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Pilatus Bank Plc is company registered in Malta.[150] [149] It was founded in 2013 by Iranian-American businessman Ali Sadr Hasheminejad and received its banking license in 2014.[151] [612]

Between 2014, when the bank was set up,[150] [149] and 2018, when it was shuttered over serious anti-money laundering failures,[612] it processed payments worth 1.7 billion euros ($2 billion).[341] [945] [936] A large portion of these were on behalf of high-risk and politically connected customers from Azerbaijan,[11] including the Aliyeva sisters and their business partners Tale and Nijat Heydarov, sons of Azerbaijan’s Emergency Situations Minister Kamaladdin Heydarov. Pilatus Bank also opened accounts for a web of anonymous shell companies, some of which, money laundering investigators suspected, may have been ultimately owned by the sisters or their business associates.[341]

According to money laundering investigators, the bank had targeted clients in high-risk countries such as Iran, Azerbaijan, and the UAE.[341] As a result, it had effectively “banked the unbankable.”[341] Investigators said that there was nothing inherently wrong with that, so long as steps were taken to identify and mitigate money laundering risks, but the bank “did not achieve that standard.”[341]

Investigators found that some of the bank’s corporate customers were connected by common owners, directors, and signatories, as well as by close trading connections.[341] On several occasions, the bank transferred funds between customer accounts before transferring funds out, which might be “part of a mechanism to disguise the source and destination of fund flows, which is a common characteristic of organised money laundering schemes.”[341] In 2021, Maltese regulators fined the bank 4.9 million euros ($4.15 million) for its “serious and systemic failure” in following anti-money laundering rules.[616] [1076]