General evidence and their summary, confirming the guilt of Pakhomov V.S. in committing an offence under part 3 of article 210 and 151 of an offence under part 4 of article 159 of the Criminal Code of the Russian Federation:
Testimony of Z.V. Munaev, given by him as a witness, suspect, accused (the criminal case on the accusation of Z.V. Munaev of committing a crime under part 2 of article 210 of the Criminal Code of the Russian Federation and 50 crimes under part 4 of article 159 of the Criminal Code of the Russian Federation was separated on 15 April 2022 for the completion of the preliminary investigation into a separate proceeding based on p.4
Testimony of Z.V. Munaev (continued):
He does not know why the correspondence links Berezka and the tax inspection; Avalon was also R.V. Shpakov’s company.
In the fragment of correspondence within the group “Fin Potoki”, whose participants were
Linda (+ 357 99 920015), she is the creator of the group,
Munaev (+7 903 100–41–84),
Tatiana Milekhina in the period from 19.06.2020 from 14:17:03 to 16:58:14 and 02.11.2020, 15:03:12 in this correspondence is about the transfer of funds from one controlled company of Shpakov R.V.. - Q.Broker LLC - to another, Cyprus - licensed Constance Investment.
The payment under discussion was unilateral, non-refundable, and did not raise any questions, as it was formalised as a transfer of investments from one company to another.
The amount in question was 230,000 Euros.
Judging by the amount, it contributes to the authorised capital as an investment from the founder.
The investment company lives, as a rule, by ensuring the operation of such items as commissions from clients and turnover.
In the case of insufficient funds under management, the company does not have enough commissions to support its operations and salaries; in this case, the founder may make regular capital contributions to keep the company going when it cannot break even on its own due to poor performance.
This example is realised in this correspondence in the part of regular additions to the authorised capital of “Constance Investment” by R.V. Shpakov because the company did not have time to accumulate sufficient funds under management for good payback, which made R.V. Shpakov very angry, it was a constant ground for quarrels between him and Linda.
Further, according to the inspection report, there is a photo of Borzenkov’s payment slip.
Due to the competitive spirit and the exchange of results between different offices, both within the framework of contests and as a matter of routine, the managers could boast of significant results, declare their successes and remind about the efficiency of their offices.
Tatiana Milekhina was an accountant in the group of companies for a short time.
In a fragment of correspondence from the mobile application “WhatsApp” with the contact “Apollon” (+357 96 218890) dated 20.12.2017 in the period 09:27:39 to 13:14:37,
Apollon Athanasiadou speaks about the need to sign documents for the liquidation of Cypriot companies (“QB Capital CY LTD”, plus, presumably, “QB Capital Management LTD” in the set could be other companies).
It is about visiting the Cypriot embassy in Moscow: Apollo would accompany him to the embassy to sign the documents.
This has been necessary for the official procedure since he was in Moscow.
As a result, this was the case: he (Z.V. Munaev) and Apollo visited the consul together, whose participation in signing the documents was necessary to certify the organisation's liquidation properly.
In the fragment of correspondence dated 05.03.2020 in the period of time 19:21:01 to 20:02:24 in this part of the correspondence he (Z.V. Munaev) writes to Apollo Athanasiad that Nikolay , in connection with his appointment as CEO of the Russian LLC “VL Consulting”, proposed a new idea for document management support, in some part - a new format for the movement of client funds at “White Lake Management Ltd”.
This was one of the ideas. Nikolay was interested in strengthening and improving the interaction between the Clients and White Lake Management Ltd, bringing the processes in line with market and regulatory requirements.
In the fragment of correspondence in the group “Wl”, whose members were
Yuri Orlov,
Linda,
Apollo, and
Zelimkhan)
and the number +357 96 710071 belonging to Apollo
dated 19.09.2018 in the period from 11:16:42 to 13:22:15, it is said that Yuri Orlov as an IT specialist, stored some codes from websites, including the website of “White Lake Management Ltd”.
There were glitches on the site, and updates were needed; Yuri didn’t have time.
There were internal access issues, so Linda asked him for his password and debugging processes.
When clients re-signed contracts, a determination was made to terminate the contractual relationship between the client and “QB Capital CY LTD”, and a contract was concluded - either with “White Lake Management Ltd” only or in conjunction with “Simtelligence Company Limited”, or a contract could be added with “VL Consulting Ltd”.
All organisations with different jurisdictions, founders (owners), and general directors - to avoid assumptions about their affiliation to QBF group of companies, as it could lead to the idea that the client’s money passes exclusively through “their” organisations and can be used not for the intended purpose.
For the same reason, the report forms, hosting, and domains from which the reports were sent were also matched. In the fragment of correspondence in the group “Wl”, whose participants were Yuri Orlov, Linda, and Apollo for 15.11.2018 in the period from 16:05:31 to 21:07:53 in this working correspondence, it was about the uninterrupted work of the phone number in the office - representative office of “White Lake Management Ltd” in the Cayman Islands.
An operator response was needed to debug the work schedule and coordinate procedures with Linda. White Lake Management Ltd did have an office that met the minimum requirements of the regulator; he knew this from Linda Athanasiadou, as she had told him on several occasions.
There were no client managers in the office; for this reason, the telephone number needed to be answered by someone knowledgeable and could orientate clients on operations.
White Lake Management Ltd. had 10–20 clients - individuals (i.e. contracts for providing access to international stock markets were concluded, and clients transferred money to the organisation’s details).
During the Central Bank of Russia’s inspection of QBIF LLC (most likely during the second inspection), the Cayman Islands were requested by the Central Bank of Russia.
In response to this request, the Cayman Islands regulator gave explanations about the organisation “White Lake Management Ltd”: its working conditions, transfer of funds, and also that there are “live” people, clients, “live” balances, and the Cayman Islands regulator disclosed the data of these clients. The regulator had no questions about White Lake Management Ltd's work.
In addition, Nikolay was closely involved in the issues of the legitimacy of “White Lake Management Ltd” activities: he read a lot, studied websites and information from the regulator, found information about the presence of a license to act with securities, and this was the second confirmation of the presence of a license (the first confirmation was from Linda).
The financial advisors also looked into this as they had clients to work with.
The QBF office in the sales department had information in English from the Cayman Islands regulator regarding White Lake Management Ltd.
The fragment of correspondence with the contact “Smirnova Yaroslava” for 18.11.2020, in the period from 19:38:49 to 22:49:06, refers to Yaroslava Smirnova’s initiative to discuss with Shpakov R.V. and him several questions that she had previously formulated to him. The questions related to different funds of the QBF Management Company. He expressed his position on some of the questions. Where payments were necessary, he explained that we put them on the list for coordination with Shpakov R.V.
The correspondence shows Yaroslava’s dissatisfaction with the interaction and speed of coordination with LLC “IC “QBF” represented by Matyukhin Stanislav and lawyers (Rossieva Evgeniya) in the part of the realisation of units of its funds (Funds of MC) to clients coordination of operational moments.
Anastasia is Anastasia Koval, Chief Operating Officer of QBIF LLC, a subordinate of Stanislav Matyukhin. In the fragment of correspondence with the contact “Alexey Golubev” for the period 12.01.2017 from 13:13:15 to 16:25:16; 13.01.2017 at 10:25:39; 02.03.2017 at 16:07:52; 06.03.2017 from 11:49:36 to 19:40:49; 02.04.2019 in the period from 17:55:11 to 10:36:27 03.04.2019 the following is the subject of the correspondence:
At the beginning of the correspondence, colleagues (in branches) did not receive reports on some customers, and the chain of forwarding the request reached him, and he helped to get the report. In the correspondence, Golubev A.S. asks him about the need for changes in the reports of two clients for two months.
He did not prepare the reports, so he does not know why there were no changes, but the clients may have had questions. For this reason, he (Z.V. Munaev) advises A.S. Golubev to contact the back office. A.S. Golubev further asks about the tax rate calculation on foreign companies for the Clients.
However, for foreign companies, he advised him to contact Dmitry Lepeshkin, who is aware of the activities and specific work processes of both Constance Investment and Noa. “Constance Investment was established by the organisation Aspard, whose owner is Shpakov R.V.
Apollo managed the activities of NOA, and Linda Athanasiadou managed the activities of Constance Investment.
Dmitry Lepeshkin was aware of the activities of both of these organisations, but he needed to make significant decisions.
Andreas is one of Linda’s employees (foreign back office). Various contractual options were discussed with A.S. Golubev, which he explained above.
There were contracts concluded with Clients only on behalf of “White Lake Management Ltd” with cash transfers directly to this organisation; when two contracts were terminated, on behalf of “White Lake Management Ltd” and “Simtelligence Company Limited”, cash transfers were made by Clients to “Simtelligence Company Limited”, which was recognised as an agent in the contract with “White Lake Management Ltd”.
Cash transfers from customers could only take place to credit the account of Simtelligence Company Limited, while non-cash transfers could be made to both organisations.
In the fragment of correspondence with the contact “Ruslan Spinka” dated 24.10.2019 from 13:42:58 to 23:53:16 in, the mentioned fragment, he was written to by an acquaintance about a client who cannot withdraw money.
He forwarded the issue to the Sales Department to Ruslan Spinka, as he did not deal with the DP (Sales Department). In the fragment of correspondence with the contact “Ruslan Spinka” dated 14.05.2020 in the period from 12:06:31 to 21:55:47 and 14.08.2020 in the period from 09:10:45 to 17:44:18, both customer and employee issues were discussed.
Customer issues: Kushnir and Gomanova are clients in roughly the same situation.
There was a request from Ruslan Spinka to discuss additional loyalty from the company in favour of some clients, namely giving them extra “leverage” (BP) due to unsatisfactory management results for clients.
The broker could give additional “leverage” to clients; R.V. Shpakov himself had previously selectively initiated this on several occasions and confirmed this possibility to employees.
Ruslan asked for help, three to talk to R.V. Shpakov to help dissatisfied clients. “Leverage” is an opportunity for the client to increase the portfolio volume using additional borrowed funds for trading from the company - Broker.
“Leverage” is given as additional funds to the client for trading against his existing portfolio's security (pledge).
The result of trading on borrowed money (“leverage”) is profit or loss: profit After repayment of borrowed funds to the Broker is credited to the Client’s balance, loss After repayment of borrowed funds to the Broker is written off from the Client’s existing portfolio—the transaction granting additional “leverage” results from the client’s initiative.
The borrowed funds are subject to an annual interest rate, charged daily pro rata. Initially, in the company, this option appeared from the service of Consultative management (the client makes transactions).
Then, on the initiative of employees of the Sales Department to increase customer loyalty to the service, there were requests to connect this option and clients of the Trust management.
Besides, in correspondence, the issues of other clients are discussed in the working order, as well as ways to avoid conflicts.
Regarding the issues discussed about employees: I debated with Ruslan who from their side, prepared the calculation of salary and bonuses from the sales department, whether this calculation was checked, and whether it was sent to Shpakov R.V. for approval and payment. In connection with delays in payments, Ruslan asked to hurry up with the issuance of debts to employees, including asking him (Munaev Z.V.) to address Shpakov to speed up the resolution of the issue.
In the fragment of correspondence with the contact “Ruslan Spinka” from 10.11.2020 in the period from 09:33:28 to 17:47:01, it was discussed whether dissatisfied clients are on the Internet, on forums and review sites, whether representatives of the company contact them, whether they are given attention in the order of follow up, whether these clients are reliably in the lists for withdrawal. Meshkova , who was responsible for monitoring the Internet at that time, worked in the support department.
Customer complaints addressed to the company were first sent to the legal department, where lawyers looked at the contract terms and decided what to answer.
The most significant number of complaints was related to non-payment of money to clients (employees addressed Shpakov R.V. with this issue).
The second reason for appealing is clients' dissatisfaction with the financial result: why is there no profit, why were these particular items bought, why was the commission written off, although no money was earned, etc? In the fragment of correspondence with the contact “Roman Shpakov” from 07.11.2017 in the period from 22:12:15 to 23:55:00 in this fragment of correspondence in the designated dates can be associated with two events:
The situation related to the contacts of the former security officer of the company Alexey Rudnev, hired by Shpakov R.V. Rudnev, according to him, had connections in the regulator at the level of Nabiullina, as well as in the FSB at the level of the head of the entire service. The contacts turned out to be “fake” and were offered to him deliberately as part of the intent to embezzle the company’s and Shpakov R.V.’s funds (or bribe). As a result, a criminal case was initiated against Rudnev and his associates, who did not work in government agencies, following the Company’s appeal and application to law enforcement agencies when Rudnev’s initiative was uncovered. He (Z.V. Munaev) was the complainant on the instructions of R.V. Shpakov; FSB officers provided the operational support.
Roman Shpakov had a personal contact - Pavel Samiev, his old acquaintance, a former high-ranking employee of RA Expert rating agency.
Pavel has many connections in the financial market, including with the regulator.
R.V. Shpakov held many preliminary meetings and negotiations with him on the subject of helping him to recognise the Central Bank’s letters to Cyprus, whether they were someone’s “order”, whether someone wanted to harm the company, or whether these requests to Cyprus did not exist at all.
At a particular stage, when Pavel needed information on the company’s work with clients, contracts, money transfer procedure and general organisation of work, R.V. Shpakov set him (Z.V. Munaev) the task to bring all this information to Pavel in the information field of his further meetings with contacts on the market and in the regulator, to give his opinion on whether Pavel could learn anything for the company.
His involvement in working with Paul on this matter was limited to a few meetings with him, calls and correspondence.
As a result, Pavel informed him (Z.V. Munaev) that there was no information on the issue of R.V. Shpakov in the Central Bank of Russia at the level of deputy chairmen (Yudaeva, etc.), and he needed help finding something.
According to information from market participants he knows, companies may want to “mess up” QBF and R.V. Shpakov, but he does not have more detailed and helpful information and cannot find out.
Since, at that time, the issue of liquidation of “QB Capital CY LTD” in Cyprus had already started, Shpakov R.V. often tried to include him from different sides in this issue to instil in him (Munaev Z.V.) fear for the clients of the company and for the company itself, so that he (Munaev Z.V.) would get imbued and start to worry about their further fate personally.
The fragment of correspondence dated 20.12.2017 from 14:15:59 to 15:34:29 is about messages from the client Stepanov about his receipt of funds.
In the fragment of correspondence from 02.06.2020 from 00:29:25 to 11:38:21, this fragment was about nominals whether he handed over the task.
He answered yes (but what task, he does not know, he does not remember).
He answered about their awareness of the company and its people, which they may be aware of.
He answered that it would be better to use actual working and acting people in the company for appointments (in continuation of the answer on nominations).
Remy Zyman - doesn’t know who that is. Perchikov - the surname is familiar, but he does not remember who it is.
His answer about Vera (Veronika is Polezhaev’s wife, i.e. Polezhaev himself is meant) refers to the initiative of R.V. Shpakov to file a complaint against him with law enforcement authorities under the article “Extortion” since he received the money he invested.
Sam - doesn’t know who he is talking about. Matyukhin was called “Stam” or “Stan” (Stanislav), so perhaps it is about him, and there is a typo in the text.
Anya Trufanova is not personally known to him; it is some private case.
Shpakov R.V. told him something about people who could intentionally harm him and the company in their interests.
Since he does not remember the whole context of the audio files, he can tell the following from his answers:
Since the head of QBF security service, Mikhalevich, previously worked in the 6th FSB service and knows a lot about the company’s processes, he may supply information to the 6th service (earlier experience with the previous head of the FSB Rudnev left an indelible mark on many people and fear of using his official position for selfish purposes).
“The information is held by…” - perhaps we are talking about potential ill-wishers who pull the levers of the Central Bank of the Russian Federation and the Ministry of Internal Affairs of the Russian Federation.
We are talking about a large set of documents of Stepanov’s client, who had previously sent it to the CBR, and then this set was forwarded to the Ministry of Internal Affairs of the Russian Federation for the Central Administrative District.
Based on the fragment of correspondence dated 31.08.2020 for the period from 11:16:45 to 19:04:15, it explained that Shpakov R.V. and Linda had periodic disagreements, because of which Shpakov R.V. at some periods wanted to dismiss her from Constance Investment due to personal claims, inefficiency, as the company was not making money and Shpakov R.V. had to support its activities financially.
However, he was in favour of her remaining at least in the Compliance function - checking all documents in Constance Investment for reporting to clients, as he knew she was a strong specialist and could be helpful in this position.
R.V. Shpakov had periodic thoughts about dismissing her from Constance Investment (periodically, she was not satisfied with her work).
The tranche - Argento’s papers - replenished the company’s portfolio, leverage and security of the leverage, which the company took on itself and the clients.
Thus, the replenishment in Argento allowed for the release of some volumes from previously held collateral (securities and money that were already in the company’s portfolio) to make withdrawals by submitted client orders.
He further asked if DP bonuses would be paid out. Linda informed me about the possibility of making Shpakov R.V. transactions via Bitcoin. His answer: “will give 3 million rubles for bonuses” (bonuses of DP in a bad month were 2 million rubles, in a good month - up to 8 million), and accumulated debts - it was about half a year.
R.V. Shpakov often played on the emotions of employees (he relieved himself of responsibility), sometimes shifting the responsibility from incoming funds to salaries and bonuses (all debts for previous periods), paying part of the funds to “small” clients at his own expense to slightly reduce the emotional load of employees - to transfer them to another direction.
In the fragment of correspondence with the contact “Yuri Orlov” (+79263088226) on 08.06.2018 in the period from 15:58:04 to 19:01:01; 12.09.2018 from 13:23:33 to 14:47:39; 26.02.2019, from 17:47:42 to 17:58:40, this part of the correspondence with Yuri Orlov refers to the discussion of reports to clients on behalf of White Lake Management LTD, which were to be sent to them After the re-signing of international market contracts.
Linda also supervised this matter. “Vladimir Sergeyevich” - this correspondence refers to Vladimir Pakhomov.
In the fragment of correspondence with the contact “Yuri Orlov” on 13.03.2019 in the period from 16:39:41 to 21:18:13, technical aspects of ensuring the company’s activity are discussed. This part of the correspondence refers to the day of the search in the company's office.
He (Munaev Z.V.) sent Yuri the tasks formulated to him (Munaev Z.V.) by Shpakov R.V. in immediate response regarding disconnecting network media, access to computers of all managers, and restricting access to files, mail, and other access.
The fragment of correspondence dated 04.09.2019 for the period from 09:50:31 to 10:22:52 with Yuri Orlov, except for some individual topics, refers to the instructions of Shpakov R.V. on the access of employees to local discs of the company, the work of the pass system of the office, updating and purchase of this or that software, sites, servers, remote access, some equipment to the office, security and data encryption programs, systems against hacking and others.
Also, Yuri was often approached to get some reports; he (Yuri) was in charge of sending them out. Marketing mailings (advertising mailings) on the database of Customers for specific products: there could be both current Customers and a database of potential Customers.
Employees asked Orlov of Moscow's offices and branches about the work of the CRM system (software for accounting of new and maintenance of existing Customers, used, as a rule, in the sales department).
Also, Yuri was asked for an expert assessment of any market programs, their working conditions, the possibility of interaction, etc.
In the fragment of correspondence with the contact “Pakhomov” (+796574–8888) from 16.07.2019 for the period from 10:42:33 to 18:31:41, this correspondence concerns the situation with the client Polezhaev; this is the client of Pakhomov V.S.
He (Munaev Z.V.) reported that a Chechen who “deals” with the issue from the side of Polezhaev, his partner, came out to him. He (Z.V. Munaev) was threatened, as he was a signatory of Kyubi Capital, as well as the risks associated with the company, including criminal prosecution.
It was about “manual” control by Polezhaev of necessary people in law enforcement structures to put pressure on Shpakov R.V., Pakhomov V.S. and, as a consequence, on him (Munaev Z.V.), that the desired result in the case of refusal of cooperation will be achieved by any means, people are already “loaded”, even though the client received the invested money at the time of this correspondence. Categorical dissatisfaction and disagreement concerned the amount of profit (it is not fixed or guaranteed).
In fragments of correspondence with the group “Fantastic 4”, whose participants were
Roman Shpakov (+7 905 735–55–88),
Linda (+357 99 920015),
Munaev (+7 903 100–41–84), +7 965 748–88–88
Vladimir Pakhomov
dated 13.11.2017 during the period from 21:51:44 to 00:32:39 h 14.11.2017; 15.11.2017 during the period from 13:42:50 to 16:02:13; 17.11.2017 during the period from 11:12:24 to 16:17:02; 23.11.2017 in the period from 12:32:51 to 11:52:42; 28.11.2017 in the period from 00:22:03 to 02:21:59; 30.07.2018 in the period from 15:16:03 to 16:50:02, Roman Shpakov was the task setter, Linda coordinated the issue for the Cyprus regulator, Vladimir Pakhomov coordinated the issue for the Russian regulator (Central Bank of Russia).
He (Z.V. Munaev) was in correspondence as a nominee signatory of “QB Capital CY LTD”. The main content of this correspondence concerned discussions about possible letters of inquiry from the Central Bank of the Russian Federation to the Cyprus regulator SUSEC (Cysec).
Linda informed Shpakov R.V. about the receipt by the Cyprus regulator of an inquiry about the company “QB Capital CY LTD”, in connection with the company “QB Capital CY LTD”, the receipt of clients’ funds from Russia about the owner of “QB Capital CY LTD”.
Because for R.V. Shpakov, who was a beneficiary of the Russian group of companies “QBF”, this issue and disclosure of him as a beneficiary of “QB Capital CY LTD” was a risk zone, he was greatly puzzled by the solution to this issue and not declassifying this information due to possible, including criminal, consequences for him.
The correspondence was lengthy and did not reach a logical conclusion as Roman Shpakov and Vladimir Pakhomov questioned the letters from the Russian Federation to Cyprus as such and did not believe Linda, insisting that she was overemphasising the issue and her role.
The other side was Linda’s position, which argued that the letters do exist, that they are indeed a threat to everyone, and that it is urgent to address the issue in Russia because there were no problems in Cyprus initially.
Still, in case of complaints from the Russian Federation, they may appear.
The third option discussed by the participants was a possible ill-wisher and initiator of the investigation in the Central Bank of the Russian Federation, including on a reimbursable basis, who wants to cause trouble for both the company and Roman Shpakov personally.
The correspondence discussed all three options, including possible reasons, details, and consequences.
It has yet to come to reliable information.
Although at that moment, his (Z.V. Munaev) participation in the correspondence was the most inactive due to his distance from these issues, he now realises that at that time, the letters from the Central Bank of Russia to the Cyprus regulator must have taken place.
Subsequently, After the correspondence, Linda verbally informed him (Z.V. Munaev) that she communicated with representatives of the regulator, and they verbally confirmed the existence of letters but showed only internal requests from CySEC (Saisek) to “QB Capital CY LTD” in Greek.
In this correspondence, R.V. Shpakov, due to uncertainty about the source of the threat, instructs VS Pakhomov to find out the necessary information from the Central Bank of the Russian Federation and settle the matter so that the letters would no longer arrive, and at the same time instructs Linda to resolve the matter on the territory of Cyprus so that they, for their part, would provide answers satisfactory to the Russian Federation.
Vladimir Pakhomov’s communications with Linda clarifying the details of the requests and his responses indicating that he had the necessary resources at the regulator and the ability to verify all information there show both his awareness of the issue with the patronage of individuals at the CBR and his ability to resolve the specific problems if they existed.
Linda’s initiative involved risks in Cyprus, including her as a representative of the auditors, a nominee service company, and the manager of the licensed Constance Investment. Linda’s correspondence draws attention to the “sore spots” - the accounts at Piraeus Bank and Cyprus Development Bank (“CDB”), as these banks contained information about the actual beneficiary of the company - Shpakov R.V.
The correspondence also confirms his role as a signatory on the Cyprus side, indicating that Linda signed documents for him.
Some of his (Munaev Z.V.) messages in this correspondence were initiated by Shpakov R.V. in verbal communication as well as written by him (Shpakov R.V.) personally from his (Munaev Z.V.) phone, namely, reassuring Linda that they took her concerns seriously, did not fail to act, and in connection with her distrust of Pakhomov V.S.’s words did confirm the common concern and efforts to resolve the issue on the side of the Russian Federation.
The correspondence confirms his (Munaev Z.V.) role as a nominee to disclose information on him instead of information on Shpakov R.V.
The abbreviation ABB is Bank in Vanuatu (“Alpen Baruch Bank”).
The correspondence discusses V.S. Pakhomov’s request to accept 2kk - (i.e. $2 million, dates just 2017, possibly Borzenkov’s money as he realises) into this bank.
As a possible malefactor in relation to Shpakov R.V. is indicated a client of the company and, according to information of Shpakov R.V., a former raider Stepanov Sergey, who at one time initiated several applications and complaints, both in Russia and in Cyprus, as well as a court decision on arrests of accounts of LLC “IC QBF” in Russia.
After a certain period, he was paid the total amount of funds with profits, as well as an additional amount on top of the “inconvenience caused”.
(Vol. No. 306, pp. 1 - 8, 18 - 28, 47 - 50, 101 - 103, 104 - 108, 109 - 117, 147 - 157, 158 - 166, 168 - 178, 180 - 194, 196 - 210, Vol. No. 307, pp. 1 - 50)
QBF Fraud Case Munaev Testimony
References:
criminal case №12001450007000902
criminal case №12101007754000065
Case number: 10–5376/2023
Unique case identifier: 77RS0034–02–2021–001721–66.
Unique case identifier 77OS0000–02–2023–008597–18
Unique case identifier 77OS0000–02–2023–001289–20
Case number ~ material 01–0023/2022 (01–0252/2021)
Case number 402к-0680/2023
Case number 402к-0055/2023
Case number: 10–5376/2023
Case number in the lower court 01–0023/2022
Case number in the higher court: 10–5376/2023
Judge fio Case № 10–5376/2023 APPEAL DEFINITION of the city of Moscow March 27, 2023
Unique case identifier: 77RS0027–02–2021–014847–53
The case number in a higher court: 10–20643/2021, 10–20648/2021
Unique case identifier 77RS0027–02–2021–014847–53
Case number 3/6–1332/2021
Case number in the lower court: 3/6–1332/2021
Unique case identifier 77RS0016–02–2022–012632–22
Case number 3/6–0931/2022
Case number in the lower court 3/2–0581/2022
Unique case identifier 77RS0016–02–2022–028543–13
Case number 3/2–0581/2022
Case number in a higher court 10–19638/2023
Case number in a higher court 10–25794/2022
Case number in a higher court 10–25794/2022
Current state Entered into force, 13.12.2022
Unique case identifier 77RS0016–02–2022–021764–77
Case number 10–21084/2022
Case number in the lower court 3/1–0222/2022
Case number in a higher court 10–21084/2022
Unique case identifier 77OS0000–02–2021–000556–53
Case number 402к -0080/2021
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, she played a pivotal role in the scam’s operations.
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.
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 Scheme:
Formation of Criminal Association: Shpakov, leveraging his influential position, formed a criminal association with a precise 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.
QBF Fraud Case Munaev Testimony
The QBF Scam: Unveiling the Depths of Financial Fraudulence
Financial Crime/Fraud, APOLLON Athanasiades, Argento access, Constance investment, CySec, FCA, FRAUD, LBX, LINDA ATHANASIADOU, Money Laundering, NATIONAL CRIME AGENCY, QBF, ROMAN SPHAKOV, Pakhamov V.S, Zelimkhan Munayev, Matykhin S.A, Alexei Sergeyevich Golubev, Rossieva E.A, SCAM, NOA CIRCLE, Benjamin Dives, LBX/ARGENTO BONDS, Linda Athanasiadou/Kovalenko, Interpol/Europol, MOKAS, financial fraud, financial crime, CONSTANCE, Phil Millo, Ben Dives LBX — Argento SCAM
End of Munaev Testimony. QBF Fraud Case.
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