Arellano Lega Holdings Limited is a company registered in the British Virgin Islands.[11] The company held accounts at Malta’s Pilatus Bank,[11] which was shuttered in 2018 over systemic failures to comply with anti-money laundering regulations.[587] Arellano Lega Holdings was used in one of several transactions flagged as “potentially suspicious” by money laundering investigators.[341] In December 2016, $73 million was transferred internally between Pilatus bank accounts, including an account belonging to Arellano Lega Alpine, in a deal to purchase land in Moscow on behalf of Leyla and Arzu Aliyeva.[341]