INVESTIGATIONS

Dariga’s multimillion-dollar Austrian accounts. Eurasia Democracy Initiative releases report on Dariga Nazarbayeva’s financial shenanigans

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In the three years since the death of President Nazarbayev’s for­mer son-in-law Rakhat Aliyev, inves­ti­ga­tors and researchers have tried to piece togeth­er the schemes that allowed him to laun­der his sig­nif­i­cant wealth.

The report released by the Eurasia Democracy Initiative (www.eurasiademocracy.org) fol­lows months of painstak­ing research, reveal­ing how Rakhat’s first wife, Dariga Nazarbayeva, held bank accounts in Austria con­tain­ing mil­lions of dol­lars with links to Rakhat Aliyev’s alleged mon­ey-laun­der­ing schemes.

The research sug­gests that Dariga Nazarbayeva used a pass­port in the name of ‘Dariga Aliyeva’ to open these accounts, which would have allowed her to poten­tial­ly cir­cum­vent due dili­gence pro­ce­dures asso­ci­at­ed with being a ‘polit­i­cal­ly-exposed per­son’. However, the report argues that the mere pos­ses­sion of such a pass­port is in vio­la­tion of the Kazakh Criminal code, as Aliyeva was not her legal name at the time. 

The arti­cle also details what is known about Dariga’s for­tune, esti­mat­ed at near­ly $600 mil­lion, and how much of it emanates from her husband’s noto­ri­ous reign at the helm of Kazakhstan’s National Security Committee, the KNB.

Dariga’s million-dollar Austrian accounts

Report by the Eurasia Democracy Initiative, in coop­er­a­tion with
Kazakhstani Initiative on Asset Recovery,
Tom Mayne
and Natala Sadykova

Evidence sug­gests that in 2003 Dariga Nazarbayeva used an ille­gal pass­port in the name of ‘Dariga Aliyeva’ to open bank accounts con­tain­ing mil­lions of dol­lars with links to Rakhat Aliyev’s laun­der­ing schemes


$200 billion” of Kazakh money lost offshore

According to the World Bank, Kazakhstan has manged to record pos­i­tive GDP growth every year since 1999.[1] Yet it is inter­est­ing to spec­u­late how much more this growth could have been, had bil­lions of dol­lars not been lost in Kazakhstan due to cor­rup­tion: one esti­mate sug­gests that 25 per­cent of Kazakhstan’s GDP was trans­ferred out of the coun­try dur­ing the first decade of independence,[2] with $500 mil­lion lost in just one year alone.[3] The coun­try hard­ly improved its record over the next two decades: Kazakhstan lan­guished in 122nd place (out of 180 coun­tries) in Transparency International’s 2017 Corruption Perceptions Index, behind cor­rup­tion hotspots like Egypt, Pakistan and Colombia.[4] Former Kazakh Prime Minister Akezhan Kazhegeldin esti­mates that as much as $200 bil­lion could be held by the country’s rul­ing elite in over­seas funds and property.[5] It is no coin­ci­dence that the list of the rich­est peo­ple in Kazakhstan are a Whos Who of those clos­est to President Nazarbayev: his for­mer advi­sor Bolat Utemuratov, his son-in-law Timur Kulibayev, and oli­garchs Vladimir Kim and Alijan Ibragimov.[6] Indeed, the coun­try has all the hall­marks of a klep­toc­ra­cy – where a government’s lead­ers use their pow­er to exploit the country’s peo­ple and nat­ur­al resources in order to extend their own per­son­al wealth.

In recent years the appear­ance of Kazakh offi­cials in leaked doc­u­ments – the Panama and Paradise Papers, and Offshore Leaks[7] – have con­firmed the exploita­tion of Kazakhstan’s nat­ur­al resource wealth for the ben­e­fit of the few at the expense of the many. Former Minister of Energy and Oil, Sauat Mynbayev, was shown by the Organised Crime and Corruption Reporting Project to hold a stake worth hun­dreds of mil­lions of dol­lars in Meridian Capital, a com­pa­ny with many con­tracts relat­ed to Kazakh oil and gas – the very sec­tor that Mynbayev was work­ing in, sup­pos­ed­ly on behalf of the Kazakh people.[8] In anoth­er exam­ple, President Nazarbayev’s grand­son, Nurali Aliyev – who from 2014–2016 was the Deputy Mayor of Astana – was revealed to hold much of his $200 mil­lion for­tune offshore.[9] This should come as no sur­prise – Mynbayev and Aliyev were doing no dif­fer­ent from what Nazarbayev him­self has done: U.S. tri­al pro­ceed­ings relat­ed to the infa­mous ‘Kazakhgate’ case in the late 1990s estab­lished that President Nazarbayev was the ben­e­fi­cia­ry of sev­er­al accounts in Switzerland into which mon­ey relat­ed to Kazakh oil deals flowed.[10] Nazarbayev used some of the mon­ey to put his youngest daugh­ter through an exclu­sive Swiss school.[11] Other mon­ey relat­ed to the scan­dal was used to pur­chase “his and hers” snow mobiles for Nazarbayev and his wife, Sara.[12]

Rakhat & Dariga – a family business

No list of the rich­est, most pow­er­ful peo­ple in Kazakhstan would be com­plete with­out the president’s first daugh­ter, Dariga, who in 2013 was ranked by Forbes as the 13th rich­est per­son in Kazakhstan with an esti­mat­ed wealth of $595 million,18 much of it held off­shore. How did she attain such a for­tune?

The first tranche of Dariga’s wealth was earned in part­ner­ship with her noto­ri­ous for­mer hus­band, Rakhat Aliyev, who was renowned for his bru­tal tac­tics in mis­ap­pro­pri­at­ing busi­ness­es in Kazakhstan when at senior roles in the Kazakh tax police and the KNB, the state’s intel­li­gence agency. Dariga clear­ly ben­e­fit­ted from her husband’s tac­tics, as can be demon­strat­ed by their joint own­er­ship of assets in three main areas – media, sug­ar and bank­ing. Dariga and Rakhat were report­ed to have bought media com­pa­ny Karavan in 1998,[13] and were co-own­ers, along with the Kazakh state, of anoth­er media com­pa­ny, JSC Khabar, which ran the country’s main tele­vi­sion chan­nel. According to oppo­si­tion fig­ure Serik Medetbekov, much of Aliyev’s busi­ness empire was mis­ap­pro­pri­at­ed from oth­ers, includ­ing Medetbekov’s own media com­pa­ny, using a vari­ety of threats and intim­i­da­tion tactics.[14] Aliyev him­self, speak­ing under oath in 2012, claimed a busi­ness port­fo­lio of over 40 enti­ties – impres­sive work for some­one who by law was required to put all busi­ness enti­ties in trust in 1996 when he joined pub­lic service.[15]

Rakhat also owned more than half the vot­ing shares of Nurbank, a mid-sized Kazakh bank which fea­tured his son Nurali – who was just 22 at the time – as a board member.[16] Dariga and Nurali acquired the shares after Rakhat fell out with his father-in-law in 2007, and sold them in the years that followed.[17] Dariga also acquired and sub­se­quent­ly sold Rakhat’s shares in JSC Sugar Centre,[18] a com­pa­ny that Nurali had become pres­i­dent of in 2004.[19] In addi­tion to this, Nurali also held a posi­tion at a major French sug­ar com­pa­ny, Sucres et Denrées, where Rakhat held a 10 per­cent stake.[20] Dariga and Nurali also owned all of Alma TV, a telecom­mu­ni­ca­tions com­pa­ny that pro­vides cable tele­vi­sion and inter­net ser­vices in Kazakhstan.[21] In 2018, it was report­ed that Dariga and Nurali may own a build­ing of lux­u­ry apart­ments and offices worth over £130 mil­lion ($181 mil­lion) in London’s famous Baker Street, home to the fic­tion­al Victorian detec­tive Sherlock Holmes.[22]

219 Baker Street (Picture cred­it: Google Street view)

The mon­ey that Rakhat accrued through these com­pa­nies was used to acquire assets for the ben­e­fit of his fam­i­ly. Testimony from one of Rakhat’s lawyers, Christian Leskoschek, indi­cates that when Rakhat Aliyev became Ambassador of Kazakhstan to Austria in 2002, he and Dariga pur­chased a house locat­ed at Veitlissengasse 9 in Vienna. Leskoschek com­ment­ed, “Patience was not Ms Dariga Nazarbayeva’s strong suit and she said that I must on all accounts buy the property.”[23] The lawyer also tes­ti­fied that Nurali Aliyev bought an apart­ment in Vienna on Rohrbacherstrasse in 2003, and that the vil­la next door to the Veitlissengasse prop­er­ty was pur­chased in the name of Aliyev in 2005. 

As is well-known, Rakhat Aliyev was exiled to Austria in 2007, accused of attempt­ing to over­throw the gov­ern­ment, after he chal­lenged President Nazarbayev’s suprema­cy. Rakhat was then divorced from Dariga, who sub­se­quent­ly attempt­ed to reas­sign some of the assets that had been under the con­trol of her hus­band and his asso­ciates to her. These includ­ed assets owned by Rakhat’s broth­er-in-law Issam Hourani, a Lebanese-born Palestinian busi­ness­man, and Issam’s broth­ers Devincci and Hussam.[24] Dariga acquired a com­pa­ny called Universal Oilfield Supply Holdings LLP from Devincci’s broth­er-in-law Kassem Omar in June 2007.[25]Dariga also took pos­ses­sion of the Ruby Roz agri­cul­tur­al plant in the same year, and a third com­pa­ny owned by Devincci – the Caratube International Oil Company LLP – lost its licence in Kazakhstan in ear­ly 2008.[26] Both Caratube and Ruby Roz were then the sub­ject of lit­i­ga­tion, with Issam and Devincci Hourani claim­ing that that they had suf­fered harass­ment due to the fall­out between President Nazarbayev and Rakhat Aliyev[27] and that they had been “deceived or coerced to assign shares in their var­i­ous com­pa­nies to Dariga Nazarbayeva”.[28] The Caratube case was orig­i­nal­ly dis­missed in 2012 with a tri­bunal find­ing that the claimants, the Houranis, had failed to estab­lish the tribunal’s juris­dic­tion over the company,[29] though sub­se­quent lit­i­ga­tion that con­clud­ed in 2017 found the Kazakh state in breach of con­tract, with the tri­bunal award­ing $39.2 mil­lion to Caratube.[30]

The Austrian bank accounts

Dariga’s for­tune is thus inti­mate­ly tied up with Rakhat’s – any ques­tion of impro­pri­ety on how Rakhat acquired this wealth must there­fore be extend­ed to Dariga, who was clear­ly not only a ben­e­fi­cia­ry, but in many cas­es, co-own­er of Rakhat’s assets, and took con­trol of many of them after their divorce.  After his ban­ish­ment from Kazakhstan, Aliyev became of inter­est to European law-enforce­ment agen­cies: author­i­ties of at least three coun­tries – Austria, Germany, Malta – have inves­ti­gat­ed him for mon­ey laundering,[31] although the Austrian mon­ey-laun­der­ing inves­ti­ga­tion regard­ing Aliyev dates back to at least 2005 – when Rakhat was still mar­ried to Dariga.[32]

The inves­ti­ga­tion con­tin­ued for sev­er­al years. A let­ter from the Austrian crim­i­nal inves­ti­ga­tion author­i­ties dat­ed June 2007 request­ed infor­ma­tion on bank accounts in Austria con­trolled by Rakhat Aliyev. This led to a response, dat­ed 23 August 2007, from a Ministerial Advisor which was sent to a region­al crim­i­nal court in Vienna.[33]The let­ter doc­u­ments all accounts con­trolled by Rakhat Aliyev – either direct­ly or through asso­ciates – at Privatinvestbank in Vienna. 28 accounts are giv­en in total, three of which are joint accounts with Dariga (all opened on 25 June 2003), and a fur­ther three where the sole sig­na­to­ry is giv­en as Dariga (opened two days lat­er on 27 June 2003). Three more Rakhat/Dariga joint accounts had been opened on 16 June 2003 at Kathrein & Co, a pri­vate bank in Vienna.[34] Information passed to Austrian law enforce­ment by Kathrein & Co sug­gests that Rakhat and Dariga used a num­mernkon­to to hold both a cur­rent account and secu­ri­ties. A num­mernkon­to is a num­bered bank account which pro­vides for greater secre­cy, as it means that the account holder’s name will not be includ­ed on bank state­ments or bank receipts. This type of account is for­bid­den in Germany and oth­er juris­dic­tions. Information from Kathrein & Co sug­gests that Dariga held indi­vid­ual sig­na­to­ry pow­ers over a num­mernkon­to, which at the time (on 13 June 2007) held $7 mil­lion in the cur­rent account, and a fur­ther €946,000 in securities.[35]

The August 2007 let­ter then analy­ses trans­fers out of these accounts, includ­ing trans­fers to and from com­pa­nies con­trolled by Rakhat Aliyev. The trans­fers bear all the hall­marks of mon­ey laun­der­ing, as defined in a 2013 report by the Financial Action Task Force – an inter-gov­ern­men­tal body which sets the glob­al stan­dards in com­bat­ing mon­ey laun­der­ing and oth­er finan­cial crime – which lists a num­ber of ‘red flags’ that those work­ing in the finan­cial ser­vices indus­try should watch out for.  One such red flag is: “The client is using mul­ti­ple bank accounts or for­eign accounts with­out good reason.”[36] This could be applied to the accounts out­lined by the Austrian author­i­ties: on just two dates – June 25 and June 27, 2003 – inves­ti­ga­tors say the Aliyevs opened 13 accounts at the same bank: four in Rakhat’s name, four in his name of his father (Mukhtar Aliyev), three in Dariga’s name, and a fur­ther three joint accounts (Dariga/Rakhat). One of Rakhat’s com­pa­nies, AV Maximus SA, had a total of five accounts opened on two sep­a­rate days, one in 2005 and the oth­er in 

2006, and a fur­ther two accounts opened in 2004 in Kathrein Bank.[37] The trans­fers doc­u­ment­ed in the August 2007 let­ter also appear to raise oth­er red flags that are includ­ed in the FATF report: “There is a lack of sen­si­ble commercial/financial/tax or legal rea­son for the trans­ac­tion” and “Involvement of struc­tures with mul­ti­ple coun­tries where there is no appar­ent link to the client or trans­ac­tion, or no oth­er legit­i­mate or eco­nom­ic reason.”[38]

Despite this, the Ministerial Advisor con­cludes the August 2007 let­ter by say­ing: “Investigations car­ried out so far have not been able to pro­vide any evi­dence that the mon­ey assigned to Rakhat Aliyev and oth­ers may have orig­i­nat­ed from crim­i­nal activity.”[39] Yet many of the com­pa­nies men­tioned in this doc­u­ment would form the part of future mon­ey-laun­der­ing inves­ti­ga­tions against Aliyev: inves­ti­ga­tors in Malta looked at trans­fers relat­ed to, amongst oth­er com­pa­nies, AV Maximus Trading.[40] Aliyev’s assets were frozen by Maltese courts as part of a mon­ey laun­der­ing inquiry that report­ed­ly was being con­duct­ed in par­al­lel with a sim­i­lar inquiry under­way in Krefeld, Germany.[41] No finan­cial crime charges were filed against Aliyev at the time of his death in February 2015, but com­ments made by then European Commissioner for Justice Cecilia Malmström in response to a ques­tion sub­mit­ted by a mem­ber of the European Parliament about Aliyev sug­gest that the cross-bor­der nature of his finan­cial trans­ac­tions made pur­su­ing a case more dif­fi­cult, due to dif­fer­ences in each country’s laws.[42]

What of Dariga’s involve­ment? Although there is no evi­dence to sug­gest that Dariga was involved with com­pa­nies such as AV Maximus Trading, doc­u­ments indi­cate that two of the Rakhat/Dariga joint accounts held at Privatinvest Bank AG received €13,686,230 and $4,961,796 in trans­fers both made on 8 August  2005. It is pos­si­ble that because Rakhat had sig­na­to­ry con­trol over the joint accounts, Dariga may not have known or ben­e­fit­ted from the trans­fers. However, as it was a joint account, she would be legal­ly respon­si­ble for the funds con­tained in these accounts and would have been able to access them.

Dariga’s illegal passports

Regardless of the ori­gin of the funds in these accounts, and her knowl­edge of these trans­fers, a fur­ther issue is raised by the name Dariga uses to open the above accounts: Dariga Aliyeva. It appears that Dariga had two pass­ports issued in this name: one, a diplo­mat­ic pass­port issued in September 2002– the one used to open the above accounts – and a sec­ond, a non-diplo­mat­ic pass­port, num­ber 011271763, issued in June 2000 (see above and below). 

In her pub­lic life, Dariga has always been known as Nazarbayeva – there is no evi­dence to sug­gest she ever legal­ly changed her sur­name to that of her then husband.[43] The reg­is­tra­tion of Dariga’s Asar polit­i­cal par­ty came in October 2003, soon after she had opened the accounts in the name of Aliyeva in June 2003. The reg­is­tra­tion of a polit­i­cal par­ty would require offi­cial doc­u­men­ta­tion: the fact that Dariga reg­is­tered the par­ty under the name of “Nazarbayeva” indi­cates that this was her legal name at the time. 

It is like­ly that Dariga used this name to avoid enhanced due dili­gence pro­ce­dures asso­ci­at­ed with being a ‘polit­i­cal­ly-exposed per­son’ – “Dariga Aliyeva” (the sur­name being one of the most com­mon through­out Central Asia and the Caucasus) would not have been on PEP data­bas­es, unlike “Dariga Nazarbayeva,” which would have clear­ly marked her as the daugh­ter of the pres­i­dent of Kazakhstan. 

Dariga’s pos­ses­sion of mul­ti­ple pass­ports using a sur­name that was not her legal name could mean she is in breach of  Article 325 part 3 of the Criminal Code of the Republic of Kazakhstan – “Use of a forged doc­u­ment” – pun­ish­able by a fine, a 30-day peri­od of com­mu­ni­ty ser­vice, or even a pro­ba­tion peri­od of up to six months.[44]Mukhtar Ablyazov’s wife, Anna Shalabayeva, was con­vict­ed in absen­tia after alleged­ly get­ting a sec­ond pass­port from the staff of the Registration Service Committee of the Ministry of Internal Affairs and employ­ees of the Justice Department of the Atyrau region. Although Shalabayeva’s sup­port­ers con­tend that the crim­i­nal case is polit­i­cal­ly moti­vat­ed, it is strik­ing how sim­i­lar the issue is to the above exam­ple of Dariga Nazarbayeva.[45] If any­thing, the sit­u­a­tion with Dariga is even more clear cut, as, while Shalabayeva alleged­ly obtained a sec­ond pass­port in her own name, Dariga’s sec­ond pass­port was in a name that was like­ly not legal­ly hers. 

It is unclear whether the Austrian law enforce­ment author­i­ties ever con­sid­ered the aspect of fraud­u­lent doc­u­ments and false names when inves­ti­gat­ing poten­tial mon­ey-laun­der­ing by Rakhat Aliyev and his fam­i­ly. Other law enforce­ment agen­cies – includ­ing the Prosecutor General’s Office of Kazakhstan – should bear this in mind when ana­lyz­ing mon­ey flows and assets held by Dariga. 

PUBLISHED BY:

Eurasia Democracy Initiative (www.eurasiademocracy.org), in coop­er­a­tion with 

Kazakhstani Initiative on Asset Recovery (https://kiar.center

WITH THE ASSISTANCE OF:

Tom Mayne, inde­pen­dent researcher

Natala Sadykova, inde­pen­dent researcher 


[1] https://data.worldbank.org/indicator/NY.GDP.MKTP.KD.ZG?locations=KZ

[2] https://www.cnbc.com/2018/01/16/kazakhstan-is-a-kleptocracy-ruled-by-an-autocrat-its-also-an-increasingly-important-strategic-ally.html

[3] https://books.google.co.uk

[4]https://www.transparency.org/news/feature/corruption_perceptions_index_2017

[5] https://www.en.neweurasia.info

[6] https://www.forbes.com/profile/bulat-utemuratov/https://www.forbes.com/profile/timur-kulibaev/;  https://www.forbes.com/profile/vladimir-kim/;  https://www.forbes.com/profile/alijan-ibragimov/

[7] https://offshoreleaks.icij.org

[8] https://www.occrp.org/en/paradisepapers/kazakhstans-secret-billionaires

[9] https://www.occrp.org/en/panamapapers/kazakh-presidents-grandson-offshores/

[10] https://rus.azattyq.org/a/Kazakhgate_Final/2227139.html

[11]https://www.rferl.org/a/After_Seven_Years_Kazakhgate_Scandal_Ends_With_Minor_Indictment_/2123800.html

[12] https://www.globalwitness.org/documents/17833/time_for_transparency.pdf, p13.

[13] https://cpj.org/2000/03/attacks-on-the-press-1999-kazakhstan.php

[14] Written Submission of a Non-Disputing Party, sub­mit­ted by Serik Medetbekov, Caratube International Oil Company LLP v The Republic of Kazakhstan, ICSID Case No. ARB/08.12, paras 8, 11 and 19.

[15] Maltese court doc­u­ment viewed by author.

[16] https://www.reuters.com/article/us-kazakhstan-aliyev/kazakh-leaders-son-in-law-says-owns-tenth-of-sucden-idUSL1575491320070215

[17] https://www.euromoney.com/article/b12khw7k4z0j7r/kazakhstan-nurbank-looks-to-leave-school-for-scandal

[18] https://forbes.kz/ranking/object/111

[19] https://www.occrp.org/en/panamapapers/kazakh-presidents-grandson-offshores/

[20] https://www.reuters.com/article/us-kazakhstan-aliyev/kazakh-leaders-son-in-law-says-owns-tenth-of-sucden-idUSL1575491320070215

[21] https://forbes.kz/ranking/object/111

[22] https://qz.com/1245110/the-unsolved-mystery-of-who-owns-sherlock-holmes-130-million-home/

[23] Testimony of Christian Leskoschek, viewed by author.

[24] https://www.judiciary.gov.uk/wp-content/uploads/2017/03/hourani-v-Thomson-2017-ewhc-432-qb.pdf, Para 34.

[25] http://cisarbitration.com/wp-content/uploads/2015/11/Caratube‑v.-Kazakhstan-ICSID-Arbitration-No.-ARB1313-Decision-on-proposal-of-disqualifcation-20-March-2014.pdf

[26] https://www.italaw.com/sites/default/files/case-documents/ita0127_0.pdf, p48.

[27] https://www.iisd.org/itn/2017/12/21/kazakhstan-liable-expropriation-hourani-familys-investment-second-round-icsid-arbitration-caratube-international-oil-company-llp-devincci-salah-hourani-icsid-case-arb-13–13/

[28] https://www.italaw.com/sites/default/files/case-documents/italaw1100.pdf, para 177.

[29] https://www.italaw.com/sites/default/files/case-documents/italaw1100.pdf, paras 468–470.

[30] https://www.italaw.com/sites/default/files/case-documents/italaw9324.pdf, p386.

[31] Deutsche Welle, “Rakhat Aliyev inter­est­ed in both Maltese and German inves­ti­ga­tors”, 15 June 2013. Radio Free Europe/Radio Liberty, “Kazakhstan: Criminal Scandal Widens Around Ex-Ambassador Aliev”, 22 June 2015. “Kazakh President’s Daughter Divorces Fugitive Husband, 12 June 2007. Malta Today, “Investigators told of Rakhat Aliyev’s alleged mon­ey laun­der­ing net­work”, 30 July 2013. 

[32] Interpol request for infor­ma­tion: Interpol Vienna to Interpol Wiesbaden. 3 November 2005. Copy seen by author.

[33] Bundeskriminalamt, “Ergebnis der Kontenauswertung”, 23 August 2007. Copy seen by author.

[34] Ibid.

[35] Bundeskriminalamt, “Sehr Drigend”, 13 June 2007. Copy seen by author.

[36] http://www.fatf-gafi.org/media/fatf/documents/reports/ML%20and%20TF%20vulnerabilities%20legal%20professionals.pdf, p79.

[37] Another red flag is giv­en as “[the] Creation of com­pli­cat­ed own­er­ship struc­tures when there is no legit­i­mate or eco­nom­ic rea­son.” (See p82 of http://www.fatf-gafi.org/media/fatf/documents/reports/ML%20and%20TF%20vulnerabilities%20legal%20professionals.pdf) The Offshore Leaks data­base sug­gest that AV Maximus SA was reg­is­tered in the British Virgin Islands, a noto­ri­ous tax haven. Information released by lawyers work­ing on behalf of the Kazakh bankers alleged­ly mur­dered by Aliyev, indi­cate that mon­ey was trans­ferred between Aliyev’s net­work of com­pa­nies, includ­ing three men­tioned in the Austrian law enforce­ment doc­u­ment – AV Maximus SA, Armoreal Trading GmbH and S.T.A.R.T Management con­sult­ing GmbH. Other red flags are giv­en in the FATF report as: “There is a lack of sen­si­ble commercial/financial/tax or legal rea­son for the trans­ac­tion” and “Involvement of struc­tures with mul­ti­ple coun­tries where there is no appar­ent link to the client or trans­ac­tion, or no oth­er legit­i­mate or eco­nom­ic rea­son.” The doc­u­ment sug­gests $7.5m was sent to an indi­vid­ual in China from accounts con­trolled by Aliyev, though no expla­na­tion is giv­en as to the eco­nom­ic rea­son behind the trans­fer of this mon­ey.

[38] http://www.fatf-gafi.org/media/fatf/documents/reports/ML%20and%20TF%20vulnerabilities%20legal%20professionals.pdf, p79.

[39] Bundeskriminalamt, “Ergebnis der Kontenauswertung”, 23 August 2007.

[40] https://www.maltatoday.com.mt/news/national/28709/investigators-told-of-rakhat-aliyev-s-alleged-money-laundering-network-20130729

[41]https://www.maltatoday.com.mt/news/world/40793/rakhat_aliyev_threatened_in_prison_new_evidence_emerges_#.WyvURVVKiUl

[42] https://en.tengrinews.kz/politics_sub/EU-not-competent-to-investigate-Kazakhstans-Aliyev-26345/

[43] Evidence from the Offshore Leaks sug­gests that Dariga used the sur­name “Nazarbayeva” in September 2007 in order to open a com­pa­ny, Asterry Holdings Ltd, in the British Virgin Islands.  (See https://offshoreleaks.icij.org/nodes/12048181) As proof of iden­ti­ty is need­ed to open a com­pa­ny in the BVI this sug­gests that as of September 2007, Dariga pos­sessed– and was using – a pass­port with her sur­name as Nazarbayeva.

[44] https://law.vl.ru/comments/show_article.php?art_id=437

[45] http://odfoundation.eu/a/1182,kazahstan-delo-almy-shalabaevoy-mozhno-schitat-politicheski-motivirovannym

Dariga’s mil­lion-dol­lar Austrian accounts” – Eurasia Democracy Initiative releas­es report on Dariga Nazarbayeva’s finan­cial shenani­gans

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