Sun Of Justice

Dec 22, 202350 min read

Unpacking the QBF Fraud Case: (Part 4) A Comprehensive Analysis. Testimonies of E.A. Rossieva, Pakhomov V.S, and A.S. Golubev.

Updated: May 14

The indictment reveals a complex web of deceit, embezzlement, and manipulation orchestrated by the masterminds behind the QBF financial group. The exposure and subsequent dismantling of this criminal Network by law enforcement highlight the scale and severity of the operation.

Protocol of confrontation between the accused Munayev Z.V. and the accused Golubev A.S. dated 11.03.2022, according to which the accused Munayev Z.V. fully confirmed his testimony, namely that Golubev A.S. worked in St. Petersburg, started as a financial advisor.

Subsequently, after achieving results, and over time, in about 2016, he (Golubev A.S.) was promoted to the head of the office of the company QBF in St. Petersburg.
In this position, Alexey's responsibilities included fulfilment of the sales plan, hiring and working with employees, attracting clients, and meeting standard KPIs.
He (A.S. Golubev) reported to Vladimir Pakhomov, the QBF branch network director. A.S. Golubev was in charge of the company's sales department in St. Petersburg, the head of the sales department and financial advisors.
A.S. Golubev could be invited to meetings with specific clients as an oﬀicial, negotiate with clients and interview applicants for staﬀ positions.
In the oﬀice, Golubev A.S. organised the acceptance of clients for international market services and may have been a signatory to some contracts along with Vladimir Pakhomov and other oﬀice staﬀ.
The office staﬀ accepted clients' funds, both non-cash and cash. Cash from branches, including the St. Petersburg branch, was collected (picked up) and delivered for further transfer and disposal by R.V. Shlakov per his (R.V. Shpakov's) instructions.
On the territory of the office of the city of St. Petersburg office, the acceptance of cash from clients within the framework of international market contracts took place.
Their delivery to Shpakov R.V. could be carried out by a third person appointed by him (Shpakov R.V.) from outside the staﬀ by flying to St. Petersburg, someone from the St. Petersburg office could be sent by Golubev A.S. on the instructions of Shpakov R.V. or Pakhomov V.S. to Moscow to collect the funds.
In the same way, cash withdrawals of clients' funds (return of funds to clients) took place, i.e. on the instructions of R.V. Shpakov, were delivered to St. Petersburg for further disbursement to financial advisors and transferred to clients.
In the oﬀice, cash receipts, expenditure cash vouchers, and receipts for acceptance and disbursement of funds were drawn up.
These were standard documents for confirming cash turnover in the office.
Part of the salary in QBF oﬀices was also paid in cash, and employees received cash in hand following their accrued remuneration.
Withdrawals could be made, among other things, through the employees' bank cards, to which Shpakov R.V. sent funds from his company accounts for further withdrawal and disbursement to the employees.
The competence of the head of the office included determining the amount of salaries on his part and the amount of bonus remuneration to fulfil targets.
The system of accepting and disbursing client cash and cash settlements with the company's employees has been in place at QBF since 2010.
Cash could be sent to Golubev A.S.'s bank accounts for withdrawal of these funds and disbursement to employees or Clients, depending on instructions received by Golubev A.S. from Shpakov R.V. or Pakhomov V.S.
When accepting cash under international market contracts, the office manager was responsible for, among other things, appointing an employee to travel to the Moscow office and hand over client funds to Shpakov R.V.
The employee was approved by Shpakov R.V. Golubev A.S., as manager, organised the standard procedure for accepting cash at the St. Petersburg oﬀice following the company's regulations approved by Shpakov R.V. Cash for withdrawal to clients could be taken either from the St. Petersburg oﬀice or the St. Petersburg oﬀice.
He (Z.V. Munayev) believes that A.S. Golubev, as well as all QBF employees working in the international market sales units, was aware of the absence of a licence of QB CAPITAL CY LTD (QCCI) to carry out brokerage activities and other activities necessary for working with securities in the order of organising interaction with clients in the territory of the Russian Federation given his work in the licensed QBF LLC.
After 2015, due to the worsening situation with withdrawals of clients' funds, in terms of timing and procedures, the company had a standard practice of accompanying the client in the post-sale service process, including after submitting an order for withdrawal of funds.
This procedure was in place in all regional oﬀices of QBF, including the oﬀice of Alexey Golubev in St. Petersburg. St. Petersburg.
The organisation of the work of the accountable employees in negotiations with clients, both telephone and face-to-face meetings, the form of the information provided, the documents required at these meetings, possibly reports and other explanatory documents, as well as the communication of information on the documents required from clients to the company's sending banks (source of origin of funds, certificate of non - criminal record, certificate of housing and utility services, letters of recommendation and other documents) - was carried out by A.S. Golubev as head of the St. Petersburg oﬀice.
Golubev A.S., as the head of the office, discussed the claims received with employees, the reasons for their occurrence, possible solutions, and help to clients, and defended the company's reputation in the eyes of both clients and employees. A.S. Golubev could participate in meetings with clients.
As a rule, employees invited senior management to meetings with especially large or incredibly dissatisfied customers, as assistance in holding such meetings is necessary due to the high negativity and high tension.
The clients' claims were related to the timeframe for withdrawal of funds, which was increasing. Golubev A.S., as the head of the office, given the instructions he received from Pakhomov V.S., informed clients and employees that this was due to the tightening of regulation of the financial market as a whole, as well as a particularly moral attitude due to sanctions to Russian clients and money of Russian origin, the need to provide an increased and rather extensive set of documents, which was new to most.
Also, a significant part of the period was taken up by the procedure of selling assets, which lengthened in time due to the deterioration of the situation in the U.S. stock market compared to the period before 2014.
This information was communicated to the heads of all oﬀices by Pakhomov V.S., who further spoke to the employees of the oﬀices by the heads of the oﬀices, additionally shared by the employees of the oﬀices to the clients.
The initiative of transferring problem clients from the branch, including the office in St. Petersburg, to the department accompanied by the client. St. Petersburg, to the support department of the Moscow oﬀice.
In the case of extensive and problematic clients, it was coordinated with R.V. Shpakov. Due to the absence of branch management, lack of communication with the clients of the branches, and lack of authority to make any decisions with them, the information he received was based on the data provided by V.S. Pakhomov and R.V. Shpakov.
(Vol. No. 306, pp. 212 - 221)

Protocol of confrontation between the accused Munayev Z.V. and the accused Pakhomov V.S. dated 11.03.2022, according to which the accused Munayev Z.V. fully confirmed his testimony, namely that Pakhomov V.S. started working in the group of companies "QBF" in 2010 with the position of junior financial adviser.

Subsequently, he was promoted to Head of the Sales Department by R.V. Shpakov in 2011 and appointed Head of the St. Petersburg office of QBF Group in 2013.
Subsequently, when new offices were opened, Pakhomov held the position of Director of the branch network of QBF Group.
From 2013 onwards, Pakhomov's direct supervisor was R.V. Shpakov. V.S. Pakhomov's duties included fulfilling the sales plan, developing sales departments and branch networks, recruiting employees and office managers, ensuring business operations, and attracting clients and their support (clients - individuals and legal entities for international market services).
V.S. Pakhomov was subordinate to the heads of sales offices, which he managed from his office in St. Petersburg. V.S.
Pakhomov was responsible for fulfilling key performance indicators of the offices, the number of client meetings and the number of funds raised.
V.S. Pakhomov participated in meetings with clients in the recruitment of employees for critical positions (managerial positions in sales departments in the offices - branches of QBF group of companies - LLC PC QBF, LLC MC QBF, LLC Q.Broker, KG LLC, QBF JSC, QF Estate SPb LLC, QF Estate EKB LLC, QBF Capital SeaWay Ltd and other companies directly or indirectly owned by Shpakov R.V. Relations between Pakhomov V.S. and Shpakov R.V. were close and trusting, Pakhomov V.S. followed the instructions and directions received.
After 2015, with the gradual appearance of delays in withdrawals of clients' funds, the branch network started claim work, organised a document management system, tightened requirements for clients withdrawing funds, and provided additional procedures for meetings and negotiations with claim clients, especially with the key, the largest, and the most negative ones.
Since V.S. Pakhomov was responsible for work in the branches, he implemented this system in the sales offices according to R.V. Shpakov's instructions.
He adjusted it depending on the situation on the ground and private agreements with clients.
QBF Group's offices were in St. Petersburg, Yekaterinburg, Tyumen, Kaliningrad, Ufa and possibly other cities. Pakhomov V.S. had finished his work in the QBF group of companies at the time of his detention; as of May 2021, Vladimir continued to work for QBF, including at the Moscow office: he organised work there in the absence of R.V. Shpakov, carrying out his (R.V. Shpakov's) remote assignments, including based on new difficulties and tasks related to the criminal case.
Pakhomov V.S.'s remuneration, like that of other sales managers, consisted of a fixed and bonus part.
The bonus part was paid as a percentage of the funds raised by the previously listed offices, funds raised under agreements on access to international stock markets and trust and advisory management agreements.
Pakhomov V.S. was also paid a percentage of remuneration from the total accumulated client portfolio.
This payment may have varied but was subsequently fixed by him (Z.V. Munayev) and V.S. Pakhomov.
The funds were raised both in cash and non-cash form.
Cash funds from all branch offices were sent on behalf of Pakhomov V.S. and Shpakov R.V. both to the St. Petersburg office and to the Moscow office for disposal by Shpakov R.V.
These funds were not fully credited to trading accounts as they should have been: some funds were used to disburse old clients' previously invested funds and for employees' salaries and bonuses.
This system was in place at all of QBF Group's offices. Couriers for "encashment" of funds were appointed directly by R.V. Shpakov or V.S. Pakhomov in agreement with R.V. Shpakov.
Storage of client contracts, incoming and outgoing cash vouchers, receipts and other client documents was organised and carried out by V.S. Pakhomov for clients of the QBF branch network.
V.S. Pakhomov disagrees with the testimony of V.S. Pakhomov in terms of his functionality, insists on his testimony, and adds that V.S. Pakhomov was the signatory of contracts with clients on the international market and signed them personally during all terms of validity of his powers of attorney.
V.S. Pakhomov was a member of working groups in correspondence and meetings, participated in management meetings on significant issues of the QBF Group, made strategic decisions, participated in telephone correspondence and chats, and communicated instructions through them.
On the role of Pakhomov V.S. in solving the problems that arose during the audit of the activities of LLC IC QBF by the Central Bank of Russia and the role of Pakhomov V.S. when the company had issues with law enforcement agencies, it has explained the following.
During the period of difficulties in the group of companies "QBF" with the withdrawal of clients' funds, Shpakov R. V. assigned the task to Pakhomov V.S. to solve the problems with the withdrawal of clients' funds. V. set a task for Pakhomov V.S. to organise lobbying for the company's interests and its protection with the help of patronage from law enforcement agencies and the Central Bank of the Russian Federation (CBRF).
Through his circle of acquaintances and relatives, V.S. Pakhomov found the necessary people in law enforcement agencies and the Central Bank of the Russian Federation, secured an agreement with them and ensured their continued work together with R.V. Shpakov on a compensated basis.
The funds were transferred to these persons in cash, including those shared by Pakhomov V.S. In the Central Bank of the Russian Federation, these were representatives of the management and law enforcement agencies - services that directly or indirectly influenced the criminal case on Polezhaev A.'s application.
Client cash was received at the branches of the QBF group of companies under the direction of Pakhomov V.S.
Company employees received it at the offices and along routes determined by Pakhomov V.S. and Shpakov R.V. were delivered to the necessary offices for internal payments and cash withdrawals to previously attracted clients.
Internal payments included salaries, bonuses, rent and other administrative expenses.
Part of the cash raised under international market contracts was not credited to international trading accounts but was issued and spent on current payments and cash withdrawals to old customers.
Cash was also received from Russian and foreign companies of Shpakov R.V. to QBF branches.
These funds were spent under the supervision of Pakhomov V.S. Also, some funds were regularly transferred to the bank cards of the employees of the branches under the order of Shpakov R.V. and the supervision of Pakhomov V.S.
These funds were withdrawn from the bank cards given for salaries and withdrawals to clients. V.S. Pakhomov insists on his testimony regarding the role of V.S. Pakhomov in encashment and cashing of funds from the group of companies "QBF", as V.S. Pakhomov was personally interested, including in the acceptance of cash funds, as it depended on the issuance of their salaries, withdrawal of funds to clients, relations with them in the key to investment, and the reputation of the company.
Also, due to his circle of acquaintances, Pakhomov V.S. sent potential nominees to the companies of Shpakov R.V. and the lawyers of QBF group of companies for companies owned by and related to Shpakov R.V.
This was necessary for the continuation of the company's activities during the crisis period, as well as for the development of the company in other periods.
Shpakov R.V. needed, among other things, nominees in critical positions to unconditionally fulfil his instructions, make expenditures and provide external cover for his activities.
Shpakov R.V. sent these instructions, including to Pakhomov V.S.
Pakhomov V.S. knew that QB CAPITAL CY LTD (QCCI) did not have a license to carry out brokerage activities and other activities necessary for working with securities.
He repeatedly discussed it with him in personal conversations and telephone correspondence.
Pakhomov V.S. was aware of the problems related to the lack of a license at QB CAPITAL CY LTD (QCCI).
This is evident from the correspondence and was repeatedly discussed with Pakhomov V.S., Shpakov R.V. and other QB Group managers.
He (Z.V. Munayev) knows the following about the role of V.S. Pakhomov in agreeing (s) with M.I. Borzenkov, receiving money from the latter and the subsequent interaction with him on behalf of V.S. Pakhomov, international market services were offered to the client Borzenkov with knowingly invalid conditions.
This concerned both the reliability and return of his funds, including their insurance, return on invested capital and other conditions.
In addition to the standard international market contract, the client Borzenkov was offered personalised contract terms by Kirill Sobolev on behalf of Pakhomov V.S. in terms of returns to other accounts of Borzenkov and his companies, capital protection terms, and income.
When receiving funds from the client, Kirill Sobolev negotiated with him according to the instructions and terms mentioned above from Pakhomov V.S. (according to Sobolev's words).
Subsequent, direct communication between Pakhomov V.S. and the client Borzenkov could occur at his (the client's) repeated expansion of the volume of invested funds and at difficulties with withdrawing these funds and lengthy claims work.
After the contract with Borzenkov, communication was directly Borzenkov with Kirill Sobolev; he (Sobolev) personally confirmed this fact to him and established the fact of receiving instructions from Vladimir Pakhomov.
Roman Shpakov notified him (Z.V. Munayev) about subsequent cooperation with Borzenkov on the part of Vladimir Pakhomov.
Moreover, in oral face-to-face and telephone conversations (his and Pakhomov's), they repeatedly discussed the existence of such a client and the stages of problematic negotiations with him.
He (Munaev Z.V.) did not make any decisions on this client, but he is aware that Shpakov R.V. gave personal instructions to Pakhomov V.S. on all stages of interaction with this client.
This client does not belong to the Moscow office of the company but is a client of the Ekaterinburg branch network.
The fact of problematic negotiations is available in telephone correspondence with the word "Borz".
He insists on his testimony in this part.
The role of Pakhomov V.S. in the case of the beginning of claim activity in the part of the return of earlier deposited money of clients consisted in the following: in branches of a group of companies "QBF" under the direction of Pakhomov V.S. the system of claim work with clients, at which the term of withdrawal of their investments exceeded conditions of the contract, was introduced.
This system included requesting an excessive and redundant list of documents that lengthened the period of withdrawal of funds due to the long preparation of these documents by clients and the impossibility of preparing some documents in principle.
Pakhomov V.S. communicated this system to branch managers.
The managers trained staff on the system, regulated their work, and the staff ensured that the information was communicated to clients.
In addition to the source of funds and housing and utilities certificates, there were also requests for letters of recommendation from banks, lawyers, sources of other income of clients, availability of alternative identity documents, certificates in English and others.
This request was sent to the clients to the company's employees to formally send the documents received from them to the international back office for submission to the sending banks.
Still, these requests and the whole procedure considerably lengthened the withdrawal of funds due to delaying the entire process.

(Vol. No. 306, pp. 222 - 233)

Testimony of E.A. Rossieva, given to her as a witness, as a suspect, as well as in the capacity of the accused, according to which she did not admit guilt in the incriminated crimes and explained that she has no permanent registration on the territory of the Russian Federation, she has been living since about 2014 on temporary registration at the address: Moscow, Udaltsova Street, 4, sq. 230.

She (E.A. Rossieva) moved to Moscow in September 2005.
In 2001, she (E.A. Rossieva) graduated from Krasnoyarsk State University with a law degree; in 1996, she graduated from Krasnoyarsk State University with a degree in applied mathematics.
She (E.A. Rossieva) received her second higher education as an evening student.
Since 1996, she has worked as a civil law relations lawyer in various organisations.
She studied English and improved her professional qualifications, attending corporate lawyer courses at M - Logos.
In the summer of 2017, she was oﬀicially employed at QBF JSC as a lawyer.
Her duties included legal support of QBF's investment and management company in terms of professional activities on the securities market, as well as support of other civil law activities.
In 2017, the company's general director was R.V. Shpakov.
Her (E.A. Rossieva) direct supervisors were, from 2017 onwards, S.A. Matyukhin, General Director of QBIF Investment Company LLC, and Y.G. Smirnova, General Director of QBIF Asset Management LLC.
She was instructed by R.V. Shpakov, General Director, to issue legal opinions on civil law matters. In 2018, the employees of QBef JSC resigned due to the commencement of the organisation's liquidation including her.
In 2019, QBF was liquidated for corporate reasons.
Since January 2018, she (Rossieva E.A.) has been employed as a lawyer in the JSC QBF Financial Group, the leading company related to IK QBF LLC and KBF UA LLC.
Her (E.A. Rossieva) primary responsibility was legal support of IC QBF LLC and CBF UA LLC on professional activities on the securities market, asset management activities, contractual work, claims and litigation. The General Director of JSC Financial Group QBF is R.V. Shpakov.
JSC Financial Group QBF's direct managers were also S.A. Matyukhin and Ya.G. Smirnova.
The proxy representatives of QB Capital LTD were citizens of the Russian Federation.
The place of legal and actual registration address of QB Capital LTD is Cyprus; she does not remember the exact address.
The main activity of QB Capital LTD was to provide Russian clients with access to international financial markets in order to profit from trading in securities on foreign markets.
She has no information about QB Capital LTD's licences for brokerage and investment activities issued by the Cyprus regulator, but according to the information available to her, these activities did not require a licence.
As it follows from the civil law contracts sent by QB Capital LTD's former clients to the investment company as annexes to the claims, QB Capital LTD was not engaged in brokerage activities.
Gorobets, whose name and patronymic she (Rossieva E.A.) does not remember, was the general director of QB Group LLC and QBF UA LLC.
She (E.A. Rossieva) had known Gorobets personally since 2017 when they visited a notary together to register corporate actions.
Vladimir Georgievich Frolov was the general director of QBF UA IC LLC from 2012 to 2014 until mid-summer 2017.
After Frolov V.G., Matyukhin S.A. was hired as the General Director of LLC IC QBF.
After the dismissal of Frolov V.G., she (Rossieva E.A.) repeatedly communicated with him on working issues.
She selected the company "Yurmaster" LLC at the request of foreign consultants, who were engaged in support of civil law transfer of contracts concluded with clients to QB Capital LTD, namely for legal reasons, in connection with the requirement of the Cypriot regulator, according to which the transfer of contracts concluded with clients to QB Capital LTD should be made through the Russian structure, because part of the clients are Russian citizens, with the subsequent submission of a report to the Cypriot regulator.
She (E.A. Rossieva) was responsible for financial settlements with some of the counterparties under the concluded contracts.
She has yet to discover the reasons for the liquidation of QB Capital LTD.
The clients' funds were not transferred; QB Capital LTD transferred the rights of access to the funds when transferring the contract.
As explained to her, such a transfer under Cypriot law did not require the client's consent. Clients were notified of the transfer of contracts to another company by signature.
The clients who provided funds to QB Capital LTD were provided with documents for re-signing with "White Lake", which were executed according to the dates of legal transfer of contracts, about which the clients were notified by signature.
The representatives under the power of attorney of "White Lake" were Russian citizens whose data she (E.A. Rossieva) saw in the documents but she cannot remember.
The address of registration of the company "White Lake" is Caymans. She does not remember the exact address but saw it in the clients' documents.
The company "White Lake" provides services on trust management of assets of individuals and legal entities.
She cannot list the licences of "White Lake" issued by the regulator, but the reference to the licence is indicated in the civil law contract with the client.
Brokerage and investment activities are licensed under Russian law, and asset management activities are authorised under Cayman law.
White Lake has a business representative in the territory of the Russian Federation, namely VL Consulting LLC.
She (E.A. Rossieva) is personally acquainted with the former CEO of VL Consulting LLC, Nikolay Padalko.
A client of the Kyubi group of companies who wished to participate in trading on international stock markets, where White Lake participated, was provided with an asset management agreement with an investment declaration attached.
The following persons at Kyubi Group of Companies performed the following duties:
Ruslan Valeryevich Spinka - former employee of QBIF LLC, sales manager of the agency company K - Investment LLC;
Grigor Razmikovich Erzikyan - employee of the agency company K - Investment LLC;
Nikolay Sergeyevich Padalko - former general director of VL - Consulting LLC, business representative of White Lake;
Yuri Nikolayevich Orlov - manager of QBroker LLC;
Amerov Rinat Feliksovich - Head of work with banks and partners, General Director of JSC "Marketplace My Finance";
Plitin Vladislav Olegovich - Financial Advisor of K - Investment agency company;
Korzh Andrey Vasilievich - Head of Sales of K - Investment;
Zaitseva Yulia Sergeevna - Financial Advisor of K - Investment agency company;
Meshkova Daria Yurievna - financial advisor;
Frolov Vladimir Georgievich - former General Director of QBIF LLC;
Pakhomov Vladimir Sergeevich - former member of QB Group LLC, works in the regions;
Yudin Maxim Stanislavovich - former financial advisor of QBIF LLC sales department;
Shpakov Roman Valeryevich - General Director and shareholder of JSC Financial Group QBF;
Munaev Zelimkhan Visaitovich - former participant of QBF Group LLC;
Matyukhin Stanislav Anatolievich - General Director of QBF IK LLC;
Gorobets Elena Vyacheslavovna - General Director of QBF Group LLC;
Lepeshkin Dmitry Sergeevich - former partner of Shpakov R. V.В.;
Athanasiadou Linda – auditor of a Cyprus consulting company "NOA";
Vlasov Pavel Yurievich - financial advisor at K-Investment LLC;
Sobolev Kirill Sergeevich - former director of the branch in Yekaterinburg;
Golubev Alexey Sergeevich is an employee of an agency company in the city.
Yaroslava Gennadyevna Smirnova, General Director of KBF UA LLC;
Yuri Vasilyevich Shaban, General Director and shareholder of Rif JSC;
Roman Valeryevich Feoktistov, Director of QBF LLC;
Alexander Fedorovich Vozhzhov, marketing specialist;
Ekaterina Yuryevna Kozyreva, specialist of K - Consulting's department for work with banks;
Ekaterina Nikolaevna Kharina - Director of Investment Products Department of F - Experts;
Elena Anatolievna Grabareva - former employee of one of the agency companies for work with partners;
Oleg Yuryevich Timokhin - Head of BEC oﬀice of QBIF LLC;

(Vol. No. 290, pp. 1 - 2, 11 - 22, 29 - 42, 61 - 71, 160 - 162, Vol. No. 291, pp. 109 - 113, Vol. No. 293, pp. 173 - 177, Vol. No. 340, pp. 70 - 73)

The testimony of Pakhomov V.S., given by him as a witness, suspect, as well as accused, according to which he did not admit guilt in the incriminated crimes and showed that he graduated in 2013 from the St. Petersburg State University of State and Management with a degree in finance and credit from St. Petersburg State University of State and Management, specialising in finance and credit.

Subsequently he received qualification certificates from the FFMS - Central Bank of Russia certificates: basic, 1.0, 5.0.
In 2009, he got a job at Qube Finance, whose office was located on Presnenskaya Embankment, BC Tropikana, Moscow.
He does not remember the position in which he was employed. The organisation was a licensed investment company and had three licences issued by the Central Bank of Russia.
His job description included the selection of a base for phone calls. The leaders of the organisation were three shareholders: Sergey Lvovich Kuzin, Nikolay Modin and Roman Shpakov, who founded the company and opened the first oﬀice.
As far as he knows, the company had about 6000 clients in all directions, including partnerships with banks. He met Roman Shpakov about 4 - 6 months after he started working for the company.
They maintained a working relationship, and he oﬀered him (Pakhomov V.S.) to buy a stake in the company.
Sometime later, around 2011, he (V.S. Pakhomov) was appointed to this organisation as a deputy director for one of the company's areas.
His duties included the selection of premises for the opening of company oﬀices in various cities of the Russian Federation, communication with contractors, and general analysis of competitors in the cities where oﬀices were to be opened.
Around 2013, Shpakov Roman finally bought out the shares of the other two shareholders; he (Pakhomov V.S.) did not know why they left, and later, both opened their own companies.
At the general meeting, Shpakov Roman announced that he was ready to sell shares to the management in instalments of up to 9.99%, explaining that more than 10% had to be approved by the Central Bank of Russia, and this required a large set of documents, to get a package of more than 10% or equal to 10% of the company had to submit a candidate for approval to the Central Bank of Russia with a lot of requirements for reputation and proven income.
Around 2008, together with his mother, Likhina Elena Stanislavovna, he (Pakhomov V.S.) sold his flat; he still had some savings, so he thought about buying a part of the company, as he considered it a good investment.
They agreed with Roman Shpakov that he (V.S. Pakhomov) would buy 6% in instalments for 5 years. He (V.S. Pakhomov) had a desire to see how the company was developing and did not want to spend all the funds.
They went to a notary on Presnenskaya Embankment and signed a DCP (sale and purchase agreement).
He ceased to be a shareholder in 2018, selling his share back to the company. Until 2014, the organisation where he worked was called QB Finance Ltd; after renaming around 2014, the company became QBIF Investment Company Ltd.
In mid-2012, QBF decided to open a branch in St. Petersburg, for which purpose he (V.S. Pakhomov) selected premises at the address: St. Petersburg, Maloohtinsky Prospekt, v.64. 64.
He also took part in the technical opening of branches of QBIF LLC in other cities.
He may have been present at the oﬀicial opening of some branches organised by the marketing department of QBIF Ltd.
He worked in the said position until 2016 or 2017 (I can't remember exactly).
In 2016 or 2017, he left the said company and worked for another organisation.
After a break of about 8 months at QBIF Ltd, he returned to the said organisation and started working as a Development Director.
His job responsibilities included analysing the competitor market.
His immediate supervisor was the CEO - in 2016, it was Frolov, and in 2017, he (Frolov) was replaced by Matyukhin Stanislav Anatolievich. Matyukhin has a lot of experience, having worked for several years at Uralsib Management Company and about 6 - 7 years at the Central Bank of Russia in the FSFM division - licence and certificate issuing activities.
He (Pakhomov V.S.) had a small group of analysts under him, who were constantly changing, as well as technical staﬀ who were engaged in consolidating information into a single table - as a rule; it was one person.
He left the company in 2018, leading small projects not directly related to the company's operations but related to some clients who worked there.
The projects involved developing financial models that were not related to investment activities. In 2018, he (V.S. Pakhomov) resigned from QBIF LLC at his own request, after which he moved to St. Petersburg for permanent residence, and there he advised persons on matters not related to investment activities.
In November- December 2020, he took a job as Managing Director at LLC Berezka, a chain of dental clinics in the Moscow region.
The position involved travelling to other cities, and in fact, he lived in St. Petersburg. Previously, he (V.S. Pakhomov) had powers of attorney from LLC IK QBF, but he does not remember which ones.
He is not familiar with the directors and shareholders of White Lake Management Ltd, QBMF LLC, QB CAPITAL LTD, Simtelligence Company Limited, VL Consulting LLC, and WLM Ltd, but he has heard about some of these companies.
At different periods of time, while he was working in the company "QB IC" LLC, he (Pakhomov V.S.) could be approached by acquaintances and acquaintances of acquaintances who knew that he worked in the investment company as a director for strategic development and knew that his tasks included studying the market conditions and investment products of the company, so they wanted to get advice on investing money.
He could introduce investment advisors from diﬀerent investment companies, who in turn would work with the client.
He (Pakhomov V.S.) introduced his acquaintances to managers of different companies, and later, these clients concluded contracts and bought different investment products in different companies.
He went to diﬀerent investment forums, got acquainted with representatives of different investment companies and could introduce them to his clients.
He knows that there was a company "QB CAPITAL CY LTD" ("QCCI LTD"), which is actually and legally located in Cyprus, and IC QBIF had an agency agreement with "QB CAPITAL CY LTD" ("QCCI LTD") for a certain period of time.
The contract implied that the companies were to supply each other with clients, i.e., some sort of agency agreement for mutual interests.
As explained by the representative of the company who came to present products, the accounting support and administration of "QB CAPITAL CY LTD" originated from Cyprus.
The company provided agency services, and this organisation was headed by Kaznacheev Alexey, whom he (Pakhomov V.S.) had seen once in his life.
He (V.S. Pakhomov) knows that the company "Simtelligence Company Limited" is registered in Hong Kong.
The company similar to "White Lake Management Ltd." is familiar to him; it is registered in Cayman, and the company has a licence for professional investment activities.
In Russian companies, non-cash transfer of funds to clients is possible; cash was accepted at the client's request, who was given a cash warrant, and then this money was collected per the established procedure, which he (Pakhomov V.S.) does not know.
The procedure of receiving dividends by clients under the concluded contracts is described in each specific contract. Z.V. Munayev is familiar to him.
They got acquainted with him approximately in 2010 - 2011. He knows that Mr Munayev Z.V. came to QBF from an insurance company, as far as he remembers, it was called Reynisans.
Munaev Z.V. was engaged in customer service over the phone with higher education and FSFZ Basic 1.0 and AML/CFT certificates.
Since 2013, he has been a shareholder of IK QBF LLC.
He (V.S. Pakhomov) is familiar with A.S. Golubev.
As far as he knows, A.S. Golubev worked in LLC IC QBF as a director of the branch network. A.S. Golubev's task was to attract clients for the licensed company QBF LLC products.
A.S. Golubev was hired by S.A. Matyukhin, General Director of QBF LLC. He (V.S. Pakhomov) was introduced to A.V. Polezhaev by a mutual acquaintance whose details he does not remember.
A.V. Polezhaev asked for help in finding him (A.V. Polezhaev) oil products for delivery to the Republic of Kazakhstan. A.V. Polezhaev borrowed money from him (V.S. Pakhomov) many times for an amount he does not remember exactly.
He (Pakhomov V.S.) does not have any loan agreements or receipts on the transfer of funds to A.V. Polezhaev;

(Vol. No. 294, pp. 3 - 7, 17 - 19, 49 - 53, 88 - 90, 94 - 102, 112 - 115, 148 - 151, Vol. No.

295, pp. 205 - 213, 234 - 237, Vol. No. 297, pp. 247 - 249, Vol. No. 335, pp. 147 - 175)

Protocol of confrontation between the witness Pakhomov V.S. and the witness Polezhaev A.V., during which the witness Polezhaev A.V. explained that he knows Pakhomov V.S., who is one of the managers of QB Finance LLC (QBIF LLC).

He has known him since about 2012 and was introduced to him by Sergei Loginov, whom he has known for more than 15 years. was on friendly terms with him and had his own business.
Loginov introduced him (A.V. Polezhaev) to him in 2012 under the following circumstances: in 2012, he (Polezhaev, Sergei Loginov, Vladimir Pakhomov) met in a restaurant in Moscow.
The meeting implied his acquaintance with Pakhomov V.S., as earlier Loginov had told him that he (Loginov Sergey) had an acquaintance who accepted cash as an investment. He was interested in this proposal, as he had free cash at that time, as Pakhomov V.S. promised about 2 - 3 per cent of the deposited amount monthly in cash.
Also, an important fact of his trust in Pakhomov V.S. was that Loginov S. had also invested money earlier.
At the meeting, Pakhomov V.S. seemed to him to be a businessman who inspired confidence. Pakhomov told him how his business was organised, which was to attract people with free cash to invest in his business, namely by buying and selling securities and building apartment buildings.
Around April 2012, he met with Pakhomov at the Ukraina Hotel, where they agreed with him that he would hand over cash in the amount of $400,000 for the purpose of making a profit; they did not sign any documents. V.S. Pakhomov did not write a receipt for the receipt of the money.
About three months later, he received a phone call from Pakhomov V.S. asking if he still had cash, to which he replied that he did. Then, in early June 2012, Pakhomov came to the address 10 Birch Grove Drive, Moscow, where he (A.V. Polezhaev) was working at the time.
During the meeting, V.S. Pakhomov explained that it was necessary to invest more and reach USD 1,000,000, after which his interest would increase.
He was not embarrassed that they had not drawn up or signed any documentation, as a mutual acquaintance had introduced them. In the period from June 2012, Pakhomov V.S. personally paid him interest on the amount he had previously deposited, i.e. USD 600,000; the payments were made in cash.
All details were given to him by Pakhomov V.S. On 05.06.2012, Pakhomov V.S. called him and oﬀered him to invest additionally in the business project to conclude an agreement with a foreign company and to deposit additional funds in the amount of 1050,000 euros.
Pakhomov V.S. justified it by the fact that this is a new project, in which it is necessary to contribute more than 1 million dollars; it guarantees him (A.V. Polezhaev) a stable interest and return on the invested funds. After a brief deliberation, he agreed with this proposal.
He concluded an agreement with the Cyprus company "QB Capital CY LTD".
The contract was concluded on 05 June 2012. He signed this agreement while in the office of QB Capital CY LTD, located in the Moscow - City complex building, at the address: 8 Presnenskaya Naberezhnaya Embankment, bldg. 1, Moscow.
In this oﬀice he met Shpakov and Zelimkhan Munayev. Pakhomov introduced Munayev to him as the commercial director of Qubey Finance LLC and Shpakov as the deputy general director of Qubey Finance LLC.
V.S. Pakhomov explained to him that the Cyprus Company was an aﬀiliated company of Qubey Finance LLC.
Pakhomov V.S. informed him that the funds should be transferred to the settlement account of the Cyprus company.
.Further, Pakhomov V.S. informed him of the number of the settlement account, and he (Polezhaev A.S.), from his settlement account opened in a foreign bank in Germany, Berlin, transferred funds in the amount of 1,050,000 euros to the settlement account of the Cyprus company "QB Capital CY LTD".
At the signing of this agreement, Pakhomov V.S. was present; it was he who convinced him (Polezhaev V.S.) of the reliability of the transaction, and he also guaranteed him the return of the full amount and the interest due to him.
Pakhomov V.S. also guaranteed him the return of the full amount and the interest due to him (A.V. Polezhaev).
Also, Pakhomov V.S. explained to him that, in fact he had no risk of losing his funds, as the funds under clause 2.3 of the agreement were insured with the Federal Corporation for Protection of Rights of Interests within the framework of the system of compulsory deposit insurance.
After the lapse of time, he found out that there was no insurance.
Roman Valerievich Shpakov represented this criminal case from the side of "QB Capital CY LTD".
Also, at the signing of the contract on 05 June 2012 № 592 - 12/BP, an agreement was signed on the provision of "Trust management" services within the framework of the abovementioned contract.
In this agreement, the trustee on the territory of the Russian Federation was LLC "Qubey Finance" (INN 7733673955); Roman Valeryevich Shpakov also signed the agreement in person of the Commercial Director of this company.
In addition to this agreement, Annex "Trust Management" was signed, whereas from the side of LLC "Qubey Finance" was signed by Shpakov R.V.
During the period of time from 2012 to December 2018, he was paid money as interest for the use of his money provided to LLC "Qubey Finance" as an investment; these payments were inconsistent, with long intervals of time, sometimes for 8 months he was not paid.
All communication with him took place through Pakhomov V.S., sometimes Pakhomov V.S. transferred money personally, sometimes through persons unknown to him (A.V. Polezhaev), who were employees of LLC "Qubey Finance".
Several times, he also received money on his bank card from persons unknown to him, representing themselves as employees of the St. Petersburg branch of Qubey Finance LLC.
German colleagues informed him that "QB Capital CY LTD" is liquidated and does not conduct any financial activity.
Also, from the Republic of Cyprus, he was informed that "QB Capital CY LTD" on the territory of the Republic of Cyprus does not conduct any activity, is currently liquidated.
Around 2019, he had a meeting in the building of the complex "Moscow City", at the address: Moscow, Presnenskaya naberezhnaya, 8, page 1 between him and Munaev, Shpakov and Pakhomov.
At this meeting, it was decided to return him money in the amount of USD 200,000 for a period from 01 October 2019 until 01 November 2019 USD 200,000.
Starting from 01 December 2019, USD 15,000 each month for a total of USD 475,000 was returned to him, which was approximately 50% of the total amount of money he had invested.
He wrote a statement that he would have no claim after the above amount was transferred to him. In approximately October 2019, he received US$200,000 from Shpakov.
Later, he became aware of Aslambek, who was the brother of Munaev Zelimkhan, who said that he was related to Qyubi Finance LLC and was the supervisor of this company.
Aslambek then put forward the condition that he (A.V. Polezhaev) should transfer 200,000 USD to Aslambek as security for the project.
He called Shpakov and asked why Aslambek Munayev was demanding money from him, to which Shpakov replied that Aslambek had the right to negotiate within the framework of the investment project. It was Pakhomov V.S. who persuaded him to invest money in QB Finance (IK QBF LLC) and QB Capital CY LTD. V.S.
Pakhomov participated in all negotiations and promised to pay high interest.
He persuaded in every possible way to invest money in the development of the projects of the above companies. In 2017 - 2018, he (A.V. Polezhaev) learnt that there was no brokerage account in his name. It was then that he realised that he had become a victim of fraud;

(Vol. No. 294, pp. 8 - 12)

E.A. Rossieva - Pakhomov V.S and A.S. Golubev

Protocol of confrontation between the accused Pakhomov V.S. and the witness Rykov D.I., during which the witness Rykov D.I. fully confirmed the testimony previously given by him as a witness, namely, that in the group of companies "QBF" in Tyumen, he (Rykov D.I.) actually began his labour activity at the end of 2016 in the position of director of corporate business.

The group of companies includes QBIF LLC, QF EstateSPB LLC, KBF LLC, QCCI, QB Capital, White Lake Management, VL Consulting LLC, WLM, MC Asset Management and other companies, the names of which he does not remember.
In LLC QF "EstateSPB" in a certain period, dates he does not remember, the head was Pakhomov V.S., the head of LLC IC "QBF" was Matyukhin S., in "White Lake Management" Korshunov, in MC Asset Management Smirnova.
When the representative office in Tyumen was oﬀicially registered in 2017, he was employed as the director of the Tyumen branch of QBIF LLC. In fact, he worked in QBF Group until March 2020, but was oﬀicially dismissed only in April 2021.
He continued to work in QBF IK LLC until April 2021, while he carried out his activities until March 2020 at the request of Pakhomov V.S., explaining that in case of a change of the head of any branch of the Investment Company, the Central Bank of Russia will conduct an inspection of the company. This fact is "inconvenient" for it (the company).
In view of this, he complied with V.S. Pakhomov's request not to write a resignation letter.
Since March 2020, he has not worked in the Tyumen branch; he resigned at his own request due to the aggravated situation on the withdrawal and return of funds of his clients, the emergence of distrust in the management and shareholders of the group of companies "QBF".
His responsibilities included managing the Tyumen branch, representing the company's interests in Tyumen, searching for and hiring employees, conducting marketing activities in the Tyumen region, attracting clients and negotiating with them, and organising the point of sale.
Interaction was with the office located in St. Petersburg (regional centre) and the central office in Moscow.
From the beginning of his labour activity and until his (D.I. Rykov) dismissal from the Company, his (D.I. Rykov) manager was V.S. Pakhomov.
Subsequently, part of the functions of company management in terms of regional oﬀices was transferred to A.S. Golubev, and this was due to the fact that V.S. Pakhomov switched to work in the head office in Moscow, where he was engaged in the development of the entire group of companies "QBF".
Nevertheless, the final decision - making on all key issues continued to remain with V.S. Pakhomov. As R.V. Shpakov told him (D.I. Rykov) during the meeting in 2016, V.S. Pakhomov, together with Zelimkhan Munayev, was a co-owner, i.e. a shareholder of the QBF Group of Companies.
According to R.V. Shpakov, he (R.V. Shpakov), together with V.S. Pakhomov and Z. Munayev are partners.
This information was communicated to him (D.I. Rykov), managers and employees of other branches in the cities of Kaliningrad, St. Petersburg and Yekaterinburg.
Shpakov R.V. informed him (Rykov D.I.) that Pakhomov V.S. was the director of the branch network and that any questions concerning the activities of the branch network should be addressed to Pakhomov V.S. Interaction between Pakhomov V.S. and him (Rykov D.I.) took place through personal meetings. Both Pakhomov V.S. came to the Tyumen oﬀice and he (Rykov D.I.) to the central oﬀice in Moscow.
Interaction was also carried out through telephone conversations and messengers.
From the beginning of the Tyumen branch activity, the main priority, which was set before the branch by the direct head of Pakhomov V.S., was directed to foreign markets.
This direction was positioned by the branch staﬀ as a strong point of QBF Group's work, that it is this direction that is interesting for a potential client.
Initially, all the information about the products of QBF Group of Companies and the company's opportunities was communicated to the employees in the Tyumen branch, as well as in other branches, by Pakhomov V.S.
The decision on the possibility of concluding a deal with a potential client, on the format of the deal (cash/non-cash) was made by the head of the regional network Pakhomov V.S. by means of verbal negotiations and messages in messengers.
Pakhomov V.S. organised interaction of functional divisions of the group of companies with the branch in Tyumen to conclude transactions: back oﬀice, preparation of contracts.
In the case of cash transactions, Pakhomov V.S. organised cash collection from the branch to the regional centre of the company in St. Petersburg and the head office in Moscow.
As far as he (D.I. Rykov) was aware, Whitelake Management, a company registered in the Cayman Islands, held a licence to conduct brokerage activities.
Qubicapital" and "Quesiai" did not have such licences and, according to Pakhomov V.S., were not required to perform the function assigned to these companies.
These companies provided access to clients to place funds on international markets by opening a trading account.
There were instances when Pakhomov V.S. personally collected cash from the Tyumen branch.
One such case took place on 21.08.2019; cash in the amount of 15,000,000 rubles in front of witnesses Chupin I.A., Ignatov Alexander Konstantinovich was transferred by him (Rykov D.I.) to Pakhomov V.S. after concluding a transaction with the client financial advisor Chupin I.A.
The money was encashed to Moscow, the company's cash office.
In January 2017, V.S. Pakhomov presented him (D.I. Rykov) to him (D.I. Rykov).
The cash centre of QBF's head office in Moscow was a room with a money recalculation machine in it.
He (D.I. Rykov) was shown cash-in-transit orders, the order appointing Gorobets as the company's chief accountant and assigning her (Gorobets) the functions of a cashier.
Pakhomov V.S. told about the possibility of concluding transactions with clients with cash payment. During the period from 2017 to 2019, Pakhomov V.S. personally encashed cash more than 5 times.
The other instances of encashment were organised by Pakhomov V.S. and after 2018.
Cash collection was also organised by Yuri Orlov, Vladimir Maslennikov, Maxim Fedorov, Avetis Vartanov, Kirill Sobolev, Kirill Bogdanov, and A.S. Golubev.
Cash collection from the Tyumen branch to Moscow and St. Petersburg was not formalised in any way. After receiving cash from clients, the financial adviser who accepted the cash placed it for temporary storage in the safe of the head of the office.
Accordingly, the regional office in St. Petersburg already knew about the receipt of cash. After that, he (D.I. Rykov) received a message from the management of this oﬀice, depending on the period of time, from V.S. Pakhomov or A.S. Golubev, in 90% of cases in messenger Vatsap about which of the employees would come to collect the cash.
Upon arrival of the courier, the money was handed over to the courier, and the courier collected it.
No powers of attorney or transfer acts were drawn up when the money was handed over, as he (D.I. Rykov) was following the instructions of his superior.
Upon receipt of funds, after encashment, the back office notified the Tyumen oﬀice, as well as other branches, about the receipt of encashed funds.
He (D.I. Rykov) was aware of cash payments to previously invested clients as dividends at the expense of funds from new clients.
On A.S. Golubev's instruction, a part of the funds was paid to the client Y.A. Pisarev with funds received from a new client.
As Golubev A.S. explained, this was necessary to optimise the logistics costs of transporting cash.
This issue, according to A.S. Golubev, was agreed upon with V.S. Pakhomov.
The use of funds inappropriately was made 2 times on Golubev's order. In the second case, salaries were given to employees of the Tyumen branch.
Golubev explained to him (D.I. Rykov) that the money would be transferred to the client's trading accounts from the accounts of the QBF group of companies through mutual settlements between the companies;

(Vol. No. 294, pp. 175 - 184)

Protocol of confrontation between the accused Pakhomov V.S. and the witness Chupin I.A., during which the witness Chupin I.A. fully confirmed his earlier testimony as a witness, namely, that in May 2017 in Tyumen, he (Chupin I.A.), Rykov D. and Pakhomov V. were interviewed about his (Chupin I.A.) employment in the branch of QBF company in Tyumen.

Pakhomov V.S. introduced himself as a co-owner of QBF responsible for the regional network.
In June 2017, he (I.A. Chupin) started working as the Head of the Investment Services Department of LLC KF Estate SPB in Tyumen.
He worked under a service contract for about six months during the probation period.
In January 2018, he continued working in the same position, but already under the employment contract concluded with him.
The agreement on his employment was signed on behalf of V.S. Pakhomov, CEO of LLC KF Estate SPB.
In March 2021, he (I.A. Chupin) was dismissed from OOO KF Estate SPB and employed by OOO IK QBF as director of the Tyumen branch. At that time, the former director of the company, D.I. Rykov, resigned from the company, and he (I.A. Chupin) replaced him.
From 2017 until March 2021, his direct supervisor was the director of the Tyumen branch, Rykov D. According to the organised structure; his next supervisor was Pakhomov V.S.
His (Chupin I.A.) duties as the head of the investment services department of LLC KF Estate SPB included implementation of the sales plan, working with personnel, and working with clients.
As the Head of the Tyumen branch of QBIF LLC, his duties included the same duties as in his previous position, only the duties related to the Tyumen oﬀice as a whole. In addition, he was responsible for the organisation of interaction with the regional centre in St. Petersburg.
He was in direct contact with Pakhomov V.S. at joint meetings, communication with the Tyumen oﬀice staﬀ when Pakhomov V.S. came there approximately once a quarter, as well as at meetings in the regional centre in St. Petersburg.
The QBF brand ("QBF"), as the Tyumen oﬀice positioned it during training and presentations, included more than ten companies. Of these, he remembers QBF IK LLC, QBF Asset Management LLC, QCCI Ltd, White Lake Management Ltd, WLM, SIMTELLIGENCE COMPANY LIMITED, QBF Advisers LLC, QBF Advisory LLC, VL - Consulting LLC.
The group of companies included both Russian and foreign companies.
Also, construction companies were associated with the QBF group of companies, i.e. QBF brand during the training seminars, of which he remembers M1 Development LLC, Simon Jesso LLC.
More companies related to construction were mentioned, but he does not remember their names.
Pakhomov V.S. made final decisions on the employment of employees of the branch network and, in particular, the sales department entrusted to him (Chupin I.A.), personally coordinated all financial expenses related to the activity of the Tyumen branch - from consumables to purchase of expensive oﬀice equipment, as well as marketing expenses.
Pakhomov V. constantly monitored the fulfilment of its targets by the Tyumen branch and communicated with the head of the Tyumen branch and with him (Chupin I.A.) as the head of the department and ordinary financial advisors. V.S. Pakhomov had the broadest decision-making authority in the branch network.
He (I.A. Chupin) and D. Rykov gained experience in the investment sphere, including qualification certificates, while working in the Tyumen office, learning during their employment with this company, including in the course of training sessions conducted by V. Pakhomov and employees of the central (Moscow) oﬀice of the company.
The salaries of the branch employees, including the management staff, were fixed by the career model approved by the central oﬀice and the regional network management thus the motivation of remuneration was approved, which implies payment of bonuses based on the results of the plan fulfilment.
The Tyumen branch, 90 per cent of the time, did not fulfil the basic criteria, so the branch employees did not receive quarterly bonuses but were satisfied with only a monthly salary.
As explained to him (Chupin I.A.) by Golubev A.S., the amount of the unpaid bonus was distributed among the co-owners of the company, to whom he (Chupin I.A.) refers Pakhomov V.S., Munayev Z.V. and Shpakov R.V.
The Tyumen branch was only a separate subdivision in a particular territory.
Therefore, it was obliged to comply with the regulations prescribed by the centre of the regional network in St. Petersburg and the central Moscow office.
There were cases of cash deposits by clients, which occurred only with foreign companies QCCI Ltd. or WLM.
About 90% of contracts with foreign companies were accepted in cash, both in roubles, euros and US dollars. Between 2017 and 2021, approximately RUB 400,000,000,000 - 450,000,000,000 was received in cash from customers in the Tyumen Branch in the rouble equivalent.
The cash was accepted from customers by the manager working with that customer.
The funds were then deposited in a safe located in the office of the director of the Tyumen branch.
The director of the Tyumen branch informed Golubev A.S. or Pakhomov V.S. by corporate email (before 2019 to Pakhomov V.S., after 2019 to Golubev A.S.) of the transaction, indicating the contract number, the client's full name and the amount of cash received.
Within 24 hours from the address of the heads mentioned above of the branch network received instruction on the procedure of cash collection, namely the data of an employee of the group of companies who were to come and pick up these funds for their transport to the central oﬀice of the company in Moscow or St. Petersburg.
These instructions could also be transmitted through correspondence in managers' calls to mobile or fixed (working) phones.
The money was handed over to the courier from hand to hand, without any authorisation from the courier, in the building of the Tyumen oﬀice.
The funds were handed over without any transfer or accompanying documents.
The funds were in the form in which the client had handed them over, either in a bank wrapper or tied with a rubber band.
The couriers transported the money in ordinary briefcases, bags, and backpacks.
Upon receipt of the cash, the client was given a receipt confirming receipt of the cash from the client, signed by representatives of QCCI Ltd. or WLM. From "QCCI Ltd." the receipts were signed by Gorobets E.V., from "WLM" by Korshunov D.A., representatives of these companies by power of attorney.
The Tyumen oﬀice received these receipts and customer contracts for the relevant product from the back oﬀice of the regional network in St. Petersburg.
He personally observed how cash was taken from the Tyumen oﬀice and subsequently encashed by Yuri Orlov, Vladimir Maslennikov, and Vladimir Pakhomov (on one occasion on 21.08.2019 in the amount of 15,000,000 rubles, received from the client Perevozkin V.V.), A. Golubev (1 time), Kirill Bogdanov, Avetis Vartanov.
He (I.A. Chupin) transported cash to the oﬀice in Tyumen about twice from the oﬀice in St. Petersburg by order of A.S. Golubev and once from the central oﬀice in Moscow by order of V.S. Pakhomov.
These funds were intended for cash dividend payments to clients of the Tyumen branch;

(Vol. No. 294, pp. 185 - 192)

E.A. Rossieva - Pakhomov V.S and A.S. Golubev

Testimony of A.S. Golubev, given by him as a witness, suspect, as the accused, according to which he did not admit guilt in the incriminated crimes and showed that he graduated from a higher educational institution in 2013 with a degree in "Engineer - technologist", "Engineer - designer".

Since 2 February 2015, he has worked in LLC "IK - QueBiEF" in the positions of junior financial advisor, financial advisor, senior financial advisor, deputy head of the investment services department, and since 2018, director of the branch of LLC "IK - QueBiEF" in St. Petersburg. In 2021, according to the entry in his labour book, he was dismissed at his own request, but in fact, he was dismissed due to the reduction of the company's costs at the initiative of S. Matyukhin, General Director of LLC IK QBEF. LLC IC QBF's regional branches were located in St. Petersburg, Kaliningrad, Yekaterinburg, Ufa, Murmansk, Tyumen, and Surgut.
His (A.S. Golubev) duties as a financial advisor included searching and attracting clients for investment services and financial counselling of clients.
In 2016, he had a power of attorney to represent the interests of a foreign company registered outside the Russian Federation, which he does not remember.
Also, in the period from 2018, he represented the interests under the power of attorney and was a signatory on behalf of IK QBF LLC.
The legal and actual address of registration of QB Capital LTD is Cyprus; the main activity is capital management.
The company has no licences for brokerage and investment activities.
He became aware of this fact after the closure of QB Capital LTD in 2017 - 2018, after studying the regulator's website.
In 2015, he (A.S. Golubev) represented QB Capital LTD's interests in the Russian Federation's territory.
The following documents were provided to the QB Group of Companies client who wished to participate in trading on international stock markets: an agreement on providing access to the securities market a trust management agreement.
In 2015, the trust management agreement was drawn up on behalf of IK QBEEF LLC.
Legal and actual registration addresses of "White Lake Management Ltd." - Cayman Islands, the company's main activity - asset management, trust management services.
About the company "SIMTELLIGENCE COMPANY LIMITED" he knows that the actual and legal address of registration was in Hong Kong.
He also knows that "QCCI Ltd." has actual and legal addresses of registration in Cyprus; the main activity of the company is the provision of trust management services.
He learned about the absence of licences for brokerage and investment activities at "QCCI Ltd." on the regulator's website when the company was liquidated.
A client of QCCI Ltd. who wished to participate in trading on international stock markets was provided with an agreement on providing access to the securities market and a trust management agreement.
In 2015, the trust management agreement was concluded with Qubi Finance.
The following persons worked in the Kyubi group of companies. Vladimir Sergeyevich Pakhomov was a beneficiary (shareholder) of the company LLC "IC QBEEF"; in fact, he (V.S. Pakhomov), in the Q1 - 2 quarters of 2015, managed the St. Petersburg branch of LLC "IC QBEEF", which is located in the address: St. Petersburg, Degtyarny pereulok, ul. 1 lit. "B" (in 2015, the branch was located at St. Petersburg, Maloohtinsky Prospekt, ul. 64).
Further, in approximately 2019, V.S. Pakhomov was appointed Director of Strategic Development of IK Qubief LLC in the Russian Federation.
At present, V.S. Pakhomov does not hold any position in IK QBEEF LLC. However, he appears from time to time at the office of the City of. St. Petersburg.
In 2015, he (Golubev AS.) was in the position of Junior Advisor of IK QBEF LLC and carried out instructions of his immediate superior - Kisin G.V., who held the position of Deputy Head of the Investment Services Department.
Later, he (A.S. Golubev) was in direct contact with V.S. Pakhomov when he (V.S. Pakhomov) held the position of Director of Strategic Development of IC QB&EF LLC in the territory of the Russian Federation.
At that time, he (A.S. Golubev) was the director of the company's office in St. Petersburg.
They (A.S. Golubev and V.S. Pakhomov) had periodic meetings in St. Petersburg and Moscow, where V.S. Pakhomov consulted with him (A.S. Golubev) and set tasks for expansion of the company's branches in other cities on the territory of the Russian Federation, discussed issues of the order of opening of the company's oﬀices, marketing issues, strategy of development of the company's branch network.
Roman Valeryevich Shpakov has been the main beneficiary (shareholder) of the company "Qubief" since about 2010 up to the present time.
Athanasiadou Linda has no relation to the Russian organisations of the company "Kyubey"; he (A.S. Golubev) directly received consultations from her on opening bank accounts in foreign banks, which took place at a personal meeting in Moscow and in email correspondence.
Athanasiadou Linda's workplace is in Cyprus.
Munaev Zelimkhan Visaitovich was one of the beneficiaries of QB Finance Ltd.
Ruslan Valeryevich Spinka is known to him as the person responsible for the sales of IK - QBF LLC in Moscow.
Nikolai Sergeyevich Padalko is an employee of the Moscow office of a QBi company.
Yuri Nikolayevich Orlov is an IT specialist in computer maintenance at the company.
Rinat Feliksovich Amerov was engaged in partnership programmes with banks in Russia in the period from 2019 to 2020.
Andrey Vasilyevich Korzh was responsible for sales in Moscow.
He (A.S. Golubev) was in contact with A.V. Korzh on products of IK QBEF LLC in approximately 2020; the communication took place via email.
Yulia Sergeevna Zaitseva was engaged in sales of the company's products in Moscow in approximately 2018. Vladimir Georgievich Frolov worked as CEO of QB Finance Ltd.
Maksim Stanislavovich Yudin was a financial advisor of one of the QBi group of companies in 2015 - 2017.
He (A.S. Golubev) was in contact with M.S. Yudin on trust management products of IK - QBF LLC in 2017.
Matyukhin Stanislav Anatolievich was the CEO of IK - QBF LLC from around 2018.
He (Matyukhin S.A.) is his (Golubev A.S.) direct supervisor. S.A. Matyukhin's workplace is located in Moscow in the central office of LLC "IR - QBF".
Evgenia Anatolievna Rossieva is known to him as a lawyer of the company.
Dmitry Sergeevich Lepeshkin is an employee of M1 Development and works with real estate.
Elena Vyacheslavovna Gorobets is known to him from the company documents as an accountant.
Pavel Yuryevich Vlasov is a financial advisor of one of the company's groups with a workplace in Moscow.
Kirill Sergeyevich Sobolev, Director of the branch in Ekaterinburg, worked until 2017 - 2018 in the company PA "IK - QBF".
Yaroslava Gennadyevna Smirnova is the General Director of LLC "MC QBef. Asset Management".
Yuri Vasilyevich Shaban was engaged in real estate. Ekaterina Nikolaevna Kharina is a product specialist at LLC "IC QBIF", working in the company since about 2019.
Oleg Yuryevich Timokhin is an employee of LLC "IC QBIF.
He (A.S. Golubev) met I.A. Borzenkov in Ekaterinburg on the issue of creating a fund.
At the meeting, he (I.A. Borzenkov) said that he (I.A. Borzenkov) was interested in bonds, and he (I.A. Borzenkov) had the task of accepting capital abroad.
He (A.S. Golubev) drew I.A. Borzenkov's attention to such an instrument as a personal investment fund.
Borzenkov I.A. asked him (Golubev A.S.) to prepare information about this instrument, and he (Golubev A.S.) collected and sent this information to Borzenkov I.A. by e-mail.
Later on, he (A.S. Golubev) and B.G. Pechersky met him (A.S. Golubev) in Kaliningrad in about 2017 and discussed his (B.G. Pechersky's) assistance in opening an oﬀice of IK - QBF LLC in Kaliningrad.
B.G. Pechersky gave him (A.S. Golubev) recommendations on who to meet in the city in terms of potential clients and partners.
He (A.S. Golubev) was introduced to B.G. Pechersky by S.N. Blik, who was the head of the oﬀice in Kaliningrad, introducing B.G. Pechersky as an influential person in Kaliningrad.
The regional office in Kaliningrad was located in the building of a business centre, the address of which he does not remember.
Meetings with clients took place either in the office of OOO IC QBF or, at the client's request, in a restaurant.
Sometimes, meetings took place at the client's place of work or at the client's (client's) place of residence.
The meeting places were always agreed upon with the client.
He (A.S. Golubev) personally received cash from the client "hand-to-hand" once in St. Petersburg from a client named Egudkin.
Sergei Blik, director of the OOO IC QBF branch office, received cash from the company's clients in Kaliningrad.
About three times, he (A.S. Golubev) transported cash from Blik S. to St. Petersburg.
The client was given a cash-in-transit order due to the cash transfer.
The order had a number and was part of a standard trust management agreement concluded with the client.
All documents of the standard agreement were scanned, and scans were sent to the mail of the companies with which the agreements were concluded.
In the corporate programme "ECRM", the data on receipt of money from the client were entered.
The facts mentioned above of receipt of money from clients by him (A.S. Golubev) concerned a company located in the Cayman Islands. Subsequently, from St. Petersburg, the cash from the clients mentioned above was sent by courier to Moscow.
The couriers arrived after the information about the concluded transactions was sent by e-mail to the Cyprus company "QB Capital (QCCI)" or "WL Management LTD" (Cayman Islands).
The money was handed over to the visiting couriers after they voiced a verbal password.
Several instances of money were being handed over when the courier provided a written power of attorney.
The verbal passwords were sent to him by S.A. Matyukhin or R.V. Shpakov in Telegram messenger.
Sometimes, the passwords came from unknown numbers, but the subscribers' numbers were confirmed by emails from QB Capital (QCCI) or WL Management LND;

(Vol. No. 298, pp. 1 - 16, 32 - 33, 39 - 43, 64 - 69, 101 - 104, Vol. No. 299, pp. 155 - 161, Vol. No. 301, pp. 222 - 226, Vol. No. 347, 106 - 109)

Protocol of confrontation between the accused A.S. Golubev and the witness D.I. Rykov, during which the witness D.I. Rykov fully confirmed the testimony previously given by him as a witness, namely, that in LLC IC QBF he was oﬀicially the director of the branch oﬀice in Tyumen from July 2017 to 1 April 2020.

Until 2019, his manager was Pakhomov V., who organised the branch office in Tyumen; he (Pakhomov V.) also employed him (Rykov D.I.).
Around the end of 2018 and the beginning of 2019, he (D.I. Rykov) learned from V.S. Pakhomov that A. Golubev would head the regional office. S., and from that moment, he was already subordinate to the latter.
During the operation of the Tyumen oﬀice, he personally addressed A. Golubev on all issues related to the Company's activities since mid-2018. He received answers from him (A.S. Golubev), namely, issues of concluding and closing transactions, structuring transactions, legal matters of registration, KPI issues, staﬀ motivation and other issues.
A.S. Golubev's duties included setting planned tasks for the branch, operational management of the branch network, control over the implementation of plans to attract clients, training of staﬀ (including new employees), organisation of contacts with specialists of QBF Group on issues arising in the course of operations.
In 2017. QBEF IK LLC worked in "liaison" with QB Capital in the Republic of Cyprus.
At the end of 2017, it became known that QBi Capital was liquidated, and its legal successor was Qusisiai.
Munaev Zelimkhan communicated this information in the course of communication via VCS (video conferencing communication).
Later on, there appeared another group of companies: Whitelake Management, Simtelligence and several functional companies (VLM, VL Consulting), performing a specific function in the chain of interaction between the client on the territory of the Russian Federation, transfer of funds abroad and management of these funds by QBF Group.
He needed to find out whether or not QB Capital had any licences.
QCF did not have a licence to carry out brokerage activities and, according to the information of the employees of the oﬀices in Moscow and St. Petersburg, did not need such a licence, as the company was merely acting as an agent for the placement of clients' funds abroad.
In general, information on the presence or absence of licences of companies outside the Russian jurisdiction was communicated by the management of the head office and regional centre through electronic correspondence, information on network discs and as part of training procedures (in-person and remote).
He is aware of cases of cash deposits by clients.
The majority of clients' funds received in cash were accepted by financial advisors and kept in a safe at the Tyumen regional office.
Upon receiving cash from them, clients were given a cash-in-transit order executed on behalf of foreign companies: QCB Capital, QCI, and VLM.
During the branch's operation, approximately 300 - 400 million roubles were received from clients in cash.
The money was taken from the Tyumen oﬀice by employees of oﬀices in Moscow and St. Petersburg.
Of these employees, he remembers Yuri Orlov, Maxim Fedorov, Vladimir Maslennikov, V.S. Pakhomov, A.S. Golubev, and Kirill Bogdanov.
He needs to find out where the money was collected.
The instructions to collect the money were given verbally during telephone conversations and via messengers.
Instructions on collection of funds and the person to whom they were to be transferred were received from Pakhomov V.S. and Golubev A.S.
Cases of payments of funds to previously invested clients as dividend payments at the expense of funds received from new clients and use by the company of funds received from clients for other purposes unrelated to brokerage activities were present, but they happened infrequently.
Such payments were related to the optimisation of logistics in carrying out couriers' activities.
Sometimes, it was necessary to pay out funds to a client (dividends, partial/complete closing), and for this purpose, newly received funds from another client were used.
This eliminated the cost of courier services.
Once, there was a case of payment of salaries to employees in the Tyumen office out of cash received from a client;

(Vol. No. 299, pp. 162 - 169)

Protocol of confrontation between the accused A.S. Golubev and the witness I.A. Chupin, during which the witness I.A. Chupin fully confirmed the testimony previously given by him as a witness, namely, that since June 2017, he started working as the head of the investment services department of LLC CF "EstateSPB" in the Tyumen branch.

Since March 2021, he has been employed by LLC IC QBIF as the director of the Tyumen branch, and the former director of the campaign, D.I. Rykov, resigned from the campaign.
Since 2017, his (Chupin I.A.) immediate supervisor was the Tyumen branch Rykov D director.
Around the middle of 2019, when Rykov D. switched to the work of the branch in Surgut - working on the opening of other "northern" oﬀices, he (Chupin A.S.) was assigned by Golubev A.S. to deal with the activities of the Tyumen oﬀice as a manager, with the prospect of being appointed director.
At that time, he started to have regular contact with A.S. Golubev.
He (A.S. Golubev) replaced V. Pakhomov, the director of the branch network of the QBG group of companies, who had moved to another position.
He (I.A. Chupin) was actually, i.e. oﬀicially appointed to the position of Director of the Tyumen branch in March 2021.
A.S. Golubev was contacted by telephone or video link.
Face-to-face meetings were held at the regional office in St. Petersburg approximately once a quarter.
The decision to hire him (I.A. Chupin) was not made by S. Matyukhin, who was only the signatory of the relevant order.
He believes that A.S. Golubev appointed him as the director of the Tyumen branch.
Since about 2017, clients have been offered trust and advisory management services by the Cyprus-based company Kiusiai and since the end of 2018 by the Cayman Islands-based company Wightlakechange.
Whitelakechange did not have a licence but only a registration in the register of the local regulator, the Cayman Islands Department of Money Circulation.
It also offered brokerage services to Constancy Investment, a company based in the Republic of Cyprus.
Since his employment, there have been cases of receiving cash from clients in rubles and foreign currency.
Cash deposits by clients were made only under contracts with foreign companies.
Under contractual relations of clients with foreign companies, cash deposits were about 80 - 90% of the total amount.
Cash was accepted by managers who worked with the client and then placed in a safe in the Tyumen oﬀice.
Clients were given receipts for accepting cash on behalf of the foreign companies Cuspiai and VLM.
In particular, when he was (without an oﬀicial appointment) the head of the regional office, through the corporate mail of the group of companies, information (message) was sent to Golubev A.S. about cash receipts and their amount.
Immediately, or after a short period, Golubev A.S. was instructed (by email) to hand over the cash to a particular employee of the QBF group of companies who were to arrive for it.
The exchange of information on cash collection with Golubev A.S. was also made using telephone conversations and messages in messengers, where the data of this employee was also indicated.
The funds were subsequently transferred to him "from hand to hand", without any transfer documents.
The head office management explained that the cash was subsequently transferred to the client's personal account.
Pakhomov V., Orlov Yuri, Maslennikov Vladimir, and Kirill Bogdanov personally collected the cash several times.
A.S. Golubev was in the oﬀice in Tyumen once and, as it seems to him, collected cash once. When he (I.A. Chupin) was the head of the Tumen oﬀice, dividend payments were made from the money received from clients.
He received the order to pay dividends from Golubev A.
There was also a case of giving the clients' cash to the oﬀice staﬀ as a bonus (bonus) accrued earlier;

(Vol. No. 299, pp. 170 - 177)

E.A. Rossieva - Pakhomov V.S and A.S. Golubev

Scheme Overview:

The Moscow-based QBF, in collaboration with its Russian sister company Q.Broker LLC and Cypriot Company Constance Investment LTD, promised investors maximum convenience, reliability, and a significant authorized capital of 333 million rubles.
Investigations revealed that QBF did not use investors’ money to buy shares related to IPO options as promised. Instead, the funds were invested in development projects of the beneficiary of the group of companies, R.V. Shpakov, and a significant portion of the client funds were withdrawn abroad.
By 2021, QBF ceased paying investors for all over-the-counter products, blaming Q.broker LLC for not fulfilling obligations. Beneficiary Shpakov Roman reportedly disappeared abroad.

Key Players: Roman Shpakov:

Roman Shpakov: The beneficiary of the group of companies and the central figure behind the scam.
Stanislav Matyukhin: The firm’s head, implicated in creating a convoluted legal structure to shield the core business from liabilities.

Key Players: Linda Athanasiadou:

Linda Athanasiadou: Linked with audit services through her firm, AeliusCircle and NOA Circle, she played a pivotal role in the scam’s operations. She was also responsible for the money laundering operations.

Stanislav Matyukhin:

The firm’s head was implicated in creating a convoluted legal structure to shield the core business from liabilities.

Modus Operandi:

QBF’s allure lies in its promises of substantial returns, leading investors to believe in the professional management of their funds.

Deceptive Practices:

Investors were routinely provided with fabricated monthly and quarterly reports, painting a rosy picture of profitability. However, when they sought to cash out, QBF employed a myriad of excuses to deny their requests.

The extent of the Scam:

The financial devastation wrought by QBF ranges between 2 to 7 billion Russian rubles. The list of victims reads like a who’s who of society, encompassing religious leaders, generals, ministers, and directors of major institutions.

Unravelling the Scam:

The facade began to crumble when investors encountered hurdles in accessing their funds. Further probes debunked QBF’s claims of leveraging AI for investment decisions.

Legal Consequences:

QBF’s dubious operations culminated in revoking its license in July 2021. While some perpetrators faced the legal music, many victims remained silent, possibly due to the questionable nature of their investments.

Consequences:

The QBF scandal has tarnished the Russian financial sector’s reputation and underscored the dire need for stringent oversight and transparency. As the saga unfolds, it is a stark reminder of the perils of unchecked financial malfeasance.

Unpacking the QBF Fraud Case: (Part 4) A Comprehensive Analysis. Testimonies of E.A. Rossieva, Pakhomov V.S, and A.S. Golubev.

The story of QBF has garnered significant media attention in Russia, with publications like Forbes shedding light on the intricacies of the financial pyramid.

The summary of the indictment in the criminal case №12001450007000902 details the extensive and complex illegal activities led by R.V. Shpakov, the head of the financial group “QBF”. This case involves charges of forming and directing an unlawful association and committing fraud violating Articles 210 and 159 of the Russian Criminal Code.

Elements of the Criminal Scheme:

Formation of Criminal Association:

Leveraging his influential position, Shpakov formed a criminal association with a clear role distribution, focused on committing fraud through investment schemes in securities and over-the-counter option contracts.

Methodology:

The association operated through structurally separate units with specific functions. They created and registered legal entities, produced fictitious contracts, and involved direct perpetrators and unknowing participants to execute the criminal plan.

Embezzlement Process:

The scheme involved stages where potential clients were identified, deceived into believing in profitable investments and then persuaded to sign client agreements. The funds were then embezzled through various means, including creating false reports and manipulating transactions.

Roles and Duties:

As the leader, Shpakov was responsible for organizing, financing, and directing the activities, including training in deception techniques and distributing the criminal proceeds. Other key members, such as V.S. Pakhomov, Linda Athanasiadou, Matyukhin S.A., Munaev Z.V., A.S. Golubev, and E.A. Rossieva, were given specific roles in the organization, each heading different structural subdivisions and carrying out assigned functions to further the criminal objectives.

Criminal Activities and Impact:

The organization systematically committed large-scale fraud, leading to significant financial losses for numerous victims. Each specific fraud case is detailed, highlighting the systematic and coordinated approach used in the criminal activities.

Termination of Activities:

The operation of this criminal association was halted by law enforcement interventions, leading to the indictment of its members for their roles in the organization.

The indictment underscores the elaborate and coordinated nature of the criminal scheme, the roles of various individuals in perpetuating the fraud, and the significant impact on the victims involved.

Unpacking the QBF Fraud Case: (Part 4) A Comprehensive Analysis. Testimonies of E.A. Rossieva, Pakhomov V.S, and A.S. Golubev.

E.A. Rossieva - Pakhomov V.S and A.S. Golubev

FRAUDSTERS

EXPOSED

Unpacking the QBF Fraud Case: (Part 4) A Comprehensive Analysis. Testimonies of E.A. Rossieva, Pakhomov V.S, and A.S. Golubev.

Protocol of confrontation between the accused Munayev Z.V. and the accused Golubev A.S. dated 11.03.2022, according to which the accused Munayev Z.V. fully confirmed his testimony, namely that Golubev A.S. worked in St. Petersburg, started as a financial advisor.

Protocol of confrontation between the witness Pakhomov V.S. and the witness Polezhaev A.V., during which the witness Polezhaev A.V. explained that he knows Pakhomov V.S., who is one of the managers of QB Finance LLC (QBIF LLC).

Testimony of A.S. Golubev, given by him as a witness, suspect, as the accused, according to which he did not admit guilt in the incriminated crimes and showed that he graduated from a higher educational institution in 2013 with a degree in "Engineer - technologist", "Engineer - designer".

Scheme Overview:

Key Players: Roman Shpakov:

Key Players: Linda Athanasiadou:

Stanislav Matyukhin:

Modus Operandi:

Deceptive Practices:

The extent of the Scam:

Unravelling the Scam:

Legal Consequences:

Consequences:

Unpacking the QBF Fraud Case: (Part 4) A Comprehensive Analysis. Testimonies of E.A. Rossieva, Pakhomov V.S, and A.S. Golubev.

The story of QBF has garnered significant media attention in Russia, with publications like Forbes shedding light on the intricacies of the financial pyramid.

Elements of the Criminal Scheme:

Formation of Criminal Association:

Methodology:

Embezzlement Process:

Roles and Duties:

Criminal Activities and Impact:

Termination of Activities:

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QBF Scam Uncovered