Banque Havilland S.A.

Banque Havilland is a private bank headquartered in Luxembourg with offices in Monaco, London, Liechtenstein, Dubai, and Switzerland.[623] [622] It is owned by the family of David “Spotty” Rowland,[624] [625] a British property developer and former treasurer of and major donor to the British Conservative Party.[625] [626]

Leyla and Arzu Aliyeva were clients of Banque Havilland, according to confidential files leaked to Bloomberg.[626] The sisters’ relationship with the bank began after the Rowlands accompanied the UK’s Prince Andrew on a diplomatic trip to Azerbaijan in 2008.[626] Emails seen by Bloomberg show that, in 2009, PASHA Holding LLC, an Azerbaijani conglomerate owned by the Aliyeva sisters since 2013,[1336] [1112] [1270] [341] sent $5 million to an investment fund controlled by the Rowlands that had an account at Banque Havilland.[626] In 2014, Banque Havilland bought a Bahamas-based bank where the Aliyeva sisters had accounts.[528] [341] [626] Bloomberg did not name the Bahamas-based bank, but Banque Havilland acquired Pasche Bank & Trust, a Bahamas bank, in 2014.[1008]

Shortly thereafter, the sisters opened five more accounts at Banque Havilland in Luxembourg, according to a 2018 report by the Commission de Surveillance du Secteur Financier (CSSF), the country’s financial regulator.[626] According to the CSSF report, the bank had classified the Aliyeva sisters as politically exposed persons (PEPs), as it was required to do, but had failed to obtain sufficient documentation to establish their source of wealth.[626] The report stated that Banque Havilland held documents showing that transfers tied to the Aliyev family had been monitored by banks in the US and that two banks in Dubai no longer wished to process payments on their behalf.[626] The CSSF report concluded that Banque Havilland had failed to put measures in place for “high-risk clients” and had failed to establish the nature of the sisters’ business relationship with Mikhail Gutseriev, a billionaire Russian oligarch whose family the sisters had lent money to using their accounts at the bank.[626] [627]

According to Bloomberg, the bank was investigated by the CSSF for potential offences involving laundering money for their politically exposed clients, including Leyla and Arzu Aliyeva.[1061] In December 2018, the CSSF fined Banque Haviland 4 million euros ($4.6 million) for failure to comply with anti-money laundering regulations.[1062] [1083] The CSSF referred the matter to Luxembourg prosecutors, who opened a criminal probe.[1061]