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Unpacking the QBF Fraud Case: A Comprehensive Analysis of the Indictment (Part 1)

Updated: Apr 21

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There is light even in the darkest places. The Sun of Justice

INDICTMENT

in the Criminal Case №12001450007000902

on the charge in the commission of the offence of

ч. 3, Art. 210, and 151 of the offence under Part 4, Art. 159 of the Criminal Code of the Russian Federation,


In an unprecedented financial fraud case, the indictment in the criminal case №12001450007000902 sheds light on the intricate and nefarious operations of R.V. Shpakov, the mastermind behind the QBF financial group's criminal association. This blog post delves into the elaborate scheme that Shpakov and his accomplices orchestrated, revealing a complex web of deceit, embezzlement, and manipulation that spanned several years and victimized numerous individuals.


At the heart of this scandal lies the creation of a criminal association, ingeniously structured with separate units, each performing specific roles. Shpakov, exploiting his influential position, deceived investors under the guise of lucrative securities investments and over-the-counter option contracts. The indictment meticulously details the methods used, from forming legal entities and producing fictitious contracts to direct embezzlement of funds from unsuspecting investors.


Key figures like V.S. Pakhomov, Linda Athanasiadou, and others played significant roles in this elaborate scam, each heading various subdivisions and contributing to the criminal objectives. The association's tactics involved identifying potential victims, gaining their trust through false promises of high returns, and then methodically siphoning off their investments.


The consequences of this fraud were catastrophic, with a long list of victims suffering substantial financial losses. Each case detailed in the indictment paints a vivid picture of the systematic and coordinated exploitation carried out by the association. The exposure and subsequent dismantling of this criminal network by law enforcement highlight the scale and severity of the operation.


This post aims to unpack the layers of this complex financial fraud, offering insights into the inner workings of one of the most intricate criminal schemes in recent history. It is a cautionary tale about the dangers lurking in the investment world and the importance of vigilance in the face of seemingly attractive financial opportunities.



INTRO: THE QBF/NOA CIRCLE FRAUD CASE

R.V. Shpakov, being the head of the financial group “QBF” (QBF), general director and a participant of various legal entities, using his official position expressed in influencing other persons to perform specific actions aimed at their participation in a criminal association (criminal organisation), based on the importance and authority of the positions he holds and his position in the organisations that were part of this financial group, having the intention to systematically commit serious crimes of mercenary orientation, i.e., fraud.


The SCHEME

To achieve the desired criminal result, R.V. Shpakov developed a plan to create and form a criminal association with a precise distribution of roles among the participants, the main activity of which was to commit fraud under the pretext of investing funds in securities with high yields, as well as under the guise of fulfilling obligations under over — the — counter option contracts.


According to the criminal plan, R.V. Shpakov, realising the public danger of his illegal actions, using his official position for unlawful purposes, formed a criminal association as follows:
  • The creation of several functionally separate structural units that performed strictly defined functions and had an explicit specialisation for specific offences.

  • Involvement in the criminal association of direct managers of separate structural subdivisions from among trusted persons, as well as persons inclined to commit theft by deception.

  • Finding, creating and registering legal entities in accordance with the procedure established by law, the details of which were used in the production of standard sets of fictitious contracts and accompanying documents, allegedly testifying to the legitimate activities of these organisations.

  • Involvement in the criminal community (criminal organisation), in its structural subdivisions of direct executors of criminal intent from among persons involved in the activities of organisations, inclined to commit theft by deception, having mercenary aspirations;

  • Involvement in the criminal association of persons who ensured the functioning of the structural units of the criminal association as a whole;

  • Determination of the scheme of distribution of criminal income, which allowed the direct perpetrators of the crimes to maintain financial motivation directly dependent on the number of defrauded citizens, as well as the formation of a criminal fund, the money from which was used to finance the activities of the criminal association;

  • The involvement in the activities of organisations used by the criminal association of persons unaware of the criminal intent of the participants in the criminal association;

  • Development of specific methods and techniques of deception, the use of which enabled the direct perpetrators of the offences and persons involved in the activities of organisations used by the criminal association, unaware of the illegal nature of the actions of co-conspirators, to achieve the criminal association’s objective of obtaining criminal proceeds;

  • Create a strict hierarchy between the heads of functionally separate structural units, lower-level managers, and direct perpetrators of crimes to create the possibility of using the developed methods and ways of deception by persons who directly communicate with clients.


INITIAL STAGES

At the initial stage of establishing the criminal association, R.V. Shpakov determined the direction of joint illegal activity with his co—conspirators, aimed at violating the legally protected property rights of citizens by fraudulent means, and directly obtaining material benefits, developed a detailed criminal plan for an extended period of activity, which consisted in the distribution of roles among the members of the unlawful association, the interaction of its subdivisions to realise common criminal intentions, as well as the distribution of functions between them, orchestrating the criminal association’s activities, and the allocation of tasks of the criminal association.


The plan developed by R.V. Shpakov for the activities of a criminal association aimed at committing serious offences envisaged the following stages:
  • Seeking money necessary to support the criminal activities of the criminal association and its structural subdivisions;

  • Registration and search for legal entities both in the territory of the Russian Federation and in the territory of foreign states, the requisites of which were used in the preparation of standard sets of fictitious contracts, agreements and related documents, allegedly testifying to the legitimate activities of these organisations;

  • Finding and attracting accomplices, assigning them criminal roles in the criminal association, as well as attracting persons unaware of the criminal intentions of the participants in the criminal association, in order to ensure the functioning of the mechanism of committing crimes and increase the number of citizens willing to enter into client agreements for the provision of direct access services to international stock markets, trust management agreements, service agreements, agreements for the provision of services, agreements for the provision of brokerage services (attachment agreements), agreements for the provision of direct access to international stock markets, and agreements for the provision of brokerage services (attachment agreements).

  • Developing an individual plan for committing offences and selecting a method of committing and concealing offences;

  •  Coordination of the activities of participants in the criminal association;

  • Organisation of the process of producing client agreements on the provision of direct access services to international stock markets, agreements on the provision of trust management services in accordance with the agreement on the provision of direct access services to international stock markets, trust management agreements, service agreements, service agreements, brokerage service agreements (adhesion agreements), OTC option agreements, as well as other documents used for embezzlement of funds

  • Placement of advertisements in mass media and the Internet about the benefits of concluding client agreements on providing direct access to international stock markets, as well as OTC option agreements;

  • Development of various algorithms of negotiations with clients in order to create a relationship of trust between the latter and the participants of the criminal association and to mislead citizens by providing deliberately false information about the profitability of investing money;

  • Training the members of the criminal community in special terminology, algorithms of deception, as well as the formation of the latter’s goal and motivation to take possession of as much of the victim’s money as possible by creating a system of bonuses and incentives within the criminal community;

  • Finding office premises in various regions of the Russian Federation, which were used both by members of the criminal association and by persons unaware of the criminal intentions of the co — co-co-conspirators, and which were used to hold meetings, negotiate with clients and receive money from the latter;

  • Ensuring partial return (withdrawal) of funds deposited by clients (investors) that were stolen in order to create the appearance of objective trading and market volatility, as well as to prevent clients from reporting thefts to law enforcement authorities;

  • The implementation of measures to conceal offences and avoid possible criminal or other liability by giving the appearance of legality to financial activities;

  • The precise distribution of funds in the interests of the criminal association, as well as among its members, based on the “contribution” of each participant to illegal activity;

  • Implementation of other actions aimed at the smooth functioning of the criminal activity scheme.


According to the criminal plan of R.V. Shpakov, the criminal association he created and directed embezzled money from citizens under the guise of providing brokerage services. R.V. Shpakov knew that in accordance with the Federal Law of 22.04.1996 №39 — FZ “On the Securities Market”, as well as in accordance with numerous instructions, regulations, guidelines of the Central Bank of the Russian Federation in the field of professional participants of the securities market, brokerage activity is the activity on execution of the client’s order to perform civil law transactions with securities and (or) to conclude agreements that are derivative financial instruments, carried out based on compensatory contracts with the client.


At the same time, R.V. Shpakov, in violation of the above law, planned to systematically steal money belonging to citizens by means of deceit, which consisted of deliberate communication of knowingly false information to clients, with the aim of obtaining criminal income and distribution by concluding, on behalf of organisations controlled by the participants of the unlawful association, acting under the guise of brokerage companies, client agreements on provision of direct access to international stock markets, trust management agreements, and agreements on provision of financial derivatives.


Following their criminal plan developed by R.V. Shpakov to commit serious crimes, as well as to veil his illegal activity and make his actions look legitimate, no later than 31 December 2011. was sought LLC Investment Company QBIF (INN 7733673955, before renaming on 13.04.2016 — LLC IK QBIF Investment, before renaming on 23.12.2015 — LLC QBIF Finance, hereinafter referred to as the Company), which had a licence dated 24 December 2009 №045–12805–100000 for brokerage activities, licence dated 24 December 2009. №045–12816–010000 for dealer activities, license №045–12828–001000 dated 24 December 2009 for securities management activities and license №045–14078–000100 dated 08 August 2019 for depository activities (which were cancelled by the decision of the Central Bank of the Russian Federation on 08 July 2021 due to numerous violations of the requirements of the legislation, regulations of the Central Bank of the Russian Federation and internal documents of the Company). The said Company, its details and accounts were supposed to be used by the participants of the criminal association to mislead clients about the true intentions of the co—conspirators and subsequent commission of serious crimes — embezzlement of funds, as well as to create a belief in citizens (clients) about the profitable investment of funds, who believed that they were interacting with a professional participant of the securities market, which was engaged in these types of activities and was obliged to ensure the priority of the client’s interests pa.


In addition, not stopping there, to attract more clients and, as a consequence, more money for further embezzlement, R.V. Shpakov, together with members of the criminal association, in the course of criminal activity, no later than 31 December 2019, developed and implemented an additional illegal plan, which provided for the following. Within the framework of the brokerage services agreement (adhesion agreement) concluded by QBIF Investment Company LLC (hereinafter referred to as “the Broker”) with its clients, the Company, when executing transactions, executed the clients’ orders to conclude transactions on the OTC market with derivative financial instruments, including options, the underlying asset of which were equity securities of foreign issuers (hereinafter referred to as “OTC option contracts”). The counterparty (seller) under all OTC option contracts, including those concluded in the interests of clients — individuals, was an organisation affiliated with QBIF Investment Company LLC — Q.Broker LLC (INN 9703003668), the ultimate beneficiary of which was R.V. Shpakov.


In this case, per the criminal plan, the implementation of OTC options by Q.Broker LLC was to function as a financial pyramid scheme, where the source of return of funds to clients under OTC option contracts executed or partially executed by Q.Broker LLC was the funds received under newly concluded option contracts, and the ultimate goal of the option contracts was to carry out schematic operations for withdrawal of funds outside the Russian Federation, cashing out of the Russian Federation.

The direct theft of money belonging to citizens was also carried out according to the criminal plan developed by R.V. Shpakov, which was divided into several stages.


STAGES OF embezzlement

The first stage of embezzlement of citizens’ money provided that the participants of the first structural subdivision of the criminal association, as well as persons unaware of the criminal intentions of the accomplices, who were under the control of R.V. Shpakov, acting in accordance with the instructions of the head of the structural subdivision, received the data of selected potential clients (investors) who had the opportunity to transfer or deposit large sums of money into their accounts, to conclude contracts (agreements) with them, as well as to impose trust services.


The second stage of embezzlement of citizens’ money provided that the participants of the first structural subdivision of the criminal association, as well as persons unaware of the criminal intentions of the accomplices, who were under the control of R.V. Shpakov, acting in accordance with the instructions of the head of the structural subdivision, by telephone or at a personal meeting misled the clients about their true intentions and created a belief in the citizens that they were offered a profitable investment of their money. In turn, the clients believed they were interacting with a professional participant in the securities market who was engaged in brokerage activities and was obliged to ensure that the client’s interests were prioritised over their own personal interests.


The third stage of the theft of citizens’ money provided that the participants of the first structural subdivision of the criminal association, as well as persons unaware of the criminal intentions of the accomplices, who were under the control of R.V. Shpakov, acting under the instructions of the head of the structural subdivision, organised the process of preparing and signing client agreements on the provision of direct access to international stock markets, agreements on the provision of trust management services following the agreement of the first structural subdivision of the criminal association.


The fourth stage of embezzlement of citizens’ money provided that the participants of the first structural subdivision of the criminal association, as well as persons unaware of the criminal intentions of the accomplices, who were under the control of R.V. Shpakov, acting in accordance with the instructions of the head of the structural subdivision, carried out and organised the process of accepting cash or the process of transferring money from the accounts of clients to the accounts of individuals and legal entities controlled by the criminal association.


At the same time, the participants of the criminal association were allowed to modify the communication algorithm with clients, taking into account the specific situation, to achieve the common goal of extracting criminal income while fulfilling their predetermined roles. Thus, the entire plan of illegal actions was aimed solely at obtaining, by deception and abuse of trust, as much money as possible, regardless of the circumstances.


R.V. Shpakov, using his official position, in the period from 31 December 2011 to 31 August 2017, implemented plans to create a criminal association, formed from its participants, as well as other persons involved in illegal activity, a structured, organised group consisting of 3 functionally separate organised groups (structural subdivisions of the criminal association), with a clear distribution of roles, interacting with each other to implement a single criminal intent and performing strictly defined functions. At the same time, he identified the heads of these structural subdivisions from among his acquaintances, having previously obtained their consent to join the criminal association, and initiated them into the illegal plan aimed at stealing citizens’ money.


Thus, the criminal association created and directed by R.V. Shpakov included: no later than 27 March 2012, the exact date and time not determined by the investigation, V.S. Pakhomov, no later than 01 June 2012, the exact date and time not determined by the investigation, Z.V. Munaev, no later than 31 December 2013, the exact date and time not determined by the investigation, L. Athanasiadou, no later than 28 February 2015, the exact date and time not determined by the investigation, A.S. Golubev, no later than 26 July 2017, the exact date and time not determined by the investigation, S.A. Matyukhin, no later than 31 August 2017, the exact date and time not determined by the investigation, E.A. Rossieva, and in the period from 31 December 2011 to 26 May 2021, the exact date and time not determined by the investigation, unidentified persons who were initiated into the common criminal plan and involved in illegal activity. After that, the above—mentioned persons, aware of the common goals of the unlawful association, with the aim of criminal enrichment, out of selfish motives, voluntarily agreed to fulfil the criminal roles assigned to them, thus joining the criminal association.

R.V. Shpakov Duties

R.V. Shpakov, as the founder of the criminal association, assigned himself the leading role in the criminal association and assigned himself the following duties:
  • Seeking the funds necessary to support the illegal activities of the criminal organisation;

  • Organisation of the process of registration and solicitation of legal entities, including: “QB Investment Company” LLC; “QB Investment Company CY Ltd”; “QB Adviszeri” LLC (INN 7703426941); “VL Consulting” LLC (INN 7706463476); “Q.Broker” LLC; “QB Capital CY LTD” (“QB Capital CY LTD”, registration number HE 221325, since 14 August 2017. renamed QCCI LTD, incorporated in the Republic of Cyprus); WLM LTD (“WLM LTD,” registration number CR — 347210, incorporated in the Cayman Islands); White Lake Management LTD.”(registration number SE — 330557, registered in the territory of the Cayman Islands); Simtelligence Company Limited (registration number 1570903, registered in the Hong Kong Special Administrative Region of the People’s Republic of China), the details of which were used to prepare model sets of various types of fictitious contracts, agreements and related documents purportedly indicative of legitimate activities, and to credit the accounts of the above — mentioned entities with funds that were received in full by the above — mentioned entities.

  • Organising the process of registration and solicitation of legal entities, including: LLC F — Experts (INN 7703439757); LLC F — Management (INN 7703448776); LLC Format Development (INN 7708243109); LLC Managing Company Moi Finansy (INN 7725682730); LLC Sintez (INN 7708270984); LLC Simon jesso (INN 7703769586); LLC, Severspetsstroy (INN 7703769579); LLC Rentinvest (INN 7703423933); LLC Profi (INN 7703447860); LLC Millhouse Invest (INN 5029252176); LLC Finbutik (INN 7731610156); LLC M4 Invest (INN 7701973890); LLC Kucisiai (INN 7708786218); LLC Kubif (INN 7703458823); LLC Kubi Credit (INN 7703740234); LLC KF Estate SPB (INN 7840472851); LLC Q.Broker” (INN 9703003668); LLC “VL Consulting” (INN 7706463476); LLC “KP Queue 4” (INN 9731017278); LLC “KP Queue 3” (INN 7704471087); LLC “KP Queue 2” (INN7702459550); LLC “K — Consulting” (INN 7703471373); LLC “K — Investment” (INN7703470098); KG LLC (INN 7701876374); F — Technologies LLC (INN 7703448769); Qubief Asset Management LLC (INN 7704835400); Indep Smart LLC (INN 7735159230); DV Technologies LLC (INN 7703442478); Vysota LLC (INN 7734371675); LLC “Ver — mont” (INN 7718304946); LLC “776” (INN 6658523875); LLC “702” (INN 7703474800); LLC “701” (INN 7703456375); LLC “168 Kvartal” (INN 7703769272); LLC “F — Technolodges” (INN 7725726949); LLC “S — Control” (5047245990); LLC “M1 Invest” (INN 7701367560); JSC RIF (INN 5047241522); JSC Financial Group QBIF (INN 7703466327); JSC Marketplace Moi Finansy (INN 9703012630); PJSC Venture Finance Centre (INN 7734682254); JSC QBIF (INN 7703399818); Argento Access Es.A.A R.L. (“Argento Access S.A R.L.”, registration number B 174898); Constance Investment LTD (“Constance Investment LTD”, registration number HE 333743); T.C.R. International LTD (“T.C.R. International LTD, registration number HE 326383), the details of which were used to carry out schematic transactions involving the withdrawal of funds from the Russian Federation, cashing out funds, purchasing real estate, financing the construction of real estate and issuing loans to legal entities and individuals affiliated with the co-conspirators;

  • Determination of goals in the development of general plans for the activities of the criminal association, as well as the performance of actions aimed at achieving the goals of the criminal association, the distribution of roles among the participants, the organisation of logistical support, the development of ways of committing and concealing the committed crimes, the adoption of security measures against the participants of the organised group, conspiracy and the distribution of funds derived from criminal activity among all participants of the criminal association;

  • Involving accomplices in the criminal association, as well as persons unaware of the criminal activity, coordinating their activities and controlling the performance of their functions; making decisions and giving appropriate instructions to the participants of the criminal association on issues related to the distribution of stolen funds, as well as organising the process of distribution of criminal proceeds, including determining the amount of remuneration to co-conspirators, as well as financing the mechanism of criminal activity;

  • Distribution of the proceeds of crime among the criminal association participants, based on each participant's assigned role, as well as his acts that contributed to the commission of the offences.

  • Planning and organisation of criminal activity, in order to reduce material and financial losses, as well as confirmation of professional skills of persons involved by R.V. Shpakov in committing crimes, selection of persons involved in the criminal community, and production of interview procedures with such persons, which had a positive effect on further joint criminal activity;

  • Organising the process of placing advertisements in the media and on the Internet about the benefits of investing money with the involvement of QBIF Investment Company LLC, which, under the guise of a professional business entity holding licences from the Central Bank of the Russian Federation to carry out brokerage activities, dealer activities, securities management activities and depository activities, was used to introduce

  • Training the members of the criminal community in special terminology, algorithms of deception, as well as the formation of the latter’s goal and motivation to take possession of as much of the client’s money as possible by creating a system of bonuses and incentives within the criminal community;

  • Conducting regular meetings, training and debriefings on the effectiveness of all structural units of the criminal organisation with all heads of structural units of the criminal organisation, as well as with some of the participants;

  • Resolve conflict situations with citizens whose rights have been violated, including informing clients about the readiness to return their attracted funds and pay the relevant profit.


At the same time, the participants of the criminal association themselves positioned the above—mentioned legal entities as organisations that were part of a single financial group “QBF” (“QBF”), the head of which was R.V. Shpakov, and, at various times during the period of the criminal association’s operation and the commission of embezzlement of funds, was also the general director and a participant in OOO Simon jesso, OOO Severspetsstroy, OOO KG, OOO 168 Kvartal, AO QBF and AO QBF Financial Group, which was a participant in OOO QBF Investment Company, the general director of OOO  QBF. Broker”, as well as a participant of LLC “F — Management”, LLC “M4 Invest”, LLC “KF Estate SPB”, LLC “F — Technologies”, LLC “S — Control” and LLC “M1 Invest”, whose accounts and details were used both for embezzlement of funds and for the subsequent implementation of schematic operations with funds for the withdrawal of funds outside the Russian Federation, cashing in of funds received from citizens, acquisition of immovable property, securities and financing of the construction of real estate objects at the expense of funds stolen from citizens. 


Thus, R.V. Shpakov was vested with the powers of both a manager and a participant of the above companies, as provided for by Federal Law №14 — FZ dated 08.02.1998 “On Limited Liability Companies”, Federal Law №208 — FZ dated 26.12.1995 “On Joint — Stock Companies”, as well as the charters of these companies.


V.S. Pakhomov Induction to the Criminal Organisation

In turn, on a date and time not specified by the investigation but no later than 27 March 2012, R.V. Shpakov initiated V.S. Pakhomov into the criminal plan and attracted him to participate in the criminal association, assigning him a leading role in the first functionally separate structural subdivision of the criminal association created on a date and time not specified by the investigation, but no later than 27 March 2012, the participants of which, during the period from 27 March 2012 to 26 May 2021, found and equipped office premises, which were positioned by the participants of the criminal association as additional branches of LLC Investment Company QBF, operating under a single brand — QBF Financial Group (“QBF”), located on the territory of various regions of the Russian Federation in offices at the following addresses: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, and Presnenskaya Naberezhnaya, 8, p. 1. 1 and Presnenskaya Embankment, 12; Ufa, Verkhnetorgovaya Ploshchad, 4; Tyumen, ul. 4; Tyumen, 74 Maksim Gorky St.; Murmansk, 82 Lenin Ave.; Kazan, 6 Spartakovskaya St.; Ekaterinburg, 1a Boris Yeltsin St.; St. Petersburg, 11 Degtyarny Per. and 64 Maloohtinsky Prospekt, Lit. B; Kaliningrad, 35 Teatralnaya St.


Pakhomov V.S., being aware of the general goals of the criminal association functioning, having the purpose of criminal enrichment out of selfish motives, agreed to fulfil the criminal role assigned to him, thus voluntarily joined the criminal association in the role of the head of the first functionally separate structural subdivision of the criminal association. At the same time, R.V. Shpakov, using his official position, gave V.S. Pakhomov the duties of leading the largest structural subdivision of the criminal association in terms of the number of persons, whose participants, as well as persons unaware of the illegal activity, persuaded citizens of the need to transfer funds and directly carried out the receipt of cash from clients or organised the process of transferring citizens’ funds to controlled accounts, i.e. the duties of committing and managing the criminal association. At the same time, Pakhomov V.S. was to independently involve other persons in illegal activity and subsequently appoint them to higher positions with more significant income.


R.V. Shpakov endowed Pakhomov V.S. with organisational and administrative functions, who, like R.V. Shpakov, Influenced other persons to perform certain actions aimed at participation in the criminal association based on the importance and authority of his position — the head of the branch network of the financial group “QBF” (“QBF”) and who at different times during the period of operation of the criminal association and theft of funds, was also the General Director of LLC QBF Estate SPB, as well as a participant of LLC KG, which was a participant of LLC Investment Company QBF, whose accounts and details were used by the participants of the criminal association in the commission of the offences, were assigned the following duties:


Pakhomov V. S. Duties:

  • Leadership of the first structural unit of the criminal organisation;

  • Finding office premises in regions of the Russian Federation, which were used to accommodate both the participants in the criminal association and persons unaware of the criminal intentions of the co-conspirators, and which were used to hold meetings and negotiations with clients, as well as to receive money from the latter;

  • Establishment organisation of activities of individual additional branches of QBF Investment Company LLC, as well as management development of the branch network of QBF Financial Group (“QBF”) as a whole;

  • Training of the participants of the first structural subdivision of the criminal community in special terminology, algorithms of deception, as well as the formation of the latter’s goal and motivation to take possession of as much money of clients as possible utilizing observing a system of bonuses and incentives within the structural subdivision of the criminal community;

  • Conducting regular meetings and training to check the effectiveness of the activities of the participants of the first structural unit of the criminal organisation; coordination and control over the actions of the participants of the first structural subdivision of the unlawful association, as well as persons unaware of the illegal plan involved in the activities of this structural subdivision;

  • Ensuring the concealment of ongoing criminal activity by introducing new elements to disguise the true objectives of the participants in the criminal association with the knowledge and consent of the leader of the criminal association;

  • Direct personal participation in advertising, as well as organisation of placing advertisements in the mass media and the Internet about the benefits of investing money with the involvement of QBIF Investment Company LLC, which, under the guise of a professional business entity that had licences from the Central Bank of the Russian Federation for brokerage activities, dealer activities, securities management activities and depository activities.

  • Encashing in additional branches of QBIF Investment Company LLC the funds received from clients for the purpose of subsequent transfer to R.V. Shpakov for further distribution among the participants of the criminal association;

  • Organising the process of producing fictitious reports for clients on the management of the securities portfolio, as well as reports on client accounts for securities transactions and transactions related to it, and sending such reports to clients;

  • Making decisions and giving appropriate instructions to participants in the criminal association on matters related to the distribution of stolen funds, as well as organising the distribution of criminal proceeds, including determining the amount of remuneration to persons unaware of criminal intentions and financing the illegal mechanism;

  • The implementation of measures to conceal offences and avoid possible criminal or other liability by giving the appearance of legality to activities that were, in fact, criminal in nature;

  • Organisation of reports that reflected the number of clients and the amount of money they received.

  • Resolving conflict situations with citizens whose rights have been violated, including by informing clients about the readiness to return their attracted funds and pay the relevant profit;

  • Resolving problematic situations that arose during inspections and supervisions by the regulator, as well as developing an algorithm for interaction with the staff of the Central Bank of the Russian Federation;

  • taking measures to disguise the illegal activities of the criminal association to successfully and systematically operate in a manner that resulted in the stable receipt of criminal income, as well as to increase conspiracy measures to conceal the illegal activities of the criminal association from being exposed by law enforcement officials

  • Performing other actions aimed at the smooth functioning of the illegal scheme of the criminal association.

Matyukhin S.A, Munaev Z.V., A.S. Golubev inductions to the Criminal Organisation

The members of the separate structural subdivision of the criminal association led by V.S. Pakhomov, who, among other things, was authorised as the head and participant of LLC “KF Estate SPB” and LLC “KG”, respectively, as provided for by Federal Law №14 FZ dated 08.02.1998 “On Limited Liability Companies” and the charters of these companies, had the following duties:


Matyukhin S.A., appointed in accordance with Resolution №38 of the Sole Participant of QBIF Investment Company LLC dated 25 July 2017 as the General Director of the Company since 26 July 2017, was the sole executive body performing organisational, administrative and economic functions, managing the Company’s day — to — day operations, which, in accordance with Federal Law №14 — FZ “On Limited Liability Companies” dated 08.02.1998 and the Charter of QBIF Investment Company LLC, was entitled, inter alia: to act on behalf of the Company without a power of attorney, including to represent its interests and make transactions; to issue orders on the appointment of employees to the position of the CEO of QBIF Investment Company LLC.


Munaev Z.V. coordinated the activities of the participants of the criminal association, as well as persons unaware of the criminal intentions of the co—conspirators, located in one of the offices of the QBF group at the following address: 8 Presnenskaya Naberezhnaya Naberezhnaya, bldg. 1; training of the participants of the first structural unit of the criminal association in particular terminology, algorithms of deception, as well as formation of the latter’s goal and motivation to take possession of as much money of clients as possible by observing a system of bonuses and incentives within the structural unit of the criminal association; holding regular meetings, trainings and summaries of the effectiveness of the activities of the participants of the first structural unit of the criminal association; coordination and control over the actions of the participants of the first structural unit of the criminal association.


A.S. Golubev carried out: finding office premises in the regions of the Russian Federation, which were used by the participants of the criminal association and persons unaware of the criminal intentions of the co-conspirators to hold meetings and negotiations with clients, as well as to receive money from the latter; organising the activities of the participants of the criminal association and persons unaware of the criminal intentions of the coconspirators located in the offices of the QBF group at the following addresses: St. Petersburg, Degtyarny per. St. Petersburg, Degtyarny per, 11, lit. “B”, and Maloohtinsky Prospe, 64, lit. “B”; holding meetings, seminars, and training with the participants of the criminal association, as well as with persons unaware of the criminal intentions of the co-conspirators, aimed at improving the skills of working with clients to attract as much money as possible; ensuring the concealment of illegal activities by introducing new elements of veiling the actual goals of the participants of the criminal association with the knowledge and consent of the head of the criminal association; encashment in additional branches of OOO “QBF” (“QBF”) and “QBF” (“QBF”) at the addresses: St. Petersburg, Degtyarny Lane, 11, lit. “B”, and Maloohtinsky Prospekt. Unidentified co-conspirators carried out the production of client agreements on the provision of direct access services to international stock markets, agreements on the provision of trust management services in accordance with the agreement on the provision of direct access services to global stock markets, trust management agreements, service agreements, service agreements, brokerage services agreements (adhesion agreements), OTC option agreements, as well as other documents, using for x



Linda Athanasiadou/Kovalanko and NOA Circle's voluntary acceptance to join the QBF Criminal organisation, having full knowledge of its illegal activities and fraudulent intentions.


Also, on a date and time not specified by the investigation but no later than 31 December 2013, Shpakov R.V., using his official position, initiated the criminal intent and involved Athanasiadou L. in the criminal association, assigning her a leading role in the second functionally separate structural subdivision of the criminal association, created on a date and time not specified by the investigation, but no later than 31 December 2013, the participants of which were located in various office premises in Moscow at an unspecified period of time, including from an unspecified time until 26 May 2021 at the following address: 8 Presnenskaya Naberezhnaya Embankment, Moscow, p. 1. 1.


Athanasiadou L., being aware of the general goals of the criminal association, with the aim of criminal enrichment, out of selfish motives, agreed to fulfil the criminal role assigned to her, thereby voluntarily joining the criminal association in the role of head of the second functionally separate structural subdivision of the criminal association, thereby entrusting Athanasiadou L. with the following duties:
  • Leadership of the second structural subdivision of the criminal organisation;

  • Seeking organisations, nominee managers, and representatives acting under a power of attorney in the territory of foreign countries, as well as legal support for these organisations, including: “QB Capital CY LTD (“QB Capital CY LTD”); WLM LTD (“WLM LTD”); White Lake Management LTD (“White Lake Management LTD”); Simtelligence Company Limited (“Simtelligence Company Limited”); Argento Access S.A.RL. (“Argento Access S.A R.L.”); Constance Investment LTD (“Constance Investment LTD”); T.C.R. International LTD (“T.C.R. International LTD), the details of which were used in the production of standard sets of various types of fictitious contracts, agreements and accompanying documents purportedly indicative of legitimate activities, as well as for the crediting of funds received from clients to the accounts of these organisations;

  • Opening and maintaining accounts for both legal entities registered in the territory of the Russian Federation and non—residents used to embezzle funds, making transit transfers of funds received from citizens to accounts opened with credit institutions located in the territory of the Russian Federation and in various foreign countries, including Principality of Liechtenstein; Republic of Kosovo; Republic of Armenia; Republic of Turkey; Republic of South Africa; Cayman Islands; Republic of Vanuatu; Union of Comoros; United States of America; Republic of Poland; United Kingdom of Great Britain and Northern Ireland;

  • Scheme operations with citizens’ money, the ultimate goal of which was to withdraw money outside the Russian Federation, cash in, purchase immovable property and securities with the money stolen from citizens, and finance the construction of real estate;

  • Coordination and control over the actions of the participants of the second structural unit of the criminal association, as well as persons involved in the activities of this structural unit who are unaware of the illegal plan of the accomplices;

  • Ensuring the concealment of ongoing criminal activity by introducing new elements to disguise the true objectives of the participants in the criminal association with the knowledge and consent of the leaders of the criminal association;

  • Making decisions and giving appropriate instructions to participants of the criminal association on issues related to the distribution of stolen funds, as well as organising the distribution of criminal proceeds, including determining the amount of remuneration to persons unaware of the criminal intentions of accomplices and financing the illegal mechanism;

  • The implementation of measures to conceal offences and evade possible criminal or other liability by giving the appearance of legality to the illegal activity being carried out;

  • Taking measures to disguise the illegal activities of the criminal association in order to successfully and systematically operate in a manner that resulted in the stable receipt of criminal income, as well as to increase conspiracy measures to conceal the illegal activities of the criminal association from being exposed by law enforcement officers;

  • Performing other actions aimed at the smooth functioning of the criminal scheme of the criminal association.


The members of the separate structural subdivision of the criminal association led by Athanasiadou L. had the following responsibilities:

The unidentified co-conspirators sought and provided legal support in the territory of foreign countries for organisations, managers, and representatives acting under a power of attorney, including: “QB Capital CY LTD; WLM LTD; White Lake Management LTD; Simtelligence Company Limited; Argento Access S.A R.L. (“Argento Access S.A R.L.”); Constance Investment LTD (“Constance Investment LTD”); T.C.R. International LTD (“T.C.R. International LTD), NOA CIRCLE LTD (NOA CIRCLE LTD) preparation of various documents on behalf of these organisations, allegedly testifying to their legitimate activities, as well as the documents necessary for the crediting of funds received from clients and the subsequent implementation of schematic transactions with funds for the withdrawal of funds outside the Russian Federation; cashing in of funds received from citizens, acquisition of real estate and securities at the expense of funds stolen from citizens; financing the construction of the real estate.



Rossieva E.A. induction to the criminal organisation

Also, on a date and time not specified by the investigation but no later than 31 August 2017, Shpakov R.V., using his official position, initiated Rossieva E.A. into the criminal intent and involved her in the criminal association, assigning her a leading role in the third functionally separate structural subdivision of the criminal association, created on a date and time not specified by the investigation, but no later than 31 August 2017, the participants of which, between 31 August 2017 and 26 May 2021, were located in the office of QBF Group at 8 Presnenskaya Naberezhnaya Street, Moscow, p. 1. 1.


E.A. Rossieva, being aware of the general goals of the criminal association, having the purpose of criminal enrichment out of selfish motives, agreed to fulfil the criminal role assigned to her, thereby voluntarily joining the criminal association in the role of the head of the third functionally separate structural subdivision of the unlawful association, and her duties were as follows:

  • Leadership of the third structural unit of the criminal organisation;

  • attracting accomplices to the criminal association, as well as persons unaware of the criminal activity, coordinating their activities and controlling the fulfilment of their functions;

  • Organisation of the process of registration and search for legal entities, nominal general directors, participants, as well as representatives acting under a power of attorney, whose details (legal entities) were used in the preparation of standard sets of various types of fictitious contracts, agreements and related documents, ostensibly testifying to legitimate activities, for crediting funds received from clients, as well as for the implementation of scheme operations aimed at withdrawing funds outside of Russia LLC QBIF Investment Company; LLC QBIF Adviser; LLC VL Consulting; LLC Q.Broker; “F — Experts” LLC; “F — Management” LLC; “Format Development” LLC; “My Finance Management Company” LLC; “Syntez” LLC; “Simon jesso” LLC; “Severspetsstroy” Ltd; LLC Rentinvest; LLC Profi; LLC Millhouse Invest; LLC Finbutik; LLC M4 Invest; LLC Kucisiai; LLC Kubifef; LLC Kubi Credit; LLC KF Estate SPB; LLC Q.Broker; VL Consulting LLC; KP Queue 4 LLC; KP Queue 3 LLC; KP Queue 2 LLC; K — Consulting LLC; K — Investment LLC; KG LLC; F — Technologies LLC; Qubief Asset Management LLC; Indep Smart LLC; DV Technologies LLC; Vysota LLC; Ver — mont LLC; 776 LLC; 702 LLC; 701 LLC; 168 Quarter LLC; F — Technologies LLC; LLC S — Control; LLC M1 Invest; JSC RIF; JSC QBIF Financial Group; JSC Marketplace Moi Finansy; PJSC Venture Finance Centre; JSC QBF; “QB Capital CY LTD; WLM LTD; White Lake Management LTD; Simtelligence Company Limited;

  • Organisation and personal participation in legal support and representation of legal entities used in criminal activities in various state bodies and courts of general jurisdiction;

  • Organisation of the opening with receipt of “bank—client” software and further servicing of accounts of legal entities used in criminal activities;

  • Development of an algorithm for interaction with employees of the Central Bank of the Russian Federation who carried out checks and supervisions, as well as a mechanism for providing these employees with information and documents necessary to give the appearance of legality to criminal activity and prevent the illegal activity of the criminal association from being exposed;

  • Ensuring the concealment of ongoing illegal activity by introducing new elements to disguise the true objectives of the participants in the criminal association with the knowledge and consent of the leader of the criminal association;

  • Making decisions and giving appropriate instructions to participants of the criminal association on issues related to the distribution of stolen funds, as well as organising the distribution of criminal proceeds, including determining the amount of remuneration to persons unaware of the criminal intentions of accomplices and financing the illegal mechanism;

  • The implementation of measures to conceal offences and evade possible criminal or other liability by giving the appearance of legality to the illegal activity being carried out;

  • Taking measures to disguise the illegal activities of the criminal association in order to successfully and systematically operate in a manner that resulted in the stable receipt of criminal income, as well as to increase conspiracy measures to conceal the illegal activities of the criminal association from being exposed by law enforcement officials;

  • Implementation of other actions aimed at the smooth functioning of the criminal scheme.


The members of the separate structural subdivision of the criminal association, headed by E.A. Rossieva, were assigned the following duties:

The unidentified co-conspirators registered and sought legal entities, nominal general directors, participants, and representatives acting under a power of attorney, whose details (legal entities) were used to prepare model sets of various types of fictitious contracts, agreements, and related documents purportedly indicating legitimate activities, to credit funds received from clients, and to carry out schematic operations aimed at withdrawing funds from clients.


Additional Roles and Duties in the Criminal Organisation bye the heads of each subdivision of the Criminal Association Linda Athanasiadou, Matyukhin S.A, Munaev Z.V., A.S. Golubev

In addition, the first functionally separate structural unit of the criminal association, in the period from 31 December 2011 to 26 May 2021, involved persons unaware of the criminal intentions of the participants of the unlawful association, who, without affecting them in the criminal association and without initiating them into the general illegal plan, were assigned the following functions and responsibilities based on their professional qualities:

  • Communicating with clients, both in person and by telephone, about the benefits of investing money; receiving from citizens the following functions and responsibilities In the second functionally separate structural unit of the criminal association, between 31 December 2011 and 26 May 2021, persons unaware of the criminal intentions of the participants in the criminal association were recruited, without involving them in the criminal association and without initiating them into the general illegal plan, were assigned the following functions and duties based on their professional qualities:

  • Preparing and submitting to tax authorities and credit institutions various documents necessary for the registration of legal entities in the third functionally separate structural unit of the criminal association in the period from 31 December 2011 to 26 May 2021, persons unaware of the criminal intentions of the participants in the criminal association were recruited, who, without involving them in the criminal association and without initiating them into the general illegal plan, were assigned the following functions and duties based on their professional qualities: production of various documents necessary for the registration of legal entities involved in the embezzlement of funds, as well as documents for the registration of legal entities involved in the embezzlement of funds.


The QBF criminal association, created by R.V. Shpakov and led by Linda Athanasiadou, Matyukhin S.A, Munaev Z.V., and A.S. Golubev, was characterised by

  • Cohesion and stability, expressed in the stability and constancy of the leadership of structural units, constancy of the general method of committing theft;

  • Directed at committing certain crimes — embezzlement of property of citizens, the essence of which was the conclusion of various contracts and agreements on behalf of controlled organisations acting under the guise of brokerage companies, receipt of funds from clients and their subsequent embezzlement;

  • Stable structure within the criminal community, the existence of certain rules of behaviour within the criminal community with specific sanctions for non — non-compliance, which allowed the maintenance of strict discipline and subordination in the structural units in the commission of crimes and the distribution of criminal profits;

  • Distribution of roles in the commission of crimes among the participants of the criminal association, as a result of which, in the systematic commission of crimes, the participants acted in a coordinated and organised manner;

  • The use of sophisticated methods of committing and concealing offences, the use of a system of conspiracy and protection from exposure;

  • The time—consuming preparation for the commission of the crimes, expressed in the search for legal entities to give the appearance of legality of criminal activity, renting premises for the location of offices, purchasing office equipment, telephones and specialised equipment, selecting and training co-conspirators in the ways of committing crimes, and developing methods and techniques of deception;

  • The development and application of a single value and normative motivation, the basis of which was material incentives for members of the criminal association depending on the number of defrauded citizens and the amounts received from clients in the commission of crimes;

  • Distribution of criminal proceeds following the position of each participant in the hierarchy of the unlawful association, expressed in the allocation of a set percentage of the money received as a result of the commission of crimes by the participants of the criminal association to the organiser, heads of structural subdivisions, managers, as well as to persons unaware of the criminal intentions of the participants of the criminal association.


The consciousness and will of all accomplices in the offences encompassed circumstances relating not only to their criminal act but also to the acts of other accomplices. This was expressed in the following:

  • All members of the criminal association united based on common selfish goals and criminal intent aimed at obtaining systematic profits from the embezzlement of funds;

  • The actions of the members of the criminal association were coordinated and interconnected with each other and aimed at achieving a single illegal result;

  • Each of the participants was aware of the structure of the criminal association, of the actions performed by each member of the association, and hoped for their successful completion since the illegal actions of some members of the criminal association, without the successful completion of the actions of other members of the unlawful association, would not lead to the final illegal result and goals desired by the participants of the criminal association.


In addition, the participants of the criminal association determined in advance possible obstacles for themselves in committing a socially dangerous act, and, above all, in part concerning the exposure and detention of these persons by the police, in connection with which they:

  • Committed the offences with the same offences;

  • The participants of the criminal association conducted telephone conversations and text messages among themselves in a veiled form, hiding the true motives and goals of the criminal association from outsiders;

  • prepared alibis for themselves in advance (i.e. in case of detention by police officers, the accomplices had to say that they worked for an organisation that carried out legitimate financial and economic activities and were unaware of the criminal nature of these activities).


The creation and management of a criminal association and its structural subdivisions are initially conditioned by the selfish purpose of committing multiple serious crimes and obtaining as much criminal income as possible. The search for various legal entities for the commission of illegal activity, both in the territory of the Russian Federation and in the territory of different foreign countries, is conditioned by the need to give the appearance of legitimate business activity to their criminal actions. The presence of an organisational structure of an unlawful association characterises its hierarchy. It is necessary to achieve cohesion, stability, observance of strict discipline and subordination in committing crimes.



The unlawful activities of the criminal association described above continued for a long time, and its participants intended to continue their unlawful actions in the future. The termination of the unlawful activities of this criminal association occurred on 26 May 2021, not depending on the will of its participants, but due to the suppression of these activities by law enforcement agencies and the detention of the active participants of the criminal association.


Thus, the participants committed the leadership of a structural subdivision included in a criminal association (criminal organisation), participation in a criminal association (criminal organisation), committed by a person using his official position, created and directed by Shpakov R.V. during the period from 31 December 2011 (until the time when police officers suppressed the criminal activity) 26 May 2021 (until police officers stopped the illegal activity), the participants of which committed 151 grave crimes — fraud, i.e. theft of other people’s property by deception and abuse of trust, committed by an organised group, in large and especially large amounts, against the following citizens:


Kozlovskaya N.S., Polezhaev A.V., Bulin G.V., Petrov A.N., Sapozhkov N.G., Shapran A.V., Polyakova I.E., Shut O.N., Ptitsyn A.A., Vedernikova V.V., Tretiukhin A.N., Sazonov E.O., Bubnov N.A., Khlopyev V.N., Khlobyshev A.A., Eremin V.A., Lopatin M.I., Lomakina O.S., Kozlovskaya A.E., Levchenko V.V., Golovach A.V., Bruskov A.N., Egudkin B.A., Sasovskaya O.B., Sazonova I.O., Dyachenko E.V., Ermakov V.V., Cherkasov V.Y., Mullo T.I., Maslov Y.V., Velichko S.A., Gumenyuk D.V., Kholodkov S.V., Grigoriev A.B., Nikitchenko N.V., Zinoviev S.D., Lomov S.N., Nemtsev V.V., Novitskiy A.G., Vavilova L.A., Vetrova N.S., Bozhko O.B., Batalova M.R., Romanovsky A.A., Erofeev D.V., Borzenkov M.I., Baiguzina S.A., Levina G.V., Naumova E.G., Danilov A.V., Krechetova T.O., Ostovich E.N., Drobin V.M., Kilo V.A., Emirgamzaev V.E., Kosorukov O.A., Lyutov A.V., Bokov O.M., E.N. Kostovskaya, V.V. Morozov, A.V. Voropaev, S.M. Kishilov, I.L. Bogomolov, B.G. Kosovsky, I.L. Semenov, L.L. Semenova, M.A. Bolshov, Dianov E.G., Gubanov A.V., Vorobyov — Desyatovsky N.V., Galachyan K.G., Chekmareva E.F., Birnov M.A., Potapov A.V., Bosak L.V., Paramonov S.V., Grif S.V., Andreev R.V., Ivanov K.A., Petrov P.E., Baskova T.V., Mishin I.Y., Nazarenkov A.V., Burmistrov V.N., Mishin Yu, Toloknov D.Y., Kim A.L., Troshkova M.S., Ganeva E.P., Podgornaya I.A., Kovin A.P., Zatsarinsky D.E., Mudrogin A.V., Ruchev A.V., Donskov I.V., Nosenko M.N., Mitroshin N.G., Batuev A.A., Drapesa N.V., Kormilitsyn S.V., Podolnaya A.V., Koncherova V.S., Koreshkov V.S., Borisov M.A., Tokareva A.A., Malinin D.I., Kulikova A.V., Kuzmenko K.N., Shilov A.V., Voropaev A.A., Gorbunov R.V., Shlykov A.K., Kuryatnikov L.A., Demidkova T.V., Grushanina I.S., Drapez M.I., Pilenitsyn K.A., Kamzolov E.A., Elkin P.M., Bondarenko I.V., Vasyunin A.P., Grekov S.A., Borodin V.V., Chernova Zh, Ivanov A.S., Silin D.S., Sbitnev K.I., Kushkov S.V., Pavlenko I.V., Smirnov A.V., Bazaev M.A., Trishin A.A., Mitkin D.V., Sotnikov V.P., Korolskiy V.V., Trukhmeneva S.V., Alekseev F.V., Rodnevskaya M.Y., Savin A.V., Medvedev R.V., Babelyan S.A., Kalinin S.V., Galaktionov S.V., Frolov Y.A., Pilin D.A., Merts A.N., Astakhov A.B., Popov P.V., Tregubov A.V., Mayorova G.V., for a total amount of RUB 1,993,883,054.93.


The specific criminal activity of the participants in the criminal association established under the above circumstances was expressed in the following:

  1. 28.11.2013 committed embezzlement of funds of Natalia Stepanovna Kozlovskaya in the amount of 594,000 rubles, i.e. on a large scale, by deceit and breach of trust, consisting in creating in the latter, as a client of the QBF group organisation, a false appearance of the possibility of obtaining a high income, as a result of which the client concluded a service agreement for the provision of a trading account with the amount of funds in it equal to the amount of funds received from the client (brokerage service agreements), and provided the co —-conspirators with his funds in the specified amount for trust management. These agreements were concluded for direct access to trading on stock and derivatives markets. Still, the participants in the criminal association knew that their obligations to the client to pay the funds were unfulfilled since the information about the brokerage activities of the organisation with which it had concluded the agreement for direct access to international stock markets was false. The co-defendants did not use the money received from the client under this agreement for the purposes specified in the agreements but stole it and used it at their own personal discretion;

  2. In the period from April 2012 to 11.02.2014, committed embezzlement of funds of Andrey Vyacheslavovich Polezhaev in the amount of 68,477,000 roubles, i.e. on a particularly large scale, using deceit and breach of trust, which consisted in creating a false appearance of a high-income opportunity for the latter, as a client of the QBF group organisation, as a result of which the client entered into a service agreement for the provision of a trading account with the amount of funds in it equal to the amount of funds received from the client (brokerage service agreements), and provided the co-conspirators with his funds in the specified amount for trust management. These agreements were concluded for direct access to trading on stock and derivatives markets. Still, the participants in the criminal association knew that their obligations to the client to pay the funds were unfulfilled since the information about the brokerage activities of the organisation with which he had agreed to provide direct access to international stock markets was false. The co-defendants did not use the money received from the client under this agreement for the purposes specified in the agreements but stole it and used it at their OWN PERSONAL discretion;

  3. During the period from 23.01.2014 to 29.04.2014, committed embezzlement of Gennady Viktorovich Bulin’s funds in the amount of 815,000 rubles, i.e. on a large scale, by deceit and breach of trust, consisting in creating in the latter, as a client of the QBF group organisation, a false appearance of the possibility of obtaining a high income, as a result of which the client concluded a service agreement for the provision of a trading account with the amount of funds on it equal to the amount of funds received from the client (brokerage service agreements), and also provided the co—conspirators with their funds. These agreements were concluded for direct access to trading on stock and derivatives markets. Still, the participants in the criminal association knew that their obligations to the client to pay the funds were unfulfilled since the information about the brokerage activities of the organisation with which he had agreed to provide direct access to international stock markets was false. The co-defendants did not use the money received from the client under this agreement for the purposes specified in the agreements but stole it and used it at their own personal discretion;

  4. During the period 07.02.2014 to 20.05.2014, committed embezzlement of funds of Alexey Nikolayevich Petrov in the amount of 6 255 329,07 rubles, i.e. on a particularly large scale, by deceit and breach of trust, consisting in creating in the latter, as a client of the organisation of the group “QBF” (“QBF”), a false appearance of the possibility of obtaining a high income, as a result of which the client entered into a service agreement for the provision of a trading account with the amount of funds in it equal to the amount of funds received from the client (brokerage service agreements), and provided the co—conspirators with his funds in the specified amount for trust management. These agreements were concluded for direct access to trading on stock and derivatives markets. Still, the participants in the criminal association knew that their obligations to the client to pay the funds were unfulfilled since the information about the brokerage activities of the organisation with which he had agreed to provide direct access to international stock markets was false. The co-defendants did not use the money received from the client under this agreement for the purposes specified in the agreements but stole it and used it at their discretion.

  5. ………. 822 pages describing each specific case of the QBF Fraud Case were excluded... a new dedicated space on our website will be created soon.



References:

criminal case No.                                                            12001450007000902

criminal case No.                                                            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




 

  1. Scheme Overview:

  2. Key Players: Roman Shpakov: 

  3. Key Players: Linda Athanasiadou:

  4. Modus Operandi:

  5. Deceptive Practices:

  6. The extent of the Scam:

  7. Unravelling the Scam:

  8. Legal Consequences:

  9. Consequences: 

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:


  1. Formation of Criminal Association: 

  2. Methodology: 

  3. Embezzlement Process: 

  4. Roles and Duties: 

  5. Criminal Activities and Impact: 

  6. Termination of Activities: 


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.




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