To map Leyla and Arzu Aliyeva’s network, The Sentry’s investigators gathered over 1,300 documents, including court records, corporate filings, real estate records, and online sources. Where reports cited primary sources or leaked material, efforts were made to obtain or review copies. Scores of individuals were interviewed. This information was then used to create a database of companies and individuals linked to the sisters.
The Sentry verified directorships and shareholdings using corporate records and court filings and identified business associates, managers, and professional enablers. The Sentry cross-checked their names against open sources, import-export databases, corporate registries, court documents, real estate records, and leaked material, and created an in-depth profile for each to ascertain the extent of their involvement in Leyla and Arzu Aliyeva’s business ventures.
Investigations by The Sentry are based on interviews, documentary research, and, where relevant, financial forensic analysis. In some cases, sources speak to The Sentry on the condition that their names not be revealed, out of concern for their safety or other potential retaliatory action. The Sentry establishes the authoritativeness and credibility of information derived from those interviews through independent sources, such as expert commentary, financial data, original documentation, and press reports. The Sentry endeavors to contact the persons and entities discussed in its reports and afford them an opportunity to comment and provide further information. As of October 2024, no individuals had responded to The Sentry’s requests for comment. Certain entities responded to The Sentry’s requests for comment; these responses are included in their profiles.
The inclusion of a person or entity in this database is not intended to suggest they have engaged in illicit or improper activities. There are legitimate uses for holding companies, shell companies, offshore companies, trusts, and family offices. In its reporting, The Sentry evaluates activities against potential indicators of suspicious activity in accordance with guidance and red flags set out by the Financial Action Task Force (FATF), an international body that develops and promotes policies to protect the global financial system and sets standards for money laundering controls.
Due to constraints in accessing information, some reports of the sisters’ activities in Azerbaijan could not be independently corroborated. Corporate filings in Azerbaijan have not contained shareholder or director information since 2012, making it difficult to independently verify reports of Leyla and Arzu Aliyeva’s domestic businesses. However, several of their major Azerbaijani holding companies were able to be verified through other means, including through reports of publicly traded companies or audits of overseas banks.
In addition, the number of overseas companies linked to the Aliyeva sisters may be significantly higher than reported. Many of their overseas companies have only been identified because they featured in major leaks of data from offshore service providers in secrecy jurisdictions. It is possible that Leyla and Arzu Aliyeva are connected to more companies than those that have been identified in this map.
Behind the research
The Sentry’s map—the first comprehensive visualization of the Aliyev sisters’ empire—compiles and builds on the work of several organizations and individuals. The Washington Post,[1059] [1060] the Organized Crime and Corruption Reporting Project (OCCRP), the International Consortium of Investigative Journalists (ICIJ),[519] [521] Bloomberg,[626] [1061] Wikileaks,[604] [553] and Radio Free Europe/Radio Liberty (RFE/RL) have all published important and groundbreaking information on the Aliyev family and their holdings.
In the 20 years of Ilham Aliyev’s rule, these organizations and others have identified companies and exposed details of financial flows that provide insight into how these companies were used. Nevertheless, the work of a few individuals stands out, both for their significant findings and for the consequences they have faced as a result of their work.
Radio Free Europe/Radio Liberty (RFE/RL)
The work of RFE/RL correspondents Khadija Ismayilova and Nushabe Fatullayeva, in particular, merits recognition, as their investigations into the first family’s holdings in telecommunication and mining sparked a transparency crackdown. In 2012, in response to their work, Azerbaijani lawmakers approved amendments restricting access to the names of shareholders of Azerbaijani companies and granting Ilham Aliyev and all former presidents and first ladies lifelong immunity from prosecution.[859] [1277] In addition, Azerbaijani security services detained 38 activists between 2012 and 2014.[919] Ismayilova herself was subjected to harassment, blackmail, and cyber surveillance by the Aliyev regime.[858] In December 2014, she was detained and subsequently handed a seven-and-half-year prison sentence for tax evasion and embezzlement—charges widely condemned by international human rights organizations.[858] [860] Ismayilova was released from prison more than a year later, in May 2016, after some of the charges were dropped.[880]
Daphne Caruana Galizia and the Daphne Project
Another reporter whose work on this topic has had resounding impact is Maltese journalist Daphne Caruana Galizia. Her work, and the work that others have continued in the aftermath of her assassination in a coordinated car bombing in 2017, has been significant.[614] [615]
In the months before she was killed, Caruana Galizia wrote that Pilatus Bank, a private bank headquartered in Malta, had facilitated suspicious payments between political figures in Azerbaijan and Malta, including the Aliyeva sisters.[1278] [693] [893] Her most explosive allegation was that Pilatus had transferred $1 million from a company called “Al Sahra FZCO,” which Caruana Galizia said was owned by Leyla and Arzu Aliyeva, to an account held by Egrant Inc, a Panamanian company that she said was owned by the wife of Malta’s then-Prime Minister Joseph Muscat.[1383] [1387]
Her allegations sparked a political firestorm in Malta, dubbed the “Egrant Affair.” Muscat categorically denied the allegations and ordered a judicial inquiry into them, while Maltese authorities opened multiple investigations into Pilatus, and investigative journalists began examining the bank’s dealings with Azerbaijan.
After Caruana Galizia’s murder in October 2017, a consortium of reporters was formed to complete her work. In 2018, the newly formed Daphne Project, coordinated by Paris-based Forbidden Stories, revealed that the children of the two most powerful figures in Azerbaijan—President Ilham Aliyev and Emergency Situations Minister Kamaladdin Heydarov—had set up a network of offshore companies with accounts at Pilatus Bank to funnel tens of millions of euros into investments around the world.[517] The same year, Pilatus Bank was shuttered over systemic failures to comply with anti-money laundering regulations.[587]
Not long after, in 2019, two reports were published in Malta. The Daphne Inquiry, which looked into her murder, sharply criticized Malta’s government—specifically Muscat—for presiding over a culture of impunity that indirectly led to Caruana Galizia’s murder.[890] The Egrant Report, meanwhile, found no evidence that Muscat’s wife had received a $1 million payment from Leyla and Arzu Aliyeva in the manner Caruana Galizia had reported, but it did reveal more about Azerbaijan’s suspicious money movements.
As part of the Egrant inquiry, a small team of forensic and financial crime investigators was appointed. The UK-based Harbinson Forensics and Serbian forensic accountant Miroslava Milenović were given copies of Pilatus Bank’s records and tasked with assessing Caruana Galizia’s allegations,[11] while New York-based Duff & Phelps (now known as Kroll) was given the broader task of combing through Pilatus Bank’s records looking for signs of money laundering.[341] Harbinson Forensics’ report was published in the Egrant Report, but Duff & Phelps’ report was kept confidential. It would never have seen the light of day if not for a campaigning Maltese official.
Publishing the Duff & Phelps report
For 18 years, Robert Aquilina has worked as a notary public from his offices in Siggiewi, Malta.[895] [946] Like many on the island, he was outraged by Caruana Galizia’s murder and the web of corruption it revealed. When Aquilina discovered that just one person had been prosecuted as a result of the Egrant inquiry—a mid-ranking Pilatus Bank employee he’d gone to school with—he decided to file a case. The courts ordered that the case be heard behind closed doors, however.[895] [946] “That means that whatever I say there cannot be repeated in public. And whatever knowledge I gain there, even from other witnesses and documents submitted, I cannot repeat outside,” Aquilina told The Sentry.
Because he was the only witness to the case, Aquilina feared that it was a trap to stop vital information from going public. He said: “I’ll say things over there and then I can’t repeat it in public. So I decided to write a book, and make it public before I testify.” Aquilina’s book, Pilatus: A Laundromat Bank in Europe, was published in July 2023. It includes the full text of Duff & Phelps’ 400-page report into money laundering at Pilatus Bank, which had previously been strictly confidential.
The Duff & Phelps report contains a trove of previously unreported shell companies, suspicious transactions, and professional facilitators linked to Leyla and Arzu Aliyeva, which The Sentry has verified via independent sources, where possible. By publishing it, Aquilina may have defied a court order, according to a Maltese state advocate. Aquilina told The Sentry, “I’m risking going to jail for that.”
