in the company documents to increase the capital
of the company and redistribute the share capital as follows:
• OTIV PRIME REAL ESTATE B.V. (Olanda - Netherlands) 93.90%
• CED RA INTERNATIONALS.A. (Belize) 6.10%
• On 17 July 2013, the sole owner of Finpar Invest SRL ICS was changed to OTIV Prime
Real Estate B.V.
30
https://www.rise.md/english/plahotniucleaks-2/
31
https ://www .s cribd. com/docu ment/265695216/I storicul-Fi npa r-I nvest#fullscreen& from_ embed
32
http://www.jurnal.md/en/politic/2016/9/12/who-is-the-new-administrator-of-plahotniuc-s-firm-finpar-invest-srl/;
https://www.rise.md/english/plahotniucleaks-2/;
33
http://www.jurnal.md/en/social/2015/7/7/morozan-plahotniuc-s-brother-in-law-and-one-of-judges-from-hell-promoted-
at-court-of-appeal-even-if-he-was-rejected-by-timofti/; https ://www.rise .md/english/plahotniucleaks-2/;
http://thewhistleblowers .info/how-plahotniuc-built-his-offshore-empire/
34
According to the reveals made by the British justice, the Cyprus company of Plahotniuc, Finpar Victoria Ltd, is the sole
associate of the OTIV Prime Holding B. V., registered in the Netherlands. This holding includes several companies,
including the OTIV Prime Real Estate B. V., OTIV Prime Services, OTIV Prime Hospitality and OTIV Prime Media;
hit p ://j urn aI.md/ en/pol it ic/2014/ 11 /26/ as sets-of-7 0-m In-e u ro-of-pl a hotni uc-s eized-by-the-d ut ch-j us tice-d oc/
35
https://ru.crimemoldova.com/news/rassledovaniya/vladimir-plakhotnyuk-tsentr-tyazhesti-mediaindustrii-moldovy/
Pri: 1fieg,3(i r;.. ne;· Confidcn:fal 22

l Kroll Project Tenor 11, Confidential Working Papers Part I to Detailed Report,
• On 13 August 2014 the sole owner of Finpar Invest SRL ICS was changed to Asirapal
Enterprises Limited (Cyprus).
3.1.8 OTIV Prime Holding B.V.

An article 36 by Jurnal Trust Media, a Moldovan group of media companies, states that the company
'OTIV Prime Holding B.V.' is a holding company which holds all the other offshore companies which
Plahotniuc owns. It further states that OTIV Prime Holding B.V. belonged to the Cypriot registered
company 'Fin par Victoria Limited', which in the period 14 October 2010 to 3 February 2012 was the
sole shareholder of OTIV Prime Holding B.V. and therefore OTIV Prime Real Estate B.V., OTIV
Prime Services, OTIV Prime Hospitality and OTIV Prime Media are included in its corporate
structure.
The article finally states that the press has repeatedly written that OTIV belongs to Plahotniuc and
the name comes from the initials of his Wife Oxana, two son's Timofei and lnochentie and himself,
Vladimir.
3.1.9 Gemeni SA Casa de Comert ("Gemeni")

This company has been reported in the Moldovan press 37 as being owned 47.86% owned by Otiv
Prime Real Estate B.V. which is owned by Plahotniuc. Another shareholder in Gemeni is stated to
be Geomold SRL with a shareholding of 47.86% and owned by the current president of Ukraine,
Petro Oleksiyovych Poroshenko.
3.1.10 Prime Management SRL

Prime Management SRL is widely reported to be owned by Plahotniuc. Total funds of USD 1.5
million 38 which can be linked to the suspected fraud were transferred to a Victoriabank account held
by Prime Management SRL.
Bizzer.md, a website which documents data on corporate legal entities registered in Moldova,
confirms Plahotniuc to be a co-founder of Prime Management.
36
http://jurnal.md/e n/politic/2014/11 /26/assets-of-70-ml n-euro-of-plahotni uc-seized-by-the-dulch-justice-doc/
37
http://bani.md/oficial-acesta-este-noul-actionar-al-s-a-gemeni-care-a-cumparat-jumatate-din-casa-de-comert---
43200.html
38 Transaction was made in EUR 1,135,910.00
PrivileQed Eno' Confir!en tial 23

I Kroll Project Tenor 11, Confidential Working Papers Part I to Detailed Report,
Fig u re 2 - Screenshot from bizze r.md - s how ing links betwee n Pla hot n iu c and Prime Management
Societatea cu Raspunde re Limitata PRIME MANAGEMENT

@ t~sneral ,i Fc.1,:i5;0.-1:0r
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• -~ ~ I
Prime Management SRL is the only company listed on a statement of wealth for Plahotniuc which
was completed in 2014.
3.1.11 ICS Prime TV

RISE Moldova reports 39 state the Moldovan Company ICS Prime TV is part of a larger group of
companies owned by General Media Group which in turn was founded by OTIV Prime Media B.V.
part of the OTIV Prime Holding B.V. that has been linked to Plahotniuc at section 3.1 .8.
3.1.12 Basconslux SRL

ZiarulNational.md reported 40 that the company Basconslux was contracted to build a three-floor
commercial building nicknamed Media City. The building is expected to house journalists from
media outlets including Prime TV. Media City is reported 41 to be located at Str. Ghioceilor 1 which
matches the publically available address 42 for General Media Group.
39
http://www.jurnal.md/en/politic/2015/5/18/rise-moldova-documents-which-demonstrate-that-general-media-group-
belongs-to-plahotniuc-candu-owner-of-publika-through-power-of-attorney/
40
www.ziarulnational.md/cum-arata-media-city-chisinau-oraselul-media-construil-de-plahotniuc
41
https://www.rise.md/articol/plahotniucleaks/
42
http://www.bizzer.md/enlilate/1225092/societatea-cu-r%C4%83spundere-limitat%C4%83-general-media-group-corp
Privi!GgGr.:I ;;;;jrJ Conrid[: nUa/ 24

I Krol l Project Tenor II, Confidential Working Papers Part I to Detailed Report,
3.1.13 Credit cards - individuals linked to Plahotniuc companies

A number of credit cards, in the name of a UK LP called Newline Commerce LP, were identified as
being linked to Moldovan individuals . These individuals are detailed in Table 1 in section 2. These
cards received payment which can be in part traced to funds originating from the Three Moldovan
banks, particularly from Sisteme lnformationale's account at BEM. These funds were transferred
through the Core Laundering Accounts and were transferred from a company linked with Plahotniuc,
Tukumaan Ltd .
Prfviier,c: c! :.: ·nd Confir.laniiaf 25

IKroll Project Tenor 11, Confidential Working Papers Part I to Detailed Report,
3.2 Accounts linked to Vlad Filat

Companies which were identified through media research and from confidential sources as being
linked to Filat received funds totalling USO 22 million which originated in part or in whole from the
fraud. Many of the companies which are linked to Filat were founded through a proxy, Ion Rusu,
who is married to Filat's sister, Ala Rusu (nee Filat). 43 Rusu's children, Adrianna and Vladimir Rusu
were also listed as the owners of a number of companies linked to Filat. Kroll has received
intelligence from confidential sources that associates of Ion Rusu's children Ciocoi Alin Dor, Costea
Costica and Cucos Ciprian also held some company positions on behalf of Filat. This has not been
independently corroborated but has been considered in this analysis .
Fund flows analysed by Kroll have identified the following recipients of funds which could be at
least in part traced to loans issued by the Three Moldovan Banks, or linked to other aspects of the
fraud.
• Rados Overseas Ltd

• Bus Estate Investments SRL
• Overseas Property Solutions
• Caravita SRL
• Aldgate Trading LP
• East Global Business SRL
• Next Estate Investment SRL
• Timbuktu Resource LP
• Ferenta Commerce LLP
3.2.1 Rodos Overseas Ltd (USO 7.3 million)

On 29 September 2014, Rados Overseas Ltd, registered in Belize, received EUR 5.5 million (USO
million) from a company called Dovastra Capital LLP into its account at BS, which originated from
a loan to Biro Media SRL, a Shor Group company. In addition, Rados Overseas Ltd received funds
which could be in part or in full traced to the suspected fraud, through the companies Tomton Trade
and Zonitech Properties, totalling approximately USO 100,000. Review of the account statement
for Rados Overseas at Latvijas Pasta Bank , Latvia revealed that it was transacting with similar
companies to that of Business Estate Investments LP, including Ferenta Commerce LLP.
43
http://www.realitatea.md/nepotul-multimilionar-al-lui-filat-la-doar-26-de-ani-a-investit-38-de-milioane-de-euro-si-a-mai-
cerut-bani-si-de-l a-stat-doc_7016. html
Pri\ 1 /f..~g 8d t.nd ContiG'Oniia/ 26

l Kroll Project Tenor II, Confidential Working Papers Part I to Detailed Report,
3.2.2 Business Estate Investments SRL (USO 6.4 million)

Business Estate Investments SRL was registered in Moldova with company number
1013600020973 on 20 June 2013. 44 Its sole director was a Cos tea Costica. 45 The company moved
to str Sciusev Alexei 32, Chisinau, 4 July 2014 46 and is still based there. Current records show
Costea Costica as sole owner and director.
A loan was identified from BEM to Business Estate Investments, totaling MDL 30 million (USO 2.1
million) on 25 June 2014. This was not transferred to the Core Laundering Mechanism as described
in the Detailed Report, but remained in Moldova. An account in the name of Business Estate
Investments was also held at Procredit Bank and received funds from Ferenta Commerce LLP 47 at
Latvijas Pasta Bank. Statements have not been received for Ferenta Commerce LLP, but review of
other statements of companies at Latvian banks demonstrate that this company has received fraud
funds which have been transferred through Overseas Property Solutions' account at Rietumu Bank,
Latvia. Further analysis is required to quantify the total amount which originated from funds
originating from fraudulent loans.
The Business Estate Investments account at Procredit Bank also received funds from a company
called Dovastra Capital LLP, which held an account at BS. Between April and June 2014, Dovastra
Capital received EUR amounts equivalent to USO 4.3 million which could be linked in part or in
whole to funds from fraudulent loans.
3.2.3 Overseas Property Solutions Ltd (USO 4.0 million)

Overseas Property Solutions Ltd is registered at 103 Sham Peng Tong Plaza, Victoria Mahe,
Seychelles. It received USO 4.0 million from the Core Laundering Accounts into an account at
Rietumu Bank. This was transferred to various accounts including Timbuktu Resources LP and
Overseas Property Solutions Ltd (at Valartis Bank, Liechenstein). The Rietumu account also
transacted with an account in the name of Overseas Property Solutions at Eurobank, Cyprus.
3.2.4 Caravita SRL (USO 1.5 million)

Caravita Co. SRL was registered in Moldova with company number 1011600030578 on 23
September 2011 . At this time its director was Igor Ion Cijov. 48 Current records also show Cijov as
sole director and Vladimir Rusu as sole owner.
44
This was also the address of the lpteh building, which has been linked to allegations of corruption in the media
involving Filat - see http://www.timpul.md/articol/cladirea-ipteh-ii-aduce-premierului-filat-800-de-mii-de-dolari-pe-an-
23472.html
45
Buletinul electronic 07 /2013
46
Buletinul electronic 08/2014
47
Statements have not been received for Ferenta Commerce LLP, but review of other statements of companies at
Latvian banks demonstrate that this company has received fraud funds which have been transferred through Overseas
Property Solutions' account at Rietumu Bank, Latvia.
48
Buletinul official 10/2011
Prjvi!eg1:;: ,:-J anri Con fic!eni'iaf 27

Analysis to date identified two loans granted by BEM to Caravita, totaling MDL 21 million (USD
1.47 million). These loans were not transferred the Core Laundering Accounts , but were dissipated
to numerous corporate bank accounts which appear by the name to be involved in agriculture. For
example, MDL 1.8 million (USD 126,000) was transferred to the Avva Company 49 account at
Unibank on 17 September 2014. An account was also identified at Procredit Bank, Moldova, which
received numerous credits from "lpteh SA", which according to media reports operates one of the
largest buildings in Chisinau. 50 The source of these funds is currently unclear.
3.2.5 Aldgate Trading LP (USO 0.5 million)

Aldgate Trading LP was registered in Edinburgh on 27 March 2013, with the partners listed as
Kensington Consultants Ltd and Montrose Assets Ltd. 51
Aldgate trading received USD 0.5 million in four transactions in February 2014, from two Core
Laundering Accounts, Hanlay Solutions LP and Maltby Solutions LP, into a bank account at Rietumu
Bank. Statements have not yet been received for Aldgate Trading LP, but review of other Rietumu
statements indicated that it transacted regularly with Overseas Property Solutions Ltd (see above) .
The account for Overseas Property Solutions transferred USD 379,375 to Aldgate Trading LP on 5
July 2013 which originated from a company called Roldon Capital.
3.2.6 East Global Business SRL (USO 1.4 million)

Romanian corporate records show that a company called Minox SRL (J22/1715/2006, tax ID
18840159) in lasi was previously called East Global Business SRL. The company was founded by
Ion and Ala Rusu on 10 July 2006 under the name AWA Records SRL and was based at Str Lazar
27 in lasi, Romania. Rusu was the sole director. 52 Ion and Ala Rusu left the company on 22 April
2010 and were replaced by Costea Costica and Igor Cijov, who became sole directors. 53 In 2010
Vladimir Rusu replaced Costica as a 50% shareholder54 and the company changed its name to East
Global Business SRL on 22 July 2013. 55 The company - now owned entirely by Vladimir Rusu and
having changed its name to Minox SRL on 16 November 2014 56 was liquidated on 12 December
2014. 57
49
Avva Company SRL was registered in Moldova with company number 1012605003811 on 20 November 2012 with Ion
Pavel Rusu as its director. Its main activities related to plant culture and technology.
50
http://www.tim pul .md/arti col/cladirea-i pteh-ii-aduce-p remierul ui-filat-800-de-mi i-de-d ala ri-pe-an-234 72. html
51
See Exhibit 14.6 Aldgate Trading LP Partnership Agreement
52
Monitorul official 2448/2006
53
Monitorul official 1733/201 O
54
Monitorul official 4055/201 O
55
56
57
Monilorul official 0206/2015
,r:.rh-'il~g<:: c/ ;;nd Con:iciGntir;;f 28

I Kroll Project Tenor II, Confidential Working Papers Part I to Detailed Report,
Liquidation proceedings had already been brought against AWA Records in September 2010 by
Volksbank Leasing SA but creditors adopted a reorganisation plan in November 2010 with Adriana
Rusu as special administrator (receiver). 58 The company was finally dissolved on 29 June 2015,
according to the Romanian corporate register.
East Global Business SRL received USO 1.4 million which originated from the fraud funds, from
Maltby Solutions LP, Ekovold Project and Hamiltero Color, to an account at Raiffeisen Bank in
Romania. 59
3.2.7 Next Estate Investment SRL (USD 0.6 million)

Romanian records show that a company called Prod Just SRL (J22/1/2010, tax ID 26365400) in
lasi was previously called Next Estate Investment SRL. The company was founded under the name
Sagittarius Management SRL on 4 January 2010 by Ciprian Constantin Cucos (Personal ID ((CNP))
1730828270599) and based at str Vasile Lupu 134 in lasi, Romania. Its main activity was
management and business consultancy. 60
On 22 July 2013 the company was acquired by Costea Costica, who also became sole director. 61
The company had already changed its name to Next Estate investment SRL and moved to Str Lazar
27 in lasi on 11 July 2013. 62 - On 18 November 2014 the company changed its name again, this time
to Prod Just SRL. 63 The company was dissolved on 1 April 2015, according to the Romanian
corporate register.
Next Estate Investment received USO 585,000 in May and June 2014, which originated from the
fraud, from Maltby Solutions LP. Similar to East Global Business, this was received into an account
held at Raiffeisen Bank, Romania. 64
3.2.8 Timbuktu Resources LP (secondary/ linked company)

Timbuktu Resources is a UK partnership number SL 12692, established on 22 March 2013 .
Timbuktu Resources did not receive any funds directly from the Core Laundering Accounts, but
received funds originating from the fraud through Overseas Property Solutions at Latvijas Pasta
Bank, and from a bank account in the name of Ferenta Commerce LLP at Latvijas Pasta Bank. It
also transacted with other ABLV accounts , Dennisio lmpex Ltd and Midastra Industries Ltd. It
appears that this company was used as a further layering company.
58
Buletinul insolventiei 7204/09.1 0
59
A summary of transfers to accounts in Romania is included in 0
60
61
62
Monilorul official 0643/2013
63
64
Transfers made to accounts in Romania are summarised in 0
Privileged ~in d Con,ideniie.l 29

t Kroll Project Tenor 11, Confidential Working Papers Part I to Detailed Report,
3.2.9 Ferenta Commerce LLP (secondary/ linked company)

Ferenta Commerce LLP ("Ferenta") did not receive any funds from the pool of Core Laundering
Accounts but, similar to Timbuktu Resources above, both received and remitted funds originating
from the fraud :
• Ferenta remitted USO 0.01 million to Brain Logistic Limited in 2012 which in turn was
identified as receiving USO 1.7 million from the suspected fraud.
• Ferenta received USO 0.5 million from Overseas Property Solutions at Rietumu Banka in
2013. Overseas Property Solutions was identified as receiving USO 3.1 million from the
fraud to date.
Further to the above transactions with entities that received funds from the suspected fraud,
Ferenta transacted with SRL Business Estate which received a loan of USO 2.1 million from BEM.
3.2.10 Credit cards linked to Fi lat

Kroll obtained some credit card statement information from Unibank in the name of Tudor Negru ,
an affiliate of llan Shor. In a statement which was published online, llan Shor65 stated that he had
provided credit cards to Filat with approximately EUR 400,000 deposited on them .
Through the analysis of open source social media data, one of the credit card statements in the
name ofTudor Negru, account number 225948560114978 was linked to Vlad Filat's son, Luka Filat.
Review of the statements identified sizeable cash withdrawals and location-specific card payments
in several places, including Geneva, Gstaad, St. Tropez and Cannes.
Given the fact that Luka Filat's social media accounts are private or have been removed altogether,
Kroll sought to trace his movements through accounts maintained by people known to be close him .
The below transactions totalled €10, 175 being spent in Gotha Club on consecutive nights from 30
July to 1 August 2014.
Figure 3: Sequence of transactions made in Gotha Club between 30 J uly and 1 August 201 4
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The following lnstagram post was identified:
Figure 4: Post by @maxcremers placing Filat at Gotha Club in the relevant pe riod
65
Timpul, 17 October 2015: http://www.timpul.md/articol/(document-tradus)-probele-gasite-de-procurori-confirma-o-
parte-din-depozitiile-lui-ilan-or--filat-ar-fi-primit-la-10-octombrie-20-de-milioane-de-lei-in-sediu-pldm-81022 .html
Privii:; 9.r;d ~rv.i Con!ici~?nii:;:.f 30

":",! C..·- S i- :' ~ :))G35 i0 5~3i , ~~ Tl,;k 2014-0 7-3 1 :1:43:.1i

1
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0 . C:)C a :i•.;U; H .
The above post, uploaded by @maxcremers, was gee-located to Gotha Club on 31 July 2014 and
was linked to the following photograph of Luka Filat:
Figure 5: Photograph of Luka Filat and @maxcremers in Gotha Club
1
h1~a:t·v11~t ~ 0 :.
I.
Further transactions on this card were linked to social media posts of Luka Filat at the Nikki Beach
club, St Tropez.
Cash withdrawals of over EUR 2,000 were made from the card between 1 June and 3 June 2014
in St. Tropez. The photographs below posted by the Nikki Beach resort St Tropez places Luka Filat
there during that time.
Pri vifegcd end Contic!cnNal 31

Figure 6: Transactions in St Tropez in June 2014 - Luka Filat
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Figure 7: Social media link to transactions in St. Tropez
Additionally, immediately following this, there are further large cash withdrawals in Rolle,
Switzerland, where Luka Filat, according to media reports, attended Le Rosey College. 66
66
hltp://adevarul.ro/moldova/politica/copiii-vlad-filat-vlad-plahotniuc-invata-cele-mai-scumpe-scoli-lume-
1_538c45b50d 133766a838dbc3/index.html
Prjvif:;9ed c:ncf Conifcfc;-nfic:i 32

~ Kroll Project Tenor II, Confidential Working Papers Part I to Detailed Report,
4 Individuals involved in the suspected fraud

C
mechanisms - Russian accounts

As noted in Section 11 of the Detailed Report, a number of individuals provided funds to Core
Laundering Accounts and formed part of a circular flow of transactions between Alef Bank (Russia)
and accounts at ABLV and Privatbank. The individuals which held these accounts and their links to
the Shor Group and other Moldovan public figures are detailed in Table 3 below.
As shown in Table 3, a number of the funds paid to Core Laundering Accounts from these
individuals' accounts were used to fund shareholders of the Three Moldovan Banks. Others were
used to fund the purchase of a non-performing loans portfolio in BEM (the non-performing loans
portfolio was acquired by a company called Roseau Alliance LP) . The funding of shareholders and
the acquisition of the non-performing loans portfolio is detailed in Section 7.
A number of account holders of the Russian banks which paid funds into the Core Laundering
Accounts in 2012 and 2013 received some benefit from the fraud funds. It is not clear whether
these payments represent a salary, payment for services , interest on loans provided or whether the
individuals were cash couriers, responsible for moving the funds to other locations. The payments
were generally spread over a number of months and took place between June 2013 and March
2014. The payments to personal bank accounts at ABLV that can be traced to the Core Laundering
Accounts are detailed in Table 3 below:
P ri,1ifecJed a no' Confiden Ual 33

Table 3: Alef Bank accounts in the na me of ind ividuals transa ct ing w ih ABLV and Privatban k acc ou nts (li nks to Shor Group or other high profile
Moldovan figures)
Amount Amount Net Links Description Links to acquisition of shares

paid to received amount to of UB / BS or BEM non-
Russian from paid to/ Shor performing loans cession
account Russian (received Group agreement with Roseau
(USO account from) (Y/0)&1 Alliance LP ("the Roseau
Account name million) (USO Russian transaction")
(Alef Bank) million) account
- 4.4 (4.4) 0 A judge by the same name was dismissed in 2014 by the Superior Council of
Magistracy in Moldova for lack of professional integrity. 68
Alexandru Rotari
- 4.3 (4.3) y Founder and director of Citadina-Mob, a Shor Group company. 89 Haceatur was also Funds from account used to
a security officer for the delegation of the former Prime Minister Voronin to Moscow fund BEM Roseau transaction
in 2008. 70
Ambarean Haceatur
- 5.1 (5.1) 0 Reportedly director of Metrompas SRL, which also has Eugeniu Rusu listed as a Funds from account used to
founder of this company.71 Rusu is reportedly the former deputy of the General fund BEM Roseau transaction
Prosecutor's Office. 72 Metrompas has been reported to print tax and excise
documents and has given donations to the Communist Party of Moldova. 73
Nino Ciubinasvili
- 5.8 (5.8) y Director of Ghermivali SRL, 74 a Shor Group company that received loans from the
Three Moldovan Banks and transferred these funds to the Core Laundering
Mechanism.
Nadejda Coisman
- 4.0 (4.0) y Sole owner of Shor Group company Univet Invest SRL based in Chisinau in 2015. 75 Funds from account used to
The company is currently owned by Lila Gazovskyi, who is also sole director. She fund BEM Roseau transaction
is also owner and director of Alreda-Pro SRL, another Shor Group company.
lurie Fotescu
67
Y - Linked to Shor Group, O - linked to other high profile Moldovan individuals,
68
http://www.zdg .n1d/edit i a-print/so ci al/cinci-maqis t rati-a u-fos t-dern isi-de-cs m-p resed i ntele-cs i-20-di ntre-ju decatori -urmeaza-sa -fie -el i be rati-di n-f LI net ii
69
http://comoanies .casa ta.md/comoanies.pho?l=ro&action=viewcompany&rid=52600&id=73383
70
http: //le x.jL1s tice.md/i11dex. pl1p?action=view&view=doc &lang= 1&id=327157
71
http://www. tim p L1I. m d/a rti co l/la-nu nia-ef ul LI i-se rvici ul Lli-vama l-pol ii a-a r-fi -bl ocat-d rum Lll -ileg al-515 72 .l1trn I
72
htlps ://ant i co ru ptie .rnd/ro/ dos a re-de-co ru otie/d oc-fo s tL1l -a d jLI net-a 1-o ro cu ro rul L1 i-oene ral-e L19 e11-rus u-acuz at-ca -a-s cos-di n-p usca ri e- un-c ri m i na I
73
ht tp:/ /www. jc.rn di g i ne re l e-1ui-vo ron i n-rn ii i ona r-din-cont ra cte-s em na te-c u-s tat LI I/
74
See Exhibit 14.7 Extract from Ghermivali SRL_Nadejda Coisman
75
http:/ /corn pa nies .ca sata .md/cornpa ni es .php?l=ru&actio n=viewcorn pa ny&id= 7 4865
Privileged and confidential 34


(USD account from) (Y/O)e1 Alliance LP ("the Roseau
Account name million) (USD Russian transaction")
0.4 5.0 (4.6) y ilan Shor's head of administration and BS shareholder. 77 Funds from account used to
fund UB shareholder Veacesiav
76 Lupov
Maria Gutuleac
0.1 1.2 (1 .1) 0 Listed as an administrator for ABLV bank accounts which were used to launder the
funds .76
Ion Cojocaru
5.3 (5.3) y Linked to an individual by the name of Mathias Halter, who is a founder of V.I.M Funds from account used to
Mermer SRL based in Orhei (Shor's hometown). He was also director of Avia fund BEM Roseau transaction
Consulting SRL and a manager at Klassika Asiguari (a Shor Group company and
shareholder of BEM) when Avia Consulting received MDL 268.8 million from Avia
Invest SA for supplying tarmac to the airport. 79
Kristina Halter
0.2 2.6 (2.4) y Director of infoton-Com, 80 a Shor Group company that received loans from the
Vasile Lasco Three Moldovan Banks
0.3 4.5 (4.2) y Director of Shor Group company Megasoft international SRL, and the founder of
another Shor Group company Apropo-com SRL. 81 Lupov is also a shareholder of
Unibank.
Veaceslav Lupov
0.2 2.6 (2.4) y Maclovici was, according to media reports a former director of Asigromex SRL, a Funds from account used to
Shor Group company. 82 fund UB shareholders Viorel
Alexandr Maclovici Meinic and Marina Tauber
1.7 (1.7) 0 According to media reports Ruslan Malachi was the former captain of the Protection
and State Security (capitan al Serviciuiui de Protectie ~i Paza de Stat) who received
a medal for military merit from Nicaolae Timofti in April 2016. 83
Ruslan Malachi
76
In addition, Gutuleac received USD 0.4 million into an ABLY account in her name.
77
www.mold-street.com/?ao=news&n=3446 Report titled : INVESTIGATION: The Lords of the Banks in Moldova dated 17 December 2014.
78
http:/Ira d iochis i na u.m d/ d osa rul-fil at-de ta Iii-des pre-ma rtu riile-fostu Iui-sef-bem-3212 4
79 htip:/ /a nticoruo!ie .rnd/ro/dosa re-de-coruptie/do c-legatura-d u bioas a-di ntre-a ctio na rul-pri nci pa I-de-Ia-victori aba nk-aeroportul-internati onal -chis ina u-si-cont ra band a-cu-a Icool-
etiIi c-d i n-rus i a
80
http://www.bizzer.md/entitate/1053603/societatea -cu- r%c4%83spundere-limitat%c4%83- infoton-com
81
Buletinul electronic 01/2015
82
ht!ps://vvww.rise.md/foto-shor-holding-pro iecte-imobiliare-schitate-la-rnoscova-2/
83
l1ttp ://zi a ru l na tio na I. rn d/ d oi-gene ra Ii-di n-r-m oldova -decorati-de-tirnofti-un-fost-rn inistru-a-pri rn it-ord in ul-repub liciil


(USD account from) (Y/O)s1 Alliance LP ("the Roseau
5.1 (5.1) y Tauber was the head of the Moldovan Tennis Association and captain of Women's Funds from account used to
tennis in Moldova. 84 According to media sources, she was a close friend of llan fund BEM Roseau transaction
Shor8 5 and has played a leading role in the campaign to free him. 86 Both Dufremol
and Chisinau International Airport are sponsors of the Tennis Federation. 87 Tauber
was also the director of Metal Trade Group SRL, a Shor group company which
received proceeds of loans from the Three Moldovan Banks.
Marina Tauber
0.1 2.0 (1.9) y Founder and director of Moldclassica International, a Shor Group company which Funds from account used to
received loan proceeds from the Three Moldovan Banks. 88 Moisei was also director fund UB shareholder Olga
and owner of Apropo-Com SRL in July 2015, according to corporate records Bondarciuc
published in the media by Renato Usatii, the Chairman of Our Party and a left-wing
populist party.89
Moisei Mester
0.2 2.0 (1 .8) y A shareholder of Unibank, employee of Shor Group Holdings, and has been linked
to other areas of the fraud, including the distribution of funds to Vlad Filat and
family 90 ;
Tudor Nearu
4.7 (4.7) y Sole founder and director of Decfin Group, a Shor Group company which received Funds from account used to
numerous loans from the Three Moldovan Banks. 91 fund BEM Roseau transaction
Olga Nosaci
5.6 (5.6) 0 Pahiliuk can be linked to Vasile Lasco, Tudor Negru and Nino Ciubinasvili on social Funds from account used to
media which indicates that he had a personal relationship with individuals linked to fund BEM Roseau transaction
the Shor Group .92
Vladimir Pahiliuk
84
http: //www. jLI rn aI.md/ro/s po rt/2015 /3/26/rn a ri n a-ta LI ber-n o ul-ca oi ta n-a I-na tio nal ei-de-tenis-femi nin-a-mol d ovei/
85
l1tt p:/fv-..,ww. bb c.co .uk/news/111agazine-33 166383
86
http:/ /unimedia.info/stiri/sustinatorii-lui-ilan-Sor-vor-organiza-maine-un-protest-la-judecatoria-buiucani-117149. html
87
http://anticoruptie.md/ro/investigatii/economic/aeroportul-off-shor-via-rusia-ii
86
http://www.bizzer.md/entitate/ 1128103/societalea-cu-r%C4%83spL1ndere -lirnitat%C4 %83-mold classi ca -internationa!
89
http://www.re aIil atea .111d/L1lli111 a-o ra -re na to-us aIii-fa ce-noi-de zva ILli ri-i n-dos a rul-111 iii a rd LI Iui-fu rat-doc-video 27 656 . html
90
See section 3.2
91
http:/ /comp anies .cas al a.md/com pa nies . ph p?I= ro&action=viewcom oa ny&id= 4 76
92
https://www.facebook .com /vl ad imir.pahi li Llk

II Kroll Project Tenor II, Confidential Working Papers Part I to Detailed Report,

(USD account from) (Y/0)"7 Alliance LP ("the Roseau
5.1 (5.1) 0 According to media reports he was the former deputy to the General Prosecutor Funds from account used to
and head of department for the Customs Service. 93 Other media reports have linked fund BEM Roseau transaction
Rusu to former president Vladimir Voronin. 94
Eugeniu Rusu
5.1 (5.1) y Founder of Talnes SRL - which received loans from BEM totalling approximately Funds from account used to
USO 28 million. fund BEM Roseau transaction
Elena Smolei
6.7 (6.7) 0 Reportedly the wife of the head of the customs department of Moldova in 2013, Funds from account used to
Tudor Balitchi. 95 fund BEM Roseau transaction
Aliona Steflea
1.5 82.8 (81.3)
TOTAL
Table 4: Alef Bank accounts in the name of individuals transacting wih ABLV and Privatbank accounts (no identified links to Shor Group or other
high p rofile Moldovan figures}
Amount Amount Net Links Description

paid to received amount to
Russian from paid to/ Shor
account Russian (received Group
(USD account from) (Y/0)96
Account name million) (USD Russian
(Alef Bankl million) account
Irina Ciascevaia - 5.2 (5.2) Funds from account used to fund BEM Roseau transaction
Anatolie Severin
- 7.5 (7.5) Funds from account used to fund BEM Roseau transaction
Svetlana Slicova
- 5.1 (5.1) Funds from account used to fund BEM Roseau transaction
TOTAL
. 17.8 (17.8)
93
http://www. rea Iitatea. md/ auto rizare a-ma rfu ri lo r-import-expo rt-es te-u n-p roces-defectuos-i a r-oamen i i-d e-af aceri-pierd-ti m p-i-ba ni-ca re-a r-fi-s ol u-ia-video_ 34883. html
94
http://w,Nw.jc.md/ginerele-lui-voronin-m ilionar-din-cont racte-sernnate-cu-statul/
95
https://point.md/ro/noutati/obschestvo/alfa-cine-este-mireasa-shefului-de-la-vama
96
Y - Linked to Shor Group, O - linked to other high profile Moldovan individuals

5. Analysis of accounts that received suspected

fraud funds from further tracing
Section 12 of the Detailed Report summarised the amounts that were received into accounts in a
number of other jurisdictions. This section provides details of specific accounts that received more
than USO 0.5 million in aggregate. All information is provided in USO equivalent amounts.
5.1.1 Latvia (USO 302.1 million)

A large proportion of funds were traced to other Latvian accounts which have not yet been
analysed for the following reasons :
• USO 65.6 million was below the threshold defined for onward traces, according to the
tracing methodology, which was formulated with the focus on prioritizing the larger sums
for potential asset recovery. Further details can be found in Section 9 of the Detailed Report.
• USO 233 million related to traces to accounts for which statements requests are pending.
This comprised transfers to approximately 300 accounts.
The remainder of the amount related to amounts that could not be traced to transfers out of the
Latvian accounts; either as a result of the funds being used for complicated foreign exchange
contracts , or as the funds had not left the account as at the latest statement date.
5.1.2 Moldova (other Moldovan banks) (USO 169.3 million)

Kroll's analysis has identified that certain accounts held at other Moldovan banks (particularly
Victoriabank and Moldindconbank) received some suspected fraud funds. Section 10 of the
Detailed Report highlighted the involvement of accounts held at Victoriabank and Moldindconbank
in a secondary laundering mechanism, and Section 5 of the Detailed Report showed that in some
cases, fraud funds from loans issued to the Three Moldovan Banks were paid to accounts at
Victoriabank and Moldindconbank as loan repayments.
Accounts at other Moldovan banks were paid to the following banks:
Moldovan Bank Amount received

Victoriabank 106.9
Moldindconbank 50.5
Comertbank 5.4
Agroprombank Moldova 2.2
Romanian Commercial Bank Chisinau 0.8

Eximbank 0.3
En erg bank 0.2
Moldovan State Treasury (TREZMD2X) 0.3
Other97 2.7
TOTAL 169.3
The involvement of Victoriabank and Moldindconbank and the extent to which payments made to
these two banks were for loan repayments has not been quantified to date. However, to date, Kroll
has been able to classify the following as loan repayments :
• USO 43.7 million paid to accounts at Victoriabank were for loan repayments; and,
• USO 23 .9 million paid to accounts at Moldindconbank were for loan repayments.
Transfers made to accounts at Victoriabank and Moldindconbank are summarized below:
5.1.2.1 Amounts paid to Victoriabank (USD 106.9 million)

Table 5 summarises the accounts at Victoriabank that received transfers.
Table 5: Summary of transfers to accounts at Victoriabank
Account name Amount Detail

{in USD
million)
Seppota Services 21 .0 The account statement for this account is currently pending
Limited request, and the end destination of these funds is currently
unknown
Granville Limited 10.4 Funds were transferred to Granville Limited direct from Core
Laundering Account Panaroom Management LLP, according to
the statement description this transfer was for construction
materials .
Carmondean 2.3 Transfers were made to Victoriabank accounts in the names of
Development and BEM minority shareholders: Carmondean Development
Tintel Project Ltd received USO 1.3 million on 20 December 2012 and Tintel
Project Ltd received USO 1 million on 5 March 2013
Finpar Invest Sri 4.5 Finpar Invest Sri and Finpar Victoria Ltd, received USO 2.9
and Fin par Victoria million and USO 1.6 million respectively
Ltd
97
This amount includes transactions not selected for further tracing according to the tracing threshold.

Victoriabank 3.5 Appears to be funds received as transaction fees

brokerage account
Semgroup 9.2 Semgroup Systems Sri is a Shor Group company that did not
Systems Sri receive loan funds from the Three Moldovan Banks. It received
USO 8.7 million which was used as a loan repayment
according to statement descriptions.
Other Shor Group 29.9 The largest transfers were made to Shor Group companies
companies Agercom Group (USO 7.1 million), Air Clasica ICS Sri (USO
7.3 million), Grand lmobiliare Sri (USO 7.2 million) and Molint
Grup Sri (USO 3 million) .
Other transfers 26.6
Total 106.9
USO 31.8 million was transferred to an account in the name of Zenit Management at Victoriabank.
It appears that this account was set up just prior to the collapse of the Three Moldovan Banks, as
it had its first transactions on 20 November 2014. The funds were used to repay loans at lnfoart
International SRL, Semgroup Systems SRL98, Agercom Grup SRL, Grand lmobiliaire SRL and
Bogdan and Co SRL. These funds were included in the ends detailed in the table above.
5.1.2.2 Amounts paid to Moldindconbank (USD 50.5 million)
Table 6 : Summary of t ransfers to ac counts at Moldindconbank
Account name Amount Detail

(in USD
million)
Denison Limited 12.2 Denison Limited also had accounts at Trasta Komercbanka
(Latvia) which were involved in the secondary laundering
summarized in Section 10 of the Detailed Report.
Chester (NZ) 4 .9 Chester (NZ) Limited also received
Limited
Shor Group 30.3 The following Shor Group companies received significant
companies transfers into accounts held at Moldindconbank: SC Dufremol
Sri (USO 13.2 million), Contrade Sri (USO 3.8 million), Talnes
98
Semgroup Systems is reportedly a shareholder in Modasig - the leading insurance provider in Moldova -
http://agora.md/sliri/1282/cel-mai-mare-jucator-de-pe-piata-de-asigurari-din-moldova-isi-vinde-actiunile-la-bursa

Sri (USD ·3.4 million), Ghermivali Sri (USO 2.4 million),

Agercom Group (USO 2.2 million) and SC Molint Grup (USO
1.8 million) .
Other transfers 3.1
Total 50.5
5.1.3 Cyprus (USO 112.4 million)

A large number of transfers of high value to Cypriot bank accounts were identified in the tracing
exercise. The possible use of Cyprus as a secondary laundering mechanism is detailed in Section
10 of the Detailed Report.
Table 7: Overview of transfers to Cyprus
Entity Name Bank Account number No of USD

payments million
Cedok Air Limited 99 - - 1 11 .9
Tryss Group S.A. Eurobank CY02018000060000201100115746 11 10.8
EFG
Cyprus
Tiaram Holdings Ltd Hellenic CY21005003400003400155573801 17 8.9
Bank
Branch Marketing Eurobank CY45018000060000200100218505 12 7.4
Cyprus
(Eurobank) 100
Mercury Group Eurobank CY47018000050000200100025113 10 5.8
Cyprus
Trading Limited
Lazomar Trading Hellenic CY48005001400001400766204501 12 5.6
Bank
Limited 101 CY75005001400001400166204501
Cerolia Holdings Ltd Eurobank CY29018000060000201100115842 6 5.2
Thediadia Services Hellenic CY60005001400001400768661101 7 4.1
Bank
Limited CY87005001400001400168661101
Zanix Ltd Eurobank CY91018000060000201100146542 4 4.1
Canby Ltd OJSC CY27120000134080797800000647 3 3.6
PROMSVY
AZBANK
99
Account details for Cedok Air were not identifiable from the bank statements . According to internet searches, the
company was registered in Cyprus . Kroll's analysis shows that the funds transferred to Cedok Air were used to purchase
an aeroplane.
100
An account in the name of Branch Marketing Ltd was also held at ABLV (Latvia) . This account was part of the Core
Laundering Mechanism (detailed in Section 8 of the Detailed Report), used to receive and launder funds from loans
issued by the Three Moldovan Banks to Shor Group companies.
101
Linked to Longford Partners LP, see also Section 3.1 .1

lKroll Project Tenor 11, Confidential Working Papers Part I to Detailed Report,
Entity Name Bank Account number No of USD

payments million
Doltania Consulting Eurobank CY78018000030000200100207718 1 3.3
Ltd
Habarov Airport Eurobank CY77018000060000200100209393 3 3.3
Invest Ltd
Oceanic Trading Eurobank CY02018000060000201100146980 4 3.2
Limited
Sharbena Hellenic CY10005001400001400166204701 6 2.8
Investments Bank
Limited 102
Primoteks Import Eurobank CY42018000060000201100253348 9 2.7
LP103 CY67018000060000200100228682
Midastra Industries Eurobank CY30018000060000201100233873 20 2.6
Altonex CY69120000134080784010211201 1 2.4
Management
Limited
Saranic Investments Hellenic CY91005002400002400757059301 2 1.9
Ltd Bank
Canterford Trading Eurobank CY34018000060000201100116140 2 1.8

Ltd
GFL Globalforce Eurobank CY63018000040000201100269972 4 1.7
Holding Ltd
Hyperunit Eurobank CY57018000040000201100272602 2 1.3
Investments Limited
Fung Group Ltd Eurobank CY95018000060000201100250163 2 1.2
Telmo Business Ltd Piraeus CY67008001700000000001272341 1 0.9
Bank
Dennisio lmpex Ltd Eurobank CY08018000060000201100233881 11 0.9
Hi-Choice Industries Eurobank CY0301800006000020010008 5 0.9
Ltd
Digital Cloud PROMSVY CY77120000134080784070000596 3 0.8
Technologies LTd AZBANK
Choices Complete Eurobank CY38018000060000201100146235 1 0.8

Tech Limited
102
Linked to Rowallan Overseas S.A, see also 3.1.1
103
An account in the name of Primoteks Import LP was also held at ABLV (Latvia) . This account was part of the Core
Laundering Mechanism (detailed in Section 8 of the Detailed Report), used to receive and launder funds from loans
issued by the Three Moldovan Banks to Shor Group companies.

II Kroll Project Tenor 11, Confidential Working Papers Part I to Detailed Report,
Entity Name Bank Account number No of USO

payments million
Melanta Trading Ltd Hellenic CY57005002400002400158056201 2 0.8
Bank
Bornut Worldwide Hellenic CY31005003400003400162425701 1 0.8
Bank
Ltd
Dileara Trading Piraeus CY97008002700000000000992740 8 0.7
Bank
Limited CY38008002700000000000992735
Laresando Ltd Bank of CY47002001950000357005332058 4 0.6
Cyprus
ABDAsiana Hellenic CY33005001400001400168683801 1 0.6

Bank
Development
Limited 104
Vector International FBME CY7511501001052535EURCACC0 15 0.6
Bank
Holdings Ltd 01
Sapfoliaco Trading Hellenic CY66005001400001400168683401 1 0.5
Bank
Limited
Other accounts 7.9
TOTAL 112.4
Funds were transferred to 59 other accounts , including one individual account:

• Mrs Karyn a larovikova (Hellenic Bank) - USO 1,110
5.1.4 China (USO 83.3 million)

Table 8: Overview of transfers to China
Entity Name Bank Account No of USO

payments million
Brilliant Amazing Bank of OSA90000145246100 3 4.1
Limited Communications
Propitious Winds Bank of OSA90000092339100 3 3.1
Millenium Wealth Bank of OSA90000136367100 8 2.6
Telur Limited Bank of OSA90000175757100 2 1.7
Communications
Cui Li Xia Bank of China 401420801882701230 27 1.5
104
A number of accounts in this name were also held at Garanti Bank and Raiffeisen Bank in Romania. As detailed in
section 3.1 .5, this company also received funds from Tukumaan Limited, a company linked to Mr Plahotniuc.

IKroll Project Tenor II, Confidential Working Papers Part I to Detailed Report,
Entity Name Bank Account No of USD

payments million
Haining Chaona Zhejiang Haining Rural 201000074763708 15 1.3
Commercial Bank
Textile Co Ltd
Company Limited
China Haining Rural
Credit Cooperatives
Union
Xinjiang Qitai Xilu Bank of 30018801040009798 6 1.2
Communications
Co Ltd
Bank of China
Agricultural Bank of
China
Sino Edge Bank of OSA90000229694100 1 1.0
Communications
Investments
Limited
Xiamen Freede Agricultural Bank of 40303014040006400 1 0.8
China
Industry Co Ltd
Baoding Golden Bank of China 101136340094 5 0.8
Forest Trading Co
Ltd
Zhupai Trading Co Ping An Bank Co OSA11013251300102 4 0.7
(Formerly Shenzhen
Limited
Development Bank Co
Ltd)
Gucheng County Agricultural Bank of 50432014040000100 3 0.7
China 50432014040000985
Shengrui Fur
China Construction Bank 13014803700220100658
Product Co Ltd
Zaoqiang County Industrial and 0407316409300014854 3 0.7
Commercial Bank of
Ruijie Fur
China
Company Limited China Construction Bank 13014802500220100000
NWS Overseas Bank of OSA90000126186100 1 0.6
Communications
Limited
Xinjiang Hengyu Bank of 651100858018010000000 2 0.6
Communications
Feng International
Trade Co Ltd
Zao Qiang County Industrial and 0407316409300025414 3 0.6
Commercial Bank of
Liang Da Ren Fur
China
Co Ltd China Construction Bank 13014802500220100420
Zao Qiang da China Construction Bank 13014802400220100441 2 0.6
Sheng Chang Fur
Co Ltd


payments million
Anhui Longtian Bank of China 176707439259 2 0.5
Imp and Exp Co
Ltd
Zaoqiang County Bank of China 100148639381 2 0.5
Hongshanhu For
Co Ltd
Guang Dong Bank of China 663957735774 6 0.5
Silique
International
Group Garments
Co Ltd
Chongqing Meiqi Bank of China 114433129714 3 0.5
Hua Xia Bank
Industry Co Ltd 544020000181910000341
8
Guangzhou Ruiqi Bank of China 719862193384 2 0.5
Garment Co Ltd
Xinji City Yu Mao Agricultural Bank of 50301601040012933 1 0.5
China
Tai Garment Co Ltd
Other accounts 57.6
TOTAL 83.3
The remaining transfers were made to 560 accounts, including approximately 80 that appear to be in
the name of individuals in 711 transactions. A large number of transfers were made to Chinese trading
companies that appear to be active in the garment industry by their names and the payment
descriptions. Many of these payment descriptions stated that the transfers were for shoes, textiles, fur
or clothing items. These transfers appear to be part of a secondary laundering mechanism, detailed
further in Section 10 of the Detailed Report.
Funds were transferred to accounts in the names of individuals:

• Cai Juandi Ruian (Bank of China account 6216666200000033164) - USO 67,960;
• Cai Wen Quan Zheijiang (China Construction Bank Corporation account
1426149980110298149) - USO 133,064;
• Caoqi Yiwu (Bank Of China account 357161434071) - USO 35,001
• Chen Bao Ying (Bank of China account 329850317565) - USO 99,998;
• Chen Huibo (Agricultural Bank of China account 6228480085263770000) - USO 25,000;
• Chen Jun Xian (Bani< Of China account 331150311802) - USO 22,000;

• Chen Ri Yin Wenzhou (Bank of China account 370155194830) - USO 66,563;

• Chen Zhong Min (Zhejiang Tailong Commercial Bank account 3306021409800000685) - USO
150,000;
• Cheng Zheng Yuan Wenzhou (Bank of China account 385762984259) - USO 66,479;
• Cui Li Xia (see above) ;
• Guan Guang Cheng (Industrial And Commercial Bank Of China account
6222081203005240318)- USO 266,000;
• Guo Jing (Bank Of China account 337657959458) - USO 37,000;
• Han Oa Wei (Bank Of China account 344150356507) - USO 35,000;
• Hou Weijan (Bank of China account 453003001881098190) - USO 99,500;
• Huang Li Ping (Bank of China account 333750295157) - USO 9,530;
• Huang Mei Juan Zheijiang (China Construction Bank Corporation account
6227001426860019933) - USO 133,130;
• Huang Xi Hong (Bank Of China account 6216686200000251101)- USO 66,630;
• Huang Yu Ping (Agricultural Bank Of China account 6228480338715328179) - USO 135218
• Jiang Ya Na (Bank of China account 401420801883230061)- USO 54,650;
• Jiang Zhu Rong (Bank of China account 331157990502) - USO 4,054;
• Li Zheng Long (Bank Of China account 401359725391) - USO 81 ,194;
• Li Zhuo (Bank of China account 401420801881292930) - USO 16,500;
• Liang Xiao Rong (Bank of China account 6216610100003926207)-USO 20,000;
• Liao Yu Xuan (Bank Of China Qingtian account 451523301880173000) - USO 20,000;
• Lin Hua Song (Bank of China account 403953724206) - USO 20,000;
• Lin Qi Bo (Bank of China accounts 361065677044 and 376662464185)- USO 345,305;
• Lin Qing Rui (Bank Of China account 4563516206011814483)- USO 106,530;
• Lin Shi Chun (China Construction Bank Corporation account 1428079980110237790) - USO
66,630;
• Lin Yue Hong (Bank of China account 4563516206004160993) - USO 79,930;
• Liu Chang Zhen (Bank of China account 322050371066) - USO 35,000;
• Liu Shu Qin (Bank of China account 401420801882964967) - USO 14,000;
• Liu Song Chai (Bank Of China account 401354624900) - USO 133,130;
• Liu Yong Mei (Bank of China account 401420801883298804) - USO 20,000;
• Liu You Long (Industrial And Commercial Bank Of China account
12102230N201000098280744) - USO 100,000;
• Lu Dong Hua (Bank of China account 349350336587) - USO 12,000;
• Luo Meizhen (Bank Of China account 4563516207022248067) - USO 4,883;
• Ma Sai Wu (Bank of China account 337658518616) - USO 44,230;
• Ni Xiao (Bank of China account 4563510100891316261) USO 90,000;

• Qi Shu Hua (Bank of China account 336350294521) - USO 30,000;

• Qiu Song Zhou (Bank of China account 401420801882124000)- USO 10,480;
• Qu Chong Xiang (Bank Of China account 6217886200000564152) - USO 66,471;
• Ren Chai Cheng (Bank of China account 384466366496) - USO 39,867;
• Rong Li Yan (Bank of China account 325962264219) - USO 15,005;
• Sheng Hua (Bank Of China account 401420801881048479) - USO 70,000 ;
• Su Song Mei (China Construction Bank Corporation account 383160057120)- USO 92,987;
• Sun Hao Shuang (Bank Of China account 6216680100000243908)- USO 200,000;
• Sun Zheng Hong (Bank Of China account 361063375396) - USD 332,426;
• Wang Chun Ying (Bank of China account 401420801883370564) - USD 50,000;
• Wang Meiqing (Bank Of China account 453973601880344661) - USO 199,449;
• Weng Chao Qin (Bank of China account 4563511600611403645) - USD 20,000;
• Wu Chao Chi (Bank of China account 1426869980110356929) - USD 239,303;
• Wu Ling Zhi (Bank Of China account 349350289343) - USO 70,000;
• Wu Sui Juan (Agricultural Bank Of China account 19231100460079139) - USO 132,997;
• Xia Patricia (Bank Of Communications account OSA90000154428100)- USD 66,630;
• Xiang Dong Wu (Bank Of China accounts 383160057120 and 371465989497) - 396,555;
• Xu Feng (Bank of China account 5313587 40715) - USO 1,620;
• Xu Li Yan (Bank of China account 325950302688) - USO 30,001 ;
• Xu Liangchen (Bank Of China account 344150336251) - USO 395,000;
• Xue Li Jun (Bank of China account 401420801882760148)- USO 25,580;
• Yan Zhi He (Bank of China account 6013820800074118934)- USD 16,551;
• Ye Aim in Taizhou (Zhejiang Tailong Commercial Bank account 3306021420100010492)- USO
200,000;
• Ye Bo Hua (Agricultural Bank of China account number 19846014040000829) - USO 99,990;
• Ye Li Ping (China Construction Bank Corporation account 1492059980110279461) - USD
200,000;
• Zhang Ai Hua (Bank Of China account 401420801881386455) - USO 19,950;
• Zhang Feng Cai (Bank Of China account 349350331216) - USO 27,700;
• Zhang Pin Yu (Bank Of China account 403954349391) - USD 80,000;
• Zhang Xiao Qing (Bank of China account 331150295539) - USO 19,500;
• Zhang Yan Chaoyang (Bank of China account 401420801883318414)- USD 210,705;
• Xhang Ying (Bank of China account 340250354107) - USD 19,300;
• Zhang Zhizan (China Construction Bank Corporation account 62270033227 40064348) - USO
4,018;
• Zhang Zhou (Bank of China account 325958150466) - USO 18,324;
• Zhao Ai Zhen (Bank Of China account 6217866200000740000) - USO 50,000;

• Zhao Chun Fei (Bank of China account 346750348807) - USO 43,100;

• Zhao Lan Fen (China Construction Bank Corporation account 4340621420489610) - USO
53,330;
• Zhao Ya Na (Bank of China account 4014208-0188-284203-9)- USO 6,000;
• Zhao Zhi Yong (Bank of China account 401420801882883231) - USO 10,000;
• Zhe Jiang Jiang (Bank of China account 820025284308093014) - USO 3,000;
• Zheng De Fa (Bank Of China account 359763091394) - USO 85,726;
• Zheng Jie (Bank of China account 401420801883276886) - USO 20,000;
• Zhong Cheng (Ping An Bank Co. Ltd account OSA 11012216666101) - USO 6,541;
• Zhou Zheng Xue (Bank of China account 444720101880373000) - USO 9,200; and,
• Zhu Liang Xian (Agricultural Bank Of China account 6228480338626951978) - USO 319,591.
5.1.5 Russia (USD 79.5 million)

An overview of amounts dissipated to Russia, excluding the amounts from further traces detailed
below is provided in Section 11. USO 37.1 million dissipated to Russia was from further traces of
amounts originally dissipated from the Core Laundering Mechanism to Latvia, Estonia and
Moldova.
Many of the transfers were made to accounts at Russian banks that were not involved in the transfer
of the circular flow of funds detailed in Section 11 (Alef Bank and Metrobank).
The following accounts received a series of large transfers:
• Bahiti Ltd (a company registered in British Virgin Islands according to bank statement
descriptions) received a total of USO 14.2 million to its Eurotrust Bank and Novikombank
accounts;
• llan Shor received USO 10.9 million in 2 transfers into his Gazprom bank account (see
section 8);
• Mangold Tradestar Inc received USO 1.9 million in a series of transfers into its
Novikombank account;
• Rossol Import LLC (USA) received USO 0.6 million into its Eurotrust Bank account in a
single payment; and,
• Agroidea 000 (a Moldovan company) received USO 1 million into its Eurotrust Bank
account in 2 transfers.

No other single transfers of over USO 0.5 million were identified.

Table 9: Overview of transfers to Austria (USD 56 .1 million)

payments million
Banca de Raiffeisen Bank 1-55.069.371 8 52 .1
Economii
Advorca Finance Bank Gutmann AG AT251914003316980097 6 0.9
Ltd AT961914003316918097
Mjet 7Tegetthoff Raiffeisenlandesbank AT543200000015105794 5 0.9
Niederoesterriech-Wien
AG
Other accounts 2.2
TOTAL 56.1
The majority of the funds which were transferred to Austria (USO 52 .1 million) related to the funding
received in BEM's accounts at Raiffeisen Bank in relation to the Roseau transaction, detailed in
Section 7. These funds were transferred as part of a series of transactions whereby BEM sold a
part of its non-performing loans portfolio to its shareholders.
Transfers were made to 21 other accounts
5.1.6 Estonia (USD 51.4 million)

Approximately USO 58 million was transferred to accounts in Estonia directly from the Core
Laundering Mechanism. These amounts were traced onwards according to the tracing methodology
detailed in Section 9 of the Detailed Report with the assistance of a Memorandum of Understanding
between the NBM and the Estonian regulatory authority. The results of this analysis identified USO
51.4 million traced to Estonian bank accounts .
Section 10 detailed a secondary laundering mechanism that was identified in the Estonian banks.
The USO 51.4 million that remains in Estonia is mainly due to the following factors :
• Funds transferred to accounts where document requests are pending comprised of

transfers to around 40 accounts and amounted to USO 25 million;
• Funds amounting to USO 21 million were transferred to accounts that were mixed with other
funds in such a way that they could not be traced onwards in accordance with the tracing
methodology. By way of example, in a number of cases, funds were traced partially to a

rolling foreign exchange contract that was renewed every few days and where it was not
possible to determine an onward trace; and,
• Funds amounting to USO 5 million were transferred onwards in amounts that were below
the threshold for further tracing detailed in section 9 of the Detailed Report.
5.1.7 Switzerland (USD 42.8 million)

Table 10 : Overview of transfers to Switzerland

payments million
Grinelly Ventures Credit Suisse AG CH8805065058952712000, 12 14.4
Corp CH2804835058952711000
Mavogan Union Bancaire CH5208657007007436622 1 10.3
Holdings Limited Privee
Temporaneo Ltd UBS AG CH050020620645434660G 3 3.0
Llanmill Limited Gazprom bank CH0708660017640100333 4 1.7
(Switzerland)
Fl Property UBS AG CH200020620618718570K 3 1.5
Estates Ltd
DA Finance Ltd Bank Julius Baer and CH6908515030925652006 3 1.3
Co Ltd
Beque Group S.A. Reyl et Cie S.A. CH8108384000015190200 2 1.0
Redstone Campagne Bancaire CH8608762000796070001 1 1.0
Helvetique
Financial
Angelo Finance SG Private Banking CH88085820435116A000U 2 0.9
(Suisse) S.A.
Corp
Bonaclara Group Bank Julius Baer and CH2908515030888842002 2 0.8
Co Ltd
Ltd
VXR Trading Inc Quilvest Ltd 180888 (QVCHCHZHXXX) 3 0.7
TAG Aviation SA UBS AG CH6600240240C07957013 6 0.5
Other accounts 5.7
TOTAL 42.8
The remainder was paid to 59 accounts in 81 transactions, including transfers to 3 individuals:

• Mr Andriy Levin (UBS account CH400024024015775260Q) - USO 99,954;
• Kam ii Bernath, Bratislava (Bank Julius Baer and Co account CH5608515031018822001) -
USO 46,007; and,
• Semen Nizharadze (Bank account CH3808515063899272001) - USO 10,000.

5.1.8 USA (USO 25.5 million)

Table 11 : Overview of transfers to USA

payments million
Banca de Economii Bank of New York 890-0260-785 2 15.2
Mellon
Argo International Group Inc Wells Fargo Bank 2000004604905 2 0.8
Payment World LLC Bank of America 000245721147 2 0.7
Other accounts 8.8
TOTAL 25.5
USO 15.2 million of the amount transferred to accounts at banks in the USA was related to the
acquisition of BEM's portfolio of non-performing loans by Roseau Alliance LP ("the Roseau
transaction"). This is detailed in Section 7 of the Detailed Report.
Transfers were made to 130 other accounts, including 41 accounts that appear to be in the name
of individuals, in 235 transactions. Many of these transfers were made to accounts in the name of
individuals that appear to have South East Asian last names. An account at Wells Fargo in the
name of Sergiu Pavluscenco, received USO 0.4 million in a series of 62 transactions directly from
Core Laundering Accounts (see Table 1).
The individuals that received funds are listed as follows :

• An K Phan (Bank of America account 004605857560) - USO 120,000;
• An Tu Le (Citibank account 205777139) - USO 53,000;
• Anh Phuong Ngu (Wells Fargo Bank account 2884220936) - USO 49 ,992;
• Bui Kim Loan (Wells Fargo Bank account 8086800615)- USO 30,000 .18;
• Dang H Son (JP Morgan Chase account 559252213) - USO 100,002.30;
• Due Huu Nguyen (Bank of America account 325022528931) - USO 61,556;
• Duong Le (Wells Fargo Bank account 1010186320541)- USO 20 ,000 .15
• Giang Nguyen (Wells Fargo Bank account 5688588978) - USO 100,001;
• Ha D Nguyen (Wells Fargo Bank account 5224845601) - USO 49,999;
• Hang Pham Thu (Bank of America account 004641864326) - USO 20 ,000;
• Heather Tran (Wells Fargo Bank accounts 3779726144 and 9168208933)- USO 10,002;
• Sergei laralov (Santander Bank account 73004936016) - USO 8,000;
• lelizaveta Yushchenko (JP Morgan Chase Bank account 3602196339) - USO 50,000;
• Joseph Maalouf (UW Credit Union account 54152001)- USO 48,998 ;
• Khanh Duy Pham (Bank of America account 325047307140) - USO 100,001 .18;

lKroll Project Tenor II, Confidential Working Papers Part I to Detailed Report,
• Larysa Filippenkova (JP Morgan Chase account 4422899512) - USO 6,914;

• Le My Thi Su (Bank of America account 586028859249) - USO 100,002;
• Linh Van Nguyen (Houston Federal Credit Union account 4238560) - USO 138,000;
• Mai Xuan Loe (Bank of America account 325009893715) - USO 77,214;
• My N Dang (Bank of America account 2986067077) - USO 40,001;
• NATALIA AND ROBERT PLOTKIN (JP Morgan Chase Bank account 733981260) - USO
65,000 ;
• NGOC D PALMER (JP Morgan Chase Bank account 424427511) - USO 95.499;
• Oanh Kim Ha (Bank of America account 488045213830) - USO 139,999.50;
• Phuoc Quang Phan (Wells Fargo Bank account 5447532937) - USO 34,996 ;
• Rumi Ngoc Anh Thu Tran (Wells Fargo Bank account 7296878601) - USO 100,001 .15;
• Serghei Luchian (Citi Bank account 9136451465)- USO 19,147;
• Serghei Odobescu (JP Morgan Chase Bank account 2919217780) - USO 19,000;
• Sergiu Pavluscenco (Wells Fargo Bank account 1010298861040) - USO 408,500;
• Stanislav Poritskiy (JP Morgan Chase Bank account (000000877088989) - USO 9,900;
• Steve Tuan (Bank of America account 325046255976) - USO 100,000;
• Tetiana Markova (Bank of America account 483043375885) - USO 60,000;
• Thanh P Wesser (Wells Fargo Bank account 1345065773)- USO 30,001 ;
• Thao Chow (Bank of America account 325000829937) - USO 49,999;
• Th ien Tan Nguyen (Bank of America account 5860354 75849) - USO 100,000.50;
• Thuy Ha Bach (Citi Bank account 40045095888) - USO 100,000;
• Thuy Thi Thu Pham (PNC Bank NA account 5568089864) - USO 50,000
• Tim Le Marconi (Wells Fargo Bank account 8914567717) - USO 299,996 ;
• Trung Nguyen (JP Morgan Chase account 3326183935 and Bank of America account
325009013948) - USO 210.496 ;
• Tuyen Tran (Wells Fargo Bank account 2832387134) - USO 91 ,000; and,
• Uyen P Wesser (Wells Fargo Bank account 1345064719) - USO 30,001 .

, Kroll. Project Tenor II, Confidential Working Papers Part I to Detailed Report,
5.1.9 Hong Kong (USD 22.6 million)
Tab le 12: Overview of transfers t o Hong Kong
Entity Name Bank Account number No of USO

payments million
Bata Limited Hong HSBC 015458417838 3 0.9
Kong
Bright Progress Hang Seng Bank Limited 364226241883 6 0.7
International Limited
Thai Xiang HK HSBC 023277882838 2 0.7
Investment Limited
Bergner (HK) Union Bank of India 000014010000034 3 0.6
Limited
Naval Star HSBC 817-392616-838 1 0.5
International Limited
Tran Due Dung HSBC 646041723833 2 0.5
Other accounts 18.7
TOTAL 22.6
Payments were made to 226 other accounts in 290 transactions, including transfers to 8 individuals
detailed below. Most payments were made to companies that appear to be trading concerns . Many
of these companies have similar names to the account names of the Chinese trading companies
that received funds and many of the same descriptions of trading goods were used.
The individuals that received funds are listed as follows:

• Chen Zhuo (HSBC bank account 436803464888) - USO 11,390;
• Cheung Sau Ko (HSBC bank account 078496411833) - USO 17,675;
• Ding Lian Qin (Hang Seng Bank account 2207711066) - USO 50,000;
• Ho Ko Yane Gin (Hang Seng Bank account 024383539863888) - USO 80,030;
• Hung Chang Chi (China Trust Commercial Bank Hong Kong account 904134050433) -
USO 70,000;
• Li Zheng Long (Bank of China Hong Kong account 01268792056347) - USO 66,479;
• Rinku Ghai (HSBC account 509490199833) - USO 57,000; and,
• Xu Shunmin (Bank of China Hong Kong account 01268792062524) - USO 19,700.

lKroll Project Tenor 11, Confidential Working Papers Part I to Detailed Report,
5.1.10 Italy (USD 16.8 million)
Table 13 : Overview of transfers to Italy

payments million
Landini Cassa di IT09U0616037890000001804C00 1 8.0
Alessandro Risparmio di
Firenze
Golden Plast Banca IT65S0100568870000000009020 3 1.0
SPA Nazionale Del IT70V0100502000000000820849
Lavoro S.P.A.
No Silence SRL Deutsche Bank IT51 L0310403217000000820800 6 0.8
Camel Group Unicredit S.P.A IT51G0200861860000023110362 7 0.8
SRL
Fidicontrol Banca Monte dei IT72T0103002858000063172748 1 0.5
S.P.A. Paschi di Siena
Other entities 5.7
TOTAL 16.8
An account in the name of in Italian individual received USO 8 million in a single transfer to an
account at Cassa di _Risparmio di Firenze. Payment description for this transfer was "purchase price
Fattoria Viticcio Socieata Agricola ar/". Google searches 105 indicate that a property with the name
of "Farm stay Gattoria Viticcio" in Chianti is available to book for accommodation.
Payments to 168 other accounts were made in 207 transactions.
Two additional transfers were made to an account in the name of an individual:

• Fabio Fetel (Banca Monte Dei Paschi di Siena account IT82V0103049630000063115164)
- USO 12,819.
105
htips://www.tripadvisor.co . uk/Hotel Rev iew-9530240-d 309982-Reviews- Fattoria Viticcio-
Greve in Chianti Tuscany.html

5.1.11 Romania (USD 15.8 million)
Table 14: Overvie w of transfers to Romania

payments million
ABO Asiana Development Garanti Bank RO07UGBI0000102014928 23 12.1
Limited 106 RO04UGBI0000102014929USD
RO07UGBI000010201492BEUR
Raiffeisen Bank RO54RZBR0000060016942411
RO65RZBR0000060016942407
East Global Business Srl1°7 Raiffeisen Bank RO85RZBR0000060015554656 1.3
Next Estate Investment Raiffeisen Bank RO19RZBRD000060013628842 0.7
Sr110s
Other accounts (23) 34 1.7
TOTAL 15.8
Payments were made to 23 other accounts in 34 transactions mainly in 2013 and 2014, including
to four accounts in the names of individuals :
• Adrian Ragnar Thiess (Unicredit Bank account RO80BACX0000000025492320) - USO
113,050;
• Christos Konstantinou (Banca Transilvan ia SA account RO78BTRLEURCRT0215229101)
- USO 59,983 ;
• Negura Gheorghe (Raiffeisen Bank account RO70RZBR0000060014195083) - USO
97 ,090; and ,
• Sargsyan Abraham (Bank account RO73RZBR0000060016481319) - USO 4,256.
5.1.12 Germany (USD 11.1)
Table 15 : Overview of transfers to Germany

payments million
Gebr Heinemann Deutsche Bank DE31200700000540530300 1 1.8
SE and Co KG
Aero-Dienst Bayerische DE98700500000001250914 5 1.2
Landesbank
106
An account in this name was also held at Hellenic Bank in Cyprus . As detailed in section 3.1 .5, Asiana Development
Limited received funds from Tukumaan Limited , a company linked to Mr Plahotniuc.
107
Linked to Vlad Fila!, see 3.2.6
108
Linked to Vlad Fila!, see 3.2. 7

Fossil (Europe) Unicredit Bank Ag DE13700202700871027994 3 0.5

GmbH
ISV Norddeutsche DE56250500000152000220 1 0.5
Steuerungssysteme Landesbank
GmbH
Other 7.1
TOTAL 11.1
Gebr. Heinemann SE and Co received USD 1.8 million into a Deutsche Bank account in December
2014. This company transacted frequently with a number of the Core Laundering Accounts (see
Section 8), although it is unclear what the relationship between the entity and the Core Laundering
Account is .
Other transfers were made to 125 accounts in 158 transactions, including transfers made to 8
individuals :
• Alexander Muchin (account DE06200100200854748202)- USD 41 ,762 ;
• Danh Uy Lao (Deutsche Postbank account DE36700100800126501803) - USD 66,467;
• Dinh Ha Vu Kel N (account DE55850550004100040488) - USD 48 ,252;
• Ganna Roytblat (Sparkasse Karlsruhe Ettlingen account DE63660501010108180613) -
USD 29 ,260;
• Johann Haugg (Comerzbank account DE59703800060706380500) - USD 8,645;
• Sergiy Yenkov (Sparkasse Hannover account DE54250501800010643036)- USD 117,584;
• Suren Mkrtchyan (account DE09200505501001807237) - USD 3,929 ; and,
• Victoria Koval (Nassuische Sparkasse account DE57510500150273009720) - USD
39,990.

5.1.13 Turkey {USO 10.4 million)
T able 16: Ove r view of transfers t o Turkey

payments million
Ecem Kredi Turkiye TR62002050000910836670010 2 1.8
Lojistic lnsaat Cumhuriyeti 1
Kuyumculuk Ltd Ziraat Bankasi TR39000100248968490665500
A.S. 6
Soma Kozmetic Finansbank A.S. TR97001110000000004095284 3 1.0
San Dis Tic Ltd Yapi Ve Kredi 1
STI Bankasi A.S. TR90000670100000008545004
6
Merdil Tekstil Kuveyt Turk TR73002060027002175702010 2 0.6
Elektronik IC Ve Katilim Bankasi 1
Dis Ticaret San AS. TR41002050000085209960010
Ve Ticaret 1
Limited STI
Cak Tekstil San Yapi Ve Kredi TR83000670100000004690440 3 0.5
Ve TicA.S. Bankasi A.S. 9
Other entities 6.5
TOTAL 10.4
Transfers were made to 97 other accounts in 127 transactions , including transfers to 15 individuals.
Many of these transactions had descriptions related to trading goods, similar to amounts transferred
to accounts in China. The use of Turkey as a potential secondary laundering mechanism is detailed
in Section 10.
The individuals that received funds are listed as follows:

• Bedrettin Valcin (Yapi Ve Kredi Bankasi A.S. account TR160006701000000093351446) -
USO 15,000;
• Berivan Cetinkaya (Akbank account TR100004600710001000072315) - USD 31,520;
• Birol Sahin (Denizbank account TR670013400000674694900002) - USO 73,000;
• Dzhamal al Lakhverdiiev (Kuveyt Turk Katilim Bankasi AS account
TR070020500009125998200001) - USO 36,005;
• Ergul Kursungoglu (Yapi Ve Kredi Bankasi A.S. account TR510006701000000062941995)
- USO 50,000;

lKroll Project Tenor II, Confidential Working Papers Part I to Detailed Report,
• Gulistan Kitay (Yapi Ve Kredi Bankasi A.S . account TR180006701000000040705145) -

USO 15,001 ;
• Guzide Deniz Galik (account TR110006200145600009099215) - USO 40 ,000 ;
• Huseyin Ka Cmaz (Turkiye Garanti Bankasi AS account TR770006200043700009092937)
- USO 32,897;
• Mustafa Su Ngur (Finansbank AS account TR680011100000000018628425) - USO 1,180;
• Murat Kaya Lalel (Turkiye Garanti Bank account TR490006200060100009093203) - USO
5,000;
• Olena Gyria (Denizbank AS account TR730013400001101267800002) - USO 100,000;
• Sabir Mame Dov (Turkiye Halk Bankasi AS account TR500001200982000059000110) -
USO 40,000;
• Saruhan Gulcur (Turkey Akbank T.A.S . account TR110004600277001000035747) - USO
14,935;
• Sinem Ates (Finansbank account TR240011100000000018048672) - USO 50,593; and ,
• SURAT DENI Z EVI (Turkiye Garanti Bankasi A.S. account
TR42000620004000000900363) - USO 42,500 .
5.1.14 Netherlands (USO 8.6 million)
Table 17: Overview of tran sfers to Netherlands

payments million
Samsung Citibank NL27CITI0104630847 6 2.3
Electronics NL36CITI0104630103
Overseas B.V.
Doliver Services ING Bank NL22INGB0020027699 5 2.3
Inc
Arma Steel Garanti Bank NL90UGBl8263272637 1 1.0
Trading LP International
Alden Commercial Amsterdam Trade NL55ATBA0801404001 3 0.7
Ltd Bank
Wealth Investment Amsterdam Trade NL56ATBA0802451001 1 0.6
Holdings Inc Bank
Other entities 35 1.7
TOTAL 8.6

I Krol l Project Tenor II, Confidential Working Papers Part I to Detailed Report,
Payments lower than USD 0.5 million in aggregate were made to 31 other entities in 35
transactions. The payments were made mainly in 2013 and 2014 to companies that from their
names appear to be acting in a number of different industries including navigation , export and
logistics.
Payment was made to one account in the name of an individual :

• Mikhail Volovitch (ABN Amro Bank account NL 18ABNA0411240757) - USO 13,087.
5.1.15 United Arab Emirates ("UAE") (USD 6.8 million)

Table 18: Overview of transfers to UAE
Entity Name Bank Accounts No of USD

payments million
Eze General Abu Dhabi AE410030010088409195001 3 2.6
Trading LLC Commercial
Bank
Bank of Baroda AE120110090010200022879
YVH Building Bank of Baroda AE500110090010200023165 1 0.8
Materials
Trading LLC
Other entities 62 3.4
TOTAL 6.8
Payments were made to 40 other entities in 62 transactions . Many payments made to UAE
companies were made to trading companies, mainly in 2013 and 2014 . Many of the companies that
received funds had names that suggested they were in the automobile industry.
Payment was made to two accounts in the name of individuals :

• Vensimal Mulchand (Habib Bank account AE070290420311333174373) - USD 39 ,999 ;
and,
• Nguyen Tri Long (bank account AE820330000019010018521) - USD 36,000 .

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I Kroll_

Detailed tracing analysis

Privileged and Confidential

(Detailed Tracing Analysis)

Privileged and Confidential

Rest ricted Use Warn ing

(Detailed Tracing Analysis)

3. Transactions with corporate accounts linked to individuals ................................. ........... 17

3. 1.5 Tukumaan Limited (secondary I linked company) ........................................................................... 19

3. 1.9 Gemeni SA Casa de Comert ("Gemeni'J .................................................................................... .... 23

4. Individuals involved in the suspected fraud mechanisms - Russian accounts ............... 33

,0 tivile~rar.l f1nd Conliclentiaf

(Detailed Tracing Analysis)

F)rivifega cl and Contir:.'enUe.!

(Detailed Tracing Analysis)

List of Figures and Tables

Privileg scJ anc/ Conficlentiat

(Detailed Tracing Analysis)

1. Introduction to detailed tracing analysis

The Detailed Tracing Analysis focusses on the following areas:

F'1} 1.1iiegsd 2nd Cordiderdia/

(Detailed Tracing Analysis)

• A glossary of company accounts in multiple jurisdictions which, according to Kroll's analysis,

t'ri"iie9ecl ancl Conric!enNa i

(Detailed Tracing Analysis)

2. Individual Moldovan beneficiaries / transit

Name Summary of transactions and details of individual Total of

,0 rivilegGcf and Cc;nfic!en/ia/

(Detailed Tracing Analysis)

Name Summary of transactions and details of individual Total of

Shor received funds which originated in part from the

The USD 13.0 million was made up of 35 transactions

Cojocaru was listed as an administrator for two ABLV

F'rfi 1f!eqe d and (;onli•:lentia i

(Detailed Tracing Analysis)

Name Summary of transactions and details of individual Total of

An ABLV account in the name of Cojocaru received funds

Ilona Sh or's ABLV bank account was classified as a Core

Ilona Shor received a total of USO 2.5 million from the

Privi.!egad and Con{ic/Gniie, I

(Detailed Tracing Analysis)

Name Summary of transactions and details of individual Total of

Further detail is set out in the example fund flow traces

Lupov was a shareholder in UB, who received funds from

5 https ://ww1,v.ri se. rnd/arti col/plaholniucleaksihttps ://1,w:w.rise.mdiarlicol/plahotniucleaks/

F•r_ivilegeo' :.1;11] 00i?rtcienfia/

(Detailed Tracing Analysis)

Name Summary of transactions and details of individual Total of

F:,rivffeger.l anc;f Confideni'iaf

(Detailed Tracing Analysis)

Name Summary of transactions and details of individual Total of

%0 1%89%O0%B5%O0%B9 %01 %8 '1%D1 %82%D1 %80%O0%B0%O0%BO%O0%B5/1553/

Privileged &nd Ccni'icie ntial

(Detailed Tracing Analysis)

Name Summary of transactions and details of individual Total of

received USO 109,191 to the credit card account linked

1cii~ 1ifegec! a,7c! Cont"ic!ential

(Detailed Tracing Analysis)

Name Summary of transactions and details of individual Total of

,,.:~~;'!+~,\';~:.~;.i;':'-;::..::-;•:~r:':~~ .~: ''.~1':' ··. :@) C