Raphael Investment Limited

Raphael Investment Limited is a company registered in Dubai’s Jebel Ali Free Zone.[349] It was jointly owned by Leyla and Arzu Aliyeva, according to know your customer (KYC) records at Malta’s Pilatus Bank.[11] [341]

Raphael Investment is named in investigators’ reports as having featuring in an interconnected network of shell companies that held accounts at Pilatus,[11] [665] which was shuttered in 2018 over systemic failures to comply with anti-money laundering regulations.[587] The company featured in one of several transactions flagged as “potentially suspicious” by money laundering investigators,[341] who found that the company was used in a deal to purchase land in Moscow.[341]

Raphael Investment opened an account with Pilatus in October 2016.[341] The following month, Leyla Aliyeva deposited 293.7 million AED ($79.9 million) into the account from an account she held at the National Bank of Abu Dhabi.[341] [439] The source of funds for the Raphael account was recorded in Pilatus Bank files as dividends from PASHA Holding LLC,[341] an Azerbaijani conglomerate ultimately owned by the Aliyeva sisters.[1337] [1336] [1112] [1270] [341] The deposit was complicated, however, as, according to emails in the bank’s records, a German correspondent bank refused to act on the transaction because its compliance team would not authorize it.[341]

The next month, in December 2016, Pilatus Bank lent Raphael Investments $73 million to buy shares in AO Eruville, a company in Moscow that owned land.[341] [11] The transaction had “several layers,” and funds went through several different companies with nonresident accounts at Pilatus, ending in a Cyprus bank account held by the seller.[341] [11] The first stage was a transfer of $73 million as a loan from Pilatus Bank, followed by a transfer of 68.5 million euro ($73.1 million) from the account of Raphael Investment to that of Kubernao Trust Limited as Trustee of the Arellano Lega Trust.[341] [11] [1003] From there, the same amount was transferred to the Pilatus Bank account of Arellano Lega Holdings Limited,[341] [11] a BVI registered company. Finally, Arellano Lega Holdings transferred the same amount to the account of Arellano Lega Alpine AG,[341] [11] a company registered in Switzerland.[317] This last transfer was recorded as a loan to allow Arellano Lega Alpine to purchase all the shares in AO Eruville, the company in Moscow that owned land, from the Cyprus company that owned it at the time.[341] [11]

The deal went ahead in December 2016, according to Pilatus Bank records.[341] Money laundering investigators said that the transaction and its complexity “lacked apparent commercial rationale”:[341] deposit and loan funds were “commingled,”[341] and there were several “apparently unnecessary” currency conversions.[341] Investigators concluded that it could be “an attempt to conceal the origin of the funds by obscuring whether loan funds or personal monies were used to finance the acquisition.”[341]