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  • Writer's pictureSun Of Justice

Unpacking the QBF Fraud Case: (Part 2) A Comprehensive Analysis Z.V. Munaev Testimony's

Updated: May 14


Pakhomov on the left - Zelimkhan Munaev on the righ
Pakhomov on the left - Zelimkhan Munaev on the righ

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. Munayev, given by him as a witness, suspect, accused (the criminal case on the accusation of Z.V. Munayev 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


  • According to which he testified that in 2010 when he was a student at a financial academy, he received an invitation for a job on the Internet from the website hh.ru, and then was interviewed for the position of financial adviser and was employed by Qubi Finance Ltd.

  • Arseny Rukhov conducted the interview. At that time, Qubey Finance LLC had 5–6 sales departments, a lot of employees, and a high staff turnover.

  • The office was in the Tropicana business centre at 24 Krasnaya Presnya Street, Krasnaya Presnya, Moscow.

  • Many of the heads of sales departments were acquaintances of R.V. Shpakov, reporting to him personally, and he (R.V. Shpakov) was one of the co-founders of the company, along with Sergey Lvovich Kuzin and Nikolai Mikhailovich Modin.

  • The company's beneficiary was Kuzin Sergey, who had 50% or more of the authorised capital. R.V. Shpakov and N.M. Modin had the remainder of the official capital in approximately equal shares.

  • His (Z.V. Munaev) direct supervisor was Arseny Rukhov, and he (Z.V. Munaev) performed his duties, which included receiving from A. Rukhov a client base for ringing, making calls, telephone negotiations, holding meetings in the office of the company, concluding contracts, attracting and further support of clients.

  • Qubey Finance LLC was licensed by the Federal Financial Markets Service and carried out activities in the securities market, mainly brokerage and trust management. In 2011, Cube Finance moved to a new office-mixed-use complex, “City of Capitals”, at the following address: 8 Presnenskaya Naberezhnaya Street, Moscow, building 1, 12th floor.

  • During the year, the work system did not change; the staff increased and was regularly renewed. He (Z.V. Munaev) and some other colleagues, such as Vladimir Pakhomov, Avetis Vartanov, and Maxim Yudin, were promoted to the positions of sales department heads, and they all reported to R.V. Shpakov as head of the sales office. In 2011, cash turnover started, i.e., receiving and giving money to clients in cash.

  • Transactions with clients were speedy; withdrawal then took 1–2 weeks. As explained to them (employees), cash turnover was carried out by direct bank transfer from the client’s balance and collection services when paying cash in the company’s office.

  • The cash was accumulated by Duntonse and delivered to the office at Shpakov's request. R.V. Duntonse was associated with a Russian company, Freedom Finance, headed by Timur Turlov. When receiving money from clients in cash, a receipt was made out on the Duntonse form or handwritten in free form. In this receipt, the signatory on the Duntonse side was an ordinary employee of this company acting under a power of attorney.

  • On the side of Qubey Finance LLC, the signatories were R.V. Shpakov and Frolov. This activity was not part of the standard activities of a professional securities market participant supervised by the Central Bank and the FFMS. The Russian investment legislation in force did not formalise it at the time.

  • In 2012, the management of QB Finance (Shpakov, Kuzin, Modin) established QB CAPITAL CY LTD (Cyprus), which entirely fulfilled the role of Duntonse and replaced it in servicing clients and transactions.

  • As Timur Turlov owned Duntonse, Shpakov paid Turlov T. for the services his (Turlov T.) company, Duntonse, provided to QB Finance’s clients. To reduce costs and consolidate financial flows under his management, a company, “QB CAPITAL CY LTD,” was established.

  • This company was acquired by QB Finance management from Cliffe Law Company under the name Asheraxe LTD, and Cliffe provided the first bank servicing this organisation, Piraeus Bank.

  • Neither QB CAPITAL CY LTD nor Duntonse had a licence to carry out brokerage or any other securities activity during their entire period of operation due to the licence held by the Russian entity QB Finance Ltd.

  • The company “QB CAPITAL CY LTD” was controlled by R.V. Shpakov, and, as he subsequently learned, R.V. Shpakov was its sole founder. Shpakov, Modin and Kuzin also set up similar companies called “QB Financial Service QB” and “QB CAPITAL MANAGEMENT LTD” in the Republic of Cyprus. The organisation “QB Financial Services QB” was intended for the activity of a new Kyiv branch under Arseniy Rukhov's management. QB CAPITAL MANAGEMENT LTD was intended for non-Moscow clients of the branch network in the Russian Federation territory.

  • The “QB CAPITAL MANAGEMENT LTD” general director was appointed as “nominee”. “QB Financial Services QB” and “QB CAPITAL MANAGEMENT LTD” were used to sign client contracts, and client funds were attracted to the companies’ bank accounts. Linda “led” these companies and Shpakov R.V. These companies had no licences to deal with securities.

  • The similarity in the name was necessary to show that the companies belonged to the same group. In 2013, Kuzin Sergey and Modin Nikolay left, and the founders of QBF LLC and Shpakov R.V. bought out their shares. Around the same year, QBF Asset Management LLC was founded by Shpakov R.V. alone.

  • This company managed funds. In the same year, the first QBF Real Estate fund was launched and formed, related to the construction of the Gribovsky Les LCD in Odintsovo, where the developer was Simon Jesso LLC, affiliated to R.V. Shpakov, and which was sold by the sales department of QBF Finance LLC as one of the group companies.

  • In 2013, R.V. Shpakov, directly or with the help of colleagues, became acquainted with NOA CIRCLE, a certified provider of corporate, legal and accounting services in Cyprus, of which Linda and Apollo Athanasiadou were the representatives on behalf of R.V. Shpakov, Vladimir Pakhomov and Dmitry Lepeshkin travelled to Cyprus to negotiate with the above persons.

  • “NOA CIRCLE” took over the maintenance and servicing of all clients of “Duntonse” and transferred to “QB CAPITAL CY LTD”, “QB CAPITAL MANAGEMENT LTD”, “QB Financial Services” and new clients of “QB CAPITAL CY LTD”, their financial operations, maintenance of company accounts, submission of financial statements of the organisations.

  • Bank-client and remote access keys were at Shpakov R.V. The system of working with clients in non-cash and cash settlements remained the same. Subsequently, he (Z.V. Munaev) learnt that the clients’ funds received in cash were not correctly entered into the settlement accounts of “Duntonse” and “QB CAPITAL CY LTD”.

  • The clients were provided balance reports reflecting the total investment amount. Shpakov R.V. had in his assistants employees of Freedom Finance and Duntonse, who generated and provided reports on QB CAPITAL CY LTD transactions and passed them to Shpakov R.V. One of his assistants was Igor Klyushnev, who was aware of the interaction between Duntonse and QB CAPITAL CY LTD, was not directly involved in the preparation of reports, but, according to Shpakov R.V., was related to them.

  • Maxim Povalishin, an employee, played a primary role in preparing the reports, and Igor Klushnev was involved in their preparation. Both Povalishin and Klushnev ceased to have anything to do with the compilation of the reports by 2018, as Simtelligence was already a company in 2019.

  • After the liquidation of “QB CAPITAL CY LTD” and the transfer of its rights and obligations to “SIMTELLIGENCE COMPANY LIMITED”, the report writers remained the same, and the essence of the reports is the same.

  • After their departure, from the point of view of the reports' content, R.V. Shpakov played a significant role in their formation, and Linda Athanasiadou may have been aware of it in some part. Regarding the form of the reports and their distribution, this was handled by Yuri Orlov, the IT specialist.

  • For some clients, the sales staff did the most detailed analysis of the reports, their content, the consistency of positions and values with the actual market data, the change of these positions and prices through months and years, the impact of each position on the shift in the portfolio value and profit/loss of each client, and the consistency of the behaviour of this portfolio with the actual behaviour of the market and indices.

  • Linda and Apollon Athanasiadou had many personal and professional connections in Cyprus, both in the financial sector, the law firm and the regulator. Moreover, they had more excellent expertise and knowledge of the operating environment of local jurisdiction companies in the international financial markets.

  • In addition, Apollon Athanasiadou is a relative of the President of Cyprus (as of 2013 and after).

  • NOA provided full financial and legal support to R.V. Shpakov’s Cypriot and later other foreign companies, reporting to regulators and conducting audits.

  • Apollo was the CEO of NOA, and Linda was the company's employee (representative).

  • Linda Athanasiadou also performed orders for R.V. Shpakov in the banks servicing his company.

  • Linda had the necessary keys, access to the “bank-client” of the companies “QB CAPITAL CY LTD”, “QB CAPITAL MANAGEMENT LTD”, “QB Financial Services” for herself and other persons, and other necessary documents to perform the actions assigned by R.V. Shpakov.

  • According to Linda, when making transfers, she always provided the banks with the client’s contracts with the Cypriot and Russian licensed companies to confirm the activity's legality.

  • As a result of an agreement between R.V. Shpakov and Linda, QBF Investment (later renamed Constance) was established in 2014. Its founder was R.V. Shpakov, its head (general director) was Linda Athanasiadou, and she carried out all Constance's financial and economic activities.

  • Constance’s financial operations were unrelated to Shpakov’s previous companies; they were subject to different terms and conditions, had various products and services, and attracted new clients, including Russian clients.

  • During this period, the Russian company’s main focus was foreign markets. Two contracts were concluded with the client: with Russian and foreign organisations.

  • On the Russian side, the contract was concluded with QB Finance LLC (since 2016-QBIF LLC)-Asset Management Assignment (Trust Management Agreement), or Consultancy Management Agreement; the second contract with the client-Agreement on Providing Access to the International Securities Market, which was concluded on behalf of the foreign organisation (before 2013 it was Duntonse, After 2013-QB CAPITAL CY LTD).

  • The funds were transferred directly under the second contract to the settlement account of the organisation “Duntonse”, opened in “Piraeus” bank in Cyprus.

  • Then, the clients’ funds were transferred: in the case of “Duntonse”-to the accounts of the top brokers, in particular, other companies of the “Freedom Finance” group, as well as “LEK Securities” and other brokers, and they already carried out operations on the exchange trading accounts, and in the case of “QB CAPITAL CY LTD”-to the accounts of “Duntonse” and other brokers.

  • This whole scheme was signalled to the clients after the contract. Clients were given receipts and cash receipts/expenditure vouchers from the foreign organisation with which the client had a contract. Withdrawals were made to the client’s current accounts.

  • The system of settlement with the client was as follows: money was transferred directly from individuals and legal entities to the Duntonse account, then oral and written orders were carried out, both from clients and portfolio managers of Kubi Finance under the direction of R.V. Shpakov to execute transactions on trading accounts.

  • Every month, clients receive reports from “Duntonse” on the results of financial transactions and, depending on their desire, could request either partial or complete withdrawal of funds or make pre-investment.

  • When clients’ funds were transferred to the accounts of Duntonse, and then QB Capital CY LTD, some portion was accurately channelled to the trading accounts of the top brokers and transactions were executed.

  • Before 2015, a portion of more than 50 per cent of client funds was directed to the top brokers’ accounts, and After 2015, less than 50 per cent was referred to the top brokers’ accounts.

  • However, the client's reports included the amount invested (funds credited). A company with a licence (Qubey Finance, then IK QBF LLC) used foreign trading accounts to transact with client funds. According to the agreement, securities were to be purchased and registered by internal accounting for the client, with no confirmation of the trades executed, as the pool was managed, i.e., the totality of accumulated client funds, internally divided into extensive trading strategies, in 2011–2014.

  • Qubey Finance LLC provided clients with monthly reports that contained information on portfolio type, asset/instrument mix, purchase price, quantity, month-end price, the value of each position, margin lending level (leverage), entries and withdrawals (amounts, dates), portfolio changes, and transitions from strategy to strategy.

  • In the case of Duntonse, the responsible officer was also identified. These reports were the only source of information. The reporting periods were varied, as was the frequency of distribution. In QBF, the reporting period was a month. As a rule, the report was sent electronically in “PDF” format to clients’ mailboxes every 10th day of the month following the end of the previous reporting period (month).

  • The company had clients both for the “Advisory brokerage” service (the client gave the order to buy and sell; the manager did not have the rights to make transactions independently but executed the client’s order) and for the “Trust management” service (the manager independently made transactions according to the agreement signed by the client and the declaration specifying the main criteria, strategies and possible limitations).

  • Most of the company’s clients in the international market had contracts of the second type, “trust management”.

  • In the case of advisory management contracts, the client gave a transaction order electronically (scan of the document signed by the client) for each transaction or gave the order “by voice” by calling a unique telephone number with a record of the conversation: the client identifies himself, says in full the type of transaction and the instruments he needs.

  • The securities and each specific position on the stock exchange are purchased in the company's name, “QB CAPITAL CY LTD”.

  • The balances in the reports to the international market clients did not correspond to the amounts that R.V. Shpakov sent to the respective clients' accounts in “QB CAPITAL CY LTD”, the top brokers.

  • Thus, the incoming balance in the reports was only formally indicated. In the period around 2015, Shpakov R.V. had a “hole” in his total funds of all clients, i.e. he (Shpakov R.V.) lost part of the company’s funds on stock exchange transactions, but at the time did not disclose this in client reports to hide losses and not to cause an outflow of funds, deterioration of reputation, threat to the whole business. In his reports, R.V. Shpakov substituted unprofitable positions he bought on the stock exchange with other stock exchange positions with neutral-positive trading (financial) results for the company and clients.

  • Many attracted clients were paid their own and “earned” funds at the expense of other clients’ funds. At the same time, the clients attracted in the period since 2015. QBF LLC (QBF IK) offered yields already lower than in previous periods, more than 2–3 times lower, tariffs were increased, the product line was raised, and marketing materials were improved.

  • Thus, he and many employees carried out relevant and essential work on the company’s struggle with the difficult market situation. Still, these actions did not lead to the desired favourable result, as it turned out that on the part of Roman Shpakov, there was a misuse of clients’ money, i.e. Roman Shpakov used depositors’ money for his enrichment.

  • Also, the circumstances of 2015 and Afterwards led Shpakov to the fact that he used the funds of other newly attracted clients for settlements with some clients, which only aggravated the company's and the market's problematic situation. If the clients’ funds had been placed on segregated (separate) accounts and there had been timely control over them by the regulator, the risk of misuse of newly received clients’ funds would have been much less.

  • He (Z.V. Munaev) and many employees during the long years of the company’s operation asked R.V. Shpakov questions concerning the company’s activity, system of functioning, including the system of settlements with clients, and the company’s profit.

  • Most questions found reasonable answers, but they needed help to get complete and meaningful answers. The team was especially concerned about this in the period starting in 2015 when the first severe shifts in the timing of settlements with clients began.

  • At the same time, Shpakov R.V., as a manager, always stopped excessive questions and interest in the internal activities of the company, always saying that the client, in the end, although with an extended period, receives money in total, and many and most with a profit that exceeds the level of competitors’ offers, which justified his approach to such activities.

  • Duntonse and QB CAPITAL CY LTD did not have their licences but used third-party licences held by QB Finance Ltd. QB Finance Ltd. did not accept client funds. In addition, Duntonse and QB CAPITAL CY LTD did not have separate client accounts, which increased the risk and opportunities for the account manager to use client funds both in favour of clients and make better deals on the stock exchange and in his interests. 

  • He knew about QB Capital CY LTD's activities and was a QB Capital Real Estate Fund shareholder or QB Capital Regional Real Estate Fund. 

  • He is listed in the register of owners in the Management Company.

  • The presence of “QB Capital CY LTD” Clients of one of the positions in their reports of units of ZPIF “Real Estate” indicates that “QB Capital CY LTD” should have used a part of the funds accepted from the Clients to purchase a share in the said Fund for further channelling the funds to the Developer in the construction project.

  • The clients are not provided with the confirmation of the acquisition of the fund units either from “QB Capital CY LTD” or from QBF Asset Management.

  • Since the rights and obligations of “QB Capital CY LTD” were transferred to “Simtelligence Company Limited” in full, Simtelligence Company Limited had the right of claim to the funds of MC “QB Asset Management” within the framework of the funds transferred to the Fund from “QB Capital CY LTD”.

  • Since the transfers were not made in full, the reports sent to the clients did not correspond to the purchased positions (purchased shares in the Fund).

  • The units purchased by the company “QB Capital CY LTD” are registered in the fund only for it; the Fund does not re-register them to the clients of “QB Capital CY LTD.” this assignment of rights should have been carried out by the internal accounting of “QB Capital CY LTD”.

  • Decisions on the amount of funds transferred within each of the products of “QB Capital CY LTD” to specific instruments were made directly by R.V. Shpakov based on the conditions and restrictions of the Fund.

  • It would have been much easier for R.V. Shpakov to withdraw or otherwise withdraw funds from foreign accounts controlled by him and transfer them directly to construction projects using managed developers and builders.

  • However, even if the total amount of the required funds were directed to the relevant Real Estate Funds, this product did not have a mandatory cash and interest payment term but rather had target yields and a 100% risk of cash loss like any other investment product.

  • Therefore, the Fund’s obligations to the Units QB Capital CY LTD and Simtelligence Company Limited do not constitute a guaranteed payment of corpus and interest.

  • All Client monies transferred to “QB Capital CY LTD” and “Simtelligence Company Limited”, regardless of the portfolio positions, contractual terms and conditions and other legal aspects, will not be returned to the clients, as this decision can be made directly only by R.V. Shpakov, and all funds were appropriated unilaterally by him.

  • In 2014, he (Z.V. Munaev) was appointed Head of Sales Department of Moscow, and Vladimir Pakhomov was sent to St. Petersburg to open the first regional branch while still listed in Qubi Finance LLC.

  • In the same year, he (Z.V. Munaev) and Pakhomov, only the two of them, were assigned (transferred) shares in Qubey Finance LLC by R.V. Shpakov for 6 per cent each, but he (Z.V. Munaev) never received dividends from them.

  • From 2012 to 2014, the timeframe for withdrawal of clients’ funds from Cyprus increased to 1–1.5 months.

  • Since 2014, many banks, including Piraeus Bank, have complicated and aggravated the transaction requirements.

  • In addition, due to the new requirements for funds received from the territory of the Russian Federation, the period of their verification for the source of origin, the source of the client’s income, and the client’s identity has increased.

  • In 2015, both the documents required for deposit and withdrawal of funds and the withdrawal terms increased for the clients of Qubi Finance LLC.

  • R.V. Shpakov and Linda initially provided the employees with a greatly expanded list of documents required from clients to withdraw funds. Still, most of the papers from this list did not represent a set of documents required by the bank.

  • For example, the bank did not need a diploma of education, certificate of military duty, proof of residence, or other documents from the above-extended list.

  • In reality, banks require the following documents: source of origin of funds, source of income, certificate of no criminal record, and letter of recommendation from the bank/lawyer/advocate.

  • R.V. Shpakov artificially extended the list of documents for withdrawal of funds to increase the timeframe for withdrawal and the possibility of using these funds for a more extended period.

  • Since 2015, the withdrawal terms of clients’ funds from Cyprus have increased to 1.5–3 months.

  • At the same time, “QB CAPITAL CY LTD” ceased to be serviced in the banks of Cyprus.

  • From 2015 to 2018, construction projects increased by raising customer funds.

  • The branch network increased enormously, as well as the number of complaints and dissatisfied customers regarding the withholding of funds due to them under their contracts.

  • Also, due to the circumstances, employee dissatisfaction with management increased, and the working climate deteriorated.

  • The employees had fears of the continuation of the organisation’s activities with clients and the impossibility of paying the latter money.

  • Due to unsatisfactory sales results, in R.V. Shpakov’s opinion, he (Z.V. Munaev) was removed from the sales manager position.

  • Vladimir Pakhomov was appointed to this position and became sales manager for both Moscow and St. Petersburg.

  • In 2018, the liquidation of “QB CAPITAL CY LTD” began.

  • Following complaints from citizens to the Central Bank and Cyprus, the question arose to check the activities of QB CAPITAL CY LTD, an affiliate of QB Finance Group, in Cyprus.

  • Linda and Apollon Athanasiadou, Shpakov Roman were afraid of full disclosure of the data of the owners of the Cypriot companies, their affiliation with “QB Finance”, account providers, financial transactions because they were illegal on the territory of Cyprus, which Linda emphasised and explained that in the territory of the Russian Federation, it would be presented as a financial pyramid scheme.

  • To prevent these events, there was a change in all corporate documents of the founder's management from R.V. Shpakov to his (Z.V. Munaev) name.

  • Linda Athanasiadou provided him (Z.V. Munaev) with these documents, drawn up “backdated” for his signature.

  • During the same period, in order not to disclose the affiliation of the organisations, he was removed from the founders of IK QBF LLC (renamed QBF LLC in 2016–2017).

  • R.V. Shpakov and Linda Athanasiadou told him that two organisations would be set up to continue client settlements and prevent the company from reneging on its obligations to them (clients).

  • As soon as possible, two companies were set up, namely: “SIMTELLIGENCE” (Hong Kong) and “WHITE LAKE MANAGEMENT LTD” (Cayman Islands).

  • Settlements with former clients QB CAPITAL CY LTD and Duntonse continued, as well as the attraction of new clients using these organisations and the procedure of re-signing the contracts of “old” clients to new agreements with SIMTELLIGENCE COMPANY LIMITED and WHITE LAKE MANAGEMENT.

  • SIMTELLIGENCE COMPANY LIMITED was owned by Linda’s partner and mate, Mike Christofi; he is a citizen of the Republic of Cyprus who was living in Hong Kong.

  • When the liquidation of “QB Capital CY LTD” was on the agenda, Linda looked for a new company and jurisdiction, and by criteria known only to her and Apollo, Hong Kong was chosen, where Mike had a friendly, owned, almost “empty” company.

  • Linda acquired it in 2018 in favour of R.V. Shpakov, and “Simtelligence Company Limited” took over the rights and obligations of “QB Capital CY LTD” and continued to carry on its previous activities.

  • “Simtelligence Company Limited had no licences to carry out securities activities.

  • The regulator did not have any complaints about the legality of the company’s activities.

  • The accounts and funds of the company were managed by Linda Athanasiadou and R.V. Shpakov, similar to “QB Capital CY LTD”.

  • A third company, VL Consulting LLC, was sometimes added to this bundle.

  • Its role served only as a communication link for the correct legal transfer of information between the Russian Federation and foreign jurisdictions.

  • VL Consulting LLC did not have a securities licence.

  • Settlements and cash transactions in this bundle were handled directly by Simtelligence Company Limited, as was QB Capital CY LTD in the previous bundle.

  • “Simtelligence Company Limited” accepted clients’ funds into its accounts, After which it was understood that the funds would be directed to the accounts of the top brokers and “White Lake Management Ltd” as a licensed entity.

  • At least this was discussed as “QB Capital CY LTD” was liquidated as a procedure for new companies and jurisdictions.

  • After the account of “Simtelligence Company Limited” was opened in AMERIA - Bank (Armenia) with his (Z.V. Munaev) participation, the first funds of this company were credited to it (the account) because it had just taken over the activities of “QB Capital CY LTD”.

  • His participation was necessary because he (Z.V. Munaev) was the last signatory of “QB Capital CY LTD”.) was the final signatory of “QB Capital CY LTD”, was the only one who was able to explain the transfer of activities to “Simtelligence Company Limited”, the legality of the activities, the former connection with “Qubi Finance” LLC, as well as in person (which was mandatory) to go through the standard banking procedures for opening a non - resident account.

  • Subsequently, according to Linda, his involvement was no longer necessary, either with this Bank or others.

  • He did not open any further accounts for Simtelligence Company Limited.

  • White Lake Management Ltd was set up from scratch in the Cayman Islands, and Linda and her team then ensured that the company went through the necessary procedures to obtain a licence.

  • The company had a director named Paul, a Cayman Island national accountable to the regulator.

  • Paul was founded and appointed as a director by Linda Athanasiadou.

  • When Linda was in the Moscow office, he (Z.V. Munaev) saw their telephone conferences in the conference room several times.

  • “White Lake Management Ltd” had the ability as a broker/manager to accept funds directly into their accounts and trade them independently with the necessary access and terminal.

  • The sales staff was interested in attracting clients to the licensed company. Therefore, sales started at “White Lake Management Ltd”, but due to the late stage of its establishment and development, it attracted about 1–2 dozen new clients.

  • “White Lake Management Ltd” also had 1–2 bank accounts, and “White Lake Management Ltd” was also a management company/broker for clients of “Simtelligence Company Limited”.

  • It was in conjunction with it that the clients of Simtelligence Company Limited could access international markets.

  • However, it was also a direct transaction from Simtelligence Company Limited to FFin Bs and possibly other companies and brokers.

  • The “White Lake Management Ltd” operations were managed by R.V. Shpakov and Linda, who also had access to the accounts.

  • “White Lake Management Ltd” was set up to distribute cash flows similar to the earlier examples of “QB Capital CY LTD”, “QB CAPITAL MANAGEMENT LTD”, and “QB Financial Services QB”.

  • “WLM LTD” was to take only cash client payments, transfer them and issue them back to the client.

  • The linkage of the work of “WLM LTD” was also with “White Lake Management Ltd”.

  • The jurisdiction of “WLM LTD” was the Cayman Islands, and it was entered into 2019–2020; it was managed by the same persons: Linda and Shpakov R.V.

  • The director of the company was a nominee.

  • Externally, the procedure for concluding contracts and cash flow should have been identical, but whether the actual crediting of funds to the company’s accounts was carried out, he does not know, just as he does not know.

  • The name was similar to make the clients understand that the company belonged to a group of companies, which included “White Lake Management Ltd” and “VL Consulting” Ltd. WLM LTD did not have a securities licence.

  • Initially, it was brought to the employees' attention that the banks used by the brokers were necessary for the further transfer of funds to the accounts of the top brokers.

  • The brokers of “QB Capital CY LTD”, and at the time of liquidation of “QB Capital CY LTD” (QCCI), should have had no problems with accepting client funds because, according to Linda’s words, the transfers were accompanied by documents attached to them both by “QB Capital CY LTD” and the Russian licensed LLC “Qubey Finance”, in connection with which this bundle of companies ensured the legality of sending and crediting the funds to their destination.

  • Linda Athanasiadou opened the accounts of R.V. Shpakov’s foreign companies in foreign banks.

  • Apollo Athanasiadou could provide additional legal support.

  • He (Z.V. Munaev) assumes that his data and his signature After signing that liquidation kit could have been used by R.V. Shpakov and Linda Athanasiadou in other corporate documents of “QB Capital CY LTD” and “Simtelligence Company Limited” in other jurisdictions, including the banks mentioned by him.

  • This is because Linda and R.V. Shpakov were very much afraid of the disclosure of information on R.V. Shpakov during the liquidation of “QB Capital CY LTD” due to the existence of requests of the Central Bank of the Russian Federation in Russia at that time and the distribution of these requests among banks abroad.

  • He (Z.V. Munaev) has no information about the accounts of “QB Capital CY LTD” being closed their cash balances and has never had it.

  • At the closing of “QB Capital CY LTD” the funds from its bank accounts were transferred to the accounts of “Simtelligence Company Limited”, as the liquidation procedure itself, to be legal, did not imply bankruptcy of the company and zeroing out/withdrawal of debts, but the transfer of rights and obligations from “QB Capital CY LTD” to “Simtelligence Company Limited”.

  • Around 2018–2019, the Cypriot regulator CySEC began to receive enquiries from the Central Bank of Cyprus regarding the related activities of QB Capital CY LTD and QB CAPITAL CY LTD.

  • At that time, Linda was very concerned about possible difficulties for the companies she was accompanying.

  • On behalf of R.V. Shpakov, Linda travelled to the regulator, including negotiations with the head of the regulator to eliminate possible risks for the companies.

  • Linda Athanasiadou was a qualified professional in the Republic of Cyprus, had many connections in the local financial market, and was a confidant of many Cypriot business people and other influential persons.

  • She also had “friendly” relations with the Cyprus regulator and central bank management.

  • At the same time, NOA was assigned to support R.V. Shpakov’s companies. “SIMTELLIGENCE COMPANY LIMITED” and “White Lake Management”, Linda Athanasiadou had the necessary keys access to the “bank-client” and these companies.

  • In addition to the previously mentioned companies and services, the interaction between R.V. Shpakov and Linda was reflected in the creation of such funds as “Purity” and “Falco”.

  • Linda created the funds in approximately 2018 with the financing of Roman Shpakov.

  • Linda and R.V. Shpakov managed these funds and their financial and economic activities.

  • Also, in approximately 2019, Linda, through her connections, introduced into the perimeter of work (attracted) Shpakov R.V.’s companies the company “Argento…”-an organisation for the creation and management of structured products, operating in conjunction with Magento and Societe Generale Bank.

  • R.V. Shpakov began to include securities of this company in client portfolios.

  • The assignment of rights from “SIMTELLIGENCE COMPANY LIMITED” and “WHITE LAKE MANAGEMENT LTD” to RIF (Rent Investment Fund) real estate funds was initiated by R.V. Shpakov as the second big stage of transferring/resigning a significant part of clients to long-term and transparent products.

  • In the first stage, this second stage was not planned but started to be realised later.

  • Almost all clients were offered to buy fund units, and the justification was the same as before the re-signing of contracts: stricter regulation, the difficulty of interaction between Russia and foreign counterparties, complexity, paperwork, cost, time, language barriers, and many other reasons.

  • The organiser of the procedure of the second re-signing was the same executor, Linda Athanasiadou.

  • In the Russian part, Yaroslava Smirnova and Evgeniya Rossieva probably registered units or relations with other objects (construction as an investment object).

  • The company “LAMERA HOLDING LIMITED” was founded by Linda.

  • Some nominee or a person appointed by Linda signed the documents on behalf of the company.

  • When sold in a primarily formed and established fund, a unit's value, where no owners (fund) yet, is determined based on an appraiser’s report and relevant standard appraisal procedures strictly regulated by the Management Company and the Central Bank of the Russian Federation.

  • The sale of RIF units to new (including “oversubscribed”) clients was not like this, i.e. it was not primary.

  • After all the necessary procedures, the initial owner of the first units was one of R.V. Shpakov’s companies, most likely LLC Q.Broker.

  • Further sale of the company’s units is carried out at the market price, not based on the appraiser’s report and market procedures, as the seller sets the price- the company Shpakov R.V.

  • Thus, the market value of the sale of units from the company to the client was determined by the seller's willingness to pay the assigned price and appropriate bargaining.

  • The intention of the employees during the period of their high activity in sales and re-signings for the purchase of units of the real estate fund “RIF” was based on the desire to settle accounts with clients and make a transparent withdrawal of their funds from foreign companies to the Russian jurisdiction, as this, including in the work both in general within the company and with clients, fell under the concept of “withdrawal of funds”, and “LAMERA HOLDINGS LIMITED” was needed to document the wiring from abroad to the Russian fund.

  • The fact that the clients had units was the closure of the obligations of the previous companies to the clients: both SIMTELLIGENCE COMPANY LIMITED and QB CAPITAL CY LTD made a total settlement of the last balances in the reports, the previous contractual relations ended, and new ones began with clear transparent conditions and with a real investment object.

  • One of the objects was an actual income-generating warehouse (probably warehouses) for logistics and other companies; this object brought rent income and was inside the RIF fund. This income was to be paid to the shareholders.

  • The original owner of the warehouses received payment from the sale of shares in them, a cash payment as part of the transaction with R.V. Shpakov, most likely at a value equal to or close to the appraiser’s report of the given value of the object.

  • R.V. Shpakov determined the further sale value of the fund units to the client.

  • There were no other market benchmarks, and the difference with the initial amount paid by the appraiser was the company’s “margin”.

  • The final sale price, although it had a precise set bar and range from Shpakov R.V., had a bargaining zone, the presence of which depended on the initiative of the buyer as a typical standard sale transaction.

  • The sales staff had their commission from sales and could only sometimes communicate the possibility of bargaining and other conditions to the customers.

  • The management company MC QBF Asset Management was responsible for executing the assignment agreement in the Russian part and crediting the units to the clients’ names. In the foreign part, Linda Athanasiadou and her foreign team were responsible for bringing the Russian part from the side of SIMTELLIGENCE COMPANY LIMITED and LAMERA HOLDINGS LIMITED.

  • Perhaps one of the employees, Kirill Olezhko, was involved in some process. Olezhko was involved in some corporate correspondence with the Moscow office staff.

  • If even 50 per cent of SIMTELLIGENCE COMPANY LIMITED’s obligations to Clients were transferred under assignment agreements into units, SIMTELLIGENCE COMPANY LIMITED would be liquidated. In 2019, QBIF, LLC's activity was providing services through over-the-counter auction contracts (OTC) for IPOs and other transactions.

  • This service was provided by IK QBEF LLC, directly accepting funds from clients under its licences.

  • By signing an accession agreement, the client entered into a brokerage service agreement with IK QBEF LLC and transferred money from its current account to the company’s existing account opened with Alfa-Bank, Sberbank, NSD and other payment organisations.

  • Clients were provided with a separate brokerage account (segregated) with a corresponding balance of funds belonging to them.

  • Further, the Client submitted an order on his behalf to enter into an OTC option contract (OOC) with Q.Broker LLC, a company owned by R.V. Shpakov, where he was the CEO for the transaction (bet) he was interested in.

  • As part of the brokerage account services, including transactions concluded with Q.Broker LLC, the client submitted an order for each new transaction on his behalf, expressing his desire and agreeing to its terms.

  • All clients had the essential information in the Framework Contract (agreement), where general concepts, including legislative and regulatory, were formulated.

  • This order was submitted to IC QBF LLC, and IC QBF LLC, represented by its General Director S.A. Matyukhin, entered into this agreement with Q.Broker LLC on behalf and at the client's expense.

  • Clients joined it and sent orders for each new IPO with specific terms and conditions for calculating the financial result (win rate).

  • The submission of an order from the client’s side was accompanied by the transfer of funds from LLC IC QBF to the settlement account of LLC Q.Broker.

  • The funds were transferred from the Client’s brokerage account to the brokerage account of Q.Broker LLC, which was opened in the same organisation - IC QBF LLC.

  • Further, the funds from Q.Broker LLC were channelled following the submitted client orders to execute IPO and other transactions.

  • The IPO transactions were executed jointly with Constance Investment (formerly Constance) as the foreign broker of Q.Broker LLC. Clients’ funds were transferred from the settlement account of “Q.Broker” LLC to the settlement account of “Constance Investment” in Cyprus, and further, from “Constance Investment” were sent to the top brokers for the execution of transactions.

  • Almost all participants of the Russian financial market have IPO contracts of this type, which are settlement rather than delivery contracts, i.e. the option at its end provides the client with a monetary financial result in the form of profit or loss on each specific transaction, rather than the delivery of securities on the IPO transaction for which the application was submitted.

  • According to this example, in IC QBF LLC, the VODs were settlement VODs; after the contract, Clients were notified of the type of profit or loss in monetary terms without delivery of securities to their brokerage accounts.

  • Constance Investment received the IPO securities as a foreign broker and depositary for this transaction.

  • The sales staff made sales of IPO ADSs of the sales department to their client bases.

  • Contracts could be concluded remotely in the company’s office via certified software and State Services (ESIA). This algorithm is uniform for customers throughout the Russian Federation.

  • Under the terms of the IOU, the company has no obligation to send funds to specific details, as the terms of the option are a bet between the client and the market following the bet he makes on this contract. The important thing for him is the final financial result.

  • Accordingly, the company has no legal or other restrictions on channelling funds and their use. These conditions are uniform for all brokers, both in Russia and abroad. The participants in the financial chain of transactions for the IPO WOD were:

  1. Accounting department represented by Ekaterina Gramza (personal treasurer of R.V. Shpakov and supervisor of economic distribution in the jurisdiction of the Russian Federation);

  2. Licensed broker represented by Stanislav Matyukhin, General Director of QBIF LLC, who was responsible for all professional activities of the company on the Russian market;

  • Intermediary Company - Q.Broker LLC, represented by its owner and General Director R.V. Shpakov;

  • 4.1 Foreign broker “Constance Investment” represented by Director Linda Athanasiadou, or

  • Terminating this chain by clause 4.2 was not unlawful, but this option of passing their money was not voiced to the clients.

  • The necessary and statutory end of the entire financial chain of the IPO WOD is the receipt of funds by the clients with profit or loss following the terms of their contracts.

  • In this case, due to financial management errors and managerial decisions of R.V. Shpakov, the clients faced the fact that they could not receive funds on their brokerage accounts and previously submitted orders for IPO IOUs and other IOUs.

  • Thus, R.V. Shpakov, utilising decisions on actions of p.4.2, directed funds in his interests and at his discretion, thereby misleading both the company’s employees and clients in terms of the direction of the use of funds, did not ensure the return of withdrawn funds to the brokerage accounts of clients, violated the terms of the concluded IOUs in terms of final settlements under these contracts, jeopardised the entire activity of the company and clients.

  • R.V. Shpakov attracts clients through more favourable IPO rates, access to more companies, and better conditions for IPO entry, allocation and IPO exit.

  • The standard negotiation methodology of IK QBF LLC and any other financial company does not include the description of the legal and financial chain of trade deals, as the client came to receive the finished service and results.

  • Thus, in negotiations, only curious and persistent clients sought information about top brokers, legal terms, contract terms for specific IPOs, etc. In contrast, most of the clients needed to be explained. QBIF LLC had IOUs for relevant products and services of related companies such as Purity, Argento… “ whose activities were managed by Linda Athanasiadou.

  • Client funds received by QBIF LLC were channelled through Q.Broker LLC through the financial chain to these funds and products - “Purity”, “Argento…”.

  • The clients’ funds transferred to Purity through Q.Broker LLC were partially or fully returned to the clients, while for Argento…, due to the extended maturity of these securities held and registered with NSD’s depository, the funds were not returned since the maturity date had not occurred, but due to the actions taken and being taken by R.V. Shpakov to dispose of these funds.

  • Most of the clients of trust management services on the Russian stock market received their funds in the appropriate amount, as the company made many transactions on the Moscow and St. Petersburg stock exchanges with quoted securities following the standards of client service conditions and the practice of Russian investment companies.

  • Other transactions for which funds were channelled from Q.Broker LLC were the purchase of Argento Access Sarl securities registered with NSD.

  • As far as Argento Access Sarl securities are concerned, although they are issued by a certified Issuer and are registered with NSD, they are not trustworthy, liquid and meet the expected interests of clients, i.e. the money was transferred to this company in the interests of R. Shpakov.V. with the help of Linda Athanasiadou with the intention of not returning this money to the clients; transfer to the accounts of LLC “Management Company QBF” and its mutual funds, including ZPIFs for the construction projects of Shpakov R.V., i.e. at the expense of attracted clients’ funds the clients’ funds were invested in the construction projects of R.V. Shpakov through the shell funds; transferred to the accounts of construction companies LLC “M1 Development”, LLC “Simon Jesso” (Developer), LLC “SeverSpecStroy” (Developer), and other companies related to the construction projects of R.V. Shpakov, the names of which he does not know.

  • His mother, Irina Nikolaevna Shpakova, managed all the construction activities of R.V. Shpakov in Severodvinsk.

  • Also, I.N. Shpakova managed financial operations of all construction projects in Severodvinsk and supervised the work of the Russian accounting department of LLC IC QBF - all accountants, financial operations, payments of the companies related and controlled by R.V. Shpakov; transfers to the accounts of JSC QBF Group (the company that owns 100 per cent of the shares of LLC IC QBF and LLC MC QBF).

  • This company, among other things, entered into promissory notes with clients to accept money from them for loans at interest.

  • The Company could also make direct settlements with certain specific employees regarding financial obligations, such as refunds, salaries, payments with counterparties for core and other activities, and withdrawal of money to the accounts of R.V. Shpakov and his affiliated companies. 

  • And companies affiliated with him, such as LLC 168 Kvartal, LLC 701, LLC 702, LLC 776, LLC Ver - Mont, LLC Vysota, LLC KG, LLC K - Investment, LLC K - Consulting, LLC KF Estate SPB, LLC Cusisiai, LLC Finbutik, LLC Indep Smart, LLC RentInvest, LLC Synthesis, LLC F - Management, LLC F - Technologies, LLC F - Experts, PJSC CEF, JSC RIF and others.

  • Thus, for the entire business to function and be in the client's best interests, the cash had to be transferred back to Q.Broker LLC at a profit or loss and further transferred to the clients to their brokerage accounts at QBIF LLC in the appropriate amount and result.

  • At the end of each ICO, the funds must be automatically credited to the accounts of QBIF LLC and its clients. 

  • In contrast, the withdrawal of funds to clients’ current accounts from QBIF LLC results from an order submitted by the client for the amount of the brokerage account balance.

  • Financial instruments that do not meet the criterion of liquidity, recoverability, or sufficient collateral for repayment were the most significant financial investments of IC QBF LLC and Q.Broker LLC, such as: - VODs; - units of construction ZPIFs; - securities of Argento Access Sarl.

  • Entering into transactions with these financial instruments is not a good faith practice and is not acting in the client's best interests.

  • Without reliable information about these instruments and directions for their use, clients would refuse to purchase them. In contrast, in our case, R.V. Shpakov organised a system of their (clients’) attraction with a pre-existing intention to use the funds in his interests and not to return them to their owners. It was a scheme of misleading on his part and obtaining clients’ money by fraudulent means.

  • Even though the whole chain of cash flow from the client to exchange or other unknown transactions was legal, the system of work outlined earlier is still illegal in its final link, R.V. Shpakov’s decision not to pay money back to clients and return it to their accounts.

  • Stanislav Matyukhin performed some of the operations of withdrawing (cashing out) funds from the accounts of QBIF LLC and some QBIF Group companies on behalf of R.V. Shpakov. S.A. Matyukhin received financial orders for transfers from R.V. Shpakov for investment and related business. 

  • At the same time, Ekaterina Gramza carried out orders from R.V. Shpakov for other companies unrelated to the investment business, but she made transfers for Q.Broker LLC.

  • The cash received by the employees of QBIF LLC from clients under the concluded agreements on the provision of direct access to international stock markets was accepted both in the offices of the company and at off - site meetings with clients. For the most part, this occurred in the office of IC QBF LLC.

  • Cash was accepted by the company’s employees, who were instructed that this was a standard and legal procedure and that the funds were credited to the clients’ foreign accounts within the Company’s general account.

  • All hired employees accepted Cash from customers at all times without restriction, with the authorisation of the immediate supervisor, as prior notification was required for a separate meeting room and cash counting equipment (counting machine).

  • Accepted cash was left in the cash room in a safe. Then, the head of the department to which the client belongs, or the head of the department at the end of the working day of the office, reported to R.V. Shpakov about the amount of received funds. The statistics collected for all department heads at the end of the day were sent to Shpakov R.V. by the head of the sales department in correspondence. Shpakov R.V. was then instructed to bring the money to him personally in his office or to one of the employees of the sales department who was in the office after the end of the working day or to one of his trusted employees of non-selling departments or assistants. In case R.V. Shpakov was absent from the office, he (R.V. Shpakov) instructed that the money be brought to him (Z.V. Munaev during his tenure as head of the sales department) so that he (Z.V. Munaev), having waited for R.V. Shpakov, transferred this money to him (R.V. Shpakov) for further transfer abroad or in case of counter cash flows (from abroad to Russia/from Russia to abroad) employing netting, he would disburse funds on his orders, including but not limited to the following: salaries of sales and non-sales employees, commissions and bonuses of sales and non - sales employees, office and other related expenses, disbursement of clients’ funds on behalf of R.V. Shpakov (returns on orders from R.V. Shpakov).V. (returns on withdrawal orders), personal orders of Shpakov R.V. to one of his employees.

  • Sometimes, he (R.V. Shpakov) asked to give part of the money to persons unknown to the employees.

  • He sent part of the money received from clients by Shpakov R.V. to the relevant “supervisors” in the Central Bank of Russia and government agencies to prevent negative consequences for the company QBIF LLC.

  • The procedure described above was standard to both the Moscow office and the branches, except for the following differences known to him: consolidation of funds from the branches generally took place in the St. Petersburg office through business trips of employees from the branches to St. Petersburg, or business trips of employees of the St. Petersburg office or Pakhomov V.S. personally to the branches. At the request of R.V. Shpakov, V.S. Pakhomov encashed funds from all branches of QBF LLC, namely the branches in Tyumen, Yekaterinburg, Kaliningrad, Ufa and St. Petersburg, with varying frequency.

  • The decision to make payments in the Moscow office personally by R.V. Shpakov. In contrast, for the branches, the decision on the cash consolidation in St. Petersburg was made by V.S. Pakhomov and R.V. Shpakov, with Shpakov’s final approval.

  • Due to Shpakov R.V.’s direct presence in the Moscow office, he made all significant decisions, including financial decisions. The managers in Moscow did not have such extensive powers. In contrast, for the branches, due to Shpakov R.V.’s remoteness from these offices and lack of personal immersion in their daily activities, the powers of the head of the branch network, Pakhomov V.S., were much more comprehensive. 

  • He was more independent, although he coordinated the most critical issues with Shpakov R.V. and also necessarily fulfilled his instructions.

  • Money from St. Petersburg was transported from St. Petersburg to Moscow to Shpakov R.V. personally by Pakhomov V.S. at the request of Shpakov R.V. without any apparent periodicity.

  • Such “encashment” was absent in the branches due to personal business trips of branch employees to St. Petersburg and was only in Moscow, which was mentioned by Shpakov R.V. when he organised the work.

  • The procedure for transferring funds collected from Moscow and the branches from employees on behalf of Shpakov R.V. to visiting persons unknown to the employees was called “encashment” by Shpakov R.V.

  • By the lists of clients’ applications for withdrawal transmitted from the Moscow and branch sales departments, Shpakov R.V., based on the cash received, made decisions on the withdrawal of some of the clients from the lists of money for withdrawal on his behalf. The remaining withdrawals were carried out by bringing so-called “encashment” cash received from foreign trading accounts and by direct non-cash transfers to clients.

  • The issuance of documents accompanied by a receipt of money from customers: a receipt to a cash receipt order or a receipt for receipt of funds.

  • Only some of the money received from clients was transferred to their respective accounts. Mutual cash settlements from the company’s offices and non-cash withdrawals from trading accounts from abroad, as stated by R.V. Shpakov, did not always occur.

  • The cash received should have matched the amount declared to be withdrawn from the foreign trading account so that the money would not have to be transferred. Still, it could be taken into account immediately for settlement on the spot (in banking and brokerage terminology, this is called “clearing of payments”).

  • Since about 2015, without any systematic regularity in terms of terms, amounts or participants in the process, R.V. Shpakov gave orders to the company’s employees, whom he chose, to accept funds to their accounts from him (R.V. Shpakov) or his companies to withdraw and make payments, which were initially known to him (R.V. Shpakov) personally, and later, as the company’s organisational structure grew, part of the payments were known to him (Z.R. Munaev) and other heads of structural divisions. The funds were transferred to employees' accounts (he was sometimes among them), often under loan agreements. Neither he nor other employees shared the money back. Ekaterina Gramza drafted the contracts.

  • These contracts were signed, and they knew they were R.V. Shpakov's corporate funds. The employees rarely had additional questions since the withdrawals were made through everyday banking transactions within available banking limits and bank laundering checks.

  • Moreover, some of the funds were due to some employees, such as salary from Shpakov R.V. or bonuses. Also, due to frequent salary delays and very severe delays in commissions and bonuses, After 2015, employees always reacted adequately and positively to Shpakov R.V.’s instruction to transfer funds to employees’ accounts for withdrawal and disbursement to the sales department for salaries.

  • Most of the salaries and bonuses were given “in an envelope” by one of the employees in charge of the technical issuance of envelopes.

  • This employee was Kristina Bogdanova, a former secretary, a young girl unfamiliar with financial activities and much that went on in the company.

  • The money could have been transferred to her by one of the employees and possibly personally by Shpakov R.V.

  • This system of payments was practised in the company to save money and avoid taxation (the UST tax was not paid in total). Subsequently, closer to the liquidation of “QB CAPITAL CY LTD”, when difficulties in settlements with clients were very noticeable, such transfers to the accounts of employees from R.V. Shpakov to withdraw cash to the company, including contained payments to clients of these employees, as clients were in a long wait for money. Shpakov R.V. used them as employees to save on infrastructure costs and withdrawal transfers; Shpakov R.V. could ask for a cash withdrawal from an employee several times a year.

  • These were transfers from R.V. Shpakov as an individual and from companies controlled by him: JSC FG, KG LLC, possibly from Gramza’s account, and also from the accounts of Q.Broker LLC.

  • In all the years of QBF’s operation, such cash-out procedures involved, as a rule, heads of sales departments and heads of sales departments, including both Moscow and branches.

  • Even though there was a turnover of employees even at the level of heads of departments, a new manager could be involved in such procedures sometimes after his appointment.

  • As a rule, for him, it was a direct order from the Company’s CEO or passed on through the heads of sales departments (his, Spinka, Pakhomov, Golubev, Korzh, and other persons), so it was not objectionable.

  • Of the employees known to him who took part in cashing money for R.V. Shpakov: Avetis Vartanov, Maxim Yudin, Nikita Selivanov, Nikolay Padalko, Dmitry Kipa, Alexander Zaitsev, Ara Balayan, Ruslan Spinka, Andrey Korzh, Vladimir Pakhomov, him (Z.V. Munaev), Alexey Golubev, Vladislav Plitin, Vladimir Maslennikov, Pavel Dzhumamuratov.

  • Everything was formalised with loans that were not initially physically signed but were signed later. “Alfa-Bank” and “Sberbank” were the most common banks whose accounts were transferred to employees’ accounts. The banks sometimes had average banking questions, which were exhausted when Gramza provided the contracts.

  • The employees personally handed the withdrawn money to R.V. Shpakov; it could also be handed over to him (Z.V. Munaev) in his (R.V. Shpakov’s) absence or employment for subsequent handover to the latter.

  • The money could also be handed over to one of the department heads because of Shpakov R.V.’s absence or Spinka in the office.

  • Temporarily, the money could have been transferred to and held by Spinka, one of the heads of the sales department.

  • Shpakov R.V. kept the transferred cash in his office, on his nightstand.

  • The loans were a documentary cover, while this was an illegal cash-in. The original origin of the money could only be known to some of the employees of the Moscow office except Ekaterina Gramza; it was, in some part, client funds, not corporate funds belonging to R.V. Shpakov, and not his funds. Vladimir Pakhomov, head of the branch network, and Alexei Golubev, head of the St. Petersburg office, were also involved in the cash-out.

  • Vladimir Pakhomov organised the cashing of funds by employees of the St. Petersburg office, while Alexey Golubev was aware of this system.

  • In addition, clients were depositing money to obtain access to the international stock market to invest in brokerage services at QBIF LLC. 

  • At the same time, the contracts and relevant agreements were concluded on behalf of the employees of QBIF LLC, who accompanied these clients and were signed by them.

  • This was done by private agreement between the client and the employee when the clients did not want their identity and data in connection with the investment of funds to become known to anyone, as well as to ensure that there was no documentary evidence of this particular way of using the funds. With the development of cryptocurrency transactions both in the world and Russia, R.V. Shpakov repeatedly took an interest in such transactions.

  • Shpakov R.V. had some attempts at transactions in cryptocurrency both for his speculative purposes and in terms of operations for clients in the period of about 2016–2017. 

  • Still, they could have been more successful and needed to be adequately developed. He knows about this from the words of Shpakov R.V.

  • The second continuation of operations with cryptocurrencies was approximately in 2019; it concerned the interaction between Shpakov R.V., Linda and banks and brokers servicing Shpakov’s foreign operations, capable of independently converting or transferring funds (US dollars and Euros) into cryptocurrency. From the words of R.V. Shpakov and Linda, he (Z.V. Munaev.) is aware that due to the transition from “QB Capital CY LTD” to “Simtelligence Company Limited” and “White Lake LTD”, some of the operations of earlier clients of “QB Capital CY LTD” were hampered, not all the Banks properly accepted the client’s set of documents. Linda’s documents on the “QB Finance” - “QB Capital CY LTD” bundle, therefore, at some point, by their decision, cryptocurrency transactions allowed abroad were connected for some settlements in some part.

  • It was a part of settlements between sending funds from the Bank servicing “Simtelligence Company Limited” and receiving funds from the client in non-cash and cash form. 

  • He (Z.V. Munaev) needs to learn the details of the transfers and their belonging to the clients, other participants and executors on the part of R.V. Shpakov.

  • However, the receipt of funds in cash in the office was still accompanied by the arrival of unknown people with money, and to receive them, Shpakov R.V. sent someone from the staff or received them personally.

  • Pavel Vlasov may have more information than other employees, as he (P. Vlasov) was often the employee to whom Shpakov R.V. instructed to collect the cash.

  • Also, LLC IC QB&Ef and Vostochny Bank developed a scheme of interaction and implementation of investment programmes through the bank sale of trust management services (after this TM) on individual investment accounts (hereinafter-IIS) of LLC IC QB&Ef to clients of Vostochny Bank, which began in about 2019.

  • The company employee responsible for this direction was Renat Amerov-Director for work with partners and counterparties.

  • He hired him (R. Amerov) around that time in 2019 because, after his (Z.V. Munaev) removal from the Director of Sales Department position, he was interested in new directions, as he was afraid for his place in the company and financial situation.

  • He and Renat considered different categories of financial and non-financial partners to create a joint product with them and offer it through their sales networks.

  • For obvious reasons, the most promising financial categories were banks. During the year of his work, Renat went around many banks, big and small, and in some meetings, he (Z.V. Munaev) participated as well.

  • One of these banks was Vostochny Bank. At that time, they were doing very well selling investment insurance for the long term, from 3–5 years, where the Bank received a commission of about 20 per cent.

  • On the Bank’s agenda was the issue of launching trust management partners. Bank Vostochny considered options of partners BCS (IK QBF LLC) and ITA Capital.

  • As a result, all three companies were admitted to sales at different periods. QBIF Ltd. had an agency agreement with Bank Vostochny, with a commission to the bank of about 10 per cent, and sold the Vostochny IIS DM product “Stable Growth” with a term of 5 years. Still, the actual term of the product was unlimited until the complete withdrawal of the client’s funds.

  • Renat hired additional employees-coaches, who organised sales with the employees of the territorial offices of Vostochny Bank, located all over the country; it was about 500 offices, among which about one-third was allocated to the coaching company.

  • Each coach had a list of assigned cities and offices, the employees of which had the product of QBIF Ltd. in their “showcase” of sales, among other products.

  • The coach's task with the bank employee was to ensure the planned sales volume and the necessary commission income for the bank.

  • Under this product, the client concludes an agreement with QBIF Ltd. at a bank branch using an electronic digital signature (EDS), immediately transferring money to the company’s investment account, thus becoming an active client for servicing.

  • His funds are placed in exchange-traded securities and over-the-counter financial instruments by the portfolio manager and the Investment Committee's decision.

  • The Investment Committee determines the strategy, permissible limits, conditions and restrictions.

  • The CEO and risk manager of the company (respectively Stanislav Matyukhin and Georgiy Dandov) directly influenced the decision.

  • For the most critical decisions for approvals, Renat and he (Z.V. Munaev) approached R.V. Shpakov about the organisation of sales and coaching work. Stanislav, Georgiy, and other employees did their part.

  • Initially, the strategy configuration contained only stock exchange instruments, and the funds were fully allocated to the Moscow stock exchange.

  • Employees received timely remuneration for this product, Vostochny Bank received timely commissions, and Clients received the necessary returns.

  • Because these were fully liquid funds and traded on the Moscow Exchange, Clients could withdraw the entire amount at any time, net of commissions paid, and with the earned yield by applying to a bank branch or remotely electronically directly to the company to the bank details-an account opened with Bank Vostochny.

  • In such a configuration, the product worked for a long time, about half a year.

  • Then, by the end of this period, sales were stopped due to a new tender in Vostochny Bank for selecting a company provider of investment services. QBIF Ltd. continued to serve the previously accumulated pool of clients.

  • The bank demanded new product configurations with increased commission and conclusion via an option contract (structured note).

  • This coincided with the launch of IPO services via OTC option contracts. Through long coordination and personal meetings with the Bank’s management, R.V. Shpakov proposed a new configuration of a structured product for Vostochny Bank with the use of OODs for five years with an annual yield of approximately 10–20 per cent (non-guaranteed) and the conclusion of an IIS via OTC (Brokerage). The launch of sales was successful but did not last long.

  • At the same time, sales were going on at BCS and Aitiay Capital. Shpakov R.V. lamented the additional financial arrangements of these companies with the management of Bank Vostochny.

  • A few months after the second launch, in 2020, the bank disconnected QBIF from sales unilaterally.

  • The coaching department serviced old clients; some were transferred to the Sales Department.

  • With the development of sales of IPO VOD at some point in time, R.V. Shpakov decided to include VOD as a tool in the strategy of trust management of both clients of the Sales Department of Moscow and branches, as well as agent networks and partners, in particular, the bank “Vostochny”.

  • He does not know in what configuration and in what volumes (limits) and to whom these assignments were addressed; he learnt about the fact itself when the company’s employees, in particular, the sales department and coaches, started contacting him with questions about the meaning of these option agreements.

  • Having collected the questions, they sent them to R.V. Shpakov and, through joint discussion with him, received answers satisfactory to them, related to the increased profitability for clients of these option agreements, not so long term and the possibility of redemption of some of these option agreements by the company at the personal decision of the management, namely R.V. Shpakov, without losses for clients.

  • The number of such option agreements could amount to dozens, if not hundreds, of contracts concluded within the framework of trust management services.

  • Thus, the decision to include the options in the sales of Vostochny Bank’s MA was made not at the time of the direct sale of these products and receipt of client funds to the company’s accounts but much later, through the decision of R.V. Shpakov with the approval of the officials of IC QBF LLC. When the client concluded a Trust Management Agreement (TM) with IC QBF LLC through Vostochny Bank, the following documents were executed: IIS Trust Agreement (signed between the Client and LLC IC QB&Ef), with client funds being sent directly from LLC IC QB&Ef to the Moscow Exchange. At a certain point in time, by decision of R.V. Shpakov, the following documents were also signed for each ICO:-an instruction (signed between IC QBF LLC and Q.Broker LLC), a contract (signed between IC QBF LLC and Q.Broker LLC). When the client concluded the Brokerage Service Agreement (BO) with IC QBF LLC through Vostochny Bank, the following documents were executed:-BO IIS contract (signed between the Client and IC QBF LLC);-an instruction (signed between the Client and IC QBF LLC; this instruction was given once for the entire contract amount, which was equal to the contract amount); -a contract (signed between the Client and Q.Broker LLC).

  • At the end of 2017 or early 2018, an on-site inspection as part of a working group of the Central Bank of Russia (CBR) began at the office of QBIF LLC to check all the organisation's investment activities as a professional participant in the securities market.

  • As he later learnt, R.V. Shpakov had an acquaintance in the Central Bank of the Russian Federation.

  • He (R.V. Shpakov) informed him (Z.V. Munaev) about it in the office of the company in his office during a conversation immediately after the beginning of the inspection of the Central Bank of Russia.

  • This acquaintance was, according to R.V. Shpakov, Deputy Chairman of the Central Bank of Russia Skobelkin, who supervised currency control activities.

  • During the same conversation, R.V. Shpakov showed him (Z.V. Munaev) the website of the Central Bank of the Russian Federation, wherein the management structure he pointed to the page with the profile data of this employee with information about his position.

  • Further, in the course of communication with R.V. Shpakov, he informed him (Z.V. Munaev) that this support of the activity of the company LLC IC QBEF by Skobelkin is carried out on a regular and reimbursable basis.

  • Periodically, namely monthly, After making settlements in the office of the company, Shpakov R.V. instructed him (Munaev Z.V.) to transfer to him (Shpakov R.V.) an amount of 50–80 thousand US dollars with the comment “For our friends” in the context of verification activities of the Central Bank of the Russian Federation.

  • On this basis, he concluded that these funds were intended to be transferred by R.V. Shpakov to R.V. Skobelkin as a reward for the latter’s support of the company’s activities and to minimise the negative consequences of the verification measures.

  • The audit by the CBR working group lasted approximately half a year.

  • During the same period, there were cross enquiries from the CBR not only to QB IC QF LLC but also in Cyprus to the local regulator on the related activities of QB CAPITAL CY LTD on the subject of investment of funds of Russian citizens attracted on the territory of the Russian Federation in the office of QB IC QF LLC, using QB CAPITAL CY LTD and its bank accounts.

  • The funds to be transferred to Skobelkin through QB CAPITAL CY LTD and its bank accounts were shared by R.V. Shpakov personally and on behalf of R.V. Shpakov through V.S. Pakhomov (repeatedly).

  • The transfer of funds to Skobelkin began immediately After the CBR audit, was carried out monthly, usually from the 15th to the 25th day of the month, and continued After the end of the CBR audit until May 2021.

  • This contact, namely, an acquaintance of Shpakov R.V. with Skobelkin, appeared to Shpakov R.V. through his uncle Pakhomov V.S.

  • He knows about it both from Shpakov R.V. and from Pakhomov V.S. Also, in his (Munaevu Z.V.) presence, there was a conversation between Pakhomov V.S. and Shpakov R.V., from which it became known that one of the managers of the Central Bank of Russia, surnamed Shvetsov, had long been dissatisfied with the activities of IK QBF LLC and was looking for an opportunity to suspend the company’s activities; such an opportunity was the audit that began in late 2017 - early 2018.

  • Including another employee of the Central Bank of Russia, surnamed Chistyukhin, in this situation, among other things, made it possible to prevent negative consequences for the activities of IK QBF LLC. As he (Z.V. Munaev) understood from the context of the conversation between R.V. Shpakov and V.S. Pakhomov, Chistyukhin interceded for the company at the “request” of Skobelkin or the security officers of the Central Bank of Russia.

  • During the time period of approximately November 2020 to January 2021, a meeting between V.S. Pakhomov and CBR employee(s) took place in the area of Neglinnaya Street, Moscow, during which they discussed an increase in the amount of the regular monthly remuneration due to the emerging new and aggravating circumstances of QBIF LLC.

  • He learned about this meeting, After its conclusion, from Pakhomov V.S. during a conversation in which he (Munaev Z.V.), Pakhomov V.S. and Shpakov R.V. took part. Directly interacted with during his work in the company can explain the following: Stanislav Matyukhin, General Director of QBIF LLC, was responsible for all of the company’s activities in the Russian market, its operational activities, coordinated marketing materials, scripts (dialogue templates) for sales, contracts, tariffs, implemented the necessary software, was responsible to the regulator and other supervisory structures.

  • S.A. Matyukhin was responsible for the entire Russian part of the business and was aware of the directions and amounts in which client funds from QBIF LLC were channelled. S.A. Matyukhin also coordinated with sales managers the methods (scripts) of negotiations with clients and the information communicated by financial advisors to clients. The information displayed to clients by financial advisors agreed with S.A. Matyukhin, mainly related to the terms of service and proposed trade deals, did not cover much of the legal and financial components, did not contain complete information on transfers to the companies involved in the service; Pakhomov Vladimir started working at Qubey Finance LLC (since 2011. QF LLC, since 2016 QBIF LLC) in 2010 in sales with a junior position as a financial advisor in Moscow, then within 1–2 years was promoted by R.V. Shpakov to the position of the head of one of the six sales departments of the Moscow office of QF LLC.

  • Around 2013. V.S. Pakhomov was sent on a business trip to St. Petersburg to open a new office there and was appointed by R.V. Shpakov to head this new office with accommodation in St. Petersburg. V.S. Pakhomov was entirely responsible for all activities of this office at that time, almost on a par with the powers that R.V. Shpakov had over the Moscow office, namely: recruitment and training of employees, determination of salary, development of sales policy, negotiation techniques, training materials and memos, templates for telephone conversations and meetings with clients, handling objections, as well as development of marketing strategy and implementation of expenses, solving issues of rent and possible relocation to new offices.

  • Pakhomov V.S. directly conducted meetings with clients, showed by his example various negotiation techniques, set standards for employees on essential parameters of efficiency of the regional sales department, and determined the amount of remuneration for financial advisors, marketing specialists, IT- employees, regional lawyers and accountants. V.S. Pakhomov opened all the company's regional offices in Yekaterinburg, Kaliningrad, Tyumen, Ufa and Murmansk in about 2014. V.S. Pakhomov was the director of the entire branch network of QBIF LLC and had complete authority over it on a par with those mentioned above about the St. Petersburg office.

  • His main task was to attract clients and ensure the activity of the regional sales department, which was based in St. Petersburg.

  • V.S. Pakhomov from St. Petersburg managed all the company's offices. In his activities, Pakhomov V.S. was subordinate only to Shpakov R.V. In his (Pakhomov V.S.) subordination were the heads of all client offices of regional cities and their subordinate employees. V.S. Pakhomov was subsequently employed by LLC KF Estate SPB, JSC FG, JSC QBF, and possibly other companies. Pakhomov V.S. received remuneration from sales in the form of a percentage of the volume of attracted funds (a percentage of newly acquired funds - as a standard motivation model in sales on the financial market, as well as a percentage of the accumulated portfolio depending on the results of the plan fulfilment).

  • All persons involved in sales, including V.S. Pakhomov, had the system of motivation and payment from sales specified in agency contracts rather than in labour contracts.

  • Both salaries and interest on sales were paid to them as employees in cash. Some of the money paid to the employees, namely most of the interest on sales, still needs to be paid officially.

  • As a rule, salaries were paid to employees once a month, usually in the middle of the month, and interest on sales was delivered once a month, at the end of the month. Employees employed by accountable licensed companies were paid twice a month (advance and repayment).

  • For him (Z.V. Munaev) and V.S. Pakhomov, around 2014, the system was changed to an average percentage of the accumulated fixed client portfolio in ruble terms, accrued monthly.

  • They were also promised dividends from the profits of Qubey Finance Ltd. Pakhomov V.S. After he (Munaev Z.V.) was detained in May 2021. A measure of restraint in the form of imprisonment was chosen against him; he knew from the corporate lawyers who accompanied him that Pakhomov V.S. continued to work at QBIF LLC or one of the related companies with Shpakov R.V. under his direct supervision. Despite their strained relationship in 2019–2020, Despite their strained relationship in 2019–2020 related to Shpakov R.V.’s work with government agencies and not the smoothest resolution of issues, in 2021, their (Shpakov and Pakhomov’s) relationship strengthened and became very close due to a new criminal case and detentions of employees in May 2021. organised the activities of the Moscow office and branches “on the ground”, receiving instructions from R.V. Shpakov by telephone and other means of communication, and managed the distribution of finances, the work and instruction of employees and their interaction with clients, to obtain the most significant benefits for himself and R.V. Shpakov, both in their position and status in the criminal case and in terms of money.

  • Ekaterina Gramza got a job at Qubey Finance LLC around 2013–2014 in one of the initial positions - in the administrative department as a secretary or file clerk.

  • At some point in time, R.V. Shpakov needed to expand the finance department. At the same time during this period, he (R.V. Shpakov) developed a close, trusting relationship with Ekaterina Gramza, in connection with which she was transferred to the position of junior accountant at Qubey Finance LLC.

  • At first, she helped with several issues, and then she was appointed to the position of accountant with her function and authority by 2015 and by 2018.

  • Gramza E. made payments and entries both in licensed companies (not alone, as these companies had accountants reporting to the regulator) and in related companies of Shpakov R.V. involved in financial flows, e.g. Q.Broker LLC, FG JSC, QBF JSC (despite the fact that these organisations may have had other persons as accountants).

  • Almost all of Shpakov R.V.’s corporate and personal payment orders were made through Ekaterina Gramza.

  • The complete list of transactions made by her was unknown to anyone, as many of them concerned personal payments of Shpakov R.V. However, due to the trust in Shpakova I.N., her competence in accounting and supervision of the entire accounting department of Shpakov R.V. companies, Ekaterina Gramza coordinated and approved with Shpakova I.N. part of the issues of making payments, reporting on them, as well as the company’s reporting to the tax inspection and regulator.V. was 100 per cent. In comparison, Shpakova I.N. may have owned 60–70 per cent of all financial information, which included full coverage of corporate payments and bookkeeping, but may not have included personal payments and orders from Shpakova R.V. Shpakova I.N., residing in Severodvinsk, flew to Moscow and stayed there, appearing in the office from several days to 1–2 weeks.

  • The frequency of her visits to Moscow was once every 1–3 months. I.N. Shpakova became involved in managing financial flows from about 2015 to 2016. Shpakova I.N. did not have access to personal accounts; she did not need them, while Ekaterina Gramza had access to several company personal accounts.

  • Shpakova I.N. is the mother of Shpakova R.V. She is an accountant/financier by competence and speciality. I.N. Shpakova started participating in the company’s affairs around 2014 when the construction of the first residential buildings in Severodvinsk, where she permanently resides, began.

  • The construction of residential properties in this city began with the launch of the QBIF Regional Real Estate fund through QBIF Asset Management LLC and the client money attracted there, as well as the bank credit line obtained on this basis. R.V. Shpakov entrusted her with this city's complete financial and organisational construction management.

  • After 2015, with financial difficulties in payments to clients and delays in salaries and remuneration of the company’s employees, she began to take part in the work of the entire accounting department of Shpakov R.V.’s Russian companies.

  • Shpakova I.N. supervised the hiring of accounting staff, organised their work, supported the creation of company reports to the tax authorities and regulators, supported the processing of certain significant and document-intensive payments, supervised responses to requests and instructions from the tax authorities and regulators, took part in the preparation of the company’s financial statements, participated in the preparation of the company’s financial and organisational management. A.V. Sorokin, the husband of I.N. Shpakova, and D.V. Sorokin (brother of A.V. Sorokin) were trustees of R.V. Shpakov and I.N. Shpakova about construction projects of R.V. Shpakov in Severodvinsk. With the help of these persons, R.V. Shpakov organised the possession of the construction objects and the procedures of various registration, reporting, and payments related to these construction objects.

  • The Sorokin brothers have permanent residence in the Arkhangelsk region and represent the interests of R.V. Shpakov there, fulfilling his instructions.

  • Timur Turlov is an old acquaintance, friend and partner of R.V. Shpakov, with whom the latter started to organise his business. Shpakov R.V.’s financial transactions involved Duntonse and then the Freedom Finance Group, including but not limited to FFin Bs (Belize), an organisation owned by Timur Turlov.

  • These entities accepted client money from Qubey Finance LLC and coagulated some or all of the funds raised in their accounts. The first of these companies, Duntonse, started working with R.V. Shpakov in 2010: its accounts were recommended by the sales department staff to be used by clients to send funds directly (opened in Cyprus).

  • Subsequently, when “QB Capital CY LTD” appeared, client funds were sent from it to “Duntonse” and then later to “FFin Bs” (Belize).

  • According to R.V. Shpakov, he and Timur had agreements.

  • Timur had financial participation and a share of remuneration due to him from the total turnover of client money attracted to Timur’s company accounts. During the period of direct referrals to Duntonse, this remuneration was higher.

  • Then, during the initial attraction to “QB Capital CY LTD” and transfer to Timur’s companies, his remuneration became lower, as Shpakov R.V. undertook the central part of the risks on initial payments.

  • At the same time, he (Munaev Z.V.) is convinced that Shpakov and Turlov’s companies carried out operations with the attracted funds not entirely per clients' interests but primarily based on their interests and intentions in appropriating part of client funds. Decisions made on the disposal of clients’ funds with “QB Capital CY LTD”, “Duntonse”, “FFin Bs” (Belize) could not have been made without joint and complete agreement between Shpakov and Turlov, as the foreign counterparties hired by them were responsible for ensuring the work of these organisations.

  • Timur Turlov also facilitated non-cash and cash payments to R.V. Shpakov and his companies and his offices. Timur transferred some of the non-cash funds to accounts controlled by Shpakov R.V.; in particular, he knows of several such payments to Kubi Finance LLC.

  • However, the main interest of R.V. Shpakov in receiving funds from Timur Turlov was in cash. In addition to the fact that Freedom Finance itself accepted and issued cash in its offices, sometimes, according to R.V. Shpakov, with receipts signed personally by Timur Turlov, the latter assisted R.V. Shpakov in withdrawing non-cash funds from foreign and Russian accounts, converting them into cash, delivering them at the request of R.V. Shpakov to him personally or his office for further processing.

  • Many employees, and he (Z.V. Munaev) among others, considered this delivery a collection service, which may have been some of the funds. Still, later, Shpakov R.V. often told high-ranking employees that Timur Turlov had helped him obtain these funds.

  • With the beginning of IPO sales by QBIF LLC, the relationship between Shpakov R.V. and Turlov T. was outwardly more competitive, and more recently, their (Shpakov’s and Turlov’s) relationship and financial interactions have been equal and identical to where they originally started.

  • Based on the large amount of client funds previously raised and transactions on them together with Timur Turlov, as it turned out, the latter was the only (apart from Linda Athanasiadou) reliable person for Shpakov R.V. who could provide custody of the remaining client funds at Shpakov R.V.’s disposal.

  • The previously accumulated funds in Turlov’s accounts could have allowed Shpakov R.V. to dispose of them at his discretion and in agreement with Timur, even in the face of a federal and international search, since these funds and the accounts controlled by Timur are located in foreign jurisdictions with complex ownership structures, where the relationship of these funds to Shpakov R.V. may not be evident at this time.

  • Moreover, R.V. Shpakov may use the situation with the criminal case to pressure Timur with various arguments in his favour to threaten him with criminal prosecution for earlier transactions if he is caught or if Turlov does not assist him in general. 

  • Alexey Golubev started working for QBF Group in St. Petersburg around 2013–2015 and was employed by either QBF Finance LLC or QF Estate SPB LLC; he began as a financial advisor, then was promoted to head of the department, then to head of office in St. Petersburg.

  • In management positions, he (A.S. Golubev) organised sales, recruitment of employees and their training,  and a non-material motivation system (trips, strengthening of corporate spirit).

  • Under A.S. Golubev’s leadership, sales of QBF products to clients were carried out by financial advisors. A.S. Golubev was responsible for the fulfilment of the sales plan, set sales plans for subordinate employees, determined vital indicators, the effectiveness of their activities, such as the number of calls, appointments, meetings held, contracts signed, the number of clients attracted for the month.

  • At different periods, Pakhomov V.S. and Golubev A.S. were signatories to the Agreements in the St. Petersburg offices and other branches.

  • When new branches were opened in the Russian Federation, the St. Petersburg manager, most likely Pakhomov V.S., acted as a signatory on behalf of QBIF LLC, and then, when the manager of the new office passed his probationary period and confirmed his position, he (Pakhomov V.S.) appointed Golubev A.S. as a direct signatory.

  • The management of the branch offices, their opening, organisation of their work and sales were carried out from the St. Petersburg office directly by Pakhomov V.S. Pakhomov V.S. had a power of attorney from the General Director of LLC IC QB&EF to sign client agreements on behalf of the company, as well as other business agreements (before 2017 - on behalf of the General Director of LLC IC QB&EF Frolov V.G., After 2017. - on behalf of Matyukhin S.).

  • On the instructions and orders of V.S. Pakhomov and R.V. Shpakov, the General Director of IC QBF LLC issued powers of attorney to other persons to sign client agreements. Office managers mostly communicated with Pakhomov V.S. and Shpakov R.V. only in urgent corporate matters, mainly during corporate trips, training and other team-building events. Evgenia Rossieva joined QBF Group In 2016. 

  • E.A. Rossieva’s direct supervisor was R.V. Shpakov, who supervised her activities and the activities of the entire division.

  • The Legal Department had several areas of action: corporate, licence activities, and legal proceedings. E.A. Rossieva and other lawyers needed a power of attorney to sign on behalf of the company. 

  • Eugenia personally recruited employees in the legal department.

  • She also organised the employees' work, workload, connection to specific corporate tasks, and interaction with other departments and employees. Related departments, both selling and non-selling, often turned to Evgenia and her staff for their direction and confirmation/acceptance from the legal department where necessary in internal and external counterparties' disputes and conflicts.

  • His interaction with Eugenia was regular on sales department issues, employee and client issues, and company contracts (labour, agency, client, partner). In sales and interaction with employees, he could give her direct assignments within his competence, and she made decisions to participate within her workload and in coordination with her manager, Shpakov R.V.

  • Also, interaction with her and her department was carried out on the side of the branch network, as a rule, on issues of the sales department, its employees and clients. In addition to the Russian part supervised by Evgenia, the interaction with her was carried out by Linda on the foreign part. Evgenia received instructions from her to create documents and bring them into compliance with Russian legislation so that they did not violate the law.

  • Evgenia was at the intersection of the Russian and foreign legal parts. 

  • Still, she needed to make decisions in the foreign part. 

  • She received input on the system of work, regulations, procedures, and norms mostly from Linda and less or very little from Apollo Athanasiadou. She also hired employees - “nominees” for the role of signatories through Shpakov R.V.’s contractors, as Shpakov R.V. had created a large number of companies in the perimeter and did not want to entrust specific issues to the hired staff - signatories, and instructed to engage external “nominees” for this purpose so that his orders would be carried out unconditionally.

  • Since R.V. Shpakov was the beneficiary of the licensed companies of the QBF group of companies, as well as the General Director of JSC FG QBF, the parent company of the group, he was subject to certain restrictions from the regulator and other inspection authorities in terms of combining positions, combining activities of the companies of his “formal” group of companies, and other companies related to him through “nominees”.

  • This applied to both the Russian part and the foreign part.

  • For example, on the foreign part at a particular moment, the will of the nominee for the company “QB Capital CY LTD” was made by him (Z.V. Munaev) because Linda approved that R.V. Shpakov for the liquidation of this company could not be directly connected with it.

  • Rossieva E.A. assesses her closeness to R.V. Shpakov as rather tight, as he (R.V. Shpakov) brought her up to speed and gave her instructions on a broad and relatively narrow range of issues concerning him personally.

  • E.A. Rossieva’s awareness was relatively high. E.A. Rossieva was paid a monthly fixed remuneration of not less than 100,000 roubles and annual and quarterly bonuses based on her performance. During his work in the company, he was aware that the heads of branches of LLC IC QBIF in the process of work, communication with clients, management of subordinates and processes, organisation of conclusion of contracts, deepening of their knowledge about investment products sooner or later began to ask questions that related to the activities of their offices. Some of these questions were inconvenient for R.V. Shpakov, who did not want to give detailed answers.

  • The heads of branches were interested in the reason why the terms of withdrawal of funds on behalf of clients are so long, where the clients’ funds are transferred to, what is the earnings of the company for a specific period, positions on the earnings of individual clients, how the clients’ accounts in organisations are credited with the funds accepted by them in cash, and how the withdrawal of funds is made from the company’s accounts for cash disbursement to clients, confirmation of reports, their compliance with the truth, and the reason for the agreement between the company and the clients.

  • There were questions about interaction with Timur Turlov. R.V. Shpakov explained to everyone that the Broker had the right to take a loan for himself, and R.V. Shpakov explained the high commissions of the company by this.

  • The office managers knew that “QB CAPITAL CY LTD” and “SIMTELLIGENCE COMPANY LIMITED” had no licences to carry out activities with securities.

  • He (Z.V. Munaev) knows about the activities of several heads of central departments and directions in the group of companies: he knows Oleg Timokhin personally; he (Timokhin) was one of the heads of the back office of “QB IC” LLC, was subordinate to Stanislav Matyukhin, kept records of the company’s clients’ operations using standard software, prepared reports for the regulator, was one of the employees accountable to the regulatory requirements.

  • His (Timokhin’s) accounting included all Brokerage Services and Trust Management operations. With the appearance of the IPO product in the company, he (Timokhin) also had close communication with Shpakov R.V., Korzh A.V., Spinka R.V. Shpakov R.V. gave Timokhin instructions to form the terms of contracts, their expiry dates, other standard points of accounting due to deep penetration into the operational processes of the company.

  • The accounting that Timokhin was in charge of was not part of the accounting and finance department and was not responsible for the distribution of finances and payments; however, Timokhin worked closely with the accounting department due to related reporting accompanied contracts (with VOD) with Q.Broker LLC, informed Shpakov R.V. and the sales department about impending cancellations, necessary prolongations and other actions for the standard work of the brokerage business.

  • Ruslan Spinka was the Head of the Sales Department after Vladimir Pakhomov's term, approximately from 2020. He (Spinka R.), like the previous heads of the department, had under his command heads of sales departments, financial advisors, and freelance agents who were hired for a percentage.

  • He started his working career in the most junior position; from about 2014, he was engaged in personal sales and was the head of the sales department for a long time. Spinka was personally appointed to the position of Head of the Sales Department by R.V. Shpakov, and his duties included the standard functionality: ensuring sales plans, developing new products, liaising with related departments, creating a personal account for the company’s clients, ensuring traditional activity and efficiency indicators for sales department employees.

  • He interacted with him (Spinka) personally in terms of assisting in the work of the sales department given his (Munaev Z.V.) extensive previous experience, as well as given the development of partner and agency areas. His (Spinka R.) period of work also coincided with the “boom” of the IPO product launch; he (Spinka R.) ensured the recruitment of new employees. International market clients were transferred to the support department. Spinka reported directly to R.V. Shpakov and carried out his (Z.V. Munaev’s) assignments as directed by R.V. Shpakov.

  • Andrey Korzh started in a junior position, fulfilled his personal sales plan, was later promoted to Head of Sales, and effectively met sales targets. On Spinka’s appointment as Head of Sales, Korzh was appointed as his deputy and assisted Spinka in organising and running the sales department. Korzh’s direct communication with customers was active during his tenure as a financial advisor and his personal sales plan.

  • After that, his work with clients was sporadic, involving either conflict situations or the need to attend a meeting when discussing prospective deals at the request of either clients or subordinate employees. As he (Korzh) worked for the company, his (Korzh’s) functionality expanded but did not change much.

  • Korzh had a close relationship with Timokhin during his work with the IPO product regarding contract renewals.

  • Also, R.V. Shpakov often instructed Andrey Korzh about these or those prolongations, new IPO deals, and the need to discuss with clients directly. Vladimir Maslennikov joined the company around 2012.

  • Maslennikov has been a financial advisor for almost his entire career and has received numerous awards for best results, but his promotion was delayed.

  • When Ruslan Spinka was appointed head of the sales department, the latter appointed Vladimir as head of the client support department, including some former sales department employees and new employees.

  • All international clients of the Moscow office were transferred to this department. Vladimir Frolov, who at that time and after that held the position of General Director of Qubey Finance LLC, has known him since his employment.

  • Subsequently, it was explained to him that he (Frolov) was a nominal director, i.e. a fictitious, fake director. The actual director managing the company is R.V. Shpakov. Everyone treated it as a common practice. Subsequently, when the legal department appeared, Shpakov R.V. assigned him (Munaev Z.V.) the task of finding nominees (front directors) for certain companies, and for the most part, Evgeniya Rossieva, in the foreign part, the tasks were assigned by Shpakov to Linda Athanasiadou. Some of the signatories he remembers now were Gorobets Elena, Korshunov, Maricheva, Marichev and others. He was not personally acquainted with them.

  • Gorobets was a nominee in “QB CAPITAL CY LTD” for a long time, probably during the period of management and ownership by R.V. Shpakov directly. 

  • The name Gorobets was in the incoming and outgoing cash documents, and facsimiles made signatures (which corresponded to reality).

  • He and all employees knew about her (Gorobets) existence and heard that she had often been to the notary’s office with lawyers, probably before and during her work with Evgeniya Rossieva.

  • Her (Gorobets) role was at least as a signatory from “QB CAPITAL CY LTD”. Roles of signatories of “QB CAPITAL CY LTD”, including nominal ones, in different periods were fulfilled by many other employees: heads of departments, offices, and sales departments, and initially including Shpakov R.V., Kuzin S.L., Modin N.V. as real actors. In this connection, the roles of the signatories on behalf of “QB CAPITAL CY LTD” caused a few questions for the company's employees.

  • The signatory should have had a power of attorney from Shpakov R.V. For a long time, the director and signatory of the contracts of “QB CAPITAL CY LTD” was directly Shpakov R.V. Voronova was the accountant of “QB CAPITAL CY LTD” for a long time approximately in the period from 2010 to 2018. Voronova accompanied the operations of both the licensed companies and other operations of Shpakov R.V.’s companies before the appointment of Ekaterina Gramza to this function. Voronova was aware of the operations of Shpakov’s companies in the Russian part.

  • She may also have been aware of some relations between Shpakov R.V. and Turlov, knew about the company “Dantons”, accepted payments to LLC “Kyubi Finance”, and reported to the tax inspectorate between 2015 and 2018. Voronova worked closely with Ekaterina Gramza, who assisted her and took over some of her functions. During the initial work period, Shpakov R.V.’s level of trust in Voronova was close to 100 per cent in the Russian part.

  • With the introduction of Ekaterina Gramza into the accounting department, Shpakov’s trust in Voronova diminished. Korshunov had been solicited no earlier than 2018 and was one of the signatories in Shpakov’s foreign companies.

  • Evgeniya Rossieva, employees of the legal department, other freelancers from among possible acquaintances of Shpakov or acquaintances of the company’s employees participated in the search for nominees on behalf of R.V. Shpakov.

  • Discussions on the need for nominees were held, particularly with Kirill Padun. In addition, Berezka Andrei, an acquaintance of Vladimir Pakhomov, assisted in the search for nominees.

  • Eugenia Rossieva approached Berezka A. on behalf of Shpakov to search for nominees. Rossieva had direct cooperation with Berezka.

  • One of the private situations of conditions in attracting and servicing clients was the situation with Borzenkov, about which he has information from the words of R.V. Shpakov and V.S. Pakhomov, as well as Sobolev, including during his (Z.V. Munaev) visits to the Moscow office of IK QBF LLC, as well as from general corporate correspondence and chats in messengers.

  • According to R.V. Shpakov’s decision, QBIF LLC's activities of selling financial products were carried out in various regions of the Russian Federation, including in the city of Yekaterinburg.

  • An office in this city was opened by Kirill Sobolev and Vladimir Pakhomov in approximately 2014.

  • Together they organised the recruitment of staff, sales methodology, production and maintenance of memos, staff training, marketing materials and their distribution to potential clients, radio and other advertising, a system of document management, acceptance and transfer of funds, legal support for local clients and the office as a whole, as well as rent and related administrative matters.

  • Sobolev was the first head of this office and was appointed to this position by Vladimir Pakhomov. V.S. Pakhomov, in turn, was the director of the entire branch network, responsible for its functioning, ensuring its operations and attracting clients.

  • By that time, apart from the Moscow office of Qubey Finance, there were at least 2 and at most 4 regional offices.

  • One of the clients of the Ekaterinburg office was Borzenkov. He (Z.V. Munaev) learned about this client within a year after his appearance from R.V. Shpakov and V.S. Pakhomov in connection with comparing the sales results of the Moscow and branch network offices.

  • Moscow and the offices of the branch network, when they were discussing the successes of these offices and the most significant results.

  • Sobolev and Pakhomov personally knew Borzenkov, participated in negotiations with this Client, and offered him (Borzenkov) an individual and different approach to the organisation of work with the Company due to Borzenkov’s considerable financial resources and prospects for their expansion in work with the Company. Borzenkov was a local businessman and former local official.

  • From the words of R.V. Shpakov and V.S. Pakhomov, he (Z.V. Munaev) knows that Borzenkov was offered personalised legal terms, additional agreements, service tariffs, financial transaction schemes, other personalised terms (terms different from other clients, more favourable).

  • Sobolev and Pakhomov V.S. promoted and insisted on these conditions and scheme of work due to their high interest in developing relations with the client and receiving personal financial results and personal remuneration, which depended on the amount of money deposited.

  • They also had an agent from among the employees of Borzenkov’s companies, who, for a fee, assisted both in attracting this client and in financial and legal support.

  • The remuneration of this agent was also non-standard and differed significantly from the remuneration of the other agents. This remuneration may have included payments to Sobolev, Pakhomov V.S., and others.

  • As part of the agreements concluded with Borzenkov in 2016–2017 with IK QBIF LLC (asset management agreements) and QB CAPITAL CY LTD (for the provision of direct access to international stock markets), the client transferred funds to the accounts of QB CAPITAL CY LTD.

  • As with other clients, it was assumed that Borzenkov would receive standard trust management services and income according to the agreed strategy.

  • As we know from the situation with the companies of QB Group on the Clients attracted in this way on the relevant contracts with LLC “IC “QB” and “QB CAPITAL CY LTD”, money for management was received directly by R.V. Shpakov, having all the keys both from the bank - client “QB CAPITAL CY LTD” and other trading access keys as the owner (beneficiary).

  • Pakhomov and Sobolev took part according to the roles defined to them by Shpakov R.V. in misleading Borzenkov in terms of his service on the international financial markets, namely in the reliability of the scheme of work of the companies involved, the perimeter of the licence coverage, the presence of regulatory structures, the reliability of bank inspections, further supervision of regulators on the targeted use of funds. Significant in the desire to induce Borzenkov to agree were the increased returns promised to Borzenkov and the personal financial and legal scheme of work specifically for Borzenkov that was presented as legal.

  • “QB CAPITAL CY LTD” did not have a licence from the Cyprus regulator to carry out investment brokerage activities, did not have personal client accounts, as well as access of portfolio managers of “IC QBIF” LLC to foreign trading accounts of QB CAPITAL CY LTD, as all accesses were directly with R.V. Shpakov.

  • When the investment company received the funds and transferred them for management, they were distributed to portfolio managers (traders) who, following their job descriptions, powers, as well as experience and skills, should implement a trading strategy using these funds to make a profit for the clients and the Company.

  • In the case of Borzenkov, the funds did not reach the portfolio managers; R.V. Shpakov handled all the funds himself and at his discretion.

  • According to the words of R.V. Shpakov and V.S. Pakhomov, on the personal scheme of work with Borzenkov, the funds transferred by him to “QB CAPITAL CY LTD, initially had a specific purpose, belonged to companies related to him, who received these funds for specific uses.

  • Borzenkov’s financial director organised and consolidated the funds from these companies, and together with Sobolev and Pakhomov, they transferred the funds to Cyprus under contracts with “QB CAPITAL CY LTD” to subsequently receive the funds (part of them) used in circulation on the financial market to other accounts of Borzenkov and his related companies.

  • For this purpose, Sobolev and Pakhomov prepared additional supporting accounting documents for Borzenkov and his financial director to close Borzenkov's and his companies' accounts. According to Pakhomov, via wire transfer, V.S. Borzenkov received some of the money in different amounts at different times. While working with Shpakov, Borzenkov and Shpakov had difficulties acquiring the rest of the money.

  • Borzenkov expressed apparent dissatisfaction and promised Shpakov R.V. problems, about which Shpakov R.V. personally informed him (Munaev Z.V.). In conversation with him, discussing the reasons for the impossibility of total return of Borzenkov’s money, Shpakov R.V. referred to the market situation, documentary requirements of banks, the complexity of trade transactions, the procedure of client checks by banks - exactly everything that he (Shpakov R.V.) told him (Munaev Z.V.) and other clients of the Moscow office. Moscow. When interacting with Borzenkov on behalf of Shpakov R.V., Pakhomov V.S. and Sobolev also vastly exaggerated the list of required client documents for the bank to delay the withdrawal process, to frighten the client with bank requirements, to make the client change his mind and refuse to withdraw funds, to be more loyal to the company for the support provided to him in defence of his interests before banks and verification procedures.

  • Pakhomov V.S. and Sobolev were aware of this and were executors in this part. But the main reason of non - repayment is the intention of Shpakov R.V. to embezzle the funds of Borzenkov, whom Pakhomov V.S. and Sobolev misled on his (Shpakov R.V.) scheme of work.

  • Regardless of the situation with banks and inspections, if R.V. Shpakov had the intention to realise a settlement with a client, he could have done it in various other ways.

  • According to the contracts concluded with Borzenkov, the client was counting on the target return specified in them (in the form of profit in monetary terms, not in the form of receipt of securities as an asset or property, the delivery of which was not stipulated in the contracts), which Pakhomov and Sobolev could increase due to their negotiating position and authority, which undoubtedly attracted the client and, along with other personal conditions, convinced him of the need to cooperate with Borzenkov.

  • One of the managers of the Cypriot company “NOA CIRCLE” Athanasiadou Linda, was aware of the situation and participated in the process of organisation of financial flows, transfers, legal support, preparation of necessary documents, reporting to banks, etc., including Borzenkov’s money. According to her, Shpakov R.V. did not allocate timely financing of the required amounts for the transfers to Borzenkov on the required dates.

  • Also from Pakhomov’s words he (Munaev Z.V.) knows that he (Pakhomov V.S.) kept a part of client contracts and documents.

  • The documents were kept at his residence in a flat in St. Petersburg and in a flat in Moscow: these were contracts (or part of them) concerning clients in St. Petersburg. Pakhomov V.S. could have kept customer contracts of other branches, as customer contracts were taken from branches but with different frequency. As for the client contracts of clients in Moscow, they were kept on behalf of R.V. Shpakov by the responsible employee Ekaterina Gramza at the following address: Moscow, Presnenskaya Naberezhnaya, 8 p. 1, residential apartments in the tower. 1, residential apartments of the Capital City Tower, north block, apartment number and floor he does not know. Pakhomov V.S. was directly involved in supervising the company’s issues with the Central Bank of Russia and law enforcement agencies, for which he received additional remuneration from Shpakov R.V. In general, Pakhomov V.S.’s awareness of the work of Qube Finance LLC in Russia and abroad is relatively high, in private matters with Shpakov R.V. and his assignments, as well as in solving issues with various government agencies.

  • During his work in the company, he (Z.V. Munaev) had a corporate phone, an “iPhone XS Max” IMEI 357287094420629, a corporate SIM card with the number 9031004184 was installed in it; this phone was intended for his personal use. He and sometimes Shpakov R.V. used the phone in correspondence with Cyprus and negotiations with Linda, in those cases when he allegedly wanted to communicate information from his (Munaev Z.V.) phone, allegedly on his behalf. Shpakov R.V. also conducted some personal correspondence from his phone, which he (Shpakov R.V.), as he said, deleted afterwards.

  • After presenting a copy of the protocol of examination of items (documents) dated 20.12.2020, he explains the following: in the correspondence dated 12.03.2018 for the period of time from 09:19:34 to 17:47:04 from the mobile application “WhatsApp” between him and the lawyer of the company Rossieva Evgenia Anatolievna, with mobile phone number (+7985–173–43–21) it was about the purchase of the company, which was necessary for the procedure of re - signing contracts with Clients in connection with the liquidation of “QB Capital CY LTD”, to other companies, which subsequently were “Simtelligence Company Limited” and “White Lake Management Ltd”. At first, for this purpose the company “Big City” was found, which was abandoned, and another organisation was found - “Yurmaster” LLC, the head of which was a nominee in the interests of Shpakov R.V. The nominee had a power of attorney on behalf of Shpakov R.V., and Evgeniya Rossieva knew more about it.

  • This company, which is referred to in the correspondence, was to take over as an intermediate Russian party the rights and obligations of “QB Capital CY LTD” (the Cypriots, i.e. Linda insisted on this; they were the ones who developed this scheme), to take over and immediately transfer the rights and obligations to “Simtelligence Company Limited”. In the correspondence dated 12.03.2018 for the period from 10:23:16 to 17:46:45, 13.03.2018 for the period from 09:50:11 to 15:19:09, as well as 26.03.2018 at 15:07:01, it was discussed that all monetary relations, payments, payments, confirmations, approvals on expenses were given directly by R.V. Shpakov.

  • Often, for lower-level employees, he could aggregate information for some payments for different departments for his approval without his direct participation, as the number of employees in the Moscow office is more than 150 people from more than ten departments. 

  • Also, often in correspondence, he could negotiate some expenses and discuss the company’s position on his behalf. Still, he often referred to R.V. Shpakov because all employees knew that the payments came from him. All lists of required expenditures he collected were handed over personally to Shpakov R.V. He did not contain all the lists. 

  • Still, only a part of them for those departments with which he interacted, or not for his departments, but concerning issues related to Shpakov R.V.’s instructions, these could be, as a rule, heads of departments, also persons reporting personally to R.V. Shpakov or, due to the importance of payments, discussing upcoming payments with him privately.

  • They could also be assistants and secretaries close to R.V. Shpakov during different company work periods (they were dismissed and changed). For Eugenia Rossieva, as a rule, he handed over lists and applications with the actual amounts needed.

  • During most of the company’s operation, all payments and lists were handled directly by Shpakov. Still, when the financial situation with external and internal payments became complicated, in order not to be “pestered”, he (R.V. Shpakov) would put him (Z.V. Munaeva) as an intermediate link for filtering.

  • On the lists handed over to him, R.V. Shpakov put either “pluses” (if he fully agreed with the necessity of this expenditure item) or, if he disagreed, a specific amount that he decided to allocate for this expenditure item.

  • Also, R.V. Shpakov could ask him to confirm any item. For the most part, his (Z.V. Munaev’s) involvement in these matters concerns the period After he was removed from his position as head of the sales department because, in his opinion, he had sufficient free time.

  • He (Z.V. Munaev) regularly had to face the negative attitude of R.V. Shpakov towards payment and, as a consequence, late payment of both critical and most minor payments.

  • Shpakov R.V. controlled all expenses of the company and employees to the ruble, both significant and essential, and relatively insignificant.

  • As a result, R.V. Shpakov mainly distributed money for previously agreed expenditures to employees himself - primarily through the heads of departments. Sometimes, he (Shpakov) passed the required amounts through him.

  • In the correspondence, “RV” and “Roman” - this is everywhere. Shpakov R.V. Alena - this is Kabanova Alena, the secretary of the 2nd internal reception, who was subordinate to all employees of this unit.

  • Who is Sergei - he can’t remember now.

  • This correspondence is about fulfilling some unimportant assignment, some momentary issue unrelated to regular activities—Svetlana Beloded - Head of the Recruitment Department.

  • Natalia is a corporate lawyer, Eugenia’s subordinate.

  • Anastasia is Anastasia Ananyeva. Six per cent of the share of the authorised capital of QB Capital CY LTD was “rewritten” from him to her: due to the process of re-signing contracts and liquidation of QB Capital CY LTD; he was removed from the number of participants of QB Capital CY LTD), although he did not want it and waited for at least the first payment of dividends from 2014 to 2018.

  • A share in a company has value, especially in a licensed company, and he was counting on it. Shpakov R.V. offered him the option of transferring “on paper” his part, 6 per cent of the share in the company, to some of his trustees.

  • For this reason, he turned to his acquaintance, Anastasia Ananyeva, who agreed to help him without knowing the details out of her kindness. Ananyeva was appointed to take part in the company for some time, but this lasted only a short time.

  • After the liquidation and all the procedures had been completed, Shpakov R.V. denied him the right to have Anastasia among the participants of LLC “Kyubi Group” and offered to transfer to him (Shpakov R.V.) these 6 per cent of the authorised capital of the company, explaining that now he would tacitly and by their verbal agreement have the same 6 per cent share in case of sale of the company or accrual of dividends with him (Shpakov R.V.). Pakhomov V.S.’s share in the Company (6 per cent) remained unchanged.

  • Because earlier Shpakov R.V. convinced him of the necessity of his participation in the liquidation procedure of “QB Capital CY LTD”, the role of nominee and signatory, and the fact that he agreed with it, he did not think that he (Munaev Z.V.) would become a participant and procedural part of all legal, documentary, other processes, meetings, correspondence.

  • However, it happened because he agreed and signed.

  • During and After the liquidation procedure of “QB Capital CY LTD”, contrary to his wishes, he had to lead or mediate in many meetings and correspondence. However, the initiatives and tasks were not from his side. In the correspondence, “approached C” - suggests that this refers to Stepanov, one of the major clients, but he is unsure.

  • Stepanov was one of the first to file a complaint with the Central Bank law enforcement agencies or go to court regarding delayed refunds. “Kg” - we are talking about “KG” LLC (Kyubi Group).

  • The 6 per cent stake he previously owned is about his participation in the authorised capital of LLC Kubi Group.

  • Marianna Scherbakova is a marketing specialist.

  • At one time, the issue of providing additional services from marketing for a particular segment of clients, including legal services, was discussed.

  • Shcherbakova had contacts in law firms, as far as he remembers. Evgenia Rossieva could have approached Marianna about finding candidates for the role of nominee director. “Ds” for cash.

  • In the correspondence from the mobile app for 14.03.2018, 14:26:37 and 14.03.2018, 14:27:41, the abbreviation “kep” was used to refer to “QB Capital CY LTD”, the abbreviation “IC” referred to QB Investment Company Ltd.

  • In this correspondence it is about sending letters to clients about liquidation of “QB Capital CY LTD” and re - signing contracts to other organisations, so that they understand that the procedure is legal, it is not bankruptcy, not a “scam”, but a process of renewal of infrastructure and jurisdiction.

  • Talking about “unpaid invoices”, - he does not know what kind of invoices we are discussing. Still, he believes that Evgeniya Rossieva did not want the presence of such information to provoke negativity on the part of Clients so that various unnecessary thoughts and logical chains would not arise.

  • There were never any direct payments between “QB Capital CY LTD” and IK QBIF LLC, which should not have been, according to the initial installation.

  • "We wrote everywhere" - referring to QB Capital CY LTD’s responses to enquiries from the Central Bank.

  • "Frolov signed" refers to notifications to clients.

  • In the fragment of correspondence for 15.03.2018 for the period from 22:56:50 to 15.03.2018, 22:56:58, the phrase “Noa candidate” indicates that at that time there was a recruitment of employees in the Russian organisation “NOA” - a law firm being established to provide services to external clients.

  • The plan was to create a Russian firm with the name “NOA”, a project of Linda Athanasiadou.

  • "NOA candidates" - those wishing to be employed were also partly lawyers or had contacts with law firms.

  • There is such a business practice that even if they are not employed, potential business relationships with some remain.

  • As a result, the Russian NOA organisation was established in 2020, and Alexander Nepomnyashchy was appointed its director.

  • The Russian NOA had its own separate line of business related to Russian services for new Russian clients.

  • The Russian “NOA” did not overlap with the Cyprus “NOA CIRCLE” previous lines of business mentioned earlier in the interrogations.

  • The fragment of correspondence from 16.03.2018 from 12:41:27 to 18:48:22 is about the search for a nominal (front) director for the organisation “BigCity”.

  • According to one of Shpakov R.V.’s instructions, this organisation was to be registered to him (ownership of it), and a nominee was sought for the post of general director.

  • In the fragment of correspondence dated 22.03.2018 in the period of time from 12:40:03 to 14:02:26 the abbreviations “signatories” were used, “BR” - Bank of Russia, “Intermarket” - direction to conclude agreements with Clients on direct access to international stock markets; “they” - either Evgenia Rossieva or she together with Stanislav Matyukhin.

  • Eugenia’s message suggests that there were no violations of the letter of the law at the moment on the part of the company, but there are verbal recommendations, instructions and “motivated judgement” (this is the official stable wording”) of the Bank of Russia about this or that event or practice, which prompts a market participant either to refuse something or to bring it into compliance with a change in structure or interest.

  • In the context of “ik” on the part of “br”, this is what is being referred to. “Cyprus 3 contracts” - We are talking about three clients who complained about the non-return of funds and could write complaints to the Bank of Russia website.

  • The contracts with the Clients were standard: one with a Russian organisation, one with a foreign one.

  • "The “signatories” to the contracts were employees of QBIF LLC who had powers of attorney to sign the contracts on behalf of the company.

  • All of the branch managers of QB&E LLC, in particular, were signatories.

  • Reorg is a part of the process of general liquidation and re - signing procedure, which means reorganisation of LLC IC QB&EF directly, spin - off of LLC QB&EF from it, which “takes” from LLC IC QB&EF the assignment contracts (international market contracts), thus fulfilling the recommendation of the Bank of Russia to stop participation of a licensed company in the procedure (practice) of international assignment contracts. “Edweiserie” - LLC “QBF Edweiserie”.

  • There should have been another company, also an official member of the QBF group of companies, but at the same time not falling under a licensed IC, which would have handled international assignment agreements so that interaction with Clients would have been within the law (the latest recommendations of the regulator).

  • The idea was to use QBF Advisor LLC for these purposes, but it still needs to be realised. The Bank of Russia did not like OOO IC QBF carrying out international activities that the Russian regulator should have covered. Therefore, the Bank of Russia recommend “rid” OOO IC QBF of international contracts. In the fragment of correspondence dated 29.03.2018 in the period from 13:22:24 to 13:23:12, the mentioning of “Cayman and Hong Kong” and “need two signatories” refers to the organisations “Simtelligence Company Limited” (Hong Kong) and “White Lake Management Ltd” (Cayman Islands), to which it was planned to renegotiate contracts with Clients from “QB Capital CY LTD”. This was one of Linda’s assignments, the fulfilment of which was part of the overall re-signing process.

  • "Baffle your colleagues and Berezka" is about persons who Evgeniya Rossieva approaches to search for nominee directors for the role of founders/nominee directors of organisations, including Andrei Berezka, who was mentioned earlier.

  • Eugenia was given tasks on this matter directly (Linda) and through him, as he took on many tasks. In the last sentence, authored by him (Z.V. Munaev), he had the following in mind: there were cases when a client asked why the person whose signature was on the contract was not present and wanted to see that person in person.

  • For such purposes, it would be possible to show the signatory of the contracts at the client’s request that “they should be ready to come to the office”.

  • In the fragment of correspondence dated 29.03.2018 from 16:03:29 to 17:25:26, the following persons were referred to: Gorobets is the nominal director of “QB Capital CY LTD”.

  • "Other similar friends" are other nominee directors of organisations within the QB Capital CY group of companies. He did not know the amount of their fees and had yet to deal with it before; this is known to Eugenia in detail.

  • As far as he knows, when negotiating payment for the nominee’s services, the latter proposed a price, and R.V. Shpakov either agreed or adjusted it. His (Z.V. Munaev) role in this matter was reporting (giving information) and coordinating, but he did not take responsibility.

  • Evgeniya Rossieva was in charge of calculations with the nominators for their services. 

  • The payment was monthly, either in cash or by transfer to a card. 

  • This procedure was in place both before he joined the organisation and during his employment with it. It was carried out by Evgenia Rossieva or other employees of the legal department, who did not have any unnecessary questions about this practice of engaging nominee directors. The fragment of correspondence dated 30.03.2018 refers to the ZPIF of art objects, “Artfond”.

  • This is a separate topic of conversation.

  • The fragment of correspondence dated 02.04.2018 at 11:03:59 - 11:05:24 is about the following: reorganisation - refers to the process of separation of QBIF LLC from QBIF IK LLC to form a Russian organisation to switch international stock market access contracts to it on the strict recommendation of the Bank of Russia. Rentinvest LLC was a company of R.V. Shpakov that leased offices, which subsequently hired specific areas to specific Shpakov companies. Maxim Yudin was one of the signatories.

  • On Shpakov R.V.’s initiative, he again wanted to be involved as a signatory; he (Munaev Z.V.) knows Yudin well and knows that for him penetrations into foreign processes of the firm were not pleasant, so he asked to minimise his role. “Discuss issues of assignment contracts” - meaning international stock market access contracts: there was a planned discussion about which organisation they would transfer to After the reorganisation, plus there were topical issues of communication with clients so that everyone was notified and everything went smoothly.

  • The discussion was planned, as the process was accompanied in the Russian part by Evgenia Rossieva and in the foreign part by Linda Athanasiadou. In the fragment of correspondence from 23.04.2018 in the period from 13:03:14 to 13:07:13 and 24.04.2018 in the period from 11:02:48 to 11:04:02, the following was discussed: Alena is Alena Kabanova, birch is Andrey Berezka, Kirill is Kirill Padun. An intermediate variant of finding an organisation was discussed. In the end, the organisation Yurmaster Ltd was acquired, but he remembers exactly that it happened without the participation of Andrei Berezka.

  • As a secretary, Alena could pass information about upcoming expenditures to Shpakov R.V. and him (Munaev Z.V.) to pass to Shpakov R.V. Kirill Padun was approached by Eugenia for services, as was Berezka.

  • The nominee (here, meaning the signatory - the person on whose behalf the contracts would be signed from the organisation “White Lake Management Ltd”) was found by Kirill Padun.

  • Since Linda was in contact with the CEO of White Lake Management Ltd, she had to execute a power of attorney for the signatory on his behalf.

  • This power of attorney was eventually formalised and executed abroad. Draf contracts were awaited from Apollo Athanasiadou.

  • Discussions of payments did not signify the obligation to fulfil them later. The fragment of correspondence from 23.04.2018 from 15:37:38 to 18:30:00 was about Yurmaster Ltd.

  • Christina is Christina Bogdanova. She could have done what she was asked on an errand; however, why could she have been approached with a request related to Andrei Berezka? He does not know. In the fragment of correspondence dated 06.04.2018, the following abbreviations are used: Q is “QB Capital CY LTD”. “C” meant the Client Stepanov, who, because of the problems that arose with the withdrawal of funds applied to some instances, at the same time, collected an impressive set of documents, including some in the territory of Cyprus. Gorobets signed contracts for “QB Capital CY LTD” and “QB Group” Ltd.

  • For this reason, Evgeniya Rossieva feared that this fact might suggest that these organisations were affiliated. The fragment of correspondence dated 06.04.2018 from 15:47:52 to 15:58:52 was about Zarechnev, a current employee; for this reason, he was not suitable for the role of a signatory. Marianna is Marianna Shcherbakova, and she had contacts from previous jobs in law firms.

  • For this reason, Eugenia periodically turned to her for help finding signatories and nominees. In the fragment of correspondence dated 06.04.2018 in the period from 15:59:44 to 17:44:03, the possibility of resolving the issue to take into account the previous comments of the Bank of Russia (CBRF) regarding the work of QBIF LLC and international agreements was discussed.

  • At this point in the correspondence, the question immediately arises regarding a legitimate company that would be an authorised agent for the sale of services of foreign investment companies, having the necessary signatories and documents. The company in question is K - Investment LLC. This company subsequently had employees employed by it selling units of different markets (jurisdictions) and various products of other companies.

  • The company acted as an Agent in Russia, selling services of foreign companies. The fragment of correspondence dated 12.11.2020 in the period from 12:41:35 to 16:15:42 is about contractual relations with Vyatkina A.G., as well as about the actions and decisions of the employees of IK QBF LLC concerning her, namely Ruslan Spinka - Director of Sales Department, they went together with him to Shpakov R.V. to discuss issues of payments to clients. For this reason, Evgeniya approached him (Z.V. Munaev) with a question about another client, Vyatkina, so that he could find out the details from Spinka. Usually, if the client was from Moscow, he could answer or find out from Spinka, and if not, he would forward these questions to Golubev and Pakhomov.

  • He needs to remember the details of his interaction with a client such as Vyatkina. There were different people among the clients: some asked for cash withdrawal only, some needed only a cashless transfer, and some did not care. However, noncash transfer of funds could be made only After re-signing contracts with “QB Capital CY LTD” to “Simtelligence Company Limited” and “White Lake Management Ltd”. Usually, R.V. Shpakov decides how to disburse funds to a particular client or could meet the client’s requirements if they were specific (cash or non - cash payments).

  • "Closed in the ECB" means “to close the transaction.” After signing contracts with the client, he received funds from the client within the framework of the achieved contractual relations. So, the client in question, Vyatkina, transferred money to the company’s account in Yekaterinburg. “VSP” stands for Vladimir Sergeevich Pakhomov. Dp - Sales Department. FS - Financial Advisor.

  • He does not know who Vyatkina’s financial advisor was.

  • The fragment of correspondence from the mobile application “WhatsApp” with the contact “Andrey Korzh” (+7 965 411–72–25) in the period from 06:03:10 to 12:50:24, is about contractual relations with Koptev S., as well as about the actions and decisions of the employees of LLC “IC QBF” regarding him, namely: he was afraid to meet with clients at certain moments because promises and deadlines for withdrawal of funds were not fulfilled.

  • Some of the clients were very senior and influential persons, and given that he was a signatory and one of the executives in the company whom the clients might know, he was wary of making commitments because he could not honour them as it was not up to him.

  • The clients were restrained as best they could: they were asked to wait, referring to the unfavourable value of the portfolio at the moment; they said that we were withdrawing, wait; it depended not on us but on foreign banks, which did not let money into Russia; foreign partners were delaying; we were selling off the portfolio, everything would be soon; the money was hanging in a bank abroad; there was a hefty commission at the stock exchange in the bank, and so on.

  • According to personal agreements with clients, it could have been a matter of settling assets/property - meaning RIF, real estate.

  • He (Z.V. Munaev) would give such a recommendation, which was left for discussion, as the decision did not depend on him.

  • But in the case of his employees’ appeal to him, he always tried to get into it and help with an opinion or action as much as possible.

  • Koptev was Pakhomov’s Moscow client during his time in Moscow.

  • They initially had a good personal relationship, which deteriorated.

  • Since the client is Moscow-based, he was assigned to Andrei Korzh as an escort.

  • In a fragment of correspondence from the mobile application “WhatsApp” with the contact “MAKS” from 18.10.2018 from 12:26:41 to 14:00:44, the dialogue was with Maxim Yudin.

  • They got a job at QBF in 2010.

  • They have an excellent mate-working relationship.

  • The correspondence with Yudin was about non-cash withdrawals to clients.

  • He asked to send lists of clients to report to R.V. Shpakov so that he (R.V. Shpakov) could pay attention to incredibly dissatisfied clients for settlements with them.

  • Maxim raised the issue of sending reports to clients After re-signing contracts.

  • It was also discussed that reports to clients from “White Lake Management Ltd” are visually similar to the previous reports from “QB Capital CY LTD”.

  • The reports were prepared and sent by the same persons both on behalf of “QB Capital CY LTD” and on behalf of “White Lake Management Ltd” and “Simtelligence Company Limited”.

  • The reports were sent After the contracts were re-signed and should have been sent from a different domain so that the clients would not have any questions.

  • However, at first, the report mailings on behalf of “White Lake Management Ltd” and “Simtelligence Company Limited” were technically done from the same domain as “QB Capital CY LTD”, i.e., they forgot to update.

  • In addition, it had to be remembered that the “old” clients who had not re-signed the contracts and reports had to be prepared and sent on behalf of “QB Capital CY LTD”.

  • In the fragment: “Max: There would have been bought positions in the reports”, this phrase meant that some clients had blank report forms, which was a programming error.

  • QBF employees received client reports about 3–5 days before the clients, checked them, and analysed them to prepare reviews and comments.

  • According to the regulations, once a month at least, the client is consulted either by phone or in person, as the client must be aware of what is happening with the portfolio, the balances, terms of service, and their possible changes.

  • Reports were sent to clients in a few days if everything was normal.

  • If there were some software errors (e.g., empty reports), we had to contact Orlov, and he solved technical errors.

  • If the errors were not technical but in terms of meaning and content, we turned to R.V. Shpakov.

  • In the fragment of correspondence in the group “Restructuring”, participants: (Apollo (+357 96 218890), Linda (+357 99 920015), Munaev (+7 903 100 41 -84) and the subscriber number +7 965 748 88 88 belongs to Vladimir Pakhomov (in the correspondence “Vova”) for the period from 09:41:03 to 21:17:10 it is about the following with the following subscribers: Apo - Apollo Athanasiadou.

  • In the present correspondence, Linda Athanasiadou writes that the name of R.V. Shpakov was removed from wherever it was possible (from the management of “QB Capital CY LTD”). She keeps the contracts (signed on behalf of “QB Capital CY LTD” by R.V. Shpakov) in a safe place, but it is necessary to organise the closing of the issue with the Central Bank of Russia.

  • V.S. Pakhomov replied that he would try (as he said in earlier interrogations, he solved issues regarding QB Capital CY LTD through his people in the Central Bank of Russia).

  • Some points discussed in the correspondence could have been discussed separately with R.V. Shpakov earlier.

  • Linda wrote that the Central Bank of Russia had sent an inquiry to the Cypriot regulator (Cysec, Cysec) regarding nine companies, listing them.

  • Haris is a regulatory expert, auditor, and consultant in Cyprus, a professional who assisted Linda.

  • If there were any irregularities in the work of the Cypriot companies, the Cypriot regulator would have immediately sent appropriate inquiries to these companies.

  • However, since there were no violations in terms of interaction with Russian companies following the law, there were only questions from the regulator.

  • The correspondence is connected with someone’s “order”, but this threatened the possible start of an investigation.

  • When processing client money, Linda provided the banks with client agreements with both “QB Capital CY LTD” and a Russian-licensed organisation, and the Cypriot regulator had no questions.

  • However, in connection with inquiries to the Cyprus regulator from the Central Bank, questions to Linda began to come, which signaled specific problems for her.

  • And it is necessary to remove their source for her - inquiries from the Central Bank of Russia to the Cypriot regulator.

  • There are different cooperation agreements signed between Cyprus and Russia; for this reason, the presence of questions on the activities of companies from Russia could lead to their occurrence in Cyprus, as it would also be taken for violations of the law, which threatened fines, company closures, and possible criminal prosecution.

  • All the inspections started because of customer complaints.

  • R.V. Shpakov was the beneficiary in the Russian part. According to the latest recommendations heard from the Central Bank of Russia, it was clear that in the case of his presence in the foreign part, the actions of attracting clients by concluding contracts on behalf of “QB Capital CY LTD” could be considered an unfair practice, as the funds deposited under the completed contracts do not fall under the jurisdiction of the Central Bank of Russia due to their transfer abroad.

  • In a fragment of correspondence in the group “Reorganisation”, participants: Shpakov (+7 905 735–55–88), Rossieva (+7 985 173–43–21) - the creator of the group, Munaev (+7 903 100–41–84) in the period from 10.04.04.2018, 13:56:34 to 12.04.2018 17:20:17 and 22.05.2018 at 17:28:13, the discussion is about the reorganisation of QBIF LLC, the separation of a separate entity (QBIF LLC) from the structure of the latter.

  • The selection of a nominee for the role of general director is under discussion.

  • The candidacies of Gorobets and Yudin are not suitable, as they still need to meet the requirements of the tax inspection for the reorganisation.

  • It is proposed to put him (Z.V. Munaev) in this role.

  • Earlier, he did not give Shpakov R.V. consent to his role as general director of this company.

  • For the general re-signing procedure, he was sufficient as a nominal owner, and he tried in every possible way to avoid the initiative to take on the role of a general director as well.

  • Andrei Berezka, mentioned in this correspondence, provided one of the nominees for the reorganisation procedure instead of Gorobets and Frolov.

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