The QBF NOA Circle Scam: Eventually everything comes to light: how justice finally caught up with the masterminds behind the QBF financial scandal. Linda Athanasiadou, among others, tried to manipulate the system and evade justice, but their fraud couldn't remain hidden.

INDICTMENT..................................................................................................................................
22
IN CRIMINAL CASE NO. 12001450007000902 .............................................................................22

on the charge in the commission of the o/ence of ч. 3, Art. 210, and 151 of the o/ence under Part 4, Art. 159
of the Criminal Code of the Russian Federation, in the commission of the o/ence of ч. 3, Art. 210, and 123
o/ences under Part 4, Art. 159 of the Criminal Code of the Russian Federation, .......................................... 22
CONVICTED IN ABSENTIA AND ON THE RUN: R.V. SHPAKOV......................................................22
CONVICTED IN ABSENTIA AND ON THE RUN: ATHANASIADOU LINDA (KOVALENKO, TORRES,

ATHANASIADES) ...........................................................................................................................22
CONVICTED AND JAILED: .............................................................................................................22

CONVICTED AND JAILED: Vladimir Sergeevich Pakhomov, ......................................................................... 22
CONVICTED AND JAILED: Munaev Z.V........................................................................................................ 22
CONVICTED AND JAILED: Stanislav Anatolievich Matyukhin....................................................................... 22
CONVICTED AND JAILED: Evgenia Anatolievna Rossieva ............................................................................ 22
CONVICTED AND JAILED: Alexei Sergeyevich Golubev ............................................................................... 22
and unidentified persons.......................................................................................................................... 22
APPROVED ....................................................................................................................................22
First Deputy Prosecutor General R ............................................................................................................ 22
ussian Federation state councillor ............................................................................................................ 22
CONVICTED:..................................................................................................................................23
IN THAT HE VLADIMIR SERGEEVICH PAKHOMOV COMMITTED THE MANAGEMENT OF A

STRUCTURAL SUBDIVISION INCLUDED IN A CRIMINAL ASSOCIATION (CRIMINAL
ORGANISATION), PARTICIPATION IN A CRIMINAL ASSOCIATION (CRIMINAL ORGANISATION),
COMMITTED BY A PERSON USING HIS OFFICIAL POSITION, NAMELY:.......................................23
ACCORDING TO THE CRIMINAL PLAN, R.V. SHPAKOV, REALISING THE PUBLIC DANGER OF HIS
CRIMINAL ACTIONS, USING HIS OFFICIAL POSITION FOR CRIMINAL PURPOSES, FORMED A
CRIMINAL ASSOCIATION AS FOLLOWS: ......................................................................................24
ACCORDING TO THE CRIMINAL PLAN OF R.V. SHPAKOV, THE CRIMINAL ASSOCIATION

CREATED AND DIRECTED BY HIM EMBEZZLED MONEY FROM CITIZENS UNDER THE GUISE OF
PROVIDING BROKERAGE SERVICES. ...........................................................................................25
THE DIRECT THEFT OF MONEY BELONGING TO CITIZENS WAS ALSO CARRIED OUT
ACCORDING TO THE CRIMINAL PLAN DEVELOPED BY R.V. SHPAKOV, DIVIDED INTO SEVERAL
STAGES. .........................................................................................................................................26
1
R.V. SHPAKOV, AS THE FOUNDER OF THE CRIMINAL ASSOCIATION, ASSIGNED HIMSELF THE
LEADING ROLE IN THE CRIMINAL ASSOCIATION AND ASSIGNED HIMSELF THE FOLLOWING
DUTIES:..........................................................................................................................................27
IN TURN, ON A DATE AND TIME NOT SPECIFIED BY THE INVESTIGATION, BUT NO LATER THAN
27 MARCH 2012, R.V. SHPAKOV INITIATED V.S. PAKHOMOV INTO THE CRIMINAL PLAN AND
ATTRACTED HIM TO PARTICIPATE IN THE CRIMINAL ASSOCIATION, ASSIGNING HIM A LEADING
ROLE IN THE FIRST FUNCTIONALLY SEPARATE STRUCTURAL SUBDIVISION OF THE CRIMINAL
ASSOCIATION CREATED ON A DATE AND TIME NOT SPECIFIED BY THE INVESTIGATION, BUT
NO LATER THAN 27 MARCH 2012,................................................................................................29
AT THE SAME TIME, PAKHOMOV V.S. WAS TO INDEPENDENTLY INVOLVE OTHER PERSONS IN
CRIMINAL ACTIVITY AND SUBSEQUENTLY APPOINT THEM TO HIGHER POSITIONS WITH
GREATER INCOME.........................................................................................................................29
PAKHOMOV V.S. WAS ASSIGNED THE FOLLOWING DUTIES: ......................................................29
THE MEMBERS OF THE SEPARATE STRUCTURAL SUBDIVISION OF THE CRIMINAL

ASSOCIATION LED BY V.S. PAKHOMOV, WHO, AMONG OTHER THINGS, WAS AUTHORISED AS
THE HEAD AND PARTICIPANT OF LLC "KF ESTATE SPB" AND LLC "KG", RESPECTIVELY, AS
PROVIDED FOR BY FEDERAL LAW NO. 14 - FZ DATED 08.02.1998 "ON LIMITED LIABILITY
COMPANIES" AND THE CHARTERS OF THESE COMPANIES, HAD THE FOLLOWING DUTIES: ...31
- MATYUKHIN S.A., ........................................................................................................................31
- MUNAEV Z.V. ...............................................................................................................................31
A.S. GOLUBEV ...............................................................................................................................31
ALSO ON A DATE AND TIME NOT SPECIFIED BY THE INVESTIGATION, BUT NO LATER THAN 31
DECEMBER 2013, SHPAKOV R.V., USING HIS OFFICIAL POSITION, INITIATED THE CRIMINAL
INTENT AND INVOLVED ATHANASIADOU LINDA IN THE CRIMINAL ASSOCIATION, ASSIGNING
HER A LEADING ROLE IN THE SECOND FUNCTIONALLY SEPARATE STRUCTURAL SUBDIVISION
OF THE CRIMINAL ASSOCIATION, ................................................................................................32
ATHANASIADOU LINDA VOLUNTARILY JOINING THE CRIMINAL ASSOCIATION IN THE ROLE OF

HEAD OF THE SECOND FUNCTIONALLY SEPARATE STRUCTURAL SUBDIVISION OF THE
CRIMINAL ASSOCIATION, THEREBY ENTRUSTING ATHANASIADOU LINDA WITH THE
FOLLOWING DUTIES: ....................................................................................................................32

ASSOCIATION LED BY ATHANASIADOU LINDA HAD THE FOLLOWING RESPONSIBILITIES: ......33
2
ALSO ON A DATE AND TIME NOT SPECIFIED BY THE INVESTIGATION, BUT NO LATER THAN 31
AUGUST 2017, SHPAKOV R.V., USING HIS OFFICIAL POSITION, INITIATED ROSSIEVA E.A. INTO
THE CRIMINAL INTENT AND INVOLVED HER IN THE CRIMINAL ASSOCIATION, ASSIGNING HER
A LEADING ROLE IN THE THIRD FUNCTIONALLY SEPARATE STRUCTURAL SUBDIVISION OF THE
CRIMINAL ASSOCIATION, .............................................................................................................33
E.A. ROSSIEVA, BEING AWARE OF THE GENERAL GOALS OF THE CRIMINAL ASSOCIATION,
HAVING THE PURPOSE OF CRIMINAL ENRICHMENT, OUT OF SELFISH MOTIVES AGREED TO
FULFIL THE CRIMINAL ROLE ASSIGNED TO HER, THEREBY VOLUNTARILY JOINED THE
CRIMINAL ASSOCIATION IN THE ROLE OF THE HEAD OF THE THIRD FUNCTIONALLY SEPARATE
STRUCTURAL SUBDIVISION OF THE CRIMINAL ASSOCIATION, AND HER DUTIES WERE AS
FOLLOWS: .....................................................................................................................................33

ASSOCIATION, HEADED BY E.A. ROSSIEVA, WERE ASSIGNED THE FOLLOWING DUTIES: ........34
THE CRIMINAL ASSOCIATION CREATED BY R.V. SHPAKOV WAS CHARACTERISED BY: .............34
THE CONSCIOUSNESS AND WILL OF ALL ACCOMPLICES IN THE OFFENCES ENCOMPASSED

CIRCUMSTANCES RELATING NOT ONLY TO THEIR OWN CRIMINAL ACT, BUT ALSO TO THE
ACTS OF OTHER ACCOMPLICES. THIS WAS EXPRESSED IN THE FOLLOWING: .........................35
IN ADDITION, THE PARTICIPANTS OF THE CRIMINAL ASSOCIATION DETERMINED IN ADVANCE

POSSIBLE OBSTACLES FOR THEMSELVES IN COMMITTING A SOCIALLY DANGEROUS ACT, AND,
ABOVE ALL, IN THE PART CONCERNING THE EXPOSURE AND DETENTION OF THESE PERSONS
BY THE POLICE, IN CONNECTION WITH WHICH THEY: ...............................................................35
THUS, PAKHOMOV V.S. COMMITTED THE LEADERSHIP OF A STRUCTURAL SUBDIVISION

INCLUDED IN A CRIMINAL ASSOCIATION (CRIMINAL ORGANISATION), PARTICIPATION IN A
CRIMINAL ASSOCIATION (CRIMINAL ORGANISATION), COMMITTED BY A PERSON USING HIS
OFFICIAL POSITION, .....................................................................................................................36
THE SPECIFIC CRIMINAL ACTIVITY OF THE PARTICIPANTS IN THE CRIMINAL ASSOCIATION

ESTABLISHED UNDER THE ABOVE CIRCUMSTANCES WAS EXPRESSED IN THE FOLLOWING:.36
THUS, PAKHOMOV VLADIMIR SERGEEVICH COMMITTED FRAUD, I.E. THEFT OF OTHER

PEOPLE'S PROPERTY BY DECEPTION AND ABUSE OF TRUST, COMMITTED BY A PERSON USING
HIS OFFICIAL POSITION, BY AN ORGANISED GROUP, ON A PARTICULARLY LARGE SCALE, I.E.
THE CRIME PROVIDED FOR BY PART 4 OF ARTICLE 159 OF THE CRIMINAL CODE OF THE
RUSSIAN FEDERATION. ..............................................................................................................360
3
GENERAL EVIDENCE AND THEIR SUMMARY, CONFIRMING THE GUILT OF PAKHOMOV V.S. IN
COMMITTING AN OFFENCE UNDER PART 3 OF ARTICLE 210 AND 151 OF AN OFFENCE UNDER
PART 4 OF ARTICLE 159 OF THE CRIMINAL CODE OF THE RUSSIAN FEDERATION: .................360
- TESTIMONY OF Z.V. MUNAYEV..................................................................................................360
- PROTOCOL OF CONFRONTATION BETWEEN THE ACCUSED MUNAYEV Z.V. AND THE

ACCUSED GOLUBEV A.S. DATED 11.03.2022, ACCORDING TO WHICH THE ACCUSED
MUNAYEV Z.V. FULLY CONFIRMED HIS TESTIMONY, .................................................................392
- PROTOCOL OF CONFRONTATION BETWEEN THE ACCUSED MUNAYEV Z.V. AND THE

ACCUSED PAKHOMOV V.S. DATED 11.03.2022, ACCORDING TO WHICH THE ACCUSED
MUNAYEV Z.V. FULLY CONFIRMED HIS TESTIMONY..................................................................393
- TESTIMONY OF E.A. ROSSIEVA, GIVEN TO HER AS A WITNESS, AS A SUSPECT, AS WELL AS IN

THE CAPACITY OF THE ACCUSED, .............................................................................................395
- THE TESTIMONY OF PAKHOMOV V.S., GIVEN BY HIM AS A WITNESS, SUSPECT, AS WELL AS

THE ACCUSED, ............................................................................................................................397
- PROTOCOL OF CONFRONTATION BETWEEN THE WITNESS PAKHOMOV V.S. AND THE

WITNESS POLEZHAEV A.V. .........................................................................................................399
- PROTOCOL OF CONFRONTATION BETWEEN THE ACCUSED PAKHOMOV V.S. AND THE

WITNESS RYKOV D.I....................................................................................................................400
- PROTOCOL OF CONFRONTATION BETWEEN THE ACCUSED PAKHOMOV V.S. AND THE

WITNESS CHUPIN I.A.,................................................................................................................402
- TESTIMONY OF A.S. GOLUBEV, GIVEN BY HIM AS A WITNESS, SUSPECT, AS WELL AS THE

ACCUSED, ...................................................................................................................................403
- PROTOCOL OF CONFRONTATION BETWEEN THE ACCUSED A.S. GOLUBEV AND THE WITNESS
D.I. RYKOV ...................................................................................................................................405
- PROTOCOL OF CONFRONTATION BETWEEN THE ACCUSED A.S. GOLUBEV AND THE WITNESS
I.A. CHUPIN .................................................................................................................................406
- THE TESTIMONY OF S.A. MATYUKHIN, GIVEN BY HIM AS A WITNESS, SUSPECT, AS WELL AS

THE ACCUSED.............................................................................................................................407
- A. ABDUKADYROV'S TESTIMONY, GIVEN BY HIM AS A WITNESS,...........................................411
4
ABRAMYAN'S TESTIMONY GIVEN AS A WITNESS ......................................................................412
- R.F. AMEROV'S TESTIMONY AS A WITNESS .............................................................................413
- THE TESTIMONY OF AFANASYEVA Y.S......................................................................................417
- TESTIMONY OF BALAYAN A.S ...................................................................................................418
- THE TESTIMONY OF BASHKIROV D.A .......................................................................................418
- BELYAKOV B. E.'S TESTIMONY...................................................................................................419
- D. V. BERKUTOVA'S TESTIMONY ...............................................................................................420
- THE TESTIMONY OF BLIK S.N.,..................................................................................................421
- THE TESTIMONY OF BOLTOVA L.N.,..........................................................................................422
- TESTIMONY OF V.G. BUTKOVSKAYA .........................................................................................423
- VLASOV P.Y.'S TESTIMONY - VLASOV P.Y.'S TESTIMONY GIVEN BY HIM AS A WITNESS, .........425
- A.F. VOZHZHOV'S TESTIMONY,.................................................................................................426
- I. A. GAVRILOVA'S TESTIMON- I. A. GAVRILOVA'S TESTIMONY ...........................................427
- THE TESTIMONY OF GADIRLI T.R.O.,.........................................................................................428
- K.V. HERTSIK'S TESTIMON K.V. HERTSIK'S TESTIMONY ...........................................................428
A.S. GOLUBEVA'S TESTIMONY....................................................................................................429
I.S. GORSHENEVA'S TESTIMONY GIVEN TO HER AS A WITNESS,..............................................430
E.A. GRABAREVA'S TESTIMONY..................................................................................................430
- M.V. DANILENKO'S TESTIMONY, ...............................................................................................431
- E.Y. DOROKHINA'S TESTIMONY ................................................................................................434
- A.V. DRACHEVA'S TESTIMONY..................................................................................................435
5
R.V. DYNDA'S TESTIMONY...........................................................................................................436
- TESTIMONY OF G.R. ERZIKYAN, ...............................................................................................437
- TESTIMONY OF S.R. ERMOLENKO, ...........................................................................................438
- ZAVYALOVA T.G.'S TESTIMONY .................................................................................................439
- E.G. ZOLOTOVA'S TESTIMONY ..................................................................................................440
A.V. ZYKOV'S TESTIMONY ...........................................................................................................440
IBRAHIMOV E.E.'S TESTIMONY ...................................................................................................441
- I. N. IVANOVA'S TESTIMONY ................................................................................................443
A.K. IGNATOV'S TESTIMONY GIVEN AS A WITNESS,..................................................................443
- A.V. ILYIN'S TESTIMONY GIVEN BY HIM AS A WITNESS, ..........................................................445
IOSIFOVA E.O.'S TESTIMONY AS A WITNESS, .............................................................................446
- KAMINSKY P.A.'S TESTIMONY ...................................................................................................448
- THE TESTIMONY OF KIPA D.S., GIVEN BY HIM AS A WITNESS, ................................................449
- KOZLOVA M.V.'S TESTIMONY GIVEN TO HER AS A WITNESS, ..................................................450
- A.V. KORZH'S TESTIMONY GIVEN BY HIM AS A WITNESS, .......................................................451
- THE TESTIMONY OF KRYACHEK E.I., GIVEN TO HER AS A WITNESS, ......................................454
KUZNETSOV S.A.'S TESTIMONY GIVEN BY HIM AS A WITNESS, ................................................455
- TESTIMONY OF KURANINA L.V., GIVEN TO HER AS A WITNESS, .............................................455
- THE TESTIMONY OF LEGROVA I.I., GIVEN TO HER AS A WITNESS,..........................................457
- D.S. LEPESHKIN'S TESTIMONY GIVEN BY HIM AS A WITNESS, ...............................................457
- A.Y. LOZHKINA'S TESTIMONY GIVEN TO HER AS A WITNESS, .................................................458
6
- A.V. LOPUKHOVA'S TESTIMONY GIVEN TO HER AS A WITNESS, .............................................459
MANAENKOV V.K.'S TESTIMONY GIVEN BY HIM AS A WITNESS, ...............................................460
- MARKINA M.S.'S TESTIMONY GIVEN TO HER AS A WITNESS,..................................................461
- THE TESTIMONY OF MESHKOVA D.Y., GIVEN TO HER AS A WITNESS,.....................................461
- TESTIMONY OF E.V. MIKHALEVICH, GIVEN BY HIM AS A WITNESS, ........................................463
- MKRTCHYAN D.G.'S TESTIMONY AS A WITNESS,.....................................................................463
- THE TESTIMONY OF MONTES A.A.,...........................................................................................464
- A.V. MURASHEV'S TESTIMONY GIVEN BY HIM AS A WITNESS, ...............................................466
- K.R. MUSTAFINA'S TESTIMONY ................................................................................................468
NABIULLINA T.A.'S TESTIMONY ..................................................................................................468
A.V. NEPOMNYASHCHY'S TESTIMONY, ......................................................................................469
- NESTERENKO N.S.'S TESTIMONY , .........................................................................................470
- A. S. OBERMAN'S TESTIMONY...............................................................................................470
- THE TESTIMONY OF Y.Y. OLIFIRENKO, GIVEN TO HER AS A WITNESS, ....................................471
- THE TESTIMONY OF Y .N. ORLOV, GIVEN BY HIM AS A WITNESS,.........................................472
- I.S. PANKOV'S TESTIMONY .......................................................................................................473
- A.V. PASHINYAN'S TESTIMONY.................................................................................................474
A.V. PIROGOV'S TESTIMONY.......................................................................................................475
- TESTIMONY OF PLITIN V.O., GIVEN BY HIM AS A WITNESS,.....................................................476
- RADCHENKO A.S.'S TESTIMONY ..............................................................................................477
- THE TESTIMONY OF ROMANENKOVA D.D., GIVEN TO HER AS A WITNESS,............................477
7
- T.V. RUDAKOVA'S TESTIMONY GIVEN TO HER AS A WITNESS, ................................................478
- THE TESTIMONY OF D.I. RYKOV, GIVEN BY HIM AS A WITNESS,..............................................479
RYAZANOV S.A.'S TESTIMONY ....................................................................................................481
SAMOILOV V.R.'S TESTIMONY , GIVEN BY HIM AS A WITNESS,...............................................482
- D. A. SEROV'S TESTIMONY ....................................................................................................483
- A.V. SIDOROVA'S TESTIMONY GIVEN TO HER AS A WITNESS,.................................................484
- YA.G. SMIRNOVA'S TESTIMONY................................................................................................486
R.V. SPINKA'S TESTIMONY AS A WITNESS,.................................................................................488
- THE TESTIMONY OF SUKHANOV E.O., GIVEN BY HIM AS A WITNESS, ....................................489
- TESTIMONY OF TERESHENKOVA E.V., GIVEN TO HER AS A WITNESS, ....................................489
O.Y. TIMOKHIN'S TESTIMONY .....................................................................................................490
- TESTIMONY OF TREIMAN A.S., GIVEN BY HIM AS A WITNESS,................................................492
- THE TESTIMONY OF ULANOVA K.S.,.........................................................................................493
- THE TESTIMONY OF FROLOV V.G., GIVEN BY HIM AS A WITNESS, ..........................................493
- E. N. KHARINA'S TESTIMONY ................................................................................................494
- S.A. KHMILEVOY'S TESTIMONY ................................................................................................496
- THE TESTIMONY OF A.V. CHENTSOV, GIVEN BY HIM AS A WITNESS,......................................497
- THE TESTIMONY OF CHEPIUK A.F., GIVEN TO HER AS A WITNESS, ........................................498
- CHISLUK O.R.'S TESTIMONY GIVEN TO HER AS A WITNESS,...................................................500
I.A. CHUPIN'S TESTIMONY GIVEN AS A WITNESS,.....................................................................501
EVGENY A. SHALIMOV'S TESTIMONY AS A WITNESS, ...............................................................503
8
A.A. SHOSHIN'S TESTIMONY GIVEN BY HIM AS A WITNESS, ....................................................505
YUDIN M.S.'S TESTIMONY GIVEN BY HIM AS A WITNESS, .........................................................505
- I. A. YURLOVA'S TESTIMONY GIVEN TO HER AS A WITNESS,..............................................506
- THE TESTIMONY OF N.G. YAKUBOVA, GIVEN TO HER AS A SPECIALIST,.................................507
- A. A. KHAIRULLIN'S TESTIMONY, GIVEN BY HIM AS A WITNESS, .........................................509
- THE TESTIMONY OF V.A. ZHDANOVA, GIVEN TO HER AS A WITNESS .....................................509
- THE TESTIMONY OF LUKISHA V.V., GIVEN BY HIM AS A WITNESS, ..........................................510
- D.N. STATSENKO'S TESTIMONY, GIVEN BY HIM AS A WITNESS,..............................................511
- STEPANOV A.N.'S TESTIMONY, GIVEN BY HIM AS A WITNESS,................................................511
- THE TESTIMONY OF D.M. KHARLASHIN, GIVEN BY HIM AS A WITNESS, ................................512
- A. V. ERMOLAEVA'S TESTIMONY GIVEN TO HER AS A WITNESS, .........................................512
- E.E. PASENKO'S TESTIMONY GIVEN TO HER AS A WITNESS, ..................................................513
- A. A. SENINA'S TESTIMONY GIVEN TO HER AS A WITNESS,.................................................513
- KISELEVA E.S.'S TESTIMONY GIVEN TO HER AS A WITNESS,...................................................514
- A. A. ABANOV'S TESTIMONY, GIVEN BY HIM AS A WITNESS, ...............................................515
- THE TESTIMONY OF N.I. KHEKALO, GIVEN TO HER AS A WITNESS, ........................................515
- TESTIMONY OF N.A. KADYMALIEV, GIVEN BY HIM AS A WITNESS, .........................................516
R.A. KHLEBNIKOV'S TESTIMONY, GIVEN BY HIM AS A WITNESS,..............................................517
- THE TESTIMONY OF LEONOV D.V., GIVEN BY HIM AS A WITNESS, ..........................................517
- BAGHDASARYAN M.A.'S TESTIMONY GIVEN TO HER AS A WITNESS, .....................................518
- TESTIMONY OF M.Y. ZHUK, GIVEN TO HER AS A WITNESS, .....................................................518
9
- SEMENISHCHENKOVA S.V.'S TESTIMONY GIVEN TO HER AS A WITNESS, ..............................519
- E.A. ZELENSKAYA'S TESTIMONY AS A WITNESS, .....................................................................519
- A. Y. ALEKSEEVSKY'S TESTIMONY, GIVEN BY HIM AS A WITNESS, ......................................520
- A.S. MOROZ'S TESTIMONY AS A WITNESS,..............................................................................521
- TESTIMONY OF E.S. TSYBENKO, GIVEN TO HER AS A WITNESS, .............................................521
GINOSYAN M.S.'S TESTIMONY GIVEN TO HER AS A WITNESS,..................................................522
- THE TESTIMONY OF N.A. CHERNYSHEVA, GIVEN TO HER AS A WITNESS,.............................522
- THE TESTIMONY OF MARICHEVA E.Y., GIVEN TO HER AS A WITNESS,....................................523
- SOLOMATOV M.E.'S TESTIMONY GIVEN AS A WITNESS, .........................................................524
- A. A. LVOVA'S TESTIMONY GIVEN TO HER AS A WITNESS,...................................................524
- THE TESTIMONY OF LAPSHINA K.A., GIVEN TO HER AS A WITNESS,......................................525
- E.A. MALEEVA'S TESTIMONY GIVEN TO HER AS A WITNESS, ..................................................526
- A.V. SPIRIDONOV'S TESTIMONY AS A WITNESS, .....................................................................526
- DEEVA E.I.'S TESTIMONY GIVEN TO HER AS A WITNESS,.........................................................527
- THE TESTIMONY OF SYSOEVA V.M., GIVEN TO HER AS A WITNESS, .......................................528
-G .A. HASANOV'S TESTIMONY AS A WITNESS, ....................................................................529
- A. V. TUMILOVICH'S TESTIMONY GIVEN TO HER AS A WITNESS,.........................................529
- A.S. VOITENKO'S TESTIMONY GIVEN TO HER AS A WITNESS, ................................................530
- THE TESTIMONY OF MESHALKINA Y.A., GIVEN TO HER AS A WITNESS, .................................531
- THE TESTIMONY OF KORNEEV V.S., GIVEN BY HIM AS A WITNESS, ........................................533
- M.I. POLNIKOV'S TESTIMONY, GIVEN BY HIM AS A WITNESS,.................................................534
10
- TESTIMONY OF NEVSKAYA ZH. V., GIVEN TO HER AS A WITNESS,..........................................534
- STRAX D.I.'S TESTIMONY GIVEN TO HER AS A WITNESS, ........................................................535
- TESTIMONY OF Y.A. FOMENKO, GIVEN TO HER AS A WITNESS,..............................................536
- I. O. ABRAMOVA'S TESTIMONY GIVEN TO HER AS A WITNESS, ..........................................537
- THE TESTIMONY OF TARAKANOVSKAYA M.V., GIVEN TO HER AS A WITNESS, .......................538
- THE TESTIMONY OF M.V. BUGAEV, GIVEN BY HIM AS A WITNESS, ..........................................539
- A. S. ZARIPOVA'S TESTIMONY ...............................................................................................539
- N.S. BURLAKOVA'S TESTIMONY ...............................................................................................540
- PHYSICAL EVIDENCE -..............................................................................................................542
N.V. MODIN'S TESTIMONY AS A WITNESS,.................................................................................542
- THE TESTIMONY OF KUZIN S.L., GIVEN BY HIM AS A WITNESS,..............................................543
A.A. KUZNETSOVA'S TESTIMONY GIVEN TO HER AS A WITNESS, .............................................544
- M. M. KHRIPUNOV'S TESTIMONY , GIVEN BY HIM AS A WITNESS, ....................................544
- THE TESTIMONY OF E.V. GOROBETS, GIVEN TO HER AS A WITNESS, .....................................546
R.V. FEOKTISTOV'S TESTIMONY AS A WITNESS, ........................................................................546
- D. G. BURYAKOVSKY'S TESTIMONY GIVEN AS A WITNESS, .................................................547
- BOGDANOVA K.V.'S TESTIMONY AS A WITNESS, .....................................................................548
I.V. RYBALKA'S TESTIMONY GIVEN TO HER AS A WITNESS,.......................................................549
O.D. MATYUKHINA'S TESTIMONY ...............................................................................................551
- A.O. TALLEROV'S TESTIMONY...................................................................................................552
- FEDOROV M.S.'S TESTIMONY ...................................................................................................553
11
THE TESTIMONY OF SMIRNOV S.B., GIVEN BY HIM AS A WITNESS,..........................................554
- TESTIMONY OF T.O. SHABUNINA, GIVEN TO HER AS A WITNESS, ..........................................555
- D. V. GOLOVANOVA'S TESTIMONY ........................................................................................555
- D. A. GOLOVANOV'S TESTIMONY..........................................................................................556
- T.N. CHEREZOVA'S TESTIMONY................................................................................................558
- O.V. MARICHEVA'S TESTIMONY ................................................................................................559
THE TESTIMONY OF TARANUKH D.V. ..........................................................................................560
- THE TESTIMONY OF SHABAN Y.V., GIVEN BY HIM AS A WITNESS,...........................................561
- NESTEROVA I.S.'S TESTIMONY..................................................................................................562
RUMAK S.E.'S TESTIMONY, GIVEN BY HIM AS A WITNESS, ........................................................563
- THE TESTIMONY OF N.V. MIKHAILOV, GIVEN BY HIM AS A WITNESS, .....................................563
- AGAFONOV S.V.'S TESTIMONY, GIVEN BY HIM AS A WITNESS,................................................564
MAZNICHENKO P.L.'S TESTIMONY GIVEN BY HIM AS A WITNESS, ............................................565
ARSENCHUK V.E.'S TESTIMONY, GIVEN BY HIM AS A WITNESS, ...............................................566
- THE TESTIMONY OF D.V. SOROKIN, GIVEN BY HIM AS A WITNESS, ........................................567
- A.V. SOROKIN'S TESTIMONY , GIVEN BY HIM AS A WITNESS,...............................................568
- TESTIMONY OF V.A. ZARECHNEV, GIVEN BY HIM AS A WITNESS,...........................................569
- THE TESTIMONY OF G.S. TRISHIN, GIVEN BY HIM AS A WITNESS,..........................................570
- THE TESTIMONY OF S.A. KHARITONOV, GIVEN BY HIM AS A WITNESS, .................................572
- TESTIMONY OF ZHERDEVA E.S., GIVEN TO HER AS A WITNESS,.............................................573
- TESTIMONY OF SYUKSYUMOV M.M., GIVEN BY HIM AS A WITNESS,......................................573
12
- KOZHEVNIKOVA T.N.'S TESTIMONY GIVEN TO HER AS A WITNESS,........................................574
- TESTIMONY OF S.V. GOLTYAEV, GIVEN BY HIM AS A WITNESS,...............................................574
THE TESTIMONY OF N.N. GIVEN KUKHMAZOVA, TO HER AS A WITNESS, ................................576
- TESTIMONY OF T.V. SINYAGINA, GIVEN TO HER AS A WITNESS, .............................................577
- A. A. CHIRUKHINA'S TESTIMONY , GIVEN TO HER AS A WITNESS, ......................................578
- I. N. SHPAKOVA'S TESTIMONY GIVEN TO HER AS A WITNESS, ...........................................578
- TESTIMONY OF V.F. SHPAKOV, GIVEN BY HIM AS A WITNESS, ................................................579
- THE TESTIMONY OF V.P. FEOKTISTOV, GIVEN BY HIM AS A WITNESS, ....................................580
- THE TESTIMONY OF A.V. DIORDITS, GIVEN BY HIM AS A WITNESS, ........................................580
- ZVARIN E.N.'S TESTIMONY , GIVEN BY HIM AS A WITNESS,..................................................581
- M.A. TOCHILOVA'S TESTIMONY GIVEN TO HER AS A WITNESS,..............................................582
V.V. SMIRNOVA'S TESTIMONY GIVEN TO HER AS A WITNESS,...................................................582
- CHOPOROV D.A.'S TESTIMONY, GIVEN BY HIM AS A WITNESS, ..............................................583
- THE TESTIMONY OF KOCHETKOVA N.V., GIVEN TO HER AS A WITNESS, ................................584
- D.E. BELOV'S TESTIMONY AS A WITNESS, ...............................................................................585
O.V. VASYUKOVA'S TESTIMONY GIVEN TO HER AS A WITNESS, ................................................586
I.A. POLIBIN'S TESTIMONY GIVEN AS A WITNESS, ....................................................................586
A.A. PANOV'S TESTIMONY GIVEN BY HIM AS A WITNESS .........................................................587
- I.A. ZOTOVA'S TESTIMONY GIVEN TO HER AS A WITNESS,......................................................588
V.A. ZOTOV'S TESTIMONY GIVEN BY HIM AS A WITNESS, .........................................................588
THE TESTIMONY OF MARICHEV A.N.,.........................................................................................589
13
- M.V. LESHCHEV'S TESTIMONY GIVEN BY HIM AS A WITNESS, ................................................589
- M.A. MELNIKOVA'S TESTIMONY ...............................................................................................590
- E.G. SOROKINA'S TESTIMONY ..................................................................................................591
- TESTIMONY OF G.V. SUZDALTSEV,............................................................................................591
- A.P. CHERDINTSEVA'S TESTIMONY ..........................................................................................592
- I.A. BOLSHAKOVA'S TESTIMONY ..............................................................................................592
- A.S. BEREZK'S TESTIMONY.......................................................................................................592
E.O. MIKHEEVA'S TESTIMONY.....................................................................................................594
- I.V. LEVINA'S TESTIMONY ..........................................................................................................594
- THE TESTIMONY OF SHAARANI SH.T., GIVEN BY HIM AS A WITNESS, ....................................595
ISKHAKOV E.V.'S TESTIMONY ......................................................................................................598
- TESTIMONY OF S.N. LOGINOV, .................................................................................................599
-D .V. PODOYNIKOV'S TESTIMONY ........................................................................................599
- D. A. KORSHUNOV'S TESTIMONY ,........................................................................................600
CHRISTOFI MICHALAKIS' TESTIMONY .......................................................................................601
- A. V. PSHENICHNIKOVA'S TESTIMONY .................................................................................604
A.A. LITVINOVA'S TESTIMONY ....................................................................................................608
- TESTIMONY OF E.S. ROGACHEVA, GIVEN TO HER AS A WITNESS, .........................................611
- TESTIMONY OF Y.V. DRONOV, GIVEN BY HIM AS A WITNESS, .................................................614
- PROTOCOL OF SEIZURE DATED 23 SEPTEMBER 2021, CONDUCTED AT THE CENTRAL BANK

OF THE RUSSIAN FEDERATION, 12 NEGLINNAYA STREET, MOSCOW, DURING WHICH
DOCUMENTS RELEVANT TO THE CRIMINAL CASE WERE SEIZED;............................................627
14
- PROTOCOL OF EXAMINATION OF DOCUMENTS DATED 12 MARCH 2022, SEIZED DURING THE
SEIZURE ON 23 SEPTEMBER 2021 AT THE CENTRAL BANK OF THE RUSSIAN FEDERATION,
WHICH ARE OF SIGNIFICANCE AND ESTABLISH THE CIRCUMSTANCES OF THE CRIMINAL
CASE;...........................................................................................................................................627
A GROUP CHAT CORRESPONDENCE NAMED ...........................................................................636
- PROTOCOL OF EXAMINATION OF ITEMS AND DOCUMENTS DATED 11 FEBRUARY 2022,

SEIZED ON 26 MAY 2021 IN THE DWELLING OF E.A. ROSSIEVA AT THE ADDRESS: .................641
14.12.2017 ..................................................................................................................................650
12.03.2018 ..................................................................................................................................650
13.03.2018 ..................................................................................................................................652
14.03.2018 ..................................................................................................................................653
15.03.2018 ..................................................................................................................................654
16.03.2018 ..................................................................................................................................655
26.03.2018 ..................................................................................................................................656
29.03.2018 ..................................................................................................................................657
30.03.2018 ..................................................................................................................................658
23.04.2018 ..................................................................................................................................659
24.04.2018 ..................................................................................................................................661
06.04.2018 ..................................................................................................................................663
12.11.2020 ..................................................................................................................................664
THE CORRESPONDENCE OF THE PARTICIPANTS OF THE GROUP "RESTRUCTURING", WHICH

INCLUDED "LINDA" (SUBSCRIBER NUMBER +3 - 57 - 99 - 920 - 015), "APOLLO" (SUBSCRIBER
NUMBER +3 - 57 - 96 - 218 - 890), "MUNAEV" (SUBSCRIBER NUMBER +7 - 903 - 100 - 41 - 84),
WAS FOUND AND EXAMINED; IN ADDITION, A SUBSCRIBER WITH THE PHONE NUMBER +7 -
965 - 748 - 88 - 88, USED BY THE ACCUSED PAKHOMOV V. S., WAS A PARTICIPANT OF THE
15
GROUP.S. DURING THE EXAMINATION, CORRESPONDENCE WAS ESTABLISHED, INCLUDING
THE FOLLOWING:........................................................................................................................665
THE CORRESPONDENCE OF THE MEMBERS OF THE GROUP "WL", WHICH INCLUDED "YURI
ORLOV" (SUBSCRIBER NUMBER +7 - 926 - 306 - 82 - 26), "LINDA" (SUBSCRIBER NUMBER +3 -
57 - 99 - 920 - 015), "APOLLO" (SUBSCRIBER NUMBER +3 - 57 - 96 - 218 - 890), "MUNAEV"
(SUBSCRIBER NUMBER +7 - 903 - 100 - 41 - 84) WAS FOUND AND EXAMINED. DURING THE
INSPECTION, CORRESPONDENCE WAS ESTABLISHED, INCLUDING THE FOLLOWING:.........672
06.03.2017 ..................................................................................................................................675
02.04.2019 ..................................................................................................................................676
13.02.2020 ..................................................................................................................................679
THE CORRESPONDENCE OF THE MEMBERS OF THE GROUP "FANTASTIC 4", .........................680
WHICH INCLUDED "ROMAN SHPAKOV" (SUBSCRIBER NUMBER +7 - 905 - 735 - 55 - 88),

"LINDA" (SUBSCRIBER NUMBER +3 - 57 - 99 - 920 - 015), "MUNAEV" (SUBSCRIBER NUMBER +7
- 903 - 100 - 41 - 84) WAS FOUND AND EXAMINED; IN ADDITION, A SUBSCRIBER WITH THE
PHONE NUMBER +7 - 965 - 748 - 88 - 88, USED BY THE ACCUSED PAKHOMOV V. S., WAS A
MEMBER OF THE GROUP.S. DURING THE EXAMINATION, CORRESPONDENCE WAS
ESTABLISHED, INCLUDING THE FOLLOWING:...........................................................................680
14.11.2017 ..................................................................................................................................681
15.11.2017 ..................................................................................................................................682
17.11.2017 ..................................................................................................................................685
- MATERIAL EVIDENCE - A MOBILE PHONE "IPHONE XS MAX" BELONGING TO Z.V. MUNAEV,

IMEI: 35 728709 442062 9;..........................................................................................................752
- OTHER DOCUMENTS - MATERIALS OF CIVIL CASE NO. 2 - 5956/17 ON THE CLAIM OF

STEPANOV S.V. AGAINST QBIF INVESTMENT COMPANY LLC, CONTAINING ............................755
EXPERT OPINION NO. 1447 - E DATED 27.11.2017, ...................................................................758
- A.V. POLEZHAEV'S TESTIMONY AS A WITNESS, ......................................................................824
- TESTIMONY OF BULIN G.V., GIVEN BY HIM AS A WITNESS AND VICTIM, ................................827
16
- TESTIMONY OF PETROV A.N., GIVEN BY HIM AS A WITNESS AND VICTIM, ............................830
- THE TESTIMONY OF N.G. SAPOZHKOV, GIVEN BY HIM AS A WITNESS AND VICTIM,..............832
- THE TESTIMONY OF A.V. SHAPRAN, GIVEN TO HER AS A WITNESS AND VICTIM ...................833
- I. E. POLYAKOVA'S TESTIMONY , GIVEN TO HER AS A WITNESS, A VICTIM,........................835
- TESTIMONY OF O.N. SHUT, GIVEN TO HER AS A WITNESS AND VICTIM, ................................836
A.A. PTITSYN'S TESTIMONY ........................................................................................................839
- VEDERNIKOVA V. V.'S TESTIMONY , GIVEN TO HER AS A WITNESS, A VICTIM,.....................841
- TESTIMONY OF TRETIUKHIN A.N., GIVEN BY HIM AS A WITNESS AND VICTIM, .....................843
- E.O. SAZONOV'S TESTIMONY ...................................................................................................844
- TESTIMONY OF N.A. BUBNOV, GIVEN BY HIM AS A WITNESS AND VICTIM, ...........................846
- THE TESTIMONY OF KHLOPIEV V.N., GIVEN BY HIM AS A WITNESS AND VICTIM,..................848
- TESTIMONY OF A.A. KHLOBYSHEV, GIVEN BY HIM AS A WITNESS AND VICTIM.....................850
- TESTIMONY OF V.A. EREMIN, GIVEN BY HIM AS A WITNESS AND VICTIM, .............................851
- THE TESTIMONY OF LOPATIN M.I., GIVEN BY HIM AS A WITNESS AND VICTIM, .....................853
- THE TESTIMONY OF LOMAKINA O.S., GIVEN TO HER AS A WITNESS AND VICTIM, ................854
- A.E. KOZLOVSKAYA'S TESTIMONY, GIVEN TO HER AS A WITNESS AND VICTIM, ....................856
- THE TESTIMONY OF LEVCHENKO V.V., GIVEN BY HIM AS A WITNESS AND VICTIM,...............857
- A.V. GOLOVACH'S TESTIMONY, GIVEN BY HIM AS A WITNESS AND VICTIM ...........................859
- A.N. BRUSKOV'S TESTIMONY , GIVEN BY HIM AS A WITNESS AND VICTIM, ........................860
- B.A. YEGUDKIN'S TESTIMONY , GIVEN BY HIM AS A WITNESS AND VICTIM, .......................861
- THE TESTIMONY OF O.B. SASOVSKAYA, GIVEN TO HER AS A WITNESS AND VICTIM, ...........863
17
I.O. SAZONOVA'S TESTIMONY ....................................................................................................864
- DYACHENKO E.V.'S TESTIMONY................................................................................................866
- TESTIMONY OF V.V. ERMAKOV, GIVEN BY HIM AS A WITNESS AND VICTIM,...........................867
- THE TESTIMONY OF V.Y. CHERKASOV, GIVEN BY HIM AS A WITNESS AND VICTIM, ...............868
- MULLO T.I.'S TESTIMONY , GIVEN BY HIM AS A WITNESS AND VICTIM,................................870
- THE TESTIMONY OF MASLOV Y.V., GIVEN BY HIM AS A WITNESS AND VICTIM,......................872
- THE TESTIMONY OF S.A. VELICHKO, GIVEN BY HIM AS A WITNESS AND VICTIM,..................874
- THE TESTIMONY OF GUMENYUK D.V., GIVEN BY HIM AS A WITNESS AND VICTIM, ...............876
- TESTIMONY OF KHOLODKOV S.V. GIVEN BY HIM AS A WITNESS AND VICTIM, ......................877
- TESTIMONY OF GRIGORIEV A.B., GIVEN BY HIM AS A WITNESS AND VICTIM ........................879
- TESTIMONY OF NIKITCHENKO N.V., GIVEN BY HIM AS A WITNESS AND VICTIM,...................880
- TESTIMONY OF S.D. ZINOVIEV, GIVEN BY HIM AS A WITNESS AND VICTIM ...........................883
- S.N. LOMOV'S TESTIMONY .......................................................................................................884
- TESTIMONY OF V.V. NEMTSEV, GIVEN BY HIM AS A WITNESS AND VICTIM, ...........................887
- TESTIMONY OF A.G. NOVITSKY, GIVEN BY HIM AS A WITNESS AND VICTIM, .........................888
- VAVILOVA L.A.'S TESTIMONY, GIVEN TO HER AS A WITNESS AND VICTIM,.............................890
- TESTIMONY OF N.S. VETROVA, GIVEN TO HER AS A WITNESS AND VICTIM,..........................892
- O.B. BOZHKO'S TESTIMONY, GIVEN TO HER AS A WITNESS AND VICTIM...............................893
- THE TESTIMONY OF M.R. BATALOVA, GIVEN TO HER AS A WITNESS AND VICTIM, ................894
A.A. ROMANOVSKY'S TESTIMONY, GIVEN BY HIM AS A WITNESS AND VICTIM, ......................895
- TESTIMONY OF D.V. EROFEEV, GIVEN BY HIM AS A WITNESS AND VICTIM,............................897
18
- M.I. BORZENKOV'S TESTIMONY AS A VICTIM, .........................................................................898
- THE TESTIMONY OF THE WITNESS BORZENKOV I.A. ..............................................................901
- THE TESTIMONY OF G.V. LEVINA, GIVEN TO HER AS A WITNESS AND VICTIM, ......................907
DANILOV A.V.'S TESTIMONY ........................................................................................................910
- TESTIMONY OF T.O. KRECHETOVA, GIVEN TO HER AS A WITNESS AND VICTIM, ...................911
- THE TESTIMONY OF OSTOVICH E.N., GIVEN TO HER AS A WITNESS AND VICTIM, ................912
- THE TESTIMONY OF V.M. DROBIN, GIVEN BY HIM A SS, THE S A WITNE VICTIM ....................914
- THE TESTIMONY OF KILO V.A., GIVEN BY HIM AS A WITNESS AND VICTIM ............................915
- V. E. EMIRGAMZAEV'S TESTIMONY, GIVEN BY HIM AS A WITNESS AND VICTIM,................916
O.A. KOSORUKOV'S TESTIMONY , GIVEN BY HIM AS A WITNESS AND VICTIM, .....................918
- TESTIMONY OF A.V. LYUTOV, GIVEN BY HIM AS A WITNESS AND VICTIM, ..............................920
- THE TESTIMONY OF BOKOV O.M., GIVEN BY HIM AS A WITNESS AND VICTIM,......................921
- THE TESTIMONY OF KOSTOVSKAYA E.N., GIVEN TO HER AS A WITNESS AND VICTIM, .........922
- TESTIMONY OF V.V. MOROZOV, GIVEN BY HIM AS A WITNESS AND VICTIM, ..........................924
- TESTIMONY OF VOROPAEV A.V., GIVEN BY HIM AS A WITNESS AND VICTIM, ........................926
- TESTIMONY OF S.M. KISHILOV, GIVEN BY HIM AS A WITNESS AND VICTIM, ..........................928
- I.L. BOGOMOLOV'S TESTIMONY AS A WITNESS AND VICTIM, ................................................929
- TESTIMONY OF KOSOVSKY B.G., GIVEN BY HIM AS A WITNESS AND VICTIM, .......................930
- I.L. SEMENOV'S TESTIMONY AS A WITNESS AND VICTIM, ......................................................931
- TESTIMONY OF L.L. SEMENOVA, GIVEN TO HER AS A WITNESS AND VICTIM, .......................933
- BOLSHOV M.A.'S TESTIMONY AS A WITNESS AND VICTIM, ....................................................935
19
- TESTIMONY OF DIANOV E.G., GIVEN BY HIM AS A WITNESS AND VICTIM,.............................936
- A.V. GUBANOV'S TESTIMONY AS A WITNESS AND VICTIM,..................................................... 940
- TESTIMONY OF VOROBYEVA - DESYATOVSKAYA N.N., GIVEN TO HER AS A WITNESS AND

VICTIM, ........................................................................................................................................942
- K.G. GALACHYAN’S TESTIMONY AS A WITNESS AND VICTIM, ................................................943
- E.F. CHEKMAREVA'S TESTIMONY AS A WITNESS AND VICTIM,............................................... 945
- TESTIMONY OF M.A. BIRNOV, GIVEN BY HIM AS A WITNESS AND VICTIM, ............................946
- THE TESTIMONY OF POTAPOV A.V., GIVEN BY HIM AS A WITNESS AND VICTIM, ...................947
- TESTIMONY OF BOSAK L.V., GIVEN TO HER AS A WITNESS AND VICTIM, ...............................948
- TESTIMONY OF PARAMONOV S.V., GIVEN BY HIM AS A WITNESS AND VICTIM,..................... 950
- TESTIMONY OF GRIF S.V., GIVEN TO HER AS A WITNESS AND VICTIM, ..................................951
- R.V. ANDREEV'S TESTIMONY AS A WITNESS AND VICTIM,......................................................953
- TESTIMONY OF IVANOV K.A., GIVEN BY HIM AS A WITNESS AND VICTIM, ............................. 955
- TESTIMONY OF PETROV P.E., GIVEN BY HIM AS A WITNESS AND VICTIM,..............................956
- TESTIMONY OF T.V. BASKOVA, GIVEN TO HER AS A WITNESS AND VICTIM,...........................958
- TESTIMONY OF MISHIN I.Y., GIVEN BY HIM AS A WITNESS AND VICTIM,................................ 960
- TESTIMONY OF A.V. NAZARENKOV, GIVEN BY HIM AS A WITNESS AND VICTIM, ...................961
- THE TESTIMONY OF BURMISTROV V.N., GIVEN BY HIM AS A WITNESS AND VICTIM, ............962
- THE TESTIMONY OF MISHIN Y.A., GIVEN BY HIM AS A WITNESS AND VICTIM,.......................963
- THE TESTIMONY OF V.G. MAZITOV, GIVEN BY HIM AS A WITNESS AND VICTIM ..................... 965
- D.Y. TOLOKNOV'S TESTIMONY AS A WITNESS AND VICTIM ....................................................966
20
- A.L. KIM'S TESTIMONY AS A WITNESS AND VICTIM ................................................................968
- TESTIMONY OF TROSHKOVA M.S., GIVEN TO HER AS A WITNESS AND VICTIM, ....................969
- TESTIMONY OF GANEVA E.P., GIVEN TO HER AS A WITNESS AND VICTIM, ............................970
- TESTIMONY OF I.A. PODGORNAYA, GIVEN TO HER AS A WITNESS AND VICTIM ...................972
- THE TESTIMONY OF KOVIN A.P., GIVEN BY HIM AS A WITNESS AND VICTIM,.........................973
- TESTIMONY OF ZATSARINSKY D.E., GIVEN BY HIM AS A WITNESS AND VICTIM,...................975
- TESTIMONY OF A.V. MUDROGIN, GIVEN BY HIM AS A WITNESS AND VICTIM, .......................977
- A.V. RUCHEEV'S TESTIMONY AS A WITNESS AND VICTIM, .....................................................978
- TESTIMONY OF I.V. DONSKOY, GIVEN BY HIM AS A WITNESS AND VICTIM, ...........................981
- TESTIMONY OF NOSENKO M.N., GIVEN BY HIM AS A WITNESS AND VICTIM, ........................982
- TESTIMONY OF N.G. MITROSHIN, GIVEN BY HIM AS A WITNESS AND VICTIM .......................983
- A. A. BATUEV'S TESTIMONY AS A WITNESS AND VICTIM,....................................................985
- THE TESTIMONY OF N.V. DRAPESA, GIVEN BY HIM AS A WITNESS AND VICTIM, ...................986
- KORMILITSYN S.V.'S TESTIMONY, GIVEN BY HIM AS A WITNESS AND VICTIM, .......................988
- THE TESTIMONY OF PODOLNA A.V., GIVEN TO HER AS A WITNESS AND VICTIM,..................989
- THE TESTIMONY OF V.S. KONCHEROVA, GIVEN TO HER AS A WITNESS AND VICTIM, ..........991
- THE TESTIMONY OF V.S. KORESHKOV, GIVEN BY HIM AS A WITNESS AND VICTIM,...............992
- THE TESTIMONY OF BORISOV M.A., GIVEN BY HIM AS A WITNESS AND VICTIM,...................994
21
INDICTMENT
in criminal case No. 12001450007000902
on the charge in the commission of the o/ence of ч. 3, Art. 210, and 151 of the o/ence under Part 4, Art. 159
of the Criminal Code of the Russian Federation, in the commission of the o/ence of ч. 3, Art. 210, and 123
o/ences under Part 4, Art. 159 of the Criminal Code of the Russian Federation,
CONVICTED IN ABSENTIA AND ON THE RUN: R.V. Shpakov
CONVICTED IN ABSENTIA AND ON THE RUN: Athanasiadou Linda (Kovalenko, Torres,

Athanasiades)
CONVICTED AND JAILED:

CONVICTED AND JAILED: Vladimir Sergeevich Pakhomov,
CONVICTED AND JAILED: Munaev Z.V.
CONVICTED AND JAILED: Stanislav Anatolievich Matyukhin
CONVICTED AND JAILED: Evgenia Anatolievna Rossieva
CONVICTED AND JAILED: Alexei Sergeyevich Golubev
and unidentified persons
APPROVED
First Deputy Prosecutor General R
ussian Federation state councillor
22
CONVICTED:
1.Surname, first name, patronymic Vladimir Sergeevich Pakhomov (Vol. No. 295, page
246)
2. Date of birth Born on 08.01.1988 (Vol. No. 295, page 246)
3. place of birth city. Moscow (Vol. No. 295, l.d. 246)
4.Place of residence and (or) registration, telephone registered at: Moscow, Pechatnikov per., 26, sq. 8,
number actually resides at: Moscow, Rublevskoe shosse, 70,
bldg. 7, sq. 77 (Vol. No. 295, pp. 205, 247)
5. Nationality Russian Federation (Vol. No. 295, fol. 246)
6.Education Higher (volume No. 295, fol. 205)
7. Marital status family composition Unmarried, no children (vol. 295, pp. 205, 247).
8. Place of work or study, telephone number Not working (Vol. No. 349, pp. 110 - 111)
9. Attitude towards military duty He is liable for military duty, has been registered
with the Military Commissariat of the Tverskiy
District of the Central Administrative District of
Moscow since 30.07.2009, a private in the reserve
(Vol. No. 296, page 10).
10. Existence of a criminal record (when and by what No criminal record (Vol. No. 295, pp. 249, 250, Vol.
court was convicted, under what article of the Criminal No. 296, p. 1)
Code of the Russian Federation, type and amount of
punishment, when released)
11. Passport or other document certifying the identity Passport of a citizen of the Russian Federation,
of the defendant series 45 09 No. 712092, issued on 21.07.2008 by
the Meshchansky District Office of the Federal
Migration Service of Russia for Moscow in the
Central Administrative District, subdivision code
770 - 007 (Vol. No. 295, pp. 246 - 248)
12. other data on the identity of the accused He is not registered with the Ministry of Internal
Affairs or the Ministry of Health (Vol. No. 296, pp. 2,
3, 5 and 6) and has a formal characteristic at the
place of registration (Vol. No. 296, p. 8).
in that he Vladimir Sergeevich Pakhomov committed the management of a structural subdivision

included in a criminal association (criminal organisation), participation in a criminal association
(criminal organisation), committed by a person using his ogicial position, namely:
R.V. Shpakov, being the head of the financial group "QBF" (QBF), general director and a participant of various legal
entities, using his official position expressed in influencing other persons to perform certain actions aimed at their
participation in a criminal association (criminal organisation), based on the importance and authority of the positions
he holds and his position in the organisations that were part of this financial group, having the intention to
systematically commit serious crimes of mercenary orientation, i.e., fraud
23
In order to achieve the desired criminal result, R.V. Shpakov developed a plan to create and form a criminal
association with a clear distribution of roles among the participants, the main activity of which was to commit fraud
under the pretext of investing funds in securities with high yields, as well as under the guise of fulfilling obligations
under over - the - counter option contracts.
According to the criminal plan, R.V. Shpakov, realising the public danger of his criminal actions,
using his ogicial position for criminal purposes, formed a criminal association as follows:
- the creation of a number of functionally separate structural units that performed strictly defined functions and
had a clear specialisation for specific offences;
- involvement in the criminal association of direct managers of separate structural subdivisions from among
trusted persons, as well as persons inclined to commit thef by deception;
- Finding, creating and registering legal entities in accordance with the procedure established by law, the details of
which were used in the production of standard sets of fictitious contracts and accompanying documents,
allegedly testifying to the legitimate activities of these organisations;
- Involvement in the criminal community (criminal organisation), in its structural subdivisions of direct executors
of criminal intent from among persons involved in the activities of organisations, inclined to commit thef by
deception, having mercenary aspirations;
- involvement in the criminal association of persons who ensured the functioning of the structural units of the
criminal association as a whole;
- determination of the scheme of distribution of criminal income, which allowed the direct perpetrators of the
crimes to maintain financial motivation directly dependent on the number of defrauded citizens, as well as the
formation of a criminal fund, the money from which was used to finance the activities of the criminal association;
- the involvement in the activities of organisations used by the criminal association of persons unaware of the
criminal intent of the participants in the criminal association;
- development of certain methods and techniques of deception, the use of which enabled the direct perpetrators
of the offences and persons involved in the activities of organisations used by the criminal association, unaware
of the criminal nature of the actions of co - conspirators, to achieve the criminal association's objective of
obtaining criminal proceeds;
- creation of a strict hierarchy between the heads of functionally separate structural units, lower - level managers
and direct perpetrators of crimes, in order to create the possibility of using the developed methods and ways of
deception by persons who directly communicated with clients.
- At the initial stage of establishing the criminal association, R.V. Shpakov determined the direction of joint
criminal activity with his co - conspirators, aimed at violating the legally protected property rights of citizens by
fraudulent means, and in order to directly obtain material benefits, developed a detailed criminal plan for a long
period of activity, which consisted in the distribution of roles among the members of the criminal association,
the interaction of its subdivisions in order to realise common criminal intentions, as well as the distribution of
functions between them, orchestrating the criminal association's activities, and the allocation of functions of the
criminal association.
- The plan developed by R.V. Shpakov for the activities of a criminal association aimed at committing serious
offences envisaged the following stages:
- seeking money necessary to support the criminal activities of the criminal association and its structural
subdivisions;
- registration and search for legal entities both in the territory of the Russian Federation and in the territory of
foreign states, the requisites of which were used in the preparation of standard sets of fictitious contracts,
agreements and related documents, allegedly testifying to the legitimate activities of these organisations;
- finding and attracting accomplices, assigning them criminal roles in the criminal association, as well as attracting
persons unaware of the criminal intentions of the participants in the criminal association, in order to ensure the
functioning of the mechanism of committing crimes and increase the number of citizens willing to enter into
client agreements for the provision of direct access services to international stock markets, trust management
24
agreements, service agreements, agreements for the provision of services, agreements for the provision of
brokerage services (attachment agreements), agreements for the provision of direct access to international stock
markets, and agreements for the provision of brokerage services (attachment agreements).
- developing an individual plan for committing offences and selecting a method of committing and concealing
offences.
- coordination of the activities of participants in the criminal association;
- Organisation of the process of producing client agreements on provision of direct access services to international
stock markets, agreements on provision of trust management services in accordance with the agreement on
provision of direct access services to international stock markets, trust management agreements, service
agreements, service agreements, brokerage service agreements (adhesion agreements), OTC option agreements,
as well as other documents used for embezzlement of funds
- Placement of advertisements in mass media and the Internet about the benefits of concluding client agreements
on providing direct access to international stock markets, as well as OTC option agreements;
- development of various algorithms of negotiations with clients in order to create a relationship of trust between
the latter and the participants of the criminal association and to mislead citizens by providing deliberately false
information about the profitability of investing money;
- training the members of the criminal community in special terminology, algorithms of deception, as well as the
formation of the latter's goal and motivation to take possession of as much of the victim's money as possible by
creating a system of bonuses and incentives within the criminal community;
- Finding office premises in various regions of the Russian Federation, which were used both by members of the
criminal association and by persons unaware of the criminal intentions of the co - conspirators, and which were
used to hold meetings, negotiate with clients and receive money from the latter;
- ensuring partial return (withdrawal) of funds deposited by clients (investors) that were stolen in order to create
the appearance of objective trading and market volatility, as well as to prevent clients from reporting thefs to
law enforcement authorities;
- The implementation of measures to conceal offences and avoid possible criminal or other liability by giving the
appearance of legality to financial activities;
- clear distribution of funds in the interests of the criminal association, as well as among its members, based on
the "contribution" of each participant to criminal activity;
- implementation of other actions aimed at the smooth functioning of the criminal activity scheme.
According to the criminal plan of R.V. Shpakov, the criminal association created and directed by
him embezzled money from citizens under the guise of providing brokerage services.
R.V. Shpakov knew that in accordance with the Federal Law of 22.04.1996 No. 39 - FZ "On the Securities Market", as
well as in accordance with numerous instructions, regulations, guidelines of the Central Bank of the Russian
Federation in the field of professional participants of the securities market, brokerage activity is the activity on
execution of the client's order to perform civil law transactions with securities and (or) to conclude agreements that
are derivative financial instruments, carried out on the basis of compensatory contracts with the client. At the same
time, R.V. Shpakov, in violation of the above law, planned to systematically steal money belonging to citizens by
means of deceit, which consisted of deliberate communication of knowingly false information to clients, with the aim
of obtaining criminal income and distribution by concluding, on behalf of organisations controlled by the participants
of the criminal association, acting under the guise of brokerage companies, client agreements on provision of direct
access to international stock markets, trust management agreements, and agreements on provision of financial
derivatives.
In accordance with the criminal plan developed by R.V. Shpakov, in order to commit serious crimes, as well as in order
to veil his criminal activity and make his actions look legitimate, no later than 31 December 2011. was sought LLC
Investment Company QBIF (INN 7733673955, before renaming on 13.04.2016 - LLC IK QBIF Investment, before
renaming on 23.12.2015 - LLC QBIF Finance, hereinafer referred to as the Company), which had a licence dated 24
December 2009 No. 045 - 12805 - 100000 for brokerage activities, licence dated 24 December 2009. No. 045 - 12816 -
25
010000 for dealer activities, license No. 045 - 12828 - 001000 dated 24 December 2009 for securities management
activities and license No. 045 - 14078 - 000100 dated 08 August 2019 for depository activities (which were cancelled by
the decision of the Central Bank of the Russian Federation on 08 July 2021 due to numerous violations of the
requirements of the legislation, regulations of the Central Bank of the Russian Federation and internal documents of
the Company). The said Company, its details and accounts were supposed to be used by the participants of the
criminal association to mislead clients about the true intentions of the co - conspirators and subsequent commission
of serious crimes - embezzlement of funds, as well as to create a belief in citizens (clients) about the profitable
investment of funds, who believed that they were interacting with a professional participant of the securities market,
which was engaged in these types of activities and was obliged to ensure the priority of the client's interests pa
In addition, not stopping there, in order to attract more clients and, as a consequence, more money for further
embezzlement, R.V. Shpakov, together with members of the criminal association, in the course of criminal activity, no
later than 31 December 2019, developed and implemented an additional criminal plan, which provided for the
following. Within the framework of the brokerage services agreement (adhesion agreement) concluded by QBIF
Investment Company LLC (hereinafer referred to as "the Broker") with its clients, the Company, when executing
transactions, executed the clients' orders to conclude transactions on the OTC market with derivative financial
instruments, including options, the underlying asset of which were equity securities of foreign issuers (hereinafer
referred to as "OTC option contracts"). The counterparty (seller) under all OTC option contracts, including those
concluded in the interests of clients - individuals, was an organisation affiliated with QBIF Investment Company LLC -
Q-BROKER LLC (INN 9703003668), the ultimate beneficiary of which was R.V. Shpakov.
In this case, in accordance with the criminal plan, the implementation of OTC options by Q-BROKER LLC was to
function as a financial pyramid scheme, where the source of return of funds to clients under OTC option contracts
executed or partially executed by Q-BROKER LLC was the funds received under newly concluded option contracts, and
the ultimate goal of the option contracts was to carry out schematic operations for withdrawal of funds outside the
Russian Federation, cashing out of the Russian Federation.
The direct theft of money belonging to citizens was also carried out according to the criminal
plan developed by R.V. Shpakov, divided into several stages.
The first stage of embezzlement of citizens' money provided that the participants of the first structural subdivision of
the criminal association, as well as persons unaware of the criminal intentions of the accomplices, who were under
the control of R.V. Shpakov, acting in accordance with the instructions of the head of the structural subdivision,
received the data of selected potential clients (investors) who had the opportunity to transfer or deposit large sums of
money into their accounts, to conclude contracts (agreements) with them, as well as to impose trust services.
The second stage of embezzlement of citizens' money provided that the participants of the first structural subdivision
of the criminal association, as well as persons unaware of the criminal intentions of the accomplices, who were under
the control of R.V. Shpakov, acting in accordance with the instructions of the head of the structural subdivision, by
telephone or at a personal meeting misled the clients about their true intentions and created a belief in the citizens
that they were offered a profitable investment of their money. In turn, the clients believed that they were interacting
with a professional participant in the securities market who was engaged in brokerage activities and was obliged to
ensure that the client's interests were prioritised over its own interests.
The third stage of the thef of citizens' money provided that the participants of the first structural subdivision of the
criminal association, as well as persons unaware of the criminal intentions of the accomplices, who were under the
control of R.V. Shpakov, acting in accordance with the instructions of the head of the structural subdivision, organised
the process of preparing and signing client agreements on the provision of direct access to international stock
markets, agreements on the provision of trust management services in accordance with the agreement of the first
structural subdivision of the criminal association.
26
The fourth stage of embezzlement of citizens' money provided that the participants of the first structural subdivision
of the criminal association, as well as persons unaware of the criminal intentions of the accomplices, who were under
the control of R.V. Shpakov, acting in accordance with the instructions of the head of the structural subdivision,
carried out and organised the process of accepting cash or the process of transferring money from the accounts of
clients to the accounts of individuals and legal entities controlled by the criminal association.
At the same time, the participants of the criminal association were allowed to modify the algorithm of communication
with clients, taking into account the specific situation, in order to achieve the common goal of extracting criminal
income, while fulfilling their predetermined roles. Thus, the entire plan of criminal actions was aimed solely at
obtaining by deception and abuse of trust as much money as possible, regardless of the circumstances.
R.V. Shpakov, using his official position, in the period from 31 December 2011 to 31 August 2017, implementing plans
to create a criminal association, formed from its participants, as well as other persons involved in criminal activity, a
structured organised group consisting of 3 functionally separate organised groups (structural subdivisions of the
criminal association), with a clear distribution of roles, interacting with each other in order to implement a single
criminal intent and performing strictly defined functions. At the same time, he identified the heads of these structural
subdivisions from among his acquaintances, having previously obtained their consent to join the criminal association,
and initiated them into the criminal plan aimed at stealing citizens' money.
Thus, the criminal association created and directed by R.V. Shpakov included: no later than 27 March 2012, the exact
date and time not determined by the investigation, V.S. Pakhomov, no later than 01 June 2012, the exact date and
time not determined by the investigation, Z.V. Munaev, no later than 31 December 2013, the exact date and time not
determined by the investigation, Athanasiadou Linda , no later than 28 February 2015, the exact date and time not
determined by the investigation, A.S. Golubev, no later than 26 July 2017, the exact date and time not determined by
the investigation, S.A. Matyukhin, no later than 31 August 2017, the exact date and time not determined by the
investigation, E.A. Rossieva, and in the period from 31 December 2011 to 26 May 2021, the exact date and time not
determined by the investigation, unidentified persons who were initiated into the common criminal plan and involved
in criminal activity. Afer that, the above - mentioned persons, aware of the common goals of the criminal association,
with the aim of criminal enrichment, out of selfish motives, voluntarily agreed to fulfil the criminal roles assigned to
them, thus joining the criminal association.
R.V. Shpakov, as the founder of the criminal association, assigned himself the leading role in the
criminal association and assigned himself the following duties:
- seeking the funds necessary to support the criminal activities of the criminal organisation;
- organisation of the process of registration and solicitation of legal entities, including: "QB Investment Company"
LLC; "QB Investment Company CY Ltd"; "QB Adviszeri" LLC (INN 7703426941); "VL Consulting" LLC (INN 7706463476);
"Q.Broker" LLC; "QB Capital CY LTD" ("QB Capital CY LTD", registration number HE 221325, since 14 August 2017.
renamed QCCI LTD, incorporated in the Republic of Cyprus); WLM LTD ("WLM LTD," registration number CR - 347210,
incorporated in the Cayman Islands); White Lake Management LTD."(registration number SE - 330557, registered in the
territory of the Cayman Islands); Simtelligence Company Limited (registration number 1570903, registered in the
Hong Kong Special Administrative Region of the People's Republic of China), the details of which were used to prepare
model sets of various types of fictitious contracts, agreements and related documents purportedly indicative of
legitimate activities, and to credit the accounts of the above - mentioned entities with funds that were received in full
by the above - mentioned entities.
- Organising the process of registration and solicitation of legal entities, including: LLC F - Experts (INN 7703439757);
LLC F - Management (INN 7703448776); LLC Format Development (INN 7708243109); LLC Managing Company Moi
Finansy (INN 7725682730); LLC Sintez (INN 7708270984); LLC Simon jesso (INN 7703769586); LLC Severspetsstroy (INN
7703769579); LLC Rentinvest (INN 7703423933); LLC Profi (INN 7703447860); LLC Millhouse Invest (INN 5029252176);
LLC Finbutik (INN 7731610156); LLC M4 Invest (INN 7701973890); LLC Kucisiai (INN 7708786218); LLC Kubif (INN
27
7703458823); LLC Kubi Credit (INN 7703740234); LLC KF Estate SPB (INN 7840472851); LLC Q.Broker" (INN
9703003668); LLC "VL Consulting" (INN 7706463476); LLC "KP Queue 4" (INN 9731017278); LLC "KP Queue 3" (INN
7704471087); LLC "KP Queue 2" (INN 7702459550); LLC "K - Consulting" (INN 7703471373); LLC "K - Investment" (INN
7703470098); KG LLC (INN 7701876374); F - Technologies LLC (INN 7703448769); Qubief Asset Management LLC (INN
7704835400); Indep Smart LLC (INN 7735159230); DV Technologies LLC (INN 7703442478); Vysota LLC (INN
7734371675); LLC "Ver - mont" (INN 7718304946); LLC "776" (INN 6658523875); LLC "702" (INN 7703474800); LLC "701"
(INN 7703456375); LLC "168 Kvartal" (INN 7703769272); LLC "F - Technolodges" (INN 7725726949); LLC "S - Control"
(5047245990); LLC "M1 Invest" (INN 7701367560); JSC RIF (INN 5047241522); JSC Financial Group QBIF (INN
7703466327); JSC Marketplace Moi Finansy (INN 9703012630); PJSC Venture Finance Centre (INN 7734682254); JSC
QBIF (INN 7703399818); Argento Access Es.A.A R.L. ("Argento Access S.A R.L.", registration number B 174898);
Constance Investment LTD ("Constance Investment LTD", registration number HE 333743); T.C.R. International LTD
("T.C.R. International LTD, registration number HE 326383), the details of which were used to carry out schematic
transactions involving the withdrawal of funds from the Russian Federation, cashing out funds, purchasing real estate,
financing the construction of real estate and issuing loans to legal entities and individuals affiliated with the co -
conspirators;
- determination of goals in the development of general plans for the activities of the criminal association, as well as
the performance of actions aimed at achieving the goals of the criminal association, the distribution of roles among
the participants, the organisation of logistical support, the development of ways of committing and concealing the
committed crimes, the adoption of security measures against the participants of the organised group, conspiracy and
the distribution of funds derived from criminal activity among all participants of the criminal association;
- involving accomplices in the criminal association, as well as persons unaware of the criminal activity, coordinating
their activities and controlling the performance of their functions;
making decisions and giving appropriate instructions to the participants of the criminal association on issues related
to the distribution of stolen funds, as well as organising the process of distribution of criminal proceeds, including
determining the amount of remuneration to co - conspirators, as well as financing the mechanism of criminal activity.
- distribution of the proceeds of crime among the participants of the criminal association, based on the assigned role
of each participant, as well as his acts that contributed to the commission of the offences;
- planning and organisation of criminal activity, in order to reduce material and financial losses, as well as
confirmation of professional skills of persons involved by R.V. Shpakov in committing crimes, selection of persons
involved in the criminal community, and production of interview procedures with such persons, which had a positive
effect on further joint criminal activity;
- Organising the process of placing advertisements in the media and on the Internet about the benefits of investing
money with the involvement of QBIF Investment Company LLC, which, under the guise of a professional business
entity holding licences from the Central Bank of the Russian Federation to carry out brokerage activities, dealer
activities, securities management activities and depository activities, was used to introduce
- training the members of the criminal community in special terminology, algorithms of deception, as well as the
formation of the latter's goal and motivation to take possession of as much of the client's money as possible by
creating a system of bonuses and incentives within the criminal community;
- Conducting regular meetings, training and debriefings on the effectiveness of all structural units of the criminal
organisation with all heads of structural units of the criminal organisation, as well as with some of the participants;
- resolving conflict situations with citizens whose rights have been violated, including by informing clients about the
readiness to return their attracted funds and pay the relevant profit.
At the same time, the participants of the criminal association themselves positioned the above - mentioned legal
entities as organisations that were part of a single financial group "QBF" ("QBF"), the head of which was R.V. Shpakov,
28
and who, at various times during the period of the criminal association's operation and the commission of
embezzlement of funds, was also the general director and a participant in OOO Simon jesso, OOO Severspetsstroy,
OOO KG, OOO 168 Kvartal, AO QBF and AO QBF Financial Group, which was a participant in OOO QBF Investment
Company, the general director of OOO QBF.Broker", as well as a participant of LLC "F - Management", LLC "M4 Invest",
LLC "KF Estate SPB", LLC "F - Technologies", LLC "S - Control" and LLC "M1 Invest", whose accounts and details were
used both for embezzlement of funds, and for the subsequent implementation of schematic operations with funds for
the withdrawal of funds outside the Russian Federation, cashing in of funds received from citizens, acquisition of
immovable property, securities and financing of the construction of real estate objects at the expense of funds stolen
from citizens. Thus, R.V. Shpakov was vested with the powers of both a manager and a participant of the above
companies, as provided for by Federal Law No. 14 - FZ dated 08.02.1998 "On Limited Liability Companies", Federal
Law No. 208 - FZ dated 26.12.1995 "On Joint - Stock Companies", as well as the charters of these companies.
In turn, on a date and time not specified by the investigation, but no later than 27 March 2012,
R.V. Shpakov initiated V.S. Pakhomov into the criminal plan and attracted him to participate in the
criminal association, assigning him a leading role in the first functionally separate structural
subdivision of the criminal association created on a date and time not specified by the
investigation, but no later than 27 March 2012,
the participants of which, during the period from 27 March 2012 to 26 May 2021, found and equipped office premises,
which were positioned by the participants of the criminal association as additional branches of LLC Investment
Company QBF, operating under a single brand - QBF Financial Group ("QBF"), located on the territory of various
regions of the Russian Federation in offices at the following addresses: Moscow, Presnenskaya Naberezhnaya, 8, p. 1,
and Presnenskaya Naberezhnaya, 8, p. 1. 1 and Presnenskaya Embankment, 12; Ufa, Verkhnetorgovaya Ploshchad, 4;
Tyumen, ul. 4; Tyumen, 74 Maksim Gorky St.; Murmansk, 82 Lenin Ave.; Kazan, 6 Spartakovskaya St.; Ekaterinburg, 1a
Boris Yeltsin St.; St. Petersburg, 11 Degtyarny Per. and 64 Maloohtinsky Prospekt, Lit. B; Kaliningrad, 35 Teatralnaya
St.. Pakhomov V.S., being aware of the general goals of the criminal association functioning, having the purpose of
criminal enrichment, out of selfish motives agreed to fulfil the criminal role assigned to him, thus voluntarily joined
the criminal association in the role of the head of the first functionally separate structural subdivision of the criminal
association.
At the same time, R.V. Shpakov, using his official position, gave V.S. Pakhomov the duties of leading the largest
structural subdivision of the criminal association in terms of the number of persons, whose participants, as well as
persons unaware of the criminal activity, persuaded citizens of the need to transfer funds and directly carried out the
receipt of cash from clients or organised the process of transferring citizens' funds to controlled accounts, i.e. the
duties of committing and organising the criminal association.
At the same time, Pakhomov V.S. was to independently involve other persons in criminal activity
and subsequently appoint them to higher positions with greater income.
Pakhomov V.S., endowed by R.V. Shpakov with organisational and administrative functions, who, like R.V. Shpakov.
influenced other persons in order for them to perform certain actions aimed at participation in the criminal
association, based on the importance and authority of his position:
- the head of the branch network of the financial group "QBF" ("QBF"), and who at different times during the period of
operation of the criminal association and thef of funds, was also the General Director of LLC QBF Estate SPB, as well
as a participant of LLC KG, which was a participant of LLC Investment Company QBF, whose accounts and details were
used by the participants of the criminal association in the commission of the offences,
Pakhomov V.S. was assigned the following duties:

- leadership of the first structural unit of the criminal organisation;
29
- finding office premises in regions of the Russian Federation, which were used to accommodate both the
participants in the criminal association and persons unaware of the criminal intentions of the co - conspirators,
and which were used to hold meetings and negotiations with clients, as well as to receive money from the latter;
- establishment, organisation of activities of individual additional branches of QBF Investment Company LLC, as
well as management, development of the branch network of QBF Financial Group ("QBF") as a whole;
- training of the participants of the first structural subdivision of the criminal community in special terminology,
algorithms of deception, as well as formation of the latter's goal and motivation to take possession of as much
money of clients as possible by means of observing a system of bonuses and incentives within the structural
subdivision of the criminal community;
- conducting regular meetings, trainings, in order to check the effectiveness of the activities of the participants of
the first structural unit of the criminal organisation;
- coordination and control over the actions of the participants of the first structural subdivision of the criminal
association, as well as persons unaware of the criminal plan involved in the activities of this structural
subdivision;
- ensuring the concealment of ongoing criminal activity by introducing new elements to disguise the true
objectives of the participants in the criminal association with the knowledge and consent of the leader of the
criminal association;
- Direct personal participation in advertising, as well as organisation of placing advertisements in the mass media
and the Internet about the benefits of investing money with the involvement of QBIF Investment Company LLC,
which, under the guise of a professional business entity that had licences from the Central Bank of the Russian
Federation for brokerage activities, dealer activities, securities management activities and depository activities.
- encashing in additional branches of QBIF Investment Company LLC the funds received from clients for the
purpose of subsequent transfer to R.V. Shpakov for further distribution among the participants of the criminal
association;
- Organising the process of producing fictitious reports for clients on the management of the securities portfolio,
as well as reports on client accounts for securities transactions and transactions related to it, and sending such
reports to clients;
- making decisions and giving appropriate instructions to participants in the criminal association on matters
related to the distribution of stolen funds, as well as organising the distribution of criminal proceeds, including
determining the amount of remuneration to persons unaware of criminal intentions, and financing the criminal
mechanism;
- The implementation of measures to conceal offences and avoid possible criminal or other liability by giving the
appearance of legality to activities that were in fact criminal in nature;
- organisation of reports that reflected the number of clients and the amount of money received from them;
- resolving conflict situations with citizens whose rights have been violated, including by informing clients about
the readiness to return their attracted funds and pay the relevant profit;
- resolving problematic situations that arose during inspections and supervisions by the regulator, as well as
developing an algorithm for interaction with the staff of the Central Bank of the Russian Federation;
- taking measures to disguise the illegal activities of the criminal association in order to successfully and
systematically operate in a manner that resulted in the stable receipt of criminal income, as well as to increase
conspiracy measures to conceal the criminal activities of the criminal association from being exposed by law
enforcement officials;
- performing other actions aimed at the smooth functioning of the criminal scheme of the criminal association.
30
The members of the separate structural subdivision of the criminal association led by V.S.
Pakhomov, who, among other things, was authorised as the head and participant of LLC "KF
Estate SPB" and LLC "KG", respectively, as provided for by Federal Law No. 14 - FZ dated
08.02.1998 "On Limited Liability Companies" and the charters of these companies, had the
following duties:
- Matyukhin S.A.,
appointed in accordance with Resolution No. 38 of the Sole Participant of QBIF Investment Company LLC dated 25
July 2017 as the General Director of the Company since 26 July 2017, was the sole executive body performing
organisational, administrative and economic functions, managing the Company's day - to - day operations, which, in
accordance with Federal Law No. 14 - FZ "On Limited Liability Companies" dated 08.02.1998 and the Charter of QBIF
Investment Company LLC, was entitled, inter alia: to act on behalf of the Company without a power of attorney,
including to represent its interests and make transactions; to issue orders on the appointment of employees to the
position of the CEO of QBIF Investment Company LLC.
- Munaev Z.V.
coordinated the activities of the participants of the criminal association, as well as persons unaware of the criminal
intentions of the co - conspirators, located in one of the offices of the QBF group at the following address: 8
Presnenskaya Naberezhnaya Naberezhnaya, bldg. 1; training of the participants of the first structural unit of the
criminal association in special terminology, algorithms of deception, as well as formation of the latter's goal and
motivation to take possession of as much money of clients as possible by observing a system of bonuses and
incentives within the structural unit of the criminal association; holding regular meetings, trainings and summaries of
the effectiveness of the activities of the participants of the first structural unit of the criminal association;
coordination and control over the actions of the participants of the first structural unit of the criminal association.
A.S. Golubev
carried out: finding office premises in the regions of the Russian Federation, which were used by the participants of
the criminal association and persons unaware of the criminal intentions of the co - conspirators to hold meetings and
negotiations with clients, as well as to receive money from the latter; organising the activities of the participants of
the criminal association and persons unaware of the criminal intentions of the co - conspirators located in the offices
of the QBF group at the following addresses: St. Petersburg, Degtyarny per. St. Petersburg, Degtyarny per, 11, lit. "B",
and Maloohtinsky Prospe, 64, lit. "B"; holding meetings, seminars, trainings with the participants of the criminal
association, as well as with persons unaware of the criminal intentions of the co - conspirators, aimed at improving
the skills of working with clients in order to attract as much money as possible; ensuring the concealment of criminal
activities by introducing new elements of veiling the true goals of the participants of the criminal association with the
knowledge and consent of the head of the criminal association; encashment in additional branches of OOO "QBF"
("QBF") and "QBF" ("QBF") at the addresses: St. Petersburg, Degtyarny Lane, 11, lit. "B", and Maloohtinsky Prospekt.-
unidentified co - conspirators carried out: production of client agreements on provision of direct access services to
international stock markets, agreements on provision of trust management services in accordance with the
agreement on provision of direct access services to international stock markets, trust management agreements,
service agreements, service agreements, brokerage services agreements (adhesion agreements), OTC option
agreements, as well as other documents, using for x
31
Also on a date and time not specified by the investigation, but no later than 31 December 2013,
Shpakov R.V., using his ogicial position, initiated the criminal intent and involved Athanasiadou
Linda in the criminal association, assigning her a leading role in the second functionally separate
structural subdivision of the criminal association,
created on a date and time not specified by the investigation, but no later than 31 December 2013, the participants of
which were located in various office premises in Moscow at an unspecified period of time, including from an
unspecified time until 26 May 2021 at the following address: 8 Presnenskaya Naberezhnaya Embankment, Moscow, p.
1. 1. Athanasiadou Linda, being aware of the general goals of the criminal association, with the aim of criminal
enrichment, out of selfish motives agreed to fulfil the criminal role assigned to her, thereby
Athanasiadou Linda voluntarily joining the criminal association in the role of head of the second
functionally separate structural subdivision of the criminal association, thereby entrusting
Athanasiadou Linda with the following duties:
- leadership of the second structural subdivision of the criminal organisation;
- seeking organisations, nominee managers, representatives acting under a power of attorney in the territory of
foreign countries, as well as legal support of these organisations, including: "QB Capital CY LTD ("QB Capital CY
LTD"); WLM LTD ("WLM LTD"); White Lake Management LTD ("White Lake Management LTD"); Simtelligence
Company Limited ("Simtelligence Company Limited"); Argento Access S.A.S.A.A.A R.L. ("Argento Access S.A R.L.");
Constance Investment LTD ("Constance Investment LTD"); T.C.R. International LTD ("T.C.R. International LTD), the
details of which were used in the production of standard sets of various types of fictitious contracts, agreements
and accompanying documents purportedly indicative of legitimate activities, as well as for the crediting of funds
received from clients to the accounts of these organisations;
- opening and maintaining accounts for both legal entities registered in the territory of the Russian Federation and
non - residents used to embezzle funds, making transit transfers of funds received from citizens to accounts
opened with credit institutions located in the territory of the Russian Federation and in various foreign countries,
including: Principality of Liechtenstein; Republic of Kosovo; Republic of Armenia; Republic of Turkey; Republic of
South Africa; Cayman Islands; Republic of Vanuatu; Union of the Comoros; United States of America; Republic of
Poland; United Kingdom of Great Britain and Northern Ireland;
- Scheme operations with citizens' money, the ultimate goal of which was to withdraw money outside the Russian
Federation, cash in, purchase immovable property and securities with the money stolen from citizens, and
finance the construction of real estate;
- coordination and control over the actions of the participants of the second structural unit of the criminal
association, as well as persons involved in the activities of this structural unit who are unaware of the criminal
plan of the accomplices;
objectives of the participants in the criminal association with the knowledge and consent of the leaders of the
- making decisions and giving appropriate instructions to participants of the criminal association on issues related
to the distribution of stolen funds, as well as organising the distribution of criminal proceeds, including
determining the amount of remuneration to persons unaware of the criminal intentions of accomplices, and
financing the criminal mechanism;
- The implementation of measures to conceal offences and evade possible criminal or other liability by giving the
appearance of legality to the criminal activity being carried out;
enforcement officers;
- performing other actions aimed at the smooth functioning of the criminal scheme of the criminal association.
32
The members of the separate structural subdivision of the criminal association led by
Athanasiadou Linda had the following responsibilities:
The unidentified co - conspirators sought and provided legal support in the territory of foreign countries for
organisations, managers, and representatives acting under a power of attorney, including: "QB Capital CY LTD; WLM
LTD; White Lake Management LTD; Simtelligence Company Limited; Argento Access Es.A.A R.L. ("Argento Access S.A
R.L."); Constance Investment LTD ("Constance Investment LTD"); T.C.R. International LTD ("T.C.R. International LTD),
preparation of various documents on behalf of these organisations, allegedly testifying to their legitimate activities, as
well as the documents necessary for the crediting of funds received from clients and the subsequent implementation
of schematic transactions with funds for the withdrawal of funds outside the Russian Federation; cashing in of funds
received from citizens, acquisition of real estate and securities at the expense of funds stolen from citizens; financing
the construction of real estate.
Also on a date and time not specified by the investigation, but no later than 31 August 2017,
Shpakov R.V., using his ogicial position, initiated Rossieva E.A. into the criminal intent and
involved her in the criminal association, assigning her a leading role in the third functionally
separate structural subdivision of the criminal association,
created on a date and time not specified by the investigation, but no later than 31 August 2017, the participants of
which, between 31 August 2017 and 26 May 2021, were located in the office of QBF Group at 8 Presnenskaya
Naberezhnaya Street, Moscow, p. 1. 1.
E.A. Rossieva, being aware of the general goals of the criminal association, having the purpose of
criminal enrichment, out of selfish motives agreed to fulfil the criminal role assigned to her,
thereby voluntarily joined the criminal association in the role of the head of the third functionally
separate structural subdivision of the criminal association, and her duties were as follows:
- leadership of the third structural unit of the criminal organisation;
- attracting accomplices to the criminal association, as well as persons unaware of the criminal activity,
coordinating their activities and controlling the fulfilment of their functions;
- Organisation of the process of registration and search for legal entities, nominal general directors, participants,
as well as representatives acting under a power of attorney, whose details (legal entities) were used in the
preparation of standard sets of various types of fictitious contracts, agreements and related documents,
ostensibly testifying to legitimate activities, for crediting funds received from clients, as well as for the
implementation of scheme operations aimed at withdrawing funds outside of Russia LLC QBIF Investment
Company; LLC QBIF Adviser; LLC VL Consulting; LLC Q.Broker; "F - Experts" LLC; "F - Management" LLC; "Format
Development" LLC; "My Finance Management Company" LLC; "Syntez" LLC; "Simon jesso" LLC;
"Severspetsstroy" Ltd; LLC Rentinvest; LLC Profi; LLC Millhouse Invest; LLC Finbutik; LLC M4 Invest; LLC Kucisiai;
LLC Kubifef; LLC Kubi Credit; LLC KF Estate SPB; LLC Q.Broker; VL Consulting LLC; KP Queue 4 LLC; KP Queue 3
LLC; KP Queue 2 LLC; K - Consulting LLC; K - Investment LLC; KG LLC; F - Technologies LLC; Qubief Asset
Management LLC; Indep Smart LLC; DV Technologies LLC; Vysota LLC; Ver - mont LLC; 776 LLC; 702 LLC; 701 LLC;
168 Quarter LLC; F - Technologies LLC; LLC S - Control; LLC M1 Invest; JSC RIF; JSC QBIF Financial Group; JSC
Marketplace Moi Finansy; PJSC Venture Finance Centre; JSC QBF; "QB Capital CY LTD; WLM LTD; White Lake
Management LTD; Simtelligence Company Limited;
- organisation and personal participation in legal support and representation of legal entities used in criminal
activities in various state bodies and courts of general jurisdiction;
- Organisation of the opening with receipt of "bank - client" sofware and further servicing of accounts of legal
entities used in criminal activities;
- development of an algorithm for interaction with employees of the Central Bank of the Russian Federation who
carried out checks and supervisions, as well as a mechanism for providing these employees with information
33
and documents necessary to give the appearance of legality to criminal activity and prevent the criminal activity
of the criminal association from being exposed;
objectives of the participants in the criminal association with the knowledge and consent of the leader of the
- making decisions and giving appropriate instructions to participants of the criminal association on issues related
to the distribution of stolen funds, as well as organising the distribution of criminal proceeds, including
determining the amount of remuneration to persons unaware of the criminal intentions of accomplices, and
financing the criminal mechanism;
- The implementation of measures to conceal offences and evade possible criminal or other liability by giving the
appearance of legality to the criminal activity being carried out;
enforcement officials;
- implementation of other actions aimed at the smooth functioning of the criminal scheme.
The members of the separate structural subdivision of the criminal association, headed by E.A.
Rossieva, were assigned the following duties:
The unidentified co - conspirators registered and sought legal entities, nominal general directors, participants, and
representatives acting under a power of attorney, whose details (legal entities) were used to prepare model sets of
various types of fictitious contracts, agreements, and related documents purportedly indicating legitimate activities,
to credit funds received from clients, and to carry out schematic operations aimed at withdrawing funds from clients.
In addition, the first functionally separate structural unit of the criminal association, in the period from 31 December
2011 to 26 May 2021, involved persons unaware of the criminal intentions of the participants of the criminal
association, who, without involving them in the criminal association and without initiating them into the general
criminal plan, were assigned the following functions and responsibilities based on their professional qualities:
communicating with clients, both in person and by telephone, about the benefits of investing money; receiving from
citizens the following functions and responsibilities
In the second functionally separate structural unit of the criminal association, between 31 December 2011 and 26 May
2021, persons unaware of the criminal intentions of the participants in the criminal association were recruited who,
without involving them in the criminal association and without initiating them into the general criminal plan, were
assigned the following functions and duties based on their professional qualities: preparing and submitting to tax
authorities and credit institutions various documents necessary for the registration of legal entities and
In the third functionally separate structural unit of the criminal association, in the period from 31 December 2011 to
26 May 2021, persons unaware of the criminal intentions of the participants in the criminal association were recruited,
who, without involving them in the criminal association and without initiating them into the general criminal plan,
were assigned the following functions and duties based on their professional qualities: production of various
documents necessary for the registration of legal entities involved in the embezzlement of funds, as well as
documents for the registration of legal entities involved in the embezzlement of funds.
The criminal association created by R.V. Shpakov was characterised by:

- cohesion and stability, expressed in the stability and constancy of the leadership of structural units, constancy of
the general method of committing thefs;
34
- - directed at committing certain crimes - embezzlement of property of citizens, the essence of which was the
conclusion of various contracts and agreements on behalf of controlled organisations acting under the guise of
brokerage companies, receipt of funds from clients and their subsequent embezzlement;
- stable structure within the criminal community, the existence of certain rules of behaviour within the criminal
community with specific sanctions for non - compliance, which allowed to maintain strict discipline and
subordination in the structural units in the commission of crimes and the distribution of criminal profits;
- distribution of roles in the commission of crimes among the participants of the criminal association, as a result of
which, in the systematic commission of crimes, the participants acted in a coordinated and organised manner;
- the use of sophisticated methods of committing and concealing offences, the use of a system of conspiracy and
protection from exposure;
- the time - consuming preparation for the commission of the crimes, expressed in the search for legal entities to
give the appearance of legality of criminal activity, renting premises for the location of offices, purchasing office
equipment, telephones and specialised equipment, selecting and training co - conspirators in the ways of
committing crimes, and developing methods and techniques of deception;
- the development and application of a single value and normative motivation, the basis of which was material
incentives for members of the criminal association depending on the number of defrauded citizens and the
amounts received from clients in the commission of crimes;
- - distribution of criminal proceeds in accordance with the position of each participant in the hierarchy of the
criminal association, expressed in the allocation of a set percentage of the money received as a result of the
commission of crimes by the participants of the criminal association to the organiser, heads of structural
subdivisions, managers, as well as to persons unaware of the criminal intentions of the participants of the
criminal association.
The consciousness and will of all accomplices in the ogences encompassed circumstances
relating not only to their own criminal act, but also to the acts of other accomplices. This was
expressed in the following:
- all members of the criminal association united on the basis of common selfish goals and criminal intent aimed at
obtaining systematic profits from embezzlement of funds;
- the actions of the members of the criminal association were coordinated and interconnected with each other
and aimed at achieving a single criminal result;
- Each of the participants was aware of the structure of the criminal association, of the actions performed by each
member of the association, and hoped for their successful completion, since the illegal actions of some members
of the criminal association, without the successful completion of the actions of other members of the criminal
association, would not lead to the final criminal result and goals desired by the participants of the criminal
association.
-
In addition, the participants of the criminal association determined in advance possible

obstacles for themselves in committing a socially dangerous act, and, above all, in the part
concerning the exposure and detention of these persons by the police, in connection with which
they:
- committed the offences with the same offences;
- The participants of the criminal association conducted telephone conversations and text messages among
themselves in a veiled form, hiding the true motives and goals of the criminal association from outsiders;
- prepared alibis for themselves in advance (i.e. in case of detention by police officers, the accomplices had to say
that they worked for an organisation that carried out legitimate financial and economic activities and were not
aware of the criminal nature of these activities).
35
The creation and management of a criminal association, as well as its structural subdivisions, is initially conditioned
by the selfish purpose of committing multiple serious crimes and obtaining as much criminal income as possible. The
search for various legal entities for the commission of criminal activity, both in the territory of the Russian Federation
and in the territory of various foreign countries, is conditioned by the need to give the appearance of legitimate
business activity to their criminal actions, and the presence of an organisational and staff structure of a criminal
association characterises its hierarchy and is necessary to achieve cohesion, stability, observance of strict discipline
and subordination in the commission of crimes.
The unlawful activities of the criminal association described above continued for a long time, and its participants
intended to continue their unlawful actions in the future. The termination of the unlawful activities of this criminal
association occurred on 26 May 2021, not depending on the will of its participants, but due to the suppression of
these activities by law enforcement agencies and the detention of the active participants of the criminal association.
Thus, Pakhomov V.S. committed the leadership of a structural subdivision included in a criminal
association (criminal organisation), participation in a criminal association (criminal
organisation), committed by a person using his ogicial position,
created and directed by Shpakov R.V. during the period from 31 December 2011 (until the time when the criminal
activity was suppressed by police officers). 26 May 2021 (until the criminal activity was stopped by police officers), the
participants of which committed 151 grave crimes - fraud, i.e. thef of other people's property by deception and abuse
of trust, committed by an organised group, in large and especially large amounts, against the following citizens:
Kozlovskaya N.S., Polezhaev A.V., Bulin G.V., Petrov A.N., Sapozhkov N.G., Shapran A.V., Polyakova I.E., Shut O.N.,
Ptitsyn A.A., Vedernikova V.V., Tretiukhin A.N., Sazonov E.O., Bubnov N.A., Khlopyev V.N., Khlobyshev A.A., Eremin V.A.,
Lopatin M.I., Lomakina O.S., Kozlovskaya A.E., Levchenko V.V., Golovach A.V., Bruskov A.N., Egudkin B.A., Sasovskaya
O.B., Sazonova I.O., Dyachenko E.V., Ermakov V.V., Cherkasov V.Y., Mullo T.I., Maslov Y.V., Velichko S.A., Gumenyuk D.V.,
Kholodkov S.V., Grigoriev A.B., Nikitchenko N.V., Zinoviev S.D., Lomov S.N., Nemtsev V.V., Novitskiy A.G., Vavilova L.A.,
Vetrova N.S., Bozhko O.B., Batalova M.R., Romanovsky A.A., Erofeev D.V., Borzenkov M.I., Baiguzina S.A., Levina G.V.,
Naumova E.G., Danilov A.V., Krechetova T.O., Ostovich E.N., Drobin V.M., Kilo V.A., Emirgamzaev V.E., Kosorukov O.A.,
Lyutov A.V., Bokov O.M., E.N. Kostovskaya, V.V. Morozov, A.V. Voropaev, S.M. Kishilov, I.L. Bogomolov, B.G. Kosovsky, I.L.
Semenov, L.L. Semenova, M.A. Bolshov, Dianov E.G., Gubanov A.V., Vorobyov - Desyatovsky N.V., Galachyan K.G.,
Chekmareva E.F., Birnov M.A., Potapov A.V., Bosak L.V., Paramonov S.V., Grif S.V., Andreev R.V., Ivanov K.A., Petrov P.E.,
Baskova T.V., Mishin I.Y., Nazarenkov A.V., Burmistrov V.N., Mishin Yu, Toloknov D.Y., Kim A.L., Troshkova M.S., Ganeva
E.P., Podgornaya I.A., Kovin A.P., Zatsarinsky D.E., Mudrogin A.V., Ruchev A.V., Donskov I.V., Nosenko M.N., Mitroshin
N.G., Batuev A.A., Drapesa N.V., Kormilitsyn S.V., Podolnaya A.V., Koncherova V.S., Koreshkov V.S., Borisov M.A.,
Tokareva A.A., Malinin D.I., Kulikova A.V., Kuzmenko K.N., Shilov A.V., Voropaev A.A., Gorbunov R.V., Shlykov A.K.,
Kuryatnikov L.A., Demidkova T.V., Grushanina I.S., Drapez M.I., Pilenitsyn K.A., Kamzolov E.A., Elkin P.M., Bondarenko
I.V., Vasyunin A.P., Grekov S.A., Borodin V.V., Chernova Zh, Ivanov A.S., Silin D.S., Sbitnev K.I., Kushkov S.V., Pavlenko
I.V., Smirnov A.V., Bazaev M.A., Trishin A.A., Mitkin D.V., Sotnikov V.P., Korolskiy V.V., Trukhmeneva S.V., Alekseev F.V.,
Rodnevskaya M.Y., Savin A.V., Medvedev R.V., Babelyan S.A., Kalinin S.V., Galaktionov S.V., Frolov Y.A., Pilin D.A., Merts
A.N., Astakhov A.B., Popov P.V., Tregubov A.V., Mayorova G.V., for a total amount of RUB 1,993,883,054.93.
The specific criminal activity of the participants in the criminal association established under the
above circumstances was expressed in the following:
- 28.11.2013 committed embezzlement of funds of Natalia Stepanovna Kozlovskaya in the amount of 594,000
rubles, i.e. on a large scale, by deceit and breach of trust, consisting in creating in the latter, as a client of the
QBF group organisation, a false appearance of the possibility of obtaining a high income, as a result of which
the client concluded a service agreement for the provision of a trading account with the amount of funds in it
equal to the amount of funds received from the client (brokerage service agreements), and provided the co -
conspirators with his funds in the specified amount for trust management. These agreements were
36
concluded for direct access to trading on stock and derivatives markets, but the participants in the criminal
association knew that their obligations to the client to pay the funds were unfulfilled, since the information
about the brokerage activities of the organisation with which it had concluded the agreement for direct
access to international stock markets was false. The co - defendants did not use the money received from the
client under this agreement for the purposes specified in the agreements, but stole it and used it at their own
discretion;
- in the period from April 2012 to 11.02.2014 committed embezzlement of funds of Andrey Vyacheslavovich
Polezhaev in the amount of 68,477,000 roubles, i.e. on a particularly large scale, by means of deceit and
breach of trust, which consisted in creating a false appearance of a high income opportunity for the latter, as
a client of the QBF group organisation, as a result of which the client entered into a service agreement for the
provision of a trading account with the amount of funds in it equal to the amount of funds received from the
client (brokerage service agreements), and provided the co - conspirators with his funds in the specified
amount for trust management. These agreements were concluded for direct access to trading on stock and
derivatives markets, but the participants in the criminal association knew that their obligations to the client
to pay the funds were unfulfilled, since the information about the brokerage activities of the organisation
with which he had concluded the agreement on providing direct access to international stock markets was
false. The co - defendants did not use the money received from the client under this agreement for the
purposes specified in the agreements, but stole it and used it at their own discretion;
- during the period from 23.01.2014 to 29.04.2014 committed embezzlement of Gennady Viktorovich Bulin's
funds in the amount of 815,000 rubles, i.e. on a large scale, by deceit and breach of trust, consisting in
creating in the latter, as a client of the QBF group organisation, a false appearance of the possibility of
obtaining a high income, as a result of which the client concluded a service agreement for the provision of a
trading account with the amount of funds on it equal to the amount of funds received from the client
(brokerage service agreements), and also provided the co - conspirators with their own funds. These
agreements were concluded for direct access to trading on stock and derivatives markets, but the
participants in the criminal association knew that their obligations to the client to pay the funds were
unfulfilled, since the information about the brokerage activities of the organisation with which he had
concluded the agreement to provide direct access to international stock markets was false. The co -
defendants did not use the money received from the client under this agreement for the purposes specified
in the agreements, but stole it and used it at their own discretion;
- during the period 07.02.2014 to 20.05.2014 committed embezzlement of funds of Alexey Nikolayevich Petrov
in the amount of 6 255 329,07 rubles, i.e. on a particularly large scale, by deceit and breach of trust,
consisting in creating in the latter, as a client of the organisation of the group "QBF" ("QBF"), a false
appearance of the possibility of obtaining a high income, as a result of which the client entered into a service
agreement for the provision of a trading account with the amount of funds in it equal to the amount of funds
received from the client (brokerage service agreements), and provided the co - conspirators with his funds in
the specified amount for trust management. These agreements were concluded for direct access to trading
on stock and derivatives markets, but the participants in the criminal association knew that their obligations
to the client to pay the funds were unfulfilled, since the information about the brokerage activities of the
organisation with which he had concluded the agreement on providing direct access to international stock
markets was false. The co - defendants did not use the money received from the client under this agreement
for the purposes specified in the agreements, but stole it and used it at their own discretion;
- 30.07.2014 committed embezzlement of funds of Nikolay Georgievich Sapozhkov in the amount of 3,563,000
rubles, i.e. on a particularly large scale, by deceit and breach of trust, consisting in creating in the latter, as a
client of the QBF group organisation, a false appearance of the possibility of obtaining a high income, as a
result of which the client entered into a service agreement for the provision of a trading account with the
amount of funds in it equal to the amount of funds received from the client (brokerage service agreements),
and provided the co - conspirators with his funds in the specified amount for trust management. These
37
concluded the agreement on providing direct access to international stock markets was false. The co -
- 31.10.2014 committed embezzlement of funds of Anna Vasilievna Shapran in the amount of 425,000 rubles,
i.e. on a large scale, by deceit and breach of trust, consisting in creating in the latter, as a client of the QBF
group organisation, a false appearance of the possibility of obtaining a high income, as a result of which the
client concluded a service agreement for the provision of a trading account with the amount of funds in it
equal to the amount of funds received from the client (brokerage service agreements), and provided the co -
discretion;
- during the period from 13.10.2014 to 11.12.2014 committed embezzlement of funds of Irina Eizerovna
Polyakova in the amount of 1,768,320 rubles, i.e. on a particularly large scale, by means of deceit and breach
of trust, which consisted in creating a false appearance of the possibility of receiving a high income in the
latter, as a client of the QBF group organisation, as a result of which the client concluded a service agreement
for the provision of a trading account with the amount of funds in it equal to the amount of funds received
from the client (brokerage service agreements), and provided the co - conspirators with his funds in the
specified amount for trust management. These agreements were concluded for direct access to trading on
stock and derivatives markets, but the participants in the criminal association knew that their obligations to
the client to pay the funds were unfulfilled, since the information about the brokerage activities of the
organisation with which it had concluded the agreement for direct access to international stock markets was
- during the period from 27.07.2013 to 16.12.2014 committed embezzlement of funds of Olga Nikolaevna Shut
in the amount of 1,950,000 rubles, i.e. on a particularly large scale, by deception and breach of trust,
consisting in creating in the latter, as a client of the QBF group organisation, a false appearance of the
possibility of receiving a high income, as a result of which the client concluded a service agreement for the
provision of a trading account with the amount of funds on it equal to the amount of funds received from the
client (brokerage service agreements), and also provided the co - conspirators with their own funds. These
unfulfilled, since the information about the brokerage activities of the organisation with which it had
concluded the agreement for direct access to international stock markets was false. The co - defendants did
not use the money received from the client under this agreement for the purposes specified in the
agreements, but stole it and used it at their own discretion;
- 26.12.2014 committed thef of Andrey Aleksandrovich Ptitsyn's money in the amount of 6,156,540 rubles, i.e.
on a particularly large scale, by deception and breach of trust, consisting in creating in the latter, as a client of
the QBF group organisation, a false appearance of the possibility of obtaining a high income, as a result of
which the client entered into a service agreement for the provision of a trading account with the amount of
funds in it equal to the amount of funds received from the client (brokerage service agreements), and
provided the co - conspirators with his funds in the specified amount for trust management. These
38
- during the period from 27.03.2012 to 31.12.2014 committed embezzlement of funds of Veronika Valeryevna
Vedernikova in the amount of 5,027,110 rubles, i.e. on a particularly large scale, by means of deceit and
breach of trust, which consisted in creating a false appearance of the possibility of receiving a high income in
the latter, as a client of the organisation of the group "QBF" ("QBF"), as a result of which the client concluded
a service agreement for the provision of a trading account with the amount of funds in it equal to the amount
of funds received from the client (brokerage service agreements), and provided the co - conspirators with his
funds in the specified amount for trust management. These agreements were concluded for direct access to
trading on stock and derivatives markets, but the participants in the criminal association knew that their
obligations to the client to pay the funds were unfulfilled, since the information about the brokerage
activities of the organisation with which it had concluded the agreement on providing direct access to
international stock markets was false. The co - defendants did not use the money received from the client
under this agreement for the purposes specified in the agreements, but stole it and used it at their own
discretion;
- in the period from 29.04.2015 to 23.06.2015 committed embezzlement of Andrey Nikolayevich Tretiukhin's
money in the amount of 1,405,200 rubles, i.e. on a particularly large scale, by means of deceit and breach of
trust, which consisted in creating in the latter, as a client of the QBF group organisation, a false appearance of
the possibility of receiving a high income, as a result of which the client entered into a service agreement for
the provision of a trading account with the amount of funds in it equal to the amount of funds received from
the client (brokerage service agreements), and provided the co - conspirators with his funds in the specified
- during the period from 06.08.2015 to 02.10.2015 committed embezzlement of funds of Sazonov Evgeny
Olegovich in the amount of 8,882,130.8 rubles, i.e. on a particularly large scale, by deceit and breach of trust,
possibility of receiving a high income, as a result of which the client entered into a service agreement for the
- during the period from 24.06.2015 to 13.10.2015 committed thef of Nikolai Alexandrovich Bubnov's money in
the amount of 1,583,810 rubles, i.e. on a particularly large scale, by deception and breach of trust, consisting
in creating in the latter, as a client of the QBF group organisation, a false appearance of the possibility of
receiving a high income, as a result of which the client entered into a service agreement for the provision of a
trading account with the amount of funds in it equal to the amount of funds received from the client
(brokerage service agreements), and provided the co - conspirators with his funds in the specified amount for
trust management. These agreements were concluded for direct access to trading on stock and derivatives
markets, but the participants in the criminal association knew that their obligations to the client to pay the
funds were unfulfilled, since the information about the brokerage activities of the organisation with which he
had concluded the agreement on providing direct access to international stock markets was false. The co -
39
- in the period from 29.04.2015 to 19.10.2015 committed embezzlement of funds of Vyacheslav Nikolaevich
Khlopiev in the amount of 9,213,600 rubles, i.e. on a particularly large scale, by deceit and breach of trust,
- in the period from 30.10.2015 to 28.01.2016 committed embezzlement of funds of Aleksey Alekseevich
Khlobyshev in the amount of 2 211 431,35 rubles, i.e. on a particularly large scale, by deception and breach of
trust, consisting in creating a false appearance of the possibility of receiving a high income in the latter, as a
client of the group organisation "QBF" ("QBF"), as a result of which the client entered into a service
- 09.03.2016 committed thef of funds of Vladimir Aleksandrovich Eremin in the amount of 13 340 634,06
rubles, i.e. on a particularly large scale, by deceit and breach of trust, consisting in creating a false
appearance of a high income opportunity for the latter, as a client of the organisation of the QBF group (QBF),
as a result of which the client concluded a service agreement for the provision of a trading account with the
amount of funds on it equal to the amount of funds received from the client (brokerage service agreements),
and also provided the client with a brokerage account. These agreements were concluded for direct access to
obligations to the client to pay the funds were unfulfilled, as the information about the brokerage activities of
the organisation with which he concluded the agreement for direct access to international stock markets was
- during the period from 24.03.2016 to 20.04.2016 committed thef of funds of Mikhail Ivanovich Lopatin in the
amount of 800,000 rubles, i.e. on a large scale, by deceit and breach of trust, consisting in creating in the
latter, as a client of the group organisation "QBF" ("QBF"), a false appearance of the possibility of obtaining a
high income, as a result of which the client concluded a service agreement for the provision of a trading
account with the amount of funds on it in the amount of the funds received from the client (brokerage service
agreements), and provided the co - conspirators with their own funds. These agreements were concluded for
direct access to trading on stock and derivatives markets, but the participants in the criminal association
knew that their obligations to the client to pay the funds were unfulfilled, since the information about the
brokerage activities of the organisation with which he had concluded the agreement to provide direct access
to international stock markets was false. The co - defendants did not use the money received from the client
discretion;
40
- 11.05.2016 committed embezzlement of Oksana Sergeyevna Lomakina's funds in the amount of RUB
665,892.5, i.e. on a large scale, by deception and breach of trust, which consisted in creating a false
appearance of a high income opportunity for the latter, as a client of the QBF group organisation, as a result
of which the client concluded a service agreement for the provision of a trading account with the amount of
- in the period from 03.07.2014 - May 2016 committed thef of funds of Anna Eduardovna Kozlovskaya in the
amount of 792,980 rubles, i.e. on a large scale, by deceit and breach of trust, consisting in creating a false
appearance of the possibility of obtaining a high income for the latter, as a client of the organisation of the
group "QBF" ("QBF"), as a result of which the client concluded a service agreement for the provision of a
funds were unfulfilled, since the information about the brokerage activities of the organisation with which it
had concluded the agreement for direct access to international stock markets was false. The co - defendants
did not use the money received from the client under this agreement for the purposes specified in the
- during the period from 25.12.2014 to 22.08.2016 committed thef of funds of Valery Vladimirovich Levchenko
in the amount of 1,060,045 rubles, i.e. on a particularly large scale, by deceit and breach of trust, consisting in
creating in the latter, as a client of the organisation of the group "QBF" ("QBF"), a false appearance of the
possibility of obtaining a high income, as a result of which the client entered into a service agreement for the
- 19.10.2016 committed embezzlement of funds of Alexander Vasilievich Golovach in the amount of RUB
327,028, i.e. on a large scale, by deceit and breach of trust, which consisted in creating a false appearance of a
high income opportunity for the latter, as a client of the QBF group organisation, as a result of which the
client concluded a service agreement for the provision of a trading account with the amount of funds on it
equal to the amount of funds received from the client (brokerage service agreements), and also provided a co
- conspirator. These agreements were concluded for direct access to trading on stock and derivatives
had concluded the agreement to provide direct access to international stock markets was false. The co -
- in the period from 30.05.2016 to 10.11.2016 committed embezzlement of funds of Alexey Nikolaevich Bruskov
41
- in the period from 29.09.2016 to 14.11.2016 committed embezzlement of funds of Yegudkin Boris
Anatolievich in the amount of 13 082 940 rubles, i.e. on a particularly large scale, by deceit and breach of
trust, consisting in creating in the latter, as a client of the QBF group organisation, a false appearance of the
- during the period from 22.09.2015 to 18.11.2016 committed embezzlement of funds of Olga Borisovna
Sasovskaya in the amount of 1,000,000 rubles, i.e. on a large scale, by deceit and breach of trust, consisting in
(brokerage service agreements), and also provided the co - conspirators with their own funds. These
- during the period from 11.05.2016 to 25.11.2016 committed embezzlement of funds of Irina Olegovna
Sazonova in the amount of 2,688,400 rubles, i.e. on a particularly large scale, by deceit and breach of trust,
possibility of obtaining a high income, as a result of which the client concluded a service agreement for the
with which it had concluded the agreement for direct access to international stock markets was false. The co
- defendants did not use the money received from the client under this agreement for the purposes specified
- 31.01.2017 committed embezzlement of funds of Ekaterina Vladimirovna Dyachenko in the amount of
5,000,000 rubles, i.e. on a particularly large scale, by deceit and breach of trust, consisting in creating in the
latter, as a client of the QBF group organisation, a false appearance of the possibility of receiving a high
income, as a result of which the client concluded a service agreement for the provision of a trading account
with the amount of funds on it equal to the amount of funds received from the client (brokerage service
42
agreements), and also provided a co - brokerage service. These agreements were concluded for direct access
to trading on stock and derivatives markets, but the participants in the criminal association knew that their
activities of the organisation with which it had concluded the agreement for direct access to international
stock markets was false. The co - defendants did not use the money received from the client under this
agreement for the purposes specified in the agreements, but stole it and used it at their own discretion;
- in the period from 24.12.2015 to 31.01.2017 committed thef of funds of Yermakov Valery Vasilyevich in the
amount of 1,040,180 rubles, i.e. on a particularly large scale, by deceit and breach of trust, consisting in
- 21.07.2017 committed embezzlement of funds of Vasily Yurievich Cherkasov in the amount of 4,135,600
rubles, i.e. on a particularly large scale, through deceit and breach of trust, which consisted in creating a false
appearance of the possibility of obtaining a high income for the latter, as a client of the QBF group
organisation, as a result of which the client entered into a service agreement for the provision of a trading
account with the amount of funds in it equal to the amount of funds received from the client (brokerage
service agreements), and provided the co - conspirators with his funds in the specified amount for trust
management. These agreements were concluded for direct access to trading on stock and derivatives
- in the period from 08.06.2016 to 14.08.2017 committed embezzlement of funds of Mullo Taiwo Ivanovic in the
amount of 4,970,000 rubles, i.e. on a particularly large scale, by deception and breach of trust, consisting in
- 17.08.2017 committed thef of Yuri Viktorovich Maslov's money in the amount of 50,860,000 rubles, i.e. on a
particularly large scale, by deception and breach of trust, consisting in creating in the latter, as a client of the
the client entered into a service agreement for the provision of a trading account with the amount of funds in
it equal to the amount of funds received from the client (brokerage service agreements), and provided the co
- conspirators with his funds in the specified amount for trust management. These agreements were
43
about the brokerage activities of the organisation with which he had concluded the agreement on providing
direct access to international stock markets was false. The co - defendants did not use the money received
from the client under this agreement for the purposes specified in the agreements, but stole it and used it at
their own discretion;
- in the period from 11.04.2013 to 28.08.2017 committed embezzlement of funds of Velichko Sergey
Alexandrovich in the amount of 1 175 030 rubles, i.e. on a particularly large scale, by deceit and breach of
trust, consisting in creating in the latter, as a client of the organisation of the group "QBF" ("QBF"), a false
- in the period from 15.09.2017 to 04.10.2017 committed thef of Gumenyuk Denis Vasilievich's money in the
creating a false appearance of the possibility of obtaining a high income in the latter, as a client of the
organisation of the group "QBF" ("QBF"), as a result of which the client entered into a service agreement for
- 11.10.2017 committed embezzlement of funds of Sergey Viktorovich Kholodkov in the amount of RUB
2,600,000, i.e. on a particularly large scale, by deception and breach of trust, consisting in creating in the
latter, as a client of the QBF group organisation, a false appearance of the possibility of receiving a high
income, as a result of which the client entered into a service agreement for the provision of a trading account
with the amount of funds in it equal to the amount of funds received from the client (brokerage service
agreements), and provided the co - conspirators with his funds in the specified amount for trust
- in the period from 09.10.2015 to 16.10.2017 committed embezzlement of funds of Alexander Borisovich
Grigoriev in the amount of RUB 8,494,970, i.e. on a particularly large scale, by means of deceit and breach of
trust, which consisted in creating a false appearance of the possibility of receiving a high income in the latter,
as a client of the QBF group organisation, as a result of which the client entered into a service agreement for
44
- in the period from 21.09.2017 to 27.10.2017 committed thef of Nikitchenko Nikolay Valeryevich's money in
in creating a false appearance of the possibility of obtaining a high income in the latter, as a client of the
- 21.11.2017 committed embezzlement of Sergey Dmitrievich Zinoviev's money in the amount of 1,778,100
rubles, i.e. on a particularly large scale, by deception and breach of trust, consisting in creating in the latter,
as a client of the QBF group organisation, a false appearance of the possibility of receiving a high income, as a
- in the period from 13.12.2016 to 12.12.2017 committed embezzlement of Sergey Nikolayevich Lomov's funds
- in the period from 17.08.2017 to 14.12.2017 committed thef of Vladimir Vladimirovich Nemtsev's money in
receiving a high income, as a result of which the client entered into a service agreement for the provision of a
45
- in the period from 07.12.2017 to 14.12.2017 committed thef of funds of Andrey Gennadyevich Novitsky in the
- in the period from 22.09.2017 to 26.01.2018 committed embezzlement of funds of Ludmila Alexandrovna
Vavilova in the amount of 1,835,560 rubles, i.e. on a particularly large scale, by means of deceit and breach of
the possibility of obtaining a high income, as a result of which the client concluded a service agreement for
- 15.02.2018 committed thef of funds of Nadezhda Sergeyevna Vetrova in the amount of 712,300 rubles, i.e. on
a large scale, by deceit and breach of trust, consisting in creating in the latter, as a client of the QBF group
organisation, a false appearance of the possibility of obtaining a high income, as a result of which the client
concluded a service agreement for the provision of a trading account with the amount of funds on it equal to
the amount of funds received from the client (brokerage service agreements), and also provided the co -
conspirators with their own funds. These agreements were concluded for direct access to trading on stock
and derivatives markets, but the participants in the criminal association knew that their obligations to the
client to pay the funds were unfulfilled, since the information about the brokerage activities of the
- 13.03.2018 committed embezzlement of funds of Oksana Borisovna Bozhko in the amount of RUB 1,551,000,
i.e. on a particularly large scale, by means of deceit and breach of trust, which consisted in creating a false
QBF group ("QBF"), as a result of which the client concluded a service agreement for the provision of a
- in the period from 28.12.2017 to 22.03.2018 committed thef of funds of Maryana Rashitovna Batalova in the
46
- in the period from 20.03.2018 to 24.03.2018 committed embezzlement of funds of Alexander Anatolievich
Romanovsky in the amount of 2,464,530 rubles, i.e. on a particularly large scale, by means of deceit and
breach of trust, which consisted in creating in the latter, as a client of the QBF group organisation, a false
appearance of the possibility of obtaining a high income, as a result of which the client concluded a service
agreement for the provision of a trading account with the amount of funds on it equal to the amount of funds
received from the client (brokerage service agreements), and also provided the client with a trading account.
These agreements were concluded for direct access to trading on stock and derivatives markets, but the
unfulfilled, as the information about the brokerage activities of the organisation with which he concluded the
agreement for direct access to international stock markets was false. The co - defendants did not use the
money received from the client under this agreement for the purposes specified in the agreements, but stole
it and used it at their own discretion;
- 19.04.2018 committed embezzlement of Dmitry Vladimirovich Erofeev's funds in the amount of 2,500,000
as a client of the QBF group organisation, a false appearance of the possibility of receiving a high income, as a
- in the period from 06.05.2016 to 23.04.2018 committed embezzlement of funds of Maxim Ilyich Borzenkov in
the amount of 1,007,926,000 rubles, i.e. on a particularly large scale, by deceit and breach of trust, consisting
in creating in the latter, as a client of the organisation of the group "QBF" ("QBF"), a false appearance of the
- in the period from 27.11.2017 to 24.04.2018 committed embezzlement of funds of Svetlana Alexandrovna
Baiguzina in the amount of 4,844,400 rubles, i.e. on a particularly large scale, by deception and breach of
trust, consisting in creating in the latter, as a client of the organisation of the group "QBF" ("QBF"), a false
47
- 22.05.2018 committed embezzlement of funds of Galina Vyacheslavovna Levina in the amount of 1,250,600
rubles, i.e. on a particularly large scale, through deceit and breach of trust, which consisted in creating a false
QBF group, as a result of which the client concluded a service agreement for the provision of a trading
- 20.06.2018 committed embezzlement of money of Naumova Evgeniya Gennadyevna in the amount of
1,900,000 rubles, i.e. on a particularly large scale, by deceit and breach of trust, consisting in creating in the
latter, as a client of the organisation of the group "QBF" ("QBF"), a false appearance of the possibility of
- in the period from 07.06.2017 to 26.06.2018 committed embezzlement of funds of Andrey Vitalievich Danilov
in the amount of 4,985,000 rubles, i.e. on a particularly large scale, by means of deceit and breach of trust,
consisting in creating a false appearance of the possibility of receiving a high income in the latter, as a client
of the group organisation "QBF" ("QBF"), as a result of which the client entered into a service agreement for
- in the period from 31.01.2018 to 29.06.2018 committed thef of funds of Tatiana Olegovna Krechetova in the
creating in the latter, as a client of the group organisation "QBF" ("QBF"), a false appearance of the possibility
of obtaining a high income, as a result of which the client concluded a service agreement for the provision of
a trading account with the amount of funds on it in the amount of the funds received from the client
(brokerage services agreements), and also provided the co - conspirators with a brokerage account. These
48
unfulfilled, as the information about the brokerage activities of the organisation with which they had
- during the period from 28.12.2017 to 04.07.2018 committed thef of funds of Elena Nikolaevna Ostovich in the
(brokerage service agreements), and also provided the co - conspirators with a trading account. These
unfulfilled, as the information about the brokerage activities of the organisation with which they had
- in the period from 30.10.2017 to 25.07.2018 committed thef of funds of Vladimir Mikhailovich Drobin in the
(brokerage service agreements), and also provided the co - participants of the agreement with the client.
unfulfilled, since the information about the brokerage activities of the organisation with which he concluded
the agreement for direct access to international stock markets was false. The co - defendants did not use the
- in the period from 24.05.2016 to 31.07.2018 committed thef of funds of Kilo Valery Anatolievich in the
a trading account with the amount of funds on it in the amount of the amount of funds received from the
client (brokerage service agreements), and also provided a co - conspirator. These agreements were
about the brokerage activities of the organisation with which he had concluded the agreement to provide
- in the period from 03.04.2017 to 02.08.2018 committed embezzlement of funds of Vilen Eduardovich
Emirgamzaev in the amount of 7,501,091 rubles, i.e. on a particularly large scale, by means of deceit and
breach of trust, which consisted in creating in the latter, as a client of the organisation of the group "QBF"
("QBF"), a false appearance of the possibility of obtaining a high income, as a result of which the client
entered into a service agreement for the provision of a trading account with the amount of funds in it equal
to the amount of funds received from the client (brokerage service agreements), and provided the co -
49
about the brokerage activities of the organisation with which he had concluded the agreement for direct
discretion;
- in the period from 29.08.2017 to 17.08.2018 committed embezzlement of funds of Oleg Anatolievich
Kosorukov in the amount of 1,820,000 rubles, i.e. on a particularly large scale, by deceit and breach of trust,
consisting in creating in the latter, as a client of the group organisation "QBF" ("QBF"), a false appearance of
the possibility of obtaining a high income, as a result of which the client entered into a service agreement for
with which he had concluded the agreement for direct access to international stock markets was false. The co
- 21.08.2018 committed thef of funds of Lyutov Alexander Vladimirovich in the amount of 671,800 rubles, i.e.
on a large scale, by deception and breach of trust, consisting in creating in the latter, as a client of the QBF
group organisation, a false appearance of the possibility of obtaining a high income, as a result of which the
equal to the amount of funds received from the client (brokerage service agreements), and also provided a co
- conspirator. These agreements were concluded for direct access to trading on stock and derivatives
- 12.09.2018 committed thef of Oleg Mikhailovich Bokov's money in the amount of 1,500,000 roubles, i.e. on a
particularly large scale, by deception and breach of trust, which consisted in creating a false appearance of a
high income opportunity for the latter, as a client of the QBF group organisation, as a result of which the
equal to the amount of funds received from the client (brokerage service agreements), and also provided the
co - conspirators with the money. These agreements were concluded for direct access to trading on stock and
with which he concluded the agreement for direct access to international stock markets was false. The co -
- in the period from 20.06.2017 to 03.10.2018 committed embezzlement of funds of Kostovskaya Ekaterina
Nikolaevna in the amount of 2,745,920 rubles, i.e. on a particularly large scale, by means of deceit and breach
of trust, which consisted in creating in the latter, as a client of the QBF group organisation, a false appearance
of the possibility of obtaining a high income, as a result of which the client concluded a service agreement for
the provision of a trading account with the amount of funds on it equal to the amount of funds received from
the client (brokerage service agreements), and also provided a co - brokerage service. These agreements
were concluded for direct access to trading on stock and derivatives markets, but the participants in the
criminal association knew that their obligations to the client to pay the funds were unfulfilled, since the
information about the brokerage activities of the organisation with which it had concluded the agreement for
50
- in the period from 14.06.2017 to 10.10.2018 committed embezzlement of funds of Viktor Viktorovich Morozov
in the amount of RUB 1,980,000, i.e. on a particularly large scale, by means of deceit and breach of trust,
of the organisation of the QBF group ("QBF"), as a result of which the client entered into a service agreement
for the provision of a trading account with the amount of funds in it equal to the amount of funds received
from the client (brokerage service agreements), and provided the co - conspirators with his funds in the
specified amount for trust management. These agreements were concluded for direct access to trading on
stock and derivatives markets, but the participants in the criminal association knew that their obligations to
the client to pay the funds were unfulfilled, since the information about the brokerage activities of the
organisation with which he had concluded the agreement for direct access to international stock markets
was false. The co - defendants did not use the money received from the client under this agreement for the
- 22.10.2018 committed embezzlement of funds of Voropaev Alexey Vladimirovich in the amount of 1,950,000
as a client of the QBF group organisation, a false appearance of the possibility of obtaining a high income, as
a result of which the client entered into a service agreement for the provision of a trading account with the
- in the period from 21.02.2018 to 28.10.2018 committed thef of Semyon Mikhailovich Kishilov's money in the
obtaining a high income, as a result of which the client entered into a service agreement for the provision of a
- in the period from 01.06.2018 to 30.10.2018 committed thef of Bogomolov Igor Leonidovich's money in the
amount of 5 094 671,8 rubles, i.e. on a particularly large scale, by deception and breach of trust, consisting in
creating a false appearance of the possibility of receiving a high income in the latter, as a client of the
- 30.10.2018 committed thef of funds of Boris Georgievich Kosovsky in the amount of 1,579,440 roubles, i.e. on
a particularly large scale, by deception and breach of trust, which consisted in creating a false appearance of
51
a high income opportunity for the latter, as a client of the QBF group organisation, as a result of which the
equal to the amount of funds received from the client (brokerage service agreements), and also provided the
co - participants of the agreement with the client. These agreements were concluded for direct access to
activities of the organisation with which he concluded the agreement for direct access to international stock
- 06.11.2018 committed thef of Semenov Igor Leonidovich's money in the amount of 2,000,000 rubles, i.e. on a
particularly large scale, by deceit and breach of trust, consisting in creating in the latter, as a client of the QBF
group organisation (QBF), a false appearance of the possibility of obtaining a high income, as a result of
which the client concluded a service agreement for the provision of a trading account with the amount of
funds on it equal to the amount of funds received from the client (brokerage service agreements), and the co
- conspirators also provided the client with a trading account. These agreements were concluded for direct
access to trading on stock and derivatives markets, but the participants in the criminal association knew that
their obligations to the client to pay the funds were unfulfilled, since the information about the brokerage
activities of the organisation with which he had concluded the agreement to provide direct access to
international stock markets was false. The co - defendants did not use the money received from the client
discretion;
- in the period from 06.11.2018 to 07.11.2018 committed embezzlement of funds of Ludmila Leonidovna
Semenova in the amount of 2 029 950 rubles, i.e. on a particularly large scale, by deceit and breach of trust,
- 13.12.2018 committed thef of funds of Mikhail Alexandrovich Bolshov in the amount of RUB 1,660,500, i.e. on
a particularly large scale, by deception and breach of trust, which consisted in creating a false appearance of
a high income opportunity for the latter, as a client of the QBF group organisation, whereby the client
concluded a service agreement for the provision of a trading account with the amount of funds on it equal to
the amount of funds received from the client (brokerage service agreements), and also provided the client
with a coachee. These agreements were concluded for direct access to trading on stock and derivatives
in the agreements, but stole it and used it at their own discretion;28.12.2018 committed thef of money of
Evgeny Gennadyevich Dianov in the amount of RUB 68,000,000, i.e. on a particularly large scale, by means of
deceit and breach of trust, consisting in creating a false appearance of a high income opportunity for the
latter, as a client of the QBF group organisation, as a result of which the client concluded a service agreement
for the provision of a trading account with the amount of funds on it equal to the amount of funds received
from the client (brokerage service agreements), and also provided the co - participants of the agreement with
the client. These agreements were concluded for direct access to trading on stock and derivatives markets,
52
but the participants in the criminal association knew that their obligations to the client to pay the funds were
- in the period from 09.10.2018 to 05.02.2019 committed embezzlement of funds of Alexey Vyacheslavovich
Gubanov in the amount of 15,000,000 rubles, i.e. on a particularly large scale, by deceit and breach of trust,
consisting in creating a false appearance of the possibility of obtaining a high income in the latter, as a client
of the organisation of the group "QBF" ("QBF"), as a result of which the client entered into a service
- 19.02.2019 committed embezzlement of funds of Nikolay Vladimirovich Vorobyev - Desyatovsky in the
amount of 4,500,000 rubles, i.e. on a particularly large scale, by means of deceit and breach of trust,
of the QBF group organisation, as a result of which the client entered into a service agreement for the
- 25.02.2019 committed embezzlement of funds of Kim Gagikovich Galachyan in the amount of 1,310,200
rubles, i.e. on a particularly large scale, by means of deceit and breach of trust, which consisted in creating in
the latter, as a client of the QBF group organisation, a false appearance of the possibility of obtaining a high
income, as a result of which the client entered into a service agreement for the provision of a trading account
with the amount of funds in it equal to the amount of funds received from the client (brokerage service
agreements), and provided the co - conspirators with his funds in the specified amount for trust
- 15.03.2019 committed thef of funds of Ekaterina Fedorovna Chekmareva in the amount of 3,741,382.27
rubles, i.e. on a particularly large scale, by deception and breach of trust, consisting in creating a false
group "QBF" ("QBF"), as a result of which the client concluded a service agreement for the provision of a
53
- in the period from 29.03.2018 to 05.06.committed thef of funds of Birnov Mark Abramovich in the amount of
5,825,800 rubles, i.e. on a particularly large scale, by deception and breach of trust, consisting in creating in
the latter, as a client of the group organisation "QBF" ("QBF"), a false appearance of the possibility of
trading account with the amount of funds on it in the amount of the funds received from the client
(brokerage service agreements), and also provided the co - conspirators with a trading account. These
- 26.07.2019 committed thef of funds of Anatoly Vladimirovich Potapov in the amount of 1,898,353 rubles, i.e.
on a particularly large scale, by deception and breach of trust, consisting in creating in the latter, as a client of
which the client entered into a service agreement for the provision of a trading account with the amount of
- in the period from 28.06.2018 to 31.07.2019 committed thef of funds of Bosak Larisa Vasilievna in the
- in the period from 02.03.2017 to 01.08.2019 committed embezzlement of funds of Sergey Viktorovich
Paramonov in the amount of 3,371,206 rubles, i.e. on a particularly large scale, by means of deceit and breach
of trust, consisting in creating a false appearance of the possibility of receiving a high income in the latter, as
a client of the organisation of the group "QBF" ("QBF"), as a result of which the client entered into a service
54
- during the period from 20.08.2019 to 27.08.2019 committed thef of funds of Svetlana Vladimirovna Grif in the
possibility of obtaining a high income, as a result of which the client concluded a service agreement on the
provision of a trading account with the amount of funds on it, in the amount of the amount of funds received
from the client (agreements on the provision of brokerage services), and also provided a co - conspirator.
- during the period from 03.09.2012 to 02.10.2019 committed embezzlement of Andreev Roman
Vladimirovich's money in the amount of 1,971,020 rubles, i.e. on a particularly large scale, by means of deceit
and breach of trust, consisting in creating a false appearance of the possibility of receiving a high income in
the latter, as a client of the QBF group organisation, as a result of which the client entered into a service
- in the period from 23.01.2018 to 28.10.committed embezzlement of funds of Kirill Alekseevich Ivanov in the
amount of RUB 6,328,000, i.e. on a particularly large scale, by deception and breach of trust, consisting in
creating in the latter, as a client of the organisation of the QBF group, a false appearance of the possibility of
obtaining a high income, as a result of which the client entered into a service agreement for the provision of a
- in the period from 30.01.2019 to 15.11.2019 committed embezzlement of funds of Pavel Evgenievich Petrov in
the amount of 3,923,550 rubles, i.e. on a particularly large scale, by means of deceit and breach of trust,
which consisted in creating in the latter, as a client of the QBF group organisation, a false appearance of the
provision of a trading account with the amount of funds on it equal to the amount of funds received from the
55
- in the period from 14.08.2017 to 28.11.committed embezzlement of funds of Tatyana Vyacheslavovna
Baskova in the amount of 4,565,438 rubles, i.e. on a particularly large scale, by means of deceit and breach of
trust, consisting in creating a false appearance of the possibility of receiving a high income in the latter, as a
client of the organisation of the group "QBF" ("QBF"), as a result of which the client concluded a service
- in the period from 16.11.2018 to 30.11.committed embezzlement of funds of Mishin Ilya Yurievich in the
amount of 1,579,783.06 rubles, i.e. on a particularly large scale, by means of deceit and breach of trust, which
consisted in creating in the latter, as a client of the organisation of the group "QBF" ("QBF"), a false
- 19.12.2019 committed embezzlement of funds of Andrey Vladimirovich Nazarenkov in the amount of
3,438,138 rubles, i.e. on a particularly large scale, by means of deceit and breach of trust, which consisted in
organisation of the QBF group ("QBF"), as a result of which the client entered into a service agreement for the
- 25.12.2019 committed embezzlement of funds of Vadim Nikolayevich Burmistrov in the amount of 2,550,000
rubles, i.e. on a particularly large scale, by means of deceit and breach of trust, consisting in creating a false
appearance of the possibility of receiving a high income in the latter, as a client of the QBF group
- in the period from 31.10.2017 to 31.12.2019 committed embezzlement of funds of Mishin Yuri Alekseevich in
the amount of 5,533,493.45 rubles, i.e. on a particularly large scale, by deceit and breach of trust, consisting
56
- 03.02.2020 committed embezzlement of funds of Vadim Gennadyevich Mazitov in the amount of 4,104,100
rubles, i.e. on a particularly large scale, by means of deceit and breach of trust, consisting in creating a false
appearance of the possibility of receiving a high income in the latter, as a client of the QBF group
- in the period from 28.11.2019 to 06.02.2020 committed embezzlement of Dmitry Yurievich Toloknov's funds
consisting in creating in the latter, as a client of the group organisation "QBF" ("QBF"), a false appearance of
the possibility of obtaining a high income, as a result of which the client entered into a service agreement for
with which he had concluded the agreement for direct access to international stock markets was false. The co
- during the period from 31.05.2019 to 10.02.2020 committed thef of funds of Kim Alexei Leonidovich in the
a trading account with the amount of funds on it, in the amount of the amount of funds received from the
- 18.02.2020 committed embezzlement of funds of Maria Semenovna Troshkova in the amount of 686,200
rubles, i.e. on a large scale, by deceit and breach of trust, consisting in creating in the latter, as a client of the
QBF group organisation, a false appearance of the possibility of receiving a high income, as a result of which
the client concluded a service agreement for the provision of a trading account with the amount of funds on
57
it equal to the amount of funds received from the client (brokerage service agreements), and also provided
the co - conspirators with their own funds (brokerage service agreements). These agreements were
discretion;
- 28.02.2020 committed embezzlement of funds of Elena Petrovna Ganeva in the amount of 1,919,828 rubles,
i.e. on a particularly large scale, by deceit and breach of trust, consisting in creating in the latter, as a client of
which the client concluded a service agreement for the provision of a trading account with the amount of
- 21.04.2020 committed embezzlement of funds of Irina Andreyevna Podgornaya in the amount of 7 022 350
rubles, i.e. on a particularly large scale, by means of deceit and breach of trust, which consisted in creating a
false appearance of the possibility of obtaining a high income for the latter, as a client of the organisation of
the QBF group, as a result of which the client concluded a service agreement for the provision of a trading
- during the period from 28.05.2019 to 23.04.2020 committed thef of funds of Kovin Anatoly Petrovich in the
a trading account with the amount of funds on it in the amount of the funds received from the client
(brokerage service agreements), and also provided the co - conspirators with a brokerage account. These
unfulfilled, as the information about the brokerage activities of the organisation with which he had
concluded the agreement to provide direct access to international stock markets was false. The co -
- 01.06.2020 committed embezzlement of Dmitry Evgenyevich Zatsarinsky's money in the amount of 1,400,000
rubles, i.e. on a particularly large scale, by means of deceit and breach of trust, which consisted in creating a
false appearance of the possibility of obtaining a high income in the latter, as a client of the QBF group
organisation, as a result of which the client concluded an option agreement, by which he instructed the
employees of this organisation to conclude transactions with derivative financial instruments, including
options, on the OTC market at the expense of the money provided to them. At the same time, the participants
58
of the criminal association knowingly did not intend to fulfil the obligations assumed under this agreement.
The co - conspirators did not use the money received from the client under this agreement for the purposes
specified in the agreement, but stole it and used it at their own discretion;
- during the period from 25.12.2017 to 25.06.2020 committed embezzlement of funds of Mudrogin Alexey
Vladimirovich in the amount of 943,000 rubles, i.e. on a large scale, by deceit and breach of trust, consisting
possibility of obtaining a high income, as a result of which the client concluded an option agreement, by
which he instructed the employees of this organisation to conclude transactions with derivative financial
instruments, including options, basis, on the OTC market at the expense of the funds provided to them. At the
same time, the participants of the criminal association knowingly did not intend to fulfil the obligations
assumed under this agreement. The co - conspirators did not use the money received from the client under
this agreement for the purposes specified in the agreement, but stole it and used it at their own discretion;
- during the period from 02.06.2020 to 29.06.committed embezzlement of funds of Alexander Valeryevich
Rucheev in the amount of 195,000,000 rubles, i.e. on a particularly large scale, by means of deceit and breach
of the possibility of obtaining a high income, as a result of which the client concluded an option agreement
by which he instructed the employees of this organisation to conclude transactions with derivative financial
instruments, including options, on the OTC market at the expense of the funds provided to them. At the same
time, the participants of the criminal association knowingly did not intend to fulfil the obligations assumed
under this agreement. The co - conspirators did not use the money received from the client under this
agreement for the purposes specified in the agreement, but stole it and used it at their own discretion;
- 08.07.2020 committed thef of Igor Vladimirovich Donskov's money in the amount of 1,443,400 rubles, i.e. on
a particularly large scale, by deceit and breach of trust, consisting in creating in the latter, as a client of the
the client concluded an option agreement by which he instructed the employees of the organisation to
conclude transactions with derivative financial instruments, including options, on the OTC market at the
expense of the money provided by him. At the same time, the participants of the criminal association did not
knowingly intend to fulfil the obligations assumed under this agreement. The co - conspirators did not use
the money received from the client under this agreement for the purposes specified in the agreement, but
stole it and used it at their own discretion;
- during the period from 17.06.2020 to 08.07.2020 committed embezzlement of funds of Mikhail Nikolayevich
Nosenko in the amount of 6,200,000 rubles, i.e. on a particularly large scale, by means of deceit and breach of
trust, which consisted in creating in the latter, as a client of the organisation of the group "QBF" ("QBF"), a
false appearance of the possibility of obtaining a high income, as a result of which the client concluded an
option agreement, by which he instructed the employees of this organisation to conclude transactions with
derivative financial instruments, including options, on the OTC market at the expense of the funds provided
to them. At the same time, the participants of the criminal association knowingly did not intend to fulfil the
obligations assumed under this agreement. The co - conspirators did not use the money received from the
client under this agreement for the purposes specified in the agreement, but stole it and used it at their own
discretion;
- 06.08.2020 committed embezzlement of funds of Nikolay Gitalievich Mitroshin in the amount of 4,000,000
roubles, i.e. on a particularly large scale, by deceit and breach of trust, consisting in creating a false
of which the client concluded an option agreement, by which he instructed the employees of the
organisation to conclude transactions with derivative financial instruments, including options, on the OTC
market at the expense of the funds provided to them. At the same time, the participants of the criminal
organisation did not knowingly intend to fulfil the obligations assumed under the contract. The co -
conspirators did not use the money received from the client under this agreement for the purposes specified
in the agreement, but stole it and used it at their own discretion;
59
- during the period from 04.08.2020 to 21.10.2020 committed embezzlement of funds of Batuev Anton
Alexandrovich in the amount of 5,250,000 rubles, i.e. on a particularly large scale, by deceit and breach of
trust, which consisted in creating a false appearance of the possibility of obtaining a high income in the latter,
as a client of the organisation of the group "QBF" ("QBF"), as a result of which the client concluded an option
agreement, by which he instructed the employees of this organisation to conclude transactions with
to them, At the same time, the participants of the criminal association knowingly did not intend to fulfil the
discretion;
- during the period from 22.10.2020 to 24.10.2020 committed embezzlement of funds of Nikolay Valeryevich
Drapesa in the amount of 4,000,000 rubles, i.e. on a particularly large scale, by means of deceit and breach of
option agreement by which he instructed the employees of this organisation to conclude transactions with
discretion;
- during the period from 10.09.2020 to 19.11.committed thef of funds of Sergey Valeryevich Kormilitsyn in the
which he instructed employees of this organisation to conclude transactions with derivative financial
instruments, including options, on the OTC market at the expense of the funds provided to them, At the same
- On 23.11.2020 they committed thef of Anna Vladimirovna Podolna's money in the amount of 6,000,000
roubles, i.e. on a particularly large scale, by deception and breach of trust, which consisted in creating a false
of which the client entered into an option agreement by which he instructed employees of the organisation
to enter into transactions with derivative financial instruments, including options, on the OTC market at the
expense of the money provided to them, At the same time, the participants of the criminal association
knowingly did not intend to fulfil the obligations assumed under this agreement. The co - conspirators did
agreement, but stole it and used it at their own discretion;
- in the period from 30.07.2020 to 03.12.2020 committed embezzlement of Victoria Samiullovna Koncherova's
money in the amount of 2,320,000 rubles, i.e. on a particularly large scale, by deceit and breach of trust,
possibility of obtaining a high income, as a result of which the client concluded an option agreement by
which he instructed the employees of the organisation to conclude transactions with derivative financial
instruments, including options, on the OTC market at the expense of the money provided to them, At the
- during the period from 11.09.2020 to 03.12.committed embezzlement of funds of Vasily Sergeyevich
Koreshkov in the amount of 2,050,000 rubles, i.e. on a particularly large scale, by deceit and breach of trust,
60
which he instructed employees of the organisation to conclude transactions with derivative financial
instruments, including options, on the OTC market at the expense of the funds provided by him. At the same
time, the participants of the criminal association did not knowingly intend to fulfil the obligations assumed
- during the period from 24.09.2020 to 08.12.2020 committed thef of funds of Mikhail Alekseevich Borisov in
the amount of 2,505,000 rubles, i.e. on a particularly large scale, by deceit and breach of trust, consisting in
instruments, including options, on the OTC market at the expense of the funds provided by them. At the
same time, the participants of the criminal association did not knowingly intend to fulfil the obligations
- 08.12.2020 committed embezzlement of funds of Aleksandra Alekseevna Tokareva in the amount of 6,000,000
roubles, i.e. on a particularly large scale, by means of deceit and breach of trust, which consisted in creating
in the latter, as a client of the QBF group organisation, a false appearance of the possibility of obtaining a
high income, as a result of which the client concluded an option agreement by which he instructed the
employees of this organisation to conclude transactions with derivative financial instruments, including
options, on the OTC market at the expense of the funds provided to them. At the same time, the participants
of the criminal organisation did not knowingly intend to fulfil the obligations assumed under the contract.
The co - conspirators did not use the money received from the client under this agreement for the purposes
specified in the agreement, but stole it and used it at their own discretion;
- in the period from 21.12.2018 to 09.12.2020 committed embezzlement of funds of Dmitry Igorevich Malinin in
the amount of 6,660,000 rubles, i.e. on a particularly large scale, by means of deceit and breach of trust,
which consisted in creating in the latter, as a client of the organisation of the group "QBF" ("QBF"), a false
appearance of the possibility of obtaining a high income, as a result of which the client concluded an option
agreement, by which he instructed employees of this organisation to conclude transactions with derivative
financial instruments, including options, on the OTC market at the expense of the funds provided to them. At
the same time, the participants of the criminal association knowingly did not intend to fulfil the obligations
- On 9.12.2020 they committed embezzlement of funds of Alina Vladimirovna Kulikova in the amount of
2,000,000 roubles, i.e. on a particularly large scale, by means of deceit and breach of trust, which consisted in
organisation of the QBF group, as a result of which the client concluded an option agreement, by which he
instructed the employees of this organisation to conclude transactions with derivative financial instruments,
including options, on the OTC market at the expense of the funds provided to them. At the same time, the
participants of the criminal association knowingly did not intend to fulfil the obligations assumed under this
agreement. The co - conspirators did not use the money received from the client under this agreement for
the purposes specified in the agreement, but stole it and used it at their own discretion;
- 11.12.2020 committed thef of funds of Kirill Nikolayevich Kuzmenko in the amount of 1,200,000 rubles, i.e.
on a particularly large scale, by deceit and breach of trust, consisting in creating a false appearance of a high
income opportunity for the latter, as a client of the QBF group organisation, as a result of which the client
concluded an option agreement, by which he instructed the employees of this organisation to conclude
transactions with derivative financial instruments, including options, on the OTC market at the expense of
the funds provided to them. At the same time, the participants of the criminal organisation did not knowingly
intend to fulfil the obligations assumed under this agreement. The co - conspirators did not use the money
61
received from the client under this agreement for the purposes specified in the agreement, but stole it and
used it at their own discretion;
- during the period from 25.12.2020 to 26.12.2020 committed embezzlement of funds of Andrey
Vyacheslavovich Shilov in the amount of 2,000,000 rubles, i.e. on a particularly large scale, by means of deceit
and breach of trust, which consisted in creating in the latter, as a client of the organisation of the QBF group,
a false appearance of the possibility of obtaining a high income, as a result of which the client concluded an
discretion;
- during the period from 29.06.2020 to 28.12.2020 committed thef of funds of Voropayev Alexander
Andreyevich in the amount of 3,200,000 rubles, i.e. on a particularly large scale, by deceit and breach of trust,
discretion;
- during the period from 29.09.2020 to 28.12.committed thef of funds of Roman Vladimirovich Gorbunov in the
amount of RUB 8,500,000, i.e. on a particularly large scale, by means of deceit and breach of trust, which
consisted in creating a false appearance of the possibility of receiving a high income in the latter, as a client of
the organisation of the QBF group, as a result of which the client concluded an option agreement by which he
including options, on the OTC market at the expense of the funds provided to them, At the same time, the
- in the period from 14.12.2020 to 13.01.2021 committed thef of funds of Alexander Konstantinovich Shlykov
obtaining a high income, as a result of which the client concluded an option agreement, by which he
instructed the employees of this organisation to conclude transactions with derivative financial instruments
on the OTC market at the expense of the funds provided to them. At the same time, the participants of the
criminal association knowingly did not intend to fulfil the obligations assumed under the contract. The co -
conspirators did not use the money received from the client under the agreement for the purposes specified
- during the period from 21.10.2020 to 25.01.2021 committed thef of Leonid Alekseevich Kuryatnikov's money
in the amount of 25,810,000 rubles, i.e. on a particularly large scale, by deceit and breach of trust, consisting
obtaining a high income, as a result of which the client concluded an option agreement by which he
instructed the employees of the organisation to conclude transactions with derivative financial instruments,
including options, on the OTC market at the expense of the money provided to them. At the same time, the
62
- during the period from 21.10.2020 to 26.01.2021 committed embezzlement of funds of Tatyana Vladimirovna
Demidkova in the amount of 6,150,000 rubles, i.e. on a particularly large scale, by deceit and breach of trust,
- during the period from 20.01.2021 to 28.01.2021 committed embezzlement of funds of Irina Sergeevna
Grushanina in the amount of 423,000 rubles, i.e. on a large scale, by deceit and breach of trust, consisting in
instruments on the over - the - counter market using the money provided to them, including options with
foreign issuers' equity securities as the underlying asset (over - the - counter option contracts), and also
provided his co - conspirators with his own money in the specified amount for trust management. At the
assumed under this agreement. The co - conspirators did not use the funds received from the client under
this agreement for the purposes specified in the agreement, but stole them and used them at their own
discretion;
- in the period from 28.01.2021 to 01.02.2021 committed embezzlement of funds of Maria Igorevna Drapesa in
the amount of 4,000,000 roubles, i.e. on a particularly large scale, by means of deceit and breach of trust,
instruments, including options, the underlying financial instruments, on the OTC market at the expense of
the funds provided to them. At the same time, the participants of the criminal association knowingly did not
- 01.02.2021 committed thef of funds of Kirill Andreyevich Pilenitsyn in the amount of 1,500,000 roubles, i.e.
on a particularly large scale, by deceit and breach of trust, consisting in creating in the latter, as a client of the
the client concluded an option agreement by which he instructed the employees of this organisation to
conclude transactions with derivative financial instruments, including options, on the OTC market at the
expense of the funds provided to them, At the same time, the participants of the criminal association
knowingly did not intend to fulfil the obligations assumed under this agreement. The co - conspirators did
agreement, but stole it and used it at their own discretion;
- in the period from 28.10.2020 to 05.02.2021 committed thef of funds of Evgeny Alexandrovich Kamzolov in
in creating in the latter, as a client of the group organisation "QBF" ("QBF"), a false appearance of the
instruments on the OTC market at the expense of the funds provided to them. At the same time, the
participants of the criminal association knowingly did not intend to fulfil the obligations assumed under the
contract. The co - conspirators did not use the money received from the client under this agreement for the
purposes specified in the agreement, but stole it and used it at their own discretion;
63
- during the period from 28.01.2021 to 05.02.2021 committed embezzlement of funds of Pavel Mikhailovich
Elkin in the amount of 4,000,000 rubles, i.e. on a particularly large scale, by means of deceit and breach of
to them. At the same time, the participants of the criminal association did not knowingly intend to fulfil the
obligations assumed under the agreement. The co - conspirators did not use the money received from the
client under the agreement for the purposes specified in the agreement, but stole it and used it at their own
discretion;
- during the period from 30.11.2020 to 08.02.2021 committed embezzlement of funds of Ilya Vladimirovich
Bondarenko in the amount of 3,400,000 rubles, i.e. on a particularly large scale, by means of deceit and
breach of trust, consisting in creating a false appearance of the possibility of receiving a high income in the
latter, as a client of the organisation of the group "QBF" ("QBF"), as a result of which the client concluded an
to them, At the same time, the participants of the criminal association knowingly did not intend to fulfil the
discretion;
- during the period from 24.12.2020 to 08.02.2021 committed embezzlement of Alexei Petrovich Vasyunin's
instruments, including options, on the OTC market at the expense of the money provided to them. At the
- during the period from 12.01.2021 to 08.02.2021 committed embezzlement of Sergey Alekseevich Grekov's
money in the amount of 1,300,000 rubles, i.e. on a particularly large scale, by means of deceit and breach of
trust, which consisted in creating in the latter, as a client of the organisation of the QBF group, a false
appearance of the possibility of receiving a high income, as a result of which the client concluded an option
agreement by which he instructed the employees of this organisation to conclude transactions with
derivative financial instruments, including options, on the OTC market at the expense of the money provided
discretion;
- during the period from 17.11.2020 to 09.02.2021 committed embezzlement of funds of Vyacheslav
Vladimirovich Borodin in the amount of 800,000 rubles, i.e. on a large scale, by deceit and breach of trust,
which consisted in creating in the latter, as a client of the organisation of the group "QBF" ("QBF"), a false
to them. At the same time, the participants of the criminal association did not knowingly intend to fulfil the
obligations assumed under the agreement. The co - conspirators did not use the money received from the
client under the agreement for the purposes specified in the agreement, but stole it and used it at their own
discretion;
64
- during the period from 08.02.2021 to 09.02.2021 committed thef of funds of Zhanna Borisovna Chernova in
the amount of 501,000 rubles, i.e. on a large scale, by deceit and breach of trust, consisting in creating in the
latter, as a client of the organisation of the group "QBF" ("QBF"), a false appearance of the possibility of
including options, the underlying asset, on the OTC market at the expense of the funds provided to them. At
- during the period from 18.09.2020 to 10.02.2021 committed embezzlement of funds of Andrey Sergeyevich
Ivanov in the amount of 3,000,000 roubles, i.e. on a particularly large scale, by means of deceit and breach of
the possibility of obtaining a high income, as a result of which the client concluded an option agreement by
under the agreement. The co - conspirators did not use the money received from the client under the
- during the period from 09.02.2021 to 10.02.2021 committed embezzlement of funds of Denis Sergeyevich
Silin in the amount of 1,000,000 rubles, i.e. on a large scale, by deceit and breach of trust, which consisted in
including options, the underlying shares, on the OTC market at the expense of the funds provided to them. At
- during the period from 07.12.2020 to 11.02.2021 committed embezzlement of funds of Kirill Ivanovich
Sbitnev in the amount of 1,845,000 rubles, i.e. on a particularly large scale, by means of deceit and breach of
trust, which consisted in creating in the latter, as a client of the organisation of the QBF group, a false
discretion;
- during the period from 10.07.2020 to 12.02.2021 committed embezzlement of funds of Sergey Valentinovich
Kushkov in the amount of 12,000,000 rubles, i.e. on a particularly large scale, by deceit and breach of trust,
agreement, by which he instructed employees of this organisation to conclude transactions with derivative
financial instruments, including options, on the OTC market at the expense of the funds provided to them. b
The participants of the criminal association knowingly did not intend to fulfil the obligations undertaken
under this agreement. At the same time, the participants of the criminal association did not knowingly intend
to fulfil the obligations assumed under this agreement. The co - conspirators did not use the money received
from the client under this agreement for the purposes specified in the agreement, but stole it and used it at
- during the period from 03.11.2020 to 12.02.2021 committed embezzlement of funds of Pavlenko Igor
Valeryevich in the amount of 2,942,870 rubles, i.e. on a particularly large scale, by means of deceit and
65
breach of trust, which consisted in creating a false appearance of a high income opportunity for the latter, as
a client of QBF group organisation, as a result of which the client concluded an option agreement, by which
he instructed employees of the organisation to enter into transactions with derivative financial instruments
on the over - the - counter market using the money provided to them, including options with foreign issuers'
equity securities as the underlying asset (over - the - counter option contracts), and also provided his co -
conspirators with his own money in the specified amount for trust management. At the same time, the
agreement. The co - conspirators did not use the funds received from the client under this agreement for the
purposes specified in the agreement, but stole them and used them at their own discretion;
- 12.02.2021 committed thef of money of Smirnov Alexander Vladimirovich in the amount of 2,500,000 rubles,
i.e. on a particularly large scale, by deceit and breach of trust, consisting in creating in the latter, as a client of
which the client concluded an option agreement, by which he instructed the employees of this organisation
to conclude transactions with derivative financial instruments, including options, on the OTC market at the
expense of the money provided to them. At the same time, the participants of the criminal organisation did
not knowingly intend to fulfil the obligations assumed under the contract. The co - conspirators did not use
the money received from the client under this agreement for the purposes specified in the agreement, but
stole it and used it at their own discretion;
- in the period from 21.08.2020 to 16.02.2021 committed embezzlement of funds of Maxim Aleksandrovich
Bazayev in the amount of 1,620,000 roubles, i.e. on a particularly large scale, by means of deceit and breach
of the possibility of obtaining a high income, as a result of which the client concluded an option agreement
by which he instructed the employees of the organisation to conclude transactions with derivative financial
under the agreement. The co - conspirators did not use the money received from the client under this
- On 18.02.2021 they committed embezzlement of funds of Alexey Anatolievich Trishin in the amount of
1,800,000 roubles, i.e. on a particularly large scale, by means of deceit and breach of trust, which consisted in
obtaining a high income, as a result of which the client concluded an option agreement by which he
including options, on the OTC market at the expense of the funds provided to them. At the same time, the
- during the period from 04.12.2020 to 19.02.2021 committed embezzlement of Dmitry Vladimirovich Mitkin's
instruments, including options, on the OTC market at the expense of the money provided to them, At the
- during the period from 30.12.2020 to 21.02.2021 committed embezzlement of Vladimir Pavlovich Sotnikov's
money in the amount of 8,936,002.32 rubles, i.e. on a particularly large scale, by means of deceit and breach
of the possibility of obtaining a high income, as a result of which the client concluded an option agreement,
by which he instructed the employees of the organisation to conclude transactions with derivative financial
66
instruments, including options, on the OTC market at the expense of the money provided by them At the
- during the period from 09.02.2021 to 26.02.2021 committed embezzlement of funds of Korolsky Vladimir
Vasilyevich in the amount of 2,500,000 rubles, i.e. on a particularly large scale, by means of deceit and breach
of trust, which consisted in creating in the latter, as a client of the organisation of the group "QBF" ("QBF"), a
to them. At the same time, the participants of the criminal organisation did not knowingly intend to fulfil the
obligations assumed under the contract. The co - conspirators did not use the money received from the client
under this agreement for the purposes specified in the agreement, but stole it and used it at their own
discretion;
- in the period from 02.12.2020 to 26.02.2021 committed thef of funds of Svetlana Valeryevna Trukhmeneva in
the amount of 1,602,000 rubles, i.e. on a particularly large scale, by deceit and breach of trust, consisting in
- during the period from 15.01.2021 to 03.03.2021 committed embezzlement of funds of Fedor Vladimirovich
Alekseev in the amount of 2,068,000 rubles, i.e. on a particularly large scale, by means of deceit and breach of
the possibility of receiving a high income, as a result of which the client concluded an option agreement, by
- during the period from 20.01.2021 to 19.03.2021 committed embezzlement of funds of Maria Yurievna
Rodnevskaya in the amount of 3,283,227.25 rubles, i.e. on a particularly large scale, by means of deceit and
contract, by which he instructed employees of the organisation to conclude transactions with derivative
financial instruments on the over - the - counter market using the money provided to them, including options
with foreign issuers' equity securities as the underlying asset (over - the - counter option contracts), and also
provided his co - conspirators with his own money in the specified amount for trust management. At the
assumed under this agreement. The co - conspirators did not use the funds received from the client under
this agreement for the purposes specified in the agreement, but stole them and used them at their own
discretion;
- during the period from 05.01.2021 to 23.03.2021 committed embezzlement of funds of Alexey Viktorovich
Savin in the amount of 2,000,000 rubles, i.e. on a particularly large scale, by means of deceit and breach of
option agreement by which he instructed the employees of this organisation to conclude transactions with
67
discretion;
- during the period from 30.11.2020 to 23.03.2021 committed embezzlement of funds of Medvedev Rostislav
Vladimirovich in the amount of 5,700,000 rubles, i.e. on a particularly large scale, by means of deceit and
agreement by which he instructed the employees of the organisation to conclude transactions with
discretion;
- during the period from 04.02.2021 to 24.03.2021 committed embezzlement of funds of Babelyan Sevak
Armenovich in the amount of 3 000 000 rubles, i.e. on a particularly large scale, by deceit and breach of trust,
by him. At the same time, the participants of the criminal association knowingly did not intend to fulfil the
discretion;
- 25.03.2021 committed embezzlement of funds of Sergey Vladimirovich Kalinin in the amount of 1,200,000
rubles, i.e. on a particularly large scale, by means of deceit and breach of trust, which consisted in creating in
the latter, as a client of the QBF group organisation, a false appearance of the possibility of obtaining a high
income, as a result of which the client concluded an option agreement by which he instructed the employees
of this organisation to conclude transactions with derivative financial instruments, including options, on the
OTC market at the expense of the funds provided to them. At the same time, the participants of the criminal
association knowingly did not intend to fulfil the obligations assumed under this agreement. The co -
- during the period from 13.10.2020 to 05.04.2021 committed embezzlement of funds of Sergey Vladimirovich
Galaktionov in the amount of 5,831,750 rubles, i.e. on a particularly large scale, by deceit and breach of trust,
to them. At the same time, the participants of the criminal organisation did not knowingly intend to fulfil the
obligations assumed under the contract. The co - conspirators did not use the money received from the client
under this agreement for the purposes specified in the agreement, but stole it and used it at their own
discretion;
- during the period from 06.04.2021 to 13.04.2021 committed embezzlement of funds of Yuri Alekseevich
Frolov in the amount of 1,950,000 rubles, i.e. on a particularly large scale, by deceit and breach of trust,
derivative financial instruments, including options, on the over - the - counter market at the expense of the
funds provided to them. At the same time, the participants of the criminal association knowingly did not
68
- in the period from 25.12.2020 to 26.04.2021 committed embezzlement of funds of Danila Aleksandrovich Pilin
in the amount of 1,100,000 rubles, i.e. on a particularly large scale, by means of deceit and breach of trust,
instruments, including options, on the OTC market at the expense of the funds provided by him. At the same
- On 26.04.2021 they committed thef of money of Merts Alexander Nikolayevich in the amount of 1,050,000
roubles, i.e. on a particularly large scale, by deceit and breach of trust, consisting in creating in the latter, as a
client of the QBF group organisation, a false appearance of the possibility of obtaining a high income, as a
result of which the client concluded an option agreement, by which he instructed the employees of the
organisation to conclude transactions with derivative financial instruments, including options, on the OTC
market at the expense of the money provided to them. At the same time, the participants of the criminal
association knowingly did not intend to fulfil the obligations assumed under this agreement. The co -
- in the period from 06.04.2021 to 30.04.2021 committed embezzlement of funds of Alexei Borisovich Astakhov
- during the period from 30.10.2020 to 30.04.2021 committed embezzlement of funds of Peter Vladimirovich
Popov in the amount of 4,100,000 rubles, i.e. on a particularly large scale, by deceit and breach of trust,
discretion;
- in the period from 26.03.2021 to 24.05.2021 committed thef of funds of Artem Valeryevich Tregubov in the
which he instructed employees of this organisation to conclude transactions with derivative financial
instruments, including options, on the OTC market at the expense of the funds provided to them. b The
participants of the criminal association knowingly did not intend to fulfil the obligations undertaken in this
agreement. At the same time, the participants of the criminal association did not knowingly intend to fulfil
the obligations assumed under this agreement. The co - conspirators did not use the money received from
69
the client under this agreement for the purposes specified in the agreement, but stole it and used it at their
own discretion;
- during the period from 12.03.2021 to 25.05.2021 committed embezzlement of funds of Galina Vladimirovna
Mayorova in the amount of 5,063,333 rubles, i.e. on a particularly large scale, by means of deceit and breach
of trust, which consisted in creating in the latter, as a client of the organisation of the group "QBF" ("QBF"), a
discretion, of which the involvement of Pakhomov V.S. in the thef of funds committed against the following
citizens was established: N.S. Kozlovskaya, A.V. Polezhaev, G.V. Bulin, A.N. Petrov, N.G. Sapozhkov, A.V.
Shapran, I.E. Polyakova, O.N. Shut, A.A. Ptitsyn, V.V. Vedernikova, Tretiukhin A.N., Sazonov E.O., Bubnov N.A.,
Khlopyev V.N., Khlobyshev A.A., Eremin V.A., Lopatin M.I., Lomakina O.S., Kozlovskaya A.E., Levchenko V.V.,
Golovach A.V., Bruskov A.N., Egudkin B.A., Sasovskaya O.B., Sazonova I.O., Dyachenko E.V., Ermakov V.V.,
Cherkasov V.Y., Mullo T.I., Maslov Y.V., Velichko S.A., Gumenyuk D.V., Kholodkov S.V., Grigoriev A.B.,
Nikitchenko N.V., Zinoviev S.D., Lomov S.N., Nemtsev V.V., Novitskiy A.G., Vavilova L.A., Vetrova N.S., Bozhko
O.B., Batalova M.R., Romanovsky A.A., Erofeev D.V., Borzenkov M.I., Baiguzina S.A., Levina G.V., Naumova E.G.,
Danilov A.V., Krechetova T.O., Ostovich E.N., Drobin V.M., Kilo V.A., Emirgamzaev V.E., Kosorukov O.A., Lyutov
A.V., Bokov O.M., Kostovskaya E.N., Morozov V.V., Voropaev A.V., Kishilov S.M., Bogomolov I.L., Kosovsky B.G.,
Semenov I.L., Semenova L.L., Bolshov M.A., Dianov E.G., Gubanov A.V., Vorobyov - Desyatovsky N.V.,
Galachyan K.G., Chekmareva E.F., Birnov M.A., Potapov A.V., Bosak L.V., Paramonov S.V., Grif S.V., Andreev R.V.,
Ivanov K.A., Petrov P.E., Baskova T.V., Mishin I.Y., Nazarenkov A.V., Burmistrov V.N., Mishin Yu, Mazitov V.G.,
Toloknov D.Y., Kim A.L., Troshkova M.S., Ganeva E.P., Podgornaya I.A., Kovin A.P., Zatsarinsky D.E., Mudrogin
A.V., Rucheev A.V., Donskov I.V., Nosenko M.N., Mitroshin N.G., Batuev A.A., Drapesa N.V., Kormilitsyn S.V.,
Podolnaya A.V., Koncherova V.S., Koreshkov V.S., Borisov M.A., Tokareva A.A., Malinin D.I., Kulikova A.V.,
Kuzmenko K.N., Shilov A.V., Voropaev A.A., Gorbunov R.V., Shlykov A.K., Kuryatnikov L.A., Demidkova T.V.,
Grushanina I.S., Drapesa M.I., Pilenitsyn K.A., Kamzolov E.A., Elkin P.M., Bondarenko I.V., Vasyunin A.P., Grekov
S.A., Borodin V.V., Chernova J.B., Ivanov A.S., Silin D.S., Sbitnev K.I., Kushkov S.V., Pavlenko I.V., Smirnov A.V.,
Bazaev M.A., A.A. Trishin, D.V. Mitkin, V.P. Sotnikov, V.V. Korolskiy, S.V. Trukhmeneva, F.V. Alekseev, M.Y.
Rodnevskaya, A.V. Savin, R.V. Medvedev, Babelyan S.A., Kalinin S.V., Galaktionov S.V., Frolov Y.A., Pilin D.A.,
Merts A.N., Astakhov A.B., Popov P.V., Tregubov A.V., Mayorova G.V.
- Thus, Pakhomov Vladimir Sergeevich committed the management of a structural subdivision included in a
criminal association (criminal organisation), participation in a criminal association (criminal organisation),
committed by a person using his official position, i.e. the crime provided for by part 3 of article 210 of the
Criminal Code of the Russian Federation.
- He (Pakhomov V.S.) committed fraud, i.e. thef of other people's property by deception and abuse of trust,
committed by a person using his official position, on a large scale, by an organised group, namely:
- With the purpose of systematically committing embezzlement of funds of individuals, R.V. Shpakov, being the
actual head of QBF Financial Group (QBF), general director and participant of various legal entities used for
embezzlement, including KG LLC (INN 7701876374), JSC QBF Financial Group (INN 7703466327), Q-BROKER
LLC (INN 9703003668), no later than 31 December 2011. established a criminal association (criminal
organisation) in the form of a structured organised group (hereinafer referred to as the criminal association),
consisting of three structural subdivisions, which at different times voluntarily included: Pakhomov V.S., who
was the general director of LLC "KF Estate SPB" (INN 7840472851) and a participant in LLC "KG", which was
used for embezzlement, Z.V. Munayev, Athanasiadou Linda , A.S. Golubev, E.A. Rossieva, S.A. Matyukhin, who
was the General Director of LLC Investment Company QBF (INN 7733673955, hereinafer referred to as LLC
Investment Company QBF, the Company, Broker), and unidentified persons, including employees of QBF
Group companies (QBF).
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- The locations where the co - conspirators committed actions aimed at stealing money by deceiving
individuals and abusing their trust were office premises, which were positioned by the participants of the
criminal association as additional branches of LLC IC QBF, operating under a single brand - QBF Financial
Group, located in various regions of the Russian Federation, in offices at the following addresses: Moscow,
Presnenskaya Naberezhnaya, 8, p. 1, and Presnenskaya Naberezhnaya, 12; Ufa, Verkhnetorgovaya Ploshchad,
12; Moscow, Presnenskaya Naberezhnaya, 8, p. 1, and Presnenskaya Naberezhnaya, 12. 1 and Presnenskaya
Embankment, 12; Ufa, Verkhnetorgovaya Ploshchad, 4; Tyumen, ul. 4; Tyumen, 74 Maxim Gorky St.;
Murmansk, 82 Lenin Ave.; Kazan, 6 Spartakovskaya St.; Ekaterinburg, 1a Boris Yeltsin St.; St. Petersburg, 11
Degtyarny Per. and 64 Maloohtinsky Prospekt, 64, lit. "B"; Kaliningrad, 35 Teatralnaya St.. At the same time,
the main place where the participants of the criminal association carried out most of the actions aimed at
stealing money by deceiving individuals and abusing their trust, including those carried out remotely, using
various information and telecommunication means of communication, was the office premises located at the
following address: 8 Presnenskaya Naberezhnaya Embankment, bld. 1, Moscow. 1. In their subsequent
criminal activity, using the financial and logistical base of the group "QBF" ("QBF"), formed on the
instructions of Shpakov R.V. from the money systematically stolen from citizens, the participants of the
criminal association, Shpakov R.V., Pakhomov V.S. and Matyukhin S.A., using their official position in the
above - mentioned organisations of the group, by deceit and abuse of trust, consisting of creating the money
from individuals - individuals who were systematically stolen from citizens, Shpakov R.V., Pakhomov V.S. and
Matyukhin S.A., using their official positions in the above - mentioned organisations of the above -
mentioned group, by means of deceit and abuse of trust, which consisted in creating a false appearance of
the possibility of obtaining a high income among natural persons - clients of the companies of this group,
persuaded clients to conclude agreements on rendering services on provision of a trading account with the
amount of funds on it in the amount of the amount of funds received from the client (agreements on
rendering brokerage services) and other investment agreements. These agreements and contracts were
concluded for direct access to trading on the stock and derivatives markets, but the participants in the
criminal association knew that the obligations to the clients to pay the funds were unfulfilled, as the
information about the brokerage activities of the organisation with which a particular client concluded the
agreement or contract was false. The co - conspirators did not use the money received from clients under
these agreements and contracts for the purposes specified in the agreements and contracts, but stole it and
used it at their own discretion.
- Thus on 28.11.2013, at an unspecified time, being in the office of LLC "Kyubi Finance" (INN 7733673955),
located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, under the pretext of investing funds
in securities with high yields, Shpakov R.V., Pakhomov V.S., Munaev Z.V. and unidentified persons, acting as
an organised group, jointly and in concert, organised the signing with Kozlovskaya N.S. on behalf of a non -
resident company affiliated with the criminal association - QB Capital CY LTD (QB Capital CY LTD, registered in
the Republic of Cyprus), of an agreement on direct access to the US securities market No. 1344 - 13/VR dated
28.11.2013. The co - conspirators deceived N.S. Kozlovskaya by concealing from her the information that this
organisation had no legal grounds to engage in activities related to securities transactions, as it did not have
the relevant mandatory licence issued by the authorised body of the Republic of Cyprus.
- Continuing their criminal actions, on 28.11.2013, at an unspecified time, being in the office of Qubey Finance
LLC, located at the address: Moscow, Presnenskaya Naberezhnaya, 8, bld. 1, R.V. Shpakov, V.S. Pakhomov, Z.V.
Munayev and unidentified persons, acting as an organised group, jointly and in concert, organised the
conclusion of an agreement on the provision of trust management services with N.S. Kozlovskaya on behalf
of Qube Finance LLC, an affiliate of the criminal association, under agreement No. 1344 - 13/VR of 28.11.2013
and, under the pretext of fulfilling the terms of the said agreement and contract, persuaded the latter to
transfer her funds to them, ostensibly for trust management.
- N.S. Kozlovskaya, unaware of the crime being prepared and misled as to the true objectives of the
participants of the organised group - embezzlement of funds, believing that she was investing her funds with
the aim of making a profit, which was not true, being in the office of QBF LLC, located at the address:
Moscow, Presnenskaya Naberezhnaya 8, p. 1. 1, on 28.11.2013, at an unspecified time, she transferred cash in
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the amount of USD 18,000, which at the exchange rate of the Central Bank of the Russian Federation as of
28.11.2013 amounted to RUB 594,000, to the employees of QBF Group Company (QBF).
- In turn, R.V. Shpakov, V.S. Pakhomov, Z.V. Munayev and unidentified persons, acting as an organised group,
jointly and in concert, with the involvement of persons unaware of the criminal intent, organised the
acceptance of the above - mentioned funds from N.S. Kozlovskaya, as a result of which, abusing her trust,
they received them at their disposal, i.e. took possession of the stolen funds.
- As a result, Pakhomov V.S., using his official position, acting in an organised group, jointly and in concert with
Shpakov R.V., Munayev Z.V. and unidentified persons, under the above circumstances, deliberately, through
deceit and abuse of trust, on 28.11.2013 stole money belonging to Kozlovskaya N.S. in the amount of 594,000
rubles, in a large amount.
- Thus, Pakhomov Vladimir Sergeevich committed fraud, i.e. thef of other people's property by deception and
abuse of trust, committed by a person using his official position, on a large scale, by an organised group, i.e.
the crime provided for by part 4 of article 159 of the Criminal Code of the Russian Federation.
- He (Pakhomov V.S.) committed fraud, i.e. thef of other people’s property by deception and abuse of trust,
committed by a person using his official position, by an organised group, on a particularly large scale,
namely:
used for embezzlement, Munaev Z.V., Athanasiadou Linda, Golubev A.S., Rossieva E.A., Matyukhin S.A., who
criminal association as additional branches of QBF Financial Group LLC, operating under a single brand - QBF
Financial Group, located in various regions of the Russian Federation, in offices at the following addresses: 8
Presnenskaya Naberezhnaya Naberezhnaya, bld. 1, Moscow, and 12 Presnenskaya Naberezhnaya
Naberezhnaya, Ufa, Verkhnetorgovaya Square, bld. 1 and Presnenskaya Embankment, 12; Ufa,
Verkhnetorgovaya Ploshchad, 4; Tyumen, ul. 4; Tyumen, 74 Maxim Gorky St.; Murmansk, 82 Lenin Ave.;
Kazan, 6 Spartakovskaya St.; Ekaterinburg, 1a Boris Yeltsin St.; St. Petersburg, 11 Degtyarny Per. and 64
Maloohtinsky Prospekt, 64, lit. "B"; Kaliningrad, 35 Teatralnaya St.. At the same time, the main place where
the participants of the criminal association carried out most of the actions aimed at stealing money by
deceiving individuals and abusing their trust, including those carried out remotely, using various information
and telecommunication means of communication, was the office premises located at the following address:
8 Presnenskaya Naberezhnaya Embankment, bldg. 1, Moscow. 1.
- In their subsequent criminal activity, using the financial and logistical base of the QBF group, formed on the
instructions of R.V. Shpakov from the money systematically stolen from citizens, the participants of the
criminal association, R.V. Shpakov, V.S. Pakhomov and S.A. Matyukhin, using their official position in the
above - mentioned organisations of the group, by means of deceit and abuse of trust, consisting of the
creation of the "QBF" (QBF) group from the money systematically stolen from individuals, Shpakov R.V.,
Pakhomov V.S. and Matyukhin S.A., using their official positions in the above - mentioned organisations of
the above - mentioned group, by means of deceit and abuse of trust, which consisted in creating a false
appearance of the possibility of obtaining a high income among natural persons - clients of the companies of
this group, persuaded clients to conclude agreements on rendering services on provision of a trading
account with the amount of funds on it in the amount of the amount of funds received from the client
72
(agreements on rendering brokerage services) and other investment agreements. These agreements and
contracts were concluded for direct access to trading on stock and derivatives markets, but the participants
in the criminal association knew that the obligations to the clients to pay the funds were unfulfilled, as the
- So no later than April 2012, at an unspecified date and time, being in an unspecified place in Moscow, under
the pretext of investing money in securities with high yield, R.V. Shpakov, V.S. Pakhomov and unidentified
persons, acting as an organised group, jointly and in concert convinced A.V. Polezhaev to transfer his money
to them, ostensibly for trust management.
- A.V. Polezhaev, unaware of the crime that was being prepared and misled as to the true objectives of the
participants of the organised group - embezzlement of funds, believing that he was investing his money in
order to make a profit, which was not true in April 2012, at an unspecified date and time, being at the
address: Moscow, Kutuzovsky Prospekt, d. 2/1, pp. 2/1, p. 1, transferred to V.S. Pakhomov cash in the amount
of USD 400,000, which at the maximum exchange rate of the Central Bank of the Russian Federation as of
April 2012 was RUB 11,920,000, and in June 2012, at an unspecified date and time, at the address: 10,
Berezovaya Roscha Proyezd, Moscow, transferred to V.S. Pakhomov cash in the amount of USD 200,000,
which at the maximum exchange rate of the Central Bank of the Russian Federation as of June 2012 was RUB
6,808,000.
- In turn, R.V. Shpakov, V.S. Pakhomov and unidentified persons, acting as an organised group, jointly and in
concert, with the involvement of persons unaware of the criminal intent, organised the acceptance of the
above - mentioned funds of A.V. Polezhaev, abused his trust, received them at their disposal, i.e. took
possession of the stolen funds.
- Afer that, in order to veil their criminal actions and make them look legitimate, R.V. Shpakov, V.S. Pakhomov
and unidentified persons, acting as an organised group, jointly and in concert, on 05.06.2012, at an
unspecified time, being in the office of QB Finance LLC (INN 7733673955), located at the following address:
Moscow, Presnenskaya Naberezhnaya, 8, p. 1, arranged the signing with A.V. Polezhaev on behalf of a non -
resident company QB Capital CY LTD (QB Capital CY LTD) affiliated with the criminal community. 1, organised
the signing of an agreement on direct access to the US securities market No. 592 - 12/VR dated 05.06.2012
with A.V. Polezhaev on behalf of a non - resident company QB Capital CY LTD (QB Capital CY LTD, registered in
the Republic of Cyprus) affiliated with the criminal association. The co - conspirators deceived A.V. Polezhaev
by concealing from him the information that this organisation had no legal grounds to engage in activities
related to securities transactions, as it did not have the relevant mandatory licence issued by the authorised
body of the Republic of Cyprus.
- Continuing their criminal actions, on 05.06.2012, at an unspecified time, being in the office of LLC Qubey
Finance, located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, Shpakov R.V., Pakhomov V.S.
and unidentified persons, acting in an organised group, jointly and in concert, organised the conclusion of an
agreement on behalf of an affiliated criminal association LLC Qubey Finance. 1, R.V. Shpakov, V.S. Pakhomov
and unidentified persons, acting as an organised group, jointly and in concert, organised the conclusion of an
agreement on the provision of trust management services with A.V. Polezhaev on behalf of Kyubey Finance
LLC, an affiliate of the criminal association, under agreement No. 592 - 12/VR dated 05.06.2012.
- Further, in order to achieve a criminal result aimed at stealing A.V. Polezhaev's money, R.V. Shpakov,
Pakhomov and unidentified persons, acting as an organised group, jointly and in concert, with the
involvement of persons unaware of the criminal intent, under the pretext of fulfilling the terms of the above
agreement and contract, under unspecified circumstances, persuaded A.V. Polezhaev to transfer his money
to them for trust management.
- A.V. Polezhaev, A.V. Polezhaev, unaware of the crime that was being prepared and misled about the true goals
of the participants of the organised group - embezzlement of funds, believing that he was investing his funds
for the purpose of making a profit, which was not true, on 11.02.2014 he transferred funds from his account
73
No. 42100208900255970582 opened with UniCredit Bank - HypoVereinsbk ("UniCredit Bank AG -
HypoVereinsbank"), located at the address: Federal Republic of Germany, Berlin, Leibnizstrasse, Berlin,
Germany. Berlin, Leibnitzstraße 100, to the account of QB Capital CY LTD No. 8001700000000000688040
opened with Piraeus Bank, Republic of Cyprus, in the amount of EUR 1,050,000, which at the exchange rate of
the Central Bank of the Russian Federation as of 11.02.2014 was RUB 49,749,000.
concert, with the involvement of persons unaware of the criminal intent, having received A.V. Polezhaev's
money at their disposal, abused his trust and stole the money.
Shpakov R.V. and unidentified persons, under the above circumstances, deliberately, through deceit and
breach of trust, in the period from April 2012 to 11.02.2014, stole money belonging to Polezhaev A.V. in the
amount of 68,477,000 rubles, in an especially large amount.
abuse of trust, committed by a person using his official position, by an organised group, on a particularly
large scale, i.e. the crime provided for by part 4 of article 159 of the Criminal Code of the Russian Federation.
8 Presnenskaya Naberezhnaya Embankment, bldg. 1, Moscow. 1. In their subsequent criminal activity, using
the financial and logistical base of the QBF group, formed on the instructions of R.V. Shpakov from the money
systematically stolen from citizens, the participants of the criminal association, R.V. Shpakov, V.S. Pakhomov
and S.A. Matyukhin, using their official position in the above - mentioned organisations of the group, by
means of deceit and abuse of trust, consisting of the creation of the "QBF" (QBF) group from the money
systematically stolen from individuals, Shpakov R.V., Pakhomov V.S. and Matyukhin S.A., using their official
positions in the above - mentioned organisations of the above - mentioned group, by means of deceit and
abuse of trust, which consisted in creating a false appearance of the possibility of obtaining a high income
among natural persons - clients of the companies of this group, persuaded clients to conclude agreements
on rendering services on provision of a trading account with the amount of funds on it in the amount of the
74
amount of funds received from the client (agreements on rendering brokerage services) and other
investment agreements. These agreements and contracts were concluded for direct access to trading on
stock and derivatives markets, but the participants in the criminal association knew that the obligations to
the clients to pay the funds were unfulfilled, since the information about the brokerage activities of the
organisation with which a particular client concluded the agreement or contract was false. The co -
conspirators did not use the money received from clients under these agreements and contracts for the
purposes specified in the agreements and contracts, but stole it and used it at their own discretion.
- So on 16.01.2014, at an unspecified time, being in the office of LLC "Kyubi Finance" (INN 7733673955),
located at the address: St. Petersburg, Maloohtinsky Prospekt, 64, lit. "B", under the pretext of investing
money in securities with high yield, Shpakov R.V., Pakhomov V.S. and unidentified persons, acting in an
organised group, jointly and in concert, organised the signing with Bulin G.V. on behalf of a non - resident
affiliated with the criminal community, on behalf of a non - resident, affiliated with the criminal association,
Athanasiadou Linda and unidentified persons, acting as an organised group, jointly and in concert, organised
the signing of an agreement on direct access to the US securities market No. 1426 - 14/ISR dated 16.01.2014
with Bulin G.V. on behalf of a non - resident company QB Capital CY LTD ("QB Capital CY LTD", registered in the
Republic of Cyprus), affiliated with the criminal association. The co - conspirators deceived Bulin G.V. by
concealing from him the information that this organisation had no legal grounds to engage in activities
LLC, located at the address: St. Petersburg, Maloohtinsky Prospekt, 64, lit. "B", Shpakov R.V., Pakhomov V.S.
and unidentified persons, acting in an organised group, jointly and in a coordinated manner, organised the
conclusion of a contract on behalf of the criminal association affiliated with Qubey Finance LLC with Bulin,
Athanasiadou Linda and unidentified persons, acting as an organised group, jointly and in concert, organised
the conclusion of an agreement on the provision of trust management services with Bulin G.V. on behalf of
Kyubi Finance LLC, an affiliate of the criminal association, under agreement No. 1426 - 14/ISR dated
16.01.2014 and, under the pretext of fulfilling the terms of the said agreement and contract, persuaded the
latter to transfer his funds to them, ostensibly for trust management.
- Bulin G.V., unaware of the crime that was being prepared and misled as to the true objectives of the
participants of the organised group - embezzlement of funds, believing that he invested his funds with the
aim of making a profit, which did not correspond to reality, being in the office of QBF LLC, located at the
address: St. Petersburg, Maloohtinsky Prospekt, 64, Lit. "B", carried out the transfer of cash to the employees
of the QBF Group Company (QBF) as follows: 23.01.2014, at an unspecified time, in the amount of RUB
515,000; 29.04.2014, at an unspecified time, in the amount of RUB 300,000.
- In turn, R.V. Shpakov, V.S. Pakhomov, Athanasiadou Linda and unidentified persons, acting as an organised
group, jointly and in concert, with the involvement of persons unaware of the criminal intent, organised the
acceptance of the above - mentioned funds from G.V. Bulin, as a result of which, abusing his trust, they
received them at their disposal, i.e. took possession of the stolen funds.
Shpakov R.V., Athanasiadou Linda and unidentified persons, under the circumstances described above,
deliberately, through deceit and abuse of trust, in the period from 23.01.2014 to 29.04.2014, stole money
belonging to Bulin G.V. in the amount of 815,000 rubles, in a large amount.
namely:
75
- Thus, on 07.02.2014, at an unspecified time, being in the office of LLC "Kyubi Finance" (INN 7733673955),
in securities with high yields, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda and unidentified
persons, acting as an organised group, jointly and in concert, organised the signing of an agreement on direct
access to the US securities market No. 1475 - 14/VR dated 07.02.2014 with Petrov A.N. on behalf of a non -
resident company affiliated with the criminal association - QB Capital CY LTD (QB Capital CY registered in the
Republic of Cyprus). The accomplices deceived A.N. Petrov by concealing from him the information that this
Finance, located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, Shpakov R.V., Pakhomov V.S.,
76
Munaev Z.V. 1, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda and unidentified persons,
acting as an organised group, jointly and in concert, organised the conclusion, on behalf of Kyubi Finance
LLC, affiliated with the criminal association, of an agreement on the provision of trust management services
with Petrov A.N. under Agreement No. 1475 - 14/VR of 07.02.2014 and, under the pretext of fulfilling the terms
of the said agreement and the agreement, persuaded the latter to transfer his funds to them, ostensibly for
trust management.
- A.N. Petrov, unaware of the crime being prepared and misled as to the true objectives of the participants of
the organised group - embezzlement of funds, believing that he was investing his funds with the aim of
making a profit, which was not true, being in the office of QBF LLC located at the address: 8 Presnenskaya
Naberezhnaya Embankment, page 1, Moscow, carried out the transfer of cash to the employees of QBF Group
Company (QBF) as follows: 07.02.2014, at an unspecified time, in the amount of 2,000 roubles and 139,949
USD. 1, transferred cash to employees of QBF Group Company (QBF) as follows: on 07.02.2014, at an
unspecified time, in the amount of RUB 2,000 and USD 139,949, which at the exchange rate of the Central
Bank of the Russian Federation as of 07.02.2014 was RUB 4,860,428.77; on 20.05.2014, at an unspecified time,
in the amount of USD 40,095, which at the exchange rate of the Central Bank of the Russian Federation as of
20.05.2014 was RUB 1,392,900.3.
- In turn, R.V. Shpakov, V.S. Pakhomov, Z.V. Munayev, Athanasiadou Linda and unidentified persons, acting as
an organised group, jointly and in concert, with the involvement of persons unaware of the criminal intent,
organised the acceptance of the above - mentioned funds from A.N. Petrov, as a result of which, abusing his
trust, they received them at their disposal, i.e. took possession of the stolen funds.
Shpakov R.V., Munayev Z.V., Athanasiadou Linda and unidentified persons, under the above circumstances,
deliberately, by deceit and breach of trust, in the period from 07.02.2014 to 20.05.2014, stole money
belonging to Petrov A.N. in the amount of 6,255,329.07 rubles, in an especially large amount.
namely:
77
persons, acting as an organised group, jointly and in concert, organised the signing with Sapozhkov N.G., on
behalf of a non - resident affiliated with the criminal association - QB Capital CY LTD ("QB Capital CY LTD",
registered in the Republic of Cyprus), of an agreement on the provision of services of direct access to
international stock markets No. 1721 - 14/IMR dated 23.07.2014. The co - conspirators deceived N.G.
Sapozhkov by concealing from him the information that this organisation had no legal grounds to engage in
activities related to securities transactions, as it did not have the relevant mandatory licence issued by the
authorised body of the Republic of Cyprus.
Finance, located at the address: Moscow, Presnenskaya naberezhnaya, 8, p. 1, Shpakov R.V., Pakhomov V.S.,
LLC, affiliated with the criminal association, of an agreement with Sapozhkov N.G. on the provision of "Trust
Management" services under Agreement No. 1721 - 14/IMR dated 23.07.2014 and, under the pretext of
fulfilling the terms of the said agreement and contract, persuaded the latter to transfer his funds to them,
ostensibly for trust management.
- N.G. Sapozhkov, unaware of the crime being prepared and misled as to the true objectives of the participants
of the organised group - embezzlement of funds, believing that he was investing his funds with the aim of
making a profit, which did not correspond to reality, being in the office of QBF LLC, located at the address:
Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, on 30.07.2014, at an unspecified time, he transferred cash in
the amount of USD 100,000, which at the exchange rate of the Central Bank of the Russian Federation as of
30.07.2014 was RUB 3,563,000, to the employees of QBF Group Company (QBF).
organised the acceptance of the above - mentioned funds from N.G. Sapozhkov, as a result of which, abusing
his trust, they received them at their disposal, i.e. took possession of the stolen funds.
78
deliberately, through deceit and abuse of trust, on 30.07.2014 stole money belonging to Sapozhkov N.G. in
the amount of 3,563,000 rubles, in an especially large amount.
79
- Thus, on 28.10.2014, at an unspecified time, being in an unspecified place in the territory of Moscow, under
the pretext of investing money in securities with high yield, Shpakov R.V., Pakhomov V.S., Munaev Z.V. and
unidentified persons, acting in an organised group, jointly and in concert, organised the signing with Shapran
A.V. on behalf of a non - resident affiliated with the criminal association on behalf of a non - resident affiliated
with the criminal association, Athanasiadou Linda and unidentified persons, acting as an organised group,
jointly and in concert, organised the signing with Shapran A.V., on behalf of a non - resident affiliated with the
criminal association - QB Capital CY LTD (QB Capital CY registered in the Republic of Cyprus), of an agreement
on the provision of direct access to international stock markets No. 1880 - 14/IMR dated 28.10.2014. The co -
conspirators deceived A.V. Shapran by concealing from her the information that this organisation had no legal
grounds to engage in activities related to securities transactions, as it did not have the relevant mandatory
licence issued by the authorised body of the Republic of Cyprus.
- Continuing their criminal actions, on 28.10.2014, at an unspecified time, being in an exactly unspecified place
in the territory of Moscow, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev and unidentified persons, acting in an
organised group, jointly and in concert, organised the conclusion on behalf of the affiliated with the criminal
community LLC "Kyubi Finance" (INN), Athanasiadou Linda and unidentified persons, acting as an organised
group, jointly and in concert, organised the conclusion on behalf of Kyubi Finance LLC (INN 7733673955),
affiliated with the criminal association, with Shapran A.V. of an agreement on the provision of trust
management services under Agreement No. 1880 - 14/IMR of 28.10.2014 and, under the pretext of fulfilling
the terms of the said agreement and the agreement, persuaded the latter to transfer her funds to them,
- A.V. Shapran, unaware of the crime being prepared and misled as to the true objectives of the participants of
the organised group - embezzlement of funds, believing that she was investing her funds with the aim of
making a profit, which was not true, being in the office of QBF LLC, located at the address: Moscow,
Presnenskaya Naberezhnaya, 8, p. 1, at an unspecified time, made a transfer of cash in the amount of 425,000
roubles to the employees of the QBF group company (QBF). 1, on 31.10.2014, at an unspecified time, she
transferred cash in the amount of RUB 425,000 to the employees of QBF Group Company (QBF).
organised the acceptance of the above - mentioned funds from A.V. Shapran, as a result of which, abusing her
deliberately, through deceit and breach of trust, on 31.10.2014 stole money belonging to Shapran A.V. in the
amount of 425,000 rubles, in a large amount.
namely:
80
organised group, jointly and in concert, organised the signing with Polyakova I.E. on behalf of a non - resident
affiliated with the criminal association, non - resident I.E. Athanasiadou Linda, Athanasiadou Linda and
unidentified persons, acting as an organised group, jointly and in concert, organised the signing with
Polyakova I.E. on behalf of a non - resident affiliated with the criminal association - QB Capital CY LTD (QB
Capital CY registered in the Republic of Cyprus), of an agreement on the provision of services of direct access
to international stock markets No. 1850 - 14/ISR, dated 09.10.2014. The co - conspirators deceived I.E.
Polyakova by concealing from her the information that this organisation had no legal grounds to engage in
Finance, located at the address: St. Petersburg, Maloohtinsky Prospekt, 64, lit. "B", R.V. Shpakov, V.S.
Pakhomov and unidentified persons acting in an organised group, jointly and in concert, organised the
conclusion of a contract on behalf of the criminal association affiliated with Qubey Finance LLC with
Polyakiadu L, Athanasiadou Linda and unidentified persons, acting as an organised group, jointly and in
concert, organised the conclusion, on behalf of Kyubi Finance LLC affiliated with the criminal association, of
81
an agreement on the provision of trust management services with Polyakova I.E. under agreement No. 1850 -
14/ISR dated 09.10.2014 and, under the pretext of fulfilling the terms of the said agreement and contract,
persuaded the latter to transfer her funds to them, ostensibly for trust management.
- I.E. Polyakova, unaware of the crime that was being prepared and misled as to the true objectives of the
the aim of making a profit, which did not correspond to reality, being in the office of QBF LLC, located at 64,
Lit. "B", Maloohtinsky Prospekt, St. Petersburg, carried out the transfer of cash to the employees of the QBF
Group company as follows: 13.10.2014, at an unspecified time, in the amount of RUB 600,000; 27.10.2014, at
an unspecified time, in the amount of USD 6,000, which at the exchange rate of the Central Bank of the
Russian Federation as of 27.10.2014 was RUB 250,860; 27.10.2014, at an unspecified time, in the amount of
EUR 6,000, which at the exchange rate of the Central Bank of the Russian Federation as of 27.10.2014 was
RUB 317,460; 11.12.2014, at an unspecified time, in the amount of RUB 600,000.
acceptance of the above - mentioned funds from I.E. Polyakova, as a result of which, abusing her trust, they
Shpakov R.V., Athanasiadou Linda and unidentified persons, under the circumstances described above,
deliberately, through deceit and abuse of trust, in the period from 13.10.2014 to 11.12.2014, stole money
belonging to Polyakova I.E. in the amount of 1,768,320 rubles, in an especially large amount.
namely:
following address: 8 Presnenskaya Naberezhnaya Embankment, bldg. 1, Moscow. 1.
82
the group, by means of deceit and abuse of trust, which consisted in creating in natural persons - clients of
the companies of the group a false appearance of the possibility of obtaining a high income, persuaded
clients to conclude agreements on rendering services on provision of a trading account with the amount of
funds on it in the amount of the amount of funds received from the client (agreements on rendering
brokerage services) and other investment contracts. These agreements and contracts were concluded for
knew that the obligations to the clients to pay the funds were unfulfilled, since the information about the
brokerage activities of the organisation with which a particular client concluded the agreement or contract
was false. The co - conspirators did not use the money received from clients under these agreements and
contracts for the purposes specified in the agreements and contracts, but stole it and used it at their own
discretion.
organised group, jointly and in concert, organised the signing with Shut O.N. on behalf of a non - resident
affiliated with the criminal association, Pakhomov V.S. and unidentified persons, acting as an organised
group, jointly and in concert, organised the signing of an agreement on direct access to the US securities
market No. 1131 - 13/BP dated 26.07.2013 with Shut O.N. on behalf of a non - resident company QB Capital CY
LTD (QB Capital CY registered in the Republic of Cyprus) affiliated with the criminal association. At the same
time, the accomplices deceived Shut O.N. by concealing from her the information that this organisation did
not have legal grounds to engage in the type of activity related to securities transactions, as it did not have
- Continuing his criminal actions, on 26.07.2013, at an unspecified time, being in the office of LLC Qubey
Finance, located at the address: St. Petersburg, Maloohtinsky Prospekt, 64, lit. "B", Shpakov R.V., Pakhomov
V.S. and unidentified persons, acting in an organised group, jointly and in concert, organised the conclusion
of an agreement on behalf of the affiliated with the criminal association LLC Qubey Finance with Shut's Shut,
Pakhomov V.S. and unidentified persons, acting as an organised group, jointly and in concert, organised the
conclusion of an agreement on the provision of "Trust Management" services with Shut O.N. on behalf of
Qube Finance LLC, affiliated with the criminal community, under agreement No. 1131 - 13/BP of 26.07.2013
and, under the pretext of fulfilling the terms of the said agreement and contract, persuaded the latter to
transfer her funds to them, ostensibly for trust management.
- O.N. Shut, unaware of the crime that was being prepared and misled as to the true objectives of the
participants of the organised group - embezzlement of funds, believing that she invested her funds with the
aim of making a profit, which was not true, being in the office of QBF LLC, located at the address: St.
Petersburg, Maloohtinsky Prospe, 64, lit. "B", on 27.07.2013, at an unspecified time, she transferred cash in
the amount of 330,000 rubles to the employees of QBF Group Company (QBF), and on 21.09.2013, she
transferred funds from her account No. 42307810955102415360, opened in the additional office No. 0698 of
the North - West Bank of OJSC "Sberbank of Russia", located at 23 Bukharestskaya Street, k. 1, St. Petersburg,
to the account of "QB Capital CY LTD", No. CY4800800800170000000000000000000851218, opened with
Piraeus Bank, Republic of Cyprus, in the amount of RUB 480,000.
concert, with the involvement of persons unaware of the criminal intent, having received at their disposal the
funds of O.N. Shut, abused her trust and stole these funds.
83
- Continuing their criminal actions, in order to achieve a criminal result aimed at stealing money Shut O.N.,
Shpakov R.V., Pakhomov V.S., Athanasiadou Linda and unidentified persons, acting as an organised group,
jointly and in concert, with the involvement of persons unaware of the criminal intent, under the pretext of
fulfilling the conditions of the above agreement and contract, under unspecified circumstances, persuaded
Shut O.N. to transfer her money to them for trust management.
- O.N. Shut, unaware of the crime that was being prepared and misled as to the true objectives of the
the aim of making a profit, which did not correspond to reality, being in the office of QBF LLC, located at 64,
Lit. "B", Maloohtinsky Prospekt, St. Petersburg, carried out the transfer of cash to the employees of the QBF
group company as follows: 10.04.2014, at an unspecified time, in the amount of RUB 400,000; 16.12.2014, at
an unspecified time, in the amount of RUB 740,000.
acceptance of the above - mentioned funds from O.N. Shut, as a result of which, abusing his trust, they
Shpakov R.V., Athanasiadou Linda and unidentified persons, under the above circumstances, deliberately, by
deception and abuse of trust, in the period from 27.07.2013 to 16.12.2014, stole money belonging to Shut
O.N. in the amount of 1,950,000 rubles, in an especially large amount.
namely:
84
located at the address: Moscow, Presnenskaya naberezhnaya, 8, p. 1. 1, under the pretext of investing funds
persons, acting as an organised group, jointly and in concert, organised the signing with Ptitsyn A.A. on
international stock markets No. 1969 - 14/IMR dated 26.12.2014. The co - conspirators deceived A.A. Ptitsyn
Finance, located at the address: Moscow, Presnenskaya naberezhnaya, 8, p. 1, Shpakov R.V., Pakhomov V.S.,
LLC, an affiliate of the criminal association, of an agreement with Ptitsyn A.A. on the provision of trust
management services under Agreement No. 1969 - 14/IMR dated 26.12.2014 and, under the pretext of
fulfilling the terms of the said agreement and the agreement, persuaded the latter to transfer his funds to
them, ostensibly for trust management.
- A.A. Ptitsyn, unaware of the crime that was being prepared and misled as to the true objectives of the
participants of the organised group - embezzlement of funds, believing that he was investing his funds in
order to make a profit, which was not true, being in the office of QBF LLC, located at the address: Moscow,
Presnenskaya Naberezhnaya, 8, p. 1. 1, on 26.12.2014, at an unspecified time, he transferred cash in the
amount of USD 117,000, which at the exchange rate of the Central Bank of the Russian Federation as of
26.12.2014 amounted to RUB 6,156,540, to the employees of QBF Group Company (QBF).
organised the acceptance of the above money from A.A. Ptitsyn, as a result of which, abusing his trust, they
received it at their disposal, i.e. took possession of the stolen money.
deliberately, through deceit and breach of trust, on 26.12.2014 stole money belonging to Ptitsyn A.A. in the
85
namely:
was the General Director of QBF Investment Company LLC (INN 7733673955, hereinafer referred to as QBF
Investment Company LLC, the Company, Broker), and unidentified persons, including employees of QBF
located at 12 Presnenskaya Naberezhnaya Street, Moscow, under the pretext of investing money in securities
with high yield, R.V. Shpakov and V.S. Pakhomov, acting in an organised group, jointly and in concert,
86
organised the signing with Vedernikova V.V. on behalf of a non - resident affiliated with the criminal
association, Pakhomov V.S. and unidentified persons, acting as an organised group, jointly and in concert,
organised the signing of an agreement on direct access to the US securities market No. 539 - 12/BP dated
27.03.2012 with Vedernikova V.V. on behalf of a non - resident company QB Capital CY LTD (QB Capital CY LTD,
registered in the Republic of Cyprus) affiliated with the criminal association. The co - conspirators deceived
V.V. Vedernikova by concealing from her the information that this organisation had no legal grounds to
engage in activities related to securities transactions, as it did not have the relevant mandatory licence
issued by the authorised body of the Republic of Cyprus.
Finance, located at 12 Presnenskaya Embankment, Moscow, R.V. Shpakov and unidentified persons, acting in
an organised group, jointly and in concert, organised the conclusion of an agreement on behalf of the
affiliated criminal association LLC Qubey Finance with Vederny Vederny, Pakhomov V.S. and unidentified
persons, acting as an organised group, jointly and in concert, organised the conclusion of an agreement on
the provision of trust management services with Vedernikova V.V. on behalf of Kyubey Finance LLC, affiliated
with the criminal association, under agreement No. 539 - 12/BP of 27.03.2012 and, under the pretext of
fulfilling the terms of the said agreement and contract, persuaded the latter to transfer her funds to them,
- V.V. Vedernikova, unaware of the crime that was being prepared and misled as to the true objectives of the
participants of the organised group - embezzlement of funds, believing that she was investing her funds in
order to make a profit, which was not true, being in the office of QBF LLC, located at 12 Presnenskaya
Naberezhnaya Street, Moscow, made a transfer of cash to the employees of the QBF group company as
follows: 27.03.2012, at an unspecified time, in the amount of USD 17,000, which according to the exchange
rate of the Central Bank of the Russian Federation as of 27.03.2012 was RUB 496,910; 29.03.2012, at an
unspecified time, cash in the amount of USD 15,000, which according to the exchange rate of the Central
Bank of the Russian Federation as of 29.03.03.2012 was RUB 436,200; 28.11.2012, at an unspecified time, cash
28.11.2012 was RUB 3,094,000.
concert, with the involvement of persons unaware of the criminal intent, organised the acceptance of the
above money from V.V. Vedernikova, as a result of which, abusing her trust, they received it at their disposal,
i.e. took possession of the stolen money.
- Continuing their criminal actions, in order to achieve a criminal result aimed at stealing V.V. Vedernikova's
money, R.V. Shpakov, V.S. Pakhomov, Athanasiadou Linda and unidentified persons, acting as an organised
group, jointly and in concert, with the involvement of persons unaware of the criminal intent, under the
pretext of fulfilling the conditions of the above agreement and contract, under unspecified circumstances,
persuaded V.V. Vedernikova to transfer her money to them for trust management.
- Vedernikova V.V., V.V. Vedernikova, unaware of the crime that was being prepared and misled as to the true
objectives of the members of the organised group - embezzlement of funds, believing that she was investing
her funds in order to make a profit, which was not true, being in the office of QBF LLC, located at the
following address: 12 Presnenskaya Embankment, Moscow, at an unspecified time in 2014, the exact date not
specified by the investigation, made a transfer to the employees of the QBF group company (12,
Presnenskaya Embankment, Moscow). 12, Presnenskaya Naberezhnaya Street, Moscow, in 2014, the exact
date is not specified by the investigation, at an unspecified time, she transferred cash in the amount of
1,000,000 roubles to employees of the QBF group company (QBF).
acceptance of the above money from V.V. Vedernikova, as a result of which, abusing her trust, they received it
at their disposal, i.e. took possession of the stolen money.
Shpakov R.V., Athanasiadou Linda and unidentified persons, under the above circumstances, deliberately, by
87
deception and abuse of trust, in the period from 27.03.2012 to 31.12.2014, stole money belonging to V.V.
Vedernikova in the amount of 5,027,110 rubles, in an especially large amount.
- He (Pakhomov V.S.) committed fraud, i.e. thef of other people's property through deception and abuse of
trust, committed by a person using his official position, by an organised group, on a particularly large scale,
namely:
(agreements on rendering brokerage services) and other investment contracts. These agreements and
88
located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, under the pretext of investing money
in securities with high yield, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda , L, Golubev A.S.
and unidentified persons, acting as an organised group, jointly and in concert, organised the signing with
Tretiukhin A.N. on behalf of a non - resident affiliated with the criminal association - QB Capital CY LTD ("QB
Capital CY LTD", registered in the Republic of Cyprus), of an agreement on the provision of services of direct
access to international stock markets No. 2128 - 15/IMR dated 29.04.2015. The accomplices deceived A.N.
Tretiukhin by concealing from him the information that this organisation had no legal grounds to engage in
the type of activity related to the execution of securities transactions, as it did not have the relevant
mandatory licence issued by the authorised body of the Republic of Cyprus.
- Continuing their criminal actions, on 29.04.2015, at an unspecified time, being in the office of LLC Kyubi
Munaev Z.V., Athanasiadou Linda 1, Shpakov R.V., Pakhomov V.S., Munaev Z.V., Athanasiadou L, Golubev A.S.
agreement on the provision of trust management services with Tretiukhin A.N. on behalf of Kyubi Finance
LLC, affiliated with the criminal association, under agreement No. 2128 - 15/IMR of 29.04.2015, and, under the
pretext of fulfilling the terms of the said agreement and contract, persuaded the latter to transfer his funds to
- A.N. Tretiukhin, unaware of the crime being prepared and misled as to the true objectives of the participants
making a profit, which was not true, being in the office of QBF LLC, located at the address: 8 Presnenskaya
Naberezhnaya Naberezhnaya, bldg. 1, Moscow, carried out the transfer of cash to the employees of the QBF
group company as follows. 1, realised the transfer of cash to the employees of the QBF Group Company (QBF)
as follows: 29.04.2015, at an unspecified time, in the amount of USD 14,000, which at the exchange rate of the
Central Bank of the Russian Federation as of 29.04.2015 was RUB 732,200; 23.06.2015, at an unspecified time,
in the amount of RUB 673,000.
- In turn, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda , A.S. Golubev and unidentified
persons, acting as an organised group, jointly and in concert, with the involvement of persons unaware of the
criminal intent, organised the acceptance of the above - mentioned funds from A.N. Tretiukhin, as a result of
which, abusing his trust, they received them at their disposal, i.e. took possession of the stolen funds.
deliberately, through fraud and breach of trust, from 29.04.2015 to 23.06.2015, stole from Golubev A.S,
Golubev A.S. and unidentified persons, under the circumstances described above, deliberately, through
deceit and breach of trust, in the period from 29.04.2015 to 23.06.2015 stole money belonging to Tretiukhin
A.N. in the amount of 1,405,200 rubles, in an especially large amount.
namely:
89
- In their subsequent criminal activity, using the financial and logistical base of the group "QBF" ("QBF"),
formed on the instructions of Shpakov R.V. from the money systematically stolen from citizens, the
participants of the criminal association, Shpakov R.V., Pakhomov V.S. and Matyukhin S.A., using their official
position in the above - mentioned organisations of the group, by deceit and abuse of trust, consisting of
creating the money from individuals - individuals - who were systematically stolen from citizens, Shpakov
R.V., Pakhomov V.S. and Matyukhin S.A., using their official positions in the above - mentioned organisations
of the above - mentioned group, by means of deceit and abuse of trust, which consisted in creating a false
contracts were concluded for direct access to trading on the stock and derivatives markets, but the
participants in the criminal association knew that the obligations to the clients to pay the funds were
unfulfilled, as the information about the brokerage activities of the organisation with which a particular
client concluded the agreement or contract was false. The co - conspirators did not use the money received
from clients under these agreements and contracts for the purposes specified in the agreements and
contracts, but stole it and used it at their own discretion.
and unidentified persons, acting as an organised group, jointly and in concert, organised the signing with
Sazonov E.O. on behalf of a non - resident affiliated with the criminal association - QB Capital CY LTD ("QB
access to international stock markets No. 2267 - 15/IMR dated 05.08.2015. The co - conspirators deceived E.O.
Sazonov by concealing from him the information that this organisation had no legal grounds to engage in
agreement on the provision of trust management services with Sazonov E.O. on behalf of Kyubi Finance LLC,
an affiliate of the criminal association, under agreement No. 2267 - 15/IMR dated 05.08.2015 and, under the
90
- E.O. Sazonov, unaware of the crime being prepared and misled as to the true objectives of the participants of
Presnenskaya Naberezhnaya, 8, p. 1. 1, made a transfer of cash to the employees of QBF Group Company
(QBF) as follows: on 06.08.2015, at an unspecified time, in the amount of USD 80,000, which at the exchange
rate of the Central Bank of the Russian Federation as of 06.08.08.2015 was RUB 5,017,600; 06.08.2015, at an
unspecified time, in the amount of EUR 11,220, which at the exchange rate of the Central Bank of the Russian
Federation as of 06.08.2015 was RUB 764,530.8; 02.10.2015, at an unspecified time, in the amount of RUB
3,100,000.
criminal intent, organised the acceptance of the above - mentioned funds from E.O. Sazonov, as a result of
deliberately, through fraud and breach of trust, from 06.08.2015 to 02.10.2015, stole from Golubev A.S,
deceit and breach of trust, in the period from 06.08.2015 to 02.10.2015, stole money belonging to Sazonov
E.O. in the amount of 8,882,130.8 rubles, in an especially large amount.
namely:
91
in securities with high yield, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda , A.S. Golubev
and A.S. Golubev, Golubev A.S. and unidentified persons, acting as an organised group, jointly and in concert,
organised the signing with Bubnov N.A. on behalf of a non - resident affiliated with the criminal association -
QB Capital CY LTD ("QB Capital CY LTD", registered in the Republic of Cyprus), of an agreement on the
provision of services of direct access to international stock markets No. 2197 - 15/IMR dated 24.06.2015. The
co - conspirators deceived N.A. Bubnov by concealing from him the information that this organisation had no
legal grounds to engage in activities related to securities transactions, as it did not have the relevant
agreement on the provision of trust management services with Bubnov N.A. on behalf of Kyubi Finance LLC,
affiliated with the criminal association, under agreement No. 2197 - 15/IMR dated 24.06.2015, and, under the
- N.A. Bubnov, unaware of the crime being prepared and misled as to the true objectives of the participants of
making a profit, which was not true, being in the office of QBF LLC located at 8 Presnenskaya Naberezhnaya
Naberezhnaya, bldg. 1, Moscow, carried out the transfer of cash to the employees of QBF Group Company
(QBF) as follows. 1, realised the transfer of cash to the employees of QBF Group Company (QBF) as follows:
24.06.2015, at an unspecified time, in the amount of USD 18,500, which at the exchange rate of the Central
Bank of the Russian Federation as of 24.06.2015 was RUB 1,002,885; 13.10.2015, at an unspecified time, in the
13.10.2015 was RUB 580,925.
criminal intent, organised the acceptance of the above - mentioned funds from N.A. Bubnov, as a result of
92
deliberately, through fraud and breach of trust, from 24.06.2015 to 13.10.2015, stole, by means of deceit and
abuse of trust, Golubev A.S. and unidentified persons, under the circumstances described above,
deliberately, through deceit and breach of trust, in the period from 24.06.2015 to 13.10.2015 stole money
belonging to Bubnov N.A. in the amount of 1,583,810 rubles, in an especially large amount.
namely:
93
organised the signing with Khlopiev V.N. on behalf of a non - resident affiliated with the criminal association -
provision of services of direct access to international stock markets No. 2125 - 15/IMR dated 28.04.2015. At
the same time, the accomplices deceived V.N. Khlopiev by concealing from him the information that this
organisation did not have legal grounds to engage in the type of activity related to securities transactions, as
it did not have the relevant mandatory licence issued by the authorised body of the Republic of Cyprus.
agreement on the provision of trust management services with Khlopiev V.N. on behalf of Kyubi Finance LLC,
an affiliate of the criminal association, under agreement No. 2125 - 15/IMR of 28.04.2015 and, under the
- V.N. Khlopiev, unaware of the crime being prepared and misled as to the true objectives of the participants of
making a profit, which was not true, being in the office of QBF LLC located at 8 Presnenskaya Naberezhnaya
Naberezhnaya, bldg. 1, Moscow, carried out the transfer of cash to the employees of the QBF group company
as follows. 1, realised the transfer of cash to the employees of the QBF Group Company (QBF) as follows:
11.08.2015 was RUB 1,935,000; 24.09.09.2015, at an unspecified time, in the amount of USD 40,000, which at
the exchange rate of the Central Bank of the Russian Federation as of 24.09.2015 was RUB 2,641,600;
Bank of the Russian Federation as of 19.10.2015 was RUB 3,068,000.
criminal intent, organised the acceptance of the above - mentioned funds from V.N. Khlopiev, as a result of
deliberately, by means of fraud and breach of trust, from 29.04.2015 to 19.10.2015, stole from Golubev A.S,
deceit and breach of trust, in the period from 29.04.2015 to 19.10.2015, stole money belonging to Khlopiev
V.N. in the amount of 9,213,600 rubles, in an especially large amount.
namely:
94
creating the money from individuals - individuals who were systematically stolen from citizens, Shpakov R.V.,
and unidentified persons, acting in an organised group, jointly and in concert, organised the signing with
Khlobyshev A.A. on behalf of a non - resident affiliated with the criminal association - QB Capital CY LTD ("QB
access to international stock markets No. 2379 - 15/IMR, dated 29.10.2015. At the same time, the accomplices
deceived A.A. Khlobyshev by concealing from him the information that this organisation did not have legal
95
grounds to engage in the type of activity related to securities transactions, as it did not have the relevant
agreement on the provision of trust management services with Khlobyshev A.A. on behalf of Kyubi Finance
LLC, affiliated with the criminal association, under agreement No. 2379 - 15/IMR dated 29.10.2015, and, under
the pretext of fulfilling the terms of the said agreement and contract, persuaded the latter to transfer his
funds to them, ostensibly for trust management.
- A.A. Khlobyshev, unaware of the crime being prepared and misled as to the true objectives of the members of
making a profit, which was not true, being in the office of QBF LLC, located at the address: 8 Presnenskaya
group company as follows. 1, realised the transfer of cash to the employees of QBF Group Company (QBF) as
follows: 30.10.2015, at an unspecified time, in the amount of RUB 1,160,000; 30.10.2015, at an unspecified
time, in the amount of USD 5,265, which at the exchange rate of the Central Bank of the Russian Federation
as of 30.10.2015 was RUB 337,855.05; 30.10.2015, at an unspecified time, in the amount of EUR 3,045, which
at the exchange rate of the Central Bank of the Russian Federation as of 30.10.2015 was RUB 213,576.3;
19.01.2016, at an unspecified time, in the amount of RUB 300,000; 28.01.2016, at an unspecified time, in the
amount of RUB 200,000.
criminal intent, organised the acceptance of the above - mentioned funds from A.A. Khlobyshev, as a result of
deliberately stole, by means of fraud and breach of trust, from 30.10.2015 to 28.01.2016, Golubev A.S. and
unidentified persons, under the circumstances described above, deliberately, through deceit and breach of
trust, in the period from 30.10.2015 to 28.01.2016 stole money belonging to Khlobyshev A.A. in the amount of
2,211,431.35 rubles, in an especially large amount.
namely:
96
- Thus on 17.02.2016, at an unspecified time, being in the office of LLC "IC QBIF Investment" (INN 7733673955),
located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, under the pretext of investing money in
securities with high yield, Shpakov R.V., Pakhomov V.S., Munaev Z.V., Athanasiadou Linda 1, under the pretext
of investing funds in securities with high yields, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou
Linda and A.S. Golubev, Golubev A.S. and unidentified persons, acting as an organised group, jointly and in
concert, organised the signing with Eremin V.A. on behalf of a non - resident affiliated with the criminal
association - QB Capital CY LTD ("QB Capital CY LTD", registered in the Republic of Cyprus), of an agreement
on the provision of services of direct access to international stock markets No. 2508 - 16/IMR dated
17.02.2016. The co - conspirators deceived V.A. Eremin by concealing from him the information that this
- Continuing their criminal actions, on 17.02.2016, at an unspecified time, being in the office of LLC IC QBIF
Investment, located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, Shpakov R.V., Pakhomov
V.S., Munaev Z.V., Athanasiadou Linda 1, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda and
A.S. Golubev, Golubev A.S. and unidentified persons, acting as an organised group, jointly and in concert,
organised the conclusion of an agreement on the provision of trust management services with Eremin V.A. on
behalf of Kyubi Finance LLC, affiliated with the criminal association, under the agreement No. 2508 - 16/IMR
dated 17.02.2016 and, under the pretext of fulfilling the terms of the said agreement and contract, convinced
the latter to transfer his funds to them, ostensibly for trust management.
- V.A. Eremin, unaware of the crime being prepared and misled as to the true objectives of the participants of
making a profit, which was not true, on 09.03.2016, made a transfer of funds from his account No.
97
40817840097350000292, opened in the additional office of PJSC "Rosbank", located at the address: Moscow,
Bolshaya Polyanka St., 28, k. 1, to the account "QB Capital". 1, to QB Capital CY LTD account No.
CY050140010101010101020011705019 opened with Cypress Development Bank, Republic of Cyprus, in the
amount of USD 182,274, which amounted to RUB 13,340,634.06 at the exchange rate of the Central Bank of
the Russian Federation as of 09.03.2016.
- In turn, R.V. Shpakov, Z.V. Munayev, V.S. Pakhomov, Athanasiadou Linda , A.S. Golubev and unidentified
criminal intent, having obtained at their disposal the funds of V.A. Eremin, abused his trust and stole these
funds.
Shpakov R.V., Munayev Z.V., Athanasiadou Linda, Golubev A.S. and unidentified persons, under the above
circumstances, deliberately, through deceit and abuse of trust, on 09.03.2016 stole money belonging to
Eremin V.A. in the amount of 13,340,634.06 rubles, in an especially large amount.
98
- Thus on 24.03.2016, at an unspecified time, being in the office of LLC "IC QBIF Investment" (INN 7733673955),
in securities with high yields, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda and A.S.
Golubev, Golubev A.S. and unidentified persons, acting as an organised group, jointly and in concert,
organised the signing with Lopatin M.I. on behalf of a non - resident affiliated with the criminal association -
QB Capital CY LTD ("QB Capital CY LTD", registered in the Republic of Cyprus) of an agreement on the
provision of direct access to international stock markets No. 2553 - 16/IMR dated 24.03.2016. The co -
conspirators deceived Lopatin M.I. by concealing from him the information that this organisation had no legal
- Continuing their criminal actions, on 24.03.2016, at an unspecified time, being in the office of LLC IC QBIF
Investment, located at the address: Moscow, Presnenskaya naberezhnaya, 8, p. 1, Shpakov R.V., Pakhomov
V.S., Munaev Z.V., Athanasiadou Linda 1, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda and
A.S. Golubev, Golubev A.S. and unidentified persons, acting as an organised group, jointly and in concert,
organised the conclusion of an agreement on the provision of trust management services with Lopatin M.I.
on behalf of QBIF Investment LLC, affiliated with the criminal association, under agreement No. 2553 - 16/IMR
dated 24.03.2016, and, under the pretext of fulfilling the terms of the said agreement and contract,
persuaded the latter to transfer his funds to them, ostensibly for trust management.
- Lopatin M.I., unaware of the crime that was being prepared and misled as to the true objectives of the
participants of the organised group - the thef of funds, believing that he was investing his funds with the aim
of making a profit, which was not true, being in the office of LLC IC QBF Investment, located at the address: 8
Presnenskaya Naberezhnaya Naberezhnaya, bldg. 1, Moscow, carried out the transfer of cash to the
employees of the QBF group company as follows. 1, realised the transfer of cash to the employees of QBF
Group Company (QBF) as follows: 24.03.2016, at an unspecified time, in the amount of RUB 500,000;
20.04.2016, at an unspecified time, in the amount of RUB 300,000.
criminal intent, organised the acceptance of the above - mentioned funds from M.I. Lopatin, as a result of
circumstances, deliberately, through deceit and abuse of trust, in the period from 24.03.2016 to 20.04.2016,
stole money belonging to Lopatin M.I. in the amount of 800,000 rubles, in a large amount.
99
- Thus, on 11.05.2016, at an unspecified time, being in the office of LLC "Investment Company QBF" (INN
7733673955), located at the address: Moscow, Presnenskaya naberezhnaya, 8, p. 1. 1, under the pretext of
investing funds in securities with high yields, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda
organised the signing of an agreement on the provision of services of direct access to international stock
markets No. 2618 - 16/IMR dated 11.05.2016 with Lomakina O.S. on behalf of a non - resident company QB
Capital CY LTD ("QB Capital CY LTD", registered in the Republic of Cyprus) affiliated with the criminal
association. The accomplices deceived Lomakina O.S. by concealing from her the information that this
- Continuing their criminal actions, on 11.05.2016, at an unspecified time, being in the office of LLC Investment
Company QBF, located at the following address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, Shpakov R.V.,
100
Pakhomov V.S., Munaev Z.V., Athanasiadou Linda 1, Shpakov R.V., Pakhomov V.S., Munaev Z.V., Athanasiadou
Linda, Golubev A.S. and unidentified persons, acting as an organised group, jointly and in concert, organised
the conclusion of an agreement on the provision of trust management services with Lomakina O.S. on behalf
of QBIF Investment Company LLC, affiliated with the criminal association, under agreement No. 2618 -
16/IMR dated 11.05.2016 and, under the pretext of fulfilling the terms of the said agreement and contract,
- O.S. Lomakina, unaware of the crime being prepared and misled as to the true objectives of the participants
of the organised group - embezzlement of funds, believing that she was investing her funds with the aim of
making a profit, which did not correspond to reality, being in the office of LLC Investment Company QBF,
located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, on 11.05.2016, at an unspecified
time, she transferred cash in the amount of RUB 185,000 and USD 7,250 to employees of QBF Group
Company (QBF), which at the exchange rate of the Central Bank of the Russian Federation as of 11.05.2016
was RUB 480,892.5.
criminal intent, organised the acceptance of the above - mentioned funds from O.S. Lomakina, as a result of
which, abusing her trust, they received them at their disposal, i.e. took possession of the stolen funds.
circumstances, deliberately, through deceit and breach of trust, on 11.05.2016 stole money belonging to
Lomakina O.S. in the amount of 665,892.5 rubles, in a large amount.
101
- Thus, on 03.07.2014 at an unspecified time, being in the office of LLC "Kyubi Finance" (INN 7733673955),
persons, acting as an organised group, jointly and in concert, organised the signing with Kozlovskaya A.E. on
registered in the Republic of Cyprus) of an agreement on direct access to the US securities market No. 1675 -
14/IMR dated 03.07.2014. At the same time, the accomplices deceived A.E. Kozlovskaya by concealing from
her the information that this organisation did not have legal grounds to engage in the type of activity related
to securities transactions, as it did not have the relevant mandatory licence issued by the authorised body of
the Republic of Cyprus.
LLC, located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, Shpakov R.V., Pakhomov V.S.,
LLC, affiliated with the criminal association, of an agreement on trust management services with
Kozlovskaya A.E. under Agreement No. 1675 - 14/IMR dated 03.07.2014 and, under the pretext of fulfilling the
terms of the said agreement and contract, persuaded the latter to transfer her funds to them, ostensibly for
trust management.
- A.E. Kozlovskaya, unaware of the crime being prepared and misled as to the true objectives of the
the aim of making a profit, which did not correspond to reality, being in the office of QBF LLC, located at the
address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, on 03.07.2014, at an unspecified time, she
transferred cash in the amount of USD 16,400, which at the exchange rate of the Central Bank of the Russian
Federation as of 03.07.2014 amounted to RUB 561,700, to the employees of QBF Group Company (QBF).
organised the acceptance of the above - mentioned funds from A.E. Kozlovskaya, as a result of which,
abusing her trust, they received them at their disposal, i.e. took possession of the stolen funds.
- Continuing their criminal actions, in order to achieve a criminal result aimed at stealing money A.E.
Kozlovskaya, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda and unidentified persons, acting
in an organised group, jointly and in concert, involving persons unaware of the criminal intent, under the
pretext of fulfilling the terms of the said agreement, A.S. Golubev and unidentified persons, A.S. Golubev and
unidentified persons, acting as an organised group, jointly and in concert, with the involvement of persons
102
unaware of the criminal intent, under the pretext of fulfilling the terms of the above agreement and contract,
under unspecified circumstances, persuaded A.E. Kozlovskaya to transfer her money to them for trust
management.
- A.E. Kozlovskaya, unaware of the crime that was being prepared and misled as to the true objectives of the
members of the organised group - embezzlement of funds, believing that she was investing her funds with
the aim of making a profit, which did not correspond to reality, being in the office of LLC Investment
Company QBF, located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, in May 2016, at an
unspecified time, the investigation has not determined the exact date. 1, in May 2016, on an unspecified date,
at an unspecified time, she transferred cash in the amount of USD 3,500, which at the maximum exchange
rate of the Central Bank of the Russian Federation as of May 2016 was RUB 231,280, to employees of QBF
Group (QBF).
- In turn, R.V. Shpakov, V.S. Pakhomov, Z.V. Munayev, Athanasiadou Linda , A.S. Golubev and unidentified
criminal intent, organised the acceptance of the above - mentioned funds from A.E. Kozlovskaya, as a result
of which, abusing her trust, they received them at their disposal, i.e. took possession of the stolen funds.
circumstances, deliberately, through deceit and abuse of trust, in the period from 03.07.2014 to May 2016,
stole money belonging to Kozlovskaya A.E. in the amount of 792,980 rubles, in a large amount.
namely:
103
in the criminal association knew that the obligations to the clients to pay the funds were unfulfilled, because
the information about the brokerage activities of the organisation with which a particular client concluded
the agreement or contract was false. The co - conspirators did not use the money received from clients under
- Thus on 25.12.2014, at an unspecified time, being in the office of LLC "Kyubi Finance" (INN 7733673955),
persons, acting as an organised group, jointly and in concert, organised the signing with Levchenko V.V. on
registered in the Republic of Cyprus) of an agreement on the provision of services of direct access to
international stock markets No. 1962 - 14/IMR dated 25.12.2014. The co - conspirators deceived V.V.
Levchenko by concealing from him the information that this organisation had no legal grounds to engage in
LLC, affiliated with the criminal association, of an agreement with Levchenko V.V. on the provision of "Trust
Management" services under Agreement No. 1962 - 14/IMR dated 25.12.2014 and, under the pretext of
fulfilling the terms and conditions of the said agreement and contract, persuaded the latter to transfer his
- V.V. Levchenko, unaware of the crime being prepared and misled as to the true objectives of the participants
making a profit, which did not correspond to reality, being in the office of QBF LLC, located at the address:
Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, on 25.12.2014, at an unspecified time, he transferred cash in
the amount of RUB 670,000 to the employees of QBF Group Company (QBF).
organised the acceptance of the above - mentioned funds from V.V. Levchenko, as a result of which, abusing
- Continuing their criminal actions, in order to achieve a criminal result aimed at stealing money Levchenko
V.V., Shpakov R.V., Pakhomov V.S., Munaev Z.V., Athanasiadou Linda and unidentified persons, acting in an
organised group, jointly and in concert, involving persons unaware of the criminal intent, under the pretext
of fulfilling the terms of the above agreement, Golubev A.S, Golubev A.S. and unidentified persons, acting as
under the pretext of fulfilling the terms of the above agreement and contract, under unspecified
104
circumstances, convinced Levchenko V.V. of the need for an additional transfer of his funds to them,
- V.V. Levchenko, unaware of the crime that was being prepared and misled as to the true objectives of the
participants of the organised group - embezzlement of funds, believing that he was investing his funds with
the aim of making a profit, which was not true, being in the office of LLC Investment Company QBF, located at
the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, made a transfer of cash to the employees of the
QBF Group Company (QBF) as follows. 1, realised the transfer of cash to the employees of QBF Group
Company (QBF) as follows: 14.04.2016, at an unspecified time, in the amount of USD 3,500, which at the
exchange rate of the Central Bank of the Russian Federation as of 14.04.2016 was RUB 230,195; 22.08.2016, at
an unspecified time, in the amount of USD 2,500, which at the exchange rate of the Central Bank of the
Russian Federation as of 22.08.2016 was RUB 159,850.
criminal intent, organised the acceptance of the above - mentioned funds from V.V. Levchenko, as a result of
unidentified persons, under the above circumstances, in the period from 25.12.2014 to 22.08.2016,
deliberately, through deceit and breach of trust, stole money belonging to Levchenko V.V. in the amount of
1,060,045 rubles, in an especially large amount.
105
above - mentioned organisations of the above - mentioned group, by means of deceit and abuse of trust,
consisting of the creation of the "QBF" (QBF) group from the money systematically stolen from individuals,
Shpakov R.V., Pakhomov V.S. and Matyukhin S.A., using their official positions in the above - mentioned
organisations of the above - mentioned group, by means of deceit and abuse of trust, which consisted in
creating a false appearance of the possibility of obtaining a high income among natural persons - clients of
the companies of this group, persuaded clients to conclude agreements on rendering services on provision of
client (agreements on rendering brokerage services) and other investment agreements. These agreements
and contracts were concluded for direct access to trading on stock and derivatives markets, but the
- So on 04.10.2016, at an unspecified time, being in the office of LLC Investment Company QBF (INN
7733673955), located at the address: St. Petersburg, Maloohtinsky Prospekt, 64, lit. "B", under the pretext of
investing money in securities with high yield, Shpakov R.V., Pakhomov V.S., Athanasiadou Linda and
unidentified persons acting in an organised group, jointly and in concert, organised the signing with
Golovach A.V. on behalf of a non - national affiliated with the criminal association on behalf of Golovach A.V,
Golubev A.S. and unidentified persons, acting as an organised group, jointly and in concert, organised the
signing with Golovach A.V. on behalf of a non - resident affiliated with the criminal association - QB Capital CY
LTD ("QB Capital CY LTD", registered in the Republic of Cyprus), of an agreement on the provision of services
of direct access to international stock markets No. 2862 - 16/ISR dated 04.10.2016. At the same time, the
accomplices deceived A.V. Golovach by concealing from him the information that this organisation did not
have legal grounds to engage in the type of activity related to securities transactions, as it did not have the
relevant mandatory licence issued by the authorised body of the Republic of Cyprus.
Company QBF, located at the address: St. Petersburg, Maloohtinsky Prospekt, 64, lit. "B", R.V. Shpakov, V.S.
Pakhomov, Athanasiadou Linda and unidentified persons, acting in an organised group, jointly and in a
coordinated manner, organised the conclusion on behalf of the affiliated with the criminal community LLC
Investment Company QBF, Golubev A.S. and unidentified persons, acting as an organised group, jointly and
in concert, organised the conclusion of an agreement on the provision of trust management services with
Golovach A.V. on behalf of Investment Company QBF LLC, affiliated with the criminal community, under
agreement No. 2862 - 16/ISR dated 04.10.2016 and, under the pretext of fulfilling the terms of the said
agreement and contract, convinced the latter to transfer his funds to them, ostensibly for trust management.
- Golovach A.V., unaware of the crime being prepared and misled as to the true objectives of the participants of
the organised group - embezzlement of funds, believing that he invested his funds with the aim of making a
profit, which did not correspond to reality, being in the office of LLC "Investment Company QBF", located at
the address: St. Petersburg, Maloohtinsky Ave, 64, lit. "B", on 19.10.2016, at an unspecified time, he
Federation as of 19.10.2016 amounted to RUB 327,028 to the employees of QBF Group Company (QBF).
- In turn, R.V. Shpakov, V.S. Pakhomov, Athanasiadou Linda , A.S. Golubev and unidentified persons, acting as
organised the acceptance of the above - mentioned funds from A.V. Golovach, as a result of which, abusing
Shpakov R.V., Athanasiadou Linda, Golubev A.S. and unidentified persons, under the above circumstances,
106
deliberately, through deceit and breach of trust, on 19.10.2016 stole money belonging to Golovach A.V. in the
amount of 327,028 rubles, in a large amount.
namely:
organisations of the group, by means of deceit and abuse of trust, which consisted in creating in natural
persons - clients of the companies of the group a false appearance of the possibility of obtaining a high
income, persuaded clients to conclude agreements on rendering services on provision of a trading account
with the amount of funds on it in the amount of the amount of funds received from the client (agreements on
rendering brokerage services) and other investment contracts. These agreements and contracts were
association knew that the obligations to the clients to pay the funds were unfulfilled, since the information
about the brokerage activities of the organisation with which a particular client concluded the agreement or
contract was false. The co - conspirators did not use the money received from clients under these agreements
and contracts for the purposes specified in the agreements and contracts, but stole it and used it at their own
discretion.
107
- So on 30.05.2016, at an unspecified time, being in the office of LLC "Investment Company QBF" (INN
7733673955), located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, under the pretext of
organised the signing with Bruskov A.N. on behalf of a non - resident affiliated with the criminal association -
co - conspirators deceived Bruskov A.N. by concealing from him the information that this organisation had no
legal grounds to engage in the type of activity related to securities transactions, as it did not have the
the conclusion of an agreement on the provision of trust management services with Bruskov A.N. on behalf
- Bruskov A.N., unaware of the crime being prepared and misled as to the true objectives of the participants of
making a profit, which was not true, being in the office of LLC Investment Company QBF, located at the
address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, realised the transfer of cash to the employees of
QBF Group Company (QBF) as follows: 30.05.2016, at an unspecified time, in the amount of RUB 670,000;
amount of RUB 830,000; 10.11.2016, at an unspecified time, in the amount of RUB 570,000; 10.11.2016, at an
unspecified time, in the amount of RUB 1,030,000.
criminal intent, organised the acceptance of the above - mentioned funds from A.N. Bruskov, as a result of
- As a result, Pakhomov V.S., using his official position, acting as an organised group, jointly and in concert
with Shpakov R.V., Munayev Z.V., Athanasiadou L, Golubev A.S. and unidentified persons, under the above
circumstances, in the period from 30.05.2016 to 10.11.2016, deliberately, through deceit and breach of trust,
stole money belonging to Bruskov A.N. in the amount of 3,900,000 rubles, in an especially large amount.
namely:
108
unidentified persons acting in an organised group, jointly and in concert, organised the signing with Egudkin
B.A. on behalf of a non - resident affiliated with the criminal association, on behalf of a non - resident
affiliated with the criminal association, Golubev A.S. and unidentified persons, acting as an organised group,
jointly and in concert, organised the signing with Egudkin B.A. on behalf of a non - resident affiliated with the
criminal association - QB Capital CY LTD ("QB Capital CY LTD", registered in the Republic of Cyprus), of an
agreement on the provision of services of direct access to international stock markets No. 2799 - 16/ISR,
dated 01.09.2016. The co - conspirators deceived Yegudkin B.A. by concealing from him the information that
this organisation had no legal grounds to engage in the type of activity related to securities transactions, as it
did not have the relevant mandatory licence issued by the authorised body of the Republic of Cyprus.
- Continuing their criminal actions, on 29.09.2016, at an unspecified time, being in the office of LLC
"Investment Company QBF", located at the address: St. Petersburg, Maloohtinsky Prospekt, 64, lit. "B", R.V.
Shpakov, V.S. Pakhomov, Athanasiadou Linda and unidentified persons, acting in an organised group, jointly
and in a coordinated manner, organised the conclusion on behalf of the affiliated with the criminal
community LLC "Investment Company QBF", Golubev A.S. and unidentified persons, acting as an organised
group, jointly and in concert, organised the conclusion of an agreement on the provision of "Trust
109
Management" services with Egudkin B.A. on behalf of Investment Company QBF LLC, affiliated with the
criminal community, within the framework of agreement No. 2799 - 16/ISR dated 01.09.2016 and, under the
pretext of fulfilling the conditions of the said agreement and contract, convinced the latter to transfer his
- B.A. Yegudkin, unaware of the crime being prepared and misled as to the true objectives of the participants of
making a profit, which was not true, being in the office of LLC "QBF Investment Company" located at the
address: St. Petersburg, Maloohtinsky Prospe, 64, lit. "B", he transferred cash to the employees of QBF Group
Company (QBF) as follows: 29.09.2016, at an unspecified time, in the amount of RUB 1,980,000; 14.11.2016, at
an unspecified time, in the amount of RUB 8,400,000.
organised the acceptance of the above - mentioned funds from B.A. Egudkin, as a result of which, abusing his
- Continuing their criminal actions, in order to achieve a criminal result aimed at stealing the funds of Yegudkin
B.A., on 14.11.2016, at an unspecified time, being in the office of LLC "Investment Company QBF" (INN
7733673955), located at the address: St. Petersburg, Maloohtinsky Prospekt, 64, Lit. "B", under the pretext of
investing money in securities with high yield, Shpakov R.V., Athanasiadou Linda, and Pakhomov V.S,
Pakhomov V.S., Athanasiadou L, Golubev A.S. and unidentified persons, acting as an organised group, jointly
and in concert, organised the signing with Egudkin B.A. on behalf of a non - resident affiliated with the
criminal association - QB Capital CY LTD ("QB Capital CY LTD", registered in the Republic of Cyprus), of an
agreement on the provision of services of direct access to international stock markets No. 2918 - 16/ISR dated
14.11.2016. At the same time, the accomplices deceived Yegudkin B.A. by concealing from him the
information that this organisation did not have legal grounds to engage in the type of activity related to
transactions with securities, as it did not have the relevant mandatory licence issued by the authorised body
of the Republic of Cyprus.
group, jointly and in concert, organised the conclusion of an agreement on the provision of "Advisory
Management" services with Egudkin B.A. on behalf of Investment Company QBF LLC, affiliated with the
criminal community, under the agreement No. 2918 - 16/ISR dated 14.11.2016 and, under the pretext of
fulfilling the terms of the said agreement and contract, convinced the latter to transfer his funds to them,
- Yegudkin B.A., unaware of the crime that was being prepared and misled as to the true objectives of the
aim of making a profit, which did not correspond to reality, being in the office of LLC "Investment Company
QBF", located at the address: St. Petersburg, Maloohtinsky Prospe, 64, lit. "B", on 14.11.2016, at an
unspecified time, he transferred cash in the amount of 38,000 euros, which at the exchange rate of the
Central Bank of the Russian Federation as of 14.11.2016 was 2,702,940 rubles, to the employees of QBF Group
Company (QBF).
organised the acceptance of the above - mentioned funds from B.A. Egudkin, as a result of which, abusing his
110
deliberately, by deception and breach of trust, in the period from 29.09.2016 to 14.11.2016 stole money
belonging to Egudkin B.A. in the amount of 13,082,940 rubles, in an especially large amount.
- Thus, Pakhomov Vladimir Sergeevich committed fraud, i.e. thef of other people's property by deceit and
111
in securities with high yield, Shpakov R.V., Pakhomov V.S., Munaev Z.V., Athanasiadou Linda, Golubev A.S. and
Sasovskaya O.B. on behalf of a non - resident affiliated with the criminal association - QB Capital CY LTD ("QB
access to international stock markets No. 2311 - 15/IMR, dated 08.09.2015. The co - conspirators deceived
O.B. Sasovskaya by concealing from her the information that this organisation had no legal grounds to
agreement on trust management services with Sasovskaya O.B. on behalf of Kyubi Finance LLC, an affiliate of
the criminal association, under agreement No. 2311 - 15/IMR dated 08.09.2015 and, under the pretext of
fulfilling the terms of the said agreement and contract, convinced the latter to transfer her funds to them,
- O.B. Sasovskaya, unaware of the crime being prepared and misled as to the true objectives of the
the aim of making a profit, which was not true, being in the office of QBF LLC located at 8 Presnenskaya
group company as follows. 1, realised the transfer of cash to the employees of QBF Group Company (QBF) as
follows: 22.09.2015, at an unspecified time, in the amount of RUB 500,000; 18.11.2016, at an unspecified time,
in the amount of RUB 500,000.
criminal intent, organised the acceptance of the above - mentioned funds from O.B. Sasovskaya, as a result
circumstances, deliberately, through deceit and abuse of trust, in the period from 22.09.2015 to 18.11.2016,
stole money belonging to Sasovskaya O.B. in the amount of 1,000,000 rubles, in a large amount.
- Thus, Vladimir Sergeevich Pakhomov committed fraud, i.e. thef of other people's property by deceit and
namely:
112
criminal association, R.V. Shpakov, V.S. Pakhomov and S.A. Matyukhin, using their official positions in the
client (agreements on rendering brokerage services) and other investment contracts. These agreements and
organised the signing with Sazonova I.O. on behalf of a non - resident affiliated with the criminal association -
co - conspirators deceived I.O. Sazonova by concealing from her the information that this organisation did
the conclusion of an agreement on the provision of trust management services with Sazonova I.O. on behalf
- I.O. Sazonova, unaware of the crime being prepared and misled as to the true objectives of the participants
making a profit, which was not true, on 11.05.2016, at an unspecified time, being in the office of LLC
Investment Company QBF, located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1,
113
Federation as of 11.05.2016 amounted to RUB 1,326,600 to the employees of QBF Group Company (QBF), and
also on 25.11.2016, at an unspecified time, being in the premises of Aventura shopping centre located at:
Moscow, mkr. 1 "A", Severnoe Chertanovo, Moscow, she handed over cash in the amount of 20,000 euros to
the employees of QBF Group (QBF), which at the exchange rate of the Central Bank of the Russian Federation
as of 25.11.2016 amounted to RUB 1,361,800.
criminal intent, organised the acceptance of the above - mentioned funds from I.O. Sazonova, as a result of
which, abusing her trust, they received them at their disposal, i.e. took possession of the stolen funds.
with Shpakov R.V., Munayev Z.V., Athanasiadou L, Golubev A.S. and unidentified persons, under the above
circumstances, in the period from 11.05.2016 to 25.11.2016, deliberately, through deceit and breach of trust,
stole money belonging to Sazonova I.O. in the amount of 2,688,400 rubles, in an especially large amount.
namely:
114
in the criminal association knew that the obligations to the clients to pay the funds were unfulfilled, since the
Dychenko E.V. on behalf of a non - resident affiliated with the criminal association, Golubev A.S. and
D'chenko E.V. on behalf of a non - resident affiliated with the criminal association - QB Capital CY LTD (QB
Capital CY LTD, registered in the Republic of Cyprus), of an agreement on the provision of services of direct
access to international stock markets No. 3025 - 17/ISR dated 26.01.2017. At the same time, the co -
conspirators deceived E.V. Dychenko by concealing from her the information that this organisation did not
have legal grounds to engage in the type of activity related to the execution of transactions with securities, as
Pakhomov, Athanasiadou Linda and unidentified persons, acting in an organised group, jointly and in a
coordinated manner, organised the conclusion on behalf of the affiliated with the criminal community LLC
Investment Company QBF, Golubev A.S. and unidentified persons, acting as an organised group, jointly and
in concert, organised the conclusion of an agreement on the provision of "Trust Management" services with
Dychenko E.V. on behalf of Investment Company QBF LLC, affiliated with the criminal community, under the
agreement No. 3025 - 17/ISR dated 26.01.2017 and, under the pretext of fulfilling the terms and conditions of
the said agreement and contract, convinced the latter to transfer her funds to them, ostensibly for trust
management.
- E.V. Dychenko, unaware of the crime being prepared and misled as to the true objectives of the participants
of the organised group - embezzlement of funds, believing that she invests her funds for profit, which was not
true, being in the office of LLC "Investment Company QBF", located at the address: St. Petersburg,
Maloohtinsky Ave, 64, lit. "B", on 31.01.2017, at an unspecified time, she transferred cash in the amount of
RUB 5,000,000 to the employees of QBF Group Company (QBF).
organised the acceptance of the above - mentioned funds from E.V. Dychenko, as a result of which, abusing
her trust, they received them at their disposal, i.e. took possession of the stolen funds.
deliberately, by deception and breach of trust, on 31.01.2017 stole money belonging to Dychenko E.V. in the
115
namely:
organised the signing with Ermakov V.V. on behalf of a non - resident affiliated with the criminal association -
116
provision of services of direct access to international stock markets No. 2452 - 15/IMR, dated 23.12.2015. The
co - conspirators deceived V.V. Ermakov by concealing from him the information that this organisation had no
Finance, located at: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, Shpakov R.V., Pakhomov V.S., Munaev Z.V.,
Athanasiadou Linda 1, Shpakov R.V., Pakhomov V.S., Munaev Z.V., Athanasiadou L, Golubev A.S. and
unidentified persons, acting as an organised group, jointly and in concert, organised the conclusion of an
agreement on the provision of trust management services with Ermakov V.V. on behalf of Kyubi Finance LLC,
affiliated with the criminal association, under agreement No. 2452 - 15/IMR dated 23.12.2015 and, under the
- V.V. Ermakov, unaware of the crime that was being prepared and misled as to the true objectives of the
participants of the organised group - embezzlement of funds, believing that he was investing his funds in
order to make a profit, which was not true, being in the office of QBF LLC, located at 8 Presnenskaya
group company as follows. 1, realised the transfer of cash to employees of QBF Group Company (QBF) as
follows: 24.12.2015, at an unspecified time, in the amount of USD 10,000, which at the exchange rate of the
Central Bank of the Russian Federation as of 24.12.2015 was RUB 709,300; 31.01.2017, at an unspecified time,
31.01.2017 was RUB 330,880.
criminal intent, organised the acceptance of the above - mentioned funds from V.V. Ermakov, as a result of
deliberately, through deceit and breach of trust, stole money belonging to Ermakov V.V. in the amount of
namely:
117
Cherkasov V.Y., on behalf of a non - resident affiliated with the criminal association, on behalf of the criminal
association, Golubev A.S. and unidentified persons, acting as an organised group, jointly and in concert,
organised the signing with Cherkasov V.Y. on behalf of a non - resident affiliated with the criminal association
- QB Capital CY LTD ("QB Capital CY LTD", registered in the Republic of Cyprus), of an agreement on the
provision of services of direct access to international stock markets No. 3315 - 17/ISR dated 21.07.2017. The
accomplices deceived V.Y. Cherkasov by concealing from him the information that this organisation had no
Pakhomov, Athanasiadou Linda and unidentified persons acting in an organised group, jointly and in
concert, organised the conclusion on behalf of the affiliated with the criminal community LLC Investment
Company QBF, Golubev A.S. and unidentified persons, acting as an organised group, jointly and in concert,
organised the conclusion of an agreement on the provision of "Trust Management" services with Cherkasov
V.Y. on behalf of Investment Company QBF LLC, affiliated with the criminal community, within the framework
of agreement No. 3315 - 17/ISR dated 21.07.2017 and, under the pretext of fulfilling the terms of the said
agreement and contract, persuaded the latter to transfer his funds to them, ostensibly for trust management.
118
- Cherkasov V.Y., unaware of the crime being prepared and misled as to the true objectives of the participants
of the organised group - embezzlement of funds, believing that he invested his funds with the aim of making
a profit, which did not correspond to reality, being in the office of LLC "Investment Company QBF", located at
Federation as of 21.07.2017 amounted to RUB 4,135,600 to the employees of QBF Group Company (QBF).
organised the acceptance of the above - mentioned funds from V.Y. Cherkasov, as a result of which, abusing
deliberately, through deceit and breach of trust, on 21.07.2017 stole money belonging to Cherkasov V.Y. in the
namely:
119
discretion.
unidentified persons acting in an organised group, jointly and in concert, organised the signing with Mullo
T.I., on behalf of a non - resident affiliated with the criminal association, of a non - resident, Golubev A.S. and
unidentified persons, acting as an organised group, jointly and in concert, organised the signing of an
26.05.2016 with Mullo T.I. on behalf of the non - resident company QB Capital CY LTD (QB Capital CY LTD,
registered in the Republic of Cyprus), affiliated with the criminal association. At the same time, the
accomplices deceived Mullo T.I. by concealing from him the information that this organisation did not have
legal grounds to engage in the type of activity related to the execution of transactions with securities, as it did
not have the relevant mandatory licence issued by the authorised body of the Republic of Cyprus.
group, jointly and in concert, organised the conclusion of an agreement on the provision of trust
management services with Mullo T.I. on behalf of QBIF Investment Company LLC, affiliated with the criminal
community, under agreement No. 2660 - 16/ISR dated 26.05.2016 and, under the pretext of fulfilling the terms
of the said agreement and contract, persuaded the latter to transfer his funds to them, ostensibly for trust
management.
- Mullo T.I., unaware of the crime being prepared and misled as to the true objectives of the participants of the
organised group - embezzlement of funds, believing that he invested his funds with the aim of making a
the address: St. Petersburg, Maloohtinsky Prospe, 64, lit. "B", he transferred cash to the employees of QBF
Group Company (QBF) as follows: on 08.06.2016, at an unspecified time, in the amount of RUB 670,000; on
organised the acceptance of the above - mentioned funds from T.I. Mullo, as a result of which, abusing his
- Continuing their criminal actions, in order to achieve a criminal result aimed at embezzlement of funds,
Mullo T.I., Shpakov R.V., Pakhomov V.S., Athanasiadou Linda, Golubev A.S., S.A. Matyukhin and unidentified
criminal intent, under the pretext of fulfilling the terms of the above agreement and contract, under
unspecified circumstances, persuaded Mullo T.I. to transfer additional funds to them, ostensibly for trust
management.
120
profit, which did not correspond to reality, being in the office of LLC Investment Company QBF, located at the
address: St. Petersburg, Maloohtinsky Prospe, 64, lit. "B", on 14.08.2017, at an unspecified time, he
transferred cash in the amount of RUB 1,800,000 to the employees of QBF Group Company (QBF).
- In turn, R.V. Shpakov, V.S. Pakhomov, Athanasiadou Linda , A.S. Golubev, S.A. Matyukhin and unidentified
criminal intent, organised the acceptance of the above - mentioned funds from T.I. Mullo, as a result of which,
abusing his trust, they received them at their disposal, i.e. took possession of the stolen funds.
- Not resting on their laurels, continuing their criminal actions, in order to achieve a criminal result aimed at
stealing the funds of Mullo T.I., on 10.08.2017, at an unspecified time, being in the office of LLC "Investment
Company QBF" (INN 7733673955), located at the address: St. Petersburg, Maloohtinsky Prospekt, 64, Lit. "B",
under the pretext of investing money in securities with high yield, Shpakov R.V, Pakhomov V.S., Athanasiadou
Linda, Golubev A.S., S.A. Matyukhin and unidentified persons, acting as an organised group, jointly and in
concert, organised the signing with T.I. Mullo, on behalf of a non - resident affiliated with the criminal
association - QB Capital CY LTD (QB Capital CY LTD, registered in the Republic of Cyprus), of an agreement on
the provision of direct access services to international stock markets No. 3341 - 17/ISR dated 10.08.2017. At
the same time, the accomplices deceived Mullo T.I. by concealing from him the information that this
organisation did not have legal grounds to engage in the type of activity related to transactions with
securities, as it did not have the relevant mandatory licence issued by the authorised body of the Republic of
Cyprus.
Company QBF, located at the address: St. Petersburg, Maloohtinsky Prospekt, 64, lit. "B", Shpakov R.V.,
Pakhomov V.S., Athanasiadou Linda, Golubev A.S., S.A. Matyukhin and unidentified persons, acting as an
organised group, jointly and in concert, organised the conclusion of an agreement on the provision of
"Advisory Management" services under Agreement No. 3341 - 17/ISR dated 10.08.2017 with T.I. Mullo on
behalf of QBIF Investment Company LLC, affiliated with the criminal association, and under the pretext of
the address: St. Petersburg, Maloohtinsky Prospe, 64, lit. "B", on 10.08.2017, at an unspecified time, he
criminal intent, organised the acceptance of the above - mentioned funds from T.I. Mullo, as a result of which,
Shpakov R.V., Athanasiadou Linda, Golubev A.S., S.A. Matyukhin and unidentified persons, under the
circumstances described above, deliberately, through deceit and breach of trust, in the period from
08.06.2016 to 14.08.2017, stole money belonging to Mullo T.I. in the amount of 4,970,000 rubles, in an
especially large amount.
namely:
121
investing money in securities with high yield, Shpakov R.V., Pakhomov V.S., Athanasiadou Linda, Golubev
A.S., S.A. Matyukhin and unidentified persons, acting as an organised group, jointly and in concert, organised
the signing with Y.V. Maslov on behalf of a non - resident affiliated with the criminal association - QB Capital
CY LTD ("QB Capital CY LTD", registered in the Republic of Cyprus), of an agreement on the provision of
services of direct access to international stock markets No. 3354 - 17/ISR dated 17.08.2017. The co -
conspirators deceived Maslov Y.V. by concealing from him the information that this organisation had no legal
122
organised group, jointly and in concert, organised the conclusion of an agreement on the provision of trust
management services with Y.V. Maslov on behalf of QBIF Investment Company LLC, affiliated with the
criminal association, within the framework of agreement No. 3354 - 17/ISR dated 17.08.2017 and, under the
pretext of fulfilling the terms of the said agreement and contract, convinced the latter to transfer his funds to
- Maslov Y.V., unaware of the crime being prepared and misled as to the true objectives of the participants of
transferred cash to the employees of QBF Group Company (QBF) as follows: in the amount of USD 400,000,
which at the exchange rate of the Central Bank of the Russian Federation as of 17.08.2017 amounted to RUB
23,860,000; in the amount of EUR 300,000, which at the exchange rate of the Central Bank of the Russian
Federation as of 17.08.2017 amounted to RUB 21,000,000; in the amount of RUB 6,000,000.
criminal intent, organised the acceptance of the above - mentioned funds from Y.V. Maslov, as a result of
Shpakov R.V., Athanasiadou Linda, Golubev A.S., Matyukhin S.A. and unidentified persons, under the above
circumstances, deliberately, through deceit and abuse of trust, on 17.08.2017 stole money belonging to
Maslov Y.V. in the amount of 50,860,000 rubles, in an especially large amount.
namely:
123
located at the address: Moscow, Presnenskaya naberezhnaya, 8, p. 1. 1, under the pretext of investing money
in securities with high yield, Shpakov R.V., Pakhomov V.S., Munaev Z.V., and unidentified persons, acting as an
organised group, jointly and in concert, organised the signing with Velichko S.A. on behalf of a non - resident
affiliated with the criminal association - QB Capital CY LTD ("QB Capital CY LTD", registered in the Republic of
Cyprus), of an agreement on direct access to the US securities market No. 964 - 13/VR dated 10.04.2013. The
co - conspirators deceived Velichko S.A. by concealing from him the information that this organisation had no
Finance, located at the address: Moscow, Presnenskaya Naberezhnaya, 8, bld. 1, R.V. Shpakov, V.S. Pakhomov,
Z.V. Munayev and unidentified persons, acting as an organised group, jointly and in concert, organised the
conclusion of an agreement on the provision of trust management services with S.A. Velichko on behalf of
Qube Finance LLC, affiliated with the criminal association, within the framework of agreement No. 964 -
13/VR of 10.04.2013, and, under the pretext of fulfilling the terms and conditions of the said agreement and
contract, persuaded the latter to transfer his funds to them, ostensibly for trust management.
- Velichko S.A., unaware of the crime that was being prepared and misled as to the true goals of the
participants of the organised group - embezzlement of funds, believing that he invested his funds for the
purpose of making profit, which did not correspond to reality, on 11.04.2013 made a transfer of funds from
his account No. 42306840400320000249, opened in the branch of OTP Bank OJSC, located at the address:
Moscow, Zemlyanoy Val str. 46, to the account of "QB Capital CY LTD" No.
CY1700800170000000000000000000688040 opened with "Piraeus Bank" ("Piraeus Bank", Republic of Cyprus)
11.04.2013 amounted to 341,000 roubles, and also, being in the office of LLC "QB Finance", located at the
address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, on 27.08.2013, on 27.08.2013, being in the office of
LLC "QB Finance", located at the address: Moscow, Presnenskaya Naberezhnaya, 8, bld. 1, on 27.08.2013, at
an unspecified time, he transferred cash in the amount of USD 10,000, which at the exchange rate of the
124
Central Bank of the Russian Federation as of 27.08.2013 amounted to RUB 329,600, to the employees of QBF
Group (QBF).
jointly and in concert, with the involvement of persons unaware of the criminal intent, having received
Velichko S.A.'s money at their disposal, abused his trust and stole the money.
- Continuing their criminal actions, in order to achieve a criminal result aimed at stealing money Velichko S.A.,
Shpakov R.V., Pakhomov V.S., Munaev Z.V. and unidentified persons, acting in an organised group, jointly and
in a coordinated manner, involving persons unaware of the criminal intent, under the pretext of fulfilling the
terms of the aforementioned agreement, Athanasiadou Linda and unidentified persons, acting as an
organised group, jointly and in concert, with the involvement of persons unaware of the criminal intent,
under the pretext of fulfilling the terms of the above agreement and contract, under unspecified
circumstances, convinced Velichko S.A. to transfer additional funds to them, ostensibly for trust
management.
- Velichko S.A., unaware of the crime being prepared and misled as to the true objectives of the members of
making a profit, which was not true, being in the office of QBF LLC located at the address: Moscow,
19.05.2014 amounted to RUB 208,680 to the employees of QBF Group Company (QBF).
organised the acceptance of the above - mentioned funds from S.A. Velichko, as a result of which, abusing his
- Not stopping there, continuing their criminal actions, in order to achieve a criminal result aimed at stealing
money Velichko S.A., Shpakov R.V., Pakhomov V.S., Munaev Z.V., Athanasiadou Linda, Golubev A.S., S.A.
Matyukhin and unidentified persons, acting as an organised group, jointly and in concert, with the
agreement and contract, under unspecified circumstances, convinced S.A. Velichko to transfer additional
- Velichko S.A., unaware of the crime being prepared and misled as to the true objectives of the participants of
time, he transferred cash in the amount of USD 5,000, which at the exchange rate of the Central Bank of the
Russian Federation as of 28.08.2017 amounted to RUB 295,750 to the employees of QBF Group Company
(QBF).
- In turn, R.V. Shpakov, V.S. Pakhomov, Z.V. Munayev, Athanasiadou Linda , A.S. Golubev, S.A. Matyukhin and
unaware of the criminal intent, organised the acceptance of the above - mentioned funds from S.A. Velichko,
as a result of which, having abused his trust, they received them at their disposal, i.e. took possession of the
stolen funds.
with Shpakov R.V., Munayev Z.V., Athanasiadou Linda, Golubev A.S., S.A. Matyukhin and unidentified persons,
under the above circumstances, in the period from 11.04.2013 to 28.08.2017, deliberately, through deceit and
breach of trust, stole money belonging to S.A. Velichko in the amount of 1,175,030 rubles, in an especially
large amount.
125
namely:
7733673955), located at the address: St. Petersburg, Maloohtinsky Prospekt, 64, Lit. "B", under the pretext of
A.S., Matyukhin S.A., and unidentified persons acting in an organised group, jointly and in concert, organised
the signing with Gumenyuk D.V. on behalf of a non - resident affiliated with the criminal association, Rossieva
E.A. and unidentified persons, acting as an organised group, jointly and in concert, organised the signing with
126
Gumenyuk D.V. on behalf of a non - resident affiliated with the criminal association - QCCI LTD ("QCCI LTD",
registered in the Republic of Cyprus), of an agreement on the provision of direct access services to
international stock markets No. 3408 - 17/ISR dated 13.09.2017. At the same time, the accomplices deceived
D.V. Gumenyuk by concealing from him the information that this organisation did not have legal grounds to
engage in the type of activity related to securities transactions, as it did not have the relevant mandatory
Pakhomov, Athanasiadou Linda , A.S. Golubev, S.A. Matyukhin and unidentified persons acting in an
organised group, jointly and in concert, organised the conclusion of a contract on behalf of the criminal
affiliated LLC Investment Company QBF, Rossieva E.A. and unidentified persons, acting as an organised
management services with Gumenyuk D.V. on behalf of QBIF Investment Company LLC, affiliated with the
criminal association, under agreement No. 3408 - 17/ISR dated 13.09.2017 and, under the pretext of fulfilling
the terms of the said agreement and contract, persuaded the latter to transfer his funds to them, ostensibly
for trust management.
- Gumenyuk D.V., unaware of the crime that was being prepared and misled as to the true objectives of the
the aim of making a profit, which was not true, being in the office of LLC "QBF Investment Company" located
at the address: St. Petersburg, Maloohtinsky Prospe, 64, lit. "B", realised the transfer of cash to the employees
of QBF Group Company (QBF) as follows: 15.09.2017, at an unspecified time, in the amount of USD 30,000,
which at the exchange rate of the Central Bank of the Russian Federation as of 15.09.2017 was RUB 1,733,100;
- In turn, R.V. Shpakov, V.S. Pakhomov, Athanasiadou Linda , A.S. Golubev, S.A. Matyukhin, E.A. Rossieva and
unaware of the criminal intent, organised the acceptance of the aforementioned funds from D.V. Gumenyuk,
stolen funds.
with Shpakov R.V., Athanasiadou Linda, Golubev A.S., Matyukhin S.A., Rossieva E.A. and unidentified persons,
breach of trust, stole money belonging to Gumenyuk D.V. in the amount of 2,891,900 rubles, in an especially
large amount.
namely:
127
discretion.
investing funds in securities with high yields, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda ,
A.S. Golubev, S.A. Matyukhin, Rossieva E.A. and unidentified persons, acting in an organised group, jointly
and in concert, organised the signing of an agreement on the provision of direct access to international stock
markets No. 3663 - 17/IMR dated 11.10.2017 with Kholodkov S.V. on behalf of a non - resident company QCCI
LTD ("QCCI LTD", registered in the Republic of Cyprus), affiliated with the criminal association. The co -
conspirators deceived Kholodkov S.V. by concealing from him the information that this organisation had no
Company QBF, located at: Moscow, Presnenskaya naberezhnaya, 8, p. 1, Shpakov R.V., Pakhomov V.S.,
Munaev Z.V., Athanasiadou Linda, Golubev A.S., Matyukhin S.S. 1, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev,
Athanasiadou Linda , A.S. Golubev, S.A. Matyukhin, Rossieva E.A. and unidentified persons, acting as an
management services with Kholodkov S.V. on behalf of QBIF Investment Company LLC, affiliated with the
criminal association, under agreement No. 3663 - 17/IMR dated 11.10.2017 and, under the pretext of fulfilling
128
- Kholodkov S.V., unaware of the crime being prepared and misled as to the true objectives of the participants
of the organised group - embezzlement of funds, believing that he was investing his funds in order to make a
profit, which was not true, being in the office of LLC Investment Company QBF, located at the address:
Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, on 11.10.2017, at an unspecified time, transferred cash in the
amount of RUB 2,600,000 to employees of QBF Group Company (QBF).
- In turn, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda , A.S. Golubev, S.A. Matyukhin, E.A.
Rossieva and unidentified persons, acting as an organised group, jointly and in concert, with the involvement
of persons unaware of the criminal intent, organised the acceptance of the above - mentioned funds from S.V.
Kholodkov, as a result of which, having abused his trust, they received them at their disposal, i.e. took
- As a result, Pakhomov V.S., using his official position, acting as an organised group, jointly and in
coordination with Shpakov R.V., Munayev Z.V., Athanasiadou Linda, Golubev A.S., Matyukhin S.A., Rossieva
E.A. and unidentified persons, under the circumstances described above, deliberately, through deceit and
breach of trust, on 11.10.2017 stole money belonging to Kholodkov S.V. in the amount of 2,600,000 rubles, in
an especially large amount.
namely:
129
knew that the obligations to the clients to pay the funds were unfulfilled, as the information about the
discretion.
in securities with high yield, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda , A.S. Golubev,
and A.S, Golubev A.S. and unidentified persons, acting in an organised group, jointly and in concert,
organised the signing with Grigoriev A.B. on behalf of a non - resident affiliated with the criminal association -
provision of services of direct access to international stock markets No. 2348 - 15/IMR, dated 08.10.2015. The
co - conspirators deceived Grigoriev A.B. by concealing from him the information that this organisation did
agreement on the provision of trust management services with Grigoriev A.B. on behalf of Kyubi Finance LLC,
an affiliate of the criminal association, under agreement No. 2348 - 15/IMR dated 08.10.2015 and, under the
- Grigoriev A.B., unaware of the forthcoming crime and misled as to the true objectives of the participants of
Presnenskaya Naberezhnaya, 8, p. 1. 1, carried out the transfer of cash to employees of QBF Group Company
(QBF) as follows: 09.10.2015, at an unspecified time, in the amount of RUB 1,640,000 and USD 20,000, which
at the exchange rate of the Central Bank of the Russian Federation as of 09.10.2015 was RUB 1,245,800;
26.09.2016 was RUB 957,900.
criminal intent, organised the acceptance of the above - mentioned funds from A.B. Grigoriev, as a result of
- Continuing their criminal actions, in order to achieve a criminal result aimed at stealing A.B. Grigoriev's
money, on 08.07.2016, at an unspecified time, being in the office of LLC "Investment Company QBF" (INN
7733673955), located at: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, under the pretext of investing money
in securities with high yield, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda , under the
130
pretext of investing in securities with high yields. 1, under the pretext of investing funds in securities with
high yields, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda and A.S. Golubev, Golubev A.S.
and unidentified persons, acting in an organised group, jointly and in concert, organised the signing with
Grigoriev A.B. on behalf of a non - resident affiliated with the criminal association - QB Capital CY LTD ("QB
access to international stock markets No. 2709 - 16/IMR, dated 05.07.2016. The co - conspirators deceived
Grigoriev A.B. by concealing from him the information that this organisation had no legal grounds to engage
in the type of activity related to securities transactions, as it did not have the relevant mandatory licence
Company QBF, located at the address: Moscow, Presnenskaya naberezhnaya, 8, p. 1. 1, R.V. Shpakov, V.S.
Pakhomov, Z.V. Munaev, Athanasiadou Linda , A.S. Golubev, and unidentified persons, acting as an organised
group, jointly and in concert, organised the conclusion of an agreement on the provision of "Advisory
Management" services under Agreement No. 2709 - 16/IMR dated 05.07.2016 with A.B. Grigoriev on behalf of
QBIF Investment Company LLC, an affiliate of the criminal association.
- Grigoriev A.B., unaware of the crime being prepared and misled as to the true objectives of the participants of
Russian Federation as of 08.07.2016 amounted to RUB 1,088,850 to the employees of QBF Group Company
(QBF).
criminal intent, organised the acceptance of the above - mentioned funds from A.B. Grigoriev, as a result of
- Continuing their criminal actions, in order to achieve a criminal result aimed at stealing money Grigorieva
A.B., Shpakov R.V., Pakhomov V.S., Munaev Z.V., Athanasiadou Linda, Golubev A.S., Matyukhin S.A., E.A.
of persons unaware of the criminal intent, under the pretext of fulfilling the conditions of the above
agreements and contracts, under unspecified circumstances, persuaded A.B. Grigoriev of the need for an
additional transfer of his funds to them, ostensibly for trust management.
- Grigoriev A.B., unaware of the crime being prepared and misled as to the true objectives of the members of
address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, on 16.10.2017, at an unspecified time, made a cash
transfer in the amount of USD 26,000, which at the exchange rate of the Central Bank of the Russian
Federation as of 16.10.2017 amounted to RUB 1,498,120.
of persons unaware of the criminal intent, organised the acceptance of the above money from A.B. Grigoriev,
stolen funds.
Shpakov R.V., Munayev Z.V., Athanasiadou Linda, Golubev A.S., Matyukhin S.A., Rossieva E.A. and unidentified
persons, under the above circumstances, in the period from 09.10.2015 to 16.10.2017, deliberately, through
deceit and breach of trust, stole money belonging to Grigoriev A.B. in the amount of 8,494,970 rubles, in an
131
namely:
- Thus on 18.09.2017, at an unspecified time, being in the office of LLC "Investment Company QBF" (INN
132
A.S. Golubev, S.A. Matyukhin, Rossieva E.A. and unidentified persons, acting as an organised group, jointly
and in concert, organised the signing with Nikitchenko N.V., on behalf of a non - resident affiliated with the
criminal association - QCCI LTD ("QCCI LTD", registered in the Republic of Cyprus), of an agreement on the
provision of direct access services to international stock markets No. 3412 - 17/IMR dated 18.09.2017. The co -
conspirators deceived Nikitchenko N.V. by concealing from him the information that this organisation did not
Company QBF, located at: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, Shpakov R.V., Pakhomov V.S.,
management services with Nikitchenko N.V. on behalf of Investment Company QBF LLC, affiliated with the
criminal association, under the agreement No. 3412 - 17/IMR dated 18.09.2017 and, under the pretext of
- Nikitchenko N.V., unaware of the crime being prepared and misled as to the true objectives of the
participants of the organised group - embezzlement of funds, believing that he was investing his funds for
Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, realised the transfer of cash to the employees of QBF Group
exchange rate of the Central Bank of the Russian Federation as of 21.09.2017 was RUB 581,300; 21.09.2017, at
an unspecified time, in the amount of EUR 8,500, which at the exchange rate of the Central Bank of the
USD 5,000, which at the exchange rate of the Central Bank of the Russian Federation as of 27.10.2017 was
RUB 288,850.
of persons unaware of the criminal intent, organised the acceptance of the above money from N.V.
Nikitchenko, as a result of which, having abused his trust, they received them at their disposal, i.e. took
with Shpakov R.V., Munayev Z.V., Athanasiadou Linda, Golubev A.S., Matyukhin S.A., Rossieva E.A. and
deliberately, through deceit and breach of trust, stole money belonging to Nikitchenko N.V. in the amount of
namely:
133
and in concert, organised the signing with Zinoviev S.D., on behalf of a non - resident affiliated with the
conspirators deceived S.D. Zinoviev by concealing from him the information that this organisation had no
organised group, jointly and in concert, organised the conclusion of an assignment agreement No. 4198
dated 23.01.2018 with Zinoviev S.D. on behalf of QBF Advisery LLC (INN 7703426941), affiliated with the
134
criminal association, and, under the pretext of fulfilling the terms of the above agreement and contract,
convinced the latter to transfer his funds to them ostensibly for trust management.
- Zinoviev S.D., unaware of the crime being prepared and misled as to the true objectives of the participants of
(QBF).
of persons unaware of the criminal intent, organised the acceptance of the above money from S.D. Zinoviev,
stolen funds.
- As a result, Pakhomov V.S., using his official position, acting in an organised group, jointly and in
breach of trust, on 21.11.2017 stole money belonging to Zinoviev S.D. in the amount of 1,778,100 rubles, in an
- He (Pakhomov V.S.) committed fraud, i.e. thef of other people's property by deception and malicious breach
of trust, committed by a person using his official position, by an organised group, on a particularly large
scale, namely:
135
organised the signing with Lomov S.N. on behalf of a non - resident affiliated with the criminal association -
co - conspirators deceived Lomov S.N. by concealing from him the information that this organisation had no
Company QBF, located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, Shpakov R.V., Pakhomov
V.S., Munaev Z.V., Athanasiadou Linda 1, Shpakov R.V., Pakhomov V.S., Munaev Z.V., Athanasiadou Linda,
conclusion of an agreement on the provision of trust management services with Lomov S.N. on behalf of
QBIF Investment Company LLC, affiliated with the criminal association, under the agreement No. 2965 -
16/IMR dated 12.12.2016, and, under the pretext of fulfilling the terms of the said agreement and contract,
convinced the latter to transfer his funds to them, ostensibly for trust management.
- Lomov S.N., unaware of the crime that was being prepared and misled as to the true objectives of the
members of the organised group - thef of funds, believing that he was investing his funds with the aim of
making a profit, which was not true, being in the office of QBF Investment Company LLC, located at 8
employees of QBF Group Company (QBF) as follows. 1, realised the transfer of cash to the employees of QBF
Group Company (QBF) as follows: 13.12.2016, at an unspecified time, in the amount of USD 10,000, which at
the exchange rate of the Central Bank of the Russian Federation as of 13.12.2016 was RUB 615,800;
Bank of the Russian Federation as of 27.12.2016 was RUB 609,100; 03.02.2017, at an unspecified time, in the
03.02.2017 was RUB 599,900; 10.03.2017, at an unspecified time, in the amount of USD 10,000, which at the
exchange rate of the Central Bank of the Russian Federation as of 10.03.03.2017 was RUB 588,318; 11.04.2017,
at an unspecified time, in the amount of USD 10,000, which at the exchange rate of the Central Bank of the
136
RUB 510,840; 20.06.2017, at an unspecified time, in the amount of USD 1,900, which at the exchange rate of
the Central Bank of the Russian Federation as of 20.06.2017 was RUB 110,124.
criminal intent, organised the acceptance of the above - mentioned funds from S.N. Lomov, as a result of
- Continuing their criminal actions, in order to achieve a criminal result aimed at embezzlement of funds
Lomova S.N., Shpakov R.V., Pakhomov V.S., Munaev Z.V., Athanasiadou Linda, Golubev A.S., Matyukhin S.A.,
E.A. Rossieva and unidentified persons, acting as an organised group, jointly and in concert, with the
agreement and contract, under unspecified circumstances, persuaded S.N. Lomov to transfer additional
- Lomov S.N., unaware of the crime being prepared and misled as to the true objectives of the participants of
the organised group - embezzlement of funds, believing that he invested his funds with the aim of making
profit, which was not true, on 12.12.2017 made a transfer of funds from his account No.
40817840040000131156 opened in the additional office of PJSC "Promsvyazbank" located at 21
Dolgorukovskaya Street, page 1, Moscow to the account No. 40817840040000131156 opened with Alpen
Baruch Bank LTD (Alpen Baruch Bank LTD). 1, to QCCI LTD account No. 0127031002 opened with Alpen Baruch
Bank LTD (Republic of Vanuatu) in the amount of USD 95,000, which at the exchange rate of the Central Bank
of the Russian Federation as of 12.12.2017 amounted to RUB 5,626,850.
of persons unaware of the criminal intent, having received Lomov S.N.'s money at their disposal, abused his
trust and stole the money.
deliberately, through deceit and breach of trust, stole money belonging to Lomov S.N. in the amount of
namely:
137
following address: 8 Presnenskaya Naberezhnaya Embankment, bld. 1, Moscow. 1.
A.S., S.A. Matyukhin and unidentified persons, acting as an organised group, jointly and in concert, organised
the signing with V.V. Nemtsev, on behalf of a non - resident affiliated with the criminal association - QB
Capital CY LTD ("QB Capital CY LTD", registered in the Republic of Cyprus), of an agreement on the provision of
services of direct access to international stock markets No. 3356 - 17/ISR dated 17.08.2017. The co -
conspirators deceived V.V. Nemtsev by concealing from him the information that this organisation had no
management services with V.V. Nemtsev on behalf of QBIF Investment Company LLC, affiliated with the
criminal association, under the agreement No. 3356 - 17/ISR dated 17.08.2017 and, under the pretext of
fulfilling the terms of the said agreement and the contract, convinced the latter to transfer his funds to them,
- V.V. Nemtsev, unaware of the crime that was being prepared and misled as to the true objectives of the
aim of making a profit, which did not correspond to reality, being in the office of LLC Investment Company
QBF, located at the address: St. Petersburg, Maloohtinsky Prospe, 64, lit. "B", on 17.08.2017, at an unspecified
138
(QBF).
criminal intent, organised the acceptance of the above - mentioned funds from V.V. Nemtsev, as a result of
- Continuing their criminal actions, in order to achieve a criminal result aimed at stealing money Nemtseva
V.V., Shpakov R.V., Pakhomov V.S., Athanasiadou Linda, Golubev A.S., Matyukhin S.A., E.A. Rossieva and
under unspecified circumstances, persuaded V.V. Nemtsev to transfer additional funds to them, ostensibly for
trust management.
- V.V. Nemtsev, unaware of the crime being prepared and misled as to the true objectives of the participants of
unaware of the criminal intent, organised the acceptance of the above - mentioned funds from V.V. Nemtsev,
stolen funds.
breach of trust, stole money belonging to Nemtsev V.V. in the amount of 6,556,400 rubles, in an especially
large amount.
namely:
139
7733673955), located at the address: St. Petersburg, Degtyarny per. 11, lit. "B", under the pretext of investing
money in securities with high yield, Shpakov R.V., Pakhomov V.S., Athanasiadou Linda, Golubev A.S.,
Matyukhin S.A., Rossieva E.A. and unidentified persons, acting as an organised group, jointly and in concert,
organised the signing with Novitsky A.G. on behalf of a non - resident affiliated with the criminal association -
QCCI LTD ("QCCI LTD", registered in the Republic of Cyprus), of an agreement on the provision of direct access
services to international stock markets No. 4130 - 17/ISR, dated 08.11.2017. The co - conspirators deceived
A.G. Novitsky by concealing from him the information that this organisation had no legal grounds to engage
in activities related to securities transactions, as it did not have the relevant mandatory licence issued by the
"Investment Company QBF", located at the address: St. Petersburg, Degtyarny per. 11, lit. "B", Shpakov R.V.,
Pakhomov V.S., Athanasiadou Linda, Golubev A.S., Matyukhin S.A., Rossieva E.A. and unidentified persons,
acting as an organised group, jointly and in concert, organised the conclusion of an agreement on the
provision of trust management services with Novitskiy A.G. on behalf of QBIF Investment Company LLC,
affiliated with the criminal association, under the agreement No. 4130 - 17/ISR dated 08.11.2017 and, under
the pretext of fulfilling the terms of the said agreement and contract, convinced the latter to transfer his
- Novitskiy A.G., unaware of the crime that was being prepared and misled as to the true objectives of the
the aim of making a profit, which did not correspond to reality, being in the office of LLC "Investment
Company QBF" located at the address: St. Petersburg, Degtyarny per, 11, Lit. "B", he transferred cash to the
employees of QBF Group Company (QBF) as follows: on 07.12.2017, at an unspecified time, in the amount of
USD 30,000, which at the exchange rate of the Central Bank of the Russian Federation as of 07.12.2017
140
amounted to RUB 1,767,900; on 14.12.2017, at an unspecified time, in the amount of USD 20,000, which at
the exchange rate of the Central Bank of the Russian Federation as of 14.12.2017 amounted to RUB 1,182,800.
unaware of the criminal intent, organised the acceptance of the above money from A.G. Novitsky, as a result
of which, having abused his trust, they received them at their disposal, i.e. took possession of the stolen
funds.
under the above circumstances, in the period from 07.12.2017 to 14.12.2017, deliberately, by deception and
breach of trust, stole money belonging to Novitsky A.G. in the amount of 2,950,700 rubles, in an especially
large amount.
namely:
141
and in concert, organised the signing with Vavilova L.A., on behalf of a non - resident affiliated with the
provision of direct access services to international stock markets No. 3421 - 17/IMR, dated 21.09.2017. The co
- conspirators deceived Vavilova L.A. by concealing from her the information that this organisation did not
management services with Vavilova L.A. on behalf of QBIF Investment Company LLC, affiliated with the
criminal association, under agreement No. 3421 - 17/IMR dated 21.09.2017, and, under the pretext of fulfilling
the terms of the said agreement and contract, persuaded the latter to transfer her funds to them, ostensibly
- L.A. Vavilova, unaware of the crime being prepared and misled as to the true objectives of the members of
the organised group - embezzlement of funds, believing that she was investing her funds for profit, which
was not true, being in the office of QBF Investment Company LLC located at 8 Presnenskaya Naberezhnaya
26.01.2018 was RUB 671,160.
of persons unaware of the criminal intent, organised the acceptance of the above - mentioned funds from
L.A. Vavilova, as a result of which, having abused her trust, they received them at their disposal, i.e. took
possession of the stolen money.
deliberately, through deceit and breach of trust, stole money belonging to Vavilova L.A. in the amount of
142
A.S., Matyukhin S.A., Rossieva E.A. and unidentified persons, acting as an organised group, jointly and in
concert, organised the signing with Vetrova N.S., on behalf of a non - resident affiliated with the criminal
association - QCCI LTD ("QCCI LTD", registered in the Republic of Cyprus), of an agreement on the provision of
direct access services to international stock markets No. 4236 - 17/ISR dated 15.11.2017. The co - conspirators
143
deceived N.S. Vetrova by concealing from her the information that this organisation had no legal grounds to
organised group, jointly and in coordination, organised the conclusion on behalf of the criminal affiliated LLC
Investment Company QBF, Rossieva E.A. and unidentified persons, acting as an organised group, jointly and
Vetrova N.S. on behalf of QBIF Investment Company LLC, affiliated with the criminal association, under the
agreement and contract, persuaded the latter to transfer her funds to them, ostensibly for trust
management.
- N.S. Vetrova, unaware of the crime that was being prepared and misled as to the true objectives of the
participants of the organised group - embezzlement of funds, believing that she invested her funds in order
to make a profit, which did not correspond to reality, being in the office of LLC Investment Company QBF,
located at the address: St. Petersburg, Maloohtinsky Prospe, 64, lit. "B", on 15.02.2018, at an unspecified
time, she transferred cash in the amount of 10,000 euros, which at the exchange rate of the Central Bank of
the Russian Federation as of 15.02.2018 was 712,300 rubles, to the employees of QBF Group Company (QBF).
unaware of the criminal intent, organised the acceptance of the aforementioned funds from N.S. Vetrova, as a
result of which, having abused her trust, they received them at their disposal, i.e. took possession of the
stolen money.
Shpakov R.V., Athanasiadou Linda, Golubev A.S., Matyukhin S.A., Rossieva E.A. and unidentified persons,
under the above circumstances, deliberately, through deceit and abuse of trust, on 15.02.2018 stole money
belonging to Vetrova N.S. in the amount of 712,300 rubles, in a large amount.
namely:
144
concert, organised the signing with Bozhko O.B. on behalf of a non - resident affiliated with the criminal
association - the company "QCCI LTD" ("QCCI LTD", registered in the Republic of Cyprus), the agreement on
the provision of services of direct access to international stock markets No. 4285 - 18/ISR dated 13.03.03.2018
and under the pretext of fulfilling the terms of the said agreement convinced the latter to transfer her funds
to them allegedly for trust management. At the same time, the accomplices deceived O.B. Bozhko by
concealing from her the information that this organisation had no legal grounds to engage in the type of
activity related to transactions with securities, as it did not have the relevant mandatory licence issued by the
- O.B. Bozhko, unaware of the crime that was being prepared and misled as to the true objectives of the
time, she transferred to the employees of QBF Group Company (QBF) cash in the amount of EUR 6,000, which
at the exchange rate of the Central Bank of the Russian Federation as of 13.03.2018 amounted to RUB 418,800
and in the amount of USD 20,000, which at the exchange rate of the Central Bank of the Russian Federation as
of 13.03.2018 amounted to RUB 1,132,200.
unaware of the criminal intent, organised the acceptance of the above - mentioned funds from O.B. Bozhko,
as a result of which, having abused her trust, they received them at their disposal, that is, took possession of
the stolen money.
145
coordination with Shpakov R.V., Athanasiadou Linda, Golubev A.S., Matyukhin S.A., Rossieva E.A. and
trust, on 13.03.2018 stole money belonging to Bozhko O.B. in the amount of 1,551,000 rubles, in an especially
large amount.
namely:
146
and in concert, organised the signing with Batalova M.R., on behalf of a non - resident affiliated with the
provision of direct access services to international stock markets No. 4182 - 17/IMR, dated 11.11.2017. At the
same time, the accomplices deceived M.R. Batalova by concealing from her the information that this
dated 28.12.2017 with Batalova M.R. on behalf of QBF Advisery LLC (INN 7703426941), affiliated with the
criminal association, and, under the pretext of fulfilling the terms of the said agreement and contract,
- M.R. Batalova, unaware of the crime being prepared and misled as to the true objectives of the members of
the organised group - embezzlement of funds, believing that she was investing her funds with the aim of
following address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, realised the transfer of cash to the
employees of QBF Group Company (QBF) as follows: 28.12.2017, at an unspecified time, in the amount of
RUB 1,149,000; 22.03.2018, at an unspecified time, in the amount of EUR 10,000, which at the exchange rate
of the Central Bank of the Russian Federation as of 22.03.2018 was RUB 705,700.
of persons unaware of the criminal intent, organised the acceptance of the above money from M.R. Batalova,
as a result of which, having abused her trust, they received them at their disposal, i.e. took possession of the
stolen funds.
deliberately, by deception and breach of trust, stole money belonging to M.R. Batalova in the amount of
namely:
147
concert, organised the signing with Romanovsky A.A., on behalf of a non - resident affiliated with the criminal
deceived A.A. Romanovsky by concealing from him the information that this organisation had no legal
Shpakov, V.S. Pakhomov, Athanasiadou Linda , A.S. Golubev, S.A. Matyukhin, and unidentified persons acting
in an organised group, jointly and in concert, organised the conclusion on behalf of the affiliated with the
criminal community LLC "QBF Education", Rossieva E.A. and unidentified persons, acting as an organised
148
group, jointly and in concert, organised the conclusion of an assignment agreement No. 4298 dated
20.03.2018 with Romanovsky A.A. on behalf of QBF Advisery LLC (INN 7703426941), affiliated with the
- A.A. Romanovsky, unaware of the crime being prepared and misled as to the true objectives of the
participants of the organised group - embezzlement of funds, believing that he was investing his funds for
profit, which was not true, being in the office of LLC "QBF Investment Company" located at the address: St.
Petersburg, Maloohtinsky Ave, 64, lit. "B", realised the transfer of cash to the employees of QBF Group
exchange rate of the Central Bank of the Russian Federation as of 20.03.2018 was RUB 1,151,000; 24.03.2018,
Russian Federation as of 24.03.2018 was RUB 1,313,530.
unaware of the criminal intent, organised the acceptance of the aforementioned funds from A.A.
Romanovsky, as a result of which, having abused his trust, they received them at their disposal, that is, took
breach of trust, stole money belonging to Romanovsky A.A. in the amount of 2,464,530 rubles, in an
namely:
149
Matyukhin S.A., Rossieva E.A. and unidentified persons, acting in an organised group, jointly and in concert,
organised the signing of an agreement on the provision of direct access services to international stock
markets No. 4341 - 18/ISR dated 19.04.2018 with D.V. Erofeev on behalf of a non - resident company QCCI LTD
("QCCI LTD", registered in the Republic of Cyprus), affiliated with the criminal association. The co -
conspirators deceived D.V. Erofeev by concealing from him the information that this organisation had no legal
grounds to engage in the type of activity related to the execution of securities transactions, as it did not have
"Investment Company QBF", located at the address: St. Petersburg, Degtyarny per. 11, lit. "B", R.V. Shpakov,
V.S. Pakhomov, Athanasiadou Linda , A.S. Golubev, S.A. Matyukhin, and unidentified persons acting in an
organised group, jointly and in a coordinated manner, organised the conclusion on behalf of the affiliated
with the criminal community LLC "QBF Advisery", Rossieva E.A. and unidentified persons, acting as an
dated 19.04.2018 with Erofeev D.V. on behalf of QBF Advisery LLC (INN 7703426941), affiliated with the
persuaded the latter to transfer his funds to them ostensibly for trust management.
- D.V. Erofeev, unaware of the crime being prepared and misled as to the true objectives of the participants of
located at the address: St. Petersburg, Degtyarny Lane, 11, lit. "B", on 19.04.2018, at an unspecified time, he
transferred cash in the amount of 2,500,000 rubles to the employees of QBF Group Company (QBF).
unaware of the criminal intent, organised the acceptance of the above money from D.V. Erofeev, as a result of
which, having abused his trust, they received them at their disposal, i.e. took possession of the stolen funds.
150
trust, on 19.04.2018 stole money belonging to D.V. Erofeev in the amount of 2,500,000 rubles, in an especially
large amount.
namely:
151
- Thus on 28.04.2016, at an unspecified time, being in the office of LLC Investment Company QBF (INN
7733673955), located at 1a Boris Yeltsin St., Ekaterinburg, under the pretext of investing money in securities
with high yield, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda and unidentified persons
acting in an organised group, jointly and in concert, organised the signing of a contract with M.I. Borzenkov
on behalf of a non - resident affiliated with the criminal association, Golubev A.S. and unidentified persons,
acting as an organised group, jointly and in concert, organised the signing with Borzenkov M.I. on behalf of a
non - resident affiliated with the criminal association - QB Capital CY LTD ("QB Capital CY LTD", registered in
the Republic of Cyprus), of an agreement on the provision of services of direct access to international stock
markets No. 2611 - 16/IER dated 28.04.2016. The co - conspirators deceived M.I. Borzenkov by concealing
from him the information that this organisation had no legal grounds to engage in activities related to
securities transactions, as it did not have the relevant mandatory licence issued by the authorised body of
Company QBF, located at 1a Boris Yeltsin St., Ekaterinburg, R.V. Shpakov, V.S. Pakhomov, Z.V. Munayev,
Athanasiadou Linda and unidentified persons acting in an organised group, jointly and in concert, organised
the conclusion on behalf of the criminal affiliated LLC Investment Company QBF, Golubev A.S. and
agreement on the provision of "Trust Management" services under agreement No. 2611 - 16/IЕR dated
28.04.2016 with Borzenkov M.I. on behalf of QBIF Investment Company LLC, affiliated with the criminal
community, and subsequently, at the specified address, on an unspecified date and time, during the period
from 28.04.2016 to 01.02.2017, organised the signing with M.I. Borzenkov on behalf of a non - resident
affiliated with the criminal association - QB Capital CY LTD (QB Capital CY LTD), of an agreement on the
provision of direct access to international stock markets No. 2611 - 16/IER dated 01.02.2017 and, under the
pretext of fulfilling the terms of the above agreements and the contract, persuaded the latter to transfer his
- M.I. Borzenkov, Borzenkov M.I., unaware of the crime that was being prepared and misled as to the true
objectives of the participants of the organised group - embezzlement of funds, believing that he was
investing his funds for profit, which was not true, made transfers of funds from his account No.
40817840848010178524, opened in the Uralsky branch of Gazprombank JSC, located at the address:
Sverdlovsk region, Ekaterinburg, Lunacharskogo str. 134 - v to the accounts of QB Capital CY LTD ("QB Capital
CY LTD"). Ekaterinburg, Lunacharskogo str. 134 - v, to the accounts of QB Capital CY LTD ("QB Capital CY LTD")
as follows: 06.05.2016 in the amount of USD 500,000, which at the exchange rate of the Central Bank of the
Russian Federation as of 06.05.2016 was RUR 32,945,000; 23.05.2016 in the amount of USD 400,000, which at
the exchange rate of the Central Bank of the Russian Federation as of 23.05.2016 was RUR 26,552,000;
10.06.2016 in the amount of USD 100,000, which at the exchange rate of the Central Bank of the Russian
Federation as of 10.06.06.2016 was RUB 6,374,000; 26.08.2016 in the amount of USD 500,000, which at the
exchange rate of the Central Bank of the Russian Federation as of 26.08.2016 was RUB 32,475,000; 08.09.2016
in the amount of USD 1,000,000, which at the exchange rate of the Central Bank of the Russian Federation as
of 08.09.2016 was RUB 64,380,000. In addition, on 26.01.2017 he transferred funds from his account No.
40817840848010178524, opened in the Uralsky branch of JSC Gazprombank, located at the address:
Sverdlovsk region, Ekaterinburg, Lunacharskogo str. 134 - v, to the account "QB Capital CY LTD" ("QB Capital
CY LTD") No. 11800083622101 opened with Anelik Bank ("Anelik Bank", Republic of Armenia) in the amount of
USD 1,500,000, which at the exchange rate of the Central Bank of the Russian Federation as of 26.01.2017
amounted to RUB 88,725,000. On 03.02.2017 he transferred funds from his account No.
40817840848010178524 opened with the Uralsky branch of JSC Gazprombank located at the address:
Sverdlovsk region, Ekaterinburg, Lunacharskogo str. 134 - v, to the account "QB Capital CY LTD" ("QB Capital
CY LTD") No. RS35105051012100012316 opened with AIK Banka ("AIK Banka", Republic of Serbia) in the
amount of USD 1,500,000, which at the exchange rate of the Central Bank of the Russian Federation as of
03.02.2017 amounted to RUB 89,985,000. On 21.02.2017 he transferred funds from his account No.
40817840848010178524 opened with the Uralsky branch of JSC Gazprombank located at the address:
152
Sverdlovsk region, Ekaterinburg, Lunacharskogo str. 134 - v, to QB Capital CY LTD account No.
RS35150007020000052652 opened with Direktna Banka ("Direktna Banka", Republic of Serbia) in the amount
of USD 1,500,000, which at the exchange rate of the Central Bank of the Russian Federation as of 21.02.2017
was RUB 87,150,000.
criminal intent, having obtained at their disposal the funds of M.I. Borzenkov, abused his trust and stole these
funds.
- Continuing their criminal actions, in order to achieve a criminal result aimed at stealing the funds of
Borzenkov M.I., on 30.03.2017, at an unspecified time, being in the office of LLC "Investment Company QBF"
(INN 7733673955), located at the address: Ekaterinburg, Boris Yeltsin St., 1a, under the pretext of investing
funds in securities with high yield, Shpakov R.V., Munaev Z.V., Athanasiadou Linda, Golubev A.S. and
unidentified persons, acting in an organised group, jointly and in concert, Pakhomov V.S., Munaev Z.V.,
Athanasiadou Linda, Golubev A.S. and unidentified persons, acting as an organised group, jointly and in
concert, organised the signing of agreement No. 3117 - 17/IЕR dated 30.03.2017 with Borzenkov M.I. on
behalf of a non - resident company QB Capital CY LTD (QB Capital CY LTD, registered in the Republic of
Cyprus) affiliated with the criminal association. The co - conspirators deceived Borzenkov M.I. by concealing
- Further, on 30.03.2017, at an unspecified time, being in the office of LLC Investment Company QBF, located at
1a Boris Yeltsin St., Ekaterinburg, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda and
unidentified persons, acting in an organised group, jointly and in concert, organised the conclusion on behalf
of the criminal affiliated LLC Investment Company QBF, Golubev A.S. and unidentified persons, acting as an
management services with Borzenkov M.I. on behalf of QBIF Investment Company LLC, affiliated with the
criminal association, under agreement No. 3117 - 17/IER dated 30.03.2017, and, under the pretext of fulfilling
- M.I. Borzenkov, Borzenkov M.I., unaware of the crime that was being prepared and misled as to the true
objectives of the participants of the organised group - embezzlement of funds, believing that he was
investing his funds for profit, which was not true, made transfers of funds from his account No.
40817840848010178524, opened in the Uralsky branch of Gazprombank JSC, located at the address:
Sverdlovsk region, Ekaterinburg, Lunacharskogo str. 134 - v to the account of QB Capital CY LTD ("QB Capital
CY LTD"). Ekaterinburg, Lunacharskogo street, 134 - v, to QB Capital CY LTD ("QB Capital CY LTD") account No.
RS35150007020000052652 opened with Direktna Banka ("Direktna Banka", Republic of Serbia), as follows:
20.04.2017 in the amount of USD 800,000, which at the exchange rate of the Central Bank of the Russian
Federation as of 20.04.2017 amounted to RUB 44,944,000; 24.04.2017 in the amount of USD 200,000, which at
the exchange rate of the Central Bank of the Russian Federation as of 24.04.2017 amounted to RUB
11,246,000; 14.06.2017 in the amount of USD 1,000,000, which at the exchange rate of the Central Bank of the
Russian Federation as of 14.06.2017 amounted to RUB 56,910,000.
criminal intent, having obtained at their disposal the funds of M.I. Borzenkov, abused his trust and stole these
funds.
Borzenkov M.I., on 06.12.2017, at an unspecified time, being in the office of LLC "Investment Company QBF"
(INN 7733673955), located at 1a Boris Yeltsin St., Ekaterinburg, under the pretext of investing funds in
securities with high yield, Shpakov R.V., Munaev Z.V., Athanasiadou Linda, Golubev A.S., Matyukhin S.A.,
Rossieva E.A. and Neustanovan, Pakhomov V.S., Munaev Z.V., Athanasiadou Linda, Golubev A.S., Matyukhin
153
S.A., Rossieva E.A. and unidentified persons, acting as an organised group, jointly and in concert, organised
the signing of agreement No. 4148 - 17/IER with Borzenkov M.I. on behalf of a non - resident company QCCI
LTD (QCCI LTD, registered in the Republic of Cyprus) affiliated with the criminal association. The co -
conspirators deceived Borzenkov M.I. by concealing from him the information that this organisation had no
compulsory licence issued by the authorised body of the Republic of Cyprus.
- Further, on 06.12.2017, at an unspecified time, being in the office of QBIF Investment Company LLC located at
1a Boris Yeltsin Street, Ekaterinburg, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda , A.S.
Golubev, S.A. Matyukhin and unidentified persons acting in an organised group, jointly and in concert,
organised the conclusion on behalf of the criminal association - affiliated QBIF Investment Company LLC, E.A.
Rossieva and unidentified persons, acting as an organised group, jointly and in concert, organised the
conclusion of an agreement on the provision of "trust management" services under the agreement (Account
004148) with M.I. Borzenkov on behalf of QBIF Investment Company LLC, an affiliate of the criminal
association, and, under the pretext of fulfilling the terms of the agreement and the agreement, persuaded
- M.I. Borzenkov, Borzenkov M.I., unaware of the crime being prepared and misled as to the true objectives of
the members of the organised group - embezzlement of funds, believing that he was investing his funds for
profit, which was not true, made transfers of funds from his account No. 40817840848010178524 opened with
the Uralsky branch of Gazprombank JSC located at the address: Sverdlovsk region, Ekaterinburg,
Lunacharskogo str. 134 - v, to QCCI LTD" ("QCCI LTD") account No. 1570025497880101 opened with
Ameriabank ("Ameriabank", Republic of Armenia), as follows: 07.12.2017 in the amount of USD 2,000,000,
which at the exchange rate of the Central Bank of the Russian Federation as of 07.12.2017 was RUB
117,860,000; 26.01.2018 in the amount of USD 2,000,000, which at the exchange rate of the Central Bank of
the Russian Federation as of 26.01.01.2018 was RR 111,860,000; 15.03.2018 in the amount of USD 2,000,000,
which at the exchange rate of the Central Bank of the Russian Federation as of 15.03.2018 was RR
113,880,000; 23.04.2018 in the amount of USD 2,000,000, which at the exchange rate of the Central Bank of
the Russian Federation as of 23.04.2018 was RR 122,640,000.
of persons unaware of the criminal intent, having obtained at their disposal the funds of M.I. Borzenkov,
abused his trust and stole these funds.
deceit and breach of trust, stole money belonging to Borzenkov M.I. in the amount of 1,007,926,000 rubles, in
namely:
154
concert, organised the signing with Baiguzina S.A., on behalf of a non - resident affiliated with the criminal
direct access services to international stock markets No. 4126 - 17/ISR, dated 08.11.2017. The co -
conspirators deceived Baiguzina S.A. by concealing from her the information that this organisation did not
Baiguzina S.A. on behalf of QBIF Investment Company LLC, affiliated with the criminal association, under
155
agreement No. 4126 - 17/ISR dated 08.11.2017, and, under the pretext of fulfilling the terms of the said
management.
- Baiguzina S.A., unaware of the crime being prepared and misled as to the true objectives of the participants
address: St. Petersburg, Maloohtinsky Prospe, 64, lit. "B", she transferred cash to the employees of QBF
the exchange rate of the Central Bank of the Russian Federation as of 27.11.2017 was RUB 1,755,900;
unaware of the criminal intent, organised the acceptance of the aforementioned funds from S.A. Baiguzina,
stolen funds.
breach of trust, stole money belonging to Baiguzina S.A. in the amount of 4,844,400 rubles, in an especially
large amount.
namely:
156
creating the "QBF" ("QBF") group from the money systematically stolen from individuals, Shpakov R.V.,
and in concert, organised the signing with Levina G.V. on behalf of a non - resident affiliated with the criminal
association - the company "QCCI LTD" ("QCCI LTD", registered in the Republic of Cyprus), the agreement on
the provision of services of direct access to international stock markets No. 4374 - 18/IMR dated 22.05.2018.
At the same time, the accomplices deceived Levina G.V. by concealing from her the information that this
organisation did not have legal grounds to engage in the type of activity related to the execution of
dated 22.05.2018 with Levina G.V. on behalf of QBF Advisery LLC (INN 7703426941), affiliated with the
- Levina G.V., unaware of the forthcoming crime and misled as to the true objectives of the participants of the
organised group - embezzlement of funds, believing that she invested her funds with the aim of making a
the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, on 22.05.2018, at an unspecified time, she
Federation as of 22.05.2018 amounted to RUB 1,250,600 to the employees of QBF Group Company (QBF).
G.V. Levina, as a result of which, having abused her trust, they received them at their disposal, i.e. took
157
persons, under the circumstances described above, deliberately, through deceit and breach of trust, on
22.05.2018 stole money belonging to Levina G.V. in the amount of 1,250,600 rubles, in an especially large
amount.
namely:
158
discretion.
and in concert, organised the signing with Naumova E.G., on behalf of a non - resident affiliated with the
provision of direct access services to international stock markets No. 4411 - 18/IMR, dated 19.06.2018. At the
same time, the accomplices deceived Naumova E.G. by concealing from her the information that this
dated 19.06.2018 with Naumova E.G. on behalf of QBF Advisery LLC (INN 7703426941), affiliated with the
- E.G. Naumova, unaware of the crime being prepared and misled as to the true objectives of the participants
making a profit, which was not true, being in the office of LLC Investment Company QBF, located at: Moscow,
Presnenskaya Naberezhnaya, 8, p. 1, at an unspecified time, made a transfer of cash in the amount of
1,900,000 rubles to the employees of the QBF Group Company (QBF). 1, on 20.06.2018, at an unspecified
time, she handed over cash in the amount of RUB 1,900,000 to employees of QBF Group Company (QBF).
E.G. Naumova, as a result of which, having abused her trust, they received them at their disposal, i.e. took
20.06.2018 stole money belonging to Naumova E.G. in the amount of 1,900,000 rubles, in an especially large
amount.
namely:
159
- So on 11.05.2016 at an unspecified time, being in the office of LLC "Investment Company QBF" (INN
unidentified persons acting in an organised group, jointly and in concert, organised the signing with Danilov
A.V. on behalf of a non - resident affiliated with the criminal community, Golubev A.S. and unidentified
persons, acting as an organised group, jointly and in concert, organised the signing with Danilov A.V. on
registered in the Republic of Cyprus) of the agreement on providing services of direct access to international
stock markets No. 2623 - 16/ISR dated 11.05.2016. The co - conspirators deceived Danilov A.V. by concealing
160
management services with Danilov A.V. on behalf of QBIF Investment Company LLC, affiliated with the
criminal community, under agreement No. 2623 - 16/ISR dated 11.05.2016 and, under the pretext of fulfilling
- Danilov A.V., unaware of the crime being prepared and misled as to the true objectives of the participants of
transferred cash in the amount of RUB 600,000 to the employees of QBF Group Company (QBF).
organised the acceptance of the above - mentioned funds from A.V. Danilov, as a result of which, abusing his
- Continuing their criminal actions, in order to achieve a criminal result aimed at stealing money Danilova A.V.,
Shpakov R.V., Pakhomov V.S., Athanasiadou Linda, Golubev A.S., S.A. Matyukhin and unidentified persons,
acting as an organised group, jointly and in concert, with the involvement of persons unaware of the criminal
intent, under the pretext of fulfilling the terms of the above agreement and contract, under unspecified
circumstances, persuaded A.V. Danilov to transfer additional funds to them, ostensibly for trust management.
criminal intent, organised the acceptance of the above - mentioned funds from A.V. Danilov, as a result of
- Further, continuing their criminal actions, in order to achieve a criminal result aimed at stealing money
Danilova A.V., Shpakov R.V., Pakhomov V.S., Athanasiadou Linda, Golubev A.S., Matyukhin S.A., E.A. Rossieva
and unidentified persons, acting as an organised group, jointly and in concert, with the involvement of
persons unaware of the criminal intent, under the pretext of fulfilling the terms of the above agreement and
contract, under unspecified circumstances, once again persuaded A.V. Danilov of the need for an additional
transfer of his funds to them, ostensibly for trust management.
address: St. Petersburg, Maloohtinsky Prospe, 64, lit. "B", realised the transfer of cash to the employees of
QBF Group Company (QBF) as follows: 21.12.2017, at an unspecified time, in the amount of RUB 1,655,000;
unaware of the criminal intent, organised the acceptance of the above money from A.V. Danilov, as a result of
breach of trust, stole money belonging to Danilov A.V. in the amount of 4,985,000 rubles, in an especially
large amount.
161
namely:
162
concert, organised the signing with Krecheteva T.O., on behalf of a non - resident affiliated with the criminal
direct access services to international stock markets No. 4213 - 17/ISR, dated 13.11.2017. At the same time,
the accomplices deceived T.O. Krechetova by concealing from her the information that this organisation did
Krechetova T.O. under agreement No. 4213 - 17/ISR dated 13.11.2017 on behalf of QBIF Investment Company
LLC, affiliated with the criminal association, and, under the pretext of fulfilling the terms of the said
management.
- T.O. Krechetova, unaware of the crime that was being prepared and misled as to the true objectives of the
the aim of making a profit, which was not true, being in the office of LLC "Investment Company QBF" located
at the address: St. Petersburg, Maloohtinsky Prospe, 64, lit. "B", she transferred cash to the employees of QBF
Group Company (QBF) as follows: 31.01.2018, at an unspecified time, in the amount of RUB 1,400,000;
unaware of the criminal intent, organised the acceptance of the above - mentioned funds from T.O.
Krechetova, as a result of which, having abused her trust, they received them at their disposal, i.e. took
breach of trust, stole money belonging to Krechetova T.O. in the amount of 1,950,000 rubles, in an especially
large amount.
namely:
163
A.S., Matyukhin S.A., Rossieva E.A. and unidentified persons, acting in an organised group, jointly and in
concert, organised the signing with Ostovich E.N., on behalf of a non - resident affiliated with the criminal
direct access services to international stock markets No. 4186 - 17/ISR, dated 11.11.2017. At the same time,
the accomplices deceived E.N. Ostovich by concealing from her the information that this organisation did not
Ostovich E.N. on behalf of QBIF Investment Company LLC, affiliated with the criminal association, under
agreement No. 4186 - 17/ISR dated 11.11.2017, and, under the pretext of fulfilling the terms of the said
management.
164
- E.N. Ostovich, unaware of the crime that was being prepared and misled as to the true objectives of the
the address: St. Petersburg, Maloohtinsky Prospe, 64, lit. "B", she transferred cash to the employees of QBF
Group Company (QBF) as follows: 28.12.2017, at an unspecified time, in the amount of RUB 600,000;
unaware of the criminal intent, organised the acceptance of the above money from E.N. Ostovich, as a result
of which, having abused her trust, they received them at their disposal, i.e. took possession of the stolen
money.
breach of trust, stole money belonging to Ostovich E.N. in the amount of 1,230,000 rubles, in an especially
large amount.
namely:
8 Presnenskaya Naberezhnaya Embankment, bld. 1, Moscow. 1.
165
and in concert, organised the signing with Drobin V.M., on behalf of a non - resident affiliated with the
conspirators deceived V.M. Drobin by concealing from him the information that this organisation had no legal
management services with Drobin V.M. on behalf of QBIF Investment Company LLC, affiliated with the
criminal community, under agreement No. 3994 - 17/IMR dated 24.10.2017 and, under the pretext of fulfilling
- V.M. Drobin, unaware of the crime being prepared and misled as to the true objectives of the members of the
organised group - thef of funds, believing that he was investing his funds with the aim of making a profit,
which was not true, being in the office of QBF Investment Company LLC located at 8 Presnenskaya
Naberezhnaya Naberezhnaya, bldg. 1, Moscow, carried out the transfer of cash to the employees of QBF
Group Company (QBF) as follows. 1, realised the transfer of cash to the employees of QBF Group Company
(QBF) as follows: 30.10.2017, at an unspecified time, in the amount of RUB 500,000; 31.10.2017, at an
unspecified time, in the amount of RUB 300,000; 25.07.2018, at an unspecified time, in the amount of RUB
1,000,000.
- In turn, R.V. Shpakov, V.S. Pakhomov, Z.V. Munayev, Athanasiadou Linda , A.S. Golubev, S.A. Matyukhin, E.A.
V.M. Drobin, as a result of which, having abused his trust, they received them at their disposal, i.e. took
deceit and breach of trust, stole money belonging to Drobin V.M. in the amount of 1,800,000 rubles, in an
166
namely:
167
organised the signing with Kilo V.A. on behalf of a non - resident affiliated with the criminal association - QB
Capital CY LTD ("QB Capital CY LTD", registered in the Republic of Cyprus), of an agreement on the provision of
services of direct access to international stock markets No. 2650 - 16/IMR, dated 23.05.2016. At the same time,
the accomplices deceived Kilo V.A. by concealing from him the information that this organisation did not
Company QBF, located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, Shpakov R.V., Pakhomov
V.S., Munaev Z.V., Athanasiadou Linda 1, Shpakov R.V., Pakhomov V.S., Munaev Z.V., Athanasiadou Linda,
conclusion of an agreement on the provision of trust management services with Kilo V.A. on behalf of QBIF
Investment Company LLC, affiliated with the criminal association, under agreement No. 2650 - 16/IMR dated
23.05.2016, and, under the pretext of fulfilling the terms of the said agreement and contract, persuaded the
- V.A. Kilo, unaware of the crime being prepared and misled as to the true objectives of the participants of the
organised group - embezzlement of funds, believing that he was investing his funds with the aim of making a
profit, which was not true, on 24.05.2016 made a bank transfer of funds from his account No.
40817810201000936854, opened with JSC Raiffeisenbank, located at the address: Moscow, Kutuzovsky Ave.
34, p. 14, to QB Capital CY LTD account No. CY240140010101010101150011705010 opened with The Cyprus
Development Bank, Republic of Cyprus, in the amount of RUB 1,000,000. In addition, while in the office of LLC
Investment Company QBF, located at 8 Presnenskaya Naberezhnaya Naberezhnaya, bld. 1, Moscow, he
handed over to the company's employees the sum of RUB 1,000,000. 1, realised the transfer of cash to the
RUB 1,000,000 and USD 4,000, which at the exchange rate of the Central Bank of the Russian Federation as of
28.10.2016 was RUB 252,160; 23.01.2017, at an unspecified time, in the amount of EUR 10,000, which at the
exchange rate of the Central Bank of the Russian Federation as of 23.01.2017 was RUB 637,300; 28.03.03.2017,
Russian Federation as of 28.03.2017 was RUB 1,083,380; 28.07.2017, at an unspecified time, in the amount of
EUR 32,000, which at the exchange rate of the Central Bank of the Russian Federation as of 28.07.2017 was
RUB 2,228,480.
criminal intent, organised the acceptance of the above - mentioned funds from V.A. Kilo, as a result of which,
- Continuing their criminal actions, in order to achieve a criminal result aimed at embezzlement of funds Kilo
V.A., Shpakov R.V., Pakhomov V.S., Munaev Z.V., Athanasiadou Linda, Golubev A.S., Matyukhin S.A., E.A.
of persons unaware of the criminal intent, under the pretext of fulfilling the terms of the above agreement
and contract, under unspecified circumstances, persuaded V.A. Kilo to transfer additional funds to them,
- V.A. Kilo, unaware of the crime being prepared and misled as to the true objectives of the members of the
profit, which was not true, being in the office of QBF Investment Company LLC, located at the address: 8
employees of QBF Group Company (QBF) as follows. 1, realised the transfer of cash to the employees of QBF
the exchange rate of the Central Bank of the Russian Federation as of 28.06.2018 was RUB 505,120, and EUR
13,450, which at the exchange rate of the Central Bank of the Russian Federation as of 28.06.2018 was RUB
168
989,920; 31.07.2018, at an unspecified time, in the amount of RUB 80,000 and EUR 4,500, which at the
exchange rate of the Central Bank of the Russian Federation as of 31.07.2018 was RUB 329,400.
of persons unaware of the criminal intent, organised the acceptance of the aforementioned funds from V.A.
Kilo, as a result of which, having abused his trust, they received them at their disposal, i.e. took possession of
the stolen funds.
deceit and breach of trust, stole money belonging to Kilo V.A. in the amount of 8,105,760 rubles, in an
namely:
169
unfulfilled, since the information about the brokerage activities of the organisation with which a particular
persons, acting as an organised group, jointly and in concert, organised the signing with Emirgamzaev V.E. on
international stock markets No. 1753 - 14/IMR dated 07.08.2014. At the same time, the accomplices deceived
V.E. Emirgamzaev by concealing from him the information that this organisation did not have legal grounds
to engage in the type of activity related to securities transactions, as it did not have the relevant mandatory
LLC, located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, Shpakov R.V., Pakhomov V.S.,
LLC, affiliated with the criminal association, of an agreement with Emirgamzaev V.E. on the provision of
"Trust Management" services under Agreement No. 1753 - 14/IMR dated 07.08.2014 and, under the pretext of
fulfilling the terms of the said agreement and contract, persuaded the latter to transfer his funds to them,
- Emirgamzaev V.E., unaware of the crime being prepared and misled as to the true objectives of the
the aim of making a profit, which did not correspond to reality, being in the office of LLC Investment
Company QBF, located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, carried out the transfer
of cash to the employees of the QBF group company as follows: 03.04.2017, at an unspecified time, in the
amount of 100,000 roubles and 8,200 US dollars. 1, transferred cash to employees of QBF Group Company
(QBF) as follows: on 03.04.2017, at an unspecified time, in the amount of RUB 100,000 and USD 8,200, which
at the exchange rate of the Central Bank of the Russian Federation as of 03.04.04.2017 in the amount of RUB
458,872; 07.04.2017, at an unspecified time, in the amount of RUB 500,000; 11.07.2017, at an unspecified
time, in the amount of RUB 390,000 and USD 600, which at the exchange rate of the Central Bank of the
Russian Federation as of 11.07.2017 was RUB 36,180.
criminal intent, organised the acceptance of the above - mentioned funds from V.E. Emirgamzaev, as a result
of which, abusing his trust, they received them at their disposal, i.e. took possession of the stolen funds.
Emirgamzaeva V.E., Shpakov R.V., Pakhomov V.S., Munaev Z.V., Athanasiadou Linda, Golubev A.S., Matyukhin
S.A., E.A. Rossieva and unidentified persons, acting as an organised group, jointly and in concert, with the
agreement and contract, under unspecified circumstances, convinced V.E. Emirgamzaev of the need for an
additional transfer of his funds to them, ostensibly for trust management.
- Emirgamzaev V.E., unaware of the crime being prepared and misled as to the true objectives of the
170
the address: 8 Presnenskaya Naberezhnaya Naberezhnaya, bldg. 1, Moscow, carried out the transfer of cash
to the employees of the QBF group company as follows. 1, realised the transfer of cash to the employees of
13.04.2018, at an unspecified time, in the amount of RUB 1,100,000 and USD 6,500, which at the exchange
rate of the Central Bank of the Russian Federation as of 13.04.2018 was RUB 403,455; 30.05.2018, at an
unspecified time, in the amount of RUB 1,775,000 and USD 600, which at the exchange rate of the Central
Bank of the Russian Federation as of 30.05.2018 was RUB 37,584; 18.07.2018, at an unspecified time, in the
amount of RUB 1,700,000; 02.08.2018, at an unspecified time, in the amount of RUB 600,000.
V.E. Emirgamzaev, as a result of which, having abused his trust, they received them at their disposal, i.e. took
deceit and breach of trust, stole money belonging to Emirgamzaev V.E. in the amount of 7,501,091 rubles, in
namely:
171
A.S. Golubev, S.A. Matyukhin and unidentified persons, acting as an organised group, jointly and in concert,
organised the signing with O.A. Kosorukov on behalf of a non - resident affiliated with the criminal
association - QB Capital CY LTD ("QB Capital CY LTD", registered in the Republic of Cyprus), of an agreement
on the provision of services of direct access to international stock markets No. 3384 - 17/IMR dated
29.08.2017. The co - conspirators deceived O.A. Kosorukov by concealing from him the information that this
Munaev Z.V., Athanasiadou Linda, Golubev A.S.. 1, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou
Linda , A.S. Golubev, S.A. Matyukhin and unidentified persons, acting as an organised group, jointly and in
concert, organised the conclusion of an agreement on trust management services with O.A. Kosorukov on
behalf of QBIF Investment Company LLC, affiliated with the criminal community, under agreement No. 3384 -
- O.A. Kosorukov, unaware of the crime being prepared and misled as to the true objectives of the members of
the organised group - embezzlement of funds, believing that he was investing his funds for profit, which was
not true, being in the office of LLC Investment Company QBF, located at the address: Moscow, Presnenskaya
Naberezhnaya, 8, p. 1. 1, on 29.08.2017, at an unspecified time, transferred cash in the amount of RUB
1,200,000 to employees of QBF Group Company (QBF).
- In turn, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda , A.S. Golubev, S.A. Matyukhin and
unaware of the criminal intent, organised the acceptance of the above - mentioned funds from O.A.
Kosorukov, as a result of which, having abused his trust, they received them at their disposal, i.e. took
- Continuing their criminal actions, in order to achieve a criminal result aimed at stealing money Kosorukova
O.A., Shpakov R.V., Pakhomov V.S., Munaev Z.V., Athanasiadou Linda, Golubev A.S., Matyukhin S.A., E.A.
172
and contract, under unspecified circumstances, persuaded O.A. Kosorukov to transfer additional funds to
- O.A. Kosorukov, unaware of the crime being prepared and misled as to the true objectives of the members of
the organised group - embezzlement of funds, believing that he was investing his funds for profit, which was
not true, being in the office of LLC Investment Company QBF, located at the address: Moscow, Presnenskaya
Naberezhnaya, 8, p. 1. 1, on 17.08.2018, at an unspecified time, transferred cash in the amount of RUB
620,000 to employees of QBF Group Company (QBF).
of persons unaware of the criminal intent, organised the acceptance of the above money from O.A.
Kosorukov, as a result of which, having abused his trust, they received them at their disposal, i.e. took
deliberately, through deceit and breach of trust, stole money belonging to Kosorukov O.A. in the amount of
173
- So 21.08.2018, at an unspecified time, being in the office of LLC "Investment Company QBF" (INN
organised the signing with Lyutov A.V., on behalf of a non - resident affiliated with the criminal association -
QCCI LTD ("QCCI LTD", registered in the Republic of Cyprus), of an agreement on the provision of services of
direct access to international stock markets No. 4506 - 18/ISR, dated 20.08.2018. The co - conspirators
deceived A.V. Lyutov by concealing from him the information that this organisation had no legal grounds to
dated 20.08.2018 with Lyutov A.V. on behalf of QBF Advisery LLC (INN 7703426941), affiliated with the criminal
association, and under the pretext of fulfilling the terms of the said agreement and contract, convinced the
latter to transfer his funds to them ostensibly for trust management.
- A.V. Lyutov, unaware of the crime that was being prepared and misled as to the true objectives of the
QBF" located at the address: St. Petersburg, Degtyarny per, 11, lit. "B", on 21.08.2018, at an unspecified time,
he transferred to the employees of QBF Group Company (QBF) cash in the amount of USD 10,000, which at
the exchange rate of the Central Bank of the Russian Federation as of 21.08.2018 amounted to RUB 671,800.
unaware of the criminal intent, organised the acceptance of the above money from A.V. Lyutov, as a result of
belonging to Lyutov A.V. in the amount of 671,800 rubles, in a large amount.
174
namely:
concert, organised the signing with Bokov O.M., on behalf of a non - resident affiliated with the criminal
175
deceived Bokov O.M. by concealing from him the information that this organisation had no legal grounds to
acting as an organised group, jointly and in concert, organised the conclusion of an assignment agreement
No. 4542 dated 12.09.2018 with Bokov O.M. on behalf of QBF Advisery LLC (INN 7703426941), affiliated with
the criminal association, and, under the pretext of fulfilling the terms of the said agreement and contract,
- Bokov O.M., unaware of the crime that was being prepared and misled as to the true objectives of the
time, he transferred cash in the amount of RUB 1,500,000 to the employees of QBF Group Company (QBF).
unaware of the criminal intent, organised the acceptance of the above money from O.M. Bokov, as a result of
belonging to Bokov O.M. in the amount of 1,500,000 rubles, in an especially large amount.
namely:
176
- So on 20.06.2017 at an unspecified time, being in the office of LLC "Investment Company QBF" (INN
Kostovskaya E.N. on behalf of a non - resident affiliated with the criminal association, Golubev A.S. and
Kostovskaya E.N. on behalf of a non - resident affiliated with the criminal association - QB Capital CY LTD ("QB
Capital CY LTD", registered in the Republic of Cyprus) of an agreement on the provision of direct access
services to international stock markets No. 3256 - 17/ISR dated 20.06.2017. At the same time, the accomplices
deceived E.N. Kostovskaya by concealing from her the information that this organisation did not have legal
grounds to engage in the type of activity related to securities transactions, as it did not have the relevant
management services with Kostovskaya E.N. on behalf of Investment Company QBF LLC, affiliated with the
criminal community, under agreement No. 3256 - 17/ISR dated 20.06.2017 and, under the pretext of fulfilling
the terms of the said agreement and contract, persuaded the latter to transfer her funds to them, ostensibly
- E.N. Kostovskaya, unaware of the crime being prepared and misled as to the true objectives of the
time, she transferred cash in the amount of RUB 1,100,000 and USD 2,000, which at the exchange rate of the
Central Bank of the Russian Federation as of 20.06.2017 amounted to RUB 115,920 to the employees of QBF
Group Company (QBF).
177
organised the acceptance of the above - mentioned funds from E.N. Kostovskaya, as a result of which,
abusing her trust, they received them at their disposal, i.e. took possession of the stolen funds.
Kostovskoy E.N., Shpakov R.V., Pakhomov V.S., Athanasiadou Linda, Golubev A.S., S.A. Matyukhin and
under unspecified circumstances, convinced E.N. Kostovskaya to transfer her money to them for trust
management.
- E.N. Kostovskaya, unaware of the crime that was being prepared and misled as to the true objectives of the
to make a profit, which did not correspond to reality, being in the office of LLC Investment Company QBF,
located at the address: St. Petersburg, Maloohtinsky Prospe, 64, lit. "B", on 26.07.2017, at an unspecified
time, she transferred cash in the amount of 250,000 rubles to the employees of QBF Group Company (QBF).
criminal intent, organised the acceptance of the above - mentioned funds from E.N. Kostovskaya, as a result
- Further, continuing their criminal actions, in order to achieve a criminal result aimed at stealing money
Kostovskoy E.N., Shpakov R.V., Pakhomov V.S., Athanasiadou Linda, Golubev A.S., Matyukhin S.A., E.A.
and contract, under unspecified circumstances, once again persuaded E.N. Kostovskaya to transfer her funds
to them for trust management.
- Kostovskaya E.N., unaware of the crime that was being prepared and misled as to the true objectives of the
to make a profit, which did not correspond to reality, being in the office of LLC "Investment Company QBF",
located at the address: St. Petersburg, Maloohtinsky Prospe, 64, lit. "B", she transferred cash to employees of
amount of RUB 700,000.
unaware of the criminal intent, organised the acceptance of the above - mentioned funds from E.N.
Kostovskaya, as a result of which, having abused her trust, they received them at their disposal, i.e. took
breach of trust, stole money belonging to Kostovskaya E.N. in the amount of 2,745,920 rubles, in an
namely:
178
- So 14.06.2017 at an unspecified time, being in the office of LLC "Investment Company QBF" (INN
unidentified persons acting in an organised group, jointly and in concert, organised the signing with Morozov
V.V. on behalf of a non - resident criminal group affiliated with the criminal association, Morozov V.V. and
Golubev A.S., Golubev A.S. and unidentified persons, acting as an organised group, jointly and in concert,
organised the signing with Morozov V.V. on behalf of a non - resident affiliated with the criminal association -
provision of services of direct access to international stock markets No. 3245 - 17/ISR, dated 13.06.2017. The
co - conspirators deceived V.V. Morozov by concealing from him the information that this organisation had no
179
group, jointly and in concert, organised the conclusion of an agreement on the provision of "Trust
Management" services with Morozov V.V. on behalf of Investment Company QBF LLC, affiliated with the
criminal community, within the framework of agreement No. 3245 - 17/ISR dated 13.06.2017 and, under the
pretext of fulfilling the conditions of the said agreement and contract, convinced the latter to transfer his
- Morozov V.V., unaware of the crime being prepared and misled as to the true objectives of the participants of
address: St. Petersburg, Maloohtinsky Prospe, 64, lit. "B", on 14.06.2017, at an unspecified time, transferred
cash in the amount of RUB 580,000 to the employees of QBF Group Company (QBF).
organised the acceptance of the above - mentioned funds from V.V. Morozov, as a result of which, abusing his
Morozova V.V., Shpakov R.V., Pakhomov V.S., Athanasiadou Linda, Golubev A.S., Matyukhin S.A., E.A. Rossieva
and unidentified persons, acting as an organised group, jointly and in concert, with the involvement of
persons unaware of the criminal intent, under the pretext of fulfilling the terms of the above agreement and
contract, under unspecified circumstances, persuaded V.V. Morozov to transfer additional funds to them,
- Morozov V.V., unaware of the crime being prepared and misled as to the true objectives of the participants of
unaware of the criminal intent, organised the acceptance of the above money from V.V. Morozov, as a result of
breach of trust, stole money belonging to Morozov V.V. in the amount of 1,980,000 rubles, in an especially
large amount.
namely:
180
discretion.
concert, organised the signing with Voropaev A.V., on behalf of a non - resident affiliated with the criminal
direct access services to international stock markets No. 4556 - 18/ISR, dated 20.09.2018. The co -
conspirators deceived A.V. Voropaev by concealing from him the information that this organisation had no
181
acting as an organised group, jointly and in concert, organised the conclusion of an assignment agreement
No. 4556 dated 20.09.2018 with Voropaev A.V. on behalf of QBF Advisery LLC (INN 7703426941), affiliated with
the criminal association, and under the pretext of fulfilling the terms of the said agreement and contract,
- Voropaev A.V., unaware of the crime being prepared and misled as to the true objectives of the participants of
the organised group - embezzlement of funds, believing that he invests his funds with the aim of making a
address: St. Petersburg, Maloohtinsky Prospe, 64, lit. "B", on 22.10.2018, at an unspecified time, transferred
cash in the amount of RUB 1,950,000 to the employees of QBF Group Company (QBF).
unaware of the criminal intent, organised the acceptance of the above money from A.V. Voropaev, as a result
funds.
trust, on 22.10.2018 stole money belonging to Voropaev A.V. in the amount of 1,950,000 rubles, in an
namely:
182
7733673955), located at: Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, under the pretext of investing funds
in securities with high yields, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda , A.S. Golubev,
S.A. Matyukhin, Rossieva E.A. and unidentified persons, acting as an organised group, jointly and in concert,
organised the signing with Kishilov S.M., on behalf of a non - resident affiliated with the criminal association -
services to international stock markets No. 4251 - 18/IMR, dated 16.11.2017. At the same time, the
accomplices deceived Kishilov S.M. by concealing from him the information that this organisation had no
dated 21.02.2018 with Kishilov S.M. on behalf of QBF Advisor LLC (INN 7703426941), affiliated with the
criminal association, and under the pretext of fulfilling the terms of the said agreement and contract,
- S.M. Kishilov, unaware of the crime being prepared and misled as to the true objectives of the participants of
making a profit, which was not true, being in the office of QBF Investment Company LLC, located at the
address: 8 Presnenskaya Naberezhnaya Naberezhnaya, bldg. 1, Moscow, carried out the transfer of cash to
the employees of QBF Group Company (QBF) as follows. 1, realised the transfer of cash to the employees of
QBF Group Company (QBF) as follows: 21.02.2018, at an unspecified time, in the amount of USD 22,000,
which at the exchange rate of the Central Bank of the Russian Federation as of 21.02.2018 was RUB 1,243,440;
21.06.2018, at an unspecified time, in the amount of RUB 700,000 and USD 18,000, which at the exchange rate
of the Central Bank of the Russian Federation as of 21.06.06.2018 was RUB 1,145,160; 28.10.2018, at an
unspecified time, in the amount of USD 22,000, which at the exchange rate of the Central Bank of the Russian
Federation as of 28.10.2018 was RUB 1,443,860.
183
S.M. Kishilov, as a result of which, having abused his trust, they received them at their disposal, i.e. took
deceit and breach of trust, stole money belonging to Kishilov S.M. in the amount of 4,532,460 rubles, in an
namely:
184
and in concert, organised the signing with Bogomolov I.L., on behalf of a non - resident affiliated with the
provision of direct access services to international stock markets No. 4388 - 18/IМR, dated 30.05.2018. The co
- conspirators deceived Bogomolov I.L. by concealing from him the information that this organisation had no
dated 30.05.2018 with Bogomolov I.L. on behalf of QBF Advisery LLC (INN 7703426941), affiliated with the
- Bogomolov I.L., unaware of the crime being prepared and misled as to the true objectives of the members of
the organised group - embezzlement of funds, believing that he was investing his funds in order to make a
Moscow, Presnenskaya Naberezhnaya, 8, p. 1, carried out the transfer of cash to the employees of QBF Group
Company (QBF) as follows: 01.06.2018, at an unspecified time, in the amount of 2,840,000 roubles and 4,5 5
5,000 roubles. 1, transferred cash to employees of QBF Group Company (QBF) as follows: on 01.06.2018, at an
unspecified time, in the amount of RUB 2,840,000 and USD 4,590, which at the exchange rate of the Central
Bank of the Russian Federation as of 01.06.2018 was RUB 284,671.8; on 30.10.2018, at an unspecified time, in
the amount of RUB 1,970,000.
of persons unaware of the criminal intent, organised the acceptance of the above money from I.L.
Bogomolov, as a result of which, having abused his trust, they received them at their disposal, i.e. took
persons, under the above circumstances, in the period from 01.06.2018 to 30.10.2018, deliberately, by
deception and breach of trust, stole money belonging to Bogomolov I.L. in the amount of 5,094,671.8 rubles,
in an especially large amount.
namely:
185
and in concert, organised the signing with Kosovsky B.G., on behalf of a non - resident affiliated with the
provision of direct access services to international stock markets No. 4639 - 18/IMR dated 30.10.2018. At the
same time, the accomplices deceived Kosovsky B.G. by concealing from him the information that this
186
dated 30.10.2018 with Kosovskiy B.G. on behalf of QBF Advisery LLC (INN 7703426941), affiliated with the
criminal association, and under the pretext of fulfilling the terms and conditions of the said agreement and
contract, persuaded the latter to transfer his funds to them ostensibly for trust management.
- B.G. Kosovsky, unaware of the crime being prepared and misled as to the true objectives of the participants
(QBF).
of persons unaware of the criminal intent, organised the acceptance of the above money from B.G. Kosovsky,
stolen money.
breach of trust, on 30.10.2018 stole money belonging to Kosovsky B.G. in the amount of 1,579,440 rubles, in
namely:
187
and in concert, organised the signing with Semenov I.L. on behalf of a non - resident affiliated with the
provision of direct access services to international stock markets No. 4648 - 18/IMR dated 06.11.2018. At the
same time, the accomplices deceived Semenov I.L. by concealing from him the information that this
dated 06.11.2018 with Semenov I.L. on behalf of QBF Advisery LLC (INN 7703426941), affiliated with the
- I.L. Semenov, unaware of the crime that was being prepared and misled as to the true objectives of the
members of the organised group - embezzlement of funds, believing that he was investing his funds for
Moscow, Presnenskaya Naberezhnaya, 8, p. 1, made a transfer of cash in the amount of 2,000,000 rubles to
the employees of QBF Group Company (QBF) on 06.11.2018 at an unspecified time. 1, on 06.11.2018, at an
unspecified time, transferred cash in the amount of RUB 2,000,000 to employees of QBF Group Company
(QBF).
of persons unaware of the criminal intent, organised the acceptance of the above - mentioned funds from I.L.
Semenov, as a result of which, having abused his trust, they received them at their disposal, i.e. took
188
06.11.2018 stole money belonging to Semenov I.L. in the amount of 2,000,000 rubles, in an especially large
amount.
namely:
189
and in concert, organised the signing with Semenova L.L., on behalf of a non - resident affiliated with the
provision of direct access services to international stock markets No. 4647 - 18/IМR dated 06.11.2018. The co -
conspirators deceived L.L. Semenova by concealing from her the information that this organisation had no
dated 06.11.2018 with Semenova L.L. on behalf of QBF Advisery LLC (INN 7703426941), affiliated with the
convinced the latter to transfer her funds to them, ostensibly for trust management.
- L.L. Semenova, unaware of the crime being prepared and misled as to the true objectives of the participants
located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, she transferred cash to employees of
QBF Group Company (QBF) as follows: 06.11.2018, at an unspecified time, in the amount of RUB 1,700,000;
Bank of the Russian Federation as of 07.11.2018 was RUB 329,950.
L.L. Semenova, as a result of which, having abused her trust, they received them at their disposal, i.e. took
deceit and breach of trust, stole money belonging to Semenova L.L. in the amount of 2,029,950 rubles, in an
namely:
190
- So 08.12.2014, at an unspecified time, being in the office of LLC "Kyubi Finance" (INN 7733673955), located at
the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, under the pretext of investing funds in
securities with high yields, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda and unidentified
persons, acting as an organised group, jointly and in concert, organised the signing with Bolshov M.A., on
behalf of a non - resident affiliated with the criminal association - QB Capital CY LTD (QB Capital CY LTD,
registered in the Republic of Cyprus), of an agreement on the provision of direct access services to
international stock markets No. 1931 - 14/IMR dated 08.12.2014. The co - conspirators deceived Bolshov M.A.
LLC, located at the address: 8 Presnenskaya Naberezhnaya Embankment, bld. 1, R.V. Shpakov, V.S.
Pakhomov, Z.V. Munaev, Athanasiadou Linda and unidentified persons, acting as an organised group, jointly
and in concert, organised the conclusion of an agreement on the provision of trust management services
with M.A. Bolshov on behalf of Kyubey Finance LLC, an affiliate of the criminal association, under agreement
No. 1931 - 14/IMR dated 08.12.2014.
191
- Further, continuing their criminal actions, on 13.12.2018, at an unspecified time, being in the office of LLC
"Investment Company QBF", located at the address: Moscow, Presnenskaya naberezhnaya, 8, p. 1. 1, R.V.
Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda , A.S. Golubev, S.A. Matyukhin, Rossieva E.A. and
additional agreement to the agreement on the provision of trust management services No. 1931 - 14/IMR
dated 08.12.2014 with Bolshov M.A. on behalf of Qubief LLC (INN 7703458823), affiliated with the criminal
association, and under the pretext of fulfilling the terms of the said agreement, the agreement and the
additional agreement thereto, persuaded the latter to transfer his funds to them, ostensibly for trust
management.
- Bolshov M.A., unaware of the crime being prepared and misled as to the true objectives of the participants of
address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, on 13.12.2018, at an unspecified time, transferred
cash in the amount of USD 25,000, which at the exchange rate of the Central Bank of the Russian Federation
as of 13.12.2018 amounted to RUB 1,660,500, to the employees of QBF Group Company (QBF).
M.A. Bolshov, as a result of which, having abused his trust, they received them at their disposal, i.e. took
breach of trust, on 13.12.2018 stole money belonging to Bolshov M.A. in the amount of 1,660,500 rubles, in an
namely:
192
discretion.
and in concert, organised the signing of trust management agreement No. 4696 - 18/IMR dated 10.12.2018
with Dianov E.G. on behalf of a non - resident company affiliated with the criminal association - White Lake
Management LTD (registered in the Cayman Islands). At the same time, the accomplices deceived E.G. Dianov
by concealing from him the information that this organisation did not have legal grounds to engage in the
type of activity related to transactions with securities, as it did not have the relevant mandatory licence
issued by the Cayman Islands competent authority. Subsequently, under the pretext of fulfilling the
conditions of the said agreement, they persuaded the latter to transfer his funds to them, ostensibly for trust
management.
- E.G. Dianov, unaware of the crime that was being prepared and misled as to the true objectives of the
participants of the organised group - embezzlement of funds, believing that he was investing his funds for the
purpose of making a profit, which was not true, on 28.12.On 28.12.2018, he transferred funds from his
account No. 42307810638045528173 opened with the branch of Sberbank of Russia PJSC located at 45
Admiral Makarov Street, Moscow to Simtelligence Company Limited account No. 1570033649480158 opened
with Ameriabank (Republic of Armenia) in the amount of RUB 68,000,000.
of persons unaware of the criminal intent, having received at their disposal the funds of E.G. Dianov, abused
his trust and stole these funds.
28.12.2018 stole money belonging to Dianov E.G. in the amount of 68,000,000 rubles, in an especially large
amount.
193
namely:
of the group, by means of deceit and abuse of trust, which consisted in creating in natural persons - clients of
direct access to trading on the stock and derivatives markets, but the participants in the criminal association
discretion.
194
organised the signing with Gubanov A.V., on behalf of a non - resident affiliated with the criminal association -
services to international stock markets No. 4590 - 18/ISR, dated 08.10.2018. At the same time, the
accomplices deceived A.V. Gubanov by concealing from him the information that this organisation did not
dated 09.10.2018 with Gubanov A.V. on behalf of QBF Advisery LLC (INN 7703426941), affiliated with the
- Gubanov A.V., unaware of the crime that was being prepared and misled as to the true objectives of the
QBF" located at the address: St. Petersburg, Degtyarny per, 11, lit. "B", he transferred cash to the employees
of QBF Group Company (QBF) as follows: on 09.10.2018, at an unspecified time, in the amount of RUB
5,000,000; on 22.11.2018, at an unspecified time, in the amount of RUB 5,000,000.
unaware of the criminal intent, organised the acceptance of the above money from A.V. Gubanov, as a result
funds.
- Continuing their criminal actions, in order to achieve a criminal result aimed at stealing the funds of Gubanov
A.V., on 30.01.2019, at an unspecified time, being in the office of LLC "Investment Company QBF", located at:
St. Petersburg, Degtyarny per, 11, lit. "B", under the pretext of investing money in securities with high yield,
R.V. Shpakov, V.S. Pakhomov, Athanasiadou Linda , A.S. Golubev, S.A. Matyukhin, and E.A. Rossieva and
uninstalled time, Rossieva E.A. and unidentified persons, acting as an organised group, jointly and in concert,
organised the signing with Gubanov A.V. on behalf of a non - resident affiliated with the criminal association -
the company "QCCI LTD" ("QCCI LTD", registered in the Republic of Cyprus), agreement on the provision of
direct access to international stock markets No. 4757 - 19/ISR dated 30.01.01.2019 and under the pretext of
fulfilling the terms of the said agreement convinced the latter to transfer his funds to them allegedly for trust
management. At the same time, the accomplices deceived Gubanov A.V. by concealing from him the
- Gubanov A.V., unaware of the crime that was being prepared and misled as to the true objectives of the
he transferred cash in the amount of 5,000,000 rubles to the employees of QBF Group Company (QBF).
unaware of the criminal intent, organised the acceptance of the above money from A.V. Gubanov, as a result
funds.
195
breach of trust, stole money belonging to Gubanov A.V. in the amount of 15,000,000 rubles, in an especially
large amount.
namely:
196
Matyukhin S.A., and unidentified persons acting in an organised group, jointly and in concert, organised the
signing with Vorobyev - Desyatovsky N.V. on behalf of the criminal affiliated with them, Rossieva E.A. and
unidentified persons, acting as an organised group, jointly and in concert, organised the signing of an
19.02.2019 with Vorobyev - Desyatovsky N.V. on behalf of a non - resident company QCCI LTD ("QCCI LTD",
registered in the Republic of Cyprus), affiliated with the criminal association. The co - conspirators deceived
Vorobyov - Desyatovsky N.V. by concealing from him the information that this organisation had no legal
grounds to engage in the type of activity related to the execution of transactions with securities, as it did not
have the relevant mandatory licence issued by the authorised body of the Republic of Cyprus.
dated 19.02.2019 with Vorobyev - Desyatovsky N.V. on behalf of QBF Advisery LLC (INN 7703426941), affiliated
with the criminal association, and under the pretext of fulfilling the terms of the said agreement and contract
convinced the latter to transfer his funds to them, ostensibly for trust management.
- Vorobyev - Desyatovsky N.V., unaware of the crime that was being prepared and misled as to the true
objectives of the participants of the organised group - embezzlement of funds, believing that he invested his
funds with the aim of making a profit, which did not correspond to reality, being in the office of Investment
Company QBF LLC, located at the address: St. Petersburg, Degtyarny per, 11, lit. "B", on 19.02.2019, at an
unspecified time, he transferred cash in the amount of 4,500,000 rubles to the employees of QBF Group
Company (QBF).
unaware of the criminal intent, organised the acceptance of the above - mentioned funds from N.V. Vorobyev
- Desyatovsky, as a result of which, having abused his trust, they received them at their disposal, i.e. took
trust, on 19.02.2019 stole money belonging to Vorobyev - Desyatovsky N.V. in the amount of 4,500,000 rubles,
namely:
197
discretion.
and in concert, organised the signing of trust management agreement No. 4734 - 18/IMR dated 28.12.2018
with Galachyan K.G. on behalf of a non - resident company affiliated with the criminal association - White
Lake Management LTD (registered in the Cayman Islands). At the same time, the accomplices deceived
Galachyan K.G. by concealing from him the information that this organisation did not have legal grounds to
engage in the type of activity related to transactions with securities, as it did not have the relevant
mandatory licence issued by the competent authority of the Cayman Islands.
198
dated 28.12.2018 with Galachyan K.G. on behalf of QBF Advisery LLC (INN 7703426941), affiliated with the
criminal association, and, under the pretext of fulfilling the terms of the said agreements, persuaded the
- Galachyan K.G., unaware of the crime being prepared and misled about the true goals of the participants of
the organised group - embezzlement of funds, believing that he invested his funds with the aim of making
profit, which was not true, on 25.02.2019 made a transfer of funds from his account No.
40817840833004011279, opened in the additional office of PJSC "VTB Bank", located at: Moscow, 33 Bolshaya
Nikitskaya St., p. 1 to the account of "White Lake Management LTD" ("White Lake Management LTD") No. 100 -
298633 - 1, opened in "Global Fidelity Bank" ("Global Fidelity Bank"). 1, to the account of "White Lake
Management LTD" ("White Lake Management LTD") No. 100 - 298633 - 1 opened with "Global Fidelity Bank"
("Global Fidelity Bank", Cayman Islands) in the amount of USD 20,000, which at the exchange rate of the
Central Bank of the Russian Federation as of 25.02.2019 was RUB 1,310,200.
of persons unaware of the criminal intent, having obtained at their disposal the funds of K.G. Galachyan,
abused his trust and stole these funds.
25.02.2019 stole money belonging to Galachyan K.G. in the amount of 1,310,200 rubles, in an especially large
amount.
namely:
199
7733673955), located at: Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, under the pretext of investing funds
in securities with high yields, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou Linda , A.S. Golubev,
S.A. Matyukhin, Rossieva E.A. and unidentified persons, acting as an organised group, jointly and in concert,
organised the signing of trust management agreement No. 4796 - 19/ISR dated 28.02.2019 with Chekmareva
E.F. on behalf of a non - resident company affiliated with the criminal association - White Lake Management
LTD (registered in the Cayman Islands). The co - conspirators deceived E.F. Chekmareva by concealing from
her the information that this organisation did not have legal grounds to engage in the type of activity related
to securities transactions, as it did not have the relevant mandatory licence issued by the Cayman Islands
competent authority.
Company QBF, located at the following address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, R.V.
unidentified persons, acting as an organised group, jointly and in concert, organised the conclusion of a
service agreement dated 28.02.2019 with Chekmareva E.F. on behalf of VL Consulting LLC (INN 7706463476),
affiliated with the criminal association, and, under the pretext of fulfilling the terms of the said agreements,
- E.F. Chekmareva, E.F. Chekmareva, unaware of the crime that was being prepared and misled about the true
objectives of the participants of the organised group - embezzlement of funds, believing that she invested
her funds with the aim of making profit, which was not true, on 15.03.2019 transferred funds from her
account No. 40817840706600001246, opened in the office of JSC "Credit Europe Bank", located at the
address: Moscow, Kievsky Vokzal Square, 2, to the account No. 30114840600010008156, opened in "CITIBANK
N.A.", USA, for further transfer to the account in the name of "White Lake Management LTD" (CITIBANK N.A.,
USA). (CITIBANK N.A., USA, for further crediting to the account in the name of "White Lake Management LTD"
the funds in the amount of USD 57,207.68, which at the exchange rate of the Central Bank of the Russian
Federation as of 15.03.2019 amounted to RUB 3,741,382.27.
of persons unaware of the criminal intent, having received at their disposal the funds of E.F. Chekmareva,
abused her trust and stole these funds.
200
persons, under the above circumstances, deliberately, by deceit and breach of trust, on 15.03.2019 stole
money belonging to Chekmareva E.F. in the amount of 3,741,382.27 rubles, in a particularly large amount.
namely:
201
and in concert, organised the signing with Birnov M.A., on behalf of a non - resident affiliated with the
provision of direct access services to international stock markets No. 4317 - 18/IМR dated 29.03.2018. The co -
conspirators deceived M.A. Birnov by concealing from him the information that this organisation had no legal
dated 29.03.2018 with Birnov M.A. on behalf of QBF Advisery LLC (INN 7703426941), affiliated with the
- M.A. Birnov, unaware of the crime being prepared and misled as to the true objectives of the members of the
organised group - embezzlement of funds, believing that he was investing his funds for profit, which was not
true, being in the office of QBF Investment Company LLC located at 8 Presnenskaya Naberezhnaya
29.03.2018, at an unspecified time, in the amount of RUB 1,500,000; 09.04.2018, at an unspecified time, in the
amount of RUB 1,000,000; 11.12.2018, at an unspecified time, in the amount of RUB 1,500,000; 17.12.2018, at
an unspecified time, in the amount of RUB 500,000; 05.06.2019, at an unspecified time, in the amount of RUB
1,000,000 and USD 5,000, which at the exchange rate of the Central Bank of the Russian Federation as of
05.06.2019 was RUB 325,800.
M.A. Birnov, as a result of which, having abused his trust, they received them at their disposal, i.e. took
deceit and breach of trust, stole money belonging to Birnov M.A. in the amount of 5,825,800 rubles, in an
namely:
202
organised the signing of service agreement No. 442209 - G dated 25.07.2019 with Potapov A.V. on behalf of a
non - resident company WLM LTD ("WLM LTD" registered in the Cayman Islands) affiliated with the criminal
association. The co - conspirators deceived A.V. Potapov by concealing from him the information that this
the relevant mandatory licence issued by the competent authority of the Cayman Islands.
acting as an organised group, jointly and in concert, organised the conclusion of a service agreement No.
203
442209 dated 25.07.2019 with Potapov A.V. on behalf of VL Consulting LLC (INN 7706463476), affiliated with
the criminal association, and, under the pretext of fulfilling the terms of the said agreement and contract,
- Potapov A.V., unaware of the crime that was being prepared and misled as to the true objectives of the
participants of the organised group - embezzlement of funds, believing that he invested his funds in order to
make a profit, which did not correspond to reality, being in the office of LLC Investment Company QBF,
located at the address: St. Petersburg, Degtyarny per, 11, lit. "B", on 26.07.2019, at an unspecified time, he
transferred to the employees of QBF Group Company (QBF) cash in the amount of USD 15,700, which at the
exchange rate of the Central Bank of the Russian Federation as of 26.07.2019 amounted to RUB 991,612 and
EUR 12,900, which at the exchange rate of the Central Bank of the Russian Federation as of 26.07.2019
amounted to RUB 906,741.
unaware of the criminal intent, organised the acceptance of the above money from A.V. Potapov, as a result of
which, having abused his trust, they received them at their disposal, i.e. took possession of the stolen money.
trust, on 26.07.2019 stole money belonging to Potapov A.V. in the amount of 1,898,353 rubles, in a particularly
large amount.
namely:
204
concert, organised the signing with Bosak L.V., on behalf of a non - resident affiliated with the criminal
direct access services to international stock markets No. 4431 - 18/ISR dated 28.06.2018. At the same time,
the accomplices deceived L.V. Bosak by concealing from her the information that this organisation did not
Shpakov, V.S. Pakhomov, Athanasiadou Linda , A.S. Golubev, S.A. Matyukhin, and unidentified persons acting
in an organised group, jointly and in concert, organised the conclusion on behalf of the affiliated with the
criminal community LLC "QBF Education", Rossieva E.A. and unidentified persons, acting as an organised
group, jointly and in concert, organised the conclusion of an assignment agreement No. 4431 dated
28.06.2018 with Bosak L.V. on behalf of QBF Advisery LLC (INN 7703426941), affiliated with the criminal
association, and under the pretext of fulfilling the terms of the said agreement and contract, persuaded the
latter to transfer her funds to them, ostensibly for trust management.
- Bosak L.V., unaware of the crime being prepared and misled as to the true objectives of the participants of
the organised group - embezzlement of funds, believing that she invested her funds with the aim of making a
address: St. Petersburg, Maloohtinsky Prospe, 64, lit. "B", 28.06.2018, at an unspecified time, transferred to
the employees of QBF Group Company (QBF) cash in the amount of USD 30,000, which at the exchange rate
of the Central Bank of the Russian Federation as of 28.06.2018 amounted to RUB 1,894,200, and 31.07.2019,
at an unspecified time, being in the office of QBF Investment Company LLC, located at: St. Petersburg,
Degtyarny per, 11, Lit. "B", she transferred cash in the amount of USD 10,000, which at the exchange rate of
the Central Bank of the Russian Federation as of 31.07.2019 amounted to RUB 633,800 to the employees of
QBF Group Company (QBF).
unaware of the criminal intent, organised the acceptance of the above - mentioned funds from L.V. Bosak, as
205
a result of which, having abused her trust, they received them at their disposal, i.e. took possession of the
stolen funds.
breach of trust, stole money belonging to Bosak L.V. in the amount of 2,528,000 rubles, in an especially large
amount.
namely:
206
discretion.
organised the signing with Paramonov S.V. on behalf of a non - resident affiliated with the criminal
association - QB Capital CY LTD ("QB Capital CY LTD", registered in the Republic of Cyprus), agreement on the
co - conspirators deceived Paramonov S.V. by concealing from him the information that this organisation had
no legal grounds to engage in activities related to securities transactions, as it did not have the relevant
"Investment Company QBF", located at the address: Moscow, Presnenskaya naberezhnaya, 8, p. 1, Shpakov
R.V., Pakhomov V.S., Munaev Z.V., Athanasiadou Linda 1, Shpakov R.V., Pakhomov V.S., Munaev Z.V.,
Athanasiadou Linda, Golubev A.S. and unidentified persons, acting as an organised group, jointly and in
concert, organised the conclusion of an agreement on the provision of trust management services with
Paramonov S.V. on behalf of QBIF Investment Company LLC, affiliated with the criminal association, under
agreement No. 3065 - 17/IMR dated 02.03.2017, and, under the pretext of fulfilling the terms of the said
- Paramonov S.V., unaware of the crime being prepared and misled as to the true objectives of the members of
the organised group - embezzlement of funds, believing that he was investing his funds for profit, which did
not correspond to reality, being in the office of LLC Investment Company QBF, located at the address:
Moscow, Presnenskaya Naberezhnaya, 8, bldg. 1, transferred cash to employees of QBF Group Company
(QBF) as follows: on 02.03.2017, at an unspecified time, in the amount of RUB 1,000,000; on 22.06.2017, at an
unspecified time, in the amount of RUB 300,000.
criminal intent, organised the acceptance of the above - mentioned funds from S.V. Paramonov, as a result of
- Continuing their criminal actions, in order to achieve a criminal result aimed at thef of funds Paramonova
S.V., Shpakov R.V., Pakhomov V.S., Munaev Z.V., Athanasiadou Linda, Golubev A.S., Matyukhin S.A., E.A.
and contract, under unspecified circumstances, convinced Paramonov S.V. to transfer additional funds to
- Paramonov S.V., unaware of the crime that was being prepared and misled as to the true objectives of the
participants of the organised group - thef of funds, believing that he was investing his funds for profit, which
was not true, being in the office of LLC Investment Company QBF, located at 8 Presnenskaya Naberezhnaya
amount of EUR 3,900, which at the exchange rate of the Central Bank of the Russian Federation as of
31.01.2018 was RUB 271,206; 28.06.2018, at an unspecified time, in the amount of RUB 650,000.
207
Paramonov, as a result of which, having abused his trust, they received them at their disposal, that is, took
Athanasiadou Linda , A.S. Golubev, S.A. Matyukhin, Rossieva E.A. and unidentified persons, acting in an
organised group, jointly and in concert, organised the signing of a service agreement No. D - 055920 - H dated
01.08.2019 with Paramonov S.V. on behalf of a non - resident company WLM LTD ("WLM LTD", registered in the
Cayman Islands), affiliated with the criminal association. The co - conspirators deceived Paramonov S.V. by
concealing from him the information that this organisation did not have legal grounds to engage in the type
of activity related to securities transactions, as it did not have the relevant mandatory licence issued by the
competent authority of the Cayman Islands.
"Investment Company QBF", located at the address: Moscow, Presnenskaya naberezhnaya, 8, p. 1. 1, R.V.
service agreement dated 01.08.2019 with Paramonov S.V. on behalf of VL Consulting LLC (INN 7706463476),
affiliated with the criminal association, and, under the pretext of fulfilling the terms of the above agreement
and contract, persuaded the latter to transfer his funds to them, ostensibly for trust management.
- Paramonov S.V., unaware of the crime being prepared and misled as to the true objectives of the participants
of the organised group - embezzlement of funds, believing that he was investing his funds in order to make a
amount of RUB 650,000 to employees of QBF Group Company (QBF).
Paramonov, as a result of which, having abused his trust, they received them at their disposal, that is, took
deliberately, by deception and breach of trust, stole money belonging to Paramonov S.V. in the amount of
namely:
208
- Thus, on 20.08.2019, at an unspecified time, being in the office of LLC "Investment Company QBF", located at
the address: St. Petersburg, Degtyarny per. 11, lit. "B", Shpakov R.V., Pakhomov V.S., Athanasiadou Linda,
Golubev A.S., Matyukhin S.A., Rossieva E.A. and unidentified persons, acting as an organised group, jointly
and in concert, organised the signing of service agreement No. 169322 - H dated 20.08.2019 with Grif S.V. on
behalf of a non - resident company WLM LTD ("WLM LTD", registered in the Cayman Islands), affiliated with
the criminal association. At the same time, the accomplices deceived Grif S.V. by concealing from her the
information that this organisation had no legal grounds to engage in the type of activity related to securities
transactions, as it did not have the relevant mandatory licence issued by the competent authority of the
Cayman Islands.
V.S. Pakhomov, Athanasiadou Linda , A.S. Golubev, S.A. Matyukhin and unidentified persons, acting in an
community LLC "VL Consulting" (INN ), Rossieva E.A. and unidentified persons, acting as an organised group,
jointly and in concert, organised the conclusion of a service agreement dated 20.08.2019 with Grif S.V. on
behalf of VL Consulting LLC (INN 7706463476), affiliated with the criminal association, and, under the pretext
of fulfilling the terms of the said agreement and contract, persuaded the latter to transfer her funds to them,
209
- Grif S.V., unaware of the crime being prepared and misled as to the true objectives of the participants of the
organised group - embezzlement of funds, believing that she was investing her funds with the aim of making
a profit, which did not correspond to reality, being in the office of LLC "QBF Investment Company" located at
the following address: St. Petersburg, Degtyarny per, 11, Lit. B, St. Petersburg, she transferred cash to the
RUB 2,000,000; 27.08.2019, at an unspecified time, in the amount of RUB 1,000,000.
unaware of the criminal intent, organised the acceptance of the above - mentioned funds from S.V. Grif, as a
result of which, having abused her trust, they received them at their disposal, i.e. took possession of the
stolen funds.
breach of trust, stole money belonging to Grif S.V. in the amount of 3,000,000 rubles, in an especially large
amount.
namely:
210
- So 03.08.2012, at an unspecified time, being in the office of LLC "Kyubi Finance" (INN 7733673955), located at
the address: Moscow, Presnenskaya naberezhnaya, 8, p. 1. 1, under the pretext of investing funds in securities
with high yields, Shpakov R.V., Pakhomov V.S., Munaev Z.V. and unidentified persons, acting as an organised
group, jointly and in concert, organised the signing with Andreev R.V., on behalf of a non - resident affiliated
with the criminal association - QB Capital CY LTD (QB Capital CY registered in the Republic of Cyprus), of an
agreement on direct access to the US securities market No. 648 - 12/VR dated 03.08.2012. The co -
conspirators deceived R.V. Andreev by concealing from him the information that this organisation had no
- Continuing their criminal actions, on 03.08.2012, at an unspecified time, while in the office of Qubey Finance
LLC, located at the address: 8 Presnenskaya Naberezhnaya Naberezhnaya, bld. 1, R.V. Shpakov, V.S.
Pakhomov, Z.V. Munayev and unidentified persons, acting as an organised group, jointly and in concert,
organised the conclusion of an agreement on the provision of trust management services with R.V. Andreev
on behalf of Kyubey Finance LLC, affiliated with the criminal association, under agreement No. 648 - 12/VR of
03.08.2012, and, under the pretext of fulfilling the terms of the said agreement and contract, persuaded the
- R.V. Andreev, unaware of the crime that was being prepared and misled as to the true objectives of the
making a profit, which was not true, made transfers of funds from his account No. 40817840000000022944
opened with JSCB Avangard OJSC, located at 24 Sadovnicheskaya St., p. 6, Moscow, to the account of QB
Capital CY LTD (QB Capital CY LTD) No. CY17008001700000000000688040, opened with Piraeusus. 6, to the
account "QB Capital CY LTD" ("QB Capital CY") No. CY170080017000000000000000688040 opened with
"Piraeus Bank" ("Piraeus Bank", Republic of Cyprus), as follows: 03.09.2012 in the amount of USD 10,000,
which at the exchange rate of the Central Bank of the Russian Federation as of 03.09.09.2012 in the amount of
RUB 325,700; 14.12.2012 in the amount of USD 7,000, which at the exchange rate of the Central Bank of the
Russian Federation as of 14.12.2012 was RUB 214,200. In addition, being in the office of LLC Qubey Finance,
located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, on 14.08.2013. 1, on 14.08.2013, at an
unspecified time, he handed over cash in the amount of RUB 170,000 to employees of the QBF Group
Company (QBF).
jointly and in concert, with the involvement of persons unaware of the criminal intent, organised the
acceptance of the above - mentioned funds from R.V. Andreev, as a result of which, abusing his trust, they
- Continuing their criminal actions, in order to achieve a criminal result aimed at stealing money Andreeva R.V.,
Shpakov R.V., Pakhomov V.S., Munaev Z.V., Athanasiadou Linda, Golubev A.S. and unidentified persons,
acting as an organised group, jointly and in concert, with the involvement of persons unaware of the criminal
intent, under the pretext of fulfilling the terms of the above agreement and contract, under unspecified
211
circumstances, persuaded Andreev R.V. to transfer additional funds to them, ostensibly for trust
management.
- R.V. Andreev, unaware of the forthcoming crime and misled as to the true objectives of the participants of the
organised group - embezzlement of funds, believing that he invested his funds for profit, which was not true,
being in the office of LLC Investment Company QBF Investment, located at the address: Moscow,
26.02.2016 amounted to RUB 611,120 to employees of QBF Group (QBF).
criminal intent, organised the acceptance of the above - mentioned funds from R.V. Andreev, as a result of
organised group, jointly and in concert, organised the signing of a service agreement No. 067774 - J dated
01.10.2019 with Andreev R.V. on behalf of a non - resident company WLM LTD ("WLM LTD", registered in the
Cayman Islands), affiliated with the criminal association. At the same time, the accomplices deceived R.V.
Andreev by concealing from him the information that this organisation had no legal grounds to engage in the
type of activity related to securities transactions, as it did not have the relevant mandatory licence issued by
the competent authority of the Cayman Islands. Subsequently, under the pretext of fulfilling the terms of the
above agreement, they convinced the latter to transfer his funds to them, ostensibly for trust management.
- R.V. Andreev, unaware of the forthcoming crime and misled as to the true objectives of the participants of the
amount of RUB 650,000 to employees of QBF Group Company (QBF).
of persons unaware of the criminal intent, organised the acceptance of the above - mentioned funds from R.V.
Andreev, as a result of which, having abused his trust, they received them at their disposal, i.e. took
persons, under the above circumstances, in the period from 03.09.2012 to 02.10.2019, deliberately, by
deception and breach of trust, stole money belonging to Andreev R.V. in the amount of 1,971,020 rubles, in an
namely:
212
organised the signing of an agreement on the provision of direct access to international stock markets No.
4199 - 17/ISR dated 13.11.2017 with Ivanov K.A. on behalf of a non - resident company QCCI LTD ("QCCI LTD",
registered in the Republic of Cyprus), affiliated with the criminal association. The co - conspirators deceived
K.A. Ivanov by concealing from him the information that this organisation had no legal grounds to engage in
organised group, jointly and in concert, organised the conclusion on behalf of the criminal affiliated LLC
"Investment Company QBF", Rossieva E.A. and unidentified persons, acting as an organised group, jointly
213
and in concert, organised the conclusion of an agreement on the provision of trust management services
with Ivanov K.A. on behalf of QBIF Investment Company LLC, affiliated with the criminal community, under
agreement and contract, convinced the latter to transfer his funds to them, ostensibly for trust management.
- Ivanov K.A., unaware of the crime being prepared and misled as to the true objectives of the participants of
address: St. Petersburg, Degtyarny per, 11, Lit. "B", realised the transfer of cash to the employees of QBF
29.01.2019, at an unspecified time, in the amount of RUB 2,050,000.
unaware of the criminal intent, organised the acceptance of the aforementioned funds from K.A. Ivanov, as a
result of which, having abused his trust, they received them at their disposal, i.e. took possession of the
stolen funds.
- Continuing their criminal actions, in order to achieve a criminal result aimed at stealing the money of Ivanov
K.A., on 29.08.2019, at an unspecified time, being in the office of LLC "Investment Company QBF", located at
the address: St. Petersburg, Degtyarny per. 11, lit. "B", Shpakov R.V., Pakhomov V.S., Athanasiadou Linda,
Golubev A.S., S.A. Matyukhin, E.A. Rossieva and unidentified persons, acting as an organised group, jointly
and in concert, organised the signing of service agreement No. 417040 - H dated 29.08.2019 with K.A. Ivanov
on behalf of a non - resident company WLM LTD ("WLM LTD" registered in the Cayman Islands) affiliated with
the criminal association. The co - conspirators deceived K.A. Ivanov by concealing from him the information
that this organisation had no legal grounds to engage in activities related to securities transactions, as it did
not have the relevant mandatory licence issued by the Cayman Islands competent authority.
Investment Company QBF, located at the address: St. Petersburg, Degtyarny per. 11, lit. "B", Shpakov R.V.,
acting as an organised group, jointly and in concert, organised the conclusion of a service agreement dated
29.08.2019 with Ivanov K.A. on behalf of VL Consulting LLC (INN 7706463476), affiliated with the criminal
association, and, under the pretext of fulfilling the terms of the above agreement and contract, persuaded
- Ivanova K.A., unaware of the crime that was being prepared and misled as to the true objectives of the
he transferred cash in the amount of 25,000 euros, which at the exchange rate of the Central Bank of the
Russian Federation as of 28.10.2019 amounted to 1,778,000 rubles, to the employees of QBF Group Company
(QBF).
unaware of the criminal intent, organised the acceptance of the aforementioned funds from K.A. Ivanov, as a
stolen funds.
breach of trust, stole money belonging to Ivanov K.A. in the amount of 6,328,000 rubles, in an especially large
amount.
214
namely:
discretion.
215
organised the signing of trust management agreement No. 4747 - 19/ISR dated 23.01.2019 with Petrov P.E. on
behalf of the non - resident company White Lake Management LTD (registered in the Cayman Islands),
affiliated with the criminal association. The co - conspirators deceived Petrov P.E. by concealing from him the
information that this organisation had no legal grounds to engage in activities related to securities
Cayman Islands.
dated 23.01.2019 with Petrov P.E. on behalf of QBF Advisery LLC (INN 7703426941), affiliated with the criminal
association, and, under the pretext of fulfilling the terms of the said agreements, persuaded the latter to
transfer his funds to them ostensibly for trust management.
- Petrov P.E., unaware of the crime being prepared and misled as to the true objectives of the participants of
the organised group - embezzlement of funds, believing that he was investing his funds for the purpose of
making profit, which was not true, on 30.01.2019 he transferred funds from his account No.
40817840508060000842, opened in the branch of JSC "Alfa Bank", located at the address: St. Petersburg,
Polikarpova Alley, d. 2, to the account of Simtelligence Company Limited No. 40817840508060000842,
opened in Ameriabank, Republic of Armenia, in the amount of USD 45,000. 2, to Simtelligence Company
Limited account No. 1570033649480101 opened with Ameriabank (Ameriabank, Republic of Armenia) in the
30.01.2019 amounted to RUB 2,985,300, and on 15.11.2019 transferred funds from his account No.
40817840508060000842 opened with the branch of JSC Alfa Bank located at: St. Petersburg, Polikarpov Alley,
ul. 2, Polikarpova Alley, St. Petersburg, to Simtelligence Company Limited account No. 1570033649480101
opened with Ameriabank (Republic of Armenia) in the amount of USD 15,000, which at the exchange rate of
the Central Bank of the Russian Federation as of 15.11.2019 was RUB 938,250.
unaware of the criminal intent, having received Petrov P.E.'s money at their disposal, abused his trust and
stole the money.
under the above circumstances, in the period from 30.01.2019 to 15.11.2019, deliberately, by deceit and
breach of trust, stole money belonging to Petrov P.E. in the amount of 3,923,550 rubles, in an especially large
amount.
namely:
216
A.S. Golubev, S.A. Matyukhin and unidentified persons, acting as an organised group, jointly and in concert,
organised the signing of an agreement on the provision of services of direct access to international stock
markets No. 3332 - 17/IMR dated 01.08.2017 with T.V. Baskova on behalf of a non - resident company QB
Capital CY LTD ("QB Capital CY LTD", registered in the Republic of Cyprus), affiliated with the criminal
association. The co - conspirators deceived T.V. Baskova by concealing from her the information that this
Munaev Z.V., Athanasiadou Linda, Golubev A.S.. 1, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev, Athanasiadou
Linda , A.S. Golubev, S.A. Matyukhin and unidentified persons, acting as an organised group, jointly and in
concert, organised the conclusion of an agreement on the provision of trust management services with T.V.
217
Baskova on behalf of QBIF Investment Company LLC, affiliated with the criminal association, under
agreement No. 3332 - 17/IMR dated 01.08.2017 and, under the pretext of fulfilling the terms of the said
management.
- T.V. Baskova, unaware of the crime that was being prepared and misled as to the true objectives of the
members of the organised group - embezzlement of funds, believing that she was investing her funds for
Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, on 14.08.2017, at an unspecified time, she handed over cash
in the amount of RUB 4,220,000 to employees of QBF Group Company (QBF).
- In turn, R.V. Shpakov, V.S. Pakhomov, Z.V. Munayev, Athanasiadou Linda , A.S. Golubev, S.A. Matyukhin and
unaware of the criminal intent, organised the acceptance of the above - mentioned funds from T.V. Baskova,
stolen funds.
unidentified persons, acting as an organised group, jointly and in concert, organised the signing of service
agreement No. 682385 - K dated 28.11.2019 with Baskova T.V. on behalf of a non - resident company "WLM
LTD" ("WLM LTD", registered in the Cayman Islands), affiliated with the criminal association. The co -
conspirators deceived T.V. Baskova by concealing from her the information that this organisation did not have
relevant mandatory licence issued by the Cayman Islands competent authority. Subsequently, under the
pretext of fulfilling the terms of this agreement, they convinced the latter to transfer her funds to them,
- T.V. Baskova, unaware of the crime that was being prepared and misled as to the true objectives of the
to make a profit, which was not true, being in the office of LLC Investment Company QBF, located at the
address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, on 28.11.2019, at an unspecified time, she
of persons unaware of the criminal intent, organised the acceptance of the above - mentioned funds from T.V.
Baskova, as a result of which, having abused her trust, they received them at their disposal, i.e. took
deceit and breach of trust, stole money belonging to Baskova T.V. in the amount of 4,565,438 rubles, in an
namely:
218
organised the signing with Mishin I.Y., on behalf of a non - resident affiliated with the criminal association -
services to international stock markets No. 4496 - 18/ISR dated 14.08.2018. The co - conspirators deceived
Mishin I.Y. by concealing from him the information that this organisation had no legal grounds to engage in
the type of activity related to securities transactions, as it did not have the relevant mandatory licence issued
by the authorised body of the Republic of Cyprus.
219
dated 14.08.2018 with Mishin I.Y. on behalf of QBF Advisery LLC (INN 7703426941), affiliated with the criminal
- Mishin I.Y., unaware of the crime being prepared and misled as to the true objectives of the participants of the
Petersburg, Degtyarny per, 11, lit. "B", realised the transfer of cash to the employees of QBF Group Company
(QBF) as follows: 16.11.2018, at an unspecified time, in the amount of USD 10,000, which at the exchange rate
of the Central Bank of the Russian Federation as of 16.11.2018 was RUB 666,200; in January 2019, the exact
date and time have not been established by the investigation, in the amount of USD 5,474, which at the
maximum exchange rate of the Central Bank of the Russian Federation as of January 2019 was RUB
367,798.06; in November 2019, the exact date and time have not been established by the investigation, in the
amount of USD 8,500, which at the maximum exchange rate of the Central Bank of the Russian Federation as
of November 2019 was RUB 545,785.
unaware of the criminal intent, organised the acceptance of the aforementioned funds from I.Y. Mishin, as a
stolen money.
breach of trust, stole money belonging to Mishin I.Y. in the amount of 1,579,783.06 rubles, in an especially
large amount.
namely:
220
organised the signing with Nazarenkov A.V., on behalf of a non - resident affiliated with the criminal
association - the company "WLM LTD" ("WLM LTD", registered in the Cayman Islands), of service agreement
No. 779786 - L, dated 17.12.2019. The co - conspirators deceived A.V. Nazarenkov by concealing from him the
information that this organisation had no legal grounds to engage in activities related to securities
Cayman Islands.
with the criminal community LLC "VL Consulting" (INN ), Rossieva E.A. and unidentified persons, acting as an
organised group, jointly and in concert, organised the conclusion of a service agreement dated 17.12.2019
with Nazarenkov A.V. on behalf of VL Consulting LLC (INN 7706463476), affiliated with the criminal
association, and under the pretext of fulfilling the terms of the said agreement and contract convinced the
- Nazarenkov A.V., unaware of the crime that was being prepared and misled as to the true objectives of the
he transferred to the employees of QBF Group Company (QBF) cash in the amount of USD 2,600, which at the
exchange rate of the Central Bank of the Russian Federation as of 19.12.2019 amounted to RUB 162,708 and
221
in the amount of EUR 47,000, which at the exchange rate of the Central Bank of the Russian Federation as of
19.12.2019 amounted to RUB 3,275,430.
unaware of the criminal intent, organised the acceptance of the above money from A.V. Nazarenkov, as a
stolen funds.
trust, on 19.12.2019 stole money belonging to Nazarenkov A.V. in the amount of 3,438,138 rubles, in a
particularly large amount.
namely:
222
organised the signing of service agreement No. 899182 - L dated 23.12.2019 with Burmistrov V.N. on behalf of
a non - resident company WLM LTD ("WLM LTD", registered in the Cayman Islands), affiliated with the criminal
association. The co - conspirators deceived V.N. Burmistrov by concealing from him the information that this
it did not have the relevant mandatory licence issued by the Cayman Islands competent authority.
acting as an organised group, jointly and in concert, organised the conclusion of a service agreement dated
23.12.2019 with Burmistrov V.N. on behalf of VL Consulting LLC (INN 7706463476), affiliated with the criminal
latter to transfer his funds to them allegedly for trust management.
- V.N. Burmistrov, unaware of the crime that was being prepared and misled as to the true objectives of the
he transferred cash in the amount of 2,550,000 rubles to the employees of QBF Group Company (QBF).
unaware of the criminal intent, organised the acceptance of the above money from V.N. Burmistrov, as a
stolen money.
trust, on 25.12.2019 stole money belonging to Burmistrov V.N. in the amount of 2,550,000 rubles, in an
namely:
223
concert, organised the signing with Mishin Y.A., on behalf of a non - resident affiliated with the criminal
direct access to international stock markets No. 4108 - 17/ISR dated 31.10.2017. At the same time, the
accomplices deceived Mishin Yu.A. by concealing from him the information that this organisation did not
Pakhomov, Athanasiadou Linda , A.S. Golubev, S.A. Matyukhin, and unidentified persons acting in an
224
Mishin Y.A. on behalf of QBIF Investment Company LLC, affiliated with the criminal association, under
- Mishin Y.A., unaware of the crime being prepared and misled as to the true objectives of the participants of
making a profit, which was untrue, being in the office of Investment Company QBF LLC, located at the
address: St. Petersburg, Maloohtinsky Prospe, 64, lit. "B", realised the transfer of cash to the employees of
12.02.2018, at an unspecified time, in the amount of RUB 540,000, as well as being in the office of LLC
"Investment Company QBF" located at: St. Petersburg, Degtyarny per, 11, lit. "B", made a cash transfer to
employees of QBF Group Company (QBF) as follows: In January 2019, the exact date and time have not been
determined by the investigation, in the amount of USD 9,900, which at the maximum exchange rate of the
Central Bank of the Russian Federation for January 2019 was RUB 665,181; in February 2019, the exact date
and time have not been determined by the investigation, in the amount of USD 11,500, which at the
maximum exchange rate of the Central Bank of the Russian Federation for February 2019 was RUB 767,050; in
March 2019, the exact date and time have not been determined by the investigation, in the amount of USD
3,000, which at the maximum exchange rate of the Central Bank of the Russian Federation for m
unaware of the criminal intent, organised the acceptance of the aforementioned funds from Y.A. Mishin, as a
stolen funds.
- Continuing their criminal actions, in order to achieve a criminal result aimed at stealing the funds of Mishin
Yu.A., on 03.10.2019, at an unspecified time, being in the office of LLC "Investment Company QBF" (INN
7733673955), located at: St. Petersburg, Degtyarny per, 11, lit. "B", under the pretext of investing money in
securities with high yield, R.V. Shpakov, V.S. Pakhomov, Athanasiadou Linda , A.S. Golubev, S.A. Matyukhin,
and E.A. Rossieva, under the pretext of investing in securities with high yields, Rossieva E.A. and unidentified
persons, acting as an organised group, jointly and in concert, organised the signing of a trust management
agreement No. D - 048711 - J dated 03.10.2019 with Mishin Y.A. on behalf of White Lake Management LTD, a
non - resident company registered in the Cayman Islands, affiliated with the criminal association, and, under
the pretext of fulfilling the terms of the said agreement, persuaded the latter to transfer his funds to them,
ostensibly for trust management. At the same time, the accomplices deceived Mishin Yu.A. by concealing
from him the information that this organisation did not have legal grounds to engage in the type of activity
related to securities transactions, as it did not have the relevant mandatory licence issued by the competent
authority of the Cayman Islands.
- Mishin Y.A., unaware of the crime that was being prepared and misled as to the true objectives of the
the aim of making a profit, which was not true, being in the office of LLC "Investment Company QBF", located
at the address: St. Petersburg, Degtyarny per, 11, lit. "B", in December 2019, the exact date and time not
determined by the investigation, he transferred cash in the amount of USD 19,145, which at the maximum
exchange rate of the Central Bank of the Russian Federation as of December 2019 was RUB 1,233,129.45, to
the employees of QBF Group (QBF).
unaware of the criminal intent, organised the acceptance of the aforementioned funds from Y.A. Mishin, as a
stolen funds.
225
breach of trust, stole money belonging to Mishin Y.A. in the amount of 5,533,493.45 rubles, in an especially
large amount.
namely:
226
Matyukhin S.A. and unidentified persons acting in an organised group, jointly and in concert, organised the
signing with Mazitov V.G. on behalf of a non - resident affiliated with the criminal association, E.A. Rossieva
and unidentified persons, acting as an organised group, jointly and in concert, organised the signing of
service agreement No. 830245 - B dated 03.02.2020 with V.G. Mazitov on behalf of a non - resident company
WLM LTD ("WLM LTD", registered in the Cayman Islands), affiliated with the criminal association. The co -
conspirators deceived V.G. Mazitov by concealing from him the information that this organisation had no
jointly and in concert, organised the conclusion of a service agreement dated 03.02.2020 with Mazitov V.G. on
of fulfilling the terms of the said agreement and contract, persuaded the latter to transfer his funds to them,
- Mazitov V.G., unaware of the crime being prepared and misled as to the true objectives of the participants of
profit, which did not correspond to reality, being in the office of LLC "QBF Investment Company" located at
the address: St. Petersburg, Degtyarny per, 11, lit. "B", on 03.02.2020, at an unspecified time, he transferred to
the employees of QBF Group Company (QBF) cash in the amount of USD 65,000, which at the exchange rate
of the Central Bank of the Russian Federation as of 03.02.2020 amounted to RUB 4,104,100.
unaware of the criminal intent, organised the acceptance of the aforementioned funds from V.G. Mazitov, as a
stolen funds.
under the circumstances described above, deliberately, through deceit and abuse of trust, on 03.02.2020
stole money belonging to Mazitov V.G. in the amount of 4,104,100 roubles, in an especially large amount.
namely:
227
- Thus, on 28.11.2019, at an unspecified time, being in the office of LLC "Investment Company QBF", located at
the address: Moscow, Presnenskaya naberezhnaya, 8, p. 1. 1, R.V. Shpakov, V.S. Pakhomov, Z.V. Munaev,
organised group, jointly and in concert, organised the signing of a service agreement No. 284592 - K, dated
27.11.2019, with Toloknov D.Y. on behalf of a non - resident company "WLM LTD" ("WLM LTD", registered in the
Cayman Islands), affiliated with the criminal association. The co - conspirators deceived Toloknov D.Y. by
concealing from him the information that this organisation had no legal grounds to engage in activities
related to securities transactions, as it did not have the relevant mandatory licence issued by the competent
service agreement dated 27.11.2019 with Toloknov D.Y. on behalf of VL Consulting LLC (INN 7706463476),
affiliated with the criminal association, and, under the pretext of fulfilling the terms of the above agreement
and contract, persuaded the latter to transfer his funds to them, ostensibly for trust management.
228
- Toloknov D.Y., unaware of the crime that was being prepared and misled as to the true objectives of the
following address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, realised the transfer of cash to the
RUB 959,550; 06.02.2020, at an unspecified time, in the amount of USD 30,000, which at the exchange rate of
the Central Bank of the Russian Federation as of 06.02.2020 was RUB 1,895,100.
of persons unaware of the criminal intent, organised the acceptance of the above money from D.Y. Toloknov,
as a result of which, having abused his trust, they received them at their disposal, that is, took possession of
the stolen funds.
persons, under the above circumstances, in the period from 28.11.2019 to 06.02.2020, deliberately, by deceit
and breach of trust, stole money belonging to Toloknov D.Y. in the amount of 2,854,650 rubles, in an
namely:
229
organised the signing of service agreement No. 416912 - E dated 31.05.2019 with Kim A.L. on behalf of a non -
resident company WLM LTD ("WLM LTD", registered in the Cayman Islands), affiliated with the criminal
association. At the same time, the accomplices deceived Kim A.L. by concealing from him the information
that this organisation did not have legal grounds to engage in the type of activity related to securities
transactions, as it did not have the relevant mandatory licence issued by the Cayman Islands competent
authority.
with Kim A.L. on behalf of VL Consulting LLC (INN 7706463476), affiliated with the criminal association, and,
under the pretext of fulfilling the terms of the above agreement and contract, persuaded the latter to transfer
his funds to them, ostensibly for trust management.
- Kim A.L., unaware of the crime that was being prepared and misled as to the true objectives of the
QBF", located at the address: St. Petersburg, Degtyarny per. 11, lit. "B", carried out the transfer of cash to the
employees of the company of the QBF group (QBF) as follows: 31.05.2019, at an unspecified time, in the
amount of RUB 1,700,000; 13.06.2019, at an unspecified time, in the amount of RUB 1,600,000; 04.07.2019, at
an unspecified time, in the amount of RUB 4,500,000; 01.08.2019, at an unspecified time, in the amount of
RUB 6,000,000; 31.10.2019, at an unspecified time, in the amount of RUB 600,000; and 10.02.2020, at an
unspecified time, in the amount of RUB 13,000,000.
unaware of the criminal intent, organised the acceptance of the above - mentioned funds from A.L. Kim, as a
stolen funds.
230
breach of trust, stole money belonging to Kim A.L. in the amount of 27,400,000 rubles, in an especially large
amount.
231
signing with Troshkova M.S. on behalf of a non - resident affiliated with the criminal community, on behalf of
a non - resident affiliated with the criminal association, E.A. Rossieva and unidentified persons, acting as an
organised group, jointly and in concert, organised the signing of service agreement No. 617579 - B dated
18.02.2020 with M.S. Troshkova on behalf of a non - resident company WLM LTD ("WLM LTD", registered in the
Cayman Islands), affiliated with the criminal association. The co - conspirators deceived M.S. Troshkova by
concealing from her the information that this organisation had no legal grounds to engage in activities
related to securities transactions, as it did not have the relevant compulsory licence issued by the Cayman
Islands competent authority.
jointly and in concert, organised the conclusion of a service agreement dated 18.02.2020 with Troshkova M.S.
on behalf of VL Consulting LLC (Taxpayer Identification Number 7706463476), affiliated with the criminal
association, and, under the pretext of fulfilling the terms of the said agreement and contract, persuaded the
latter to transfer her funds to them, ostensibly for trust management.
- Troshkova M.S., unaware of the crime being prepared and misled as to the true objectives of the participants
located at the address: St. Petersburg, Degtyarny Lane, 11, lit. "B", on 18.02.2020, at an unspecified time, she
transferred cash in the amount of EUR 10,000, which at the exchange rate of the Central Bank of the Russian
unaware of the criminal intent, organised the acceptance of the above - mentioned funds from M.S.
Troshkova, as a result of which, having abused her trust, they received them at their disposal, that is, took
stole money belonging to Troshkova M.S. in the amount of 686,200 rubles, in a large amount.
namely:
232
signing with Ganeva E.P. on behalf of a non - resident affiliated with the criminal association, E.A. Rossieva
and unidentified persons, acting as an organised group, jointly and in concert, organised the signing of
service agreement No. 738025 - B dated 28.02.2020 with E.P. Ganeva on behalf of a non - resident company
WLM LTD ("WLM LTD", registered in the Cayman Islands), affiliated with the criminal association. The co -
conspirators deceived E.P. Ganeva by concealing from her the information that this organisation had no legal
grounds to engage in activities related to securities transactions, as it did not have the relevant compulsory
licence issued by the Cayman Islands competent authority.
jointly and in concert, organised the conclusion of a service agreement dated 28.02.2020 with Ganeva E.P. on
233
of fulfilling the terms of the said agreement and contract, persuaded the latter to transfer her funds to them,
- E.P. Ganeva, unaware of the crime that was being prepared and misled as to the true objectives of the
participants of the organised group - embezzlement of funds, believing that she was investing her funds in
order to make a profit, which was not true, being in the office of LLC "QBF Investment Company" located at
the address: St. Petersburg, Degtyarny per, 11, lit. "B", on 28.02.2020, at an unspecified time, she transferred
to the employees of QBF Group Company (QBF) cash in the amount of USD 14,300, which at the exchange
rate of the Central Bank of the Russian Federation as of 28.02.2020 amounted to RUB 938,223 and in the
amount of EUR 13,700, which at the exchange rate of the Central Bank of the Russian Federation as of
28.02.2020 amounted to RUB 981,605.
unaware of the criminal intent, organised the acceptance of the above money from E.P. Ganeva, as a result of
which, having abused her trust, they received them at their disposal, i.e. took possession of the stolen funds.
under the circumstances described above, deliberately, through deceit and breach of trust, on 28.02.2020
stole money belonging to Ganeva E.P. in the amount of 1,919,828 rubles, in an especially large amount.
namely:
234
of the group, by means of deceit and abuse of trust, which consisted in creating in natural persons - clients of
brokerage services) and other investment agreements. These agreements and contracts were concluded for
discretion.
signing with Podgornaya I.A., on behalf of a non - resident affiliated with the criminal association, E.A.
Rossieva and unidentified persons, acting as an organised group, jointly and in concert, organised the signing
of service agreement No. 110500 - D dated 21.04.2020 with I.A. Podgornaya on behalf of a non - resident
company WLM LTD ("WLM LTD", registered in the Cayman Islands), affiliated with the criminal association.
The co - conspirators deceived I.A. Podgornaya by concealing from her the information that this organisation
had no legal grounds to engage in activities related to securities transactions, as it did not have the relevant
jointly and in concert, organised the conclusion of a service agreement dated 21.04.2020 with Podgornaya
I.A. on behalf of VL Consulting LLC (INN 7706463476), affiliated with the criminal association, and, under the
pretext of fulfilling the terms of the said agreement and contract, persuaded the latter to transfer her funds to
- I.A. Podgornaya, unaware of the crime being prepared and misled as to the true objectives of the participants
of the organised group - embezzlement of funds, believing that she was investing her funds for profit, which
was not true, being in the office of LLC "QBF Investment Company" located at the address: St. Petersburg,
Degtyarny per, 11, lit. "B", on 21.04.2020, at an unspecified time, she transferred cash in the amount of RUB
3,900,000 and EUR 38,500, which at the exchange rate of the Central Bank of the Russian Federation as of
21.04.2020 amounted to RUB 3,122,350 to the employees of QBF Group Company (QBF).
unaware of the criminal intent, organised the acceptance of the above - mentioned funds from I.A.
Podgornaya, as a result of which, having abused her trust, they received them at their disposal, that is, took
235
stole money belonging to Podgornaya I.A. in the amount of 7,022,350 rubles, in a particularly large amount.
namely:
236
organised the signing of service agreement No. 192630 - E dated 28.05.2019 with Kovin A.P. on behalf of a non
- resident company WLM LTD ("WLM LTD", registered in the Cayman Islands), affiliated with the criminal
association. The co - conspirators deceived Kovin A.P. by concealing from him the information that this
with Kovin A.P. on behalf of VL Consulting LLC (INN 7706463476), affiliated with the criminal association, and,
under the pretext of fulfilling the terms of the above agreement and contract, persuaded the latter to transfer
his funds to them, ostensibly for trust management.
- Kovin A.P., unaware of the crime being prepared and misled as to the true objectives of the participants of the
Petersburg, Degtyarny per, 11, lit. "B", realised the transfer of cash to the employees of QBF Group Company
(QBF) as follows: 28.05.2019, at an unspecified time, in the amount of EUR 300,000, which at the exchange
rate of the Central Bank of the Russian Federation as of 28.05.2019 was RUB 21,657,000; 30.08.2019, at an
unspecified time, in the amount of EUR 250,000, which at the exchange rate of the Central Bank of the
Russian Federation as of 30.08.2019 was RUB 18,490,000 and USD 130,000, which at the exchange rate of the
Central Bank of the Russian Federation as of 30.08.2019 was RUB 8,677,500; 06.11.2019, at an unspecified
time, in the amount of EUR 50,000, which at the exchange rate of the Central Bank of the Russian Federation
as of 06.11.2019 was RR 3,521,000; 29.11.2019, at an unspecified time, in the amount of EUR 50,000, which at
the exchange rate of the Central Bank of the Russian Federation as of 29.11.2019 was RR 3,528,500 and USD
170,000, which at the exchange rate of the Central Bank of the Russian Federation as of 29.11.2019 was RR
10,897,000; 23.04.2020, at an unspecified time, in the amount of RR 6,000,000.
unaware of the criminal intent, organised the acceptance of the above - mentioned funds from A.P. Kovin, as
a result of which, having abused his trust, they received them at their disposal, i.e. took possession of the
stolen funds.
breach of trust, stole money belonging to Kovin A.P. in the amount of 72,771,000 rubles, in an especially large
amount.
namely:
237
the group, by means of deceit and abuse of trust, which consisted in creating a false appearance of the
possibility of obtaining a high income among natural persons - clients of the companies of the group,
persuaded clients to conclude various investment contracts with LLC IC QBF, including a contract for the
provision of brokerage services, as well as to transfer under these contracts to the trust management of
them, the co - conspirators, their funds, which were then transferred to them, the co - conspirators.
- Under the brokerage services agreement, the Company, acting as a broker in executing transactions,
undertook to fulfil clients' orders to conclude transactions with derivative financial instruments, including
options, the underlying asset of which was foreign issuers' equity securities (hereinafer - OTC option
contracts), in the OTC market aimed at bringing profit to the clients (hereinafer - OTC option contracts). The
counterparty (seller) under all OTC option contracts, including those concluded in the interests of individual
clients, was Q-BROKER LLC, an affiliate of QBIF LLC. At the same time, in accordance with the criminal plan of
the participants of the criminal association, the realisation of OTC options by Q-BROKER LLC was to function
as a financial pyramid scheme, where the source of return of funds to clients under OTC option contracts
executed by Q-BROKER LLC in full or in part were funds received under newly concluded option contracts,
and the ultimate goal of concluding such contracts was in fact the implementation of schematic operations
(financial transactions) aimed at withdrawal of funds from OTC option contracts.
- Thus, R.V. Shpakov, V.S. Pakhomov, S.A. Matyukhin, using their official positions in the above - mentioned
organisations of the above - mentioned group of companies, Athanasiadou Linda , A.S. Golubev, E.A.
Rossieva and unidentified persons, being mainly in the office premises of LLC IC QBF, located at the address:
Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, as well as in unspecified places, acting as an organised
238
group, as part of a criminal association, jointly and in concert, at an unspecified period of time, but not later
than 29.05.2020, remotely, using unidentified information and telecommunication means of communication,
misled Zatsarinsky D.E. about their true intentions - the thef of his funds, under the pretext of executing an
order to conclude over - the - counter option contracts on the OTC market, without initially intending to
execute the taken order.
- Continuing their criminal actions, Shpakov R.V., Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda, Golubev
A.S., Rossieva E.A. and unidentified persons, acting in an organised group, jointly and in concert, on
29.05.2020, at an unspecified time and place, arranged for Zatsarinskiy D.E. to sign an application for consent
to conclude a brokerage services agreement with IC QBF LLC (application for adhesion for individuals), on the
basis of which on 29.05.05.2020 between Zatsarinskiy D.E. and "IC "QBF" LLC, named as a broker, concluded
the agreement on brokerage services No. FB - 528 dated 29.05.2020, and under the pretext of fulfilling the
conditions of the said agreement convinced the latter to transfer his funds to them, allegedly for trust
management.
- Zatsarinsky D.E., unaware of the crime that was being prepared and misled as to the true objectives of the
participants of the organised group - the thef of his funds, convinced that his funds would be returned afer
the terms of the option agreement were fulfilled, on 01.06.2020 made transfers of funds from his account No.
40817810300020006687 opened with LLC FFIN Bank, located at: Moscow, Karetny Ryad str. 5/10, Bldg. 2, to
QBIF LLC's account No.40701810700003010998 opened with NSD ("National Settlement Depository") located
at 12 Spartakovskaya Street, Moscow, under Brokerage Services Agreement No. FB - 528 dated 29.05.2020 in
the amount of RUB 900,000 and RUB 500,000, totalling RUB 1,400,000.
- Having received these funds from Zatsarinsky D.E. in the total amount of 1,400,000 roubles, Shpakov R.V.,
Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda, Golubev A.S., E.A. Rossieva and unidentified persons
disposed of them at their own discretion, in accordance with the criminal plan and in fulfilment of a joint
criminal intent, thereby stealing, knowingly without intending to fulfil their obligations to fulfil the terms of
the option agreement, pay and return the funds to the client.
- Further, realising that the activities of QBIF LLC were subject to inspection by the regulator, the Central Bank
of the Russian Federation, in order to conceal their criminal activities and to make their actions look
legitimate, as well as to create a belief in Zatsarinsky D.E. that his money would be invested profitably, R.V.
Shpakov, Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda, Golubev A.S., Rossieva E.A. and unidentified
persons, abusing the confidence of Zatsarinsky D.E., as well as persons unaware of the criminal intent,
persuaded him to sign instructions to a broker in order to conclude over - the - counter derivative
transactions with derivative financial instruments, namely options, in accordance with which Zatsarinsky
D.E.'s funds in various amounts were transferred to QBIF LLC as a security payment to the accounts of the
options seller, Q-BROKER LLC, an affiliate of QBIF LLC.
- Subsequently, in accordance with the criminal plan, the money stolen by the co - conspirators was used by
them to carry out scheme operations (financial transactions) aimed at withdrawing money outside the
Russian Federation, cashing out, purchasing real estate, financing construction and issuing loans to legal
entities and individuals affiliated with the co - conspirators.
Shpakov R.V., Matyukhin S.A., Athanasiadou Linda, Golubev A.S., Rossieva E.A. and unidentified persons,
stole money belonging to Zatsarinsky D.E. in the amount of 1,400,000 roubles, in an especially large amount.
239
concert, organised the signing of an agreement on the provision of direct access services to international
stock markets No. 4170 - 17/ISR dated 11.11.2017 with Mudrogin A.V. on behalf of a non - resident company
QCCI LTD ("QCCI LTD", registered in the Republic of Cyprus), affiliated with the criminal association. The co -
conspirators deceived A.V. Mudrogin by concealing from him the information that this organisation had no
240
Mudrogin A.V. on behalf of QBIF Investment Company LLC, affiliated with the criminal community, under
- Mudrogin A.V., unaware of the crime being prepared and misled as to the true objectives of the participants of
transferred cash in the amount of 593,000 rubles to the employees of QBF Group Company (QBF).
unaware of the criminal intent, organised the acceptance of the above money from A.V. Mudrogin, as a result
funds.
Mudrogin A.V., on 15.11.2019, at an unspecified time, being in the office of LLC "Investment Company QBF"
(INN 7733673955), located at the address: St. Petersburg, Degtyarny per. 11, lit. "B", under the pretext of
concert, organised the signing of a service agreement No. 760239 - K dated 15.11.2019 with Mudrogin A.V. on
behalf of a non - resident company "WLM LTD" ("WLM LTD", registered in the Cayman Islands), affiliated with
the criminal association. The co - conspirators deceived A.V. Mudrogin by concealing from him the
information that this organisation had no legal grounds to engage in the type of activity related to securities
Cayman Islands.
with Mudrogin A.V. on behalf of VL Consulting LLC (INN 7706463476), affiliated with the criminal association,
and under the pretext of fulfilling the terms of the said agreement and contract, convinced the latter to
transfer his funds to them, ostensibly for trust management.
- Mudrogin A.V., unaware of the crime that was being prepared and misled as to the true objectives of the
he transferred cash in the amount of 350,000 rubles to the employees of QBF Group Company (QBF).
unaware of the criminal intent, organised the acceptance of the above money from A.V. Mudrogin, as a result
funds.
241
breach of trust, stole funds belonging to Mudrogin A.V. in the amount of 943,000 rubles, in a large amount.
namely:
provision of brokerage services, as well as to transfer their money under these contracts to the trust
management of them, the co - conspirators, which were then transferred to them, the co - conspirators.
242
and the ultimate goal of concluding such contracts was actually the implementation of schematic operations
- Thus R.V. Shpakov, V.S. Pakhomov, S.A. Matyukhin, using their official positions in the above - mentioned
Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, as well as in unspecified places, acting in an organised
group, as part of a criminal association, jointly and in concert, at an exactly unspecified period of time, but no
later than 20.05.2020, when A.V. Rucheev visited the office of OOO IC QBF, located at the address: Moscow,
Presnenskaya Naberezhnaya, 8, p. 1, Moscow, Presnenskaya Embankment, as well as remotely, from a
remote location, from the premises of OOO IC QBF, located at the address: 8, p. 1, Presnenskaya
Naberezhnaya, Moscow. 1, as well as remotely, using unidentified information and telecommunication
means of communication, misled A.V. Rucheev about their true intentions - the thef of his funds, under the
pretext of making transactions with securities during their initial public offering (IPO - Initial Publik Offering)
on foreign stock exchanges, having neither the ability nor the intention to fulfil their obligations to both
purchase and further transfer of securities to the account of the client - A.V. Rucheev.
- Continuing their criminal actions, R.V. Shpakov, V.S. Pakhomov, S.A. Matyukhin, Athanasiadou Linda , A.S.
Golubev, E.A. Rossieva and unidentified persons, acting as an organised group, jointly and in concert, on
20.05.2020, at an unspecified time, organised the signing at the address: Moscow, 132 Bolshaya
Semyonovskaya str. 7 with A.V. Rucheev on the statement of consent to the conclusion of the agreement on
rendering brokerage services with "IC QBF" LLC (application on joining for individuals), on the basis of which
on 20.05.2020 between A.V. Rucheev. On the basis of which on 20.05.2020 between A.V. Rucheev and "IC QBF"
LLC, named as a broker, concluded a brokerage services agreement No. FB - 502 of 20.05.2020, and under the
pretext of fulfilling the conditions of the said agreement persuaded the latter to transfer his funds to them
allegedly for trust management.
- A.V. Ruchiev, unaware of the crime being prepared and misled as to the true objectives of the participants of
the organised group - the thef of his funds, convinced that his funds would be used to purchase securities at
their initial public offering with their subsequent transfer to a personalised account and registration in his
name, in the period from 02.06.06.2020 - 29.06.2020 he transferred funds from his account No.
40817810538048350189 opened with PJSC "Sberbank" in branch No. 9038/01872, located at the address:
Moscow, Romanov per, 4, to QBIF LLC's account No. 40701810700003010998 opened with NSD ("National
Settlement Depository") located at: Moscow, Spartakovskaya str. 12, under Brokerage Services Agreement
No. FB - 502 dated 20.05.2020, namely: RUB 100,000,000 on 02.06.2020, RUB 50,000,000 on 08.06.2020, RUB
25,000,000 on 16.06.2020 and RUB 20,000,000 on 29.06.2020, totalling RUB 195,000,000.
- Having received these funds from A.V. Ruchieva in the total amount of 195,000,000 roubles, R.V. Shpakov, V.S.
Pakhomov, S.A. Matyukhin, Athanasiadou Linda , A.S. Golubev and unidentified persons disposed of them at
their own discretion in accordance with the criminal plan and in fulfilment of a joint criminal intent, thereby
stealing them, knowingly without intending to execute them, E.A. Rossieva and unidentified persons
legitimate, as well as to create a conviction in A.V. Rucheev that his money was profitably invested, R.V.
persons, abusing A.V. Ruchiev's trust, as well as persons unaware of the criminal intent, persuaded him to
sign instructions to a broker for the purpose of entering into OTC derivative transactions, namely options, in
accordance with which A.V. Ruchiev's funds in various amounts were transferred to QBIF LLC as a security
payment to the accounts of the options seller, Q-BROKER LLC, an affiliate of QBIF LLC.
243
breach of trust, stole money belonging to Rucheev A.V. in the amount of 195,000,000 roubles, in an especially
large amount.
namely:
244
Matyukhin S.A. and unidentified persons acting in an organised group, jointly and in concert organised the
signing with Donskiy I.V. on behalf of a non - resident affiliated with the criminal association - non - resident -
Rossiyeva E.A.., E.A. Rossieva and unidentified persons, acting as an organised group, jointly and in concert,
organised the signing of service agreement No. 101936 - G dated 08.07.2020 with I.V. Donskiy on behalf of a
non - resident company WLM LTD ("WLM LTD", registered in the Cayman Islands), affiliated with the criminal
association. The accomplices deceived Donskoy I.V. by concealing from him the information that this
jointly and in concert, organised the conclusion of a service agreement dated 08.07.2020 with Donskiy I.V. on
of fulfilling the terms of the said agreement and contract, persuaded the latter to transfer his funds to them,
- Donskoy I.V., unaware of the crime being prepared and misled as to the true objectives of the participants of
address: St. Petersburg, Degtyarny per, 11, lit. "B", on 08.07.2020, at an unspecified time, he transferred cash
08.07.2020 amounted to RUB 1,443,400 to the employees of QBF Group Company (QBF).
unaware of the criminal intent, organised the acceptance of the aforementioned funds from I.V. Donskoy, as a
stolen funds.
belonging to Donskoy I.V. in the amount of 1,443,400 rubles, in an especially large amount.
namely:
245
the participants of the criminal association, the implementation of OTC options by Q-BROKER LLC was to
function as a financial pyramid scheme, where the source of return of funds to clients under OTC option
contracts executed by Q-BROKER LLC in full or in part were funds received under newly concluded option
contracts, and the ultimate goal of concluding such contracts was actually the implementation of schematic
operations (financial transactions) aimed at withdrawal of funds from the OTC option contracts.
organisations of the named group of companies, Athanasiadou Linda , A.S. Golubev, E.A. Rossieva and
unidentified persons, being mainly in the office premises of LLC IC QBF, located at the address: Moscow,
Presnenskaya Naberezhnaya, 8, p. 1. 1, as well as in unspecified places, acting as an organised group, as part
of a criminal association, jointly and in concert, at an unspecified period of time, but not later than
08.06.2020, remotely, using unspecified information and telecommunication means of communication,
misled Nosenko M.N. about their true intentions - the thef of his funds, under the pretext of executing an
246
order to conclude OTC option contracts on the over - the - counter market, with no initial intention of
fulfilling the undertaken obligations.
08.06.2020, at an unspecified time and place, arranged for Nosenko M.N. to sign an application for consent to
conclude a brokerage services agreement with IC QBF LLC (application for joining for individuals), on the
basis of which on 08.06.06.2020 between Nosenko M.N. and "IC "QB&EF" LLC, named as a broker, concluded
a brokerage services agreement No. FB - 547 dated 08.06.2020, and under the pretext of fulfilling the terms of
the said agreement persuaded the latter to transfer his funds to them allegedly for trust management.
- Nosenko M.N., unaware of the crime being prepared and misled as to the true objectives of the members of
the organised group - the thef of his funds, convinced that his funds would be returned afer the option
agreement was executed, in the period from 17.06.2020 to 08.07.2020 made transfers of funds from his
account No. 40817810306180024189, opened in the branch of JSC Alfa - Bank, located at the address:
Moscow, Bagrationovsky proezd, d. 3 to the account of QBIF LLC No. 40817810306180024189, opened with
NSD JSC (National Settlement Depository), located at the address: Moscow, Bagrationovsky proezd, d. 3. 3, to
IC QBF LLC account No. 40701810700003010998 opened with NSD JSC ("National Settlement Depository")
located at 12 Spartakovskaya Street, Moscow, under Brokerage Services Agreement No. FB - 547 dated
08.06.2020, namely: 17.06.2020 in the amount of RUB 2,800,000; 08.07.2020 in the amount of RUB 3,400,000,
totalling RUB 6,200,000.
- Having received these funds from Nosenko M.N. in the total amount of 6,200,000 roubles, Shpakov R.V.,
of the Russian Federation, in order to conceal their criminal activities and make their actions look legitimate,
as well as to create a belief in Nosenko M.N. that his money would be invested profitably, R.V. Shpakov,
Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda, Golubev A.S., Rossieva E.A. and unidentified persons,
abusing Nosenko M.N.'s trust, as well as persons unaware of the criminal intent, persuaded him to sign
instructions to a broker for the purpose of entering into OTC derivative transactions, namely options, in
accordance with which Nosenko M.N.'s funds in various amounts were transferred to QBIF LLC as a security
breach of trust, stole money belonging to Nosenko M.N. in the amount of 6,200,000 roubles, in an especially
large amount.
namely:
247
organisations of the group, by means of deceit and abuse of trust, which consisted in creating a false
the group, persuaded clients to conclude various investment contracts with LLC IC QBF, including a contract
for the provision of brokerage services, as well as to transfer under these contracts to the trust management
of them, the co - conspirators, their funds, which were then transferred to them, the co - conspirators.
group, as part of a criminal association, jointly and in concert, at an exactly unspecified period of time, but no
later than 10.07.2020, during a one - off visit by Mitroshin N.G. to a presentation of the activities of QBF Group
companies in the provision of brokerage services, held at the address: Moscow, Presnenskaya Naberezhnaya,
248
8, p. 1, as well as remotely. 1, as well as remotely, using unidentified information and telecommunication
means of communication, misled Mitroshin N.G. about their true intentions - the thef of his funds, under the
pretext of executing an order to conclude over - the - counter option contracts on the OTC market, without
initially intending to fulfil their obligations to pay and return funds to the client.
10.07.2020, at an unspecified time and place, arranged for Mitroshin N.G. to sign an application for consent to
conclude a brokerage services agreement with IC QBF LLC (application for adhesion for individuals), on the
basis of which on 10.07.07.2020 between Mitroshin N.G. and LLC "IC "QBF", named as a broker, concluded the
contract of brokerage services No. FB - 728 of 10.07.2020, and under the pretext of fulfilling the terms of the
contract convinced the latter to transfer his funds to them allegedly for trust management.
- Mitroshin N.G., unaware of the crime that was being prepared and misled as to the true objectives of the
the terms of the option agreement were fulfilled, on 06.08.2020 made a transfer of funds from his account No.
40817810716254002101 opened with PJSC "VTB Bank", located at: Moscow, 5, Marksistskaya str. 1, to QBIF
LLC account No. 40701810201400000052 opened with JSC Alfa - Bank located at 27 Kalanchevskaya Street,
Moscow, under brokerage services agreement No. FB - 728 dated 10.07.2020, in the amount of RUB 4,000,000.
- Having received these funds from Mitroshina N.G. in the total amount of 4,000,000 roubles, Shpakov R.V.,
legitimate, as well as to create a belief in Mitroshin N.G. that his money would be invested profitably, Shpakov
R.V., Pakhomov V.S., Athanasiadou Linda, Golubev A.S., Rossieva E.A. and unidentified persons abused their
trust in the investment of his money, Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda, Golubev A.S.,
Rossieva E.A. and unidentified persons, abusing the confidence of Mitroshin N.G., as well as persons unaware
of the criminal intent, persuaded him to sign instructions to a broker for the purpose of entering into OTC
derivative transactions, namely options, in accordance with which the funds of N.G. Mitroshin in various
amounts were transferred by QBIF IC LLC as a security payment to the accounts of the options seller, Q-
BROKER LLC, an affiliate of QBIF LLC.
stole money belonging to Mitroshin N.G. in the amount of 4,000,000 roubles, in an especially large amount.
namely:
249
of a criminal association, jointly and in concert, at an unspecified period of time, but no later than
03.08.2020, remotely, using unidentified information and telecommunication means of communication,
misled Batuev A.A. about their true intentions - the thef of his funds, under the pretext of executing an order
250
to conclude OTC option contracts on the OTC market, without initially intending to execute the undertaken
obligations.
A.S., Rossieva E.A. and unidentified persons, acting as an organised group, jointly and in concert, on
03.08.2020, at an unspecified time and place, arranged for Batuev A.A. to sign an application for consent to
basis of which on 03.08.08.2020 between Batuev A.A. and "IC "QBF" LLC, named as a broker, concluded a
brokerage services agreement No. BO - F - N - 0 - 00102 dated 03.08.2020, and under the pretext of fulfilling
the terms of the said agreement persuaded the latter to transfer his funds to them allegedly for trust
management.
- A.A. Batuev, unaware of the crime being prepared and misled as to the true objectives of the members of the
organised group - the thef of his funds, convinced that his funds would be returned afer the option
account No. 40817810200000367214 opened with JSC Tinkoff Bank, located at: 38, 2nd Khutorskaya str. "A",
building 26, to IC QBF LLC account No. 40701810700003010998 opened with NSD ("National Settlement
Depository") located at 12 Spartakovskaya Street, Moscow, under Brokerage Services Agreement No. BO - F -
F - N - 0 - 00102 dated 03.08.2020, namely: RUB 100,000 on 04.08.2020; RUB 500,000 on 04.08.2020; RUB
300,000 on 12.08.2020; RUB 300,000 on 12.08.2020; RUB 400,000 on 12.08.2020.08.08.2020 in the amount of
RUB 400,000; 17.08.2020 in the amount of RUB 200,000; 18.08.2020 in the amount of RUB 330,000; 20.08.2020
in the amount of RUB 350,000; 08.09.2020 in the amount of RUB 600,000; 10.09.2020 in the amount of RUB
500,000; 10.09.2020 in the amount of RUB 520,000; 11.09.2020 in the amount of RUB 400,000; 21.09.2020 in
the amount of RUB 400,000; 29.09.2020 in the amount of RUB 150,000; 21.10.2020 in the amount of RUB
500,000, totaling RUB 5,250,000.
- Having received these funds from Batueva A.A. in the total amount of 5,250,000 roubles, Shpakov R.V.,
legitimate, as well as to create a belief in Batuev A.A. that his money would be invested profitably, Shpakov
R.V., Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda, Golubev A.S., Rossieva E.A. and unidentified
persons abused the trust in his money, Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda, Golubev A.S.,
Rossieva E.A. and unidentified persons, abusing the confidence of Batuev A.A., as well as persons unaware of
the criminal intent, persuaded him to sign instructions to a broker for the purpose of entering into OTC
derivative transactions, namely options, in accordance with which A.A. Batuev's funds in various amounts
were transferred to QBIF LLC as a security payment to the accounts of the options seller, Q-BROKER LLC, an
affiliate of QBIF LLC.
breach of trust, stole money belonging to Batuev A.A. in the amount of 5,250,000 rubles, in an especially large
amount.
251
namely:
252
organisations of the group of companies, Athanasiadou Linda , A.S. Golubev, E.A. Rossieva and unidentified
persons, being mainly in the office premises of LLC IC QBF, located at the address: Moscow, Presnenskaya
Naberezhnaya, 8, p. 1. 1, as well as in unspecified places, acting as an organised group, as part of a criminal
association, jointly and in concert, at an unspecified period of time, but no later than 09.10.2020, remotely,
using unspecified information and telecommunication means of communication, misled N.V. Drapeza about
their true intentions - the thef of his funds, under the pretext of executing an order to conclude OTC option
contracts on the OTC market, without initially having any intention to execute the taken on
09.10.2020, at an unspecified time and place, organised the signing with Drapeza N.V. of an application for
consent to conclude a brokerage services agreement with IC QBF LLC (application for joining for individuals),
on the basis of which on 09.10.10.2020 between Drapeza N.V. and "IC "QBF" LLC, named as a broker,
concluded the agreement on brokerage services No. BO - F - N - 0 - 00565 dated 09.10.2020, and under the
pretext of fulfilling the conditions of the said agreement convinced the latter to transfer his funds to them,
- N.V. Drapeza, unaware of the crime being prepared and misled as to the true objectives of the participants of
the organised group - the thef of his funds, convinced that his funds would be returned afer fulfilling the
terms of the option agreement, in the period from 22.10.2020 to 24.10.2020 he transferred funds from his
account No. 40817810204080000716 opened with JSC Alfa - Bank, located at 27 Kalanchevskaya St., Moscow,
to QBIF LLC account No. 40701810700003010998 opened with NSD ("National Settlement Depository"),
located at 12 Spartakovskaya St., Moscow, under the option agreement, 12, under Brokerage Services
Agreement No. BO - F - N - 0 - 00565 dated 09.10.2020, namely: 22.10.2020 in the amount of RUB 300,000,
23.10.2020 in the amount of RUB 300,000, 24.10.2020 in the amount of RUB 3,400,000, totalling RUB
4,000,000.
- Having received these funds from Drapeza N.V. in the total amount of 4,000,000 roubles, Shpakov R.V.,
criminal intent, thus stealing, knowingly without intending to fulfil their obligations to fulfil the terms of the
option agreement, pay and return the funds to the client.
as well as to create a belief in Drapeza N.V. that his money would be profitably invested, R.V. Shpakov,
abusing the trust of Drapeza N.V., as well as persons unaware of the criminal intent, persuaded him to sign
instructions to a broker for the purpose of entering into OTC derivative transactions with derivative financial
instruments, namely options, in accordance with which N.V. Drapeza's funds in various amounts were
transferred by QBIF IC LLC as a security payment to the accounts of the options seller, Q-BROKER LLC, an
breach of trust, stole money belonging to Drapeza N.V. in the amount of 4,000,000 roubles, in an especially
large amount.
253
namely:
254
than 02.09.2020, remotely, using unspecified information and telecommunication means of communication,
misled Kormilitsyn S.V. about their true intentions - the thef of his funds, under the pretext of executing an
order to conclude OTC option contracts on the OTC market, without initially intending to execute the taken
instructions.
02.09.2020, at an unspecified time and place, organised the signing with Kormilitsyn S.V. of an application for
on the basis of which on 02.09.09.2020 between Kormilitsyn S.V. and "IC "QBF" LLC, named as a broker,
pretext of fulfilling the conditions of the said agreement convinced the latter to transfer his funds to them
- Kormilitsyn S.V., unaware of the crime being prepared and misled as to the true objectives of the participants
of the organised group - the thef of his funds, convinced that his funds would be returned afer the option
account No. 40817810900000359975 opened with Tinkoff Bank JSC, located at: Moscow, 38, 2nd Khutorskaya
str. "A", building 26, to IC QBF LLC account No. 40701810700003010998 opened with NSD ("National
Settlement Depository") located at 12 Spartakovskaya Street, Moscow, under Brokerage Services Agreement
No. BO - F - N - 0 - 00253 dated 02.09.2020, namely: 10.09.2020 in the amount of RUB 550,000; 10.09.2020 in
350,000; 30.09.2020 in the amount of RUB 200,000; 19.11.2020 in the amount of RUB 350,000, totalling RUB
2,250,000.
- Having received these funds from Kormilitsyn S.V. in the total amount of 2,250,000 roubles, Shpakov R.V.,
as well as to create a belief in Kormilitsyn S.V. that his money would be profitably invested, R.V. Shpakov,
abusing the confidence of Kormilitsyn S.V., as well as persons unaware of the criminal intent, persuaded him
to sign instructions to a broker for the purpose of concluding OTC derivative transactions, namely options, in
accordance with which Kormilitsyn S.V.'s funds in various amounts were transferred by QBIF IC LLC as a
security payment to the accounts of the options seller, Q-BROKER LLC, an affiliate of QBIF LLC.
255
breach of trust, stole money belonging to Kormilitsyn S.V. in the amount of 2,250,000 roubles, in an especially
large amount.
namely:
256
misled Podolna A.V. about their true intentions - the thef of her funds, under the pretext of executing an
order to conclude OTC option contracts on the OTC market, without initially intending to execute the
contracts taken by them.
Golubev and unidentified persons, acting in an organised group, together and in concert, on 18.11.2020,
Rossieva E.A. and unidentified persons, acting in an organised group, jointly and in concert, on 18.11.2020, at
an unspecified time and place, arranged for Podolna A.V. to sign an application for consent to conclude a
brokerage services agreement with IC QBF LLC (application for adhesion for individuals), on the basis of
which on 18.11.11.2020 between Podolna A.V. and "IC QBF" LLC, which was called a broker, concluded a
the terms of the said agreement persuaded the latter to transfer her funds to them allegedly for trust
management.
- A.V. Podolnaya, unaware of the crime that was being prepared and misled as to the true objectives of the
participants of the organised group - the thef of her funds, convinced that her funds would be returned afer
the option agreement was fulfilled, on 23.11.2020 transferred funds from her account No.
40817810340017621257 opened with Sberbank PJSC, located at 53, Shcherbakovskaya str. 1, to QBIF LLC
account No. 40701810700003010998 opened with NSD ("National Settlement Depository") located at 12
Spartakovskaya Street, Moscow, under Brokerage Services Agreement No. BO - F - N - 0 - 00830 dated
18.11.2020 in the amount of RUB 6,000,000.
- Having received these funds from Podolnaya A.V. in the total amount of 6,000,000 roubles, Shpakov R.V.,
as well as to create a belief in Podolna A.V. that her money would be invested profitably, R.V. Shpakov,
abusing Podolna A.V.'s trust, as well as persons unaware of the criminal intent, persuaded her to sign
accordance with which A.V. Podolna's funds in various amounts were transferred to QBIF LLC as a security
stole money belonging to Podolna A.V. in the amount of 6,000,000 roubles, in an especially large amount.
257
namely:
258
misled V.S. Koncherova about their true intentions - the thef of her funds, under the pretext of executing an
execute the undertaken by them.
27.07.2020, at an unspecified time and place, organised the signing with Koncherova V.S. of an application for
consent to conclude a brokerage services agreement with IC QBF LLC (application for adhesion for
individuals), on the basis of which on 27. 07.2020 Koncherova V.S. signed an application for consent to
conclude a brokerage services agreement with IC QBF LLC (application for adhesion for
individuals).07.07.2020 between V.S. Koncherova and "IC QBF" LLC, named as a broker, concluded the
agreement on brokerage services No. BO - F - N - 0 - 00059 dated 27.07.2020, and under the pretext of fulfilling
the conditions of the said agreement convinced the latter to transfer her funds to them, allegedly for trust
management.
- V.S. Koncherova, unaware of the crime being prepared and misled as to the true objectives of the members of
the organised group - the thef of her funds, convinced that her funds would be returned afer fulfilling the
terms of the option agreement, in the period from 30.07.2020 to 03.12.2020 made transfers of funds from her
account No. 40817810700020375867, opened with JSC "Tinkoff Bank", located at: Moscow, 2nd Khutorskaya
Street, 38A, page 26, to the account of LLC "IC QBF" No. 40701810201400000052, opened with JSC "Alfa -
Bank", located at: Moscow, Kalanchevskaya Street, 27, under the agreement on provision of brokerage
services No. BO - F - N - 0 - 00059 dated 27.07.2020, namely: 30.07.2020 in the amount of RUB 1,190,000;
31.07.2020 in the amount of RUB 980,000; 03.12.2020 in the amount of RUB 100,000; 03.12.2020 in the
amount of RUB 50,000, totalling RUB 2,320,000.
- Having received these funds from V.S. Koncherova in the total amount of 2,320,000 roubles, R.V. Shpakov, V.S.
as well as to create a conviction in V.S. Koncherova that her money was profitably invested, R.V. Shpakov, S.S.
Pakhomov, S.A. Matyukhin, Athanasiadou Linda , A.S. Golubev, E.A. Rossieva and unidentified persons
abused the trust in her money, Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda, Golubev A.S., Rossieva
E.A. and unidentified persons, abusing the confidence of Koncherova V.S., as well as persons unaware of the
criminal intent, persuaded her to sign instructions to a broker for the purpose of entering into OTC derivative
transactions, namely options, in accordance with which V.S. Koncherova's funds in various amounts were
transferred to QBIF LLC as a security payment to the accounts of the options seller, Q-BROKER LLC, an
259
breach of trust, stole money belonging to Koncherova V.S. in the amount of 2,320,000 roubles, in an
namely:
260
misled Koreshkov V.S. about their true intentions - the thef of his funds, under the pretext of executing an
order to conclude over - the - counter option contracts on the OTC market, without initially intending to fulfil
the undertaken obligations.
09.09.2020, at 11:10 a.m., at the address: Moscow, Sosenskoye settlement, Sosenskoye village, Moscow. 10
min., being at the address: Moscow, Sosenskoye settlement, Gazoprovod, ul. 4 Lesprovod. Gazoprovod, 4
Lesniye Polyany St., 7, bldg. 1, organised the signing with V.S. Koreshkov of a statement of consent to
conclude a brokerage services agreement with LLC IC QBF (application on joining for individuals), on the
basis of which on 09.09.2020 between V.S. Koreshkov and LLC IC QBF (application on joining for
individuals).S. and IK QBF LLC, which was called a broker, concluded a brokerage services agreement No. FB -
784 of 09.09.2020, and under the pretext of fulfilling the terms of this agreement convinced the latter to
transfer his funds to them allegedly for trust management.
- V.S. Koreshkov, unaware of the crime being prepared and misled as to the true objectives of the members of
account No. 42301810900002639990 opened with JSC Tinkoff Bank, located at 38, 2nd Khutorskaya str. "A, p.
26, to QBIF LLC account No. 40701810700003010998 opened with NSD ("National Settlement Depository")
located at: Moscow, Spartakovskaya str. 12, under Brokerage Services Agreement No. FB - 784 dated
09.09.2020, namely: 11.09.2020 in the amount of RUB 750,000; 25.09.2020 in the amount of RUB 500,000;
19.10.2020 in the amount of RUB 200,000; 03.12.2020 in the amount of RUB 600,000, totalling RUB 2,050,000.
- Having received these funds from Koreshkova V.S. in the total amount of 2,050,000 roubles, Shpakov R.V.,
as well as to create a belief in Koreshkov V.S. that his money was being invested in a profitable way, Shpakov
persons abused their trust in the investment of his money, Pakhomov V.S., Matyukhin S.A., Athanasiadou
Linda, Golubev A.S., Rossieva E.A. and unidentified persons, abusing the confidence of Koreshkov V.S., as well
as persons unaware of the criminal intent, persuaded him to sign instructions to a broker for the purpose of
entering into OTC derivative transactions, namely options, in accordance with which V.S. Koreshkov's funds
261
in various amounts were transferred to QBIF LLC as a security payment to the accounts of the options seller,
Q-BROKER LLC, an affiliate of QBIF LLC.
breach of trust, stole funds belonging to Koreshkov V.S. in the amount of 2,050,000 roubles, in an especially
large amount.
namely:
262
misled Borisov M.A. about their true intentions - the thef of his funds, under the pretext of executing an order
to conclude over - the - counter option contracts on the OTC market, without initially intending to execute
the contracts taken by him.
03.09.2020, at an unspecified time and place, arranged for Borisov M.A. to sign an application for consent to
basis of which on 03.09.09.2020 between Borisov M.A. and "IC QBF" LLC, named as a broker, concluded a
the terms of the said agreement persuaded the latter to transfer his funds to them allegedly for trust
management.
- M.A. Borisov, unaware of the crime being prepared and misled as to the true objectives of the members of the
account No. 40817810637004017483 opened with PJSC VTB Bank, located at 5, Marxistskaya St., Moscow, to
IC QBF LLC account No. 40701810700003010998 opened with NSD JSC ("National Settlement Depository")
located at 12 Spartakovskaya Street, Moscow, under Brokerage Services Agreement No. BO - F - N - 0 - 00263
dated 03.09.2020, namely: 24.09.2020 in the amount of RUB 800,000; 27.09.2020 in the amount of RUB
2,505,000.
- Having received these funds from Borisova M.A. in the total amount of 2,505,000 roubles, Shpakov R.V.,
as well as to create a belief in Borisov M.A. that his money was being invested profitably, Shpakov R.V.,
Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda, Golubev A.S., Rossieva E.A. and unidentified persons
abused their trust in the investment of his money, Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda,
Golubev A.S., Rossieva E.A. and unidentified persons, abusing Borisov M.A.'s trust, as well as persons
263
unaware of the criminal intent, persuaded him to sign instructions to a broker for the purpose of entering
into OTC derivative transactions, namely options, in accordance with which Borisov M.A.'s funds in various
amounts were transferred by QBIF LLC as a security payment to the accounts of the options seller, Q-BROKER
LLC, an affiliate of QBIF LLC.
under the circumstances described above, deliberately, through deceit and breach of trust, in the period
from 24.09.2020 to 08.12.2020, stole money belonging to Borisov M.A. in the amount of 2,505,000 rubles, in
namely:
264
group, as part of a criminal association, jointly and in concert, at an unspecified period of time, but no later
misled Tokareva A.A. about their true intentions - the thef of her funds, under the pretext of executing an
order to conclude over - the - counter option contracts on the OTC market, without initially having any
intention to execute the taken on
03.12.2020, at an unspecified time and place, arranged for Tokareva A.A. to sign an application for consent to
basis of which on 03.12.12.2020 between Tokareva A.A. and "IC QBF" LLC, named as a broker, concluded the
the conditions of the said agreement convinced the latter to transfer her funds to them allegedly for trust
management.
- A.A. Tokareva, A.A. Tokareva, unaware of the crime being prepared and misled as to the true objectives of the
members of the organised group - the thef of her funds, convinced that her funds would be returned afer
fulfilling the terms of the option agreement, on 08.12.2020 she transferred funds from her account No.
40817810106120090425 opened with JSC "Alfa Bank", located at the address: Moscow, Kalanchevskaya str.
27, to QBIF LLC account No. 40701810700003010998 opened with NSD ("National Settlement Depository")
dated 03.12.2020 in the amount of RUB 6,000,000.
- Having received these funds from Tokareva A.A. in the total amount of 6,000,000 roubles, Shpakov R.V.,
as well as to create a belief in Tokareva A.A. that her money would be invested profitably, R.V. Shpakov, S.S.
Pakhomov, S.S. Matyukhin, Athanasiadou Linda , A.S. Golubev, E.A. Rossieva and unidentified persons
abused their trust in the investment of her money, Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda,
Golubev A.S., Rossieva E.A. and unidentified persons, abusing Tokareva A.A.'s trust, as well as persons
265
unaware of the criminal intent, persuaded her to sign instructions to a broker for the purpose of entering into
OTC derivative transactions, namely options, in accordance with which A.A. Tokareva's funds in various
amounts were transferred to QBIF LLC as a security payment to the accounts of the options seller, Q-BROKER
stole money belonging to Tokareva A.A. in the amount of 6,000,000 roubles, in an especially large amount.
namely:
266
organised the signing with Malinin D.I., on behalf of a non - resident affiliated with the criminal association -
services to international stock markets No. 4710 - 18/ISR, dated 19.12.2018. At the same time, the
accomplices deceived Malinin D.I. by concealing from him the information that this organisation did not have
legal grounds to engage in the type of activity related to the execution of transactions with securities, as it did
not have the relevant mandatory licence issued by the authorised body of the Republic of Cyprus.
dated 19.12.2018 with Malinin D.I. on behalf of QBF Advisery LLC (INN 7703426941), affiliated with the
- Malinin D.I., unaware of the crime being prepared and misled as to the true objectives of the participants of
profit, which did not correspond to reality, being in the office of LLC "Investment Company QBF" located at
the address: St. Petersburg, Degtyarny per, 11, lit. "B", on 21.12.2018, at an unspecified time, he transferred
cash in the amount of 2,060,000 rubles to the employees of QBF Group Company (QBF).
unaware of the criminal intent, organised the acceptance of the above - mentioned funds from D.I. Malinin,
stolen money.
- Continuing their criminal actions, in order to achieve a criminal result aimed at stealing the funds of Malinin
D.I., on 31.01.2019, at an unspecified time, being in the office of LLC "Investment Company QBF" (INN
7733673955), located at the address: St. Petersburg, Degtyarny per, 11, lit. "B", under the pretext of investing
money in securities with high yield, R.V. Shpakov, V.S. Pakhomov, Athanasiadou Linda , A.S. Golubev, S.A.
Matyukhin, and E.A. Rossieva, under the pretext of investing in securities with high yields, Rossieva E.A. and
unidentified persons, acting as an organised group, jointly and in concert, organised the signing of service
agreement No. 4710 dated 31.01.2019 with Malinin D.I. on behalf of a non - resident company "WLM LTD"
("WLM LTD", registered in the Cayman Islands), affiliated with the criminal association, and, under the pretext
of fulfilling the terms of the said agreement, persuaded the latter to transfer his funds to them, ostensibly for
trust management. At the same time, the accomplices deceived D.I. Malinin by concealing from him the
267
transactions with securities, as it did not have the relevant mandatory licence issued by the competent
- Malinin D.I., unaware of the crime being prepared and misled as to the true objectives of the participants of
address: St. Petersburg, Degtyarny per, 11, lit. "B", realised the transfer of cash to the employees of QBF
20.03.2020, at an unspecified time, in the amount of RUB 1,800,000; 09.12.2020, at an unspecified time, in the
amount of RUB 1,800,000.
unaware of the criminal intent, organised the acceptance of the above - mentioned funds from D.I. Malinin,
stolen money.
breach of trust, stole money belonging to Malinin D.I. in the amount of 6,660,000 rubles, in an especially large
amount.
namely:
268
misled A.V. Kulikova about their true intentions - the thef of her funds, under the pretext of executing an
execute the assumed obligations.
an unspecified time and place, arranged for Kulikova A.V. to sign an application for consent to conclude a
brokerage services agreement with IC QBF LLC (application for joining for individuals), on the basis of which
on 12.11.11.2020 between Kulikova A.V. and "IC QBF" LLC, named as a broker, concluded a brokerage services
agreement No. BO - F - N - 0 - 00767 dated 11.11.2020, and under the pretext of fulfilling the terms of the said
agreement convinced the latter to transfer her funds to them allegedly for trust management.
- A.V. Kulikova, unaware of the crime that was being prepared and misled as to the true objectives of the
members of the organised group - the thef of her money, convinced that her money would be returned afer
fulfilling the terms of the option agreement, on 09.12.2020, she transferred funds from her account No.
40817810222254017855, opened in the additional office of PJSC VTB Bank located at 26 Varshavskoye
Shosse, Moscow, to the account No. 40701810201400000052 of LLC IC QBF, opened in JSC Alfa - Bank located
at 27 Kalanchevskaya Street, Moscow, under the brokerage services agreement No. BO - F - N - 0 - 00767
dated 11.11.2020, in the amount of RUB 2,000,000.
- Having received these funds from Kulikova A.V. in the total amount of 2,000,000 roubles, Shpakov R.V.,
269
as well as to create a belief in Kulikova A.V. that her money would be invested profitably, R.V. Shpakov,
abusing the confidence of Kulikova A.V., as well as persons unaware of the criminal intent, persuaded her to
sign instructions to a broker for the purpose of entering into OTC derivative transactions with derivative
financial instruments, namely options, in accordance with which A.V. Kulikova's funds in various amounts
were transferred to LLC IC QBF as a security payment to the accounts of the options seller, LLC Q.Broker,
affiliated with LLC IC QBF.
stole money belonging to Kulikova A.V. in the amount of 2,000,000 rubles, in an especially large amount.
namely:
270
misled Kuzmenko K.N. about their true intentions - the thef of his funds, under the pretext of executing an
23.11.2020, at an unspecified time and place, arranged for Kuzmenko K.N. to sign an application for consent
to conclude a brokerage services agreement with IC QBF LLC (application for joining for individuals), on the
basis of which on 23.11.11.2020 between Kuzmenko K.N. and "IC "QBF" LLC, named as a broker, concluded a
the terms of the said agreement convinced the latter to transfer his funds to them allegedly for trust
management.
- Kuzmenko K.N., unaware of the crime being prepared and misled as to the true objectives of the participants
agreement terms were fulfilled, on 11.12.2020 transferred funds from his account No.
40817810004010397220 opened with JSC Alfa Bank, located at the address: Moscow, Michurinsky Ave, 7, to
QBIF LLC's account No. 40701810700003010998 opened with NSD ("National Settlement Depository") located
at 12 Spartakovskaya Street, Moscow under Brokerage Services Agreement No. BO - F - N - 0 - 00861 dated
- Having received these funds from Kuzmenko K.N. in the total amount of 1,200,000 roubles, Shpakov R.V.,
271
as well as to create a belief in Kuzmenko K.N. that his money would be invested profitably, R.V. Shpakov,
abusing Kuzmenko K.N.'s trust, as well as persons unaware of the criminal intent, persuaded him to sign
accordance with which Kuzmenko K.N.'s funds in various amounts were transferred to QBIF LLC as a security
stole money belonging to Kuzmenko K.N. in the amount of 1,200,000 roubles, on a particularly large scale.
namely:
272
misled A.V. Shilov about their true intentions - to steal his money, under the pretext of executing an order to
conclude OTC option contracts on the over - the - counter market, without initially having any intention to
execute the agreements taken on the OTC market.
24.12.2020, at an unspecified time and place, arranged for Shilov A.V. to sign an application for consent to
basis of which on 24.12.12.2020 between Shilov A.V. and "IC QBF" LLC, named as a broker, concluded a
the conditions of the said agreement convinced the latter to transfer his funds to them allegedly for trust
management.
- A.V. Shilov, unaware of the crime being prepared and misled as to the true objectives of the members of the
account No. 40817810638296268651 opened with Sberbank PJSC, located at 9, bldg. 1, Sokolnicheskaya
Square, Moscow, to the account No. 40701810700003010998 opened with NSD JSC ("National Settlement
N - 0 - 01271 dated 24.12.2020, namely: 25.12.2020 in the amount of RUB 1,000,000; 26.12.2020 in the amount
of RUB 1,000,000, totalling RUB 2,000,000.
- Having received these funds from A.V. Shilova in the total amount of 2,000,000 roubles, R.V. Shpakov, V.S.
273
as well as to create a belief in Shilov A.V. that his money was being invested in a profitable way, Shpakov R.V.,
abusing Shilov A.V.'s trust, as well as persons unaware of the criminal intent, persuaded him to sign
accordance with which A.V. Shilov's funds in various amounts were transferred to QBIF LLC as a security
under the above circumstances, in the period from 25.12.2020 to 26.12.2020, deliberately, by means of deceit
and breach of trust, stole money belonging to Shilov A.V. in the amount of 2,000,000 roubles, in an especially
large amount.
namely:
274
appearance of the possibility of receiving a high income among natural persons - clients of the companies of
this group, persuaded clients to conclude various investment agreements with LLC IC QBF, including an
agreement on rendering brokerage services, as well as to transfer their funds under these agreements to the
trust management of them, the co - conspirators, which were then transferred to them, the co - conspirators.
misled Voropaev A.A. about their true intentions - the thef of his funds, under the pretext of executing an
Golubev, E.A. Rossieva and unidentified persons, acting as an organised group, jointly and in concert, on
25.06.2020, at an unspecified time, being at the following address: 46 Krasnaya Presnya St., bldg. 1, Moscow,
organised the signing with A.A. Voropaev of an application for consent to conclude a brokerage services
agreement with QBIF IK LLC (an application for joining for individuals). 1, organised the signing with A.A.
Voropaev of an application for consent to conclude a brokerage services agreement with OOO IC QBF
(application for joining for individuals), on the basis of which on 25.06.2020 between A.A. Voropaev and OOO
IC QBF. A.A. Voropaev and "IC QBF" LLC, which was called a broker, concluded a brokerage services
agreement No. FB - 655 of 25.06.2020, and under the pretext of fulfilling the terms of the said agreement
convinced the latter to transfer his funds to them allegedly for trust management.
- A.A. Voropaev, unaware of the crime being prepared and misled as to the true objectives of the participants
of the organised group - the thef of his funds, convinced that his funds would be returned afer fulfilling the
terms of the option agreement, in the period from 29.06.2020 to 28.12.2020 made transfers of funds from his
account No. 40817810300003521300, opened in JSC "Tinkoff Bank", located at the address: Moscow, 2nd
Khutorskaya St., 38A, p. 26, to the account of LLC "IK IK". 26, to IC QBF LLC account No.
40701810700003010998 opened with NSD JSC ("National Settlement Depository") located at 12
Spartakovskaya St., Moscow, under brokerage services agreement No. FB - 655 dated 25.06.2020, namely:
29.06.2020 in the amount of RUB 1,000,000; 02.07.2020 in the amount of RUB 1,000,000; 28.12.2020 in the
amount of RUB 200,000, and made transfers of funds from his account No. 40817810600006192191 opened
275
with PJSC "Moscow Credit Bank" located at: Moscow, Lukov Per. 2, pg. 1, to QBIF LLC's account No.
40701810700003010998 opened with NSD ("National Settlement Depository") located at 12 Spartakovskaya
Street, Moscow, under Brokerage Services Agreement No. FB - 655 dated 25.06.2020, namely on 15.12.2020 in
the amount of RUB 600,000; on 16.12.2020 in the amount of RUB 400,000, totalling RUB 3,200,000.
- Having received these funds from Voropaeva A.A. in the total amount of 3,200,000 roubles, Shpakov R.V.,
legitimate, as well as to create a belief in Voropaev A.A. that his money would be invested profitably, Shpakov
persons abused their trust in the investment of his money, Pakhomov V.S., Matyukhin S.A., Athanasiadou
Linda, Golubev A.S., Rossieva E.A. and unidentified persons, abusing the confidence of Voropaev A.A., as well
as persons unaware of the criminal intent, persuaded him to sign instructions to a broker in order to
conclude over - the - counter derivative transactions with derivative financial instruments, namely options, in
accordance with which A.A. Voropaev's funds in various amounts were transferred to QBIF LLC as a security
from 29.06.2020 to 28.12.2020, stole money belonging to Voropaev A.A. in the amount of 3,200,000 rubles, in
namely:
276
misled Gorbunov R.V. about their true intentions - the thef of his funds, under the pretext of executing an
24.09.2020, at an unspecified time and place, arranged for Gorbunov R.V. to sign an application for consent to
basis of which on 24.09.09.2020 between Gorbunov R.V. and "IC QBF" LLC, named as a broker, concluded the
the conditions of the said agreement persuaded the latter to transfer his funds to them allegedly for trust
management.
- Gorbunov R.V., unaware of the crime being prepared and misled as to the true objectives of the participants
277
account No. 40817810500000165006, opened with JSC "Tinkoff Bank", located at the address: 38, 2nd
Khutorskaya St., Moscow. "A" p.26, to the account No. 40701810201400000052 opened in JSC "Alfa Bank",
located at: 27 Kalanchevskaya St., Moscow, under the brokerage services agreement No. BO - F - N - 0 - 00452
dated 24.09.2020, namely: 29.09.2020 in the amount of RUB 4,000,000; 19.11.2020 in the amount of RUB
750,000, 07.12.2020 in the amount of RUB 1,250,000; 14.12.2020 in the amount of RUB 1,000,000; 28.12.2020
in the amount of RUB 1,500,000, totalling RUB 8,500,000.
- Having received these funds from Gorbunova R.V. in the total amount of 8,500,000 roubles, Shpakov R.V.,
as well as to create a belief in Gorbunov R.V. that his money was being invested profitably, Shpakov R.V.,
abusing Gorbunov R.V.'s trust, as well as persons unaware of the criminal intent, persuaded him to sign
accordance with which Gorbunov R.V.'s funds in various amounts were transferred to QBIF LLC as a security
- As a result, Pakhomov V.S., using his o/icial position, acting in an organised group, jointly and in concert
with Shpakov R.V., Matyukhin S.A., Athanasiadou Linda, Golubev A.S., Rossieva E.A. and unidentified
persons, under the above circumstances, in the period from 29.09.2020 to 28.12.2020, deliberately,
through deceit and breach of trust, stole money belonging to Gorbunov R.V. in the amount of 8,500,000
roubles, in an especially large amount.
namely:
278
misled A.K. Shlykov about their true intentions - the thef of his funds, under the pretext of executing an order
the assumed obligations.
04.12.2020, at an unspecified time and place, organised the signing with Shlykov A.K. of an application for
on the basis of which on 04.12.12.2020 between A.K. Shlykov and "IC QBF" LLC, named as a broker,
pretext of fulfilment of the conditions of the said agreement persuaded the latter to transfer his funds to
them allegedly for trust management.
- A.K. Shlykov, unaware of the crime that was being prepared and misled as to the true objectives of the
279
the option agreement conditions were fulfilled, in the period from 14.12.2020 to 13.01.2021 made transfers of
funds as follows: On 14.12.2020 from his account No. 40817810900006827689 opened with JSC Tinkoff Bank,
located at: Moscow, 2nd Khutorskaya St., 38A, page 26, to QBIF LLC account No. 40701810700003010998
opened with NSD ("National Settlement Depository"), located at. 12 Spartakovskaya Street, Moscow, under
Brokerage Services Agreement No. BO - F - N - 0 - 01000 dated 04.12.2020, in the amount of RUB 100,000; on
14.12.2020 from its account No. 40817810538294440584 opened with PJSC Sberbank of Russia, located at the
following address: Moscow, Spartakovskaya Street, Moscow. 21, Spartakovskaya St., Moscow, to the account
No. 40701810738000001955 opened in PJSC Sberbank of Russia, located at the address: Moscow, Bolshaya
Andronyevskaya St., d. 6, under the brokerage agreement. 6, under brokerage services agreement No. BO - F -
N - 0 - 01000 dated 04.12.2020, in the amount of RUB 200,000; in the period from 14.12.2020 to 13.01.2021
from its account No. 40817810940016995070 opened with PJSC Sberbank of Russia, located at: Moscow
region, Khimki, Pobedy St., 1/13, room 008, to QBIF LLC account No. 40701810738000001955 opened with
Sberbank of Russia PJSC located at 6 Bolshaya Andronievskaya St., Moscow, under brokerage services
agreement No. BO - F - N - 0 - 01000 dated 04.12.2020, namely: 14.12.2020 in the amount of RUB 500,000;
amount of RUB 600,000; 13.01.2021 in the amount of RUB 400,000, totalling RUB 2,800,000.
- Having received these funds from A.K. Shlykova in the total amount of 2,800,000 roubles, R.V. Shpakov, V.S.
their own discretion according to the criminal plan and in fulfilment of a joint criminal intent, thereby
as well as to create a belief in Shlykov A.K. that his money would be invested profitably, Shpakov R.V.,
abused trust in the investment of his money, Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda, Golubev
A.S., Rossieva E.A. and unidentified persons, abusing Shlykov A.K.'s trust, as well as persons unaware of the
criminal intent, persuaded him to sign instructions to a broker in order to conclude OTC derivative
transactions, namely options, in accordance with which A.K. Shlykov's funds in various amounts were
transferred to QBIF LLC as a security payment to the accounts of the options seller, Q-BROKER LLC, affiliated
with QBIF LLC.
from 14.12.2020 to 13.01.2021, stole money belonging to Shlykov A.K. in the amount of 2,800,000 roubles, in
namely:
280
281
misled Kuryatnikov L.A. about their true intentions - the thef of his funds, under the pretext of executing an
execute the taken instructions.
20.10.2020, at an unspecified time and place, organised the signing with Kuryatnikov L.A. of an application
for consent to conclude a brokerage services agreement with IC QBF LLC (application for joining for
individuals), on the basis of which on 20.10.10.2020 between Kuryatnikov L.A. and "IC "QBF" LLC, named as a
broker, concluded a brokerage services agreement No. BO - F - N - 0 - 00627 dated 20.10.2020, and under the
pretext of fulfilling the terms of the said agreement convinced the latter to transfer his funds to them,
- L.A. Kuriatnikov, unaware of the crime being prepared and misled as to the true objectives of the participants
account No. 40817810000004875229 opened with JSC Tinkoff Bank, located at: 38, 2nd Khutorskaya St.,
Moscow, Russia. "A", page 26, to QBIF LLC's account No. 40701810700003010998 opened with NSD ("National
No. BO - F - N - 0 - 00627 dated 20.10.2020, namely: 21.10.2020 in the amount of RUB 6,010,000; 02.11.2020 in
the amount of RUB 1,300,000; 02.11.2020 in the amount of RUB 2,000,000; 09.12.2020 in the amount of RUB
1,500,000; 11.12.2020 in the amount of RUB 2,800,000; 14.12.2020 in the amount of RUB 3,000,000;
14.12.2020 in the amount of RUB 2,000,000; 25.01.2021 in the amount of RUB 3,000,000; 25.01.2021 in the
amount of RUB 2,000,000; 25.01.2021 in the amount of RUB 2,200,000, in total in the amount of RUB
25,810,000.
- Having received these funds from Kuryatnikova L.A. in the total amount of 25,810,000 roubles, Shpakov R.V.,
as well as to create a belief in Kuryatnikov L.A. that his money would be invested profitably, Shpakov R.V.,
abused their trust in the investment of his funds, Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda,
Golubev A.S., Rossieva E.A. and unidentified persons, abusing the confidence of Kuriatnikov L.A., as well as
persons unaware of the criminal intent, persuaded him to sign instructions to a broker in order to conclude
over - the - counter derivative transactions with derivative financial instruments, namely options, in
accordance with which L.A. Kuryatnikov's funds in various amounts were transferred to LLC IC QBF as a
security payment to the accounts of the options seller, LLC Q.Broker, affiliated with LLC IC QBF.
breach of trust, stole money belonging to Kuryatnikov L.A. in the amount of 25,810,000 roubles, in an
282
namely:
283
misled Demidkova T.V. about their true intentions - the thef of her funds, under the pretext of executing an
contracts taken by her.
05.10.2020, at an unspecified time and place, arranged for Demidkova T.V. to sign an application for consent
basis of which on 05.10.10.2020 between Demidkova T.V. and "IC QBF" LLC, named as a broker, concluded a
the terms of the said agreement persuaded the latter to transfer her funds to them allegedly for trust
management.
- T.V. Demidkova, unaware of the crime being prepared and misled as to the true objectives of the members of
terms of the option agreement, in the period from 21.10.2020 to 26.01.2021 she made transfers of funds from
her account No. 40817810300000609513, opened in JSC "Tinkoff Bank", located at the address: Moscow, 2nd
05.10.2020, namely: 21.10.2020 in the amount of RUB 1,400,000; 09.12.2020 in the amount of RUB 4,400,000;
26.01.2021 in the amount of RUB 350,000, totalling RUB 6,150,000.
- Having received these funds from Demidkova T.V. in the total amount of 6,150,000 roubles, Shpakov R.V.,
as well as to create a belief in Demidkova T.V. that her money was being invested in a profitable way, Shpakov
persons abused the trust in her money, Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda, Golubev A.S.,
Rossieva E.A. and unidentified persons, abusing the confidence of Demidkova T.V., as well as persons
OTC derivative transactions, namely options, in accordance with which T.V. Demidkova's funds in various
amounts were transferred to LLC IC QBF as a security payment to the accounts of the options seller, LLC
Q.Broker, affiliated with LLC IC QBF.
breach of trust, stole money belonging to Demidkova T.V. in the amount of 6,150,000 roubles, in an especially
large amount.
284
provision of brokerage services, as well as to transfer their funds under these contracts to the trust
285
(financial transactions) aimed at withdrawal of funds from the OTC option contracts.
misled Grushanina I.S. about their true intentions - the thef of her funds, under the pretext of executing an
undertaken orders.
16.12.2020, at an unspecified time and place, arranged for Grushanina I.S. to sign an application for consent
basis of which on 16.12.12.2020 between Grushanina I.S. and "IC "QBF" LLC, named as a broker, concluded a
the terms of the said agreement convinced the latter to transfer her funds to them allegedly for trust
management.
- Grushanina I.S., unaware of the crime being prepared and misled as to the true objectives of the members of
terms of the option agreement, in the period from 20.01.2021 to 28.01.2021 she made transfers of funds from
her account No. 40817810600000053681 opened with JSC "Tinkoff Bank", located at the address: Moscow,
2nd Khutorskaya St., 38 A, p. 26, to the account of LLC "IK IK". 26, to IC QBF LLC account No.
28.01.2021 in the amount of RUB 3,000, totalling RUB 423,000.
- Having received these funds from Grushanina I.S. in the total amount of 423,000 roubles, Shpakov R.V.,
as well as to create a belief in Grushanina I.S. that her money would be invested profitably, Shpakov R.V.,
E.A. and unidentified persons, abusing the confidence of Grushanina I.S., as well as persons unaware of the
criminal intent, persuaded her to sign instructions to a broker in order to conclude over - the - counter
derivative transactions with derivative financial instruments, namely options, in accordance with which I.S.
Grushanina's funds in various amounts were transferred to QBIF LLC as a security payment to the accounts of
the options seller, Q-BROKER LLC, an affiliate of QBIF LLC.
with Shpakov R.V., Matyukhin S.A., Athanasiadou Linda, Golubev A.S., Rossieva E.A. and unidentified persons,
286
breach of trust, stole money belonging to Grushanina I.S. in the amount of 423,000 roubles, in a large
amount.
namely:
287
Naberezhnaya, 8, p. 1, as well as unidentified places, acting in an organised group as part of a criminal
association, together and in concert, during an unspecified period of time, but not later than 24.01.2021,
remotely, remotely, and also at unspecified places, acting in an organised group and as part of a criminal
association. 1, as well as in unspecified places, acting as an organised group, as part of a criminal
association, jointly and in concert, at an unspecified period of time, but not later than 24.01.2021, remotely,
using unspecified information and telecommunication means of communication, misled Drapeza M.I. as to
their true intentions - the thef of her funds, under the pretext of executing an order to conclude OTC option
contracts on the over - the - counter market, having no initial intention to execute the undertaken with the
Golubev and unidentified persons, acting in an organised group, jointly and in concert, on 24.01.2021,
organised the signing of the agreement with Drape, at an unspecified time and place, Rossieva E.A. and
unidentified persons, acting in an organised group, jointly and in concert, on 24.01.2021, at an unspecified
time and place, arranged for Drapeza M.I. to sign an application for consent to conclude a brokerage services
agreement with IC QBF LLC (application for joining for individuals), on the basis of which on 24.01.01.2021
between Drapeza M.I. and "IC "QBF" LLC, named as a broker, concluded the agreement on brokerage services
No. BO - F - N - 0 - 01527 dated 24.01.2021, and under the pretext of fulfilling the conditions of the said
agreement convinced the latter to transfer her funds to them allegedly for trust management.
- M.I. Drapeza, M.I. Drapeza, unaware of the crime being prepared and misled as to the true objectives of the
members of the organised group - the thef of her funds, convinced that her funds would be returned afer
the option agreement was executed, in the period from 28.01.2021 to 01.02.2021 she made transfers of funds
from her account No. 40817810908600119969 opened with JSC Alfa - Bank located at 27 Kalanchevskaya St.,
Moscow to QBIF LLC account No. 40701810700003010998 opened with NSD ("National Settlement
Depository") located at 12 Spartakovskaya St., Moscow, under the option agreement, 12, under Brokerage
Services Agreement No. BO - F - N - 0 - 01527 dated 24.01.2021, namely: 28.01.2021 in the amount of RUB
500,000, 29.01.2021 in the amount of RUB 500,000, 30.01.2021 in the amount of RUB 450,000, 01.02.2021 in
the amount of RUB 2,550,000, totalling RUB 4,000,000.
- Having received these funds from Drapeza M.I. in the total amount of 4,000,000 roubles, Shpakov R.V.,
as well as to create a belief in Drapeza M.I. that her money was being invested in a profitable way, R.V.
Shpakov, S.S. Pakhomov, S.S. Matyukhin, Athanasiadou Linda , A.S. Golubev, E.A. Rossieva and unidentified
persons abused the trust in her money, Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda, Golubev A.S.,
Rossieva E.A. and unidentified persons, abusing Drapeza M.I.'s trust, as well as persons unaware of the
transactions, namely options, in accordance with which Drapeza M.I.'s funds in various amounts were
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breach of trust, stole money belonging to Drapeza M.I. in the amount of 4,000,000 roubles, in an especially
large amount.
namely:
Degtyarny Per. and 64 Maloohtinsky Ave.; Kaliningrad, 35 Teatralnaya St.. At the same time, the main place
where the participants of the criminal association carried out most of the actions aimed at stealing money by
for the provision of brokerage services, as well as to transfer their funds under these contracts to the trust
289
Moscow, Presnenskaya Naberezhnaya, 8, p. 1, as well as in unidentified places, acting in an organised group
as part of a criminal association, together and in a coordinated manner, during a one - off visit to the office
premises of LLC IC QBF, located at the following address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1, as
well as in unspecified places, acting as an organised group, as part of a criminal association, jointly and in
concert, at an unspecified period of time, but not later than 18.01.2021, when Pilenitsyn K.A. attended a one -
time presentation by QBF Group companies on the provision of brokerage services, held at the address:
Moscow, Presnenskaya Naberezhnaya, 8, p. 1, as well as remotely. 1, as well as remotely, using unidentified
information and telecommunication means of communication, misled Pilenitsyn K.A. about their true
intentions - the thef of his funds, under the pretext of executing an order to conclude over - the - counter
option contracts on the OTC market, without initially intending to fulfil their obligations to pay and return
funds to the client.
organised the signing of the agreement with Pihl, at an unspecified time and place, Rossieva E.A. and
time and place, organised the signing with Pilenitsyn K.A. of an application for consent to conclude a
on 18.01.01.2021 between Pilenitsyn K.A. and "IC "QBF" LLC, named as a broker, concluded the contract of
brokerage services No. BO - F - N - 0 - 01457 dated 18.01.2021, and under the pretext of fulfilment of the
conditions of the said contract persuaded the latter to transfer his funds to them allegedly for trust
management.
- K.A. Pilenitsyn, unaware of the crime being prepared and misled as to the true objectives of the participants
agreement was executed, on 01.02.2021 transferred funds from his account No. 40817810900100230079
opened with JSC "BKS Bank", located at 21 Krasnaya Presnya St., Moscow, to the account of QBIF LLC No.
40817810900100230079 opened with NSD JSC ("National Settlement Depository"), located at 21, Krasnaya
Presnya St., Moscow, to QBIF LLC account No. 40701810700003010998 opened with NSD ("National
No. BO - F - N - 0 - 01457 dated 18 January 2021 in the amount of RUB 1,500,000.
- Having received these funds from Pilenitsyn K.A. in the total amount of 1,500,000 roubles, Shpakov R.V.,
as well as to create a belief in Pilenitsyn K.A. that his money would be invested profitably, Shpakov R.V.,
290
Golubev A.S., Rossieva E.A. and unidentified persons, abusing the trust of Pilenitsyn K.A., as well as persons
unaware of the criminal intent, persuaded him to sign instructions to a broker in order to conclude OTC
derivative transactions, namely options, in accordance with which K.A. Pilenitsyn's funds in various amounts
were transferred by QBIF IC LLC as a security payment to the accounts of the options seller, Q-BROKER LLC,
an affiliate of QBIF LLC.
stole money belonging to Pilenitsyn K.A. in the amount of 1,500,000 roubles, on a particularly large scale.
namely:
291
misled Kamzolov E.A. about their true intentions - the thef of his funds, under the pretext of executing an
08.10.2020, at an unspecified time and place, organised the signing with Kamzolov E.A. of an application for
individuals), on the basis of which on 08.10.10.2020 between Kamzolov E.A. and "IC "QBF" LLC, named as a
broker, concluded the agreement on brokerage services No. BO - F - N - 0 - 00568, dated 09.10.2020, and
under the pretext of fulfilment of the conditions of the said agreement persuaded the latter to transfer his
funds to them allegedly for trust management.
- E.A. Kamzolov, unaware of the crime being prepared and misled as to the true objectives of the participants
account No. 40817810823004013673 opened with PJSC VTB Bank, located at: Moscow, Leningradsky
Prospekt, d. 60 to the account of QBIF LLC No. 40817810823004013673 opened with NSD ("National
Settlement Depository"), located at: Moscow, Leningradsky Prospekt, d. 60. 60, to IC QBF LLC account No.
- Having received these funds from Kamzolova E.A. in the total amount of 2,000,000 roubles, Shpakov R.V.,
292
legitimate, as well as to create a belief in Kamzolov E.A. that his money would be invested profitably, Shpakov
persons abused the trust in the investment of his funds, Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda,
Golubev A.S., Rossieva E.A. and unidentified persons, abusing the confidence of Kamzolov E.A., as well as
OTC derivative transactions, namely options, in accordance with which E.A. Kamzolov's funds in various
breach of trust, stole money belonging to Kamzolov E.A. in the amount of 2,000,000 roubles, in an especially
large amount.
namely:
293
Naberezhnaya, 8, p. 1, as well as in unidentified places, acting in an organised group as part of a criminal
association, together and in concert, during an unspecified period of time, but no later than 14.01.2021. 1, as
concert, at an unspecified period of time, but not later than 14.01.2021, remotely, using unspecified
information and telecommunication means of communication, misled Elkin P.M. as to their true intentions -
the thef of his funds, under the pretext of executing an order to conclude over - the - counter option
contracts on the OTC market, without initially having any intention to execute the taken on
14.01.2021, at an unspecified time and place, organised the signing with Elkin P.M. of an application for
on the basis of which on 14.01.01.2021 between Elkin P.M. and "IC "QBF" LLC, named as a broker, concluded
a brokerage services agreement No. BO - F - N - 0 - 01421 dated 14.01.2021, and under the pretext of fulfilling
management.
- Elkin P.M., unaware of the crime being prepared and misled about the true objectives of the participants of
the organised group - the thef of his money, convinced that his money will be returned afer the execution of
the option agreement, on 28.01.2021 he transferred funds from his account No. 40817810907480026082,
opened in the office of JSC "Alfa - Bank", located at 9 Lenina St., Ryazan, to the account of LLC "IC QBF" No.
40701810700003010998, opened in NSD JSC ("National Settlement Depository"), located at the following
address: Ryazan, Spartakovskaya St., Moscow. 12 Spartakovskaya Street, Moscow, under Brokerage Services
Agreement No. BO - F - N - 0 - 01421 dated 14.01.2021 in the amount of RUB 1,500,000, and on 05.02.2021
transferred funds from its account No. 40817810800028557804 opened with JSC Tinkoff Bank located at 2
Khutorskaya St., Moscow, ul. 38A, page 26, to QBIF LLC's account No. 40701810700003010998 opened with
NSD ("National Settlement Depository") located at 12 Spartakovskaya Street, Moscow, under the Brokerage
294
Services Agreement No. BO - F - N - 0 - 01421 dated 14 January 2021 in the amount of RUB 2,500,000, totalling
RUB 4,000,000.
- Having received these funds from Elkin P.M. in the total amount of 4,000,000 roubles, Shpakov R.V.,
as well as to create a belief in Elkin P.M. that his money would be invested profitably, R.V. Shpakov, Pakhomov
V.S., Matyukhin S.A., Athanasiadou Linda, Golubev A.S., Rossieva E.A. and unidentified persons, abusing Elkin
P.M.'s trust, as well as persons unaware of the criminal intent, persuaded him to sign instructions to a broker
for the purpose of entering into OTC derivative transactions, namely options, in accordance with which Elkin
P.M.'s funds in various amounts were transferred to QBIF LLC as a security payment to the accounts of the
options seller, Q-BROKER LLC, an affiliate of QBIF LLC.
breach of trust, stole money belonging to Elkin P.M. in the amount of 4,000,000 roubles, in an especially large
amount.
namely:
295
misled Bondarenko I.V. as to their true intentions - the thef of his funds, under the pretext of executing an
25.11.2020, at an unspecified time and place, arranged for Bondarenko I.V. to sign an application for consent
to conclude a brokerage services agreement with IC QBF LLC (application for adhesion for individuals), on the
basis of which on 25.11.11.2020 between Bondarenko I.V. and "IC "QBF" LLC, named as a broker, concluded a
the terms of the said agreement convinced the latter to transfer his funds to them, allegedly for trust
management.
- Bondarenko I.V., unaware of the crime being prepared and misled as to the true objectives of the participants
account No. 40817810000023660279 opened with JSC "Tinkoff Bank", located at the address: Moscow, 2nd
296
25.11.2020, namely: 30.11.2020 in the amount of RUB 1,500,000; 25.01.2021 in the amount of RUB 600,000;
- Having received these funds from Bondarenko I.V. in the total amount of 3,400,000 roubles, Shpakov R.V.,
as well as to create a belief in Bondarenko I.V. that his money was being invested profitably, R.V. Shpakov,
abusing Bondarenko I.V.'s trust, as well as persons unaware of the criminal intent, persuaded him to sign
instruments, namely options, in accordance with which Bondarenko I.V.'s funds in various amounts were
breach of trust, stole money belonging to Bondarenko I.V. in the amount of 3,400,000 roubles, on a
particularly large scale.
namely:
297
misled A.P. Vasyunin regarding their true intentions - the thef of his funds, under the pretext of executing an
undertaken by A.P. Vasyunin.
26.11.2020, at an unspecified time and place, organised the signing with Vasyunin A.P. of an application for
on the basis of which on 26.11.11.2020 between A.P. Vasyunin and "IC "QBF" LLC, named as a broker,
concluded a brokerage services agreement No. BO - F - N - 0 - 00921 dated 26.11.2020, and under the pretext
of fulfilling the terms of the said agreement persuaded the latter to transfer his funds to them allegedly for
trust management.
- A.P. Vasyunin, unaware of the crime being prepared and misled as to the true objectives of the participants of
agreement conditions were fulfilled, in the period from 24.12.2020 to 08.02.2021 made transfers of funds
from his account No. 40817810900009895100, opened in JSC "Tinkoff Bank", located at the address: Moscow,
2nd Khutorskaya str. 38 "A", building 26, to QBIF LLC account No. 40701810700003010998 opened with NSD
JSC ("National Settlement Depository") located at 12 Spartakovskaya Street, Moscow, under Brokerage
298
1,000; 04.01.2021 in the amount of RUB 400,000; 11.01.2021 in the amount of RUB 400,000; 08.02.2021 in the
- Having received these funds from A.P. Vasyunina in the total amount of 1,201,000 roubles, R.V. Shpakov, V.S.
as well as to create a belief in Vasyunin A.P. that his money was being invested profitably, R.V. Shpakov, S.V.
Golubev A.S., Rossieva E.A. and unidentified persons, abusing the confidence of Vasyunin A.P., as well as
OTC derivative transactions, namely options, according to which A.P. Vasyunin's funds in various amounts
breach of trust, stole money belonging to Vasyunin A.P. in the amount of 1,201,000 roubles, in an especially
large amount.
namely:
299
following address: 8 Presnenskaya Naberezhnaya Embankment, bld. 1, Moscow. 1.
of the group, by means of deceit and abuse of trust, which consisted in creating a false appearance of the
misled S.A. Grekov about their true intentions - the thef of his funds, under the pretext of executing an order
to conclude OTC option contracts on the OTC market, without initially intending to fulfil the undertaken
obligations.
04.12.2020, at an unspecified time and place, arranged for Grekov S.A. to sign an application for consent to
basis of which, on 04.12.12.2020 between Grekov S.A. and "IC "QBF" LLC, named as a broker, concluded the
the terms of the said agreement convinced the latter to transfer his funds to them, allegedly for trust
management.
- Grekov S.A., unaware of the crime being prepared and misled as to the true objectives of the participants of
300
account No. 40817810100001146518, opened in JSC "Tinkoff Bank", located at the address: Moscow, 2nd
Khutorskaya St., 38A, p. 26, to the account of LLC "IKI". 26, to IC QBF LLC account No. 40701810700003010998
opened with NSD JSC ("National Settlement Depository") located at 12 Spartakovskaya St., Moscow, under
Brokerage Services Agreement No. BO - F - N - 0 - 01001 dated 04.12.2020, namely: 12.01.2021 in the amount
of RUB 750,000; 19.01.2021 in the amount of RUB 350,000; 03.02.2021 in the amount of RUB 50,000;
- Having received these funds from Grekova S.A. in the total amount of 1,300,000 roubles, Shpakov R.V.,
legitimate, as well as to create a conviction in Grekov S.A. that his money was profitably invested, Shpakov
persons, abusing Grekov S.A.'s trust, as well as persons unaware of the criminal intent, persuaded him to sign
accordance with which Grekov S.A.'s funds in various amounts were transferred to QBIF LLC as a security
and breach of trust, stole money belonging to Grekov S.A. in the amount of 1,300,000 roubles, in an especially
large amount.
301
misled Borodin V.V. as to their true intentions - the thef of his funds, under the pretext of executing an order
the undertaken by them.
13.11.2020, at an unspecified time and place, organised the signing with Borodin V.V. of an application for
on the basis of which on 13.11.11.2020 between Borodin V.V. and "IC "QBF" LLC, named as a broker,
concluded the brokerage services agreement No. BO - F - N - 0 - 00778 dated 13.11.2020, and under the
pretext of fulfilling the conditions of the said agreement convinced the latter to transfer his funds to them
- Borodin V.V., unaware of the crime that was being prepared and misled as to the true objectives of the
the terms of the option agreement were fulfilled, in the period from 17.11.2020 to 09.02.2021 made transfers
302
of funds from his account No. 40817810000001469560, opened with JSC "Tinkoff Bank", located at the
address: 38, 2nd Khutorskaya St., Moscow. "A", page 26, to the account No. 40701810201400000052 opened in
JSC "Alfa - Bank", located at: 27 Kalanchevskaya St., Moscow, under the brokerage services agreement No. BO
- F - N - 0 - 00778 dated 13.11.2020, namely: 17.11.2020 in the amount of RUB 700,000; 07.12.2020 in the
amount of RUB 50,000; 10.12.2020 in the amount of RUB 20,000; 09.02.2021 in the amount of RUB 30,000,
totalling RUB 800,000.
- Having received these funds from Borodin V.V. in the total amount of 800,000 roubles, Shpakov R.V.,
as well as to create a belief in Borodin V.V. that his money was being invested in a profitable way, R.V.
persons, abusing the confidence of Borodin V.V., as well as persons unaware of the criminal intent, persuaded
him to sign instructions to a broker for the purpose of entering into OTC derivative transactions with
derivative financial instruments, namely options, in accordance with which Borodin V.V.'s funds in various
breach of trust, stole funds belonging to Borodin V.V. in the amount of 800,000 roubles, in a large amount.
303
association, together and in concert, during an unspecified period of time, but not later than 24.01.2021,
remotely, remotely, and also at unspecified places, acting in an organised group and as part of a criminal
using unspecified information and telecommunication means of communication, misled Chernova J.B. about
their true intentions - the thef of her funds, under the pretext of executing an order to conclude OTC option
contracts on the over - the - counter market, without initially intending to fulfil the obligations undertaken by
her.
24.01.2021, at an unspecified time and place, organised the signing with Chernova J.B. of an application for
on the basis of which on 24.01.01.2021 between Chernova J.B. and "IC QBF" LLC, named as a broker,
concluded the contract of brokerage services No. BO - F - N - 0 - 01526 dated 24.01.2021, and under the
pretext of fulfilment of the conditions of the said contract convinced the latter to transfer her funds to them
304
- Chernova Z.B., unaware of the crime being prepared and misled as to the true objectives of the members of
the organised group - the thef of her funds, convinced that her funds would be returned afer the option
agreement was executed, in the period from 08.02.2021 to 09.02.2021 made transfers of funds from her
account No. 40817810338261546116 opened with Sberbank PJSC, located at 13 Sharikopodshipnikovskaya
St., p. 1, Moscow, to the account of QBIF LLC No. 40817810338261546116 opened with NSD ("National
Settlement Depository"), located at 13 Sharikopodshipnikovskaya St., Moscow. 1, to QBIF LLC account No.
24.01.2021, namely: RUB 1,000 on 08.02.2021; RUB 500,000 on 09.02.2021, totalling RUB 501,000.
- Having received these funds from Chernova J.B. in the total amount of 501,000 roubles, Shpakov R.V.,
legitimate, as well as to create a belief in Chernova J.B. that her money would be invested profitably,
Shpakov R.V., Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda, Golubev A.S., Rossieva E.A. and
unidentified persons abused the trust in her money, Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda,
Golubev A.S., Rossieva E.A. and unidentified persons, abusing Chernova J.B.'s trust, as well as persons
OTC derivative transactions with derivative financial instruments, namely options, in accordance with which
the funds of Chernova J.B. in various amounts were transferred by QBIF LLC as a security payment to the
accounts of the options seller, Q-BROKER LLC, an affiliate of QBIF LLC.
breach of trust, stole funds belonging to Chernova J.B. in the amount of 501,000 roubles, in a large amount.
namely:
305
misled Ivanov A.S. about their true intentions - the thef of his funds, under the pretext of executing an order
to conclude over - the - counter option contracts on the OTC market, without initially having any intention to
execute the taken on
16.09.2020, at an unspecified time and place, arranged for Ivanov A.S. to sign an application for consent to
basis of which on 16.09.09.2020 between Ivanov A.S. and "IC "QBF" LLC, named as a broker, concluded the
306
management.
- A.S. Ivanov, unaware of the crime being prepared and misled as to the true objectives of the members of the
agreement was fulfilled, in the period from 18.09.2020 to 10.02.2021 made transfers of funds as follows:
18.09.2020 from his account No. 40817810938067836886, opened with PJSC Sberbank, located at 9 Orekhovy
proezd, Moscow, to the account of LLC IC QBF No. 40701810738000001955, opened with PJSC Sberbank,
located at 6 Bolshaya Andronyevskaya St., Moscow, under the brokerage services agreement No. BO - F - N - 0
- 00353 dated 16.09.2020, in the amount of RUB 900,000; from 02.10.2020 to 10.02.2021 from its account No.
40817810938067836886 opened with PJSC Sberbank located at 9 Orekhovy Proezd, Moscow, to QBIF LLC
account No. 40701810700003010998 opened with NSD JSC ("National Settlement Depository") located at 12
16.09.2020, namely: RUB 400,000 on 02.10.2020; RUB 200,000 on 26.10.2020; RUB 200,000 on 07.12.2020; RUB
200,000 on 07.12.2020; RUB 200,000 on 11.12.2020; RUB 300,000 on 08.02.2021; RUB 300,000 on 08.02.2021;
RUB 300,000 on 09.02.2021; RUB 300,000 on 10.02.2021; RUB 200,000 on 10.02.2021, in the total amount of
RUB 3,000,000.
- Having received these funds from Ivanova A.S. in the total amount of 3,000,000 roubles, Shpakov R.V.,
as well as to create a belief in Ivanov A.S. that his money would be invested profitably, Shpakov R.V.,
abused the trust in his money, Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda, Golubev A.S., Rossieva
E.A. and unidentified persons, abusing Ivanov A.S.'s trust, as well as persons unaware of the criminal intent,
persuaded him to sign instructions to a broker for the purpose of entering into OTC derivative transactions
with derivative financial instruments, namely options, in accordance with which Ivanov A.S.'s funds in various
them to carry out scheme operations (financial transactions) aimed at withdrawing funds from the Russian
Federation, cashing out, purchasing real estate, financing construction and issuing loans to legal entities and
individuals affiliated with the co - conspirators.
Shpakov R.V., Matyukhin S.A., Athanasiadou Linda, Golubev A.S., E.A. Rossieva and unidentified persons,
from 18.09.2020 to 10.02.2021, stole money belonging to A.S. Ivanov in the amount of 3,000,000 roubles, on a
particularly large scale.
307
as part of a criminal association, together and in concert, during an unspecified period of time, but no later
than 25.01.2021, remotely, remotely, and also at unspecified places, acting in an organised group, at the
following address 1, as well as in unspecified places, acting as an organised group, as part of a criminal
association, jointly and in concert, during an unspecified period of time, but not later than 25.01.2021,
remotely, using unspecified information and telecommunication means of communication, misled Silin D.S.
308
about their true intentions - the thef of his funds, under the pretext of executing an order to conclude OTC
option contracts on the over - the - counter market, without initially having any intention to execute the
agreements taken on with the Bank.
Golubev and unidentified persons, acting in an organised group, jointly and in concert, on 25.01.2021, at an
unspecified time and place, organised the signing of the agreement with Silyukhin, Rossieva E.A. and
time and place, organised the signing with Silin D.S. of an application for consent to conclude a brokerage
services agreement with IC QBF LLC (application for joining for individuals), on the basis of which on
25.01.01.2021 between Silin D.S. and "IC "QBF" LLC, named as a broker, concluded a brokerage services
agreement No. BO - F - N - 0 - 01540 dated 25.01.2021, and under the pretext of fulfilling the conditions of the
said agreement persuaded the latter to transfer his funds to them allegedly for trust management.
- Silin D.S., unaware of the crime being prepared and misled as to the true objectives of the participants of the
organised group - the thef of his funds, convinced that his funds would be returned afer fulfilling the terms
of the option agreement, in the period from 09.02.2021 to 10.02.2021 made transfers of funds from his
account No. 40817810000000029273, opened with JSC "Tinkoff Bank", located at: Moscow, 38A, 2nd
Khutorskaya str. Moscow, 2nd Khutorskaya St., 38A, page 26, to QBIF LLC's account No.
St., Moscow. 12 Spartakovskaya Street, Moscow, under Brokerage Services Agreement No. BO - F - N - 0 -
01540 dated 25.01.2021, namely: RUB 500,000 on 09.02.2021; RUB 500,000 on 10.02.2021, totaling RUB
1,000,000.
- Having received these funds from Silina D.S. in the total amount of 1,000,000 roubles, Shpakov R.V.,
as well as to create a belief in Silin D.S. that his money was being invested in a profitable way, R.V. Shpakov,
V.S. Pakhomov, S.S. Matyukhin, Athanasiadou Linda , A.S. Golubev, E.A. Rossieva and unidentified persons
Golubev A.S., Rossieva E.A. and unidentified persons, abusing the trust of Silin D.S., as well as persons
into OTC derivative transactions with derivative financial instruments, namely options, in accordance with
which the funds of Silin D.S. in various amounts were transferred by QBIF LLC as a security payment to the
accounts of the options seller, Q-BROKER LLC, affiliated with QBIF LLC.
breach of trust, stole funds belonging to Silin D.S. in the amount of 1,000,000 roubles, in a large amount.
namely:
309
provision of brokerage services, as well as to transfer their money under these contracts to the trust
310
using unspecified information and telecommunication means of communication, misled K.I. Sbitnev about
their true intentions - to steal his money, under the pretext of executing an order to conclude OTC option
contracts on the over - the - counter market, without initially intending to execute the undertaken by them.
30.10.2020, at an unspecified time and place, organised the signing with Sbitnev K.I. of an application for
on the basis of which on 30.10.10.2020 between Sbitnev K.I. and "IC "QBF" LLC, named as a broker,
of fulfilling the terms of the said agreement convinced the latter to transfer his funds to them allegedly for
trust management.
- K.I. Sbitnev, unaware of the crime being prepared and misled as to the true objectives of the participants of
agreement conditions were fulfilled, in the period from 07.12.2020 to 11.02.2021 made transfers of funds
from his account No. 40817810500000192354 opened with JSC "Tinkoff Bank", located at: Moscow, 2nd
Khutorskaya Street, 38A, page 26, to the account of LLC "IC QBF" No. 40701810201400000052 opened with
JSC "Alfa Bank", located at: Moscow, Kalanchevskaya Street, 27, under the brokerage services agreement No.
BO - F - N - 0 - 00711 dated 30.10.2020, namely: 07.12.2020 in the amount of RUB 700,000, 09.12.2020 in the
amount of RUB 147,200; 10.12.2020 in the amount of RUB 22,800; 06.01.2021 in the amount of RUB
375,509.44; 28.01.2021 in the amount of RUB 206,160; 02.02.2021 in the amount of RUB 112,259.30;
08.02.2021 in the amount of RUB 146,580.70; 11.02.2021 in the amount of RUB 100,000, as well as on
19.01.2021 from his account No. 42301810200003588300 opened with JSC "Tinkoff Bank" located at the
following address: Moscow, 2 - ya. Moscow, 2nd Khutorskaya St., 38A, page 26, to the account No.
40701810201400000052 opened with OOO IC QBF opened with JSC Alfa Bank located at 27 Kalanchevskaya
St., Moscow, under brokerage services agreement No. BO - F - N - 0 - 00711 dated 30.10.2020, in the amount of
RUB 34,490.56, totalling RUB 1,845,000.
- Having received these funds from Sbitneva K.I. in the total amount of 1,845,000 roubles, Shpakov R.V.,
legitimate, as well as to create a belief in Sbitnev K.I. that his money would be invested profitably, Shpakov
persons abused their trust in the investment of his funds, Pakhomov V.S., Matyukhin S.A., Athanasiadou
Linda, Golubev A.S., Rossieva E.A. and unidentified persons, abusing Sbitnev K.I.'s trust, as well as persons
into OTC derivative transactions, namely options, in accordance with which K.I. Sbitnev's funds in various
amounts were transferred to QBIF Ltd. as a security payment to the accounts of the options seller, Q-BROKER
Ltd.
311
breach of trust, stole money belonging to Sbitnev K.I. in the amount of 1,845,000 roubles, on a particularly
large scale.
namely:
312
misled Kushkov S.V. about their true intentions - the thef of his funds, under the pretext of executing an
execute the assumed obligations.
03.07.2020, at an unspecified time, being located at the address: Tyumen, Maksim Gorky St., 74, organised
the signing with Kushkov S.V. of a statement of consent to conclude an agreement on provision of brokerage
services with IC QBF LLC (application on joining for individuals), on the basis of which, on 03. 07.2020,
Kushkov S.V. signed a statement of consent to conclude an agreement on provision of brokerage services
with IC QBF LLC (application on joining for individuals).07.07.2020 between Kushkov S.V. and LLC "IC
"QB&EF", named as a broker, concluded the contract of brokerage services № FB - 702 of 03.07.2020, and
under the pretext of fulfilment of the conditions of this contract convinced the latter to transfer his funds to
them allegedly for trust management.
- S.V. Kushkov, Kushkov S.V., unaware of the crime that was being prepared and misled as to the true objectives
of the participants of the organised group - the thef of his funds, convinced that his funds would be returned
afer the terms of the option agreement were fulfilled, in the period from 10.07.2020 to 12.02.2021 made
transfers of funds from his account No. 40817810147154000199, opened in the branch office of PO
"Znamensky" No. 6602 of the bank PJSC "VTB", located at the address: Tyumen, Chelyuskintsev Street, 1,
Bldg. 1, to the account of OOO IK "QBF" No. 40817810147154000199, opened in OOO IK "QBF". 1
Chelyuskintsev St., Bldg. 1, Tyumen, to QBIF LLC account No. 40701810700003010998 opened with NSD
("National Settlement Depository") located at 12 Spartakovskaya St., Moscow, under a brokerage agreement.
12, under Brokerage Services Agreement No. FB - 702 dated 03.07.2020, namely on 10.07.2020 in the amount
of RUB 2,000,000; on 09.12.2020 in the amount of RUB 5,000,000; on 12.02.2021 in the amount of RUB
5,000,000, totalling RUB 12,000,000.
- Having received these funds from Kushkova S.V. in the total amount of 12,000,000 roubles, Shpakov R.V.,
as well as to create a belief in Kushkov S.V. that his money would be invested profitably, R.V. Shpakov,
abusing Kushkov S.V.'s trust, as well as persons unaware of the criminal intent, persuaded him to sign
accordance with which Kushkov S.V.'s funds in various amounts were transferred to QBIF LLC as a security
313
and breach of trust, stole money belonging to Kushkov S.V. in the amount of 12,000,000 roubles, in an
namely:
the companies of this group, persuaded clients to conclude various investment contracts with LLC IC QBF,
including a contract for the provision of brokerage services, as well as to transfer under these contracts to the
trust management of them, the co - conspirators, their funds, which were then transferred to them, the co -
conspirators.
314
misled Pavlenko I.V. about their true intentions - the thef of his funds, under the pretext of executing an
order to conclude OTC option contracts on the over - the - counter market, without initially intending to
execute the undertaken by them.
06.10.2020, at an unspecified time and place, arranged for Pavlenko I.V. to sign an application for consent to
basis of which on 06.10.10.2020 between Pavlenko I.V. and "IC "QBF" LLC, named as a broker, concluded the
agreement of brokerage services No. BO - F - N - 0 - 00526 dated 06.10.2020, and under the pretext of
fulfilment of the conditions of the said agreement convinced the latter to transfer his funds to them allegedly
- Pavlenko I.V., Pavlenko I.V., unaware of the crime being prepared and misled as to the true objectives of the
fulfilling the terms of the option agreement, in the period from 03.11.2020 to 12.02.2021 he transferred funds
from his account No. 40817810800000046498 opened with Tinkoff Bank JSC, located at: Moscow, 2nd
Khutorskaya St., 38A, p. 26, to QBIF LLC account No. 40701810700003010998 opened with NSD JSC ("National
Settlement Depository"), located at: Moscow, Spartakovskaya St., ul. 12, under Brokerage Services
Agreement No. BO - F - N - 0 - 00526 dated 06.10.2020, namely: 03.11.2020 in the amount of RUB 1,000,000;
amount of RUB 330,000; 22.01.2021 in the amount of RUB 300,000; 27.01.2021 in the amount of RUB 400,000;
- Having received these funds from Pavlenko I.V. in the total amount of 2,942,870 roubles, Shpakov R.V.,
- Further, realising that the activity of QBIF LLC was subject to inspection by the regulator - the Central Bank of
the Russian Federation, in order to conceal their criminal activity and to make their actions look legitimate,
as well as to create a conviction in Pavlenko I.V. about the profitable investment of his money, R.V. Shpakov,
abusing Pavlenko I.V.'s trust, as well as persons unaware of the criminal intent, persuaded Pavlenko I.V. to
financial instruments, namely options, in accordance with which Pavlenko I.V.'s funds in various amounts
315
under the circumstances described above, deliberately, by means of deceit and breach of trust, in the period
from 03.11.2020 to 12.02.2021, stole money belonging to Pavlenko I.V. in the amount of 2,942,870 rubles, in
namely:
316
than 11.02.2021. 1, as well as in unspecified places, acting as an organised group, as part of a criminal
using unspecified information and telecommunication means of communication, misled Smirnov A.V. about
their true intentions - the thef of his funds, under the pretext of executing an order to conclude over - the -
counter option contracts on the OTC market, without initially having the intention to execute the taken on
organised the signing of the agreement with Smirnov, V.S, Rossieva E.A. and unidentified persons, acting in
an organised group, jointly and in concert, on 11.02.2021, at an unspecified time and place, arranged for
Smirnov A.V. to sign an application for consent to conclude a brokerage services agreement with IC QBF LLC
(application for joining for individuals), on the basis of which on 11.On 02.02.2021 Smirnov A.V. and "IK QBF"
LLC, named as a broker, concluded a brokerage services agreement No. BO - F - N - 0 - 01757, dated
09.02.2021, and under the pretext of fulfilling the conditions of the said agreement persuaded the latter to
transfer his funds to them ostensibly for trust management.
- A.V. Smirnov, unaware of the crime being prepared and misled as to the true objectives of the participants of
agreement was executed, on 12.02.2021 transferred funds from his account No. 42301810700002299048
opened with JSC Tinkoff Bank, located at 38, 2nd Khutorskaya St., Moscow.A, page 26, to QBIF LLC account
No. 40701810700003010998 opened with NSD ("National Settlement Depository") located at 12
- Having received these funds from Smirnov A.V. in the total amount of 2,500,000 roubles, Shpakov R.V.,
as well as to create a belief in Smirnov A.V. that his money was being invested in a profitable way, R.V.
persons, abusing Smirnov A.V.'s trust, as well as persons unaware of the criminal intent, persuaded him to
sign instructions to a broker in order to conclude OTC derivative transactions, namely options, in accordance
317
with which Smirnov A.V.'s funds in various amounts were transferred to QBIF LLC as a security payment to the
stole money belonging to Smirnov A.V. in the amount of 2,500,000 roubles, in an especially large amount.
namely:
318
misled Bazaev M.A. as to their true intentions - the thef of his funds, under the pretext of executing an order
the assumed obligations.
12.08.2020, at an unspecified time and place, organised the signing with Bazaev M.A. of an application for
on the basis of which on 12.08.08.2020 between Bazaev M.A. and "IC "QBF" LLC, named as a broker,
pretext of fulfilling the conditions of the said agreement persuaded the latter to transfer his funds to them
- M.A. Bazaev, unaware of the crime being prepared and misled as to the true objectives of the participants of
account No. 40817810340007276641, opened in PJSC "Sberbank", located at the address: Moscow region,
Dolgoprudny, Dolgoprudny, Novy Boulevard, 3, to the account of LLC "IC QBF" No. 40701810738000001955,
opened in PJSC "Sberbank", located at the address: Moscow, Bolshaya Andronyevskaya St., 6, under the
agreement on provision of brokerage services No. BO - F - N - 0 - 00142 dated 12.08.2020, namely: 21.08.2020
220,000, as well as 16.02.2021 from his account No. 40817810200022590072 opened with JSC "Tinkoff Bank"
located at: Moscow, 2 - ya Khutorskaya str. 38 "A" p.26, to the account No. 40701810201400000052 opened
with JSC Alfa - Bank located at 27 Kalanchevskaya Street, Moscow, under brokerage services agreement No.
BO - F - N - 0 - 00142 dated 12.08.2020, in the amount of RUB 700,000, totaling RUB 1,620,000.
- Having received these funds from M.A. Bazaeva in the total amount of 1,620,000 roubles, R.V. Shpakov, V.S.
their own discretion in accordance with the criminal plan and in fulfilment of their joint criminal intent,
thereby stealing them, knowingly without intending to execute them, E.A. Rossieva and unidentified persons
319
legitimate, as well as to create a belief in Bazaev M.A. that his money would be invested profitably, R.V.
persons, abusing Bazaev M.A.'s trust, as well as persons unaware of the criminal intent, persuaded him to
financial instruments, namely options, in accordance with which M.A. Bazaev's funds in various amounts
from 21.08.2020 to 16.02.2021, stole money belonging to Bazaev M.A. in the amount of 1,620,000 roubles, on
a particularly large scale.
namely:
320
than 18.02.2021, remotely, remotely, and also at unspecified locations. 1, as well as in unspecified places,
acting as an organised group, as part of a criminal association, jointly and in concert, at an unspecified
period of time, but not later than 18.02.2021, remotely, using unspecified information and
telecommunication means of communication, misled A.A. Trishin regarding their true intentions - the thef of
his funds, under the pretext of executing an order to conclude over - the - counter option contracts on the
OTC market, without initially having any intention to execute the taken on
18.02.2021, at an unspecified time and place, arranged for Trishin A.A. to sign an application for consent to
basis of which on 18.On 18.02.2021 between A.A. Trishin and "IC QBF" LLC, named as a broker, concluded the
management.
- A.A. Trishin, A.A. Trishin, unaware of the crime being prepared and misled as to the true objectives of the
fulfilling the terms of the option agreement, made a transfer of funds from his account No. opened with PJSC
"Mosoblbank" located at the address: Moscow Region, Korolev, ul.2021 he transferred funds from his account
No. 40817810002890049654, opened in PJSC Mosoblbank, located at the address: Moscow region, Korolev,
Frunze str. 21, to QBIF LLC's account No. 40701810700003010998 opened with NSD ("National Settlement
N - 0 - 01867 dated 18 February 2021 in the amount of RUB 1,800,000.
- Having received these funds from A.A. Trishina in the total amount of 1,800,000 roubles, R.V. Shpakov, V.S.
321
as well as to create a belief in Trishin A.A. that his money would be invested profitably, Shpakov R.V.,
Pakhomov V.S., Matyukhin S.S., Athanasiadou Linda, Golubev A.S., Rossieva E.A. and unidentified persons
abused the trust in the investment of his funds, Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda, Golubev
A.S., Rossieva E.A. and unidentified persons, abusing the confidence of A.A. Trishin, as well as persons
into OTC derivative transactions, namely options, in accordance with which A.A. Trishin's funds in various
amounts were transferred by QBIF IC LLC as a security payment to the accounts of the options seller, Q-
BROKER LLC, an affiliate of QBIF LLC.
stole money belonging to A.A. Trishin in the amount of 1,800,000 roubles, in an especially large amount.
namely:
322
misled Mitkin D.V. as to their true intentions - the thef of his funds, under the pretext of executing an order to
conclude OTC option contracts on the OTC market, without initially intending to execute the undertaken by
them.
23.11.2020, at an unspecified time and place, organised the signing with Mitkin D.V. of an application for
on the basis of which on 23.11.11.2020 between Mitkin D.V. and "IC "QBF" LLC, named as a broker, concluded
the agreement on brokerage services No. BO - F - N - 0 - 00872 dated 23.11.2020, and under the pretext of
fulfilment of the conditions of the said agreement convinced the latter to transfer his funds to them allegedly
- Mitkin D.V., unaware of the crime being prepared and misled as to the true objectives of the participants of
agreement conditions were fulfilled, in the period from 04.12.2020 to 19.02.2021 made transfers of funds as
follows: on 04.12.2020 from his account No. 42305810138127969958, opened in PJSC "Sberbank", located at
the address: Moscow, Pronskaya str. 2, to the account No. 40701810201400000052 opened in JSC Alfa - Bank,
located at 27 Kalanchevskaya St., Moscow, under brokerage services agreement No. BO - F - N - 0 - 00872
dated 23.11.2020, in the amount of RUB 1,900,000; in the period from 16.02.2021 to 19.02.2021 from his
account No. 40817810638127445213 opened with PJSC Sberbank, located at 2 Ponskaya St., Moscow, to the
account No. 40701810201400000052 opened with LLC IC QBF, located at 27 Kalanchevskaya St., Moscow,
323
under brokerage services agreement No. BO - F - N - 0 - 00872 dated 23.11.2020, namely: 16.02.2021 in the
amount of RUB 800,000; 19.02.2021 in the amount of RUB 200,000, totalling RUB 2,900,000.
- Having received these funds from D.V. Mitkina in the total amount of 2,900,000 roubles, R.V. Shpakov, V.S.
- Further, realising that the activity of QBIF LLC is subject to inspection by the regulator - the Central Bank of
the Russian Federation, in order to conceal their criminal activity and to make their actions look legitimate,
as well as to create a belief in Mitkin D.V. that his money is profitably invested, Shpakov R.V., Pakhomov V.S.,
Athanasiadou Linda, Golubev A.S., Rossieva E.A. and unidentified persons abused the trust in his money,
abusing Mitkin D.V.'s trust, as well as persons unaware of the criminal intent, persuaded him to sign
instruments, namely options, in accordance with which D.V. Mitkin's funds in various amounts were
transferred to LLC IC QBF as a security payment to the accounts of the options seller, LLC Q.Broker, affiliated
with LLC IC QBF.
breach of trust, stole money belonging to Mitkin D.V. in the amount of 2,900,000 rubles, in an especially large
amount.
namely:
324
misled V.P. Sotnikov about their true intentions - the thef of his funds, under the pretext of executing an
17.12.2020, at an unspecified time and place, organised the signing with V.P. Sotnikov of an application for
on the basis of which on 17.12.12.2020 between V.P. Sotnikov and "IC QBF" LLC, named as a broker,
of fulfilling the terms of the said agreement persuaded the latter to transfer his funds to them allegedly for
trust management.
- V.P. Sotnikov, unaware of the crime that was being prepared and misled as to the true objectives of the
the terms of the option agreement were fulfilled, made transfers of funds between 30.12.2020 and 21.02.2021
325
as follows: 30.12.2020 from his account No. 40817840000000960083 opened with JSC Investment Bank
FINAM, located at: Moscow, Nastasyinsky per, 7, page 2, to QBIF LLC's account No. 40701840900006010998
opened with NSD ("National Settlement Depository") located at 12 Spartakovskaya Street, Moscow, under
Brokerage Services Agreement No. BO - F - N - 0 - 01180 dated 17.12.2020, in the amount of 99,595.00.2020, in
the amount of USD 99,595.47, which at the exchange rate of the Central Bank of the Russian Federation as of
30.12.2020 amounted to RUB 7,336,202.32; in the period from 11.02.2021 to 21.02.2021 from his account No.
40817810538188237463 opened with PJSC Sberbank of Russia, located at: Moscow, Sivtsev Vrazhek per.
Sivtsev Vrazhek, 29/16, pp. 1, to the account No. 40701810738000001955 opened in PJSC Sberbank of Russia,
located at 6 Bolshaya Andronievskaya St., Moscow, under the Brokerage Services Agreement No. BO - F - N - 0
- 01180 dated 17.12.2020, namely: 11.02.2021 in the amount of RUB 999,800; 21.02.2021 in the amount of
RUB 600,000, totalling RUB 8,936,002.32.
- Having received these funds from V.P. Sotnikova in the total amount of 8,936,002.32 roubles, R.V. Shpakov,
V.S. Pakhomov, S.A. Matyukhin, Athanasiadou Linda , A.S. Golubev and unidentified persons disposed of
them at their own discretion in accordance with the criminal plan and in fulfilment of a joint criminal intent,
as well as to create a belief in Sotnikov V.P. that his money was being invested in a profitable way, R.V.
persons, abusing Sotnikov V.P.'s trust, as well as persons unaware of the criminal intent, persuaded him to
accordance with which V.P. Sotnikov's funds in various amounts were transferred to QBIF LLC as a security
breach of trust, stole money belonging to Sotnikov V.P. in the amount of 8,936,002.32 rubles, in an especially
large amount.
namely:
326
than 08.02.2021. 1, as well as in unspecified places, acting as an organised group, as part of a criminal
using unspecified information and telecommunication means of communication, misled Korolsky V.V. about
counter option contracts on the OTC market, without initially intending to execute the taken instructions.
327
the signing with Korolskiy V.V. of a statement of consent to conclude a brokerage services agreement with IK
QBF LLC (application for joining for individuals), on the basis of which on 08. 02.2021, Korolskiy V.V. signed a
statement of consent to conclude a brokerage services agreement with IK QBF LLC (application for joining for
individuals).02.02.2021 between Korolskiy V.V. and "IC "QBF" LLC, named as a broker, concluded the contract
of brokerage services No. BO - F - N - 0 - 01714 of 08.02.2021, and under the pretext of fulfilling the conditions
of this contract persuaded the latter to transfer his funds to them allegedly for trust management.
- Korolsky V.V., unaware of the crime being prepared and misled as to the true objectives of the participants of
account No. 40817810247154000455, opened in the branch office of PO "Znamensky" No. 6602 of the bank
PJSC "VTB", located at the address: Tyumen, Chelyuskintsev str. 1 Chelyuskintsev St., Bldg. 1, Tyumen, to
QBIF LLC's account No. 40701810700003010998 opened with NSD ("National Settlement Depository") located
at 12 Spartakovskaya St., Moscow. 12 Spartakovskaya Street, Moscow, under Brokerage Services Agreement
No. BO - F - N - 0 - 01714 dated 08.02.2021, namely: RUB 2,000,000 on 09.02.2021; RUB 500,000 on 26.02.2021,
in the total amount of RUB 2,500,000.
- Having received these funds from Korolsky V.V. in the total amount of 2,500,000 roubles, Shpakov R.V.,
- Further, realising that the activities of QBIF Ltd. were subject to inspection by the regulator, the Central Bank
as well as to create a conviction in Korolskiy V.V. that his money was profitably invested, Shpakov R.V.,
abusing the trust of Korolsky V.V., as well as persons unaware of the criminal intent, persuaded him to sign
instructions to a broker for the purpose of concluding OTC derivative transactions, namely options, in
accordance with which Korolsky V.V.'s funds in various amounts were transferred to QBIF LLC as a security
breach of trust, stole funds belonging to Korolsky V.V. in the amount of 2,500,000 roubles, in an especially
large amount.
namely:
328
misled S.V. Trukhmeneva as to their true intentions - the thef of her funds, under the pretext of executing an
intention to execute the undertaken obligations.
329
30.10.2020, at an unspecified time and place, organised the signing with Trukhmeneva S.V. of an application
for consent to conclude a brokerage services agreement with IC QBF LLC (application for adhesion for
individuals), on the basis of which on 30.10.10.2020 between Trukhmeneva S.V. and "IC "QBF" LLC, named as
a broker, concluded the brokerage services agreement No. BO - F - N - 0 - 00709 dated 30.10.2020, and under
the pretext of fulfilling the conditions of the said agreement convinced the latter to transfer her funds to them
- S.V. Trukhmeneva, unaware of the crime being prepared and misled as to the true objectives of the members
of the organised group - the thef of her funds, convinced that her funds would be returned afer the option
agreement was executed, in the period from 02.12.2020 to 26.02.2021 made transfers of funds from her
account No. 40817810100004773069, opened with JSC "Tinkoff Bank", located at: Moscow, 2nd Khutorskaya
str. 38 "A", page 26, to the account of LLC "IC QBF" No. 40701810201400000052 opened with JSC "Alfa Bank"
located at the address: Moscow, Kalanchevskaya str. 27, under the agreement on rendering brokerage
services No. BO - F - N - 0 - 00709 dated 30.10.2020, namely: 02.12.2020 in the amount of RUB 1,000;
03.12.12.2020 in the amount of RUB 370,000; 04.12.2020 in the amount of RUB 429,000; 11.12.2020 in the
26.02.2021 in the amount of RUB 100,000; 26.02.2021 in the amount of RUB 300,000, in total in the amount of
RUB 1,602,000.
- Having received these funds from Trukhmeneva S.V. in the total amount of 1,602,000 roubles, Shpakov R.V.,
legitimate, as well as to create a belief in Trukhmeneva S.V. that her money would be invested profitably,
Shpakov R.V., Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda, Golubev A.S., Rossieva E.A. and
unidentified persons abused the trust in her money, Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda,
Golubev A.S., Rossieva E.A. and unidentified persons, abusing the confidence of Trukhmeneva S.V., as well as
persons unaware of the criminal intent, persuaded her to sign instructions to a broker for the purpose of
entering into OTC derivative transactions with derivative financial instruments, namely options, in
accordance with which S.V. Trukhmeneva's funds in various amounts were transferred to QBIF LLC as a
security payment to the accounts of the options seller, Q-BROKER LLC, an affiliate of QBIF LLC.
from 02.12.2020 to 26.02.2021, stole money belonging to Trukhmeneva S.V. in the amount of 1,602,000
roubles, on a particularly large scale.
namely:
330
using unspecified information and telecommunication means of communication, misled Alexeev F.V. about
331
counter option contracts on the OTC market, without initially having any intention to execute the undertaken
obligations.
Golubev and unidentified persons acting in an organised group, together and in concert, Rossieva E.A. and
time and place, organised the signing with Alexeev F.V. of an application for consent to conclude a brokerage
services agreement with IC QBF LLC (application for joining for individuals), on the basis of which on
24.12.12.2020 between Alexeev F.V. and "IC "QBF" LLC, named as a broker, concluded a brokerage services
agreement No. BO - F - N - 0 - 01272 dated 24.12.2020, and under the pretext of fulfilling the conditions of the
said agreement convinced the latter to transfer his funds to them allegedly for trust management.
- Alexeev F.V., unaware of the crime being prepared and misled as to the true objectives of the participants of
terms of the option agreement, in the period from 15.01.2021 to 03.03.2021 he made money transfers as
follows: being in the office of PJSC "Sberbank of Russia", located at the address: Smolensk, Glinka str. 5,
made cash deposits to QBIF LLC's account No. 40701810700003010998 opened with NSD ("National
the amount of RUB 500,000, as well as 03.03.2021 made a transfer of funds from his account No.
40817810659004744605, opened in the branch of PJSC Sberbank of Russia, located at the address: Smolensk,
Kommunisticheskaya str. 8/5, to QBIF LLC's account No. 40701810700003010998 opened with NSD ("National
No. BO - F - N - 0 - 01272 dated 24.12.2020, in the amount of RUB 800,000, totalling RUB 2,068,000.
- Having received these funds from Alekseeva F.V. in the total amount of 2,068,000 roubles, Shpakov R.V.,
as well as to create a belief in Alexeev F.V. that his money was being invested in a profitable way, R.V. Shpakov,
S.S. Pakhomov, S.S. Matyukhin, Athanasiadou Linda , A.S. Golubev, E.A. Rossieva and unidentified persons
Golubev A.S., Rossieva E.A. and unidentified persons, abusing Alekseev F.V.'s trust, as well as persons
which the funds of Alexeev F.V. in various amounts were transferred by QBIF LLC as a security payment to the
accounts of the options seller, Q-BROKER LLC, affiliated with QBIF LLC.
breach of trust, stole funds belonging to Alekseev F.V. in the amount of 2,068,000 roubles, on a particularly
large scale.
332
namely:
333
association, together and in concert, during an unspecified period of time, but no later than 19.01.2021,
remotely, remotely, and also at unspecified places, acting in an organised group, as part of a criminal
using unspecified information and telecommunication means of communication, misled M.Y. Rodnevskaya
about their true intentions - the thef of her funds, under the pretext of executing an order to conclude OTC
option contracts on the OTC market, without initially intending to execute the undertaken obligations.
- Продолжая свои преступные действия, Шпаков Р.В., Пахомов В.С., Матюхин С.А., Атанасиаду Л.,
Голубев А.С., Rossieva E.A. and unidentified persons, acting in an organised group, jointly and in concert, on
19.01.2021, at an unspecified time and place, organised the signing with Rodnevskaya M.Y. of an application
for consent to conclude a brokerage services agreement with IC QBF LLC (application for joining for
individuals), on the basis of which on 19.01.01.2021 between Rodnevskaya M.Y. and IK QBF LLC, which was
called a broker, concluded a brokerage services agreement No. BO - F - N - 0 - 01478 dated 19.01.2021, and
under the pretext of fulfilling the terms of the said agreement convinced the latter to transfer her funds to
- M.Y. Rodnevskaya, unaware of the crime being prepared and misled as to the true objectives of the members
of the organised group - the thef of her funds, convinced that her funds would be returned afer the option
agreement was executed, made the following transfers of funds between 20.01.2021 and 19.03.2021: from
her account No. 40817810501001610170 opened with JSC Raiffeisenbank located at 17 Troitskaya str, k.1, to
IC QBF LLC account No. 40701810700003010998 opened with NSD ("National Settlement Depository")
dated 19.01.2021, namely: 20.01.2021 in the amount of RUB 50,000; 11.02.2021 in the amount of RUB 51,000;
17.03.2021 in the amount of RUB 50,000; 19.03.2021 in the amount of RUB 100,000; 01.02.2021 from its
account No. 40817810901004324364 opened with JSC Raiffeisenbank located at: Moscow, 17 Troitskaya str, k.
1, to QBIF LLC's account No. 40701810700003010998 opened with NSD, located at 12 Spartakovskaya Street,
Moscow, under Brokerage Services Agreement No. BO - F - N - 0 - 01478 dated 19.01.01.2021, in the amount of
RUB 350,000; in the period from 08.02.2021 to 11.02.2021 from his account No. 40817810503200523661
opened with JSC "BKS Bank" located at: Moscow, 3 Marksistskaya str. 1, to IC QBF LLC account No.
40701810700003010998 opened with NSD JSC located at 12 Spartakovskaya Street, Moscow, under
Brokerage Services Agreement No. BO - F - N - 0 - 01478 dated 19.01.2021, namely: 08.02.2021 in the amount
of RUB 500,000; 09.02.2021 in the amount of RUB 67,330.95; 09.02.2021 in the amount of RUB 500,000;
10.02.2021 in the amount of RUB 432,660; 10.02.2021 in the amount of RUB 1,000,000; 11.02.2021 in the
amount of RUB 182,236.30, totalling RUB 3,283,227.25.
- Having received these funds from Rodnevskaya M.Y. in the total amount of 3,283,227.25 rubles, Shpakov R.V.,
as well as to create a belief in Rodnevskaya M.Y. that her money would be invested profitably, R.V. Shpakov,
S.V. Pakhomov, S.S. Matyukhin, Athanasiadou Linda , A.S. Golubev, E.A. Rossieva and unidentified persons
E.A. and unidentified persons, abusing the confidence of Rodnevskaya M.Y., as well as persons unaware of the
transactions with derivative financial instruments, namely options, in accordance with which the funds of
334
Rodnevskaya M.Y. in various amounts were transferred to QBIF LLC as a security payment to the accounts of
the seller of options - Q-BROKER LLC, affiliated with QBIF LLC.
breach of trust, stole money belonging to Rodnevskaya M.Y. in the amount of 3,283,227.25 roubles, in an
namely:
335
using unspecified information and telecommunication means of communication, misled Savin A.V. as to their
true intentions - the thef of his funds, under the pretext of executing an order to conclude OTC option
contracts on the over - the - counter market, without initially intending to fulfil the obligations undertaken by
A.V. Savin.
25.12.2020, at an unspecified time and place, arranged for Savin A.V. to sign an application for consent to
basis of which on 25.12.12.2020 between Savin A.V. and "IC "QBF" LLC, named as a broker, concluded a
management.
- Savin A.V., unaware of the crime being prepared and misled as to the true objectives of the members of the
account No. 40817810204810096369 opened with JSC Alfa - Bank, located at: Moscow, Presnensky Val str. 3,
to QBIF LLC account No. 40701810201400000052 opened with Alfa - Bank JSC located at 27 Kalanchevskaya
St., Moscow, under brokerage services agreement No. BO - F - N - 0 - 01283 dated 25.12.2020, namely:
amount of RUB 200,000; 03.02.2021 in the amount of RUB 600,000; 23.03.2021 in the amount of RUB 200,000,
totalling RUB 2,000,000.
- Having received these funds from Savina A.V. in the total amount of 2,000,000 roubles, Shpakov R.V.,
as well as to create a belief in Savin A.V. that his money was being invested in a profitable way, R.V. Shpakov,
V.S. Pakhomov, S.S. Matyukhin, Athanasiadou Linda , A.S. Golubev, E.A. Rossieva and unidentified persons
Golubev A.S., Rossieva E.A. and unidentified persons, abusing Savin A.V.'s trust, as well as persons unaware of
336
the criminal intent, persuaded him to sign instructions to a broker for the purpose of entering into OTC
derivative transactions, namely options, in accordance with which Savin A.V.'s funds in various amounts were
- Subsequently, in accordance with the criminal plan, these funds stolen by the co - conspirators were used by
Federation, cashing out funds, purchasing real estate, financing construction and issuing loans to legal
breach of trust, stole money belonging to Savin A.V. in the amount of 2,000,000 roubles, in an especially large
amount.
namely:
337
misled Medvedev R.V. about their true intentions - the thef of his funds, under the pretext of executing an
intention to execute the undertaken obligations.
24.11.2020, at an unspecified time and place, arranged for Medvedev R.V. to sign an application for consent to
basis of which on 24.11.11.2020 between Medvedev R.V. and "IC "QBF" LLC, named as a broker, concluded a
management.
- Medvedev R.V., unaware of the crime being prepared and misled as to the true objectives of the participants
terms of the option agreement, in the period from 30.11.2020 to 23.03.2021 he made transfers of funds from
his account No. 40817810878003758742 opened in the branch of PJSC Bank FC Otkrytie located at the
address: Tyumen, 8 Marta St., d. 2/10, to the account of OOO IKK. 2/10, to IC QBF LLC account No.
Spartakovskaya St., Moscow, under Brokerage Services Agreement No. BO - F - N - 0 - 00889 dated 24.11.2020,
namely: 30.11.2020 in the amount of RUB 1,000,000; 07.12.2020 in the amount of RUB 500,000; 21.01.2021 in
the amount of RUB 1,200,000; 10.02.2021 in the amount of RUB 1,500,000; 09.03.2021 in the amount of RUB
5,700,000.
- Having received these funds from Medvedev R.V. in the total amount of 5,700,000 roubles, Shpakov R.V.,
338
as well as to create a belief in Medvedev R.V. that his money was being invested in a profitable way, Shpakov
persons, abusing Medvedev R.V.'s trust, as well as persons unaware of the criminal intent, persuaded him to
accordance with which R.V. Medvedev's funds in various amounts were transferred to QBIF LLC as a security
from 30.11.2020 to 23.03.2021, stole money belonging to Medvedev R.V. in the amount of 5,700,000 roubles,
namely:
339
this group, persuaded the clients to conclude various investment agreements with LLC IC QBF, including an
agreement on the provision of brokerage services, and also to transfer under these agreements to the trust
management of them, the co - conspirators, their monetary funds, which were then transferred to them, the
co - conspirators.
misled Babelyan S.A. as to their true intentions - the thef of his funds, under the pretext of executing an
order to conclude OTC option contracts on the over - the - counter market, with no initial intention to execute
the undertaken by them.
27.11.2020, at an unspecified time and place, organised the signing with Babelyan S.A. of an application for
individuals), on the basis of which on 27.11.11.2020 between Babelyan S.A. and "IC "QBF" LLC, named as a
broker, concluded the agreement on brokerage services No. BO - F - N - 0 - 00942 dated 27.11.2020, and under
the pretext of fulfilling the conditions of the said agreement convinced the latter to transfer his funds to them
- S.A. Babelyan, unaware of the crime being prepared and misled as to the true objectives of the participants
terms of the option agreement, in the period from 04.02.02.2021 - 24.03.2021 he made transfers of funds as
follows: in the period from 04.02.2021 to 11.03.2021 from his account No. 40817810732294005223, opened in
PJSC "VTB Bank", located at the address: Moscow, Leningradskoe shosse, 13, k.1, to IC QBF LLC account No.
27.11.2020, namely: RUB 500,000 on 04.02.2021; RUB 500,000 on 08.02.2021; RUB 300,000 on 11.03.2021; RUB
300,000 on 24.03.2021.2021 from its account No. 40817810800003206507 opened with JSC "Tinkoff Bank"
located at: Moscow, 2nd Khutorskaya St., 38A, page 26, to the account of LLC "IC QBF" No.
40701810700003010998 opened with NSD JSC ("National Settlement Depository") located at: Moscow,
Spartakovskaya str. 12 Spartakovskaya Street, Moscow, under Brokerage Services Agreement No. BO - F - N - 0
- 00942 dated 27.11.2020, in the amount of RUB 1,700,000, totalling RUB 3,000,000.
340
- Having received these funds from Babelyan S.A. in the total amount of 3,000,000 roubles, Shpakov R.V.,
as well as to create a belief in Babelyan S.A. that his money would be invested profitably, Shpakov R.V.,
abused the trust in his money, Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda, Golubev A.S., Rossieva
E.A. and unidentified persons, abusing Babelyan S.A.'s trust, as well as persons unaware of the criminal
intent, persuaded him to sign instructions to a broker in order to conclude over - the - counter derivative
transactions with derivative financial instruments, namely options, in accordance with which Babelyan S.A.'s
funds in various amounts were transferred to QBIF LLC as a security payment to the accounts of the options
seller, Q-BROKER LLC, an affiliate of QBIF LLC.
and breach of trust, stole money belonging to Babelyan S.A. in the amount of 3,000,000 roubles, in an
namely:
341
remotely, remotely, and also at unspecified places, acting in an organised group, at the following address 1,
as well as in unspecified places, acting as an organised group, as part of a criminal association, jointly and in
information and telecommunication means of communication, misled Kalinin S.V. as to their true intentions -
the thef of his funds, under the pretext of executing an order to conclude OTC option contracts on the over -
the - counter market, without having any intention to execute the undertaken by them.
24.03.2021, at an unspecified time and place, organised the signing with Kalinin S.V. of a statement of
consent to conclude a contract of brokerage services with IC QBF LLC (application for adhesion for
individuals), on the basis of which on 24.03.2021 between Kalinin S.V. and "IC "QBF" LLC, named as a broker,
pretext of fulfilment of the conditions of the said contract persuaded the latter to transfer his funds to them
- S.V. Kalinin, unaware of the crime that was being prepared and misled as to the true objectives of the
the option agreement was executed, on 25.03.2021 transferred funds from his account No.
42301810430550304155 opened with JSC CB Citibank, located at 8 - 10 Gasheka St., p. 1, Moscow, to QBIF
LLC's account No. 42301810430550304155 opened with NSD ("National Settlement Depository"), located at 8
342
- 10 Gasheka St., Moscow, Russia. 1, to QBIF LLC account No. 40701810700003010998 opened with NSD
("National Settlement Depository") located at 12 Spartakovskaya Street, Moscow, under Brokerage Services
Agreement No. BO - F - N - 0 - 02143 dated 24.03.2021 in the amount of RUB 1,200,000.
- Having received these funds from Kalinina S.V. in the total amount of 1,200,000 roubles, Shpakov R.V.,
as well as to create a belief in Kalinin S.V. that his money would be invested profitably, R.V. Shpakov,
abusing Kalinin S.V.'s trust, as well as persons unaware of the criminal intent, persuaded him to sign
accordance with which Kalinin S.V.'s funds in various amounts were transferred to QBIF LLC as a security
stole money belonging to Kalinin S.V. in the amount of 1,200,000 roubles, in an especially large amount.
namely:
343
misled Galaktionov S.V. about their true intentions - the thef of his funds, under the pretext of executing an
order to conclude OTC option contracts on the OTC market, without initially intending to execute the bribe.
29.09.2020, at an unspecified time and place, arranged for Galaktionov S.V. to sign an application for consent
basis of which on 29.09.09.2020 between Galaktionov S.V. and "IC "QBF" LLC, named as a broker, concluded
the brokerage services agreement No. BO - F - N - 0 - 00485 dated 29.09.2020, and under the pretext of
fulfilling the conditions of the said agreement persuaded the latter to transfer his funds to them allegedly for
trust management.
- S.V. Galaktionov, unaware of the crime being prepared and misled as to the true objectives of the participants
of the organised group - the thef of his funds, convinced that his funds will be returned afer the option
agreement is fulfilled, in the period from 13.10.2020 to 05.04.2021 made transfers of funds from his account
No. 40817810500016135774, opened in JSC "Tinkoff Bank", located at the address: Moscow, 2nd Khutorskaya
St., 38A, p. 26, to the account of LLC IK "Tinkoff Bank", located at the address: Moscow, 2nd Khutorskaya St.,
38A, p. 26, to the account of LLC IK "Tinkoff Bank". 26, to IC QBF LLC account No.40701810700003010998
opened with NSD JSC ("National Settlement Depository") located at 12 Spartakovskaya Street, Moscow,
under Brokerage Services Agreement No. BO - F - N - 0 - 00485 dated 29.09.2020, namely: 13.10.2020 in the
344
amount of RUB 1,270,000; 27.10.2020 in the amount of RUB 1,661,750; 05.04.2021 in the amount of RUB
2,900,000, totalling RUB 5,831,750.
- Having received these funds from Galaktionova S.V. in the total amount of 5,831,750 roubles, Shpakov R.V.,
- Further, realising that the activities of QBIF LLC are subject to inspection by the regulator - the Central Bank
legitimate, as well as to create a belief in Galaktionov S.V. that his money is profitably invested, R.V. Shpakov,
abusing Galaktionov S.V.'s trust, as well as persons unaware of the criminal intent, persuaded him to sign
instruments, namely options, in accordance with which Galaktionov S.V.'s monetary funds in various
abuse of trust, stole funds belonging to Galaktionov S.V. in the amount of 5,831,750 rubles, in an especially
large amount.
namely:
345
information and telecommunication means of communication, misled Frolov Y.A. about their true intentions
- the thef of his funds, under the pretext of executing an order to conclude OTC option contracts on the over -
the - counter market, without initially intending to execute the assumed obligations.
26.03.2021, at an unspecified time and place, arranged for Frolov Y.A. to sign an application for consent to
basis of which on 26.03.03.2021 between Frolov Y.A. and "IC QBF" LLC, named as a broker, concluded the
contract of brokerage services No. BO - F - N - 0 - 02160 of 26.03.2021, and under the pretext of fulfilment of
the conditions of the said contract persuaded the latter to transfer his funds to them allegedly for trust
management.
- Y.A. Frolov, unaware of the crime being prepared and misled as to the true objectives of the participants of
agreement was fulfilled, in the period from 06.04.2021 to 13.04.2021 made transfers of funds from his
account No. 40817810038040133008, opened with PJSC Sberbank, located at the address: 16
346
Novoslobodskaya St., Moscow, to the account of LLC IK QBF No. 40817810038040133008, opened with NKO
JSC NRSD. 16 Novoslobodskaya St., Moscow to QBIF LLC account No. 40701810700003010998 opened with
NSD ("National Settlement Depository") located at 12 Spartakovskaya St., Moscow, under the brokerage
agreement. 12, under Brokerage Services Agreement No. BO - F - N - 0 - 02160 dated 26.03.2021, namely: RUB
1,000,000 on 06.04.2021; RUB 500,000 on 12.04.2021; RUB 450,000 on 13.04.2021, totaling RUB 1,950,000.
- Having received these funds from Frolova Y.A. in the total amount of 1,950,000 roubles, Shpakov R.V.,
legitimate, as well as to create a belief in Frolov Y.A. that his money would be invested profitably, Shpakov
persons abused their trust in the investment of his funds, Pakhomov V.S., Matyukhin S.A., Athanasiadou
Linda, Golubev A.S., Rossieva E.A. and unidentified persons, abusing Frolov Y.A.'s trust, as well as persons
which Frolov Y.A.'s funds in various amounts were transferred to QBIF LLC as a security payment to the
breach of trust, stole money belonging to Frolov Y.A. in the amount of 1,950,000 roubles, on a particularly
large scale.
namely:
347
misled Pilin D.A. about their true intentions - the thef of his funds, under the pretext of executing an order to
conclude over - the - counter option contracts on the OTC market, without initially intending to fulfil the
obligations undertaken by the company.
an unspecified time and place, organised the signing with Pilin D.A. of an application for consent to conclude
a brokerage services agreement with IC QBF LLC (application for joining for individuals), on the basis of which
on 13.11.11.2020 between Pilin D.A. and "IC QBF" LLC, named as a broker, concluded a brokerage services
agreement persuaded the latter to transfer his funds to them allegedly for trust management.
- D.A. Pilin, unaware of the crime being prepared and misled as to the true objectives of the members of the
348
agreement was executed, in the period from 25.12.2020 to 26.04.2021 he made transfers of funds from his
account No. 40817810400001840912 opened with JSC "Tinkoff Bank", located at the address: Moscow, 2nd
Khutorskaya St., 38A, p. 26, to the account of LLC "IK IK". 26, to IC QBF LLC account No. 0701810700003010998
opened with NSD JSC ("National Settlement Depository") located at 12 Spartakovskaya Street, Moscow,
under Brokerage Services Agreement No. BO - F - N - 0 - 00785 dated 13.11.2020, namely: 25.12.2020 in the
- Having received these funds from Pilina D.A. in the total amount of 1,100,000 roubles, Shpakov R.V.,
as well as to create a belief in Pilin D.A. that his money would be invested profitably, R.V. Shpakov, V.S.
abused trust in the investment of his money, Pakhomov V.S., Matyukhin S.A., Athanasiadou Linda, Golubev
A.S., Rossieva E.A. and unidentified persons, abusing Pilin D.A.'s trust, as well as persons unaware of the
criminal intent, persuaded him to sign instructions to a broker for the purpose of entering into OTC derivative
transactions with derivative financial instruments, namely options, in accordance with which Pilin D.A.'s
funds in various amounts were transferred to QBIF LLC as a security payment to the accounts of the options
seller, Q-BROKER LLC, an affiliate of QBIF LLC.
from 25.12.2020 to 26.04.2021, stole money belonging to Pilin D.A. in the amount of 1,100,000 roubles, in an
namely:
349
than 31.03.2021, remotely, remotely, and also at unspecified places, acting in an organised group, at the
following address 1, as well as in unspecified places, acting as an organised group, as part of a criminal
association, jointly and in concert, during an unspecified period of time, but not later than 31.03.2021,
remotely, using unspecified information and telecommunication means of communication, as well as during
the repeated attendance by Merts A.N. of presentations of QBF group companies' activities in the provision of
brokerage services, held at the following address: Tyumen, Maximskaya str. Tyumen, Maksim Gorkogo St., 74,
misled Merts A.N. about their true intentions - the thef of his funds, under the pretext of executing an order
to conclude over - the - counter option contracts on the OTC market, without initially intending to fulfil their
obligations to pay and return the funds to the client.
350
the signing with Merts A.N. of an application for consent to the conclusion of a brokerage services agreement
with IC QBF LLC (application for joining for individuals), on the basis of which, on 31.03.03.2021 between
Merts A.N. and "IC "QBF" LLC, named as a broker, concluded the contract of rendering brokerage services BO
- F - N - 0 - 02187 dated 31.03.2021, and under the pretext of fulfilment of the conditions of the said contract
persuaded the latter to transfer his funds to them allegedly for trust management.
- Merts A.N., unaware of the crime being prepared and misled as to the true objectives of the members of the
organised group - the thef of his funds, convinced that his funds would be returned afer fulfilling the terms
of the option agreement, on 26.04.2021 he transferred funds from his account No. 40817810999933795000,
opened in the branch of PJSC Bank FC Otkrytie, located at Tyumen, V. Goltsova str. 22, to QBIF LLC's account
No. 40701810700003010998 opened with NSD (National Settlement Depository) located at 12
Spartakovskaya Street, Moscow, under Brokerage Services Agreement No. BO - F - N - 0 - 02187 dated 31
March 2021, in the amount of RUB 1,050,000.
- Having received these funds from Mertsa A.N. in the total amount of 1,050,000 roubles, Shpakov R.V.,
legitimate, as well as to create a belief in Merts A.N. that his money was profitably invested, R.V. Shpakov,
abusing Merts A.N.'s trust, as well as persons unaware of the criminal intent, persuaded him to sign
instruments, namely options, in accordance with which Merts A.N.'s funds in various amounts were
stole money belonging to Merts A.N. in the amount of 1,050,000 roubles, in an especially large amount.
namely:
351
and the ultimate goal of concluding such contracts was in fact the implementation of schematic operations
Naberezhnaya, 8, p. 1, as well as in unidentified places, acting in an organised group as part of a criminal
association, together and in concert, during an unspecified period of time, but no later than 16.03.2021. 1, as
information and telecommunication means of communication, misled Astakhov A.B. about their true
intentions - the thef of his funds, under the pretext of executing an order to conclude OTC option contracts
on the over - the - counter market, with no initial intention to execute the undertaken by them.
16.03.2021, at an unspecified time and place, arranged for Astakhov A.B. to sign an application for consent to
352
basis of which on 16.On 16.03.2021 Astakhov A.B. and "IC "QBF" LLC, named as a broker, concluded a
management.
- A.B. Astakhov, unaware of the crime being prepared and misled as to the true objectives of the participants of
account No. 40817810100010964118, opened with JSC "Tinkoff Bank", located at the address: 38A, 2nd
Khutorskaya str. Moscow, 2nd Khutorskaya St., 38A, page 26, to QBIF LLC's account No.
St., Moscow. 12 Spartakovskaya Street, Moscow, under Brokerage Services Agreement No. BO - F - N - 0 -
02055 dated 16.03.2021, namely: RUB 850,000 on 06.04.2021; RUB 300,000 on 30.04.2021, totaling RUB
1,150,000.
- Having received these funds from Astakhov A.B. in the total amount of 1,150,000 roubles, Shpakov R.V.,
as well as to create a belief in Astakhov A.B. that his money would be invested profitably, R.V. Shpakov,
abusing Astakhov A.B.'s trust, as well as persons unaware of the criminal intent, persuaded him to sign
instructions to a broker in order to conclude over - the - counter derivative transactions with derivative
financial instruments, namely options, in accordance with which Astakhov A.B.'s funds in various amounts
breach of trust, stole money belonging to Astakhov A.B. in the amount of 1,150,000 roubles, on a particularly
large scale.
namely:
353
for the provision of brokerage services, as well as to transfer their funds under these contracts to the trust
misled Popov P.V. about their true intentions - the thef of his funds, under the pretext of executing an order
to conclude over - the - counter option contracts on the OTC market, without initially intending to fulfil the
obligations undertaken by him.
354
an unspecified time and place, arranged for Popov P.V. to sign an application for consent to conclude a
on 13.10.10.2020 between Popov P.V. and "IC QBF" LLC, named as a broker, concluded a brokerage services
agreement convinced the latter to transfer his funds to them allegedly for trust management.
- Popov P.V., unaware of the crime being prepared and misled as to the true objectives of the participants of
account No. 40817810290011161531 opened with LLC "HCF Bank" (LLC "Home Credit and Finance Bank") -
the bank's head office at the address: Moscow, 8 Pravdy St., bld. 1 to the account of LLC "IKF Bank" (LLC
"Home Credit and Finance Bank"). 1, to IC QBF LLC account No. 40701810700003010998 opened with NSD
JSC ("National Settlement Depository") located at 12 Spartakovskaya Street, Moscow, under brokerage
services agreement No. BO - F - N - 0 - 00582 dated 13.10.2020, namely: 30.10.2020 in the amount of RUB
500,000, as well as in the period from 08.01.01.2021 - 30.04.2021 he made transfers of funds from his account
No. 40817810290011980631 opened with LLC "HCF Bank" (LLC "Home Credit and Finance Bank") - the main
office of the bank at the address: Moscow, Pravdy str. 8 bldg. 1, Pravdy St., Moscow, to QBIF LLC account No.
40701810700003010998 opened with NSD JSC located at 12 Spartakovskaya St., Moscow, under Brokerage
the amount of RUB 500,000, totalling RUB 4,100,000.
- Having received these funds from Popova P.V. in the total amount of 4,100,000 roubles, Shpakov R.V.,
as well as to create a belief in Popov P.V. that his money was being invested profitably, R.V. Shpakov,
abusing Popov P.V.'s trust, as well as persons unaware of the criminal intent, persuaded him to sign
instruments, namely options, in accordance with which Popov P.V.'s funds in various amounts were
from 30.10.2020 to 30.04.2021, stole funds belonging to Popov P.V. in the amount of 4,100,000 roubles, in an
355
namely:
356
information and telecommunication means of communication, misled Tregubov A.V. about their true
intentions - the thef of his funds, under the pretext of executing an order to conclude OTC option contracts
on the OTC market, without initially intending to execute the undertaken obligations.
23.03.2021, at an unspecified time and place, organised the signing with Tregubov A.V. of an application for
on the basis of which on 23.03.03.2021 between Tregubov A.V. and "IC "QBF" LLC, named as a broker,
pretext of fulfilment of the conditions of the said contract persuaded the latter to transfer his funds to them
- A.V. Tregubov, unaware of the crime being prepared and misled as to the true objectives of the participants of
account No. 40817810287060009530 opened with PJSC "Rosbank", located at the address: Moscow, Mashi
Poryvaeva str. 34, to QBIF LLC account No. 40701810700003010998 opened with NSD JSC ("National
500,000, totalling RUB 2,000,000.
- Having received these funds from A.V. Tregubova in the total amount of 2,000,000 roubles, R.V. Shpakov, V.S.
their own discretion in accordance with the criminal plan and in fulfilment of their joint criminal intent,
as well as to create a belief in Tregubov A.V. that his money would be invested profitably, Shpakov R.V.,
Golubev A.S., Rossieva E.A. and unidentified persons, abusing the confidence of Tregubov A.V., as well as
OTC derivative transactions, namely options, in accordance with which A.V. Tregubov's funds in various
amounts were transferred by QBIF LLC as a security payment to the accounts of the options seller, Q-BROKER
357
breach of trust, stole money belonging to Tregubov A.V. in the amount of 2,000,000 roubles, in an especially
large amount.
namely:
358
as part of a criminal association, together and in concert, during an unspecified period of time, but not later
than 08.02.2021, remotely, remotely, and also at unspecified places, acting in an organised group. 1, as well
as in unspecified places, acting as an organised group, as part of a criminal association, jointly and in
information and telecommunication means of communication, misled G.V. Mayorova about their true
intentions - the thef of her funds, under the pretext of executing an order to conclude over - the - counter
option contracts on the OTC market, without initially intending to execute the assumed obligations.
08.02.2021, at an unspecified time and place, organised the signing of an application for consent to conclude
a brokerage services agreement with IK QBF LLC (application for joining for individuals) with Mayorova G.V.,
on the basis of which on 08.02.02.2021 between Mayorova G.V. and "IC "QBF" LLC, named as a broker,
pretext of fulfilment of the conditions of the said contract persuaded the latter to transfer her funds to them
- G.V. Mayorova, unaware of the crime being prepared and misled as to the true objectives of the members of
the organised group - the thef of her money, convinced that her money would be returned afer fulfilling the
terms of the option agreement, in the period from 12.03.2021 to 25.05.2021 she transferred funds from her
account No. 40817810240018209765 opened with PJSC "Sberbank", located at the address: Moscow region,
Serpukhov, Lunacharskogo str. 33A, to IC QBF LLC's account No. 40701810700003010998 opened with NSD
JSC ("National Settlement Depository") located at 12 Spartakovskaya Street, Moscow, under Brokerage
230,000, 16.03.2021 in the amount of RUB 320,000, 12.04.2021 in the amount of RUB 200,000; 12.04.2021 in
100,000; 14.04.2021 in the amount of RUB 300,000; 16.04.2021 in the amount of RUB 333,333, 16.04.2021 in
the amount of RUB 150,000, and also made transfers of funds from its account No. 40817810640015794307
opened with PJSC "Sberbank", located at the address: Moscow region, Serpukhov, Lunacharskogo str. 33 A, to
IC QBF LLC's account No. 40701810700003010998 opened with NSD, located at 12 Spartakovskaya Street,
Moscow, under Brokerage Services Agreement No. BO - F - N - 0 - 01727 dated 08.02.2021, namely: 11.04.2021
300,000; 05.05.2021 in the amount of RUB 600,000; 07.05.2021 in the amount of RUB 200,000, as well as made
transfers of funds from her account No. 40817810209034000199 opened with PJSC VTB, located at the
address: Moscow region, Serpukhov, ul. 10A Krupskaya St., Serpukhov, to QBIF LLC's account No.
40701810700003010998 opened with NSD, located at 12 Spartakovskaya St., Moscow, under Brokerage
the amount of RUB 80,000; 05.05.2021 in the amount of RUB 100,000, totalling RUB 5,063,333.
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- Having received these funds from Mayorova G.V. in the total amount of 5,063,333 roubles, Shpakov R.V.,
option agreement, to pay and return the funds to the client.
legitimate, as well as to create a belief in Mayorova G.V. that her money would be profitably invested, R.V.
persons, abusing the confidence of Mayorova G.V., as well as persons unaware of the criminal intent,
persuaded her to sign instructions to a broker for the purpose of entering into OTC derivative transactions
with derivative financial instruments, namely options, in accordance with which the funds of Mayorova G.V. in
various amounts were transferred by IC QBF LLC as a security payment to the accounts of the options seller -
Q-BROKER LLC, affiliated with IC QBF LLC.
breach of trust, stole money belonging to Mayorova G.V. in the amount of 5,063,333 roubles, in an especially
large amount.
Thus, Pakhomov Vladimir Sergeevich committed fraud, i.e. theft of other people's property by
deception and abuse of trust, committed by a person using his ogicial position, by an organised
group, on a particularly large scale, i.e. the crime provided for by part 4 of article 159 of the
Criminal Code of the Russian Federation.
As a result, Pakhomov V.S. committed offences under part 3 of article 210, part 4 of article 159 of the Criminal Code of
the Russian Federation. (Vol. No. 333, pp. 37 - 236, Vol. No. 334, pp. 1 - 250, Vol. No. 335, pp. 1 - 146)
General evidence and their summary, confirming the guilt of Pakhomov V.S. in committing an
ogence under part 3 of article 210 and 151 of an ogence under part 4 of article 159 of the
Criminal Code of the Russian Federation:
- Testimony of Z.V. Munayev

- Testimony of Z.V. Munayev, given by him as a witness, suspect, accused (the criminal case on the accusation of Z.V.
Munayev of committing a crime under part 2 of article 210 of the Criminal Code of the Russian Federation and 50
crimes under part 4 of article 159 of the Criminal Code of the Russian Federation was separated on 15 April 2022 for
the completion of the preliminary investigation into a separate proceeding on the basis of p.4 According to which he
testified that in 2010, when he was a student at a financial academy, he received an invitation for a job on the Internet
from the website hh.ru, and then was interviewed for the position of financial adviser and was employed by Qubi
Finance Ltd. The interview was conducted by Arseny Rukhov. At that time Qubey Finance LLC had 5 - 6 sales
departments, a lot of employees and a high turnover of staff. The office was located at 24 Krasnaya Presnya Street,
Krasnaya Presnya, Moscow, in the Tropicana business centre. Many of the heads of sales departments were
acquaintances of R.V. Shpakov, reporting to him personally, and he (R.V. Shpakov) was one of the co - founders of the
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company, along with Sergey Lvovich Kuzin and Nikolai Mikhailovich Modin. The beneficiary of the company at that
time was Kuzin Sergey, who had 50 per cent or more of the authorised capital. R.V. Shpakov and N.M. Modin had the
remainder of the authorised capital in approximately equal shares. His (Z.V. Munaev) direct supervisor was Arseny
Rukhov and he (Z.V. Munaev) performed his duties, which included: receiving from A. Rukhov a client base for ringing,
making calls, telephone negotiations, holding meetings in the office of the company, concluding contracts, attracting
and further support of clients. Qubey Finance LLC was licensed by the Federal Financial Markets Service and carried
out activities in the securities market, mainly brokerage and trust management. In 2011 Cube Finance moved to a new
office - mixed - use complex "City of Capitals" at the following address: 8 Presnenskaya Naberezhnaya Street, Moscow,
building 1, 12th floor. During the year the system of work did not change, the staff increased and was regularly
renewed. He (Z.V. Munayeva) and some other colleagues, such as Vladimir Pakhomov, Avetis Vartanov, Maxim Yudin,
were promoted to the positions of sales department heads, and they all reported to R.V. Shpakov as head of the sales
office. In the same year 2011 cash turnover started, i.e. receiving and giving money to clients in cash. Transactions
with clients were very fast, withdrawal at that time took 1 - 2 weeks. As it was explained to them (employees), cash
turnover was carried out by Duntonse by direct bank transfer from the client's balance, as well as by collection
services when paying cash in the company's office. The cash was accumulated by Duntonse and delivered to the office
at the request of Shpakov R.V. Duntonse was associated with a Russian company, Freedom Finance, headed by Timur
Turlov. When receiving money from clients in cash, a receipt was made out on the Duntonse form or handwritten in
free form. In this receipt, the signatory on the Duntonse side was an ordinary employee of this company acting under
a power of attorney. On the side of Qubey Finance LLC, the signatories were R.V. Shpakov and Frolov. This activity was
not part of the standard activities of a professional securities market participant supervised by the Central Bank and
the FFMS and was not formalised in accordance with the Russian investment legislation in force at the time. In 2012,
the management of QB Finance (Shpakov, Kuzin, Modin) established QB CAPITAL CY LTD (Cyprus), which fully fulfilled
the role of Duntonse and replaced it in the process of servicing clients and transactions. As Duntonse was owned by
Timur Turlov, Shpakov paid Turlov T. for the services provided by his (Turlov T.) company Duntonse to QB Finance's
clients. In order to reduce costs and to consolidate financial flows under his management, a company "QB CAPITAL CY
LTD" was established. This company was acquired by QB Finance management from Cliffe Law Company under the
name Asheraxe LTD and Cliffe provided the first bank servicing this organisation, Piraeus Bank. Neither QB CAPITAL CY
LTD nor Duntonse had a licence to carry out brokerage or any other securities activity during their entire period of
operation, this was due to the licence held by the Russian entity QB Finance Ltd. The company "QB CAPITAL CY LTD"
was controlled by R.V. Shpakov and, as he subsequently learnt, R.V. Shpakov was its sole founder. Shpakov, Modin and
Kuzin also set up similar companies called "QB Financial Servicec QB" and "QB CAPITAL MANAGEMENT LTD", both in
the Republic of Cyprus. The organisation "QB Financial Servicec QB" was intended for the activity of a new branch in
Kiev under the management of Arseniy Rukhov. QB CAPITAL MANAGEMENT LTD was intended for non - Moscow clients
of the branch network in the territory of the Russian Federation. The general director of "QB CAPITAL MANAGEMENT
LTD" was appointed as "nominee". "QB Financial Servicec QB" and "QB CAPITAL MANAGEMENT LTD" were used to
sign contracts with clients, and client funds were attracted to the companies' bank accounts. Linda "led" these
companies and Shpakov R.V. These companies did not have any licences to deal with securities. The similarity in the
name was necessary to show that the companies belonged to the same group of companies. In 2013, Kuzin Sergey
and Modin Nikolay lef the founders of QBF LLC and their shares were bought out by Shpakov R.V. Around the same
year, QBF Asset Management LLC was founded by Shpakov R.V. alone. This company managed funds. In the same
year, the first CueBeef Real Estate fund was launched and formed, related to the construction of the Gribovsky Les LCD
in Odintsovo, where the developer was Simon Jesso LLC, affiliated to R.V. Shpakov, and which was sold by the sales
department of CueBeef Finance LLC as one of the group companies. In 2013. R.V. Shpakov, directly or with the help of
colleagues, became acquainted with NOA CIRCLE, a certified provider of corporate, legal and accounting services in
Cyprus, of which Linda and Apollo Athanasiadou were the representatives. On behalf of R.V. Shpakov, Vladimir
Pakhomov and Dmitry Lepeshkin travelled to Cyprus to negotiate with the above persons. "NOA CIRCLE" took over
the maintenance and servicing of all clients of "Duntonse" transferred to "QB CAPITAL CY LTD", "QB CAPITAL
MANAGEMENT LTD", "QB Financial Servicec" and new clients of "QB CAPITAL CY LTD", their financial operations,
maintenance of company accounts, submission of financial statements of the organisations. Bank - client, keys of
remote access were at Shpakov R.V. The system of work with clients in terms of non - cash and cash settlements
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remained the same. Subsequently, he (Z.V. Munayev) learnt that the clients' funds received in cash were not properly
entered into the settlement accounts of "Duntonse" and "QB CAPITAL CY LTD". The clients were provided with balance
reports, which reflected the full amount of the investment. Shpakov R.V. had in his assistants employees of Freedom
Finance and Duntonse, who generated and provided reports on QB CAPITAL CY LTD transactions and passed them to
Shpakov R.V. One of his assistants was Igor Klyushnev, who was aware of the interaction between Duntonse and QB
CAPITAL CY LTD, was not directly involved in the preparation of reports, but, according to Shpakov R.V., was related to
them. Maxim Povalishin, an employee, played a primary role in the preparation of the reports, and Igor Klushnev was
involved in their preparation. Both Povalishin and Klushnev ceased to have anything to do with the compilation of the
reports no later than 2018, as Simtelligence was already a company in 2019. Afer the liquidation of "QB CAPITAL CY
LTD" and the transfer of its rights and obligations to "SIMTELLIGENCE COMPANY LIMITED", the report writers remained
the same and the essence of the reports is the same. Afer their departure, from the point of view of the content of the
reports, R.V. Shpakov himself played a major role in their formation, and Linda Athanasiadou may have been aware of
it in some part. In terms of the form of the reports and their distribution, this was handled by Yuri Orlov, the IT
specialist. For some clients, the sales staff did the most detailed analysis of the reports, their content, the consistency
of positions and values with the real market data, also the change of these positions and prices through months and
years, the impact of each position on the change of the portfolio value and profit/loss of each client, and the
consistency of the behaviour of this portfolio with the real behaviour of the market and indices. Linda and Apollon
Athanasiades had many personal and professional connections in Cyprus, both in the financial sector, the law firm
and the regulator. Moreover, they had greater expertise and knowledge of the operating environment of local
jurisdiction companies in the international financial markets. In addition, Apollon Athanasiades is a relative of the
President of Cyprus (as of 2013 and afer). NOA provided full financial and legal support to R.V. Shpakov's Cypriot and
later other foreign companies, reporting to regulators and conducting audits. Apollo was the CEO of NOA, Linda was
also an employee (representative) of the company. Linda Athanasiadou also performed orders on behalf of R.V.
Shpakov in the banks servicing his company. Linda had the necessary keys, access to the "bank - client" of the
companies "QB CAPITAL CY LTD", "QB CAPITAL MANAGEMENT LTD", "QB Financial Servicec" for herself and other
persons, and other necessary documents to perform the actions assigned by R.V. Shpakov. According to Linda, when
making transfers, she always provided the banks with the client's contracts with both the Cypriot company and the
Russian licensed company to confirm the legality of the activity. As a result of an agreement between R.V. Shpakov
and Linda, QBF Investment (later renamed Constance) was established in 2014. Its founder was R.V. Shpakov, its head
(general director) was Linda Athanasiadou and she carried out all financial and economic activities of Constance.
Constance's financial operations were not related to those of Shpakov's previous companies, it was subject to
different terms and conditions, had different products and services, and attracted new clients, including Russian
clients. During this period, the Russian company's main focus was foreign markets. Two contracts were concluded
with the client: with a Russian organisation and with a foreign organisation. On the Russian side, the contract was
concluded with QB Finance LLC (since 2016 - QBIF LLC) - Asset Management Assignment (Trust Management
Agreement), or Consultancy Management Agreement; the second contract with the client - Agreement on Providing
Access to the International Securities Market, which was concluded on behalf of the foreign organisation (before 2013
it was Duntonse, afer 2013 - QB CAPITAL CY LTD). The funds were transferred directly under the second contract to the
settlement account of the organisation "Duntonse", opened in "Piraeus" bank in Cyprus. Then, the clients' funds were
transferred: in the case of "Duntonse" - to the accounts of the top brokers, in particular, other companies of the
"Freedom Finance" group, as well as "LEK Securities" and other brokers, and they already carried out operations on
the exchange trading accounts, and in the case of "QB CAPITAL CY LTD" - to the accounts of "Duntonse" and other
brokers. This whole scheme was signalled to the clients at the conclusion of the contract. Clients were given receipts
and cash receipts/expenditure vouchers from the foreign organisation with which the client had a contract.
Withdrawals were made to the clients' current accounts. The system of settlement with the client was as follows:
money was transferred directly from individuals and legal entities to the Duntonse account, then oral and written
orders were carried out, both from clients and portfolio managers of Kubi Finance under the direction of R.V. Shpakov
to execute transactions on trading accounts. Every month clients received reports from "Duntonse" on the results of
financial transactions and depending on their desire, could request either partial or full withdrawal of funds, or make
pre - investment. When clients' funds were transferred to the accounts of Duntonse and then QB Capital CY LTD, some
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portion was accurately channelled to the trading accounts of the top brokers and transactions were executed. Prior to
2015, a portion of more than 50 per cent of client funds was directed to the top brokers' accounts, and afer 2015, less
than 50 per cent was directed to the top brokers' accounts. However, the reports provided to the client included the
full amount invested (funds credited). A company with a licence (Qubey Finance, then IK QBF LLC) used foreign
trading accounts to make trading transactions with client funds. Securities, according to the agreement, were to be
purchased and registered by internal accounting for the client, with no confirmation of the trades executed, as the
pool was managed, i.e. the totality of accumulated client funds, internally divided into large trading strategies. In 2011
- 2014. Qubey Finance LLC provided clients with monthly reports that contained information on portfolio type,
asset/instrument mix, purchase price, quantity, month - end price, value of each position, margin lending level
(leverage), entries and withdrawals (amounts, dates), portfolio changes, and transitions from strategy to strategy. In
the case of Duntonse, the responsible officer was also identified. These reports were the only source of information.
The reporting period varied, as did the frequency of distribution. In QBF, the reporting period was a month. The report
was sent electronically in "PDF" format to clients' mailboxes, as a rule, every 10th day of the month following the end
of the previous reporting period (month). The company had clients both for "Advisory brokerage" service (the client
gave an order to buy and sell; the manager did not have the rights to make transactions independently, but executed
the client's order) and for "Trust management" service (the manager independently made transactions according to
the agreement signed by the client and the declaration specifying the main criteria, strategies and possible
limitations). Most of the company's clients in the international market had contracts of the second type, "trust
management". In the case of advisory management contracts, the client gave a transaction order electronically (scan
of the document signed by the client) for each transaction, or gave the order "by voice" by calling a special telephone
number with a record of the conversation: the client identifies himself, says in full the type of transaction and the
instruments he needs. The securities and each specific position on the stock exchange are purchased in the name of
the company "QB CAPITAL CY LTD". The balances in the reports to the clients of the international market did not
correspond to the real amounts that R.V. Shpakov actually sent to the accounts of the respective clients in "QB
CAPITAL CY LTD", the top brokers. Thus, the incoming balance in the reports was only formally indicated. In the period
around 2015, Shpakov R.V. had a "hole" in his total funds of all clients, i.e. he (Shpakov R.V.) lost part of the company's
funds on stock exchange transactions, but at the time did not disclose this in client reports to hide losses and not to
cause an outflow of funds, deterioration of reputation, threat to the whole business. R.V. Shpakov substituted in his
reports unprofitable positions actually bought by him on the stock exchange with other stock exchange positions with
neutral - positive trading (financial) result for the company and clients. Many attracted clients were paid their own
and "earned" funds at the expense of other clients' funds. At the same time, the clients attracted in the period since
2015, QBF LLC (QBF IK) offered yields already lower than in previous periods, more than 2 - 3 times lower, tariffs were
increased, the product line was increased, marketing materials were improved. Thus, he and many employees carried
out relevant and important at that time work on the company's struggle with the difficult market situation, but these
actions did not lead to the desired favourable result, as it turned out that on the part of Roman Shpakov there was a
misuse of clients' money, i.e. Roman Shpakov used depositors' money for his own enrichment. Also the circumstances
of 2015 and aferwards led Shpakov to the fact that he used for settlements with some clients the funds of other,
newly attracted clients, which only aggravated the difficult situation in the company and in the market. If the clients'
funds had been placed on segregated (separate) accounts and there had been timely control over them by the
regulator, the risk of misuse of newly received clients' funds would have been much less. Both he (Z.V. Munayev) and
many employees during the long years of the company's operation asked R.V. Shpakov questions concerning the
company's activity, system of functioning, including the system of settlements with clients, and the company's profit.
Most of the questions found reasonable answers, but they could not get full and meaningful answers. The team was
especially concerned about this in the period from 2015, when the first serious shifs in the timing of settlements with
clients began. At the same time, Shpakov R.V. as a manager always stopped excessive questions and interest in the
internal activities of the company, always saying that the client in the end, although with a long period of time, but
receives money in full, and many and most with a profit that exceeds the level of competitors' offers, which justified
his approach to such activities. Duntonse and QB CAPITAL CY LTD did not have their own licences but used third party
licences held by QB Finance Ltd. QB Finance Ltd. did not accept client funds itself. In addition, Duntonse and QB
CAPITAL CY LTD did not have separate client accounts, which increased the risk and opportunities for the account
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manager to use client funds both in favour of clients and making better deals on the stock exchange, and in his own
interests. He knows about the activities of QB Capital CY LTD that it was a shareholder of QB Capital Real Estate Fund
or QB Capital Regional Real Estate Fund and is listed in the register of owners in the Management Company. The
presence of "QB Capital CY LTD" Clients of one of the positions in their reports of units of ZPIF "Real Estate" indicates
that "QB Capital CY LTD" should have used a part of the funds accepted from the Clients to purchase a share in the
said Fund for further channelling the funds to the Developer in the construction project. The clients are not provided
with the confirmation of the acquisition of the fund units either from "QB Capital CY LTD" or from QBF Asset
Management. Since the rights and obligations of "QB Capital CY LTD" were transferred to "Simtelligence Company
Limited" in full, Simtelligence Company Limited had the right of claim to the funds of MC "QB Asset Management"
within the framework of the funds actually transferred to the Fund from "QB Capital CY LTD". Since the transfers were
not made in full, the reports sent to the clients did not correspond to the actually purchased positions (purchased
shares in the Fund). The units purchased by the company "QB Capital CY LTD" are registered in the fund only for it, the
Fund does not re - register them to the clients of "QB Capital CY LTD", this assignment of rights should have been
carried out by the internal accounting of "QB Capital CY LTD". Decisions on the amount of funds transfer within each
of the products of "QB Capital CY LTD" to specific instruments were made directly by R.V. Shpakov based on the
conditions and restrictions of the Fund. It would have been much easier for R.V. Shpakov to withdraw or otherwise
withdraw funds from foreign accounts controlled by him and transfer them directly to construction projects using
controlled developers and builders. However, even if the full amount of the required funds were directed to the
relevant Real Estate Funds, this product did not have a mandatory cash and interest payment term, but rather had
target yields and a 100% risk of cash loss like any other investment product. Therefore, the Fund's obligations to the
Units, as well as to QB Capital CY LTD and Simtelligence Company Limited, do not constitute a guaranteed payment of
corpus and interest. All Client monies transferred to "QB Capital CY LTD" and "Simtelligence Company Limited",
regardless of the portfolio positions, contractual terms and conditions and other legal aspects, will not be returned to
the clients, as this decision can be made directly only by R.V. Shpakov, and all funds were appropriated unilaterally by
him. In 2014, he (Z.V. Munaev) was appointed to the position of Head of Sales Department of Moscow, and Vladimir
Pakhomov was sent to St. Petersburg to open the first regional branch, while still listed in Qubi Finance LLC. In the
same year, he (Z.V. Munaev) and Pakhomov, only the two of them, were assigned (transferred) shares in Qubey
Finance LLC by R.V. Shpakov for 6 per cent each, but he (Z.V. Munaev) never received dividends from them. During the
time period from 2012 to 2014, the timeframe for withdrawal of clients' funds from Cyprus increased to 1 - 1.5 months.
Since 2014, many banks, including Piraeus Bank, have made the requirements for transactions more complicated and
aggravated. In addition, due to the new requirements for funds received from the territory of the Russian Federation,
the period of their verification for the source of origin, the source of the client's income, and the client's identity has
increased. In 2015, both the set of documents required for deposit and withdrawal of funds and the withdrawal terms
increased for the clients of Qubi Finance LLC. R.V. Shpakov and Linda initially provided the employees with a greatly
expanded list of documents required from clients for withdrawal of funds, but in fact most of the documents from this
list did not represent a set of documents actually required by the bank. For example, the bank did not need a diploma
of education, certificate of military duty, proof of residence and other documents from the above extended list. In
reality, banks required the following documents: source of origin of funds, source of income, certificate of no criminal
record, letter of recommendation from the bank/lawyer/advocate. The list of documents for withdrawal of funds was
artificially extended by R.V. Shpakov to increase the timeframe for withdrawal of funds and the possibility of using
these funds for a longer period of time. Since 2015, the terms of withdrawal of clients' funds from Cyprus increased to
1.5 - 3 months. At the same time "QB CAPITAL CY LTD" ceased to be serviced in the banks of Cyprus. From 2015 to
2018, the number of construction projects increased by raising customer funds. The branch network increased
strongly, as well as the number of complaints and dissatisfied customers regarding the withholding of funds due to
them under their contracts. Also, due to the circumstances, employee dissatisfaction with management and the
situation increased and the working climate deteriorated. The employees had fears and fears of the continuation of
the organisation's activities with clients and the impossibility of paying the latter money. Due to unsatisfactory, in R.V.
Shpakov's opinion, sales results, he (Z.V. Munaev) was removed from the position of sales manager. Vladimir
Pakhomov was appointed to this position and became sales manager for both Moscow and St. Petersburg. In 2018,
the liquidation of "QB CAPITAL CY LTD" began. Following complaints from citizens to the Central Bank and Cyprus, the
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question arose to check the activities of QB CAPITAL CY LTD, an affiliate of QB Finance Group, in Cyprus. Linda and
Apollon Athanasiades, Shpakov Roman were afraid of full disclosure of the data of the owners of the Cypriot
companies, their affiliation with "QB Finance", account providers, financial transactions due to the fact that they were
illegal on the territory of Cyprus, which Linda emphasised and explained that in the territory of the Russian
Federation it would be presented as a financial pyramid scheme. In order to prevent these events there was a change
in all corporate documents of the founders, management from R.V. Shpakov to his (Z.V. Munayev) name. Linda
Athanasiadou provided him (Z.V. Munayev) with these documents, drawn up "backdated" for his signature. During the
same period, in order not to disclose the affiliation of the organisations, he was removed from the founders of IK QBF
LLC (renamed from QBF LLC in 2016 - 2017). He was told by R.V. Shpakov and Linda Athanasiadou that two
organisations would be set up to continue settlements with clients and prevent the company from reneging on its
obligations to them (clients). As soon as possible, two companies were set up, namely: "SIMTELLIGENCE" (Hong
Kong), "WHITE LAKE MANAGEMENT LTD" (Cayman Islands). Settlements with former clients QB CAPITAL CY LTD and
Duntonse continued, as well as the attraction of new clients using these organisations and the procedure of re -
signing the contracts of "old" clients to new contracts with SIMTELLIGENCE COMPANY LIMITED and WHITE LAKE
MANAGEMENT. SIMTELLIGENCE COMPANY LIMITED was owned by Linda's partner and mate Mike Christofi, he is a
citizen of the Republic of Cyprus who was living in Hong Kong. When the liquidation of "QB Capital CY LTD" was on the
agenda, Linda looked for a new company and jurisdiction, and by criteria known only to her and Apollo, Hong Kong
was chosen, where Mike had a friendly owned almost "empty" company. Linda acquired it in 2018 in favour of R.V.
Shpakov and "Simtelligence Company Limited" took over the rights and obligations of "QB Capital CY LTD" and
continued to carry on its previous activities. "Simtelligence Company Limited did not have any licences to carry out
securities activities. The regulator did not have any complaints about the legality of the company's activities. The
accounts and funds of the company were managed by Linda Athanasiadou and R.V. Shpakov, similar to "QB Capital CY
LTD". The only thing that has changed is the combination of unlicensed and licensed companies: instead of the
licensed QB Capital CY LTD, the licensed White Lake Management Ltd took the place of the licensed company.
Sometimes a third company, VL Consulting LLC, was added to this bundle. Its role served only as a communication
link for the correct legal transfer of information between the Russian Federation and foreign jurisdictions. VL
Consulting LLC did not have a securities licence. Settlements and cash transactions in this bundle were handled
directly by Simtelligence Company Limited, as was QB Capital CY LTD in the previous bundle. "Simtelligence Company
Limited" accepted clients' funds into its accounts, afer which it was understood that the funds would be directed to
the accounts of the top brokers and "White Lake Management Ltd" as a licensed entity. At least this was discussed as
"QB Capital CY LTD" was liquidated as a procedure for new companies and jurisdictions. Afer the account of
"Simtelligence Company Limited" was opened in AMERIA - Bank (Armenia) with his (Z.V. Munayev) participation, the
first funds of this company were credited to it (the account) because it had just taken over the activities of "QB Capital
CY LTD". His participation was necessary because he (Z.V. Munayev) was the last signatory of "QB Capital CY LTD".) was
the last signatory of "QB Capital CY LTD", was the only one who was able to explain the transfer of activities to
"Simtelligence Company Limited", the legality of the activities, the former connection with "Qubi Finance" LLC, as
well as in person (which was mandatory) to go through the standard banking procedures for opening a non - resident
account. Subsequently, according to Linda, his involvement was no longer necessary, either with this Bank or others.
He did not open any further accounts for Simtelligence Company Limited. White Lake Management Ltd, was set up
from scratch in the Cayman Islands and Linda and her team then ensured that the company went through the
necessary procedures to obtain a licence. The company had a director by the name of Paul, a Cayman Island national
who was also accountable to the regulator. Paul was found and appointed as a director by Linda Athanasiadou. When
Linda was in the Moscow office, he (Z.V. Munaev) saw their telephone conferences in the conference room on several
occasions. "White Lake Management Ltd" had the ability as a broker/manager to accept funds directly into their
accounts and trade them independently with the necessary access and terminal. The sales staff was interested in
attracting clients to the licensed company, and therefore sales started at "White Lake Management Ltd", but due to
the late stage of its establishment and development, it attracted about 1 - 2 dozens of new clients. "White Lake
Management Ltd" also had 1 - 2 bank accounts and "White Lake Management Ltd" was also a management
company/broker for clients of "Simtelligence Company Limited". It was in conjunction with it that the clients of
Simtelligence Company Limited could access international markets. Although, it was also direct transactions from
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Simtelligence Company Limited to FFin Bs and possibly to other companies and Brokers. In fact, the operations of
"White Lake Management Ltd" were managed by R.V. Shpakov and Linda, and they also had access to the accounts.
"White Lake Management Ltd" was set up to distribute cash flows similar to the earlier example of "QB Capital CY
LTD", "QB CAPITAL MANAGEMENT LTD" and "QB Financial Servicec QB". "WLM LTD" was to take only cash client
payments, transfer them and issue them back to the client. The linkage of the work of "WLM LTD" was also with
"White Lake Management Ltd". The jurisdiction of "WLM LTD" was the Cayman Islands and it was entered into 2019 -
2020, it was managed by the same persons - Linda and Shpakov R.V. The director of the company was a nominee.
Externally, the procedure for concluding contracts and cash flow should have been identical, but whether the actual
crediting of funds to the company's accounts was carried out he does not know, just as he does not know. The
similarity of the name was to make the clients understand that the company belonged to a group of companies,
which included "White Lake Management Ltd" and "VL Consulting" Ltd. WLM LTD did not have a securities licence.
Initially it was brought to the attention of the employees that the banks used by the brokers were necessary for
further transfer of funds to the accounts of the top brokers. The brokers of "QB Capital CY LTD", and at the time of
liquidation of "QB Capital CY LTD" (QCCI), should have had no problems with accepting client funds, because,
according to Linda's words, the transfers were accompanied by documents attached to them both by "QB Capital CY
LTD" and the Russian licensed LLC "Qubey Finance", in connection with which this bundle of companies ensured the
legality of sending and crediting the funds to their destination. The accounts of R.V. Shpakov's foreign companies in
foreign banks were opened by Linda Athanasiadou. Additional legal support could be provided by Apollo
Athanasiadou . Opening of accounts at different periods of time could be both remote and with personal visit of Linda
and possibly other employees. QB Capital CY LTD" and "Simtelligence Company Limited" had accounts in the
following banks: Piraeus Bank (Cyprus), CDB Bank (Cyprus), Verso Bank, Atlas Bank (probably Montenegro), Ameria
Bank (Armenia), Bank in the Republic of Vanuatu (can't remember the name), NHSBC Bank (Hong Kong). He (Z.V.
Munayev) was personally involved in opening accounts in Ameria Bank (Armenia) because he was a signatory in the
liquidation of "QB Capital CY LTD". An account was also opened in the same bank for Simtelligence Company Limited.
Linda had acquaintances among the top management of Ameria Bank. Linda received regular payments from R.V.
Shpakov for banking and legal support. With his participation in the liquidation of "QB Capital CY LTD", only a package
of corporate documents of "QB Capital CY LTD" was signed, which he did not read carefully enough. He did not sign
any documents on closing or other actions on the bank accounts of the company and was not notified about them. He
(Z.V. Munaev) assumes that his personal data and his signature afer signing that liquidation kit could have been used
by R.V. Shpakov and Linda Athanasiadou in other corporate documents of "QB Capital CY LTD" and "Simtelligence
Company Limited" in other jurisdictions, including the banks mentioned by him. This is due to the fact that Linda and
R.V. Shpakov were very much afraid of disclosure of information on R.V. Shpakov during the liquidation of "QB Capital
CY LTD" due to the existence of requests of the Central Bank of the Russian Federation in Russia at that time and
distribution of these requests among banks abroad. He (Z.V. Munayev) has no information about the accounts of "QB
Capital CY LTD" being closed, their cash balances and has never had it. At the closing of "QB Capital CY LTD" the funds
from its bank accounts were transferred to the accounts of "Simtelligence Company Limited", as the liquidation
procedure itself, in order to be legal, did not imply bankruptcy of the company and zeroing out/withdrawal of debts,
but transfer of rights and obligations from "QB Capital CY LTD" to "Simtelligence Company Limited". Around 2018 -
2019, the Cypriot regulator CySEC began to receive enquiries from the Central Bank of Cyprus regarding the related
activities of QB Capital CY LTD and QB CAPITAL CY LTD. At that time Linda was very concerned about possible
difficulties for the companies she was accompanying. On behalf of R.V. Shpakov, Linda travelled to the regulator,
including negotiations with the head of the regulator to eliminate possible risks for the companies. Linda
Athanasiadou was a qualified professional in the Republic of Cyprus, had many connections in the local financial
market, was a confidant of many Cypriot businessmen and other influential persons, had friendly relations with the
staff of the Cyprus regulator. At the same time, NOA was assigned to support R.V. Shpakov's companies.
"SIMTELLIGENCE COMPANY LIMITED" and "White Lake Management", Linda Athanasiadou had the necessary keys,
access to the "bank - client" and these companies. In addition to the previously mentioned companies and services,
the interaction between R.V. Shpakov and Linda was reflected in the creation of such funds as "Purity", "Falco". The
said funds were created by Linda, approximately in 2018, with the financing of Roman Shpakov. The management of
these funds, their financial and economic activities were carried out by Linda and R.V. Shpakov. Also, in approximately
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2019, Linda through her connections introduced into the perimeter of work (attracted) Shpakov R.V.'s companies the
company "Argento...". - an organisation for the creation and management of structured products, operating in
conjunction with Magento and Societe Generale Bank. R.V. Shpakov began to include securities of this company in
client portfolios. The assignment of rights from "SIMTELLIGENCE COMPANY LIMITED" and "WHITE LAKE
MANAGEMENT LTD" to RIF (Rent Investment Fund) real estate funds was initiated by R.V. Shpakov as the second big
stage of transferring/resigning a significant part of clients to long - term and transparent products. At the first stage
this second stage was not planned, but started to be realised later. Almost all clients were offered to buy fund units,
and the justification was the same as before the re - signing of contracts: tougher regulation, difficulty of interaction
between Russia and foreign counterparties, complexity, paperwork, cost, time, language barriers, and many other
reasons. The organiser of the procedure of the second re - signing was the same executor - Linda Athanasiadou .
Probably, in the Russian part, Yaroslava Smirnova and Evgeniya Rossieva were involved in the registration of units or
relations with other objects (construction as an investment object). The company "LAMERA HOLDINGS LIMITED" was
found by Linda. Some nominee or a person appointed by Linda signed the documents on behalf of the company. The
value of a unit when it is sold in a primary formed and established fund, where there are no owners (fund) yet, is
determined on the basis of an appraiser's report and relevant standard appraisal procedures strictly regulated by the
Management Company and the Central Bank of the Russian Federation. The sale of RIF units to new (including
"oversubscribed") clients was not like this, i.e. it was not a primary sale. The initial owner of the first units afer all the
necessary procedures was one of R.V. Shpakov's companies, most likely LLC Q.Broker. Further sale of the company's
units is carried out at the market price, not on the basis of the appraiser's report and market procedures, as the price
is set by the seller - the company Shpakov R.V. Thus, the market value of the sale of units from the company to the
client was determined by the willingness of the seller in terms of the assigned price and appropriate bargaining. The
intention of the employees during the period of their high activity in sales and re - signings for the purchase of units of
the real estate fund "RIF" was based on the desire to settle accounts with clients and make a transparent withdrawal
of their funds from foreign companies to the Russian jurisdiction, as this, including in the work both in general within
the company and with clients, fell under the concept of "withdrawal of funds", and "LAMERA HOLDINGS LIMITED" was
needed to document the wiring from abroad to the Russian fund. The fact that the clients had units was the closure of
the obligations of the previous companies to the clients: both SIMTELLIGENCE COMPANY LIMITED and QB CAPITAL CY
LTD made a full settlement of the last balances in the reports, the previous contractual relations ended and new ones
began with clear transparent conditions and with a real investment object. One of the objects was a real income -
generating warehouse (probably warehouses) for logistics and other companies, this object brought rent income, was
inside the RIF fund. This income was to be paid to the shareholders. The original owner of the warehouses received
payment from the sale of shares in them, a cash payment as part of the transaction with R.V. Shpakov, most likely at a
value equal to or close to the appraiser's report of the given value of the object. The further sale value of the fund
units to the client was determined by R.V. Shpakov. There were no other market benchmarks, and the difference with
the initial amount paid by the appraiser was the company's "margin". The final sale price, although it had a clear set
bar and range from Shpakov R.V., had a bargaining zone, the presence of which depended on the initiative of the
buyer as a normal standard sale transaction. The sales staff had their own commission from sales and could not
always communicate the possibility of bargaining and other conditions to the customers. The management company
MC QBF Asset Management was responsible for the execution of the assignment agreement in the Russian part and
crediting the units to the clients' names. In the foreign part, Linda Athanasiadou and her foreign team were
responsible for the process of bringing the Russian part from the side of SIMTELLIGENCE COMPANY LIMITED and
LAMERA HOLDINGS LIMITED. Perhaps one of the employees, Kirill Olezhko, was involved in some process. Olezhko
was involved in some corporate correspondence with the Moscow office staff. If even 50 per cent of SIMTELLIGENCE
COMPANY LIMITED's obligations to Clients were transferred under assignment agreements into units, SIMTELLIGENCE
COMPANY LIMITED would be liquidated. In 2019, another area of activity for QBIF, LLC, was the provision of services
through over - the - counter auction contracts (OTC) for IPOs and other transactions. This service was provided by IK
QBEF LLC, directly accepting funds from clients in accordance with its licences. By signing an accession agreement,
the client entered into a brokerage service agreement with IK QBEF LLC and transferred money from its current
account to the company's current account opened with Alfa - Bank, Sberbank, NSD and other payment organisations.
Clients were provided with a separate brokerage account (segregated) with a corresponding balance of funds
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belonging to them. Further, the Client submitted an order on his behalf to enter into an OTC option contract (OOC)
with Q-BROKER LLC, a company owned by R.V. Shpakov, where he was the CEO for the transaction (bet) he was
interested in. As part of the brokerage account services, including transactions concluded with Q-BROKER LLC, the
client submitted an order for each new transaction on his own behalf and thereby expressed his desire and agreed to
its terms. All clients had the basic information contained in the Framework Contract (agreement), where general,
including legislative and regulatory, concepts were formulated. This order was submitted to IC QBF LLC, and IC QBF
LLC, represented by its General Director S.A. Matyukhin, entered into this agreement with Q-BROKER LLC on behalf
and at the expense of the client. Clients joined it and sent orders for each new IPO with its specific terms and
conditions in the calculation of the financial result (win rate). The fact of submitting an order from the client's side
was accompanied by the transfer of funds from LLC IC QBF to the settlement account of LLC Q.Broker. The funds were
transferred from the Client's brokerage account to the brokerage account of Q-BROKER LLC opened in the same
organisation - IC QBF LLC. Further the funds from Q-BROKER LLC were channelled in accordance with the submitted
client orders for execution of IPO and other transactions. The IPO transactions were executed jointly with Constance
Investment (formerly Constance) as the foreign broker of Q-BROKER LLC. Clients' funds were transferred from the
settlement account of "Q.Broker" LLC to the settlement account of "Constance Investment" in Cyprus and further,
from "Constance Investment" were sent to the top brokers for execution of transactions. Almost all participants of the
Russian financial market have IPO contracts of this type, which are settlement rather than delivery contracts, i.e. the
option at its end provides the client with a monetary financial result in the form of profit or loss on each specific
transaction, rather than the delivery of securities on the IPO transaction for which the application was submitted.
According to this example, in IC QBF LLC, the VODs were settlement VODs; at the conclusion of the contract, Clients
were notified of the type of profit or loss in monetary terms, without delivery of securities to their brokerage accounts.
The IPO securities themselves were received by Constance Investment as a foreign broker and depositary for this type
of transactions. Sales of IPO ADSs were made by the sales staff of the sales department to their client bases. Contracts
could be concluded both in the company's office and remotely via certified sofware and State Services (ESIA). This
algorithm is uniform for customers throughout the Russian Federation. In accordance with the terms of the IOU, the
company has no obligation to send funds to specific details, as the terms of the option is a bet between the client and
the market in accordance with the bet he makes on this contract. The important thing for him is the final financial
result. Accordingly, the company has no legal or other restrictions on the channelling of funds and their use. These
conditions are uniform for all brokers both in Russia and abroad. The participants in the financial chain of
transactions for the IPO WOD were: 1. Accounting department represented by Ekaterina Gramza (personal treasurer of
R.V. Shpakov and supervisor of financial distribution in the jurisdiction of the Russian Federation); 2. Licensed broker
represented by Stanislav Matyukhin, General Director of QBIF LLC, who was responsible for all professional activities
of the company on the Russian market; 3. Intermediary Company - Q-BROKER LLC represented by its owner and
General Director R.V. Shpakov; 4.1 Foreign broker "Constance Investment" represented by Director Linda
Athanasiadou, or 4.2. Companies - other, including for non - purpose areas of expenditure and related companies, of
which only the participants of the financial chain, i.e. Shpakov R.V., Gramza, Matyukhin S.A., and Linda Athanasiadou
in case of foreign transfers and transactions, were known about. The termination of this chain by clause 4.2 was not
unlawful, but this option of passing their money was not voiced to the clients. The necessary and statutory end of the
entire financial chain of the IPO WOD is the receipt of funds by the clients with profit or loss in accordance with the
terms of their contracts. In this case, due to financial management errors and managerial decisions of R.V. Shpakov,
the clients faced the fact that they were unable to receive funds on their brokerage accounts and previously submitted
orders for IPO IOUs and other IOUs. Thus, R.V. Shpakov by means of decisions on actions of p.4.2, directed funds in his
own interests and at his own discretion, thereby misleading both the company's employees and clients in terms of the
direction of the use of funds, did not ensure the return of withdrawn funds to the brokerage accounts of clients,
violated the terms of the concluded IOUs in terms of final settlements under these contracts, jeopardised the entire
activity of the company and clients. R.V. Shpakov organised attraction of clients through more favourable IPO rates,
access to more companies, better conditions for IPO entry, allocation and IPO exit. The standard negotiation
methodology of IK QBF LLC, as well as any other financial company, does not include the description of the whole
legal and financial chain of trade deals, as the client came to receive the finished service and results. Thus, in the
process of negotiations only curious and persistent clients sought information about top brokers, legal terms,
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contract terms for specific IPOs, etc., while most of the clients were not explained. QBIF LLC had IOUs for relevant
products and services of related companies such as Purity, Argento... " whose activities were managed by Linda
Athanasiadou. Client funds received by QBIF LLC were channelled through Q-BROKER LLC through the financial chain
to these funds and products - "Purity", "Argento...". The clients' funds transferred to Purity through Q-BROKER LLC
were partially or fully returned to the clients, while for Argento..., due to the long maturity of these securities held and
registered with NSD's depository, the funds were not returned due to the fact that the maturity date had not occurred,
but due to the actions taken and being taken by R.V. Shpakov to dispose of these funds. Most of the clients of trust
management services on the Russian stock market received their funds in the appropriate amount, as the company
made many transactions on the Moscow and St. Petersburg stock exchanges with quoted securities in accordance
with the standards of client service conditions and the practice of Russian investment companies. Other transactions
for which funds were channelled from Q-BROKER LLC were the purchase of Argento Access Sarl securities registered
with NSD. As far as Argento Access Sarl securities are concerned, although they are issued by a certified Issuer and are
registered with NSD, they are not trustworthy, liquid and meet the expected interests of clients, i.e. the money was
transferred to this company in the interests of R. Shpakov.V. with the help of Linda Athanasiadou with the intention of
not returning this money to the clients; transfer to the accounts of LLC "Management Company QBF" and its mutual
funds, including ZPIFs for the construction projects of Shpakov R.V., i.e. at the expense of attracted clients' funds the
clients' funds were invested in the construction projects of R.V. Shpakov through the shell funds; transferred to the
accounts of construction companies LLC "M1 Development", LLC "Simon Jesso" (Developer), LLC "SeverSpecStroy"
(Developer), and other companies related to the construction projects of R.V. Shpakov, the names of which he does
not know. All construction activities of R.V. Shpakov in Severodvinsk were managed by his mother Irina Nikolaevna
Shpakova. Also I.N. Shpakova managed financial operations of all construction projects in Severodvinsk and
supervised the work of the Russian accounting department of LLC IC QBF - all accountants, financial operations,
payments of the companies related and controlled by R.V. Shpakov; transfers to the accounts of JSC QBF Group (the
company that owns 100 per cent of the shares of LLC IC QBF and LLC MC QBF). This company, among other things,
entered into promissory notes with clients to accept money from them for loans at interest. The Company could also
make direct settlements with certain clients and employees in respect of financial obligations, such as refunds,
salaries, payments with counterparties for core and other activities; withdrawal of money to the accounts of R.V.
Shpakov and his affiliated companies. and companies affiliated with him, such as LLC 168 Kvartal, LLC 701, LLC 702,
LLC 776, LLC Ver - Mont, LLC Vysota, LLC KG, LLC K - Investment, LLC K - Consulting, LLC KF Estate SPB, LLC Cusisiai,
LLC Finbutik, LLC Indep Smart, LLC RentInvest, LLC Synthesis, LLC F - Management, LLC F - Technologies, LLC F -
Experts, PJSC CEF, JSC RIF and others. Thus, in order for the entire business to function and be in the best interests of
the clients, the cash had to be transferred back to Q-BROKER LLC at a profit or loss, and further transferred to the
clients to their brokerage accounts at QBIF LLC in the appropriate amount and result. At the end of each ICO, the
funds must be automatically credited to the accounts of QBIF LLC and its clients, while the withdrawal of funds to
clients' current accounts from QBIF LLC is the result of an order submitted by the client for the amount of the
brokerage account balance. Financial instruments that do not meet the criterion of liquidity, recoverability, sufficient
collateral for repayment were the largest financial investments of IC QBF LLC and Q-BROKER LLC, such as: - VODs; -
units of construction ZPIFs; - securities of Argento Access Sarl. Entering into transactions with these financial
instruments is not a good faith practice and is not acting in the best interests of the client. Having reliable information
about these instruments and directions of their use, clients would definitely refuse to purchase them, whereas in our
case R.V. Shpakov organised a system of their (clients') attraction with a pre - existing intention to use the funds in his
own interests and not to return them to their owners. It was a scheme of misleading on his part and obtaining clients'
money by fraudulent means. Despite the fact that the whole chain of cash flow from the client to exchange or other
unknown transactions was legal, the system of work outlined earlier is still illegal in its final link - R.V. Shpakov's
decision not to pay money back to clients and return it to their accounts. Stanislav Matyukhin performed some of the
operations of withdrawing (cashing out) funds from the accounts of QBIF LLC and some QBIF Group companies on
behalf of R.V. Shpakov. S.A. Matyukhin received financial orders for transfers from R.V. Shpakov for investment and
related business, while Ekaterina Gramza carried out orders from R.V. Shpakov for other companies not related to
investment business, but she made transfers for Q-BROKER LLC. The cash received by the employees of QBIF LLC from
clients under the concluded agreements on provision of direct access to international stock markets was accepted
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both in the offices of the company and at off - site meetings with clients. For the most part, this took place in the office
of IC QBF LLC. Cash was accepted by the company's employees, who were instructed that this was a standard and
legal procedure and that the funds were credited to the clients' foreign accounts within the Company's general
account. Cash from customers was accepted at all times by all hired employees without restriction, with the
authorisation of the immediate supervisor, as prior notification was required for a separate meeting room and cash
counting equipment (counting machine). Accepted cash was lef in the cash room in a safe. Then the head of the
department to which the client belongs, or the head of the department at the end of the working day of the office
reported to R.V. Shpakov about the amount of received funds. The statistics collected for all department heads at the
end of the day was sent to Shpakov R.V. by the head of the sales department in correspondence. Shpakov R.V. then
instructed to bring the money to him personally in his office or to one of the employees of the sales department who
was in the office afer the end of the working day, or to one of his trusted employees of non - selling departments or
assistants. In case R.V. Shpakov was absent from the office, he (R.V. Shpakov) instructed that the money be brought to
him (Z.V. Munayev during his tenure as head of the sales department) so that he (Z.V. Munayev), having waited for R.V.
Shpakov, transferred this money to him (R.V. Shpakov) for further transfer abroad or in case of counter cash flows
(from abroad to Russia/from Russia to abroad) by means of netting, he would disburse funds on his orders, including
but not limited to the following: salaries of sales and non - sales employees, commissions and bonuses of sales and
non - sales employees, office and other related expenses, disbursement of clients' funds on behalf of R.V. Shpakov
(returns on orders from R.V. Shpakov).V. (returns on withdrawal orders), personal orders of Shpakov R.V. to one of his
employees. Sometimes he (R.V. Shpakov) asked to give part of the money to persons unknown to the employees. Part
of the money received from clients by Shpakov R.V. was sent by him to the relevant "supervisors" in the Central Bank
of Russia and government agencies to prevent negative consequences in relation to the company QBIF LLC. The
procedure described above was common to both the Moscow office and the branches, except for the following
differences known to him: consolidation of funds from the branches generally took place in the St. Petersburg office
through business trips of employees from the branches to St. Petersburg, or business trips of employees of the St.
Petersburg office or Pakhomov V.S. personally to the branches. At the request of R.V. Shpakov, V.S. Pakhomov
encashed funds from all branches of QBF LLC, namely the branches in Tyumen, Yekaterinburg, Kaliningrad, Ufa and
St. Petersburg, with varying frequency. The decision to make payments in the Moscow office was made personally by
R.V. Shpakov, while for the branches the decision on the cash consolidated in St. Petersburg was made by V.S.
Pakhomov and R.V. Shpakov, with Shpakov's final approval. Due to Shpakov R.V.'s direct presence in the Moscow
office, all major decisions, including financial decisions, were made by him personally, and the managers in Moscow
did not have such extensive powers, while for the branches, due to Shpakov R.V.'s remoteness from these offices and
lack of personal immersion in their daily activities, the powers of the head of the branch network, Pakhomov V.S.,
were much wider and he was more independent, although he coordinated the most important issues with Shpakov
R.V., and also necessarily fulfilled his instructions. Money from St. Petersburg was transported from St. Petersburg to
Moscow to Shpakov R.V. personally by Pakhomov V.S. at the request of Shpakov R.V. without any clear periodicity.
Such "encashment" was absent in the branches due to personal business trips of branch employees to St. Petersburg,
and was only in Moscow, which was mentioned by Shpakov R.V. when he organised the work. The procedure for
transferring funds collected from Moscow and the branches from employees on behalf of Shpakov R.V. to visiting
persons unknown to the employees was called by Shpakov R.V. "encashment". In accordance with the lists of clients'
applications for withdrawal transmitted from the Moscow and branch sales departments, Shpakov R.V., based on the
cash received, made decisions on the withdrawal of a part of the clients from the lists of cash for withdrawal on his
behalf. In the remaining part of the withdrawals were carried out both by bringing so - called "encashment" cash
received from foreign trading accounts and by direct non - cash transfers to clients. Receipt of money from customers
was accompanied by the issuance of documents: a receipt to a cash receipt order or a receipt for receipt of money. Not
all the money received from clients was transferred to their respective accounts. Mutual settlements of cash from the
company's offices and non - cash withdrawals from trading accounts from abroad, as stated by R.V. Shpakov, did not
always take place. The cash received should have matched the amount declared to be withdrawn from the foreign
trading account, so that the cash would not have to be transferred, but could be taken into account immediately for
settlement on the spot (in banking and brokerage terminology this is called "clearing of payments"). Since about
2015, without any systematic regularity in terms of terms, amounts or participants in the process, R.V. Shpakov gave
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orders to the company's employees, whom he himself chose, to accept funds to their accounts from him (R.V.
Shpakov) or his companies to withdraw and make payments, which were initially known to him (R.V. Shpakov)
personally, and later, as the company's organisational structure grew, part of the payments were known to him (Z.R.
Munayev) and other heads of structural divisions. The funds were transferred to the accounts of employees (he was
sometimes among them), most ofen under loan agreements. In fact, neither he nor other employees transferred the
money back. The contracts were drafed by Ekaterina Gramza. These contracts were actually signed, they knew that
these were corporate funds of R.V. Shpakov, and since the withdrawals were made through normal banking
transactions within available banking limits and bank laundering checks, the employees almost never had additional
questions. Moreover, some of the funds were actually due to some of the employees as salary from Shpakov R.V. or
bonuses. Also, due to frequent salary delays and very severe delays in commissions and bonuses afer 2015,
employees always reacted adequately and positively to Shpakov R.V.'s instruction to transfer funds to employees'
accounts for withdrawal and disbursement to the sales department for salaries. Most of the salaries and bonuses
were given "in an envelope" by one of the employees who was in charge of the technical issuance of envelopes. This
employee was Kristina Bogdanova, a former secretary, a young girl unfamiliar with financial activities and much that
went on in the company. The money could have been transferred to her by one of the employees, and possibly
personally by Shpakov R.V. This system of payments was practised in the company in order to save money, to avoid
taxation (the UST tax was not paid in full). Subsequently, closer to the liquidation of "QB CAPITAL CY LTD", when
difficulties in settlements with clients were very noticeable, such transfers to the accounts of employees from R.V.
Shpakov to withdraw cash to the company, including contained payments to clients of these employees, as clients
were in a long wait for cash. Shpakov R.V. used them as employees for this purpose in order to save on infrastructure
costs and withdrawal transfers, Shpakov R.V. could ask for a cash withdrawal from an employee several times a year.
These were transfers both from R.V. Shpakov as an individual and from companies controlled by him: JSC FG, KG LLC;
possibly from Gramza's personal account, and also, from the accounts of Q-BROKER LLC. In all the years of QBF's
operation, such cash - out procedures involved, as a rule, heads of sales departments and heads of sales
departments, including both Moscow and branches. Despite the fact that there was a turnover of employees even at
the level of heads of departments, nevertheless, even a new manager could be involved in such procedures some
time afer his appointment. As a rule, for him it was a direct order from the Company's CEO or passed on through the
heads of sales departments (his, Spinka, Pakhomov, Golubev, Korzh, other persons), so it was not objectionable. Of
the employees known to him who took part in cashing money for R.V. Shpakov: Avetis Vartanov, Maxim Yudin, Nikita
Selivanov, Nikolay Padalko, Dmitry Kipa, Alexander Zaitsev, Ara Balayan, Ruslan Spinka, Andrey Korzh, Vladimir
Pakhomov, him (Z.V. Munayev), Alexey Golubev, Vladislav Plitin, Vladimir Maslennikov, Pavel Dzhumamuratov.
Everything was formalised with loans that were not initially physically signed, but were signed later. "Alfa Bank" and
"Sberbank" were the most common banks from whose accounts transfers were made to employees' personal
accounts. The Banks sometimes had questions, normal banking questions, which were exhausted when Gramza
provided the contracts. The withdrawn money was handed over by the employees personally to R.V. Shpakov, it could
also be handed over to him (Z.V. Munayev) in his (R.V. Shpakov's) absence or employment for subsequent handover to
the latter. The money could also be handed over to one of the department heads in view of Shpakov R.V.'s absence, to
him or Spinka in the office. Temporarily, the money could have been transferred to and held by Spinka as one of the
heads of the sales department. Shpakov R.V. kept the transferred cash in his office, in his nightstand. The loans were a
documentary cover, while this was an illegal cash - in. The original origin of the money could not be known to any of
the employees of the Moscow office, with the exception of Ekaterina Gramza, it was in some part client funds, not
corporate funds belonging to R.V. Shpakov, and not his personal funds. Vladimir Pakhomov, head of the branch
network, and Alexei Golubev, head of the St. Petersburg office, were also involved in the cash - out. Vladimir
Pakhomov organised the cashing of funds by employees of the St. Petersburg office, while Alexey Golubev was aware
of this system. In addition, there were cases of clients depositing money with the aim of obtaining services of access
to the international stock market for the purpose of investing in brokerage services at QBIF LLC, while the contracts
and relevant agreements were concluded on behalf of the employees of QBIF LLC who accompanied these clients and
were signed by them. This was done by private agreement between the client and the employee when the clients did
not want their identity and data in connection with the investment of funds to become known to anyone, as well as in
order to ensure that there was no documentary evidence of this particular way of using the funds. With the
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development of cryptocurrency transactions both in the world and in Russia, R.V. Shpakov repeatedly took an interest
in such transactions. Shpakov R.V. had some attempts of transactions in cryptocurrency both for his own speculative
purposes and in terms of operations for clients in the period of about 2016 - 2017, but they were not successful or
were not properly developed. He knows about this from the words of Shpakov R.V. The second continuation of
operations with cryptocurrencies was approximately in 2019, it concerned the interaction between Shpakov R.V.,
Linda and banks and brokers servicing Shpakov's foreign operations, capable of independently converting or
transferring funds (US dollars and Euros) into cryptocurrency. From the words of R.V. Shpakov and Linda, he (Z.V.
Munayev.) is aware that due to the transition from "QB Capital CY LTD" to "Simtelligence Company Limited" and
"White Lake LTD", some of the operations on earlier clients of "QB Capital CY LTD" were hampered, not all the Banks
properly accepted the client's set of documents and Linda's documents on "QB Finance" - "QB Capital CY LTD"
bundle, therefore, at some point, by their decision, cryptocurrency transactions allowed abroad were connected for
some settlements in some part. That is, it was a part of settlements between the moment of sending funds from the
Bank servicing "Simtelligence Company Limited" and the moment of receiving funds by the client in non - cash and
cash form. He (Z.V. Munayev) does not know the details of the transfers, their belonging to the clients, other
participants and executors on the part of R.V. Shpakov. However, the receipt of funds in cash in the office was still
accompanied by the arrival of unknown people with cash, and to receive them Shpakov R.V. sent someone from the
staff or received them personally. Pavel Vlasov may have more information than other employees, as he (P. Vlasov)
was ofen the employee to whom Shpakov R.V. instructed to collect the cash. Also, LLC IC QB&Ef and Vostochny Bank
developed a scheme of interaction and implementation of investment programmes through the bank - sale of trust
management services (hereinafer - TM) on individual investment accounts (hereinafer - IIS) of LLC IC QB&Ef to clients
of Vostochny Bank, which began in about 2019. The employee of the company responsible for this direction was
Renat Amerov - Director for work with partners and counterparties. He hired him (R. Amerov) around that time in
2019, because afer his (Z.V. Munaev) removal from the position of Director of Sales Department, he was interested in
new directions, as he was afraid for his place in the company, and financial situation. He and Renat considered
different categories of partners, both financial and non - financial, to create a joint product with them and offer it
through their sales networks. Financial categories - the most promising of these were banks, for obvious reasons.
During the year of his work Renat went round many banks, big and small, and in some meetings he (Z.V. Munayev)
participated as well. One of these banks was Vostochny Bank. At that time they were doing very well selling
investment insurance for a long term, from 3 - 5 years, where the Bank received a commission of about 20 per cent. On
the Bank's agenda was the issue of launching trust management partners. Bank Vostochny considered options of
partners - BCS, their (IK QBF LLC) and ITA Capital. As a result, all three companies were admitted to sales at different
periods of time. QBIF Ltd. had an agency agreement with Bank Vostochny, with a commission to the bank of about 10
per cent, and sold the Vostochny IIS DM product "Stable Growth", with a term of 5 years, but the actual term of the
product was unlimited, until full withdrawal of the client's funds. Renat hired additional employees - coaches, who
organised sales with the employees of the territorial offices of Vostochny Bank, located all over the country, it was
about 500 offices, among which about one third was allocated to the coaching company. Each coach had a list of
assigned cities and offices, the employees of which had the product of QBIF Ltd. in their "showcase" of sales among
other products. The task of the coach together with the bank employee was to ensure the planned sales volume and
the necessary commission income for the bank. Under this product, the client concludes an agreement with QBIF Ltd.
at a bank branch by means of an electronic digital signature (EDS), immediately transfers money to the company's
investment account, thus becoming an active client for servicing. His funds are placed in exchange - traded securities
and over - the - counter financial instruments by the decision of the portfolio manager and the Investment
Committee. The Investment Committee determines the strategy, permissible limits, conditions and restrictions. The
CEO and risk manager of the company (respectively Stanislav Matyukhin and Georgiy Dandov) have direct influence
on the decision. For the most important decisions for approvals, Renat and he (Z.V. Munayev) approached R.V.
Shpakov with regard to the organisation of sales and coaching work, while Stanislav, Georgiy and other employees - in
their part. Initially, the strategy configuration contained only stock exchange instruments, and the funds were fully
allocated to the Moscow stock exchange. Employees received timely remuneration for this product, Vostochny Bank
received timely commissions, and Clients received the necessary returns. Due to the fact that these were fully liquid
funds and traded on the Moscow Exchange, Clients could withdraw the entire amount at any time, net of commissions
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paid, and with the earned yield by submitting an application through a bank branch or remotely electronically directly
to the company to the bank details - an account opened with Bank Vostochny. In such configuration the product
worked for a long time, about half a year - a year. Then by the end of this period, due to a new tender in Vostochny
Bank for the selection of a company - provider of investment services, sales were stopped, and QBIF Ltd. continued to
serve the previously accumulated pool of clients. The bank demanded new product configurations with increased
commission and conclusion via an option contract (structured note). This roughly coincided with the launch of IPO
services via OTC option contracts. Through long coordination and personal meetings with the Bank's management,
R.V. Shpakov proposed a new configuration of a structured product for Vostochny Bank with the use of OODs for 5
years with an annual yield of approximately 10 - 20 per cent (non - guaranteed) and the conclusion of an IIS via OTC
(Brokerage). The launch of sales was successful but did not last long. At the same time sales were going on at BCS and
Aitiay Capital, Shpakov R.V. lamented the financial additional arrangements of these companies with the
management of Bank Vostochny. A few months afer the second launch, in 2020, the bank disconnected QBIF from
sales unilaterally. The coaching department was engaged in servicing old clients, some clients were transferred to the
Sales Department. With the development of sales of IPO VOD at some point in time, R.V. Shpakov decided to include
VOD as a tool in the strategy of trust management of both clients of the Sales Department of Moscow and branches, as
well as agent networks and partners, in particular, the bank "Vostochny". He does not know in what configuration and
in what volumes (limits) and to whom these assignments were addressed, he learnt about the fact itself when the
company's employees, in particular, the sales department and coaches, started contacting him with questions about
the meaning of these option agreements. Having collected the questions, they sent them to R.V. Shpakov and through
joint discussion with him received answers satisfactory to them, related to the increased profitability for clients of
these option agreements, not so long term and the possibility of redemption of some of these option agreements by
the company at the personal decision of the management, namely R.V. Shpakov, without losses for clients. The
number of such option agreements could amount to dozens, if not hundreds, of contracts concluded within the
framework of trust management services. Thus, the decision to include the options in the sales of Vostochny Bank's
MA was made not at the time of the direct sale of these products and receipt of client funds to the company's
accounts, but much later, through the decision of R.V. Shpakov with the approval of the officials of IC QBF LLC. When
the client concluded a Trust Management Agreement (TM) with IC QBF LLC through Vostochny Bank, the following
documents were executed: IIS Trust Agreement (signed between the Client and LLC IC QB&Ef), with client funds being
sent directly from LLC IC QB&Ef to the Moscow Exchange. When at a certain point in time, by decision of R.V. Shpakov,
the following documents were also signed for each ICO: - an instruction (signed between IC QBF LLC and Q-BROKER
LLC); - a contract (signed between IC QBF LLC and Q-BROKER LLC). When the client concluded the Brokerage Service
Agreement (BO) with IC QBF LLC through Vostochny Bank, the following documents were executed: - BO IIS contract
(signed between the Client and IC QBF LLC); - an instruction (signed between the Client and IC QBF LLC; this
instruction was given once for the entire contract amount, which was equal to the contract amount); - a contract
(signed between the Client and Q-BROKER LLC). At the end of 2017. - early 2018, an on - site inspection as part of a
working group of the Central Bank of Russia (CBR) began at the office of QBIF LLC to check all investment activities of
the organisation as a professional participant on the securities market. As he later learnt, R.V. Shpakov had an
acquaintance in the Central Bank of the Russian Federation. He (R.V. Shpakov) informed him (Z.V. Munayev) about it in
the office of the company in his office during a conversation immediately afer the beginning of the inspection of the
Central Bank of Russia. This acquaintance was, according to R.V. Shpakov, Deputy Chairman of the Central Bank of
Russia Skobelkin, who supervised currency control activities. During the same conversation, R.V. Shpakov showed
him (Z.V. Munayev) the website of the Central Bank of the Russian Federation, where in the structure of the
management he pointed to the page with the profile data of this employee, with information about his position.
Further, in the course of communication with R.V. Shpakov, he informed him (Z.V. Munayev) that this support of the
activity of the company LLC IC QBEF by Skobelkin is carried out on a regular and reimbursable basis. Periodically,
namely monthly, afer making settlements in the office of the company, Shpakov R.V. instructed him (Munayev Z.V.) to
transfer to him (Shpakov R.V.) an amount of 50 - 80 thousand US dollars with the comment "For our friends" in the
context of verification activities of the Central Bank of the Russian Federation. On this basis, he concluded that these
funds were intended to be transferred by R.V. Shpakov to R.V. Skobelkin as a reward for the latter's support of the
company's activities and to minimise the negative consequences of the verification measures. The audit by the CBR
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working group lasted approximately half a year. During the same period there were cross enquiries from the CBR not
only to QB IC QF LLC, but also in Cyprus to the local regulator on the related activities of QB CAPITAL CY LTD on the
subject of investment of funds of Russian citizens attracted on the territory of the Russian Federation in the office of
QB IC QF LLC, using QB CAPITAL CY LTD and its bank accounts. The funds to be transferred to Skobelkin through QB
CAPITAL CY LTD and its bank accounts were transferred both by R.V. Shpakov personally and on behalf of R.V. Shpakov
through V.S. Pakhomov (repeatedly). The transfer of funds to Skobelkin began immediately afer the start of the CBR
audit, was carried out monthly, usually from the 15th to the 25th day of the month, and continued afer the end of the
CBR audit until May 2021. This contact, namely acquaintance of Shpakov R.V. with Skobelkin, appeared to Shpakov
R.V. through his uncle Pakhomov V.S. He knows about it both from Shpakov R.V. and from Pakhomov V.S. Also in his
(Munayevu Z.V.) presence there was a conversation between Pakhomov V.S. and Shpakov R.V., from which it became
known that one of the managers of the Central Bank of Russia, surnamed Shvetsov, had long been dissatisfied with
the activities of IK QBF LLC, and was looking for an opportunity to suspend the company's activities, such an
opportunity was the audit that began in late 2017 - early 2018. The inclusion of another employee of the Central Bank
of Russia, surnamed Chistyukhin, in this situation, among other things, made it possible to prevent negative
consequences for the activities of IK QBF LLC. As he (Z.V. Munayev) understood from the context of the conversation
between R.V. Shpakov and V.S. Pakhomov, Chistyukhin interceded for the company at the "request" of Skobelkin or
the security officers of the Central Bank of Russia. During the time period of approximately November 2020 to January
2021, a meeting between V.S. Pakhomov and CBR employee(s) took place in the area of Neglinnaya Street, Moscow,
during which they discussed an increase in the amount of the regular monthly remuneration due to the emerging new
and aggravating circumstances of QBIF LLC. He learned about this meeting, afer its conclusion, from Pakhomov V.S.
during a conversation in which he (Munaev Z.V.), Pakhomov V.S. and Shpakov R.V. took part.) directly interacted with
during his work in the company can explain the following: Stanislav Matyukhin, General Director of QBIF LLC, was
responsible for all of the company's activities in the Russian market, its operational activities, coordinated marketing
materials, scripts (dialogue templates) for sales, contracts, tariffs, implemented the necessary sofware, was
responsible to the regulator and other supervisory structures. S.A. Matyukhin was responsible for the entire Russian
part of the business, and was aware of the directions and amounts in which client funds from QBIF LLC were
channelled. S.A. Matyukhin also coordinated with sales managers the methods (scripts) of negotiations with clients
and the information communicated by financial advisors to clients. The information communicated to clients by
financial advisors agreed with S.A. Matyukhin, mainly related to the terms of service and proposed trade deals, did
not cover much of the legal and financial components, did not contain complete information on transfers to the
companies involved in the service; Pakhomov Vladimir started working at Qubey Finance LLC (since 2011. QF LLC,
since 2016 QBIF LLC) in 2010 in sales with a junior position as a financial advisor in Moscow, then within 1 - 2 years was
promoted by R.V. Shpakov to the position of the head of one of the six sales departments of the Moscow office of QF
LLC. Around 2013. V.S. Pakhomov was sent on a business trip to St. Petersburg to open a new office there and was
appointed by R.V. Shpakov to head this new office with accommodation in St. Petersburg. V.S. Pakhomov was fully
responsible for all activities of this office, at that time almost on a par with the powers that R.V. Shpakov had over the
Moscow office, namely: recruitment and training of employees, determination of salary, development of sales policy,
negotiation techniques, training materials and memos, templates for telephone conversations and meetings with
clients, handling objections, as well as development of marketing strategy and implementation of expenses, solving
issues of rent and possible relocation to new offices. Pakhomov V.S. directly conducted meetings with clients, showed
by his example various negotiation techniques, set standards for employees on key parameters of efficiency of the
regional sales department, determined the amount of remuneration for financial advisors, marketing specialists, IT -
employees, regional lawyers and accountants. V.S. Pakhomov opened all regional offices of the company in the cities
of Yekaterinburg, Kaliningrad, Tyumen, Ufa and Murmansk. Since about 2014. V.S. Pakhomov was the director of the
entire branch network of QBIF LLC and had full authority over it on a par with those mentioned above in relation to
the St. Petersburg office. His main task was to attract clients and ensure the activity of the regional sales department,
which was based in St. Petersburg. All the offices of the company were managed by V.S. Pakhomov from St.
Petersburg. In his activities Pakhomov V.S. was subordinate only to Shpakov R.V., and in his (Pakhomov V.S.)
subordination were the heads of all client offices of regional cities and their subordinate employees. V.S. Pakhomov
was subsequently employed by LLC KF Estate SPB, JSC FG, JSC QBF, and possibly other companies. Pakhomov V.S.,
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received remuneration from sales in the form of a percentage of the volume of attracted funds (a percentage of newly
received funds - as a standard motivation model in sales on the financial market, as well as a percentage of the
accumulated portfolio depending on the results of the plan fulfilment). All persons involved in sales, including V.S.
Pakhomov, had the system of motivation and payment from sales specified in agency contracts rather than in labour
contracts. Both salaries and interest on sales were paid to them as employees in cash. Some of the money paid to the
employees, namely most of the interest on sales, was not paid officially. As a rule, salaries were paid to employees
once a month, usually in the middle of the month, and interest on sales was paid once a month, at the end of the
month. Employees employed by accountable licensed companies were paid twice a month (advance and repayment).
For him (Z.V. Munayev) and V.S. Pakhomov, around 2014, the system was changed to an average percentage of the
accumulated fixed client portfolio in ruble terms, accrued monthly. They were also promised dividends from the
profits of Qubey Finance Ltd. Pakhomov V.S., afer he (Munayev Z.V.) was detained in May 2021 and a measure of
restraint in the form of imprisonment was chosen against him, he knew from the corporate lawyers who accompanied
him that Pakhomov V.S. continued to work at QBIF LLC or at one of the related companies with Shpakov R.V. under his
direct supervision. Despite their strained relationship in 2019 - 2020, Despite their strained relationship in 2019 - 2020
related to Shpakov R.V.'s work with government agencies and not the smoothest resolution of issues, in 2021 their
(Shpakov and Pakhomov's) relationship strengthened and became very close due to a new criminal case and
detentions of employees in May 2021. organised the activities of the Moscow office and branches "on the ground",
receiving instructions from R.V. Shpakov by telephone and other means of communication, and organised the
distribution of finances, the work and instruction of employees and their interaction with clients, in order to obtain
the greatest benefits for himself and R.V. Shpakov, both in their position and status in the criminal case and in terms of
money. Ekaterina Gramza got a job at Qubey Finance LLC around 2013 - 2014 in one of the initial positions - in the
administrative department as a secretary or file clerk. At some point in time, R.V. Shpakov had a need to expand the
finance department, and at the same time during this period he (R.V. Shpakov) developed a close trusting relationship
with Ekaterina Gramza, in connection with which she was transferred to the position of junior accountant at Qubey
Finance LLC. At first she helped with a number of issues, then she was appointed to the position of accountant with
her own function and authority, and this was no earlier than 2015 and no later than 2018. Gramza E. made payments
and entries both in licensed companies (not alone, as these companies had accountants reporting to the regulator)
and in related companies of Shpakov R.V. involved in financial flows, e.g. Q-BROKER LLC, FG JSC,QBF JSC (despite the
fact that these organisations may have had other persons as accountants). Almost all of Shpakov R.V.'s corporate and
personal payment orders were made through Ekaterina Gramza. The full list of transactions made by her was
unknown to anyone, as many of them concerned personal payments of Shpakov R.V., however, due to the trust in
Shpakova I.N., her competence in accounting and supervision of the entire accounting department of Shpakov R.V.'s
companies, Ekaterina Gramza coordinated and approved with Shpakova I.N. part of the issues of making payments,
reporting on them, as well as the company's reporting to the tax inspection and regulator.V. was 100 per cent, while
Shpakova I.N. may have owned 60 - 70 per cent of all financial information, which included full coverage of corporate
payments and bookkeeping, but may not have included personal payments and orders from Shpakova R.V. Shpakova
I.N., residing in Severodvinsk, flew to Moscow and stayed there, appearing in the office from several days to 1 - 2
weeks. The frequency of her visits to Moscow was once every 1 - 3 months. I.N. Shpakova became involved in the
management of financial flows from about 2015 - 2016. Shpakova I.N. did not have access to personal accounts, she
did not need them, while Ekaterina Gramza had access to a number of personal accounts of the company. Shpakova
I.N. is the mother of Shpakova R.V. She is an accountant/financier by competence and speciality. I.N. Shpakova started
to take part in the company's affairs around 2014, when the construction of the first residential buildings in
Severodvinsk, where she permanently resides, began. The construction of residential properties in this city began
with the launch of the QBIF Regional Real Estate fund through QBIF Asset Management LLC and the client money
attracted there, as well as the bank credit line obtained on this basis. R.V. Shpakov entrusted her with full financial and
organisational management of construction in this city. Afer 2015, with the emergence of financial difficulties in
payments to clients and delays in salaries and remuneration of the company's employees, she began to take part in
the work of the entire accounting department of Shpakov R.V.'s Russian companies. Shpakova I.N. supervised the
hiring of accounting staff, organised their work, supported the creation of company reports to the tax authorities and
regulators, supported the processing of certain significant and document - intensive payments, supervised responses
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to requests and instructions from the tax authorities and regulators, took part in the preparation of the company's
financial statements, participated in the preparation of the company's financial and organisational management. A.V.
Sorokin, the husband of I.N. Shpakova, and D.V. Sorokin (brother of A.V. Sorokin) were trustees of R.V. Shpakov and I.N.
Shpakova in relation to construction projects of R.V. Shpakov in Severodvinsk. With the help of these persons R.V.
Shpakov organised the possession of the construction objects, the procedures of various registration, reporting,
payments related to these construction objects. The Sorokin brothers have permanent residence in the Arkhangelsk
region and represent the interests of R.V. Shpakov there, fulfilling his instructions. Timur Turlov is an old
acquaintance, friend and partner of R.V. Shpakov, with whom the latter started to organise his business. Shpakov R.V.'s
financial transactions involved Duntonse and then the Freedom Finance Group, including but not limited to FFin Bs
(Belize), an organisation owned by Timur Turlov. These entities were involved in accepting client money from Qubey
Finance LLC and coagulating some or all of the client money raised in their accounts. The first of these companies,
Duntonse, started working with R.V. Shpakov in 2010: its accounts were recommended by the sales department staff
to be used by clients to send funds directly (opened in Cyprus). Subsequently, when "QB Capital CY LTD" appeared,
client funds were sent from it to "Duntonse" and then later to "FFin Bs" (Belize). According to R.V. Shpakov, he and
Timur had agreements. Timur had a financial participation and a share of remuneration due to him from the total
turnover of client money attracted to Timur's company accounts. During the period of direct referrals to Duntonse,
this remuneration was higher. Then, during the initial attraction to "QB Capital CY LTD" and transfer to Timur's
companies, his remuneration became lower, as Shpakov R.V. undertook the main part of risks on initial payments. At
the same time, he (Munaev Z.V.) is convinced that Shpakov and Turlov's companies carried out operations with the
attracted funds not fully in accordance with the interests of clients, but primarily based on their own interests and
intentions in appropriating part of client funds. Decisions made on the disposal of clients' funds with "QB Capital CY
LTD", "Duntonse", "FFin Bs" (Belize) could not have been made without joint and complete agreement between
Shpakov and Turlov, as the foreign counterparties hired by them were responsible for ensuring the work of these
organisations. Timur Turlov also facilitated non - cash and cash payments to R.V. Shpakov and his companies, as well
as to his offices. Some of the non - cash funds were transferred by Timur to accounts controlled by Shpakov R.V., in
particular, he knows of several such payments to Kubi Finance LLC. But the main interest of R.V. Shpakov in receiving
funds from Timur Turlov was in cash. In addition to the fact that Freedom Finance itself accepted and issued cash in
its offices, sometimes, according to R.V. Shpakov, with receipts signed personally by Timur Turlov, the latter assisted
R.V. Shpakov in withdrawing non - cash funds from foreign and Russian accounts, converting them into cash,
delivering them at the request of R.V. Shpakov to him personally or to his office for further processing. Many
employees, and he (Z.V. Munayev) among others, considered this delivery as a collection service, which may have
been some of the funds, but later Shpakov R.V. himself ofen told high - ranking employees that Timur Turlov had
helped him obtain these funds. With the beginning of IPO sales by QBIF LLC, the relationship between Shpakov R.V.
and Turlov T. was outwardly more competitive, and more recently their (Shpakov's and Turlov's) relationship and
financial interactions have been equal and identical to where they originally started. Based on the large amount of
client funds previously raised and transactions on them together with Timur Turlov, as it turned out, the latter was the
only (apart from Linda Athanasiadou ) reliable person for Shpakov R.V. who could provide custody of the remaining
client funds at Shpakov R.V.'s disposal. The previously accumulated funds in Turlov's accounts could have allowed
Shpakov R.V. to dispose of them at his discretion and in agreement with Timur, even in the face of a federal and
international manhunt, since these funds and the accounts controlled by Timur are located in foreign jurisdictions
with complex ownership structures, where the relationship of these funds to Shpakov R.V. may not be obvious at this
time. Moreover, R.V. Shpakov may use the situation with the criminal case to put pressure on Timur with various
arguments in his favour in order to threaten him with criminal prosecution for earlier transactions if he is caught or if
Turlov does not assist him in general. Alexey Golubev started working for QBF Group in St. Petersburg around 2013 -
2015 and was employed by either QBF Finance LLC or QF Estate SPB LLC, started as a financial advisor, then was
promoted to head of department, then to head of office in St. Petersburg. In management positions he (A.S. Golubev)
organised sales, recruitment of employees and their training, non - material motivation system (trips, strengthening
of corporate spirit). Under A.S. Golubev's leadership, sales of QBF products to clients were carried out by financial
advisors. A.S. Golubev was responsible for the fulfilment of the sales plan, set sales plans for subordinate employees,
determined key indicators, the effectiveness of their activities, such as the number of calls, appointments, meetings
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held, contracts signed, the number of clients attracted for the month. At different periods of time, both Pakhomov V.S.
and Golubev A.S. were signatories to the Agreements in the St. Petersburg offices and other branches. When new
branches were opened in the Russian Federation, the St. Petersburg manager, most likely Pakhomov V.S., acted as a
signatory on behalf of QBIF LLC, and then, when the manager of the new office passed his probationary period and
confirmed his position, he (Pakhomov V.S.) appointed Golubev A.S. as a direct signatory. The management of the
branch offices, their opening, organisation of their work and sales were carried out from the St. Petersburg office
directly by Pakhomov V.S. Pakhomov V.S. had a power of attorney from the General Director of LLC IC QB&EF to sign
client agreements on behalf of the company, as well as other business agreements (before 2017 - on behalf of the
General Director of LLC IC QB&EF Frolov V.G., afer 2017. - on behalf of Matyukhin S.). On the instructions and orders of
V.S. Pakhomov and R.V. Shpakov, the General Director of IC QBF LLC issued powers of attorney to other persons to sign
client agreements. Office managers mostly communicated with Pakhomov V.S., and with Shpakov R.V. only in urgent
corporate matters, and mainly during corporate trips, training and other team - building events. Evgenia Rossieva
joined QBF Group afer 2016. E.A. Rossieva's direct supervisor was R.V. Shpakov and supervised her activities and the
activities of the entire division. There were several areas of activity of the Legal Department: corporate, licence
activities, legal proceedings. E.A. Rossieva and other lawyers did not have a power of attorney to sign on behalf of the
company. Eugenia personally recruited employees in the legal department. She also organised the work of the
employees, their workload, connection to certain corporate tasks, interaction with other departments and
employees. Related departments, both selling and non - selling, ofen turned to Evgenia and her staff for their
direction, confirmation/acceptance from the legal department where necessary, in disputes and conflict situations
both internally and with external counterparties. His interaction with Eugenia was regular, on sales department
issues, employee and client issues on company contracts (labour, agency, client, partner). In the area of sales and
interaction with employees, he could give her direct assignments within his competence, and she made decisions to
participate within her workload and in coordination with her manager Shpakov R.V. Also, interaction with her and her
department was carried out on the side of the branch network, as a rule, on issues of the sales department, its
employees and clients. In addition to the Russian part supervised by Evgenia, the interaction with her was carried out
by Linda on the foreign part, and Evgenia received instructions from her to create documents and bring them into
compliance with Russian legislation so that they did not violate the law. Evgenia was at the intersection of the Russian
and foreign legal parts, but she did not make decisions in the foreign part, and received input on the system of work,
regulations, procedures, norms mostly from Linda, and less or very little from Apollo Athanasiadou. She also hired
employees - "nominees" for the role of signatories through Shpakov R.V.'s contractors, as Shpakov R.V. had created a
large number of companies in the perimeter, and did not want to entrust certain issues to the hired staff - signatories,
and instructed to hire external "nominees" for this purpose, so that his orders would be carried out unconditionally.
Due to the fact that R.V. Shpakov was the beneficiary of the licensed companies of the QBF group of companies, as
well as the General Director of JSC FG QBF, the parent company of the group, he was subject to certain restrictions
from the regulator and other inspection authorities in terms of combining positions, combining activities of the
companies of his "formal" group of companies, and other companies related to him through "nominees". This applied
to both the Russian part and the foreign part. For example, on the foreign part at a certain moment the will of the
nominee for the company "QB Capital CY LTD" was made by him (Z.V. Munayev) due to the fact that Linda approved
that R.V. Shpakov for the liquidation of this company could not be directly connected with it. Rossieva E.A. assesses
her closeness to R.V. Shpakov as rather tight, as he (R.V. Shpakov) brought her up to speed and gave her instructions
both on a wide and rather narrow range of issues concerning him personally. E.A. Rossieva's awareness was quite
high. E.A. Rossieva was paid a monthly fixed remuneration of not less than 100,000 roubles and annual and quarterly
bonuses based on her performance. During his work in the company he was aware that the heads of branches of LLC
IC QBIF in the process of work, communication with clients, management of subordinates and processes,
organisation of conclusion of contracts, deepening of their knowledge about investment products sooner or later
began to ask questions that related to the activities of their offices. Some of these questions were inconvenient for R.V.
Shpakov, as he did not want to give detailed answers to them. The heads of branches were interested in the reason
why the terms of withdrawal of funds on behalf of clients are so long, where the clients' funds are transferred to, what
is the earnings of the company for a specific period of time, positions on the earnings of individual clients, how the
clients' accounts in organisations are credited with the funds accepted by them in cash, and how the withdrawal of
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funds is made from the company's accounts for cash disbursement to clients, confirmation of reports, their
compliance with the truth, and the reason for the agreement between the company and the clients. There were
questions about interaction with Timur Turlov. R.V. Shpakov explained to everyone that the Broker had the right to
take a loan for himself, and R.V. Shpakov explained the high commissions of the company by this. The office managers
knew that "QB CAPITAL CY LTD" and "SIMTELLIGENCE COMPANY LIMITED" had no licences to carry out activities with
securities. He (Z.V. Munayev) knows about the activities of a number of heads of major departments and directions in
the group of companies: he knows Oleg Timokhin personally, he (Timokhin) was one of the heads of the back office of
"QB IC" LLC, was subordinate to Stanislav Matyukhin, kept records of the company's clients' operations using
standard sofware, prepared reports for the regulator, was one of the employees accountable to the regulatory
requirements. His (Timokhin's) accounting included all operations of both Brokerage Services and Trust Management.
With the appearance of IPO product in the company he (Timokhin) also had close communication with Shpakov R.V.,
Korzh A.V., Spinka R.V. Shpakov R.V. gave Timokhin instructions to form the terms of contracts, their expiry dates,
other standard points of accounting due to deep penetration into the operational processes of the company. The
accounting that Timokhin was in charge of was not part of the accounting and finance department, was not
responsible for the distribution of finances and payments, however Timokhin worked closely with the accounting
department due to related reporting, accompanied contracts (with VOD) with Q-BROKER LLC, informed Shpakov R.V.
and the sales department about impending cancellations, necessary prolongations and other actions for the standard
work of the brokerage business. Ruslan Spinka was the Head of the Sales Department afer the period of Vladimir
Pakhomov approximately from 2020. He (Spinka R.), like the previous heads of the department, had under his
command heads of sales departments, financial advisors, freelance agents who were hired for a percentage. He
started his working career from the most junior position, from about 2014, he was engaged in personal sales, he was
the head of the sales department for a long time. Spinka was personally appointed to the position of Head of Sales
Department by R.V. Shpakov and his duties included the standard functionality: ensuring sales plans, developing new
products, liaising with related departments, creating a personal account for the company's clients, ensuring standard
activity and efficiency indicators for sales department employees. He interacted with him (Spinka) personally both in
terms of assisting in the work of the sales department in view of his (Munayev Z.V.) extensive previous experience, as
well as in view of the development of partner and agency areas. His (Spinka R.) period of work also coincided with the
"boom" of the IPO product launch, he (Spinka R.) ensured the recruitment of new employees. International market
clients were transferred to the support department. Spinka reported directly to R.V. Shpakov and also carried out his
(Z.V. Munayev's) assignments as directed by R.V. Shpakov. Andrey Korzh started as a junior position, fulfilled his
personal sales plan, was later promoted to Head of Sales, and was also effective in meeting sales targets. On Spinka's
appointment as Head of Sales, Korzh was appointed as his deputy and assisted Spinka in organising and running the
sales department. Korzh's direct communication with customers was active during his tenure as a financial advisor
and during his personal sales plan. Thereafer, his work with clients was sporadic, involving either conflict situations
or the need to attend a meeting when discussing prospective deals at the request of either clients or subordinate
employees. As he (Korzh) worked for the company, his (Korzh's) functionality expanded but did not change much.
Korzh had a close relationship with Timokhin during his work with the IPO product in terms of contract renewals. Also
R.V. Shpakov ofen gave instructions to Andrey Korzh about these or those prolongations, new IPO deals, the need to
discuss with clients directly. Vladimir Maslennikov joined the company around 2012. Maslennikov has been a financial
advisor for almost his entire working career, and has received numerous awards for best results, but his promotion
was clearly delayed. When Ruslan Spinka was appointed head of the sales department, the latter appointed Vladimir
as head of the client support department, which included some of the former sales department employees as well as
new employees. All international clients of the Moscow office were transferred to this department. Vladimir Frolov,
who at that time and thereafer held the position of General Director of Qubey Finance LLC, has known him since his
employment. Subsequently, it was explained to him that he (Frolov) was a nominal director, i.e. a fictitious, fake
director. The real director managing the company is R.V. Shpakov. Everyone treated it as a common practice.
Subsequently, when the legal department appeared, Shpakov R.V. assigned him (Munaev Z.V.) the task of finding
nominees (front directors) for certain companies, and for the most part Evgeniya Rossieva, in the foreign part the
tasks were assigned by Shpakov to Linda Athanasiadou. Some of the signatories whom he remembers at the moment
were Gorobets Elena, Korshunov, Maricheva, Marichev and others. He was not personally acquainted with them.
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Gorobets was a nominee in "QB CAPITAL CY LTD" for a long time, probably during the period of management and
ownership of the company by R.V. Shpakov directly, then the name of Gorobets was in the incoming and outgoing
cash documents, signatures were made by facsimiles (which corresponded to reality). He and all employees knew
about her (Gorobets) real existence, and also heard that she had been to the notary's office many times with lawyers,
probably before and during her work with Evgeniya Rossieva. Her (Gorobets) role was at least as a signatory from "QB
CAPITAL CY LTD". Roles of signatories of "QB CAPITAL CY LTD", including nominal ones, in different periods were
fulfilled by many different employees: heads of departments, offices, sales departments, and initially including
Shpakov R.V., Kuzin S.L., Modin N.V. as real actors. In this connection the roles of the signatories on behalf of "QB
CAPITAL CY LTD" caused few questions for the employees of the company. The signatory should have had a power of
attorney from Shpakov R.V. For a long time, the director and signatory of the contracts of "QB CAPITAL CY LTD" was
directly Shpakov R.V. Voronova was the accountant of "QB CAPITAL CY LTD" for a long time approximately in the
period from 2010 to 2018. Voronova accompanied the operations of both the licensed companies and other
operations of Shpakov R.V.'s companies prior to the appointment of Ekaterina Gramza to this function. Voronova was
aware of the operations of Shpakov's companies in the Russian part. She may also have been aware of some relations
between Shpakov R.V. and Turlov, knew about the company "Dantons", accepted payments from it to LLC "Kyubi
Finance", and reported to the tax inspectorate. Between 2015 and 2018. Voronova worked closely with Ekaterina
Gramza, the latter assisted her and then took over some of her functions. During the initial period of work, Shpakov
R.V.'s level of trust in Voronova was close to 100 per cent in the Russian part. With the introduction of Ekaterina
Gramza into the accounting department, Shpakov's trust in Voronova diminished. Korshunov had been solicited no
earlier than 2018 and was one of the signatories in Shpakov's foreign companies. Evgeniya Rossieva, employees of the
legal department, other freelancers from among possible acquaintances of Shpakov or acquaintances of the
company's employees participated in the search for nominees on behalf of R.V. Shpakov. Discussions on the need for
nominees were held, in particular, with Kirill Padun. In addition, Berezka Andrei, an acquaintance of Vladimir
Pakhomov, assisted in the search for nominees. Berezka A. was approached by Eugenia Rossieva on behalf of Shpakov
to search for nominees. Rossieva had direct co - operation with Berezka. One of the private situations of conditions in
attracting and servicing clients was the situation with Borzenkov, about which he has information from the words of
R.V. Shpakov and V.S. Pakhomov, as well as Sobolev, including during his (Z.V. Munayev) visits to the Moscow office of
IK QBF LLC, as well as from general corporate correspondence and chats in messengers. According to R.V. Shpakov's
decision, the activities of selling financial products of QBIF LLC were carried out in various regions of the Russian
Federation, including in the city of Yekaterinburg. An office in this city was opened by Kirill Sobolev and Vladimir
Pakhomov in approximately 2014. Together they organised the recruitment of staff, sales methodology, production
and maintenance of memos, staff training, marketing materials and their distribution to potential clients, radio and
other advertising, a system of document management, acceptance and transfer of funds, legal support for local
clients and the office as a whole, as well as rent and related administrative matters. Sobolev was the first head of this
office and was appointed to this position by Vladimir Pakhomov. V.S. Pakhomov, in turn, was the director of the entire
branch network, responsible for its functioning, ensuring its operations and attracting clients. By that time, apart from
the Moscow office of Qubey Finance, there were no less than 2 and no more than 4 regional offices. One of the clients
of the Ekaterinburg office was Borzenkov. He (Z.V. Munaev) learnt about this client within a year afer his appearance
from R.V. Shpakov and V.S. Pakhomov in connection with a comparison of the sales results of the Moscow office and
the offices of the branch network. Moscow and the offices of the branch network, when they were discussing the
successes of these offices and the most significant results. Sobolev and Pakhomov personally knew Borzenkov,
personally participated in negotiations with this Client, offered him (Borzenkov) an individual and different approach
to the organisation of work with the Company due to Borzenkov's large financial resources and prospects for their
expansion in work with the Company. Borzenkov was a local businessman and former local official. From the words of
R.V. Shpakov and V.S. Pakhomov, he (Z.V. Munayev) knows that Borzenkov was offered personalised legal terms,
additional agreements, service tariffs, financial transaction schemes, other personalised terms (terms different from
other clients, more favourable). Sobolev and Pakhomov V.S. promoted and insisted on these conditions and scheme
of work due to their high interest in developing relations with the client and receiving personal financial results and
personal remuneration, which depended on the amount of money deposited. They also had an agent from among the
employees of Borzenkov's companies, who, for a fee, assisted both in attracting this client and in financial and legal
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support. The remuneration of this agent was also non - standard and differed greatly from the remuneration of the
other agents. It is quite possible that this remuneration included payments to Sobolev and Pakhomov V.S. as well as
to other persons. As part of the agreements concluded with Borzenkov in 2016 - 2017 with IK QBIF LLC (asset
management agreements) and QB CAPITAL CY LTD (for the provision of direct access to international stock markets),
the client transferred funds to the accounts of QB CAPITAL CY LTD. As in the case with other clients, it was assumed
that Borzenkov would receive standard trust management services and receive income according to the agreed
strategy. As we know from the situation with the companies of QB Group on the Clients attracted in this way on the
relevant contracts with LLC "IC "QB" and "QB CAPITAL CY LTD", money for management was received directly by R.V.
Shpakov, having all the keys both from the bank - client "QB CAPITAL CY LTD" and other trading access keys as the
owner (beneficiary). Pakhomov and Sobolev took part according to the roles defined to them by Shpakov R.V. in
misleading Borzenkov in terms of his service on the international financial markets, namely in the reliability of the
scheme of work of the companies involved, the perimeter of the licence coverage, the presence of regulatory
structures, the reliability of bank inspections, further supervision of regulators on the targeted use of funds.
Particularly important in the desire to induce Borzenkov to enter into the agreement was the increased returns
promised to Borzenkov and the personal financial and legal scheme of work specifically for Borzenkov that was
presented as legal. "QB CAPITAL CY LTD" did not have a licence from the Cyprus regulator to carry out investment
brokerage activities, did not have personal client accounts, as well as access of portfolio managers of "IC QBIF" LLC to
foreign trading accounts of QB CAPITAL CY LTD, as all accesses were directly with R.V. Shpakov. When the investment
company received the funds and transferred them for management, they were distributed to portfolio managers
(traders) who, in accordance with their job descriptions, powers, as well as experience and skills, should implement a
trading strategy using these funds in order to make a profit for the clients and the Company. In the case of Borzenkov,
the funds did not reach the portfolio managers; R.V. Shpakov handled all the funds himself and at his own discretion.
According to the words of R.V. Shpakov and V.S. Pakhomov, on the personal scheme of work with Borzenkov: the
funds transferred by him to "QB CAPITAL CY LTD, initially had a specific purpose, belonged to companies related to
him, who received these funds for specific uses. Borzenkov's financial director organised and consolidated the funds
from these companies, and together with Sobolev and Pakhomov they transferred the funds to Cyprus under
contracts with "QB CAPITAL CY LTD" in order to subsequently receive the funds (part of them) used in circulation on
the financial market to other accounts of Borzenkov and his related companies. For this purpose, Sobolev and
Pakhomov prepared for Borzenkov and his financial director additional supporting accounting documents necessary
to close the accounts of both Borzenkov personally and his companies. According to Pakhomov, V.S. Borzenkov
received some of the money, in different amounts at different times, by wire transfer. While working with Shpakov,
Borzenkov and Shpakov had difficulties in receiving the rest of the money. Borzenkov expressed clear dissatisfaction
and promised Shpakov R.V. problems, about which Shpakov R.V. informed him (Munayev Z.V.) personally. In
conversation with him, discussing the reasons for the impossibility of full return of Borzenkov's money, Shpakov R.V.
referred to the market situation, documentary requirements of banks, the complexity of trade transactions, the
procedure of client checks by banks, - exactly everything that he (Shpakov R.V.) told him (Munayev Z.V.) and other
clients of the Moscow office. Moscow. When interacting with Borzenkov on behalf of Shpakov R.V., Pakhomov V.S. and
Sobolev also greatly exaggerated the list of required client documents for the bank in order to delay the withdrawal
process, to frighten the client with bank requirements, to make the client change his mind and refuse to withdraw
funds, to be more loyal to the company for the support provided to him in defence of his interests before banks and
verification procedures. Both Pakhomov V.S. and Sobolev were aware of this and were executors in this part. But the
main reason of non - repayment is the intention of Shpakov R.V. to embezzle the funds of Borzenkov, who was misled
by Pakhomov V.S. and Sobolev on his (Shpakov R.V.) scheme of work. Regardless of the situation with banks and
inspections, if R.V. Shpakov had the intention to realise a settlement with a client, he could have done it in various
other ways. According to the contracts concluded with Borzenkov, the client was counting on the target return
specified in them (in the form of profit in monetary terms, not in the form of receipt of securities as an asset or
property, the delivery of which was not stipulated in the contracts), which Pakhomov and Sobolev could increase due
to their negotiating position and authority, which undoubtedly attracted the client and, along with other personal
conditions, convinced him of the need to cooperate with Borzenkov. One of the managers of the Cypriot company
"NOA CIRCLE" Athanasiadou Linda was aware of the situation and participated in the process of organisation of
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financial flows, transfers, legal support, preparation of necessary documents, reporting to banks, etc., including
Borzenkov's money. According to her, Shpakov R.V. did not allocate timely financing of the required amounts for the
transfers to Borzenkov on the required dates. Also from Pakhomov's words he (Munayev Z.V.) knows that he
(Pakhomov V.S.) kept a part of client contracts and documents. The documents were kept at his place of residence in a
flat in St. Petersburg, as well as in a flat in Moscow: these were contracts (or part of them) concerning clients in St.
Petersburg. Pakhomov V.S. could have also kept customer contracts of other branches, as customer contracts were
taken from branches, but with different frequency. As for the client contracts of clients in Moscow, they were kept on
behalf of R.V. Shpakov by the responsible employee Ekaterina Gramza at the following address: Moscow,
Presnenskaya Naberezhnaya, 8 p. 1, residential apartments in the tower. 1, residential apartments of the Capital City
Tower, north block, apartment number and floor he does not know. Pakhomov V.S. was directly involved in
supervising the company's issues with the Central Bank of Russia and law enforcement agencies, for which he
received additional remuneration from Shpakov R.V. In general, Pakhomov V.S.'s awareness of the work of Qube
Finance LLC in Russia and abroad is quite high, in private matters with Shpakov R.V. and his assignments, as well as in
solving issues with various government agencies. During his work in the company he (Z.V. Munayev) had a corporate
phone "IPhone XS Max" IMEI 357287094420629, a corporate SIM card with the number 9031004184 was installed in it,
this phone was intended for his personal use. He and sometimes Shpakov R.V. used the phone in cases of
correspondence with Cyprus and for negotiations with Linda, in those cases when he wanted to communicate
information from his (Munayev Z.V.) phone, allegedly on his behalf. Shpakov R.V. also conducted some personal
correspondence from his phone, which he (Shpakov R.V.), as he said, deleted aferwards. Afer presenting a copy of
the protocol of examination of items (documents) dated 20.12.2020, he explains the following: in the correspondence
dated 12.03.2018 for the period of time from 09:19:34 to 17:47:04 from the mobile application "WhatsApp" between
him and the lawyer of the company Rossieva Evgenia Anatolievna, with mobile phone number (+7985 - 173 - 43 - 21) it
was about the purchase of the company, which was necessary for the procedure of re - signing contracts with Clients
in connection with the liquidation of "QB Capital CY LTD", to other companies, which subsequently were
"Simtelligence Company Limited" and "White Lake Management Ltd". At first, for this purpose the company "Big City"
was found, which was abandoned, and another organisation was found - "Yurmaster" LLC, the head of which was a
nominee in the interests of Shpakov R.V. The nominee had a power of attorney on behalf of Shpakov R.V., and
Evgeniya Rossieva knew more about it. This company, which is referred to in the correspondence, was to take over as
an intermediate Russian party the rights and obligations of "QB Capital CY LTD" (this was insisted on by the Cypriots,
i.e. Linda, they were the ones who developed this scheme), to take over and immediately transfer the rights and
obligations to "Simtelligence Company Limited". In the correspondence dated 12.03.2018 for the period from 10:23:16
to 17:46:45, 13.03.2018 for the period from 09:50:11 to 15:19:09, as well as 26.03.2018 at 15:07:01 it was discussed that
all monetary relations, payments, payments, confirmations, approvals on expenses were given directly by R.V.
Shpakov. Ofen for lower - level employees he could aggregate information for some payments for different
departments for his approval without his direct participation, as the number of employees in the Moscow office more
than 150 people from more than 10 departments. Also ofen in correspondence he could negotiate some expenses
and discuss the company's position on his own behalf, but most ofen he referred to R.V. Shpakov, because all
employees knew that the payments came from him. All lists of required expenditures collected by him were handed
over personally to Shpakov R.V. He did not collect all the lists, but only a part of them for those departments with
which he interacted, or not for his departments, but concerning issues related to Shpakov R.V.'s personal instructions,
these could be, as a rule, heads of departments, also persons reporting personally to R.V. Shpakov or, due to the
importance of payments, discussing upcoming payments with him personally. They could also be assistants and
secretaries close to R.V. Shpakov during different periods of the company's work (they were dismissed and changed).
For Eugenia Rossieva, as a rule, he handed over lists, applications with the actual amounts needed. During most of the
period of the company's operation all payments and lists were handled directly by Shpakov, but when the financial
situation with external and internal payments became complicated, in order not to be "pestered", he (R.V. Shpakov)
would put him (Z.V. Munayeva) as an intermediate link for filtering. On the lists handed over to him, R.V. Shpakov put
either "pluses" (if he fully agreed with the necessity of this expenditure item) or, if he disagreed, put a specific amount
that he agreed to allocate for this expenditure item. Also, R.V. Shpakov could ask him to confirm any item. For the
most part, his (Z.V. Munayev's) involvement in these matters concerns the period afer he was removed from his
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position as head of the sales department, because, in his opinion, he had sufficient free time. He (Z.V. Munayev)
regularly had to face the negative attitude of R.V. Shpakov towards payment and as a consequence late payment of
both important and smallest payments. Shpakov R.V. controlled all, absolutely all expenses of the company and
employees, to the ruble, both large and important, and quite insignificant. As a result, R.V. Shpakov mostly distributed
money for previously agreed expenditures to employees himself - mostly through the heads of departments.
Sometimes he Shpakov) passed the required amounts through him. In the correspondence "RV", "Roman" - this is
everywhere Shpakov R.V. Alena - this is Kabanova Alena, the secretary of the 2nd internal reception, was subordinate
to all employees of this unit. Who is Sergei - he can't remember now. Apparently, this correspondence is about
fulfilment of some unimportant assignment, some momentary issue not related to regular activities. Svetlana
Beloded - Head of the Recruitment Department. Natalia is a corporate lawyer, Eugenia's subordinate. Anastasia is
Anastasia Ananyeva. Six per cent of the share of the authorised capital of QB Capital CY LTD was "rewritten" from him
to her: due to the process of re - signing contracts and liquidation of QB Capital CY LTD, he was removed from the
number of participants of QB Capital CY LTD), although he did not want it and waited for at least the first payment of
dividends from 2014 to 2018. A share in a company has value, especially in a licensed company, and he was counting
on it. Shpakov R.V. offered him the option of transferring "on paper" his part, 6 per cent of the share in the company,
to some of his trustees. For this reason he turned at that time to his acquaintance Anastasia Ananyeva, who agreed to
help him, without knowing the details, out of her kindness. Ananyeva was appointed to take part in the company for
some time, but this did not last very long. Afer the liquidation and all the procedures had been completed, Shpakov
R.V. denied him the right to have Anastasia among the participants of LLC "Kyubi Group" and offered to transfer to him
(Shpakov R.V.) these 6 per cent of the authorised capital of the company, explaining that now he himself would tacitly
and by their verbal agreement have the same 6 per cent share in case of sale of the company or accrual of dividends
with him (Shpakov R.V.). Pakhomov V.S.'s share in the Company (6 per cent) remained unchanged. Due to the fact that
earlier Shpakov R.V. convinced him of the necessity of his participation in the liquidation procedure of "QB Capital CY
LTD", the role of nominee and signatory, and the fact that he agreed with it, he did not think that he (Munaev Z.V.)
would become a participant and procedural part of all legal, documentary, other processes, meetings,
correspondence. However, it happened so, because he agreed and signed. During and afer the liquidation procedure
of "QB Capital CY LTD", contrary to his wishes, he had to lead or mediate in many meetings and correspondence,
although the initiatives and tasks were not from his side. In the correspondence "approached C" - suggests that this
refers to Stepanov, one of the major clients, but he is not sure. Stepanov was one of the first to file a complaint with
either the Central Bank, law enforcement agencies or go to court in connection with delayed refunds. "Kg" - we are
talking about "KG" LLC (Kyubi Group). Always when it comes to the 6 per cent stake he previously owned, it is about
his participation in the authorised capital of LLC Kubi Group. Marianna Scherbakova is a marketing specialist. At one
time the issue of providing additional service for a certain segment of clients from marketing, including legal service,
was discussed. Shcherbakova had contacts of law firms, as far as he remembers. Evgenia Rossieva could have
approached Marianna about finding candidates for the role of nominee directors. "Ds" for cash. In the
correspondence from the mobile app for 14.03.2018, 14:26:37 and 14.03.2018, 14:27:41, the abbreviation "kep" was
used to refer to "QB Capital CY LTD", the abbreviation "IC" referred to QB Investment Company Ltd. In this
correspondence it is about sending letters to clients about liquidation of "QB Capital CY LTD" and re - signing
contracts to other organisations, so that they understand that the procedure is legal, it is not bankruptcy, not a
"scam", but a process of renewal of infrastructure and jurisdiction. Talking about "unpaid invoices" - he does not
know what kind of invoices we are talking about, but he believes that Evgeniya Rossieva did not want the presence of
such information to provoke negativity on the part of Clients, so that various unnecessary thoughts and logical chains
would not arise. There were never any direct payments between "QB Capital CY LTD" and IK QBIF LLC, and there
should not have been according to the initial installation. "We wrote everywhere" - referring to QB Capital CY LTD's
responses to enquiries from the Central Bank. "Frolov signed" - apparently referring to notifications to Clients. In the
fragment of correspondence for 15.03.2018 for the period of time from 22:56:50 to 15.03.2018, 22:56:58, the phrase
"Noa candidate" indicates that at that time there was a recruitment of employees in the Russian organisation "NOA" -
a law firm being established to provide services to external clients. The plan was to create a Russian firm with the
name "NOA", a project of Linda Athanasiadou. "NOA candidates" - those wishing to be employed, were also partly
lawyers or had contacts with law firms. There is such a business practice that even if they are not employed, there
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remain potential business relationships with some of them. As a result, the Russian NOA organisation was established
in 2020 and Alexander Nepomnyashchy was appointed as its director. The Russian NOA had its own separate line of
business related to Russian services for new Russian clients. The Russian "NOA" did not overlap with the previous
lines of business of the Cyprus "NOA CIRCLE" mentioned earlier in the interrogations. In the fragment of
correspondence for the period from 16.03.2018 in the time period from 12:41:27 to 18:48:22 it is about the search for a
nominal (front) director to the organisation "BigCity". According to one of Shpakov R.V.'s instructions, this organisation
was to be registered to him (ownership of it), and a nominee was sought for the post of general director. In the
fragment of correspondence dated 22.03.2018 in the period of time from 12:40:03 to 14:02:26 the abbreviations
"signatories" were used, "BR" - Bank of Russia, "Intermarket" - direction to conclude agreements with Clients on
direct access to international stock markets; "they" - either Evgenia Rossieva or she together with Stanislav
Matyukhin. Eugenia's message suggests that there were no violations of the letter of the law at the moment on the
part of the company, but there are verbal recommendations, instructions and "motivated judgement" (this is the
official stable wording") of the Bank of Russia about this or that event or practice, which prompts a market participant
either to refuse something or to bring it into compliance with a change in structure or interest. In the context of "ik"
on the part of "br" this is what is being referred to. "Cyprus 3 contracts" - we are talking about some three Clients who
complained about non - return of funds, could write complaints to the website of the Bank of Russia. The contracts
with the Clients were standard: one with a Russian organisation, one with a foreign one. "The "signatories" to the
contracts were employees of QBIF LLC who had powers of attorney to sign the contracts on behalf of the company. All
of the branch managers of QB&E LLC, in particular, were signatories. Reorg is a part of the process of general
liquidation and re - signing procedure, which means reorganisation of LLC IC QB&EF directly, spin - off of LLC QB&EF
from it, which "takes" from LLC IC QB&EF the assignment contracts (international market contracts), thus fulfilling the
recommendation of the Bank of Russia to stop participation of a licensed company in the procedure (practice) of
international assignment contracts. "Edweiserie" - LLC "QBF Edweiserie". There should have been another company,
also an official member of the QBF group of companies, but at the same time not falling under a licensed IC, which
would have handled international assignment agreements, so that interaction with Clients would have been within
the law (the latest recommendations of the regulator). There was an idea to use QBF Advisor LLC for these purposes,
but it was not realised. The Bank of Russia did not like the fact that OOO IC QBF was carrying out international
activities that were not covered by the Russian regulator, for this reason the Bank of Russia recommended to "rid"
OOO IC QBF of international contracts. In the fragment of correspondence dated 29.03.2018 in the period of time from
13:22:24 to 13:23:12 at the mentioning of "Cayman and Hong Kong" and "need 2 signatories" it refers to the
organisations "Simtelligence Company Limited" (Hong Kong) and "White Lake Management Ltd" (Cayman Islands), to
which it was planned to renegotiate contracts with Clients from "QB Capital CY LTD". This was one of Linda's
assignments, the fulfilment of which was part of the overall re - signing process. "Baffle your colleagues and Berezka"
- this is about persons who are approached by Evgeniya Rossieva to search for nominee directors for the role of
founders/nominee directors of organisations, including Andrei Berezka, who was mentioned earlier. Eugenia was
given tasks on this matter both directly (Linda) and through him, as he took on a pool of tasks. In the last sentence,
authored by him (Z.V. Munayev), he had the following in mind: there were cases when a client asked why the person
whose signature was on the contract was not present and wanted to see that person in person. For such purposes, so
that it would be possible to show the signatory of the contracts at the client's request that "they should be ready to
come to the office". In the fragment of correspondence dated 29.03.2018 in the period of time from 16:03:29 to
17:25:26 the following persons were referred to: Gorobets is the nominal director of "QB Capital CY LTD". "Other
similar friends" are other nominee directors of organisations within the QB Capital CY group of companies. He did not
know the amount of their fees and had not dealt with it before, this is known to Eugenia in detail. As far as he knows,
when negotiating payment for the nominee's services, the latter proposed a price, and R.V. Shpakov either agreed on
it or adjusted it. His (Z.V. Munayev) role in this matter was to report (give information), coordinate, but he did not take
responsibility. Evgeniya Rossieva was in charge of calculations with the nominators for their services. Payment was
monthly either in cash or by transfer to a card. This procedure was in place both before he joined the organisation and
during his employment with it, and was carried out by Evgenia Rossieva or other employees of the legal department,
who did not have any unnecessary questions about this practice of engaging nominee directors. The fragment of
correspondence dated 30.03.2018 at 15:02:48 refers to the ZPIF of art objects, "Artfond". Apparently, this is some
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separate topic of conversation. In the fragment of correspondence dated 02.04.2018 at 11:03:59 - 11:05:24, it is about
the following: reorganisation - refers to the process of separation of QBIF LLC from QBIF IK LLC, in order to form a
Russian organisation to switch international stock market access contracts to it on the strict recommendation of the
Bank of Russia. Rentinvest LLC was a company of R.V. Shpakov that leased offices, which subsequently leased specific
areas to specific Shpakov companies. Maxim Yudin was one of the signatories. On Shpakov R.V.'s initiative he was
again wanted to be involved as a signatory, he (Munayev Z.V.) knows Yudin well, and knows that for him penetrations
into foreign processes of the firm were not pleasant, so he asked to minimise his role. "Discuss issues of assignment
contracts" - meaning international stock market access contracts: there was a planned discussion about which
organisation they would transfer to afer the reorganisation, plus there were topical issues of communication with
clients so that everyone was notified and everything went smoothly. The discussion was planned, as the process was
accompanied in the Russian part by Evgenia Rossieva and in the foreign part by Linda Athanasiadou. In the fragment
of correspondence from 23.04.2018 in the time period from 13:03:14 to 13:07:13 and 24.04.2018 in the time period
from 11:02:48 to 11:04:02 the following was discussed: Alena is Alena Kabanova, birch is Andrey Berezka, Kirill is Kirill
Padun. An intermediate variant of finding an organisation was discussed. In the end, the organisation Yurmaster Ltd
was acquired, but he remembers exactly that it happened without the participation of Andrei Berezka. Alena, as a
secretary, could pass information about upcoming expenditures both to Shpakov R.V. directly and to him (Munaev
Z.V.) to pass to Shpakov R.V. in the end. Kirill Padun was approached by Eugenia for services, as was Berezka. The
nominee (here meaning the signatory - the person on whose behalf the contracts would be signed from the
organisation "White Lake Management Ltd") was found by Kirill Padun. Since Linda was in contact with the CEO of
White Lake Management Ltd, she had to execute a power of attorney for the signatory on his behalf. This power of
attorney was eventually formalised, executed abroad. Draf contracts were awaited from Apollo Athanasiadou.
Discussions of payments did not signify the obligation to fulfil them later. In the fragment of correspondence from
23.04.2018 in the period of time from 15:37:38 to 18:30:00, it was about Yurmaster Ltd. Christina is Christina
Bogdanova. She could have done what she was asked to do on an errand, however, for what reason she could have
been approached with a request related to Andrei Berezka, he does not know. In the fragment of correspondence
dated 14.12.2017, the following abbreviations are used: Q is "QB Capital CY LTD". "C" - meant the Client Stepanov, who
in view of the arisen problems with the withdrawal of funds applied to some instances, at the same time he collected
an impressive set of documents, including some in the territory of Cyprus. Gorobets was a signatory both in contracts
on behalf of "QB Capital CY LTD" and "QB Group" Ltd. For this reason, Evgeniya Rossieva feared that this fact might
suggest that these organisations were affiliated. In the fragment of correspondence dated 06.04.2018 in the period of
time from 15:47:52 to 15:58:52 it was about Zarechnev, who at that time was a current employee, for this reason he
was not suitable for the role of a signatory. Marianna is Marianna Shcherbakova, she had contacts from previous jobs
in law firms. For this reason, Eugenia periodically turned to her for help in finding signatories, nominees. In the
fragment of correspondence dated 06.04.2018 in the period of time from 15:59:44 to 17:44:03, the possibility of
resolving the issue to take into account the previous comments of the Bank of Russia (CBRF) regarding the work of
QBIF LLC and international agreements was discussed. At this point in the correspondence, the question immediately
arises as to a legitimate company that would be an authorised agent for the sale of services of foreign investment
companies, having the necessary signatories and documents. The company in question is K - Investment LLC. This
company subsequently had employees employed by it selling units of different markets (jurisdictions) and different
products of different companies. The company acted as an Agent in Russia selling services of foreign companies. In
the fragment of correspondence dated 12.11.2020 in the period of time from 12:41:35 to 16:15:42 it is about
contractual relations with Vyatkina A.G., as well as about the actions and decisions of the employees of IK QBF LLC in
relation to her, namely: Ruslan Spinka - Director of Sales Department, they went together with him to Shpakov R.V. to
discuss issues of payments to clients. For this reason, Evgeniya approached him (Z.V. Munayev) with a question about
another client, Vyatkina, so that he could find out the details from Spinka. Usually, if the client was from Moscow, he
could answer or find out from Spinka, and if not, he would forward these questions to Golubev and Pakhomov. At the
moment he does not remember the details of his interaction with a client such as Vyatkina. There were different
people among the clients: some asked for cash withdrawal only, some needed only a cashless transfer, some did not
care. However, non - cash transfer of funds could be made only afer re - signing of contracts with "QB Capital CY LTD"
to "Simtelligence Company Limited" and "White Lake Management Ltd". Usually R.V. Shpakov decided how to
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disburse funds to a particular client, or could meet the client's requirements if they were specific (cash or non - cash
payments). "Closed in the ECB": it means that "to close the transaction" meant that afer signing contracts with the
client, he received funds from the client within the framework of the achieved contractual relations. So the client in
question, Vyatkina, was transferring money to the company's account in Yekaterinburg. "VSP" stands for Vladimir
Sergeevich Pakhomov. Dp - Sales Department. FS - Financial Advisor. Who was Vyatkina's financial advisor, he does
not know. In the fragment of correspondence from the mobile application "WhatsApp" with the contact "Andrey
Korzh" (+7 965 411 - 72 - 25) in the period of time from 06:03:10 to 12:50:24, it is about contractual relations with
Koptev S., as well as about the actions and decisions of the employees of LLC "IC QBF" in relation to him, namely: he
was afraid to meet with clients at certain moments, because promises and deadlines for withdrawal of funds were not
fulfilled. Some of the clients were very senior and influential persons, and given that he was a signatory and one of
the executives in the company whom the clients might know, he was wary of making commitments because he did
not have the capacity to honour them as it was not up to him. The clients were restrained as best they could: they
were asked to wait, referring to the unfavourable value of the portfolio at the moment; they said that we were
withdrawing, wait; it depended not on us, but on foreign banks, which did not let money into Russia; foreign partners
were delaying; we were selling off the portfolio, everything would be soon; the money was hanging in a bank abroad;
there was a big commission at the stock exchange in the bank, and so on. According to personal agreements with
clients, it could have been a matter of settling assets/property - meaning RIF, real estate. He (Z.V. Munayev) would give
such a recommendation, which was lef for discussion, as the decision did not depend on him. But in the case of his
employees' appeal to him, he always tried to get into it and help with an opinion or action as much as possible.
Koptev was Pakhomov's Moscow client during his time in Moscow. They initially had a good personal relationship,
which deteriorated. Since the client is Moscow - based, he was assigned to Andrei Korzh as an escort. In a fragment of
correspondence from the mobile application "WhatsApp" with the contact "MAKS" from 18.10.2018 in the period from
12:26:41 to 14:00:44 the dialogue was with Maxim Yudin. They got a job at QBF in the same year in 2010. They have a
good mate working relationship. The correspondence with Yudin was about non - cash withdrawals to clients. He
asked to send lists of clients to report to R.V. Shpakov so that he (R.V. Shpakov) could pay attention to especially
dissatisfied clients for settlements with them. Maxim raised the issue of sending reports to clients afer re - signing
contracts. It was also discussed that reports to clients from "White Lake Management Ltd" are visually similar to the
previous form of reports from "QB Capital CY LTD". In fact, the reports were prepared and sent by the same persons
both on behalf of "QB Capital CY LTD" and on behalf of "White Lake Management Ltd" and "Simtelligence Company
Limited". The reports were sent afer the contracts were re - signed and should have been sent from a different
domain so that the clients would not have any questions. However, at first the report mailings on behalf of "White
Lake Management Ltd" and "Simtelligence Company Limited" were technically done from the same domain as "QB
Capital CY LTD", i.e. they forgot to update. In addition, it had to be remembered that the "old" clients who had not re -
signed the contracts, reports had to be prepared and sent on behalf of "QB Capital CY LTD". In the fragment: "Max:
There would have been bought positions in the reports", this phrase meant that some clients had blank report forms,
which was a programming error. QBF employees received client reports first, about 3 - 5 days before the clients,
checked them, analysed them to prepare reviews and comments. According to the regulations, once a month at least,
the client was consulted either by phone or in person, as the client must be aware of what is happening with the
portfolio, the balances, terms of service, their possible changes. If everything was normal, reports were sent to clients
in a few days. If there were some sofware errors (e.g. empty reports), we had to contact Orlov, he solved technical
errors. If the errors were not technical, but in terms of meaning and content, then we turned to R.V. Shpakov. In the
fragment of correspondence in the group "Restructuring" participants: (Apollo (+357 96 218890), Linda (+357 99
920015), Munaev (+7 903 100 41 - 84) and the subscriber number +7 965 748 88 88 belongs to Vladimir Pakhomov (in
the correspondence "Vova") for the period of time from 09:41:03 to 21:17:10 it is about the following with the
following subscribers: Apo - Apollo Athanasiadou. In the present correspondence Linda Athanasiadou writes that the
name of R.V. Shpakov was removed from wherever it was possible (from the management of "QB Capital CY LTD") and
she keeps the contracts (signed on behalf of "QB Capital CY LTD" by R.V. Shpakov) in a safe place, but it is necessary to
organise the closing of the issue with the Central Bank of Russia. V.S. Pakhomov replied that he would try (as he said
in earlier interrogations, he solved issues regarding QB Capital CY LTD through his people in the Central Bank of
Russia). Some points discussed in the correspondence could have been discussed separately with R.V. Shpakov
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earlier at that time. Linda wrote that the Central Bank of Russia had sent an enquiry to the Cypriot regulator
(CySEC)regarding 9 companies, listing them. Haris is a regulatory expert, auditor and consultant in Cyprus, a
professional, assisted Linda. If there were any irregularities in the work of the Cypriot companies, the Cypriot
regulator would have immediately sent appropriate enquiries to these companies. But since there were no violations
in terms of interaction with Russian companies in accordance with the law, there were only questions from the
regulator. The correspondence is connected with someone's "order", but this threatened the possible start of an
investigation. Linda, when processing client money, provided the banks with client agreements with both "QB Capital
CY LTD" and a Russian licensed organisation, and the Cypriot regulator had no questions. However, in connection
with enquiries to the Cyprus regulator from the Central Bank, questions to Linda began to come, which for her
signalled certain problems. And it is necessary to remove their source for her - enquiries from the Central Bank of
Russia to the Cypriot regulator. There are different co - operation agreements signed between Cyprus and Russia, for
this reason the presence of questions on the activities of companies from Russia could lead to their occurrence in
Cyprus, as it would also be taken for violations of the law, which threatened fines, company closures and possible
criminal prosecution. All the inspections started because of customer complaints. R.V. Shpakov was the beneficiary in
the Russian part and according to the latest recommendations heard from the Central Bank of Russia, it was clear
that in case of his presence in the foreign part, the actions of attracting clients by concluding contracts on behalf of
"QB Capital CY LTD" could be considered as unfair practice, as the funds deposited under the concluded contracts do
not fall under the jurisdiction of the Central Bank of Russia due to their transfer abroad. In a fragment of
correspondence in the group "Reorganisation", participants: Shpakov (+7 905 735 - 55 - 88), Rossieva (+7 985 173 - 43 -
21) - the creator of the group, Munaev (+7 903 100 - 41 - 84) in the period of time from 10.04.04.2018, 13:56:34 to
12.04.2018 17:20:17 and 22.05.2018 at 17:28:13, the discussion is about the reorganisation of QBIF LLC, the separation
of a separate entity (QBIF LLC) from the structure of the latter. Selection of a nominee for the role of general director
is under discussion. The candidacies of Gorobets and Yudin are not suitable, as at the moment they did not meet any
requirements of the tax inspection for the reorganisation. It is proposed to put him (Z.V. Munayev) in this role. Earlier
he did not give Shpakov R.V. consent to his role as general director of this company. For the general re - signing
procedure he was sufficient as a nominal owner, and he tried in every possible way to avoid the initiative to take on
the role of a general director as well. Andrei Berezka, who is mentioned in this correspondence, provided one of the
nominees for the reorganisation procedure, apparently instead of Gorobets and Frolov. He does not know for what
reason the correspondence links Berezka and the tax inspection; Avalon was also R.V. Shpakov's company. In the
fragment of correspondence within the group "Fin Potoki", whose participants were: Linda (+ 357 99 920015), she is
the creator of the group, Munaev (+7 903 100 - 41 - 84), Tatiana Milekhina in the period of time from 19.06.2020 from
14:17:03 to 16:58:14 and 02.11.2020, 15:03:12 in this correspondence is about the transfer of funds from one
controlled company of Shpakov R.V.. - Q-BROKER LLC - to another, Cyprus - licensed Constance Investment. The
payment under discussion was unilateral, non - refundable, and did not raise any questions, as it was formalised as a
transfer of investments from one company to another. The amount in question was 230,000 Euros. Judging by the
amount, it is a contribution to the authorised capital as an investment from the founder. The investment company
lives, as a rule, by ensuring the operation of such items as commissions from clients and turnover. In the case of
insufficient funds under management, the company does not have enough commissions to support its own
operations and salaries, in which case the founder may make regular capital contributions to keep the company
going when it cannot break even on its own due to poor performance. This example is realised in this correspondence
in the part of regular additions to the authorised capital of "Constance Investment" by R.V. Shpakov, because the
company did not have time to accumulate sufficient funds under management for sufficient payback, which made
R.V. Shpakov very angry, it was a constant ground for quarrels between him and Linda. Further, according to the
inspection report, there is a photo of Borzenkov's payment slip. Due to the competitive spirit and the exchange of
results between different offices, both within the framework of contests and as a matter of routine, the managers
could boast of significant results, declare their successes and remind about the efficiency of their offices. Tatiana
Milekhina was an accountant in the group of companies for a short time. In a fragment of correspondence from the
mobile application "WhatsApp" with the contact "Apollon" (+357 96 218890) dated 20.12.2017 in the period of time
09:27:39 to 13:14:37 Apollon Athanasiades speaks about the need to sign documents for the liquidation of Cypriot
companies ("QB Capital CY LTD", plus, presumably, "QB Capital Management LTD" in the set could be other
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companies). It is about visiting the Cypriot embassy in Moscow: Apollo was going to go with him to the embassy to
sign the documents. This is a necessary part of the official procedure, since he was in Moscow. As a result, this was
the case: he (Z.V. Munaev) and Apollo visited the consul together, whose participation in signing the documents was
necessary to properly certify the liquidation of the organisation. In the fragment of correspondence dated 05.03.2020
in the period of time 19:21:01 to 20:02:24 in this part of the correspondence he (Z.V. Munaev) writes to Apollon
Athanasiadesthat Nikolay Padalko, in connection with his appointment as CEO of the Russian LLC "VL Consulting",
proposed a new idea for document management support, in some part - a new format for the movement of client
funds at "White Lake Management Ltd". This was one of the ideas, as Nikolay had an interest in strengthening and
improving the interaction between the Clients and White Lake Management Ltd, bringing the processes in line with
both market and regulatory requirements. In the fragment of correspondence in the group "Wl", whose members
were Yuri Orlov, Linda, Apollo, Zelimkhan) and the number +357 96 710071 belonging to Apollo dated 19.09.2018 in
the period from 11:16:42 to 13:22:15 it is said that Yuri Orlov as an IT specialist stored some codes from websites,
including the website of "White Lake Management Ltd". There were glitches on the site and updates were needed,
Yuri didn't have time. There were some internal access issues, Linda asked him for his password and debugging
processes. When clients re - signed contracts, a determination was made to terminate the contractual relationship
between the client and "QB Capital CY LTD", and a contract was concluded - either with "White Lake Management
Ltd" only, or in conjunction with "Simtelligence Company Limited", or a contract could be added with "VL Consulting
Ltd". All organisations with different jurisdictions, founders (owners), general directors - in order to avoid
assumptions about their affiliation to QBF group of companies, as it could lead to the idea that the clients' money
passes exclusively through "their" organisations and can be used not for the intended purpose. For the same reason,
the report forms, hosting and domains from which the reports were sent were also matched. In the fragment of
correspondence in the group "Wl", whose participants were: Yuri Orlov, Linda, Apollo for 15.11.2018 in the period of
time from 16:05:31 to 21:07:53 in this working correspondence it was about the uninterrupted work of the phone
number in the office - representative office of "White Lake Management Ltd" in the Cayman Islands. An operator
response was needed, debugging the work schedule, coordinating procedures with Linda. White Lake Management
Ltd did have an office, met the minimum requirements of the regulator, he knew this from Linda Athanasiadou, as she
had told him on several occasions. There were no client managers in the office, for this reason it was necessary for the
telephone number to be answered by someone who was knowledgeable and could orientate clients on operations.
White Lake Management Ltd. had 10 - 20 clients - individuals (i.e. contracts for providing access to international stock
markets were concluded and clients transferred money to the organisation's details). During the Central Bank of
Russia's inspection of QBIF LLC (most likely during the second inspection), the Cayman Islands were requested by the
Central Bank of Russia. In response to this request, the Cayman Islands regulator gave explanations about the
organisation "White Lake Management Ltd": its working conditions, transfer of funds, and also that there are "live"
people, clients, "live" balances, and the Cayman Islands regulator disclosed the data of these clients. In general, the
regulator had no questions about the work of White Lake Management Ltd. In addition, Nikolay Padalko was closely
involved in the issues of legitimacy of "White Lake Management Ltd" activities: he read a lot, studied websites and
information from the regulator, found information about the presence of a licence to act with securities, and this was
the second confirmation of the presence of a licence (the first confirmation was from Linda). The financial advisors
were also looking into this as they had clients to work with. The QBF office in the sales department had information
from the Cayman Islands regulator regarding White Lake Management Ltd in English. The fragment of
correspondence with the contact "Smirnova Yaroslava" for 18.11.2020, in the time period from 19:38:49 to 22:49:06]
refers to Yaroslava Smirnova's initiative to discuss with Shpakov R.V. and him a number of questions that she had
previously formulated to him. The questions related to different funds of the QBF Management Company. He
expressed his position on part of the questions. Where payments were necessary, he explained that we put them on
the list for coordination with Shpakov R.V. The correspondence shows Yaroslava's dissatisfaction with the interaction
and speed of coordination with LLC "IC "QBF" represented by Matyukhin Stanislav and lawyers (Rossieva Evgeniya) in
the part of realisation of units of its funds (Funds of MC) to clients, coordination of operational moments. Anastasia is
Anastasia Koval, Chief Operating Officer of QBIF LLC, a subordinate of Stanislav Matyukhin. In the fragment of
correspondence with the contact "Alexey Golubev" for the period of time: 12.01.2017 from 13:13:15 to 16:25:16;
13.01.2017 at 10:25:39; 02.03.2017 at 16:07:52; 06.03.2017 from 11:49:36 to 19:40:49; 02.04.2019 in the period of time
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from 17:55:11 to 10:36:27 03.04.2019 the following is the subject of the correspondence: At the beginning of the
correspondence, apparently, colleagues (in branches) did not receive reports on some customers, and the chain of
forwarding the request reached him, he helped to get the report. In the correspondence Golubev A.S. asks him about
the lack of changes in the reports of two clients for two months. He was not the one who prepared the reports, so he
does not know why there were no changes, but the clients may have had questions in this regard. For this reason, he
(Z.V. Munayev) advises A.S. Golubev to contact the back office. A.S. Golubev further asks about the calculation of the
tax rate on foreign companies for the Clients. However, for foreign companies he advised him to contact Dmitry
Lepeshkin, who is aware of the activities and specific work processes of both Constance Investment and Noa.
"Constance Investment was established by the organisation Aspard, whose owner is Shpakov R.V. The activities of
NOA were managed by Apollo, the activities of Constance Investment were managed by Linda Athanasiadou. Dmitry
Lepeshkin was aware of the activities of both of these organisations, but he did not make significant decisions.
Andreas is one of Linda's employees (foreign back office). Various contractual options were discussed with A.S.
Golubev, which he explained above. There were contracts concluded with Clients only on behalf of "White Lake
Management Ltd" with cash transfers directly to this organisation; when two contracts were concluded, on behalf of
"White Lake Management Ltd" and "Simtelligence Company Limited", cash transfers were made by Clients to
"Simtelligence Company Limited", which was recognised as an agent in the contract with "White Lake Management
Ltd". Cash transfers from customers could only take place to credit the account of Simtelligence Company Limited,
while non - cash transfers could be made to both organisations. In the fragment of correspondence with the contact
"Ruslan Spinka" dated 24.10.2019 for the period of time from 13:42:58 to 23:53:16 in the mentioned fragment, he was
written to by an acquaintance about a client who cannot withdraw money, and he forwarded the issue to the Sales
Department to Ruslan Spinka, as he himself did not deal with the DP (Sales Department). In the fragment of
correspondence with the contact "Ruslan Spinka" dated 14.05.2020 in the period of time from 12:06:31 to 21:55:47;
14.08.2020 in the period of time from 09:10:45 to 17:44:18, both customer and employee issues were discussed.
Customer issues: Kushnir, Gomanova are clients, they had roughly the same situations. There was a request from
Ruslan Spinka to discuss additional loyalty from the company in favour of some clients, namely giving them
additional "leverage" (BP) due to unsatisfactory management result for clients. The broker could give additional
"leverage" to clients, R.V. Shpakov himself had previously selectively initiated this on a number of occasions and
confirmed this possibility to employees. Ruslan asked for help, three to talk to R.V. Shpakov to help dissatisfied
clients. "Leverage" is an opportunity for the client to increase the portfolio volume by means of additional borrowed
funds for trading from the company - Broker. "Leverage" is given as additional funds to the client for trading against
the security (pledge) of his existing portfolio. The result of trading on borrowed money ("leverage") is profit or loss:
profit afer repayment of borrowed funds to the Broker is credited to the Client's balance, loss afer repayment of
borrowed funds to the Broker is written off from the Client's existing portfolio. The transaction on granting additional
"leverage" is always the result of the client's initiative. The borrowed funds are subject to an annual interest rate,
which is charged on a daily pro rata basis. Initially in the company this option appeared from the service of
Consultative management (transactions are made by the client), then on the initiative of employees of the Sales
Department to increase customer loyalty in the service there were requests to connect this option and clients of the
Trust management. Besides, in correspondence the issues of other clients are discussed in the working order, ways to
avoid conflicts. Regarding the issues discussed about employees: I discussed with Ruslan who from their side
prepared the calculation of salary and bonuses from the sales department, whether this calculation was checked,
whether it was sent to Shpakov R.V. for approval and payment. In connection with delays in payments Ruslan asked
to hurry up with the issuance of debts to employees, including asking him (Munaeva Z.V.) to address Shpakov to
speed up the resolution of the issue. In the fragment of correspondence with the contact "Ruslan Spinka" from
10.11.2020 in the period of time from 09:33:28 to 17:47:01 it was discussed whether dissatisfied clients are on the
Internet, on forums and review sites, whether they are contacted by representatives of the company, whether they
are given attention in the order of follow - up, whether these clients are reliably in the lists for withdrawal. Meshkova -
responsible at that time for monitoring the Internet, worked in the support department. Customer complaints
addressed to the company were first of all sent to the legal department, where lawyers looked at the terms of the
contract and decided what to answer. The largest number of complaints was related to non - payment of money to
clients (employees addressed Shpakov R.V. with this issue). The second place in terms of the reasons for appealing is
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the dissatisfaction of clients with the financial result: for what reason there is no profit, why these particular items
were bought, why the commission was written off, although no money was earned, etc. In the fragment of
correspondence with the contact "Roman Shpakov" from 07.11.2017 in the period of time from 22:12:15 to 23:55:00 in
this fragment of correspondence in the designated dates can be associated with two events: 1. The situation related
to the contacts of the former security officer of the company Alexey Rudnev, hired by Shpakov R.V. Rudnev, according
to him, had connections in the regulator at the level of Nabiullina, as well as in the FSB at the level of the head of the
entire service. The contacts turned out to be "fake" and were offered to him deliberately as part of the intent to
embezzle the company's and Shpakov R.V.'s funds (or bribe). As a result, a criminal case was initiated against Rudnev
and his associates, who did not work in government agencies, following the Company's appeal and application to law
enforcement agencies when Rudnev's initiative was uncovered. He (Z.V. Munayev) was the complainant on the
instructions of R.V. Shpakov, the operational support was provided by FSB officers. 2. Roman Shpakov had a personal
contact - Pavel Samiev, his old acquaintance, a former high - ranking employee of RA Expert rating agency. Pavel has
many connections in the financial market, including with the regulator. R.V. Shpakov held many preliminary meetings
and negotiations with him on the subject of helping him to recognise the Central Bank's letters to Cyprus, whether
they were someone's "order", whether someone wanted to harm the company, or whether these requests to Cyprus
did not exist at all. At a certain stage, when Pavel needed information on the company's work with clients, contracts,
money transfer procedure and general organisation of work, R.V. Shpakov set him (Z.V. Munayev) the task to bring all
this information to Pavel, to be in the information field of his further meetings with contacts on the market and in the
regulator, to give his opinion on whether Pavel could learn anything for the company. His involvement in working
with Paul on this matter was limited to a few meetings with him, calls and correspondence. As a result, Pavel
informed him (Z.V. Munayev) that there was no information on the issue of R.V. Shpakov in the Central Bank of Russia
at the level of deputy chairmen (Yudaeva, etc.), and he had no possibility to find out anything additional there.
According to information from market participants he knows, there may be companies that want to "mess up" QBF
and R.V. Shpakov, but he does not have more detailed and useful information and cannot find out. Since at that time
the issue of liquidation of "QB Capital CY LTD" in Cyprus had already started, Shpakov R.V. ofen tried to include him
from different sides in this issue to instil in him (Munaev Z.V.) fear for the clients of the company and for the company
itself, so that he (Munaev Z.V.) would get imbued and start to personally worry about their further fate. In the
fragment of correspondence dated 20.12.2017 from 14:15:59 to 15:34:29, it is about messages from the client
Stepanov about the receipt of funds to him. In the fragment of correspondence from 02.06.2020 from 00:29:25 to
11:38:21 this fragment was about nominals, whether he handed over the task. He answered, yes (but what task, he
does not know, he does not remember). He answered about their awareness of the company and the people in the
company, that they could probably be aware. He went on to answer that it would be better to use actual working and
acting people in the company for appointments (in continuation of the answer on nominations). Remy Zyman -
doesn't know who that is. Perchikov - surname is familiar, but does not remember who it is. His answer about Vera
(Veronika is Polezhaev's wife, i.e. Polezhaev himself is meant) refers to the initiative of R.V. Shpakov to file a complaint
against him with law enforcement authorities under the article "Extortion", since he received the money he invested.
Sam - doesn't know who he is talking about. Matyukhin was called "Stam" "Stan" (Stanislav), so perhaps it is about
him and there is a typo in the text. Anya Trufanova is not personally known to him, some private case. Shpakov R.V.
told him something about people who could harm him and the company on purpose and in their own interests. Since
he does not remember the whole context of the audio files, he can tell the following from his answers: 1. Since the
head of QBF security service Mikhalevich previously worked in the 6th FSB service and knows a lot about the
company's processes, it is possible that he supplies information to the 6th service (earlier experience with the
previous head of the FSB Rudnev lef an indelible mark on many people and fear of using his official position for
selfish purposes). 2. "The information is held by..." - perhaps we are talking about potential ill - wishers who pull the
levers of the Central Bank of the Russian Federation and the Ministry of Internal Affairs of the Russian Federation. We
are talking about a large set of documents of Stepanov's client, who had previously sent it to the CBR, and then this
set was forwarded to the Ministry of Internal Affairs of the Russian Federation for the Central Administrative District.
Based on the fragment of correspondence dated 31.08.2020 for the period of time from 11:16:45 to 19:04:15,
explained that Shpakov R.V. and Linda had periodic disagreements, because of which Shpakov R.V. at some periods of
time wanted to dismiss her from Constance Investment due to personal claims, inefficiency, as the company was not
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making money and Shpakov R.V. had to financially support its activities. However, he was in favour of her remaining
at least in the Compliance function - checking all documents in Constance Investment for reporting to clients, as he
knew that she was a strong specialist and could be useful in this position. R.V. Shpakov had periodic thoughts to
dismiss her from Constance Investment (periodically she was not satisfied with her work). From the tranche -
Argento's papers - replenished the company's portfolio, leverage and security of the leverage, which the company
took on itself and the clients. Thus, the replenishment in Argento allowed for the release of some volumes from
previously held collateral (securities and money that were already in the company's portfolio) to make withdrawals in
accordance with submitted client orders. He further asked if DP bonuses would be paid out. Linda informed about
the possibility to make Shpakov R.V. transactions via bitcoin. His answer: "will give 3 million rubles for bonuses"
(bonuses of DP in a bad month were 2 million rubles, in a good month - up to 8 million), and accumulated debts - it
was about half a year. R.V. Shpakov ofen played on the emotions of employees (he relieved himself of responsibility),
sometimes shifing the responsibility from incoming funds to salaries and bonuses (all - debts for previous periods),
paying part of the funds to "small" clients at his own expense in order to slightly reduce the emotional load of
employees - to transfer them to another direction. In the fragment of correspondence with the contact "Yuri Orlov"
(+79263088226) on 08.06.2018 in the time period from 15:58:04 to 19:01:01; 12.09.2018 from 13:23:33 to 14:47:39;
26.02.2019, from 17:47:42 to 17:58:40, this part of the correspondence with Yuri Orlov refers to the discussion of
reports to clients on behalf of White Lake Management LTD, which were to be sent to them afer the re - signing of
international market contracts. This matter was also supervised by Linda. "Vladimir Sergeyevich" - this
correspondence refers to Vladimir Pakhomov. In the fragment of correspondence with the contact "Yuri Orlov" on
13.03.2019 in the period of time from 16:39:41 to 21:18:13, technical aspects of ensuring the company's activity are
discussed. This part of the correspondence refers to the day of the search in the office of the company. He (Munaev
Z.V.) sent Yuri the tasks formulated to him (Munaev Z.V.) by Shpakov R.V. on immediate response in terms of
disconnecting network media, access to computers of all managers, restricting access to files, mail, other access. In
the fragment of correspondence dated 04.09.2019 for the period of time from 09:50:31 to 10:22:52 with Yuri Orlov,
with the exception of some individual topics, refers to the instructions of Shpakov R.V. on the access of employees to
local discs of the company, the work of the pass system of the office, updating and purchase of this or that sofware,
sites, servers, remote access, some equipment to the office, security and data encryption programs, systems against
hacking and others. Also Yuri was ofen approached to get some reports, he (Yuri) was in charge of sending them out.
Marketing mailings (advertising mailings) on the database of Customers for certain products: there could be both
current Customers and a database of potential Customers. Orlov was asked by employees of Moscow - offices and
branches on the work of CRM - system (sofware for accounting of new and maintenance of existing Customers, used,
as a rule, in the sales department). Also Yuri was asked for expert assessment of any market programmes, their
working conditions, possibility of interaction, etc. In the fragment of correspondence with the contact "Pakhomov"
(+796574 - 8888) from 16.07.2019 for the period of time from 10:42:33 to 18:31:41] this correspondence concerns the
situation with the client Polezhaev, this is the client of Pakhomov V.S. He (Munaev Z.V.) reported that a Chechen who
"deals" with the issue from the side of Polezhaev, his partner, came out to him. He (Z.V. Munaev) was threatened, as
he was a signatory of Kyubi Capital, as well as the risks associated with the company, including criminal prosecution.
It was about "manual" control by Polezhaev of necessary people in law enforcement structures to put pressure on
Shpakov R.V., Pakhomov V.S. and as a consequence on him (Munayev Z.V.), that the desired result in case of refusal of
cooperation will be achieved by any means, people are already "loaded", despite the fact that the invested money
was received by the client at the time of this correspondence. Categorical dissatisfaction and disagreement
concerned the amount of profit (it is not fixed or guaranteed). In fragments of correspondence with the group
"Fantastic 4", whose participants were: Roman Shpakov (+7 905 735 - 55 - 88), Linda (+357 99 920015), Munaev (+7 903
100 - 41 - 84), +7 965 748 - 88 - 88 Vladimir Pakhomov dated 13.11.2017 during the period of time from 21:51:44 to
00:32:39 h 14.11.2017; 15.11.2017 during the period of time from 13:42:50 to 16:02:13; 17.11.2017 during the period of
time from 11:12:24 to 16:17:02; 23.11.2017in the period of time from 12:32:51 to 11:52:42; 28.11.2017in the period of
time from 00:22:03 to 02:21:59; 30.07.2018in the period of time from 15:16:03 to 16:50:02, Roman Shpakov was the
task setter, Linda coordinated the issue for the Cyprus regulator, Vladimir Pakhomov coordinated the issue for the
Russian regulator (Central Bank of Russia). He (Z.V. Munaev) was in correspondence as a nominee, signatory of "QB
Capital CY LTD". The main content of this correspondence concerned discussions about possible letters of enquiry
390
from the Central Bank of the Russian Federation to the Cyprus regulator CYSEC(CySEC). Linda informed Shpakov R.V.
about the receipt by the Cyprus regulator of an enquiry about the company "QB Capital CY LTD", in connection with
the company "QB Capital CY LTD", the receipt of clients' funds from Russia, about the owner of "QB Capital CY LTD".
Due to the fact that for R.V. Shpakov, who was a beneficiary of the Russian group of companies "QBF", this issue and
disclosure of him as a beneficiary of "QB Capital CY LTD" was a risk zone, he was greatly puzzled by the solution of
this issue and not declassifying this information due to possible, including criminal, consequences for him personally.
The correspondence was long and lengthy and did not reach a logical conclusion as Roman Shpakov and Vladimir
Pakhomov questioned the letters from the Russian Federation to Cyprus as such and did not believe Linda, insisting
that she was overemphasising the issue and her role. The other side was Linda's position, who argued that the letters
do exist and it is indeed a threat to everyone, that it is urgent to address the issue in Russia, because there are no
problems in Cyprus initially, but in case of complaints from the Russian Federation they may appear. The third option
that was discussed by the participants was a possible ill - wisher and initiator of the investigation in the Central Bank
of the Russian Federation, including on a reimbursable basis, who wants to cause trouble for both the company and
Roman Shpakov personally. All three options with possible reasons, details and consequences were discussed at
length in the correspondence. No one ever came to reliable information. Although at that moment his (Z.V. Munayev)
participation in the correspondence was the most inactive, due to his distance from these issues, he now realises that
at that time the letters from the Central Bank of Russia to the Cyprus regulator must have taken place. Subsequently,
afer the correspondence, Linda verbally informed him (Z.V. Munayev) that she communicated with representatives of
the regulator, and they verbally confirmed the existence of letters, but showed only internal requests from
CYSEC(CySEC) to "QB Capital CY LTD" in Greek. In this correspondence R.V. Shpakov, due to uncertainty about the
source of the threat, instructs VS Pakhomov to find out the necessary information from the Central Bank of the
Russian Federation and settle the matter so that the letters would no longer arrive, and at the same time instructs
Linda to settle the matter on the territory of Cyprus so that they, for their part, would provide answers satisfactory to
the Russian Federation. Vladimir Pakhomov's communications with Linda clarifying the details of the requests, and
his responses indicating that he had the necessary resources at the regulator and the ability to verify all information
there, indicate both his awareness of the issue with the patronage of individuals at the CBR and his ability to resolve
certain issues if they actually existed. Linda's initiative involved risks in Cyprus, including for her as a representative
of the auditors, a nominee service company, and the manager of the licensed Constance Investment. Linda's
correspondence draws attention to the "sore spots" - the accounts at Piraeus Bank and Cyprus Development Bank
("CDB"), as these banks contained information about the actual beneficiary of the company - Shpakov R.V. The
correspondence also confirms his role as a signatory on the Cyprus side, indicating that Linda signed documents for
him. Some of his (Munayev Z.V.) messages in this correspondence were initiated by Shpakov R.V. in verbal
communication as well as written by him (Shpakov R.V.) personally from his (Munayev Z.V.) phone, namely, reassuring
Linda that they took her concerns seriously, did not fail to act, and in connection with her distrust of Pakhomov V.S.'s
words did confirm the common concern and efforts to resolve the issue on the side of the Russian Federation. The
correspondence confirms his (Munayev Z.V.) role as a nominee, possible disclosure of information on him instead of
disclosure of information on Shpakov R.V. The abbreviation ABB is Bank in Vanuatu ("Alpen Baruch Bank"). The
correspondence discusses V.S. Pakhomov's request to accept 2kk - (i.e. $2 million, dates just 2017, possibly
Borzenkov's money as he realises) into this bank. As a possible malefactor in relation to Shpakov R.V. is indicated a
client of the company and, according to information of Shpakov R.V., a former raider Stepanov Sergey, who at one
time initiated several applications and complaints, both in Russia and in Cyprus, as well as a court decision on arrests
of accounts of LLC "IC QBF" in Russia. Afer a certain period of time, he was paid the full amount of funds with profits,
as well as an additional amount on top for the "inconvenience caused".
(Vol. No. 306, pp. 1 - 8, 18 - 28, 47 - 50, 101 - 103, 104 - 108, 109 - 117, 147 - 157, 158 - 166, 168 - 178, 180 - 194, 196 - 210,
Vol. No. 307, pp. 1 - 50)
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- Protocol of confrontation between the accused Munayev Z.V. and the accused Golubev A.S.
dated 11.03.2022, according to which the accused Munayev Z.V. fully confirmed his testimony,
- Protocol of confrontation between the accused Munayev Z.V. and the accused Golubev A.S. dated 11.03.2022,
according to which the accused Munayev Z.V. fully confirmed his testimony, namely that Golubev A.S. worked in St.
Petersburg, started as a financial advisor, then, when achieving results and over time in about 2016 was promoted to
the head of the office of the company QBF in St. Petersburg. In this position Alexey's responsibilities included
fulfilment of the sales plan, hiring and working with employees, attracting clients, meeting standard KPIs. He (A.S.
Golubev) reported to Vladimir Pakhomov, who was the Director of the QBF branch network. A.S. Golubev was in
charge of the company's sales department in St. Petersburg, the head of the sales department and financial advisors.
A.S. Golubev could be invited to meetings with certain clients as an official, participated in negotiations with clients
and took part in interviews with applicants for staff positions. In the office of the city of. Golubev A.S. organised the
acceptance of clients for international market services and may have been a signatory to some contracts along with
Vladimir Pakhomov and other office staff. The office staff accepted clients' funds both non - cash and cash. Cash from
branches, including the St. Petersburg branch, was collected (picked up) and delivered for further transfer and
disposal by R.V. Shlakov in accordance with his (R.V. Shpakov's) instructions. On the territory of the office of the city of.
On the territory of the St. Petersburg office there took place the acceptance of cash from clients within the framework
of international market contracts. Their delivery to Shpakov R.V. could be carried out by a third person appointed by
him (Shpakov R.V.) from outside the staff by flying to St. Petersburg, also someone from the St. Petersburg office could
be sent by Golubev A.S. on the instructions of Shpakov R.V. or Pakhomov V.S. to Moscow to collect the funds. In the
same way cash withdrawals of clients' funds (return of funds to clients) took place, i.e. on the instructions of R.V.
Shpakov were delivered to St. Petersburg for further disbursement to financial advisors and transfer to clients. In the
office, cash receipts, expenditure cash vouchers, receipts for acceptance and disbursement of funds were drawn up.
These were standard documents for confirming cash turnover in the office. Part of the salary in QBF offices was also
paid in cash, and employees received cash in hand in accordance with their accrued remuneration. Withdrawals could
be made, among other things, through the employees' bank cards, to which Shpakov R.V. sent funds from his
company accounts for further withdrawal and disbursement to the employees. The competence of the head of the
office included determining the amount of salaries in his part and the amount of bonus remuneration for fulfilment of
targets. The system of accepting and disbursing client cash, as well as cash settlements with the company's
employees, had been in place at QBF since 2010. Cash could be sent to Golubev A.S.'s bank accounts for withdrawal of
these funds and disbursement to employees or Clients, depending on instructions received by Golubev A.S. from
Shpakov R.V. or Pakhomov V.S.. When accepting cash under international market contracts, the office manager was
responsible for, among other things, appointing an employee to travel to the Moscow office and hand over client
funds to Shpakov R.V. The employee was approved by Shpakov R.V. Golubev A.S., as office manager, organised the
standard procedure for accepting cash at the St. Petersburg office in accordance with the company's regulations
approved by Shpakov R.V. Cash for withdrawal to clients could be taken either from the St. Petersburg office or from
the St. Petersburg office. He (Z.V. Munayev) believes that A.S. Golubev, as well as all QBF employees working in the
international market sales units, was aware of the absence of a licence of QB CAPITAL CY LTD (QCCI) to carry out
brokerage activities and other activities necessary for working with securities in the order of organising interaction
with clients in the territory of the Russian Federation in view of his work in the licensed QBF LLC. Afer 2015, due to the
worsening situation with withdrawals of clients' funds, in terms of timing and procedures, the company had a
standard practice of accompanying the client in the process of post - sale service, including afer the submission of an
order for withdrawal of funds. This procedure was in place in all regional offices of QBF, including the office of Alexey
Golubev in St. Petersburg. St. Petersburg. The organisation of the work of the accountable employees in negotiations
with clients, both telephone and face - to - face meetings, the form of the information provided, the documents
required at these meetings, possibly reports and other explanatory documents, as well as the communication of
information on the documents required from clients to the company's sending banks (source of origin of funds,
certificate of non - criminal record, certificate of housing and utility services, letters of recommendation and other
documents) - was carried out by A.S. Golubev as head of the St. Petersburg office. Golubev A.S. as the head of the
office discussed with employees the claims received, the reasons for their occurrence, possible solutions and help to
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clients, defended the reputation of the company in the eyes of both clients and employees. A.S. Golubev could
participate in meetings with clients. As a rule, employees invited senior management to meetings with either
especially large or especially dissatisfied customers, as assistance in holding such meetings is necessary due to the
high negativity and high tension. The clients' claims were related to the timeframe for withdrawal of funds, which was
increasing. Golubev A.S. as the head of the office, in view of the instructions he received from Pakhomov V.S.,
informed clients and employees that this was due to the tightening of regulation of the financial market as a whole, as
well as a particularly scrupulous attitude due to sanctions to Russian clients and money of Russian origin, the need to
provide an increased and rather capacious set of documents, which was new to most. Also, a significant part of the
period was taken up by the procedure of selling off assets, which lengthened in time due to the deterioration of the
situation on the U.S. stock market compared to the period before 2014. This information was communicated to the
heads of all offices by Pakhomov V.S., further communicated to the employees of the offices by the heads of the
offices, further communicated by the employees of the offices to the clients. The initiative of transferring problem
clients from the branch, including the office in St. Petersburg, to the department accompanied by the client. St.
Petersburg, to the support department of the Moscow office. In the case of particularly large and problematic clients it
was coordinated with R.V. Shpakov. Due to the absence of branch management and lack of communication with the
clients of the branches and lack of authority to make any decisions with them, the information he received was based
on the data provided by V.S. Pakhomov and R.V. Shpakov;
(Vol. No. 306, pp. 212 - 221)
- Protocol of confrontation between the accused Munayev Z.V. and the accused Pakhomov V.S.
dated 11.03.2022, according to which the accused Munayev Z.V. fully confirmed his testimony
- Protocol of confrontation between the accused Munayev Z.V. and the accused Pakhomov V.S. dated 11.03.2022,
according to which the accused Munayev Z.V. fully confirmed his testimony, namely that Pakhomov V.S. started
working in the group of companies "QBF" in 2010 with the position of junior financial adviser. Subsequently, he was
promoted to the position of Head of Sales Department by R.V. Shpakov in 2011, and then was appointed to the
position of Head of the St. Petersburg office of QBF Group in 2013. Subsequently, when new offices were opened,
Pakhomov held the position of Director of the branch network of QBF Group. From 2013 onwards Pakhomov's direct
supervisor was R.V. Shpakov. V.S. Pakhomov's duties included fulfilment of the sales plan, development of sales
departments and branch network, recruitment of employees and office managers, ensuring business operations,
attracting clients and their support (clients - individuals and legal entities for international market services). V.S.
Pakhomov was subordinated to the heads of sales offices, which were managed by V.S. Pakhomov from his office in
St. Petersburg. V.S. Pakhomov was responsible for the fulfilment of key performance indicators of the offices, the
number of client meetings and the amount of funds raised. V.S. Pakhomov participated in meetings with clients, in
recruitment of employees for key positions (managerial positions in sales departments in the offices - branches of
QBF group of companies - LLC PC QBF, LLC MC QBF, LLC Q.Broker, KG LLC, QBF JSC, QF Estate SPb LLC, QF Estate EKB
LLC, QBF Capital SeaWay Ltd and other companies directly or indirectly owned by Shpakov R.V. Relations between
Pakhomov V.S. and Shpakov R.V. were close and trusting, Pakhomov V.S. followed the instructions and directions
received. Afer 2015, with the gradual appearance of delays in withdrawals of clients' funds, the branch network
started claim work, organised a document management system, tightened requirements to clients withdrawing
funds; provided additional procedures for meetings and negotiations with claim clients, especially with the key, the
largest, and the most negative ones. Since V.S. Pakhomov was responsible for work in the branches, he implemented
this system in the sales offices according to R.V. Shpakov's instructions and adjusted it depending on the situation on
the ground and private agreements with clients. The offices of QBF Group were located in St. Petersburg,
Yekaterinburg, Tyumen, Kaliningrad, Ufa and possibly other cities. Pakhomov V.S. had finished his work in the QBF
group of companies at the time of his detention, as of May 2021, Vladimir continued to work for QBF, including at the
Moscow office: he organised work there in the absence of R.V. Shpakov, carrying out his (R.V. Shpakov's) remote
assignments, including on the basis of new difficulties and tasks related to the criminal case. Pakhomov V.S.'s
393
remuneration, like that of other sales managers, consisted of a fixed and bonus part. The bonus part was paid as a
percentage of the amount of funds raised - funds raised by the previously listed offices, funds raised under
agreements on access to international stock markets and trust and advisory management agreements. Pakhomov
V.S. was also paid a percentage of remuneration from the total accumulated client portfolio. This payment may have
varied, but was subsequently fixed by him (Z.V. Munayev) and V.S. Pakhomov. The funds were raised both in cash and
non - cash form. Cash funds from all branch offices were sent on behalf of Pakhomov V.S. and Shpakov R.V. both to the
St. Petersburg office and to the Moscow office for disposal by Shpakov R.V. These funds were not fully credited to
trading accounts as they should have been: some funds were used to disburse previously invested funds of old clients,
as well as for salaries and bonuses of employees. This system was in place at all of QBF Group's offices. Couriers for
"encashment" of funds were appointed directly by R.V. Shpakov or V.S. Pakhomov in agreement with R.V. Shpakov.
Storage of client contracts, incoming and outgoing cash vouchers, receipts and other client documents was organised
and carried out by V.S. Pakhomov for clients of the QBF branch network. V.S. Pakhomov does not agree with the
testimony of V.S. Pakhomov in terms of his functionality, insists on his testimony, and adds that V.S. Pakhomov was
the signatory of contracts with clients on the international market and signed them personally during all terms of
validity of his powers of attorney. V.S. Pakhomov was a member of working groups in correspondence and meetings
and participated in management meetings on major issues of the QBF Group, made strategic decisions, participated
in telephone correspondence and chats and communicated instructions through them. On the role of Pakhomov V.S.
in solving the problems that arose during the audit of the activities of LLC IC QBF by the Central Bank of Russia, as
well as the role of Pakhomov V.S. when the company had problems with law enforcement agencies explained the
following: during the period of difficulties in the group of companies "QBF" with the withdrawal of clients' funds,
Shpakov R. V. assigned the task to Pakhomov V.S. to solve the problems with the withdrawal of clients' funds.V. set a
task for Pakhomov V.S. to organise lobbying of the company's interests, its protection with the help of patronage from
law enforcement agencies and the Central Bank of the Russian Federation (CBRF). V.S. Pakhomov, through his circle of
acquaintances and relatives, found the necessary people in law enforcement agencies and the Central Bank of the
Russian Federation, secured an agreement with them and ensured their continued work together with R.V. Shpakov
on a compensated basis. The funds were transferred to these persons in cash, including those transferred by
Pakhomov V.S. In the Central Bank of the Russian Federation these were representatives of the management, and in
law enforcement agencies - services that directly or indirectly had influence on the criminal case on Polezhaev A.'s
application. Client cash was received at the branches of the QBF group of companies under the direction of Pakhomov
V.S. It was received at the offices by company employees and along routes determined by Pakhomov V.S. and Shpakov
R.V., were delivered to the necessary offices, both for internal payments and for cash withdrawals to previously
attracted clients. Internal payments included salaries, bonuses, rent and other administrative expenses. Part of the
cash raised under international market contracts was not credited to international trading accounts, but was issued
and spent on current payments and cash withdrawals to old customers. Cash was also received from Russian and
foreign companies of Shpakov R.V. to QBF branches. These funds were spent under the supervision of Pakhomov V.S.
Also, some funds were regularly transferred to the bank cards of the employees of the branches under the order of
Shpakov R.V. and under the supervision of Pakhomov V.S. These funds were withdrawn from the bank cards, given for
salaries and withdrawals to clients. V.S. Pakhomov insists on his testimony regarding the role of V.S. Pakhomov in
encashment and cashing of funds from the group of companies "QBF", as V.S. Pakhomov was personally interested,
including in the acceptance of cash funds, as it depended on the issuance of their salaries, withdrawal of funds to
clients, relations with them in the key to investment, and the reputation of the company. Also, due to his circle of
acquaintances, Pakhomov V.S. sent potential nominees to the companies of Shpakov R.V. and to the lawyers of QBF
group of companies for companies owned by and related to Shpakov R.V. This was necessary for the continuation of
the company's activities during the crisis period, as well as for the development of the company in other periods of
time. Shpakov R.V. needed, among other things, nominees in key positions to unconditionally fulfil his instructions,
make expenditures and provide external cover for his activities. Shpakov R.V. sent these instructions, including to
Pakhomov V.S. Pakhomov V.S. was aware that QB CAPITAL CY LTD (QCCI) did not have a licence to carry out brokerage
activities and other activities necessary for working with securities. He repeatedly discussed it with him in personal
conversations, telephone correspondence. Pakhomov V.S. was aware of the problems related to the lack of a licence
at QB CAPITAL CY LTD (QCCI). This is evident both from the correspondence and was repeatedly discussed together
394
with Pakhomov V.S., with Shpakov R.V. and with other managers of QB Group. He (Z.V. Munayev) knows the following
about the role of V.S. Pakhomov in concluding the agreement(s) with M.I. Borzenkov, receiving money from the latter
and the subsequent interaction with him: on behalf of V.S. Pakhomov, international market services were offered to
the client Borzenkov with knowingly invalid conditions. This concerned both the reliability and return of his funds,
including their insurance, return on invested capital and other conditions. In addition to the standard international
market contract, the client Borzenkov was offered personalised contract terms by Kirill Sobolev on behalf of
Pakhomov V.S. in terms of returns to other accounts of Borzenkov and his companies, capital protection terms, and
income. When receiving funds from the client, Kirill Sobolev negotiated with him according to the instructions and
terms mentioned above from Pakhomov V.S. (according to Sobolev's words). Subsequent direct communication
between Pakhomov V.S. and the client Borzenkov could take place at his (the client's) repeated expansion of the
volume of invested funds, as well as subsequently at difficulties with the withdrawal of these funds and lengthy
claims work. At the conclusion of the contract with Borzenkov communication was directly Borzenkov with Kirill
Sobolev, he (Sobolev) personally confirmed this fact to him, and confirmed the fact of receiving instructions from
Vladimir Pakhomov. He (Z.V. Munayev) was notified by Roman Shpakov about the fact of subsequent co - operation
with Borzenkov on the part of Vladimir Pakhomov. Moreover, in oral face - to - face and telephone conversations (his
and Pakhomov's) we repeatedly discussed the existence of such a client and the stages of problematic negotiations
with him. He (Munaev Z.V.) did not make any decisions on this client, but he is aware that Shpakov R.V. gave personal
instructions to Pakhomov V.S. on all stages of interaction with this client. This client does not belong to the Moscow
office of the company, but is a client of the Ekaterinburg branch network. The fact of problematic negotiations is
available in telephone correspondence with the word "Borz". He insists on his testimony in this part. About the role of
Pakhomov V.S. in case of beginning of claim activity in the part of return of earlier deposited money of clients,
consisted in the following: in branches of group of companies "QBF" under the direction of Pakhomov V.S. the system
of claim work with clients, at which the term of withdrawal of their investments exceeded conditions of the contract,
was introduced. This system included requesting an excessive and redundant list of documents that lengthened the
period of withdrawal of funds due to both the long preparation of these documents by clients and the impossibility of
preparing some documents in principle. This system was communicated by Pakhomov V.S. to branch managers. The
managers trained staff on the system, regulated their work, and the staff ensured that the information was
communicated to clients. In addition to the source of funds and housing and utilities certificates, there were also
requests for letters of recommendation from banks, lawyers, sources of other income of clients, availability of
alternative identity documents, certificates in English and others. This request was sent to the clients to the
company's employees in order to formally send the documents received from them to the international back office for
submission to the sending banks, but in fact these requests and the whole procedure greatly lengthened the
withdrawal of funds due to delaying the whole process; (Vol. No. 306, pp. 222 - 233)
- Testimony of E.A. Rossieva, given to her as a witness, as a suspect, as well as in the capacity of
the accused,
- Testimony of E.A. Rossieva, given to her as a witness, as a suspect, as well as in the capacity of the accused,
according to which she did not admit guilt in the incriminated crimes and explained that she has no permanent
registration on the territory of the Russian Federation, she has been living since about 2014 on temporary registration
at the address: Moscow, Udaltsova Street, 4, sq. 230. She moved to Moscow in September 2005. In 2001 she graduated
from Krasnoyarsk State University with a degree in Law and in 1996 from Krasnoyarsk State University with a degree in
Applied Mathematics. She received her second higher education as an evening student. Since 1996 she has been
working as a lawyer related to civil law relations in various organisations. She studied English and improved her
professional qualifications, attended corporate lawyer courses at M - Logos. In the summer of 2017, she was officially
employed at QBF JSC as a lawyer. Her duties included legal support of QBF's investment and management company
in terms of professional activities on the securities market, as well as support of other civil law activities. In 2017, the
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General Director of the company was R.V. Shpakov. Her (E.A. Rossieva) direct supervisors were, from 2017 onwards,
S.A. Matyukhin, General Director of QBIF Investment Company LLC, and Y.G. Smirnova, General Director of QBIF Asset
Management LLC. She was instructed by R.V. Shpakov, General Director, to issue legal opinions on civil law matters. In
2018, the employees of QBef JSC resigned due to the commencement of liquidation of the organisation, including her.
In 2019, QBF was liquidated for corporate reasons. Since January 2018, she (Rossieva E.A.) was officially employed as
a lawyer in the JSC QBF Financial Group, which was the main company in relation to IK QBF LLC and KBF UA LLC. Her
(E.A. Rossieva) main responsibility was legal support of IC QBF LLC and CBF UA LLC on professional activities on the
securities market, asset management activities, contractual work, claims and litigation. The General Director of JSC
Financial Group QBF is R.V. Shpakov. In JSC Financial Group QBF its direct managers were also S.A. Matyukhin and
Ya.G. Smirnova. The proxy representatives of QB Capital LTD were citizens of the Russian Federation. The place of legal
and actual registration address of QB Capital LTD is Cyprus, she does not remember the more exact address. The main
activity of QB Capital LTD was to provide Russian clients with access to international financial markets in order to
profit from trading in securities on foreign markets. She has no information about QB Capital LTD's licences for
brokerage and investment activities issued by the Cyprus regulator, but according to the information available to her,
these activities did not require a licence. As it follows from the civil law contracts, which were sent by the former
clients of QB Capital LTD to the investment company as annexes to the claims, QB Capital LTD was not engaged in
brokerage activities. Gorobets, whose name and patronymic she (Rossieva E.A.) does not remember, was the general
director of QB Group LLC and QBF UA LLC. She (E.A. Rossieva) has known Gorobets personally since 2017, when they
visited a notary together to register corporate actions. Vladimir Georgievich Frolov was the general director of QBF UA
IC LLC from 2012, or from 2014, and until mid - summer 2017. Afer Frolov V.G., Matyukhin S.A. was hired as the
General Director of LLC IC QBF. Afer the dismissal of Frolov V.G., she (Rossieva E.A.) repeatedly communicated with
him on working issues. The company "Yurmaster" LLC was selected by her at the request of foreign consultants, who
were engaged in the support of civil law transfer of contracts concluded with clients to QB Capital LTD, namely for
legal reasons, in connection with the requirement of the Cypriot regulator, according to which the transfer of
contracts concluded with clients to QB Capital LTD should be made through the Russian structure, because part of the
clients are Russian citizens, with the subsequent submission of a report to the Cypriot regulator. She (E.A. Rossieva)
was responsible for financial settlements with part of the counterparties under the concluded contracts. The reasons
for the liquidation of OB Capital LTD are not known to her. The clients' funds were not transferred, QB Capital LTD
transferred the rights of access to the funds when transferring the contract. Such a transfer under Cypriot law, as it
was explained to her, did not require the consent of the clients. Clients were notified of the transfer of contracts to
another company by signature. The clients who provided funds to QB Capital LTD were provided with documents for
re - signing with "White lake", which were executed according to the dates of legal transfer of contracts, about which
the clients were notified by signature. The representatives under the power of attorney of "White lake" were Russian
citizens, whose data she (E.A. Rossieva) saw in the documents, but at the moment she cannot remember. The address
of registration of the company "White lake" is Caymans, she does not remember the exact address, she saw it in the
documents of the clients. The company "White lake" provides services on trust management of assets of individuals
and legal entities. She cannot list the licences of "White lake" issued by the regulator, but the reference to the licence
is indicated in the civil law contract with the client. Brokerage and investment activities are licensed under Russian
law, asset management activities are licensed under Cayman law. White lake has a business representative in the
territory of the Russian Federation, namely VL Consulting LLC. She (E.A. Rossieva) is personally acquainted with the
former CEO of VL Consulting LLC, Nikolay Padalko. A client of the Kyubi group of companies, who wished to
participate in trading on international stock markets, where White lake participated, was provided with an asset
management agreement with an investment declaration attached. The following persons at Kyubi Group of
Companies performed the following duties: Ruslan Valeryevich Spinka - former employee of QBIF LLC, sales manager
of the agency company K - Investment LLC; Grigor Razmikovich Erzikyan - employee of the agency company K -
Investment LLC; Nikolay Sergeyevich Padalko - former general director of VL - Consulting LLC, business representative
of White lake; Yuri Nikolayevich Orlov - manager of QBroker LLC; Amerov Rinat Feliksovich - Head of work with banks
and partners, General Director of JSC "Marketplace My Finance"; Plitin Vladislav Olegovich - Financial Advisor of K -
Investment agency company; Korzh Andrey Vasilievich - Head of Sales of K - Investment; Zaitseva Yulia Sergeevna -
Financial Advisor of K - Investment agency company; Meshkova Daria Yurievna - financial advisor; Frolov Vladimir
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Georgievich - former General Director of QBIF LLC; Pakhomov Vladimir Sergeevich - former member of QB Group LLC,
works in the regions; Yudin Maxim Stanislavovich - former financial advisor of QBIF LLC sales department; Shpakov
Roman Valeryevich - General Director and shareholder of JSC Financial Group QBF; Munaev Zelimkhan Visaitovich -
former participant of QBF Group LLC; Matyukhin Stanislav Anatolievich - General Director of QBF IK LLC; Gorobets
Elena Vyacheslavovna - General Director of QBF Group LLC; Lepeshkin Dmitry Sergeevich - former partner of Shpakov
R. V.В.; Атанасиаду Линда – аудитор кипрской консалтинговой компании «НОА»; Власов Павел Юрьевич -
финансовый советник в ООО «К - Инвестмент»; Соболев Кирилл Сергеевич - бывший директор филиала в
Екатеринбурге; Голубев Алексей Сергеевич - сотрудник агентской компании в г. Yaroslava Gennadyevna
Smirnova, General Director of KBF UA LLC; Yuri Vasilyevich Shaban, General Director and shareholder of Rif JSC;
Roman Valeryevich Feoktistov, Director of QBF LLC; Alexander Fedorovich Vozhzhov, marketing specialist; Ekaterina
Yuryevna Kozyreva, specialist of K - Consulting's department for work with banks; Ekaterina Nikolaevna Kharina -
Director of Investment Products Department of F - Experts; Elena Anatolievna Grabareva - former employee of one of
the agency companies for work with partners; Oleg Yuryevich Timokhin - Head of BEC office of QBIF LLC; (Vol. No. 290,
pp. 1 - 2, 11 - 22, 29 - 42, 61 - 71, 160 - 162, Vol. No. 291, pp. 109 - 113, Vol. No. 293, pp. 173 - 177, Vol. No. 340, pp. 70 -
73)
- The testimony of Pakhomov V.S., given by him as a witness, suspect, as well as the accused,
- The testimony of Pakhomov V.S., given by him as a witness, suspect, as well as the accused, according to which he
did not admit guilt in the incriminated crimes and showed that he graduated in 2013 from the St. Petersburg State
University of State and Management with a degree in finance and credit. St. Petersburg State University of State and
Management, specialising in finance and credit. Afer that he received qualification certificates from the FFMS -
Central Bank of Russia certificates: basic, 1.0, 5.0. In 2009, he got a job at Qube Finance, whose office was located on
Presnenskaya Embankment, BC Tropikana, Moscow. He does not remember the position in which he was employed.
The organisation was a licensed investment company and had three licences issued by the Central Bank of Russia. His
job description included the selection of a base for phone calls. The leaders of the organisation were three
shareholders: Sergey Lvovich Kuzin, Nikolay Modin and Roman Shpakov, who founded the company and opened the
first office. As far as he knows, the company had about 6000 clients in all directions, including partnership with banks.
He met Roman Shpakov about 4 - 6 months afer he started working for the company. They maintained a working
relationship and he offered him (Pakhomov V.S.) to buy a stake in the company. Some time later, around 2011, he (V.S.
Pakhomov) was appointed in this organisation as a deputy director for one of the company's areas. His duties
included the selection of premises for the opening of company offices in various cities of the Russian Federation,
communication with contractors, and general analysis of competitors in the cities where offices were to be opened.
Around 2013, Shpakov Roman finally bought out the shares of the other two shareholders, why they lef he
(Pakhomov V.S.) does not know, later both opened their own companies. At the general meeting Shpakov Roman
announced that he was ready to sell shares to the management in instalments of up to 9.99%, explaining that more
than 10% had to be approved by the Central Bank of Russia, and this required a large set of documents, to get a
package of more than 10% or equal to 10% of the company had to submit a candidate for approval to the Central
Bank of Russia with a lot of requirements for reputation and proven income. Around 2008, together with his mother
Likhina Elena Stanislavovna, he (Pakhomov V.S.) sold his flat, he still had some savings, so he thought about buying a
part of the company, as he considered it a good investment. They agreed with Roman Shpakov that he (V.S.
Pakhomov) would buy 6% in instalments for 5 years. He (V.S. Pakhomov) had a desire to see how the company was
developing and did not want to spend all the funds. They went to a notary on Presnenskaya Embankment and signed
a DCP (sale and purchase agreement). He ceased to be a shareholder in 2018, selling his share back to the company.
Until 2014, the organisation where he worked was called QB Finance Ltd, afer renaming around 2014, the company
became QBIF Investment Company Ltd. In mid - 2012, QBF decided to open a branch in St. Petersburg, for which
purpose he (V.S. Pakhomov) selected premises at the address: St. Petersburg, Maloohtinsky Prospekt, v. 64. 64. He
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also took part in the technical opening of branches of QBIF LLC in other cities. He may have been present at the
official opening of some branches organised by the marketing department of QBIF Ltd. He worked in the said position
until 2016 or 2017 (can't remember exactly). In 2016 or 2017 he lef the said company and worked for another
organisation. Afer a break of about 8 months at QBIF Ltd, he returned to the said organisation and started working as
a Development Director. His job responsibilities included analysing the competitor market. His immediate supervisor
was the CEO - in 2016 it was Frolov, and in 2017 he (Frolov) was replaced by Matyukhin Stanislav Anatolievich.
Matyukhin has a lot of experience, having worked for several years at Uralsib Management Company and before that
about 6 - 7 years at the Central Bank of Russia in the FSFM division - licence and certificate issuing activities. He
(Pakhomov V.S.) had a small group of analysts under him, who were constantly changing, as well as technical staff
who were engaged in consolidating information into a single table - as a rule, it was one person. He lef the company
in 2018, leading small projects not directly related to the company's operations, but related to some clients who
worked there. The projects involved developing financial models that were not related to investment activities. In
2018, he (V.S. Pakhomov) resigned from QBIF LLC at his own request, afer which he moved to St. Petersburg for
permanent residence, and there he advised persons on matters not related to investment activities. In November -
December 2020, he took a job at LLC Berezka, a chain of dental clinics in the Moscow region, as Managing Director.
The position involved travelling to other cities, and in fact he lived in St. Petersburg. Previously, he (V.S. Pakhomov)
had powers of attorney from LLC IK QBF, but he does not remember which ones. He is not familiar with the directors
and shareholders of White Lake Management Ltd, QBMF LLC, QB CAPITAL LTD, Simtelligence Company Limited, VL
Consulting LLC, WLM Ltd, but he has heard about some of these companies. At different periods of time, while he was
working in the company "QB IC" LLC, he (Pakhomov V.S.) could be approached by acquaintances and acquaintances
of acquaintances, who knew that he worked in the investment company as a director for strategic development and
knew that his tasks included studying the market conditions and investment products of the company, so they
wanted to get advice on investing money. He could introduce investment advisors from different investment
companies, who in turn would work with the client. He (Pakhomov V.S.) introduced his acquaintances to managers of
different companies and later these clients concluded contracts and bought different investment products in different
companies. He went to different investment forums, got acquainted with representatives of different investment
companies and could introduce them to his clients. He knows that there was a company "QB CAPITAL CY LTD" ("QCCI
LTD"), which is actually and legally located in Cyprus, and IC QBIF had an agency agreement with "QB CAPITAL CY
LTD" ("QCCI LTD") for a certain period of time. The contract implied that the companies were to supply each other
with clients, i.e., some sort of agency agreement for mutual interests. As explained by the representative of the
company who came to present products, the accounting support and administration of "QB CAPITAL CY LTD"
originated from Cyprus. The company provided agency services, and this organisation was headed by Kaznacheev
Alexey, whom he (Pakhomov V.S.) had seen once in his life. He (V.S. Pakhomov) knows that the company
"Simtelligence Company Limited" is registered in Hong Kong. The company similar to "White Lake Management Ltd."
is familiar to him, it is registered in Kaimakh, the company has a licence for professional investment activities. In
Russian companies non - cash transfer of funds to clients is possible, cash was accepted at the request of the client,
who was given a cash warrant, and then this money was collected in accordance with the established procedure,
which he (Pakhomov V.S.) does not know. The procedure of receiving dividends by clients under the concluded
contracts is described in each specific contract. Z.V. Munayev is familiar to him. They got acquainted with him
approximately in 2010 - 2011. He knows that Mr Munayev Z.V. came to QBF from an insurance company, as far as he
remembers it was called Reynisans. Munaev Z.V. was engaged in customer service over the phone, has higher
education, as well as FSFZ Basic 1.0 and AML/CFT certificates. Since 2013, he has been a shareholder of IK QBF LLC. He
(V.S. Pakhomov) is familiar with A.S. Golubev. As far as he knows, A.S. Golubev worked in LLC IC QBF as a director of
the branch network. A.S. Golubev's task was to attract clients for the products of the licensed company QBF LLC. A.S.
Golubev was hired by S.A. Matyukhin, General Director of QBF LLC. He (V.S. Pakhomov) was introduced to A.V.
Polezhaev by a mutual acquaintance whose details he does not remember. A.V. Polezhaev asked for help in finding
him (A.V. Polezhaev) oil products for delivery to the Republic of Kazakhstan. A.V. Polezhaev borrowed money from him
(V.S. Pakhomov) many times, for what amount he does not remember exactly. He (Pakhomov V.S.) does not have any
loan agreements or receipts on the transfer of funds to A.V. Polezhaev; (Vol. No. 294, pp. 3 - 7, 17 - 19, 49 - 53, 88 - 90,
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94 - 102, 112 - 115, 148 - 151, Vol. No. 295, pp. 205 - 213, 234 - 237, Vol. No. 297, pp. 247 - 249, Vol. No. 335, pp.
147 - 175)
- Protocol of confrontation between the witness Pakhomov V.S. and the witness Polezhaev A.V.
- Protocol of confrontation between the witness Pakhomov V.S. and the witness Polezhaev A.V., during which the
witness Polezhaev A.V. explained that he knows Pakhomov V.S., who is one of the managers of QB Finance LLC (QBIF
LLC). He has known him since about 2012 and was introduced to him by Sergei Loginov, whom he has known for more
than 15 years, was on friendly terms with him and had his own business. Loginov introduced him (A.V. Polezhaev) to
him in 2012 under the following circumstances: in 2012, he (Polezhaev, Sergei Loginov, Vladimir Pakhomov) met in a
restaurant in Moscow. The meeting implied his acquaintance with Pakhomov V.S., as earlier Loginov had told him that
he (Loginov Sergey) had an acquaintance who accepted cash as an investment. He was interested in this proposal, as
he had free cash at that time, as Pakhomov V.S. promised about 2 - 3 per cent of the deposited amount monthly in
cash. Also an important fact of his trust in Pakhomov V.S. was that earlier Loginov S. had also invested money. At the
meeting Pakhomov V.S. seemed to him a businessman who inspired confidence. Pakhomov told him how his business
was organised, which was to attract people with free cash to invest in his business, namely by buying and selling
securities and building apartment buildings. Around April 2012, he met with Pakhomov at the Ukraina Hotel, where
they agreed with him that he would hand over cash in the amount of $400,000 for the purpose of making a profit; they
did not sign any documents. V.S. Pakhomov did not write a receipt for the receipt of the money. About three months
later he received a phone call from Pakhomov V.S. asking if he still had cash, to which he replied that he did. Then, in
early June 2012, Pakhomov came to the address: 10 Birch Grove Drive, Moscow, where he (A.V. Polezhaev) was
working at the time. During the meeting, V.S. Pakhomov explained that it was necessary to invest more and reach USD
1,000,000, afer which his interest would increase. He was not embarrassed that they had not drawn up or signed any
documentation, as they had been introduced by a mutual acquaintance. In the period from June 2012 Pakhomov V.S.
personally paid him interest on the amount he had previously deposited, i.e. USD 600,000, the payments were made
in cash. All details were given to him by Pakhomov V.S. On 05.06.2012, Pakhomov V.S. called him and offered him to
invest additionally in the business project and to conclude an agreement with a foreign company and to deposit
additional funds in the amount of 1050,000 euros. Pakhomov V.S. justified it by the fact that this is a new project, in
which it is necessary to contribute more than 1 million dollars, it guarantees him (A.V. Polezhaev) a stable interest and
return on the invested funds. Afer brief deliberation he agreed with this proposal. He concluded an agreement with
the Cyprus company "QB Capital CY LTD". The contract was concluded on 05 June 2012. He signed this agreement
while in the office of QB Capital CY LTD, located in the building of the Moscow - City complex, at the address: 8
Presnenskaya Naberezhnaya Embankment, bldg. 1, Moscow. In this office he met Shpakov and Zelimkhan Munayev.
Pakhomov introduced Munayev to him as the commercial director of Qubey Finance LLC, and Shpakov as the deputy
general director of Qubey Finance LLC. V.S. Pakhomov explained to him that the Cyprus Company was an affiliated
company of Qubey Finance LLC. Pakhomov V.S. informed him that the funds should be transferred to the settlement
account of the Cyprus company, further Pakhomov V.S. informed him of the number of the settlement account and he
(Polezhaev A.S.) from his settlement account opened in a foreign bank in Germany, Berlin, transferred funds in the
amount of 1,050,000 euros to the settlement account of the Cyprus company "QB Capital CY LTD". At the signing of
this agreement Pakhomov V.S. was present, it was he who convinced him (Polezhaev V.S.) in the reliability of the
transaction, he also guaranteed him the return of the full amount and the interest due to him. Pakhomov V.S. also
guaranteed him the return of the full amount and the interest due to him (A.V. Polezhaev). Also Pakhomov V.S.
explained to him that in fact he had no risk of losing his funds, as the funds under clause 2.3 of the agreement were
insured with the Federal Corporation for Protection of Rights of Interests, within the framework of the system of
compulsory deposit insurance. Afer the lapse of time, he found out that there was no insurance. Roman Valerievich
Shpakov acted as a representative in this criminal case from the side of "QB Capital CY LTD". Also at the signing of the
contract on 05 June 2012 № 592 - 12/BP, there was signed an agreement on the provision of "Trust management"
services within the framework of the abovementioned contract. In this agreement the trustee on the territory of the
Russian Federation was LLC "Qubey Finance" (INN 7733673955), the agreement was also signed by Roman
399
Valeryevich Shpakov in the person of the Commercial Director of this company. In addition to this agreement was
signed Annex "Trust Management", where from the side of LLC "Qubey Finance" was signed by Shpakov R.V. During
the period of time from 2012 to December 2018, he was paid money as interest for the use of his money provided to
LLC "Qubey Finance" by him as an investment, these payments were inconsistent, with long intervals of time,
sometimes for 8 months he was not paid. All communication with him took place through Pakhomov V.S., sometimes
Pakhomov V.S. transferred money personally, sometimes through persons unknown to him (A.V. Polezhaev), who
were employees of LLC "Qubey Finance". Several times he also received money on his bank card from persons
unknown to him, representing themselves as employees of the St. Petersburg branch of Qubey Finance LLC. German
colleagues informed him that "QB Capital CY LTD" is liquidated, does not conduct any financial activity, also from the
Republic of Cyprus he was informed that "QB Capital CY LTD" on the territory of the Republic of Cyprus does not
conduct any activity, is currently liquidated. Around 2019, he had a meeting in the building of the complex "Moscow
City", at the address: Moscow, Presnenskaya naberezhnaya, 8, page 1 between him and Munaev, Shpakov and
Pakhomov. At this meeting, it was decided to return to him money in the amount of USD 200,000 for a period until 01
October 2019, until 01 November 2019 USD 200,000. Starting from 01 December 2019, USD 15,000 each month for a
total of USD 475,000 was returned to him, which was approximately 50% of the total amount of money he had
invested. He wrote a statement that he would have no claim afer the above amount was transferred to him. In
approximately October 2019, he received US$200,000 from Shpakov. Later, he became aware of Aslambek, who was
the brother of Munaev Zelimkhan, who said that he was related to Qyubi Finance LLC and was the supervisor of this
company. Aslambek then put forward the condition that he (A.V. Polezhaev) should transfer 200,000 USD to Aslambek
as security for the project. He called Shpakov and asked why Aslambek Munayev was demanding money from him, to
which Shpakov replied that Aslambek had the right to negotiate within the framework of the investment project. It
was Pakhomov V.S. who persuaded him to invest money in QB Finance (IK QBF LLC) and QB Capital CY LTD. V.S.
Pakhomov participated in all negotiations and promised to pay high interest. He persuaded in every possible way to
invest money in the development of the projects of the above companies. In 2017 - 2018, he (A.V. Polezhaev) learnt
that there was no brokerage account in his name. It was then that he realised that he had become a victim of fraud;
(Vol. No. 294, pp. 8 - 12)
- Protocol of confrontation between the accused Pakhomov V.S. and the witness Rykov D.I
- Protocol of confrontation between the accused Pakhomov V.S. and the witness Rykov D.I., during which the witness
Rykov D.I. fully confirmed the Testimony
previously given by him as a witness, namely, that in the group of companies "QBF" in Tyumen, he (Rykov D.I.)
actually began his labour activity at the end of 2016 in the position of director of corporate business. The group of
companies includes QBIF LLC, QF EstateSPB LLC, KBF LLC, QCCI, QB Capital, White Lake Management, VL Consulting
LLC, WLM, MC Asset Management and other companies, the names of which he does not remember. In LLC QF
"EstateSPB" in a certain period, dates he does not remember, the head was Pakhomov V.S., the head of LLC IC "QBF"
was Matyukhin S., in "White Lake Management" Korshunov, in MC Asset Management Smirnova. When the
representative office in Tyumen was officially registered in 2017, he was employed as the director of the Tyumen
branch of QBIF LLC. In fact, he worked in QBF Group until March 2020, but was officially dismissed only in April 2021.
He continued to work in QBF IK LLC until April 2021, while he carried out his activities until March 2020 at the request
of Pakhomov V.S., explaining that in case of change of the head of any branch of the Investment Company, the Central
Bank of Russia will conduct an inspection of the company and this fact is "inconvenient" for it (the company). In view
of this, he complied with V.S. Pakhomov's request not to write a resignation letter. Since March 2020, he has not
worked in the Tyumen branch, he resigned at his own request due to the aggravated situation on withdrawal and
return of funds of his clients, the emergence of distrust to the management and shareholders of the group of
companies "QBF". His responsibilities included managing the Tyumen branch, representing the company's interests
in Tyumen, searching for and hiring employees, conducting marketing activities in the Tyumen region, attracting
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clients and negotiating with them, organising the point of sale. Interaction was with the office located in St.
Petersburg (regional centre) and the central office in Moscow. From the beginning of his labour activity and until his
(D.I. Rykov) dismissal from the Company, his (D.I. Rykov) manager was V.S. Pakhomov. Subsequently, part of the
functions of company management in terms of regional offices was transferred to A.S. Golubev, and this was due to
the fact that V.S. Pakhomov switched to work in the head office in Moscow, where he was engaged in the development
of the entire group of companies "QBF". Nevertheless, the final decision - making on all key issues continued to
remain with V.S. Pakhomov. As R.V. Shpakov told him (D.I. Rykov) during the meeting in 2016, V.S. Pakhomov together
with Zelimkhan Munayev was a co - owner, i.e. a shareholder of the QBF Group of Companies. According to R.V.
Shpakov, he (R.V. Shpakov) together with V.S. Pakhomov and Z. Munayev are partners. This information was
communicated to him (D.I. Rykov), managers and employees of other branches in the cities of Kaliningrad, St.
Petersburg and Yekaterinburg. Shpakov R.V. informed him (Rykov D.I.) that Pakhomov V.S. was the director of the
branch network and that any questions concerning the activities of the branch network should be addressed to
Pakhomov V.S. Interaction between Pakhomov V.S. and him (Rykov D.I.) took place through personal meetings. Both
Pakhomov V.S. came to the Tyumen office and he (Rykov D.I.) to the central office in Moscow. Interaction was also
carried out through telephone conversations and messengers. From the beginning of the Tyumen branch activity the
main priority, which was set before the branch by the direct head Pakhomov V.S., was directed to foreign markets.
This direction was positioned by the branch staff as a strong point of QBF Group's work, that it is this direction that is
interesting for a potential client. Initially all the information about the products of QBF Group of Companies, about
the company's opportunities, was communicated to the employees in the Tyumen branch, as well as in other
branches by Pakhomov V.S. The decision on the possibility of concluding a deal with a potential client, on the format
of the deal (cash/non - cash) was made by the head of the regional network Pakhomov V.S. by means of verbal
negotiations and messages in messengers. Pakhomov V.S. organised interaction of functional divisions of the group of
companies with the branch in Tyumen to conclude transactions: back office, preparation of contracts. In case of cash
transactions Pakhomov V.S. organised cash collection from the branch to the regional centre of the company in St.
Petersburg and the head office in Moscow. As far as he (D.I. Rykov) was aware, a licence to conduct brokerage
activities was held by Whitelake Management, a company registered in the Cayman Islands. Qubicapital" and
"Quesiai" did not have such licences and, according to Pakhomov V.S., were not required to perform the function
assigned to these companies. These companies provided access to clients to place funds on international markets by
opening a trading account. There were instances when Pakhomov V.S. personally collected cash from the Tyumen
branch. One of such cases took place on 21.08.2019, cash in the amount of 15,000,000 rubles in front of witnesses
Chupin I.A., Ignatov Alexander Konstantinovich was transferred by him (Rykov D.I.) to Pakhomov V.S. afer concluding
a transaction with the client financial advisor Chupin I.A. The money was encashed to Moscow, where the company's
cash office was located. In January 2017, he (D.I. Rykov) was presented to him (D.I. Rykov) by V.S. Pakhomov. The cash
centre of QBF's head office in Moscow was a room with a money recalculation machine in it. He (D.I. Rykov) was
shown cash - in - transit orders, the order appointing Gorobets as the chief accountant of the company and assigning
her (Gorobets) the functions of a cashier. Pakhomov V.S. told about the possibility of concluding transactions with
clients with cash payment. During the period from 2017 to 2019 Pakhomov V.S. personally encashed cash more than 5
times. The other instances of encashment were organised by Pakhomov V.S., and afer 2018. Cash collection was also
organised by Yuri Orlov, Vladimir Maslennikov, Maxim Fedorov, Avetis Vartanov, Kirill Sobolev, Kirill Bogdanov, A.S.
Golubev. Cash collection from the Tyumen branch to Moscow and St. Petersburg was not formalised in any way. Afer
receiving cash from clients, the financial adviser who accepted the cash placed it for temporary storage in the safe of
the head of the office. Accordingly, the regional office in St. Petersburg already knew about the receipt of cash. Afer
that he (D.I. Rykov) received a message from the management of this office, depending on the period of time, from
V.S. Pakhomov or A.S. Golubev, in 90% of cases in messenger Vatsap about which of the employees would come to
collect the cash. Upon arrival of the courier, the money was handed over to the courier and the courier collected it. No
powers of attorney or transfer acts were drawn up when the money was handed over, as he (D.I. Rykov) was following
the instructions of his superior. Upon receipt of funds, afer encashment, the back office notified the Tyumen office, as
well as other branches, about the receipt of encashed funds. He (D.I. Rykov) was aware of cases of cash payments to
previously invested clients as dividends at the expense of funds received from new clients. On A.S. Golubev's
instruction, a part of the funds was paid to the client Y.A. Pisarev with funds received from a new client. As Golubev
401
A.S. explained, this was necessary to optimise the logistics costs of transporting cash. This issue, according to A.S.
Golubev, was agreed upon with V.S. Pakhomov. The use of funds inappropriately was made 2 times on Golubev's
order. In the second case, salaries were given to employees of the Tyumen branch. Golubev explained to him (D.I.
Rykov) that the money would be transferred to the clients' trading accounts from the accounts of QBEF group of
companies through mutual settlements between the companies; (Vol. No. 294, pp. 175 - 184)
- Protocol of confrontation between the accused Pakhomov V.S. and the witness Chupin I.A.,
- Protocol of confrontation between the accused Pakhomov V.S. and the witness Chupin I.A., during which the witness
Chupin I.A. fully confirmed his earlier testimony as a witness, namely, that in May 2017 in Tyumen, he (Chupin I.A.),
Rykov D. and Pakhomov V. were interviewed about his (Chupin I.A.) employment in the branch of QBF company in
Tyumen. Pakhomov V.S. introduced himself as a co - owner of QBF responsible for the regional network. In June 2017,
he (I.A. Chupin) started working as the Head of Investment Services Department of LLC KF Estate SPB in Tyumen. For
about six months, during the probation period, he worked under a service contract. In January 2018, he continued
working in the same position, but already under the employment contract concluded with him. The agreement on his
employment was signed on behalf of V.S. Pakhomov, CEO of LLC KF Estate SPB. In March 2021, he (I.A. Chupin) was
dismissed from OOO KF Estate SPB and employed by OOO IK QBF as director of the Tyumen branch. At that time, the
former director of the company, D.I. Rykov, resigned from the company and he (I.A. Chupin) replaced him. From 2017
until March 2021, his direct supervisor was the director of the Tyumen branch Rykov D. According to the organised
structure, his next supervisor was Pakhomov V.S. His (Chupin I.A.) duties as the head of the investment services
department of LLC KF Estate SPB included implementation of the sales plan, work with personnel, and work with
clients. As the Head of the Tyumen branch of QBIF LLC, his duties included the same duties as in his previous position,
only the duties related to the Tyumen office as a whole. In addition, he was responsible for the organisation of
interaction with the regional centre in St. Petersburg. He was in direct contact with Pakhomov V.S. at joint meetings,
communication with the Tyumen office staff when Pakhomov V.S. came there approximately once a quarter, as well as
at meetings in the regional centre in St. Petersburg. The QBF brand ("QBF"), as the Tyumen office positioned it during
training and presentations, included more than ten companies. Of these, he remembers QBF IK LLC, QBF Asset
Management LLC, QCCI Ltd, White Lake Management Ltd, WLM, SIMTELLIGENCE COMPANY LIMITED, QBF Advisers LLC,
QBF Advisory LLC, VL - Consulting LLC. The group of companies included both Russian and foreign companies. Also
construction companies were associated with QBF group of companies, i.e. QBF brand during the training seminars,
of which he remembers M1 Development LLC, Simon Jesso LLC. More companies related to construction were
mentioned, but he does not remember their names. Pakhomov V.S. made final decisions on employment of
employees of the branch network and in particular the sales department entrusted to him (Chupin I.A.), personally
coordinated all financial expenses related to the activity of the Tyumen branch - from consumables to purchase of
expensive office equipment, as well as marketing expenses. Pakhomov V. constantly monitored the fulfilment by the
Tyumen branch of its targets and communicated not only with the head of the Tyumen branch, but also with him
(Chupin I.A.) as the head of the department and ordinary financial advisors. V.S. Pakhomov had the broadest decision
- making authority in the branch network. He (I.A. Chupin) and D. Rykov gained experience in the investment sphere,
including qualification certificates, while working in the Tyumen office, learning during their employment with this
company, including in the course of training sessions conducted by V. Pakhomov and employees of the central
(Moscow) office of the company. The salaries of the branch employees, including the management staff, were fixed by
the career model approved by the central office and the regional network management, thus the motivation of
remuneration was approved, which implies payment of bonuses based on the results of the plan fulfilment. The
Tyumen branch 90 per cent of the time did not fulfil the basic criteria, so the branch employees did not receive
quarterly bonuses, but were satisfied with only a monthly salary. As explained to him (Chupin I.A.) by Golubev A.S.,
the amount of the unpaid bonus was distributed among the co - owners of the company, to whom he (Chupin I.A.)
refers Pakhomov V.S., Munayev Z.V. and Shpakov R.V. The Tyumen branch was only a separate subdivision in a
particular territory, therefore it was obliged to comply with the regulations prescribed by the centre of the regional
network in St. Petersburg and the central Moscow office. There were cases of cash deposits by clients, which occurred
only with foreign companies QCCI Ltd. or WLM. About 90% of contracts with foreign companies were accepted in cash,
402
both in roubles, euros and US dollars. Between 2017 and 2021, approximately RUB 400,000,000,000 - 450,000,000,000
was received in cash from customers in the Tyumen Branch in the rouble equivalent. The cash was accepted from
customers by the manager working with that customer. The funds were then deposited in a safe located in the office
of the director of the Tyumen branch. The director of the Tyumen branch informed Golubev A.S. or Pakhomov V.S. by
corporate email (before 2019 to Pakhomov V.S., afer 2019 to Golubev A.S.) of the transaction, indicating the contract
number, the client's full name and the amount of cash received. Within 24 hours from the address of the above -
mentioned heads of the branch network received an instruction on the procedure of cash collection, namely the data
of an employee of the group of companies, who was to come and pick up these funds for their transport to the central
office of the company in Moscow or St. Petersburg. These instructions could also be transmitted through
correspondence in managers, calls to mobile or fixed (working) phones. The money was handed over to the courier
from hand to hand, without any authorisation from the courier, in the building of the Tyumen office. The funds were
handed over without any transfer or accompanying documents. The funds were in the form in which the client had
handed them over, either in a bank wrapper or tied with a rubber band. The couriers transported the money in
ordinary briefcases, bags, backpacks. Upon receipt of the cash, the client was given a receipt confirming receipt of the
cash from the client, signed by representatives of QCCI Ltd. or WLM. From "QCCI Ltd." the receipts were signed by
Gorobets E.V., from "WLM" by Korshunov D.A., representatives of these companies by power of attorney. These
receipts together with customer contracts for the relevant product were received by the Tyumen office from the back
office of the regional network in St. Petersburg. He personally observed how cash was taken from the Tyumen office
and subsequently encashed by Yuri Orlov, Vladimir Maslennikov, Vladimir Pakhomov (on one occasion on 21.08.2019
in the amount of 15,000,000 rubles, received from the client Perevozkin V.V.), A. Golubev (1 time), Kirill Bogdanov,
Avetis Vartanov. He (I.A. Chupin) transported cash to the office in Tyumen about twice from the office in St. Petersburg
by order of A.S. Golubev and once from the central office in Moscow by order of V.S. Pakhomov. These funds were
intended for cash dividend payments to clients of the Tyumen branch;
(Vol. No. 294, pp. 185 - 192
- Testimony of A.S. Golubev, given by him as a witness, suspect, as well as the accused,
- Testimony of A.S. Golubev, given by him as a witness, suspect, as well as the accused, according to which he did not
admit guilt in the incriminated crimes and showed that he graduated from a higher educational institution in 2013
with a degree in "Engineer - technologist", "Engineer - designer". Since 2 February 2015, he worked in LLC "IK -
QueBiEF" in the positions of junior financial advisor, financial advisor, senior financial advisor, deputy head of the
investment services department, and since 2018, director of the branch of LLC "IK - QueBiEF" in St. Petersburg. In
2021, according to the entry in his labour book, he was dismissed at his own request, but in fact he was dismissed due
to the reduction of the company's costs at the initiative of S. Matyukhin, General Director of LLC IK QBEF. The regional
branches of LLC IC QBF were located in the cities of St. Petersburg, Kaliningrad, Yekaterinburg, Ufa, Murmansk,
Tyumen, Surgut. His (A.S. Golubev) duties as a financial advisor included: search and attraction of clients for
investment services, financial counselling of clients. In 2016 he had a power of attorney to represent the interests of a
foreign company registered outside the Russian Federation, which one he does not remember. Also in the period from
2018 he represented the interests under the power of attorney and was a signatory on behalf of IK QBEF LLC. The legal
and actual address of registration of QB Capital LTD is Cyprus, the main activity is capital management. The company
has no licences for brokerage and investment activities. He became aware of this fact afer the closure of QB Capital
LTD, in 2017 - 2018, afer studying the regulator's website. In 2015, he (A.S. Golubev) represented the interests of QB
Capital LTD on the territory of the Russian Federation. The following documents were provided to the client of QB
Group of Companies who wished to participate in trading on international stock markets: an agreement on providing
access to the securities market, a trust management agreement. In 2015, the trust management agreement was
drawn up on behalf of IK QBEEF LLC. Legal and actual registration addresses of "White Lake Management Ltd." -
Cayman Islands, the main activity of the company - asset management, trust management services. About the
company "SIMTELLIGENCE COMPANY LIMITED" he knows that the actual and legal address of registration was in Hong
Kong. He also knows that "QCCI Ltd." has actual and legal addresses of registration in Cyprus, the main activity of the
company is provision of trust management services. He learned about the absence of licences for brokerage and
403
investment activities at "QCCI Ltd." on the website of the regulator, when the company was liquidated. A client of QCCI
Ltd. who wished to participate in trading on international stock markets was provided with an agreement on
providing access to the securities market and a trust management agreement. In 2015, the trust management
agreement was concluded with Qubi Finance. The following persons worked in the Kyubi group of companies.
Vladimir Sergeyevich Pakhomov was a beneficiary (shareholder) of the company LLC "IC QBEEF", in fact he (V.S.
Pakhomov) in Q1 - 2 quarters of 2015 managed the St. Petersburg branch of LLC "IC QBEEF", which is located at the
address: St. Petersburg, Degtyarny pereulok, ul. 1 lit. "B" (in 2015 the branch was located at: St. Petersburg,
Maloohtinsky Prospekt, ul. 64). Further, in approximately 2019, V.S. Pakhomov was appointed Director of Strategic
Development of IK Qubief LLC in the Russian Federation. At present, V.S. Pakhomov does not hold any position in IK
QBEEF LLC, however, he appears from time to time at the office of the City of. St. Petersburg. In 2015, he (Golubev AS.)
was in the position of Junior Advisor of IK QBEF LLC and carried out instructions of his immediate superior - Kisin G.V.,
who held the position of Deputy Head of the Investment Services Department. Later he (A.S. Golubev) was in direct
contact with V.S. Pakhomov when he (V.S. Pakhomov) held the position of Director of Strategic Development of IC
QB&EF LLC in the territory of the Russian Federation. He (A.S. Golubev) was the director of the company's office in St.
Petersburg at that time. They (A.S. Golubev and V.S. Pakhomov) had periodic meetings in St. Petersburg and Moscow,
where V.S. Pakhomov consulted with him (A.S. Golubev) and set tasks for expansion of the company's branches in
other cities on the territory of the Russian Federation, discussed issues of the order of opening of the company's
offices, marketing issues, strategy of development of the company's branch network. Roman Valeryevich Shpakov has
been the main beneficiary (shareholder) of the company "Qubief" since about 2010 up to the present time.
Athanasiadou Linda has no relation to the Russian organisations of the company "Kyubey", he (A.S. Golubev) directly
received consultations from her on opening bank accounts in foreign banks, which took place at a personal meeting
in Moscow and in e - mail correspondence. Athanasiadou Linda's workplace is in Cyprus. Munaev Zelimkhan
Visaitovich was one of the beneficiaries of QB Finance Ltd. Ruslan Valeryevich Spinka is known to him as the person
responsible for the sales of IK - QBF LLC in Moscow. Nikolai Sergeyevich Padalko is an employee of the Moscow office
of a QBi company. Yuri Nikolayevich Orlov is an IT specialist in computer maintenance of the company. Rinat
Feliksovich Amerov was engaged in partnership programmes with banks in Russia in the period from 2019 to 2020.
Andrey Vasilyevich Korzh was responsible for sales in Moscow. He (A.S. Golubev) was in contact with A.V. Korzh on
products of IK QBEF LLC in approximately 2020, the communication took place via email. Yulia Sergeevna Zaitseva
was engaged in sales of the company's products in the period of approximately 2018 in Moscow. Vladimir Georgievich
Frolov worked as CEO of QB Finance Ltd. Maksim Stanislavovich Yudin was a financial advisor of one of the QBi group
of companies in 2015 - 2017. He (A.S. Golubev) was in contact with M.S. Yudin on trust management products of IK -
QBF LLC in 2017. Matyukhin Stanislav Anatolievich was the CEO of IK - QBF LLC from around 2018. He (Matyukhin S.A.)
is his (Golubev A.S.) direct supervisor. S.A. Matyukhin's workplace is located in Moscow in the central office of LLC "IR -
QBF". Evgenia Anatolievna Rossieva is known to him as a lawyer of the company. Dmitry Sergeevich Lepeshkin is an
employee of M1 Development and works with real estate. Elena Vyacheslavovna Gorobets is known to him from the
company documents as an accountant. Pavel Yuryevich Vlasov is a financial advisor of one of the company's groups
with a workplace in Moscow. Kirill Sergeyevich Sobolev Director of the branch in Ekaterinburg, he worked until 2017 -
2018 in the company PA "IK - QBF". Yaroslava Gennadyevna Smirnova is the General Director of LLC "MC QBef. Asset
Management". Yuri Vasilyevich Shaban was engaged in real estate. Ekaterina Nikolaevna Kharina is a product
specialist at LLC "IC QBIF", working in the company since about 2019. Oleg Yuryevich Timokhin is an employee of LLC
"IC QBIF. He (A.S. Golubev) met I.A. Borzenkov in Ekaterinburg on the issue of creating a fund. At the meeting he (I.A.
Borzenkov) said that he (I.A. Borzenkov) was interested in bonds and he (I.A. Borzenkov) had the task of accepting
capital abroad. He (A.S. Golubev) drew I.A. Borzenkov's attention to such an instrument as a personal investment
fund. Borzenkov I.A. asked him (Golubev A.S.) to prepare information about this instrument, and he (Golubev A.S.)
collected and sent this information to Borzenkov I.A. by e - mail. Later on, he (A.S. Golubev) and B.G. Pechersky met
him (A.S. Golubev) in Kaliningrad in about 2017 and discussed his (B.G. Pechersky's) assistance in opening an office of
IK - QBF LLC in Kaliningrad. B.G. Pechersky gave him (A.S. Golubev) recommendations on who to meet in the city in
terms of potential clients and partners. He (A.S. Golubev) was introduced to B.G. Pechersky by S.N. Blik, who was the
head of the office in Kaliningrad, introducing B.G. Pechersky as an influential person in Kaliningrad. The regional
office in Kaliningrad was located in the building of a business centre, the address of which he does not remember.
404
Meetings with clients took place either in the office of OOO IC QBF or, at the client's request, in a restaurant.
Sometimes meetings took place at the client's place of work or at the client's (client's) place of residence. The
meeting places were always agreed with the client. He (A.S. Golubev) personally received cash from the client "hand -
to - hand" once in St. Petersburg from a client named Egudkin. Sergei Blik, director of the branch office of OOO IC QBF,
received cash from the company's clients in Kaliningrad. About three times he (A.S. Golubev) transported cash from
Blik S. to St. Petersburg. The client was given a cash - in - transit order as a result of the cash transfer. The order had a
number and was part of a standard trust management agreement concluded with the client. All documents of the
standard agreement were scanned, scans were sent to the mail of the companies with which the agreements were
concluded. In the corporate programme "ECRM" the data on receipt of money from the client were entered. The
above - mentioned facts of receipt of money from clients by him (A.S. Golubev) concerned a company located in the
Cayman Islands. Subsequently, from St. Petersburg the money from the above mentioned clients was sent by courier
to Moscow. The couriers arrived afer the information about the concluded transactions was sent from e - mail to the
Cyprus company "QB Capital (QCCI)" or "WL Management LTD" (Cayman Islands). The money was handed over to the
visiting couriers afer they voiced a verbal password. There were several instances of money being handed over when
the courier provided a written power of attorney. The verbal passwords were sent to him by S.A. Matyukhin or R.V.
Shpakov in Telegram messenger. Sometimes the passwords came from unknown numbers, but the subscribers'
numbers were confirmed by emails from QB Capital (QCCI) or WL Management LND;
(Vol. No. 298, pp. 1 - 16, 32 - 33, 39 - 43, 64 - 69, 101 - 104, Vol. No. 299, pp. 155 - 161, Vol. No. 301, pp. 222 - 226, Vol. No.
347, 106 - 109)
- Protocol of confrontation between the accused A.S. Golubev and the witness D.I. Rykov
- Protocol of confrontation between the accused A.S. Golubev and the witness D.I. Rykov, during which the witness
D.I. Rykov fully confirmed the testimony previously given by him as a witness, namely, that in LLC IC QBF he was
officially the director of the branch office in Tyumen from July 2017 to 1 April 2020. Until 2019, his manager was
Pakhomov V., who organised the branch office in Tyumen; he (Pakhomov V.) also employed him (Rykov D.I.). Around
the end of 2018, beginning of 2019, he (D.I. Rykov) learnt from V.S. Pakhomov that the regional office would be headed
by A. Golubev. S. and from that moment he was already subordinate to the latter. During the operation of the Tyumen
office, he personally addressed A. Golubev on all issues related to the Company's activities since mid - 2018, and
received answers from him (A.S. Golubev), namely, issues of concluding and closing transactions, structuring
transactions, legal issues of registration, KPI issues, staff motivation and other issues. A.S. Golubev's duties included
setting planned tasks for the branch, operational management of the branch network, control over the
implementation of plans to attract clients, training of staff (including new employees), organisation of contacts with
specialists of QBF Group on issues arising in the course of operations. In 2017. QBEF IK LLC worked in "liaison" with
QB Capital located in the Republic of Cyprus. At the end of 2017, it became known that QBi Capital was liquidated and
its legal successor was Qusisiai. This information was communicated by Munaev Zelimkhan in the course of
communication via VCS (video conferencing communication). Later on there appeared another group of companies:
Whitelake Management, Simtelligence and a number of functional companies (VLM, VL Consulting), performing a
certain function in the chain of interaction between the client on the territory of the Russian Federation, transfer of
funds abroad and management of these funds by QBF Group. He had no information about whether or not QB Capital
had any licences. QCF did not have a licence to carry out brokerage activities and, according to the information of the
employees of the offices in Moscow and St. Petersburg, did not need such a licence, as the company was merely
acting as an agent for the placement of clients' funds abroad. In general, information on the presence or absence of
licences of companies outside the Russian jurisdiction was communicated by the management of the head office and
regional centre through electronic correspondence, information on network discs and as part of training procedures
(in - person and remote). He is aware of cases of cash deposits by clients. The predominant majority of clients' funds
received in cash were accepted by financial advisors and kept in a safe at the Tyumen regional office. Clients, upon
receipt of cash from them, were given a cash - in - transit order executed on behalf of foreign companies: QCB Capital,
405
QCI, VLM. During the period of the branch's operation, approximately 300 - 400 million roubles were received from
clients in cash. The money was taken from the Tyumen office by employees of offices in Moscow and St. Petersburg.
Of these employees he remembers Yuri Orlov, Maxim Fedorov, Vladimir Maslennikov, V.S. Pakhomov, A.S. Golubev,
Kirill Bogdanov. He does not know where the money was collected. The instructions to collect the money were given
verbally during telephone conversations and via messengers. Instructions on collection of funds and the person to
whom they were to be transferred were received from Pakhomov V.S. and Golubev A.S. Cases of payments of funds to
previously invested clients as dividend payments at the expense of funds received from new clients and use by the
company of funds received from clients for other purposes not related to brokerage activities were present, but it
happened infrequently. Such payments were related to the optimisation of logistics in carrying out couriers' activities.
Sometimes it was necessary to pay out funds to a client (dividends, partial/full closing) and for this purpose newly
received funds of another client were used. This eliminated the cost of courier services. Once there was a case of
payment of salaries to employees in the Tyumen office out of cash received from a client;
(Vol. No. 299, pp. 162 - 169)
- Protocol of confrontation between the accused A.S. Golubev and the witness I.A. Chupin
- Protocol of confrontation between the accused A.S. Golubev and the witness I.A. Chupin, during which the witness
I.A. Chupin fully confirmed the testimony previously given by him as a witness, namely, that since June 2017 he
started working as the head of the investment services department of LLC CF "EstateSPB" in the Tyumen branch.
Since March 2021, he was employed by LLC IC QBIF as the director of the Tyumen branch, as the former director of the
campaign, D.I. Rykov, resigned from the campaign. Since 2017, his (Chupin I.A.) immediate supervisor was the director
of the Tyumen branch Rykov D. Around the middle of 2019, when Rykov D. switched to the work of the branch in
Surgut - working on the opening of other "northern" offices, he (Chupin A.S.) was assigned by Golubev A.S. to deal
with the activities of the Tyumen office as a manager, with the prospect of being appointed director. At that time he
started to have regular contact with A.S. Golubev. He (A.S. Golubev) replaced V. Pakhomov, the director of the branch
network of the QBG group of companies, who had moved to another position. He (I.A. Chupin) was actually, i.e.
officially appointed to the position of Director of the Tyumen branch in March 2021. A.S. Golubev was contacted by
telephone or video link. Approximately once a quarter, face - to - face meetings were held at the regional office in St.
Petersburg. The decision to hire him (I.A. Chupin) was not made by S. Matyukhin, who was only the signatory of the
relevant order. He believes that the decision to appoint him as the director of the Tyumen branch was made by A.S.
Golubev. Since about 2017, clients have been offered trust and advisory management services by the Cyprus - based
company Kiusiai, and since about the end of 2018 by the Cayman Islands - based company Wightlakechange.
Whitelakechange did not have a licence, but only a registration in the register of the local regulator, the Cayman
Islands Department of Money Circulation. It also offered brokerage services to Constancy Investment, a company
based in the Republic of Cyprus. Since his employment there have been cases of receiving cash from clients both in
rubles and in foreign currency. Cash deposits by clients were made only under contracts with foreign companies.
Under contractual relations of clients with foreign companies, cash deposits were about 80 - 90% of the total amount.
Cash was accepted by managers who worked with the client and then placed in a safe in the Tyumen office. Clients
were given receipts for accepting cash on behalf of the foreign companies Cuspiai and VLM. In particular, when he was
(without an official appointment) the head of the regional office, through the corporate mail of the group of
companies, information (message) was sent to Golubev A.S. about cash receipts and their amount. Immediately, or
afer a short period of time, Golubev A.S. was instructed (by e - mail) to hand over the cash to a certain employee of
the QBF group of companies who was to arrive for it. The exchange of information on cash collection with Golubev
A.S. was also made by means of telephone conversations and messages in messengers, where the data of this
employee were also indicated. The funds were subsequently transferred to him "from hand to hand", without any
transfer documents. The management of the head office explained that the cash was subsequently transferred to the
client's personal account. Pakhomov V., Orlov Yuri, Maslennikov Vladimir, and several times Kirill Bogdanov personally
collected the cash. A.S. Golubev was in the office in Tyumen once and, as it seems to him, collected cash once. When
406
he (I.A. Chupin) was the head of the Tumen office, dividend payments were made from the cash received from clients.
He received the order to pay dividends from Golubev A. There was also a case of giving the clients' cash to the office
staff as a bonus (bonus) accrued earlier;
(Vol. No. 299, pp. 170 - 177)
- The testimony of S.A. Matyukhin, given by him as a witness, suspect, as well as the accused
- The testimony of S.A. Matyukhin, given by him as a witness, suspect, as well as the accused, according to which he
did not admit guilt in the incriminated crimes and testified that in 2008 he graduated from the Moscow State
University of Instrumentation and Informatics with a degree in "optical technologies and materials", in 2009. - higher
education institution with a speciality in "finance and credit". From 2007 to 2014 he worked at the Federal Financial
Markets Service. From 2007 to 2009, he worked as a 1st class specialist of the Housing Construction Organisations
Division of the Department for Regulation and Control over Collective Investments, which is a structural subdivision of
the Federal Financial Markets Service. From approximately 2010 to 2011, he worked as a chief specialist - expert of the
housing construction organisations department of the department for regulation and control over collective
investments, which is a structural subdivision of the Federal Financial Markets Service. From 2012 to 2013, he worked
as an advisor to the Department of Regulatory and Methodological Support of the Collective Investment Industry of
the Department of Regulation and Control over Collective Investments, which is a structural subdivision of the Federal
Financial Markets Service. From 2013 to 2014, he worked as Deputy Head of the department for licensing of joint -
stock investment funds of management companies, specialised depositories and non - state pension funds of the
Financial Market Admission and Register Management Department. In 2013 - 2014, the functions of the Federal
Financial Markets Service were transferred to the Central Bank of Russia. Afer he resigned from the CBR in
approximately 2014, he worked at JSC Uralsib Management Company as Deputy General Director - Controller, where
he was engaged in the implementation of functions related to the company's internal control to prevent violations of
the securities market legislation. He worked in this position until his dismissal in 2017. In this regard, in 2017, he
posted a CV on the Head Hunter classifieds site on the Internet, in which he indicated his CV and employment history,
afer which he was contacted by a representative of QBF, Svetlana Beloded, on the mobile phone number indicated in
the advertisement, and invited to an interview for the position of Deputy General Director - Controller. The interview
took place in the office of QBF, located in BC "Moscow City", located at the following address: Moscow, Presnenskaya
nab. 8, p. 1, floor 9. 1, floor 9. His first interview was conducted by Beloded S., afer which he was interviewed by Yuri
Minaev, Deputy General Director of QBF Management Company LLC, and Dmitry Kipa, Director of the Investment
Banking Department, both of whom were employees of QBF Group. He (S.A. Matyukhin) was then interviewed by
Zelimkhan Munayev and Roman Shpakov, managers of QBF Group. Afer the interview he was interviewed by Vladimir
Pakhomov, who also belonged to the management of the QBF group of companies. Based on the results of the
interviews, he (S.A. Matyukhin) was hired as the General Director of LLC Investment Company QBF. On 25 July 2017,
he was appointed to the position of General Director of QBIF Investment Company LLC (QBIF Investment Company
LLC) on the basis of the Decision of the sole participant of QBIF Investment Company LLC - KG LLC ("QBIF Group")
represented by Elena Olegovna Gorobets. Approximately on the same day he received this decision, signed in his
absence by E.O. Gorobets. His salary was initially 100,000 roubles per month and then 200,000 roubles per month. His
duties as general director of LLC "Investment Company QBF" included general management of the organisation's
activities within the framework of licensed activities. From the moment of his employment as CEO, he immediately
began to exercise full management of LLC Investment Company QBF and exercised it until the introduction of the
temporary administration in 2021. He himself managed the organisation, made all decisions, determined the
direction and conducted the financial and economic activities of the company. All documents were signed only by
him, or by persons authorised to sign in his absence: Anastasia Koval, Operations Director, or Alexander Koloskov,
Broker. At the time he was hired, he had about 15 - 20 people under his command, and then the staff increased to 40
people. The organisational structure of QBIF Investment Company LLC included the following divisions: Internal
Control Service with Butkovskaya Vladislava as its head; Asset Management Department with Korolenko Alexey as its
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head; Depositary Operations Department with Tomara Elena as its head; Financial Market Support Department with
Timokhin Oleg as its head; Midloffice with Kopylova Maria as its head; Anti - Money Laundering and Counter -
Terrorism Financing Department with Head N.N. Koloskov as its head. On his behalf as the General Director of LLC
Investment Company QBIF, powers of attorney in simple written form were executed for the heads of the branches in
the above cities, but these powers of attorney provided for the authority to conclude contracts within the framework
of professional activities (i.e. activities carried out on the basis of a licence). He remembers Alexey Golubev (St.
Petersburg), Rykov (Tyumen), Iskhakov (Yekaterinburg), Artem (he does not remember his surname, the head of the
Kazan branch) and the head of the Murmansk branch (he does not remember his details as he saw him once). The
office of LLC Investment Company QBF and, accordingly, his (S.A. Matyukhin's) workplace was located in BC "Moscow
City", located at the following address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, floor 11. 1, floor 11. The said
organisation was engaged in trust management of assets of management founders, i.e. clients' assets, brokerage
activities, depositary activities, dealer activities, as well as activities of an investment advisor. When concluding a
brokerage services agreement, the client signed a statement of adherence to the regulations on brokerage services
(signed unilaterally due to the very concept of adherence agreement as a type of agreement). Further the client
determined the section and types of transactions, in respect of which he plans to be serviced (by marking in the form
established by the company). Further, depending on the types of transactions, a qualification procedure was carried
out in relation to the clients and on the basis of their application, afer which the client submitted orders for execution
of transactions. Brokerage activity is understood as the activity of executing clients' orders. Accordingly, further on
submission of an order by the client, the broker was obliged to execute it, i.e. he executed it in exact accordance with
the terms of the order. There were two procedures for concluding contracts: in writing (in person) and by means of a
remote electronic signature. On his (S.A. Matyukhin's) side, no signature was required by law for either of these
procedures. When concluding the agreement in writing, the Regulations on Brokerage Services used his (S.A.
Matyukhin's) signature (facsimile) on the application for accession, which was affixed in some cases and not affixed in
some cases. The Regulation on rendering brokerage services by QBIF Investment Company LLC was placed on the
website of QBIF LLC and is a public offer. Under this type of agreement, at least once a quarter, according to the
regulations, it is stipulated to send to the client reports on the status of clients' accounts. The reports were
automatically uploaded from the internal accounting database and sent to the clients. His task as the General Director
was to monitor the timeliness of the reports, their content (availability of all necessary items for the report, reliability
of the information provided to the client, absence of misleading the client). These reports were sent to clients without
his signature, but in the manner prescribed by the regulations, namely from the company's e - mail specified in the
regulations to the client's e - mail specified in the questionnaire at the conclusion of the contract. When the Client
requested a report (for example, to confirm the costs of transferring assets to another broker, for the tax inspection
and for other purposes), the report was generated by the back office manager (Timokhin Oleg) and sent to the Client
signed by the relevant manager (Timokhin) and with his (Matyukhin S.A.) "live" signature. He could also put his
signature in response to another request from the Client. Around 2019, the "NABIX" system of remote customer
acceptance appeared. According to this system, all documents were signed by the customer using his electronic
signature, and an application for joining sent to the company's email could thus have his signature affixed to it.
Individual reports on request and responses to various client enquiries were sent to clients with his "live" signature.
QBIF Investment Company LLC operated under licences issued by the Federal Financial Markets Service and the CBR.
Funds were transferred to the company from the client's settlement account to special accounts opened by the
company as part of its licenced activities. There were clients who, as part of their activities, brought cash, which was
passed through the cash desk and cash receipt documents were issued for it. The company's settlement accounts
were opened with Sberbank of Russia, VTB, Alfa - Bank, Bank Otkritie, Tinkoff - Bank, Bank Uralsib and NSD. He and
Olga Vasyukova, the chief accountant, had access to the organisation's current accounts (afer her duties were
performed by Daria Filina". The ultimate beneficiary of the organisation's activities is Roman Shpakov, who is the
100% owner of the share of the founder of JSC Financial Group QBF, i.e. the company JSC Financial Group QBF.
Clients were attracted to QBIF Investment Company LLC in the following way. There were clients who came to the
company independently, i.e. received information on the Internet site or from other open sources. There were also
clients who came on recommendation and there were agents, i.e. legal entities that were engaged in attracting
clients. In addition, there were clients who were attracted through banks. The procedure of execution of contractual
408
relations with the client was carried out either remotely, i.e. through the Nabix programme, which was accessed by
agents and provided by potential clients, or in person at the office of QBIF Investment Company LLC. The preparation
of contracts was handled by "midlofis" employees. The group of JSC "QBF Financial Group", i.e. the parent company
owned by R.V. Shpakov, also includes: LLC "QBF Investment Company", i.e. the organisation where he (S.A. Matyukhin)
is the CEO, LLC "QBF Management Company", the head of which is Yaroslava Smirnova, and other companies that R.V.
Shpakov used in his activities. Around the end of 2017, he became aware that QBF had contractual relationships with
individuals for the provision of "trust management" services, with the funds of these clients being accepted by the
Cypriot jurisdiction, QB Capital Limited (later renamed QBCI). The funds were not returned to these clients, the return
of funds was delayed, and there were numerous complaints from clients. This scheme of dealing with clients was
illegal and put the licence company IK QBF Ltd at risk. He reported about it to R.V. Shpakov, Z.V. Munayev and V.
Pakhomov. They made a decision to change the scheme of work in foreign jurisdictions, OOO IK QBF was completely
removed from contractual relations, the Cyprus company QB Capital Limited was decided to liquidate. Simtelligence
Company Limited and White Lake Management Limited, QB Adviser LLC, VL Consulting LLC were established in their
place. This decision could have been made by the management: Shpakov, Munayev, Pakhov, Athanasiadou Linda. In
October 2017, a decision was made to reorganise QBIF Investment Company LLC in the form of a spin - off, i.e. QBIF
LLC was spun off from QBIF Investment Company LLC. KG LLC was the sole participant of QBF LLC. Feoktistov was
appointed General Director of QBF LLC. The list of creditors was formed for about half a year. The rights and
obligations under previously concluded contracts were transferred to QBF LLC as a result of the reorganisation.
Information about the reorganisation was disclosed within half a year, during this time no objections from creditors or
any of their claims were received by QBIF Investment Company. The notification was carried out by means of
information disclosure on the website through the information resource established by law ("Vestnik"). Afer the
reorganisation, the company "QBIF Investment Company" continued to carry out professional activities. In 2017, the
Company was audited by the Central Bank of the Russian Federation. Based on the results of this inspection, the Bank
of Russia identified violations of its activities. It eliminated these violations and the company continued to operate.
Starting from 2018, work with clients in a foreign jurisdiction was organised as follows: a client who came to IC QBF
LLC entered into agreements on providing access to international trading platforms with Simtelligence Company
Limited and White Lake Management Limited; the client also entered into agreements on providing "trust
management" services with QB Advisor LLC, VL Consulting LLC. Numerous complaints were also received from clients
regarding non - return of invested funds or significant delays in return. And since the client was informed by
managers: Spinka R., Padalko N., Maslennikov V., when concluding the above agreements that all these organisations
were affiliated to IC QBF LLC, the client wrote complaints to supervisory and law enforcement authorities, referring to
IC QBF LLC. The following persons were aware of the activities of the foreign jurisdiction and made decisions within
their competences: R. Shpakov, Z. Munayev, V. Pakhomov, E. Rossieva, Athanasiadou Linda and sales managers R.
Spinka, N. Padalko, Maslennikov V. In his activity Shpakov Roman Valerievich used other organisations: JSC Financial
Group QBF, JSC Marketplace My Finance, JSC RIF, LLC VL - Consulting, LLC Indep Smart, LLC Investment Company
QBF, LLC CBF Asset Management, LLC KG, LLC K - Investment, LLC K - Consulting, LLC KF Estate SPB, LLC Q.Broker, LLC
Quby Group, LLC Quby Credit, LLC Qubyef Advisory, LLC Qubyef, LLC Qusisiai, LLC Millhouse Invest, LLC Profi, LLC
Rentinvest, LLC Severspetsstroy, LLC Simon Jesso, MC Granat LLC, F - Management LLC, F - Technologies LLC, F -
Technologies LLC, F - Expert LLC, PJSC Venture Finance Centre, White Lake Management Ltd, QB Capital (later QCCI),
Simtelligence Company Limited. Some of the above organisations were used in financial activities, some in
development projects, some of the above organisations had auxiliary functions in conducting business projects.
Munaev Zelimkhan was responsible for expanding the client base in Moscow and Pakhomov Vladimir was responsible
for expanding the client base in the regions. Linda Athanasiadou was in charge of the foreign part of Shpakov R.'s
business, including Cyprus. Evgenia Rossieva was responsible for legal support of contractual relations between White
Lake Management Ltd, QB Capital (later QCCI), Simtelligence Company Limited, IK QBF Ltd, QBF Advisers Ltd, VL
Consulting Ltd and clients. Direct interaction with clients was carried out by employees of the Sales Department, the
head of which, since 2020, was Ruslan Spinka. Sales managers were, among others, Korzh Andrey, Maslennikov
Vladimir (afer 2018 transferred to the client support department), Padalko Nikolay (until 2018), Golubev Alexey,
Vlasov Pavel (until 2018). The activity of raising money from citizens, according to R. Shpakov, was organised since
2012. From about 2014 onwards, problems with cash payments to clients began to arise. The money was not returned
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to some clients, some clients were returned with significant time delays. And by that time the flow of incoming clients
had multiplied. Problems with the return of funds to clients began because of the start of Shpakov R.'s development
project to build a cottage village "Gribovsky les" in the Odintsovsky district. Shpakov R. could use the funds from the
investment area specifically in a foreign jurisdiction to close financial expenses in the construction project. The
motivation of the employees of the sales department was directly related to the fulfilled plan for attracting clients and
interest from the amounts deposited by citizens. Part of the financial flows from the activity of raising funds for the
foreign jurisdiction could be distributed between Shlakov R., Munayev 3., Pakhomov V., Linda A.. In cash raising
activities prior to the beginning of 2018, Shpakov R., Munayev 3., Pakhomov V., Linda A., QB Capital (later QCCI) and
QBIF LLC were used by each of them within the framework of their functional duties, afer 2018 the licensed
organisation QBIF LLC was no longer used, instead White Lake Management Ltd, Simtelligence Company Limited,
QBIF LLC, VL Consulting LLC were used by R.V. Shpakov. He (S.A. Matyukhin) insisted on removing IC QBF LLC from the
above scheme when he was employed by QBF in the summer of 2017. R.V. Shpakov, 3. Munayev and V. Pakhomov had
doubts on this issue, as the QBF brand is promoted and known, the flow of clients was significant. But later the
decision was made, probably influenced by an unscheduled inspection of the Central Bank of Russia. In April 2021 the
second inspection of the Central Bank of LLC "Investment Company QBIF" began, afer which it was decided to cancel
all 4 licences of the company. In September 2021, based on the order of the Central Bank of the Russian Federation, a
temporary administration was introduced in the company "QBIF Investment Company" LLC, and by the same order
the powers of the sole executive body of the company (i.e. him as CEO) were suspended. On 15.10.2021 the head of
the temporary administration issued an order to determine the period of time during which he (S.A. Matyukhin)
should appear in the office and provide information to the temporary administration, give answers to questions. At
the end of February 2022, he received a demand from the manager to hand over the FANCY database and the server
access key. To this request he received a reply that the database was seized on 26.05.2021 during the search by the
Ministry of Internal Affairs, he does not have the keys to the server, as well as the fact that IT - support was not
provided by the employees of the Investment Company QBF LLC, but by the company F - Management LLC on the
basis of contractual relations. On 04.03.2022 the head of the temporary administration of "QBIF Investment
Company" LLC made a decision to suspend him (S.A. Matyukhin) from work and from his position, accordingly his
dismissal from the company was issued. Starting from May 2021 to July 2021, as the General Director of LLC IC QB&Ef,
he, as the General Director of LLC QB&Ef, requested from LLC Q-BROKER by sending to the official e - mail address of
LLC Q-BROKER provided for in the contract, as well as by sending a registered letter by Russian Post a business plan,
financial model, primary accounting documents confirming the composition and structure of assets and liabilities, as
well as sending on a daily basis requests to exercise options and replenish the special brokerage account. Starting
from June 2021, 2 pre - trial claims were sent to Q-BROKER LLC in connection with the failure of Q-BROKER LLC to
fulfil its obligations under previously concluded options in which Q-BROKER LLC acted as a seller. Subsequently, a
claim was filed with the Moscow Arbitration Court against Q-BROKER LLC. OTC transactions with derivative financial
instruments were executed by the Broker on the basis of clients' orders, the terms of which contained information
that the obligations under the contracts were to be fulfilled by the seller of the options - Q-BROKER LLC, as well as
that it was an affiliated entity of QBIF LLC, that there might be a conflict of interest, that there might be violations of
terms on the part of the seller of options. Within the framework of brokerage activities of QBIF LLC, transactions with
derivative financial instruments (options) were carried out by persons who are qualified investors and recognised as
such by the Company on the basis of their application and in compliance with the requirements established by
Federal Law No. 39 - FZ "On the Securities Market". For the Company to recognise a client as a qualified investor, one
of the following requirements must be met: the amount of funds on the client's accounts with credit institutions must
have been at least RUB 6 million; the client must have had a turnover on securities transactions in the amount and
within the timeframes stipulated by Federal Law No. 39 - FZ; the client has a qualification certificate of a financial
market specialist, which is obtained either in self - regulatory organisations determined by the Central Bank of the
Russian Federation, or is confirmed by a document of higher education, and the client has a higher education
certificate. Clients made decisions to execute transactions independently, had the opportunity to familiarise
themselves with the terms and conditions of orders (transactions), signed a risk declaration and were professional
participants of the securities market. Brokerage activities, namely execution of clients' orders for civil law
transactions with securities or financial instruments, were regulated by Federal Law No. 39 - FZ "On the Securities
410
Market". The requirements for derivative financial instruments, futures contracts (options) are defined by the Central
Bank of the Russian Federation's Guidelines. For settlements within the brokerage activity the client sends funds to a
special brokerage account, the right to use which is restricted by the legislation, i.e. IC QBF LLC is not entitled to use
funds without the client's instruction. All transactions executed by the Broker (OOO IC QB&EF) under the brokerage
service agreements are executed by the Broker on the basis of the clients' instructions. All orders given by clients to
the Broker were stored electronically in the company, as well as clients' applications for joining the brokerage service
regulations, as well as documents confirming the client's qualification, all payment documents within the framework
of transaction execution. All option funds were received by Q-BROKER Ltd. as it was the seller of options, which was
known to the clients in advance and they were familiarised with it by signing their orders for transactions. He had
nothing to do with Q-BROKER Ltd;
(vol. No. 302, pp. 1 - 6, 7 - 9, 10 - 14, 15 - 18, 98 - 105, 128 - 132, vol. No. 303, pp. 78 - 80, vol. No. 305, pp. 185 - 189, vol.
No. 338, pp. 34 - 38)
- A. Abdukadyrov's testimony, given by him as a witness,

A.A. Abdukadyrov's testimony, given by him as a witness, according to which in September 2014, on the
recommendation of his acquaintance named Pavel, he was employed at QBF LLC as a junior financial advisor. Then, in
about February 2015, he (Abdukadyrov A.A.) was reemployed at QBF Investment LLC as a financial advisor, in this
position he worked until the end of 2018. In December 2018, he resigned from QBF Investment LLC and was employed
by third - party organisations, namely JSC "BCS" JSC "Otkritie Broker". In approximately March 2021, he (A.A.
Abdukadyrov) resigned from JSC Otkritie Broker and was employed by K - Investment LLC as a junior specialist in the
client support department. During his employment as a junior financial and financial advisor, his job duties included
selling the company's products, namely trust management products, advisory management products, brokerage
services, MC products, as well as searching for new clients. During the period of time from 2014 to 2018 his managers
were: Alexander Zaitsev, Anton Shkrut. The trust management products that he (Abdukadyrov A.A.) offered were: the
strategy "Weighted average", which implied investing in foreign companies that are traded on a foreign exchange. He
also explained that the process and mechanism of investing in foreign companies was a scheme of investing money in
products of international stock exchanges, which took place by transferring clients' money to QB Capital's settlement
accounts opened in foreign banks. He was sometimes present at the signing of documents between clients and QB
Capital, but did not participate. These meetings related to signing of contracts between clients and QB Capital were
held by the managers of the direction, namely Alexander Zaitsev, Anton Shkrut and Nikolay Padalko, as far as he
(Abdukadyrov A.A.) knows, he took part in them at most twice. He has no exact information about the licences held by
QB Capital, as well as information sources containing such information, as the emphasis was on the conclusion of the
trust management agreement concluded between QB Capital IK LLC and the client. Who administered the activities of
QB Capital, he does not know, he is familiar with this organisation only from the contracts offered to clients. The
ultimate head of the QBF group of companies is Roman Valeryevich Shpakov. He knows that QB Capital is liquidated,
as it was explained to him, the company was liquidated in connection with the deoffshorisation of Cyprus. This
information was given to him by the management of the company represented by his immediate superior, namely
Anton Shkrutya, as well as by the mass media. At the time of his employment at K - Investment LLC as a junior
specialist in the client support department, his direct supervisor was Vladimir Maslennikov. The main activity of K -
Investment LLC is advising clients on the assignment of assets previously attracted to QB Capital. As far as he knew,
from the clients' words, they had financial products, which he accompanied: weighted average portfolio, ETFs. He
also offered the clients some structured products, namely option contracts. Three clients took advantage of this offer.
Afer his probationary period, he transferred to the client support department. He heard that Q-BROKER LLC was
affiliated with QBF IK LLC. He did not know who was acting as the general director of QBF LLC. Stanislav Anatolyevich
Matyukhin has been the CEO of QB&EF IK LLC since the beginning of 2019, in his (Abdukadyrov A.A.) opinion. To the
best of his knowledge, QBIF LLC had all necessary licences in accordance with the current legislation of the Russian
Federation, namely, four licences of the Central Bank of the Russian Federation were obtained at different periods of
411
time: depositary, securities management, brokerage and dealer licences. LLC MC QBF Asset Management had a
licence to manage mutual funds. Information on the licences held by the above companies was also posted on the
official website of the Central Bank of Russia. Any client or employee of the organisation could at any time
independently check the actual validity of the licence in real time. The office of the organisation where he worked was
located at the following address: 8 Presnenskaya Naberezhnaya Street, Moscow, bld. 1 Moscow City International
Exhibition Centre. The office was located on the 9th floor of the Capital City building, in the south block. At the
entrance to the office there was a reception desk where there were company secretaries who escorted clients to the
meeting room. There were 5 meeting rooms for clients. The customer escort department, employed about 5 to 8
employees. His salary consisted of a salary and KPI, however, he did not receive anything in addition to the salary, as
he had not fulfilled the conditions for bonuses in time, therefore, he did not receive a bonus. He explained that the
client, being on brokerage service, could submit orders for withdrawal of funds, for winding up of funds, also for
termination of the contract. Of all the organisations: JSC Marketplace My Finance, JSC RIF, LLC VL - Consulting, LLC
Indep Smart, LLC KG, LLC K - Consulting, LLC KF Estate SPB, LLC Qubey Group, LLC Kuby Credit, LLC Kubyef Education,
LLC Kucisiai, LLC Millhouse Invest, LLC Profi, LLC Rentinvest, LLC Severspetsstroy, Simon Jesso LLC, MC Granat LLC, F -
Management LLC, F - Technologies LLC (INN 7703448769), F - Technologies LLC, F - Expert LLC, PJSC Venture Finance
Centre, White Lake Management Ltd, QB Capital (later QCCI), Simtelligence Company Limited, he has heard the name
VL - Consulting LLC. To the best of his knowledge, this organisation is associated with "White Lake Management Ltd",
however, the subject matter of their activities is not known to him. Simon Jesso LLC is the developer of the Gribovsky
les Residential Complex, however, he does not know who is the head of this company;
(Vol. No. 265, pp. 1 - 5)
Abramyan's Testimony given as a witness

given as a witness, according to which in February 2021 he received a call from representatives of the QBF group of
companies and was invited for an interview. He agreed with the proposal and at the appointed time came to the
interview, which was held in two stages. He (Abramyan A.A.) does not remember her surname, however, he
remembers that Tallerov Artem and Julia were a couple and were in close relations. Afer being interviewed at the
address: 8 Presnenskaya Nab. Presnenskaya, 8, the number of the office he does not remember, the building "Capital
City" of the business centre "Moscow City", namely 19.02.2021 he was hired as a junior financial advisor of the
department of work with clients in LLC "K - Investment". His duties as a financial advisor included: searching and
inviting clients, informing clients to sell investment products and trust management of clients' invested funds,
opening brokerage accounts. As a financial advisor, he sold the following products of the company: iPOs - non -
exchange traded assets, RESPO Transactions, Trust Management, RIF mutual funds. The organisations on behalf of
which the iPOs were sold were QBroker Ltd and QBiEF Investment Company Ltd. The solicitation of clients for the sale
of the company's products may have been through cold calls to potential clients, or through social media, through
various video bloggers. His direct supervisor was Tallerov Artem, from whom he received instructions on his work and
also reported to him on the results of his work. Artem Tallerov was supervised by Ruslan Spinka and Andrei Korzh. His
salary was approximately 45,000 roubles per month, with fixed payments based on the results of plan fulfilment in the
amount of 10,000 - 15,000 roubles, as well as a % of the amount of funds raised. He received his salary in cash from
Tallerov Artem, and he (Abrahamyan A.A.) did not sign in any statement for receiving his salary. In its turn, "K -
Investment" LLC was a part of "QBF" group of companies, but he does not know exactly how many organisations were
part of this group of companies. The office of K - Investment LLC was located at the following address: 8,
Presnenskaya Nab. Presnenskaya, 8, Moscow City business centre, Capital City building, he does not remember the
office number. The principal activity of QBF Group of Companies was attracting clients for the sale of investment
products and trust management of funds invested by clients. The head of the group of companies "QBF" was Roman
Valeryevich Shpakov, however, he (A.A. Abrahamyan) did not know him personally. He worked at K - Investment LLC
until approximately 8 July 2021. He resigned from "K - Investment" LLC at his own will, because in May 2021 the
412
company he worked for started to "fall apart" and salary delays started. He currently maintains a friendly relationship
with Artem Tallerov (89261990081), however, he rarely sees him. During his employment with QBF, he had to
communicate with various employees, some of whom he remembers, such as: Matyukhin Stanislav - General Director
of LLC "IC QBF", Korzh Andrey - could be Matyukhin Stanislav's deputy on operational issues, Spinka Ruslan - Head of
Sales Department, Balayan Ara - Head of Sales Department, Javid Isaev - developed iPO, Murashov Alexey - Senior
Financial Advisor, Fedorov Maxim - Vice - President of the company (financial advisor), Stella - Head of Department,
Trunyaev Alexey - Financial Advisor, trader; Dorokhina Ekaterina - financial advisor; Chentsov Alexey - senior financial
advisor, Orlov Vladislav - financial advisor, Burshtein Marina - client support department, Kopylova Maria - head of
"Middle office", Kiseleva Kristina - specialist of BEC office, Zaitseva Yulia - hr, worked in the support department,
Munaev Zelimkhan - was a manager responsible for foreign activities. He knows nothing about the location of R.V.
Shpakov. He learnt about the fact that R.V. Shpakov was wanted from publicly available sources of information;
(Vol. No. 265, pp. 7 - 10)
- R.F. Amerov's testimony as a witness

R.F. Amerov's testimony as a witness, according to which in 2017, the exact date he does not remember, he became an
employee of LLC "K - consulting" as the director of the department for work with partners and counterparties with a
salary of approximately 200,000 rubles per month, which he received in cash. He received his salary in the accounting
department. The salaries were placed on a table in a common area with names on each envelope, and he would take
the envelope with his name on it. Subsequently, he signed the prepared statement for the money received earlier. K -
Consulting LLC was actually part of the QBF group of companies, but these organisations had no legal relationship to
each other. All employees of K - Consulting LLC sold products of the QBF group of companies, as there was no
independent activity in K - Consulting LLC. K - Consulting LLC actually paid salaries to him and other employees of the
organisation, which were approximately 20 - 30 people. The main activity of the QBF group of companies was
attracting clients for the sale of investment products and trust management of money invested by clients. On the
instructions of Zelimkhan Munayev, in 2019 he organised cooperation between QBIF LLC and Vostochny Bank on the
basis of an agency agreement, under which the bank's employees attracted clients for the sale of QBIF LLC products,
namely trust management (trust management). The work was organised in about 20 cities, including St. Petersburg.
For convenient work on sale of financial products of IK QBF LLC using a special website, on the initiative of Munaev
Zelimkhan, Marketplace My Finance JSC was established, where he (R.F. Amerov) was also the founder and general
director on the instructions of Munaev Zelimkhan. Later, namely in August 2020, on the instructions of Zelimkhan
Munaev, he (R.F. Amerov) became a participant of LLC "MC Granat" in the amount of 9.9% of the shares of the
authorised capital, which amounted to 4,455,000 roubles. He became a participant as a natural person, however,
soon afer, on the instructions of Munaev Zelimkhan there was a change of the participant of the Company in the
person of him (R.F. Amerov) to JSC "Marketplace My Finance". He was elected Chairman of the Board of Directors of
MC Granat LLC by the general decision of the Company's participants. In 2021, the exact date he does not remember,
LLC MC Granat was renamed LLC MC Moi Finansy, in accordance with the general development strategy of the
company, which was planned by Roman Shpakov and Zelimkhan Munayev. The director of MC Granat LLC and later
MC Moi Finansy LLC was Rybalka Irina Vasilievna. I.V. Rybalka has been the CEO of this company for a long time and is
not affiliated and controlled by Roman Shpakov and Zelimkhan Munaev. The participants of MC Moi Finansy LLC
include the following persons who previously worked at QBF Group and he knows them personally: Bogdanova
Kristina Vladislavovna; Gramza Ekaterina Valeryevna; Korzh Andrey Vasilyevich; Maslennikov Vladimir Alexandrovich;
Mikhalevich Evgeny Vladimirovich; Orlov Yuri Nikolayevich; Spinka Ruslan Valeryevich; Fedorov Maxim Sergeevich;
Artem Olegovich Tallerov; JSC Marketplace My Finance INN 9703012630, where he is the CEO and sole participant;
Olga Dmitrievna Matyukhina, who is the mother of Stanislav Matyukhin, formerly of QBF Group. He (R.F. Amerov) has
never met her (O.D. Matyukhina) and does not know her personally. All the above - mentioned participants of this
Company do not make any independent decisions when participating in the Company, as they are controlled by the
management of the group of companies "QBF" represented by Shpakov Roman through his proxies, possibly
413
Matyukhin Stanislav, as initially Matyukhin Stanislav was an authorised person from Shpakov Roman when carrying
out any actions related to LLC "MC Moi Finansy". He does not know where Roman Shpakov is at present. He learns all
information about Roman Shpakov and other management of QBF Group from publicly available sources of
information. He, as well as Marketplace My Finance JSC are currently independent persons from the opinion of the
management of QBF Group and are not controlled by Shpakov Roman. He explained that the company QBF
Consulting Ltd. was in the QBF group of companies and had employees. QBF - Consulting LLC did not have its own
products, he does not know what specific activities the company carried out apart from employment of part of the
staff of QBF group of companies. His manager was directly Munayev Zelimkhan, who hired him and set his tasks. Of
the banks involved, we managed to conclude an agency agreement only with Bank Vostochny and Kamsky
Commercial Bank. There were no sales in Kamsky Commercial Bank. Munaev Zelimkhan negotiated the launch of
sales in Bank Vostochny at a high level, he said - with the board of the bank. His communication was with Vladimir
Kudryashov - at that time Director for commission products of the bank. His (Kudryashov's) area of responsibility
included conclusion of an agency agreement with QBIF LLC for sales of Vostochny. Stable Growth", as well as setting
planned norms for the bank's network of additional offices. He (R.F. Amerov) had the task of hiring trainers (coaches)
for training in the product of ISI "Vostochny. Stable Growth" from QBIF LLC (the CEO was Stanislav Matyukhin) to the
bank's retail employees, and to assist in the product's execution via sofware. The sales pilot started in 2019, scaling
sales (approximately 20 cities) was in 2020. The total amount of funds raised in the Vostochny Stable Growth DM (IIS)
product was approximately RUB 800 million. From the sales volume, QBIF LLC took a commission for the initial
placement of funds (published in the DM regulations, which were posted on the company's website in accordance
with the requirements of the Central Bank), of which a part paid to the bank an agency fee for attracting clients on the
basis of the agency agreement between Vostochny Bank and QBIF LLC. In 2020, the bank, namely Vladimir
Kudryashov, said that the DM product "Vostochny. Stable Growth" does not compete with the products of
competitors, namely BCS and ITA, due to the fact that there is no capital protection in DU. And in order to increase
sales indicators and to give for distribution all regions of the Russian Federation, where there are additional offices of
the bank, it was required (according to Vladimir Kudryashov) to make the product like the competitors. Thus, QBF's
legal department, namely Evgenia Rossieva (Head of Department) presented the product OTC Option Contract (OOC),
where the underlying asset was shares and bonds, as in the product of the "Vostochny Stable Growth", as well as the
possibility of capital protection in case the market of shares and bonds fell. This product satisfied Vladimir
Kudryashov and the rest of the bank's executives. The launch of this product implied conclusion of a separate
agreement with the bank, where there were 3 parties - Bank Vostochny, QBIF LLC and QBroker LLC. QBroker LLC was
registered at that time, the general director was Roman Shpakov. The Bank asked, as part of the agreement, to
advance commission for sales of this product in the amount of approximately RUB 200 million for a year of sales in
advance. The sales plan in the contract was more than 1 billion roubles. Afer signing the agreement, the actual sales
were about 98 for the amount of about 20 million rubles, then the bank stopped sales and returned the advanced
amount back to LLC IC QBF or LLC QBroker - he does not know to whom exactly - he does not remember all the details
of the agreement. Afer the sales stopped, the bank froze the project and there were no more sales. There were no
new banks on a similar algorithm of co - operation. Subsequently, there were about 12 refusals at the stage of tenders
from banks. In June 2020, he was offered to start developing sales through agents - individuals of IIS and IOU product,
to develop consulting services for corporate clients (organisation of exchange - traded bonds issue for medium - sized
businesses), and to launch a project office inside the company to launch these projects. Thus, in June 2020 he was
transferred to the position of Executive Director at K - Consulting Ltd. There were practically no sales in the agency
network and corporate direction. There were less than 10 transactions in the IIS business, and in the IOD business he
finds it difficult to answer - perhaps there were none at all. None of the projects in the corporate area had time to be
launched. The project office was engaged in preparation of agency agreements, sofware customisation, as well as
creation of client paths for online and offline sales, and provided assistance (coordination) on other projects of the
company. Also, in July 2020 Munaev Zelimkhan offered him to lead the project "Marketplace My Finance", the purpose
of which was to create a website and aggregate on it products of mutual funds, mutual funds of Central Bank -
licensed management and investment companies in the Russian Federation, as well as advisory products for
individuals and legal entities (tax consulting, assistance in obtaining tax deductions, etc.), banking products (cards,
deposits, loans), telemedicine - from service providers. The list of these products was also to include products of QBF
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IK LLC, mutual funds and Garnat LLC DM, which at that time was purchased by QBF Group employees with
instructions from Munaev Zelimkhan (August 2020). Munaev Zelimkhan asked him to become the owner and CEO of
"Marketplace My Finance" JSC, justifying this position by the fact that the company is opened for his (Amerov R.F.)
project, and he will be able to quickly conclude agency contracts with service providers and add them to the
Marketplace site, sell them online and through partners in the future, as well as eventually make a licensed product
line of trust management in LLC Management Company "Granat", which was later renamed to LLC Management
Company "My Finance". To start this project, in addition to developing the website, it was necessary to develop
sofware for the product design process of external service providers, to find and attract service providers and
potential partners to sell their product line. In order to finance these tasks, Munayev Zelimkhan organised the transfer
of funds with further crediting to the settlement account of Marketplace My Finance from QBF LLC in the amount of
RUB 3,350,000 and from QBroker LLC in the amount of RUB 540,000. According to these agreements, by the end of
2021, the company JSC Marketplace My Finance was to provide full advertising of the services of the above
companies: advertising of DM products (IIS) from IK QBF LLC, advertising of the structured product VOD from QBroker
LLC. In addition to these payments, Munaev Zelimkhan Zelimkhan said that he would also receive funds for the
development of the company, but afer 25 May 2021, the cash flow stopped. Thus, it was not possible to complete the
development of the website and provide advertising services, in view of which "Marketplace my Finance" JSC had
accounts payable to the above mentioned companies under both contracts. The transferred funds were spent on
renting a new office (from March 2021), where QBF's employees - approximately 15 people and only 2 employees of
Marketplace Moi Finansy, a.s. - were actually located. The funds were also spent on buying furniture for the new office,
laying cables, connecting and paying for internet, and several payments were made for the development of the
website, but the development was not finalised. Due to the fact that the funds on the current account ran out, and
Munaev Zelimkhan and other employees of the group stopped contacting me, since August I have surrendered the
premises to the landlord, cancelled the lease agreement, the amount of debt to the landlord is currently about 1
million rubles, including penalties for overdue payments. The company has had no legal address since August. The
landlord has several times sent pre - trial demands, which he cannot fulfil due to the balance on the current account
of less than 10,000 roubles. He, as an individual, purchased a share in LLC MC "Granat" (later LLC MC "Moi Finansy")
through a loan from LLC "QBroker" - according to other participants of LLC MC "Moi Finansy". He does not remember
the loan agreement itself and does not remember whether he put his signature there. The shares were purchased
through the company FG QBF JSC, according to the information in the payment order and documents. Then, on the
instructions of the legal department in the person of Rossieva Evgenia, he sold his share to JSC "Marketplace Moi
Finansy" - sale and purchase agreement, but he has not received any money from this transaction as an individual.
LLC Management Company "Moi Finansy" was actually acquired for the money of Roman Valerievich Shpakov, who is
one of the beneficiaries of "QBF", as Pakhomov V.S. and Munayev Z.V. Shpakov R.V. on behalf of "QBF", concluded a
loan agreement on his (Amerov R.F.) name, with this organisation. In fact, he did not receive these funds and did not
actually dispose of them. He did not personally pay the loan, and at the moment he does not know whether it has
been written off or not. When talking to Z.V. Munayev, he (Z.V. Munayev) explained to him that the entire amount
would be repaid by R.V. Shpakov. He knows that the QBF group of companies includes the following legal entities: QBF
IK LLC, QBF Management Company LLC, QBF FG JSC, possibly Q-BROKER LLC. Legally only these three are part of the
group. In fact, in addition to K - Consulting, Vl - Consulting may have been part of it. On his work email
[email protected], there was a newsletter about products containing information about foreign investments
and there was a logo of "White lake", and the products were offered by "Vl - Consulting". Munaev, one of the leaders of
QBF group, from whom he (Amerov R.F.) received tasks and reported to him. Munayev also introduced him to Nikolay
Padalko, General Director of Vl - Consulting. Zelimkhan introduced Padalko to him and informed him that Nikolay was
involved in investments in Western markets and asked him to discuss the possibility of selling such products through
banks. During the conversation with Padalko, Padalko explained to him that Vl - Consulting was not a professional
participant, namely it did not have licences for brokerage and asset management activities. He does not know the
legal address, but he knows that Vl - Consulting is actually located in the Capital City Tower, South Block, 9th floor,
Moscow. He knows that Vl - Consulting does not possess any licences. As a person with an economic education and as
a person who understands financial market instruments, he assumed that Vl - Consulting could be used to attract
investments and carry out brokerage activities without having a licence for this type of activity, as a consulting agent.
415
He was also aware that Vl - Consulting sold its services through QBF Group managers, who in turn sought clients. He
did not know anything about the "White lake" company, but he read on the Banki.ru portal, a review about the
company. In the article it was stated that clients do not get their money back in time, also managers do not pick up
the phones. He heard about the firm "SIMTELLIGENCE COMPANY LIMITED" from colleagues in direct sales, that it
exists and refers to the international market, possibly as a company - intermediary. "QCCI Ltd." is a company
registered in Cyprus that represents investment in Western markets. QBF has previously offered the services of "QCCI
Ltd" to its clients. The messages about "White lake" appeared on the corporate mail when the messages about "QCCI
Ltd" disappeared. Explained that the following persons performed duties in the group of companies "QBeeF": Ruslan
Valeryevich Spinka - director of sales management, he leads a team of financial advisors, about 40 people, also he
concluded contracts with clients, could represent "Vl - Consulting", other firms; Grigor Razmikovich Erzikyan - knows
that he communicates with clients, but who exactly by position does not know; Nikolay Sergeyevich Padalko - general
director of "Vl - Consulting"; Yuri Nikolayevich Orlov - manager of "QBroker" company, more of an IT specialist;
Vladislav Olegovich Plitin - previously worked about a year ago, was engaged in client support; Andrey Vasilievich
Korzh - deputy of R. Spinka.В., functional as the latter; Zaitseva Yulia Sergeevna - works with agents who attract
clients to the branches; Frolov Vladimir Georgievich - around 2017 was the CEO of QBIF LLC, who was later replaced by
Matyukhin Stanislav; Pakhomov Vladimir Sergeevich - shareholder, manages the branch network as well as direct
sales; Maxim Stanislavovich Yudin - Group Chief Operating Officer, managed two IT departments; Roman Valeryevich
Shpakov - manages the whole company, co - founder of JSC QBF and similar organisations under the QBF brand;
Zelimkhan Visaitovich Munaev - responsible for the Moscow office. The employees perceive R.V. Shpakov as the main
person in QBF, and Z.V. Munaev and V.S. Pakhomov are also shareholders of the business. Matyukhin Stanislav
Anatolievich - General Director of QBIF LLC, signatory in all contracts; Rossieva Evgenia Anatolievna - Director of Legal
Department; Gorobets Elena Vyacheslavovna - I have never seen her, she was a signatory in the labour contract when
she was employed; Lepeshkin Dmitry Sergeevich - works in the company "NOA", which provides consulting for legal
entities and individuals, possibly a co - founder; Athanasiadou Linda - consulted on western products, something
related to Cyprus; Vlasov Pavel Yurievich - manager on work with clients; Sobolev Kirill Sergeevich - previously worked
in the company, what he was doing does not know; Golubev Alexey Sergeevich - heads a branch in St. Petersburg.
Smirnova Yaroslava Gennadyevna - was the General Director of QBF Management Company; Shaban Yuri Vasilyevich -
is a partner, deals with real estate, attracts real estate for the fund; Vozhzhov Alexander Fedorovich - designer, does
website layout; Kozyreva Ekaterina Yurievna - his (Amerov R.F.) subordinate, manages projects of the fund; Kozireva
Yurievna - his (Amerov R.F.) subordinate.) subordinate, manages office projects, is responsible for reporting and
procurement of IT projects, works in "K - consulting"; Kharina Ekaterina Nikolaevna - productologist, deals with
product development; Grabareva Elena Anatolievna - his former subordinate in sales through agents; Timokhin Oleg
Yurievich - head of back office of IC QBF LLC. In early 2021, Z.V. Munayev was instructed to select a candidate for the
position of General Director of Q-BROKER LLC (TIN 9703003668) and the execution of the above instruction fell to the
HR department, and he was asked to additionally recommend a potential candidate. Around February 2021, the HR
department had a final candidate in the works, but the latter declined employment at the last minute. Due to the
events described above, Y.N. Orlov, who was planned for the position of project manager in the part concerning the
mobile application, was appointed to the position of company manager at the very last moment with the wording
from Z.V. Munayev that Y.N. Orlov could be entrusted with more responsibility. Yuri Orlov repeatedly flew to UAE,
Dubai, to the beneficiary of Q-BROKER LLC Roman Valeryevich Shpakov. He does not know what they talked about in
the UAE, however, Yuri Orlov repeatedly mentioned that he travelled there together with Evgenia Rossieva on the
instructions of R.V. Shpakov on business matters;
(Vol. No. 265, pp. 27 - 35, 43 - 45, 52 - 54, 55 - 58, 60 - 64)
416
- The testimony of Afanasyeva Y.S
- The testimony of Afanasyeva Y.S., given to her as a witness, according to which approximately in November 2019,
she received a phone call from an earlier acquaintance, Ornella Chisluk, who worked at QBF and invited her to work at
QBF in the personnel training department. She (Y.S. Afanasyeva) agreed with Ornella's proposal and at the appointed
time came for an interview at the following address: Moscow, Nab. Presnenskaya d.8, she does not remember the
number of the office, the Capital City building of the Moscow City business centre. She was interviewed by Tatyana
Novikova, Head of the Training Department, and Anastasia Zaripova, Hr Specialist. Afer passing the interview in
November 2019, the exact date she does not remember, she was hired as a specialist of the training department in the
HR department of QBF. Her duties as a specialist of the training department included: conducting training games with
employees, testing employees, teaching the rules of etiquette when communicating with the company's clients,
adaptation of employees in the team. QBF was a group of companies, but she does not know how many organisations
were part of this group of companies. The office of QBF was located at the following address: 8, Presnenskaya Nab.
Presnenskaya 8, Moscow City business centre, Capital City building, she does not remember the office number. The
principal activity of QBF Group of Companies was attracting clients for the sale of investment products and trust
management of funds invested by clients on the Russian and international markets. Roman Shpakov and Zelimkhan
Munayev were the managers of QBF Group. She also remembers that one of the managers of QBF was Vladimir
Pakhomov, but to the best of her knowledge he worked in St. Petersburg. She did not personally know these
managers and had never had any contact with them in her work. Her direct supervisor was Tatiana Novikova, but
about 2 months afer her employment, Novikova lef the company and there was no department head. Tatiana
Novikova reported to Valeria Gubanova, Director of Human Resources at QBF, in her activities. Afer Novikova's
dismissal, all employees of the training department reported directly to Valeria Gubanova. In turn, Gubanova Valeria
was able to interact with Shpakov and Munayev in her line of work because she was the head of the department. In
addition to Novikova, Vartanov Avetis and Chepurkova Anastasia worked in the training department as business
trainers. Her salary was approximately 85,000 roubles per month. She received her salary in cash from Tatiana
Novikova, and afer Novikova's dismissal, her salary was given to her by Valeria Gubanova, and she did not sign for her
salary on any statement. The amount of salary under her labour contract was less than the amount she actually
received, but she does not remember the amount under the contract. She does not know how the company
management calculated the difference in wages between what was stipulated in the contract and what was given to
the employees, as well as how the management reported to the tax authorities, and she was not interested in this
issue. She worked for QBF until approximately June 2021. She resigned from QBF at her own request because by the
time of her resignation, the company had started to "fall apart", many employees had lef and there were delays in
wages. She is aware that law enforcement officers conducted investigative actions in the QBF office, but she was not
present at the workplace at the time of the investigative actions. At the beginning of her employment with QBF, she
did not suspect that the company's management could have been engaged in fraudulent activities with clients'
money, as the company had a number of licences from the Central Bank of the Russian Federation to carry out
professional activities in the financial sphere. She began to have doubts about the legality of QBF management's
actions afer investigative actions were carried out in the company's office. During her employment with QBF, she had
to communicate with various employees, some of whom she remembers, such as: Matyukhin Stanislav - General
Director of LLC "IC QBF"; Spinka Ruslan - Head of Sales Department; Korzh Andrey - was Deputy Head of Sales
Department; Javid Isaev - Head of Sales Department, developed iPO; Balayan Ara - Head of Sales Department;
Padalko Nikolay - head of sales department, supervised foreign investments; Murashov Alexey - senior financial
advisor; Fedorov Maxim - vice - president of the company (financial advisor); Linda - was engaged in Cyprus direction;
Chentsov Alexey - financial advisor in Tallerov's department; Alexey Trunyaev - financial advisor; Alexander Trutnev -
financial advisor in Ara Balayan's department; Valentin Samoilov - financial advisor; Ekaterina Dorokhina - financial
advisor in Tellerov's department; Vladislav Orlov - junior financial advisor in Tellerov's department; Burshtein Marina -
client support department in Zavyalova Tatiana's department; Kopylova Maria - head of Middle Office; Zaitseva Yulia -
financial advisor, partnerships, agents; Baranova Olga - head of reception; Bogdanova Kristina - payroll. She knows
nothing about the whereabouts of R.V. Shpakov;
417
(Vol. No. 265, pp. 83 - 86)
- Testimony of Balayan A.S

- Testimony of Balayan A.S., given by him as a witness, according to which from August 2016 to October 2021 he
worked in QBF group of companies, officially he was employed in LLC "K - Investment" until approximately December
2020, then he was registered in LLC MC "QBF Asset Management", however, in the above companies he was nominally
listed. Initially, he performed the function of a financial advisor, his tasks included: consulting clients on the
company's products, supporting current clients. Then from about 2017 or 2018 he was promoted to the deputy head
of the sales department, his tasks included forming a team consisting of financial advisors, counselling clients,
training financial advisors in applying in practice the theoretical knowledge they received in the "Training"
department. He is familiar with the names of such organisations as: QB Capital LTD, "White Lake Menedgment",
Simtelligence company LTD, at the moment he cannot remember the exact names of the agreements concluded on
behalf of these organisations. He explained that an agreement was concluded between the client and QB Capital LTD.
QB Capital LTD provided an opportunity to participate in international markets, also an agreement was concluded
with IC QBife, within the framework of which IC QBife LLC managed the client's account opened with QB Capital LTD.
At the moment he cannot recall the profile data of the clients he attracted and the clients he was assigned to support.
His duties were only to advise clients on products. He is aware that White Lake Menedgment, was positioned as a
licensed investment company. He was aware that the employees of White Lake Menedgment were based in the
Cayman Islands. This information was provided to him by Nikolay Padalko and Maxim Yudin. Also in the period from
August 2016 to the end of 2019 his direct supervisor was Anton Shkrut, then, for about a short period of time, his
supervisor was Vladimir Pakhomov, in late 2019 or early 2020 his supervisor was Andriy Korzh. He himself was not
involved in the re - signing of contractual relations concluded between the clients of QB Capital LTD to contracts with
White Lake Menedgment;
(Vol. No. 265, pp. 88 - 92)
- The testimony of Bashkirov D.A

- The testimony of Bashkirov D.A., given by him as a witness, according to which he has an acquaintance, Ruslan
Dynda, who in January 2021 offered him a job at QBF. At that time he (D.A. Bashkirov) worked in "MOSENERGOSBYT",
as an engineer - inspector. As he was interested in Dynda R.'s proposal, he decided to try to get a job at QBF. Afer he
lef "MOSENERGOSBYT", he sent his CV to Dynda R. Then, some time later, he received a call from a girl who
introduced herself as Yulia and said that she represented the interests of QBF. In the course of communication with
him, she invited him for an interview in the company. On 21.01.2021 he came for the second time to the office of the
company at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, for an interview. 1, for an interview. At this
interview there was also Yulia and the head of the department, who introduced himself as Isayev Javid. During the
interview Isayev Javid presented the investment activities of the company, informing him that the company is
engaged in participation in IPO, and also provides financial products such as IIS (Individual Investment Account), trust
management and UIF (Unit Investment Fund) and others. In addition, he said that QBIF LLC has licences from the
Central Bank of the Russian Federation. At the end of the interview Isaev D. informed him that he would be contacted.
The next day on 22.01.2021 he learnt by phone from Julia that his candidacy for employment in the company had
been agreed upon and his first working day would be on 25.01.2021. On his first working day he started training,
which lasted about one week. During the training he was told about the company, the company's financial products,
sales training and other things. On or about 02/02/2021, he was officially employed by K - Investment LLC as a
financial advisor. At that time, he was aware that he would not be employed by Q - Investment LLC as he did not have
418
an economics background. As a financial advisor, he had the following job duties: attracting clients, selling the
company's products, supporting transactions with clients, consulting clients. In addition, one of the requirements of
the heads of departments was that each financial advisor must raise a total of at least 3,000,000 roubles of client
money for the company per month. In the department in which he worked, the head of the department was Isaev
Javid, and in addition to him (Isaev Javid) and himself, the following other employees worked in the department:
Khmilev S., Murashev A., Manaenkov V., Treiman A., Pirogov A., Chernysheva V., Dynda R., Lazarev A., Lopukhova A.,
and Ilyin A. In addition to the above mentioned employees, he saw Shpakov R., Munayev Z., Korzh A., Spink R. V.
During the period of his work he attracted 20 clients totalling approximately 20 million roubles. All of his clients
wished to participate in the IPO. In order to conclude a contract for the provision of brokerage services, the client had
to provide a passport of a citizen of the Russian Federation, SNILS, e - mail details, and details of a current account for
withdrawal of funds. The client sent these documents to his QBF work email. Afer that, he entered the client's data
through the Nabix programme. This programme would then generate a package of documents and send them to the
client via email. These documents were sent to the client for review. At the same moment, the client received a sms -
message with a code to confirm the signing of these documents, which he (Bashkirov D.A.) was informed by the client.
He entered this code into the programme and afer that the signed copies of the agreement, both from the side of
QBIF Ltd. and from the side of the client, were sent to the client. On the side of QBF LLC the contract was signed by the
general director Matyukhin S.A. with an electronic signature. Afer the contract was concluded with the client, the
client was assigned a personal account on the QBF website, where the client could track his funds and reports on the
client's brokerage account. The client transferred funds to the brokerage account opened to him. To participate in the
IPO, the client had to sign a master agreement. As Murashev A. explained to him, the funds were transferred to the
settlement account of QBroker LLC so that QBroker LLC could dispose of the funds as instructed by the client. The
counterparty that works with QBroker LLC was not disclosed, citing commercial secrecy. In May 2021, law
enforcement officers searched QBIF LLC. For the entire period of his employment he was paid once a salary of 70,000
roubles, in March 2021. In April - May 2021, he received a sales bonus of 50,000 roubles. He resigned in May 2021. He
knows Nikolai Padalko, who was in charge of the company's offshore and cash assets, as well as supervising the
company "WhiteLake"; in the office he (Nikolai Padalko) sat separately from all departments;
(Vol. No. 265, pp. 94 - 98)
- Belyakov B. E.'s Testimony

as a witness, according to which, in the period from September 2018 to spring - summer 2021, the exact date he does
not remember, he worked at QBF as an analyst. He found employment at QBF by placing an advert on the website
NN.ru, where he was looking for an interesting vacancy in the financial sector. At the time of his job search, he was a
2nd (second) year university student. Around September 2018, he received a call from the representatives of QBF
Group of Companies and was invited for an interview at the office located at the following address: Moscow, Nab.
Presnenskaya 8, the number of the office he does not remember. He agreed to the proposal and, at the appointed
time, went to the interview at the following address: Moscow, Nab. Presnenskaya 8, the number of the office he does
not remember, the Capital City building of the Moscow City business centre, which took place in several stages. One of
the representatives of QBF who interviewed him was the head of the analytical department, Arzhaev Alexander, where
he was hired, around September 2018, as a data analyst at F - Technologies LLC. In turn, F - Technolodges LLC was
part of the QBF group of companies, but he does not know exactly how many organisations were part of this group of
companies. At work he had to communicate only with Arzhaev Alexander and some analysts from his department,
whose names and surnames he no longer remembers. In addition, during his employment with QBF he was a full -
time student and was not always at work, but only when possible. The office of F - Technologies LLC was located at
the following address: 8, Presnenskaya Nab. Presnenskaya 8, Moscow City business centre, Capital City building, she
does not remember the office number. The principal activity of QBF Group was to attract clients for the sale of
investment financial products. As he later learnt from the mass media, the head of the QBF group of companies was
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Roman Shpakov. He received work instructions from Alexander Arzhaev and reported to him on the results of his
work. His salary was approximately 50,000 roubles per month and he received it in cash. As an analyst, his duties
included analysing the liquidity of shares in companies that were traded mainly on the Russian stock exchange, but
sometimes he had to analyse the international market as well. In addition, he created algorithms (computer
programs) that could also analyse the liquidity of shares of companies traded on the stock exchange. The information
on the analysis was accumulated and systematised on the work computer, which was later provided to the head of
the department, Arzhaev Alexander, if necessary. He does not know which financial products were sold at QBF. He
worked at F - Technologies LLC until spring - summer 2021, he does not remember the exact date. He lef F -
Technologies LLC at his own request because he did not see further development and professional growth in this
company;
(Vol. No. 265, pp. 99 - 102)
- D. V. Berkutova's testimony
- D. V. Berkutova's testimony given to her as a witness, according to which, in 2019, she placed an advertisement in
publicly available sources of information to find a job. In September 2019, she received a call from representatives of
the QBF group of companies on her ad and was invited for an interview at the office located at: Moscow, Nab.
Presnenskaya d.8, the number of the office she does not remember, the building "Capital City" of the business centre
"Moscow City". The interview took place in three stages on different days. The first stage of the interview was
conducted by Anastasia, a member of the HR department, she does not remember her surname, the second stage of
the interview was conducted by Ara Balayan, the head of one of the sales teams of the sales department, and the third
stage of the interview was conducted by Ruslan Spinka, the head of another sales team of the sales department.
Subsequently, Spinka Ruslan took the position of head of the sales department, which included all sales groups.
Following the interview, she was offered the position of lead financial advisor. Afer the interview, she became an
employee of K - Investment LLC with a salary of approximately RUB 120,000 from September 2019. She received her
salary in cash and was given it in an envelope either by Ruslan Spinka, who was her direct supervisor, or by other
employees of the QBF group of companies who were tasked with issuing the salary. She did not sign in any statement
for the money received. K - Investment LLC was part of the QBF group of companies, but she does not know exactly
how many organisations were part of this group of companies. The office of K - Investment LLC was located at the
following address: 8, Presnenskaya Nab. Presnenskaya 8, Moscow City business centre, Capital City building, she does
not remember the office number. The main activity of the K - Investment group of companies was attracting clients for
the sale of investment products and trust management of money invested by clients. The heads of the group of
companies "Q - Investment" were: Shpakov Roman Valeryevich, Zelimkhan Munayev, Pakhomov Vladimir, but the
main head was Shpakov R.V. Her direct supervisor was Spinka Ruslan, from him she received instructions on work,
and also she reported to him on the results of the work done. She does not know who Spinka Ruslan was directly
subordinate to. She did not receive any instructions from anyone other than Spinka Ruslan. She did not have to
communicate with the main management of the QBF group of companies due to the nature of her work, as she
addressed Spinka Ruslan on all matters of interest to her. In addition to Spinka Ruslan, her colleagues were:
Ermolenko Stella, Trutnev Alexander, Tatiana. Her duties as a financial advisor included: searching and inviting
clients, informing clients to sell the company's products, assisting clients in collecting documents for further
conclusion of an agreement with the company, meeting with the company's clients, making calls to the company's
clients, redirecting clients to the BEC office, which directly concluded agreements with the company's clients and
opened brokerage accounts for them. The work plan (KPI) in the organisation was not permanent and could change
quarterly. Basically, her KPIs included: the number of meetings held with the company's clients, the number of calls
made to the company's clients, the number of brokerage accounts opened for the company's clients for the purpose
of further trust management of the money invested by the clients, however, opening a brokerage account for a client
of the company did not guarantee the placement of funds on it. Her workplace was located in QBF's main office in the
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Moscow City Business Centre. She worked at K - Investment LLC until approximately May 2020, the exact date she
does not remember, afer which she went on maternity leave with further maternity leave, where she has been to
date, being officially employed by K - Investment LLC as a senior financial advisor. During her employment with QBF,
she had to communicate with various employees of the company, some of whom she remembers, such as: Avetis
Vartanov - instructor for training of financial advisors; Vladimir Maslennikov - worked in the support department
(withdrawal of clients' funds at their request in case of contract cancellation); Stanislav Matyukhin - General Director
of IK QBroker LLC, a member of QBF Group, he was introduced as one of the main managers; Dmitry Lepeshkin -
worked at QBF, but she does not know him personally; Pavel Vlasov - worked at QBF, but she does not know him
personally; Maxim Yudin - worked at QBF in a senior position, but she does not know him personally; Marina
Nikolaeva - worked at QBF IC, but she does not remember her position, but she did not work with clients, she
prepared documents for transactions; Christina Bogdanova - worked, but she does not know her position;
Athanasiadou Linda - worked, but she does not know her position; Korzh Andrey - head of one of the groups in the
sales department; Tallerov Artem - head of one of the groups in the sales department; Fedorov Maxim - financial
advisor, but later he moved to a higher position; Amerov Rinat - conducted trainings with employees, developed new
products of the organisation; Zaitseva Yulia - worked with agency contracts, but she does not know her exact position;
Yevgeniya Rossieva - Chief Lawyer of QBF Group; Vladimir Pakhomov - was one of the main managers of QBF Group;
Zelimkhan Munaev - was one of the main managers of QBF Group, business partner of Roman Valeryevich Shpakov;
Roman Valeryevich Shpakov - was the main manager of QBF Group;
(Vol. No. 265, pp. 106 - 109)
- The testimony of Blik S.N.,

- The testimony of Blik S.N., given by him as a witness, according to which, previously, in the period of time from 2016
to 02.12.2020, he worked for LLC IC QBF in the position of deputy head of department and as a financial advisor.
However, he was not formally employed until 2018 at KF Estate - SPb LLC, in the position of deputy head of
department and subsequently as a financial advisor. He explained that around September 2016 he was contacted by
Alexei Golubev, as he was looking for a job at the time and had placed an advert on the HandHunter website. In the
course of the telephone conversation, they agreed to meet in Kaliningrad for his interview. So in September 2016 he
met with Golubev A. in Kaliningrad, in the course of communication Golubev A. presented to him the financial
activities of the company, and also informed him that the company had a licence to participate in tenders. As he was
satisfied with everything, he decided to take up employment with the company in question. He was then invited to
Moscow for a conference, where he met Vladimir Pokhomov, Rima Rutinsh. R. Rutinsh and V. Pokhomov agreed on his
candidature for employment with the company. Having returned to Kaliningrad, he first started working as an agent,
his duties included attracting clients and accompanying them. Meetings with clients took place in an agreed place, as
there was no office in Kaliningrad. However, from January to June 2017, the company rented an office in Kaliningrad
at 4 Pobedy Square. At the same time, there were no meetings in the said office. Before the meeting, if the client said
that he was ready to deposit money to the current account in cash, he informed Golubev A., who, in turn, flew from St.
Petersburg to Kaliningrad on the day of the meeting with the client. Then, at the meeting, Golubev A. handed the
client a package of documents, and the client handed over money, which Golubev A. accepted. The client received a
receipt signed by the accountant (Gorobets). At the specified time, he worked on the territory of Kaliningrad together
with Gubanov Vadim. Gubanov V. was interviewed by both Golubev A. and Pohomov V. In June 2017, the company
opened a new office in the "Marine Business Centre" at the address: 35 Teatralnaya Street, Kaliningrad, office 807. The
opening of this office was attended by R. Shpakov himself, 3. Munayev, A. Golubev, V. Pokhomov, V. Apolon
Anastasiadou, Gevorg Gevorgyan and others. Afer the opening of the office, Golubev A. became the head there, he
(Blik S.N.) also became the deputy head of the department. There was also another deputy head of the department,
Sergey Tetyuev. There was a safe in their office, the keys to which only Tetyuev S. had. In the said safe, they mainly
kept mobile phones and headsets for them. However, on one of the days Tetyuev S. was not in the office and it was
necessary to take the phone from the safe, and he had the key. He opened the safe and saw in it, in addition to the
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phones, the seals of the following companies: one "WhiteLake", four "QBF" companies, one "WLM" company, one
"QCCI", one "Simtelligence", one "VL - Consulting" and the facsimile signatures of the heads of these companies. The
clients primarily entered into trust management agreements with QB Capital during the time period from 2016 to
2018. There were five clients during this time period. Then in 2018, the clients began to renegotiate contracts with the
company "White Lake Management Ltd". On this fact Golubev A. explained it by the fact that the company "QB
Capital" Cyprus regulator is tightening the regulation of activities in Cyprus and it is necessary to renegotiate
contracts with "White Lake Management Ltd" in the Cayman Islands, that this broker also has a licence. These
justifications were also mentioned by Gevorg Gevorgyan and Pokhomov V. Since 2018, he started to advise his clients
about participating in the IRO through the company "QCCI". Reports on concluded trust management agreements
with clients' funds were sent to his email from Ekaterina Martsenyuk. The reports were prepared by Orlov Y. Until 2019
Orlov Y. worked as a programmer in the company QBIF LLC, later he (Orlov Y.) became the General Director of Q-
BROKER LLC. Since 2019, clients of QBIF LLC began to experience delays in withdrawing funds. On this fact Golubev A.
and Pokhomov V. explained that the client did not provide full documents for withdrawal of funds, also explanations
were on the fact of problems with banks. At that time he began to suspect that there was something wrong with these
companies, the managers of which began not to answer his questions about the deposited funds, clients, as well as to
avoid answering in every possible way regarding the terms of withdrawal of funds. However, he was not fully
convinced that the company was embezzling money from customers. Subsequently, in January 2021, he learnt that
the company had embezzled funds from its clients, and therefore he concluded that it was a fraudulent scheme. At
that time he was no longer an employee of the company, having resigned on 02 December 2020. To his testimony he
attached the following documents received from Golubev A., Gevorgyan G. and Pakhomov V.: a list of clients, the
scheme of work of the investment holding "QBF", a memo "Reliability Guarantees" of the company "White Lake
Management Ltd", a memo "Reliability Guarantees" of the company "QBF", a copy of electronic correspondence of
Golubev A. with the client, a proposal for cooperation;
(Vol. No. 265, pp. 111 - 114)
- The testimony of Boltova L.N.,

- The testimony of Boltova L.N., given to her as a witness, according to which, from 01.12.2020 to 12.07.2021 she was
officially employed at K - Investment LLC as a manager of the Russian market support department. She got this
position through the Headhunter search engine. One of the managers who interviewed her was Ruslan Spinka. When
she was employed by the above - mentioned company, her direct supervisor was Tatiana Zavyalova. In fact, her job
duties included accompanying clients, informing them about the company's news, the profitability of the client's
portfolio, requesting orders from QBIF LLC or QBIF Asset Management LLC to buy or sell. The main activity of QBIF LLC
was trust management of clients' funds within the framework of securities purchase and compilation of securities
portfolio from the offered strategies. She was aware that the clients she accompanied had the following financial
products in their portfolios: stocks and bonds, trust management, over - the - counter option contracts. She has
advised approximately over 100 clients. She did not offer anyone the Structured Product, namely the "OTC option
contract" for IPOs, but accepted requests from clients for an order for a specific IPO, she also explained that clients
had previously used this instrument at QBF LLC, so she did not need to explain the structure of this product to them.
All she can explain about the mechanism and structure of the IPO option contract is that the buyer of the option was
QBF LLC and the seller of the option was the legal entity Q-BROKER LLC. She is aware of the fact that Q-BROKER LLC
was an affiliate of QBIF LLC. Stanislav Anatolievich Matyukhin performed the duties of the General Director of LLC IC
QBF. As far as she is aware, QBIF LLC has obtained all necessary licences in accordance with the current legislation of
the Russian Federation, namely, four licences of the Central Bank of the Russian Federation were obtained at different
periods of time: depositary, securities management, broker and dealer licences. Also, LLC MC QBF Asset Management
had a licence to manage investment funds, unit investment funds and non - state pension funds. Information on the
licences held by the above companies was also posted on the official website of the Central Bank of Russia. Any client
or employee of the organisation at any time could independently check the actual validity of the licence in real time.
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The office of the organisation in which it operated was located at the following address: 8 Presnenskaya
Naberezhnaya Street, Moscow, bld. 1 Moscow City IMDC, on the 9th floor of the Capital City building, in the northern
block. The sales department employed approximately 60 employees. Her salary consisted of a salary and a
performance bonus based on the number of meetings she had with current clients during the month, namely 16, and
she was required to make at least 20 calls per day, depending on the number of clients on follow - up, which varied
every month. She explained that the client, being on brokerage service, could perform trading operations on his
account in the following ways: by signing a personal order to purchase the selected asset in the office of the company
(the order form is available on the official website of the company, in the section "information disclosure"), by
submitting a handwritten signed order from his authorised e - mail to the e - mail of the company (broker), specified
in the contract. VL - Consulting Ltd and White Lake Management Ltd were international market companies, what
exactly they did, she does not know. She knows R.V. Shpakov as the head of the group of companies, she knows
Ruslan Spink as a manager, however, she does not know in what direction he was a manager;
(Vol. No. 265, pp. 140 - 143)
- Testimony of V.G. Butkovskaya

- Testimony of V.G. Butkovskaya, given to her as a witness, according to which in 2017, at the suggestion of Stanislav
Matyukhin, she was employed as a controller at KBF.ua LLC. Her job duties included: checking and compiling reports
for the Bank of Russia, also compiling internal reports of the controller, compiling reports to Rosfinmonitoring,
coordinating transactions with the property of Mutual Funds with special depositaries in accordance with Federal Law
No. 156 "On Investment Funds". She worked in this position until 2020. Her duties included the following: checking
and preparing reports for the Bank of Russia, preparing responses to the Bank of Russia's requests and sending them
as an executor, writing and amending documents involved in the company's internal document flow due to changes
in the Federal Law "On the Securities Market", preparing responses to appeals received from the company's clients,
preparing internal reports of the controller. She checked the reporting form on "bank accounts" OKUD No. 409. These
reports included the following information: a table containing information on bank account numbers, details of the
organisation where bank accounts were opened, cash turnover for the reporting period for each account, incoming
and outgoing account balances, the possibility of using cash in one's own interests, account types, account currency,
as well as information on accounts opened with superior brokers and clearing centres. OKUD No. 415 "On Securities"
this form included tables with the following indicators: information on the name and number of securities held in
trust by the company and owned by the company, as well as information on securities held in the company's
depository and their movement during the reporting period. OKUD No. 417 "On OTC transactions" this form included
information on OTC transactions concluded during the reporting period, information on which is not subject to
transfer to the repository. This form consists of the following indicators, namely: the date of the transaction, the
counterparty to the transaction, the name of the security, its quantity or value, and the type of settlement of the
transaction. This reporting form included information on over - the - counter securities transactions, most of the
transactions consisted of investment units under the management of KBF.ua LLC. She was also responsible for
reviewing the "Loans and Credits" form. This form included figures on loans and credits received or granted by the
company, their amount and repayment dates. She recalled the following names of the main creditors of LLC IC QBF at
the moment: JSC FG, where the beneficiary and general director was Roman Valerievich Shpakov; loans were also
granted to Stanislav Anatolievich Matyukhin as an individual. She explained that the mechanism of attracting clients'
funds under the option agreements concluded with Q-BROKER LLC and the brokerage services agreement with QBIF
LLC was as follows: the client, namely an individual or a legal entity, initially submits information for AML/CFT
verification before concluding a brokerage services agreement with QBIF LLC. Further, afer the verification, QBIF LLC
concludes a brokerage service agreement with the client, the client opens an internal accounting account with QBIF
LLC, the client transfers funds to the special brokerage account of QBIF LLC opened either with NSD, Sberbank PJSC,
Alfa Bank JSC. The client then submits an order to QBIF LLC to purchase an option, QBIF LLC accepts the order from
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the client as a seller. Further, QBIF Ltd. accepts the order from the client acting as a buyer and receives a counter order
from Q-BROKER Ltd. acting as a seller. Further, QBIF Ltd acts, on the basis of the client's order, as the buyer of the
option and acts on its own behalf in the interests of the buyer. On the other hand, IC QBF LLC, on the basis of an
instruction and power of attorney of Q-BROKER LLC, acts as the seller of the option. Subsequently, information on the
concluded transaction is entered into the company's internal accounting system and transferred to the repository.
Thus, on the basis of the concluded option contract, the client (buyer) receives the right to claim a lump sum payment
calculated in accordance with the contract specification. This lump sum claim is made by submitting an order to QBIF
Ltd. for early termination of the option contract or the client, upon expiry of the option contract, receives funds in the
amount of the lump sum payment according to the specification of the option contract. According to the terms of the
option contract, QBIF LLC accepts the specified instructions of the client (buyer) and calculates the amount of the
lump sum payment according to the change in the quotations of the underlying asset and submits the claims to the
option seller, namely QBroker LLC. In accordance with the terms of the option agreement QBIF LLC, without any
additional instruction from QBIF LLC, fulfils obligations under the presented claims at the expense of QBIF LLC funds
accounted on the internal accounting account opened with QBIF LLC within the framework of the concluded
agreement of brokerage services with QBIF LLC. The fulfilment of Q-BROKER LLC's obligations under option contracts
is performed by crediting funds to the internal accounting account opened with QBIF LLC to the client (buyer) under
the brokerage services agreement. Approximately at the end of 2020 or at the beginning of 2021, LLC IC QBF started to
receive orders of a new type, namely "Framework Agreements". The essence of a framework agreement was to
provide the buyer of an option in the future with the possibility to conclude option contracts on standard terms and
conditions defined by the framework agreement. In this case, the client (buyer) under the framework agreement
makes a security payment in favour of LLC Q-BROKER (seller), these funds, made as a security payment by the client
(buyer) are received on the internal accounting account opened in LLC IC QBF in the name of LLC Q-BROKER under
the agreement on provision of brokerage services. In this case QBroker LLC has the right to dispose of the funds
received under the framework agreements at its own discretion. Olga Vasyukova is the chief accountant of LLC IC QBF,
whose subordinate was the accountant Filina Daria. She explained that she knows Ekaterina Gramza, she (V.G.
Butkovskaya) knows her as an accountant, but she does not know in which companies she was engaged in
accounting. She also explained that she did not interact directly with clients or representatives of Q-BROKER LLC, but
she knows that the general director was Yuri Orlov, who directly executed documents on updating the data of Q-
BROKER LLC on updating the data of providing brokerage services, also received and transmitted correspondence
related to the activities of Q-BROKER LLC. She also knows that the beneficiary of Q-BROKER LLC was Roman
Valeryevich Shpakov. She knows that a young man named Dmitry, Evgenia Rossieva and a girl named Madina,
assistant of Evgenia Rossieva, were engaged in preparation of documents on behalf of Q-BROKER LLC. She contacted
Madina about requesting documents on Q-BROKER LLC in terms of legal support. She did not communicate directly
with Dmitriy, however, he was engaged in the preparation of orders from Q-BROKER LLC. In the period of time from
2019 to 2021, funds were transferred to the settlement accounts of Q-BROKER LLC, part of the funds were invested in
the securities of Argento, these funds were transferred on behalf of Q-BROKER LLC. Argento organisation is known to
her, QBF LLC requested documents both directly from Argento and through Q-BROKER LLC. On Argento's part,
documents were provided electronically, from the company's email account. Argento is an issuer of securities, namely
"Bonds", according to S.A. Matyukhin. Argento is interested in Q-BROKER LLC due to the possibility of receiving
coupon payments to the internal account of Q-BROKER LLC, in accordance with the Argento bond purchase
agreement. She also knows that Q-BROKER LLC issued promissory notes, she does not remember the names of the
counterparties. Timokhin Oleg was the head of the BEC - office of QBIF LLC, responsible for keeping internal records of
all operations and transactions within the framework of professional activities. The profile of the Back Office includes
interaction with clients and counterparties, including Q-BROKER LLC. Interaction involves receiving orders from Q-
BROKER LLC, and the BEC - office also maintains internal accounting of QBIF LLC clients' funds and QBIF LLC's own
funds within the framework of dealer activities;
(Vol. No. 265, pp. 145 - 150)
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- Vlasov P.Y.'s testimony - Vlasov P.Y.'s Testimony given by him as a witness,
according to which from 2014 to 2019 he worked at IC QBF as Vice President. From 2019 to the present time at F -
Experts LLC as a Vice President. Afer he took a job at QBF EC, he was in the position of Counsellor for the first three
months, i.e. during his probationary period. His job duties as Vice President included client attraction (inviting new
clients on favourable terms), client support (consulting, discussing reports). At F - Expert LLC, his job duties as Vice
President included client referrals (inviting new clients on favourable terms), client follow - up (consulting, discussing
reports). He explained that QB Capital LTD is a Cyprus company, whose shareholder is Roman Valeryevich Shpakov, as
well as Zelimkhan Visaitovich Munaev and Vladimir Sergeyevich Pakhomov. He is not personally acquainted with the
General Director of QB Capital LTD, but in the documents he saw the name of the General Director Elena Gorobets. QB
Capital LTD is registered and actually located in Cyprus. The main activity of QB Capital LTD is trust capital
management. He suspected that QB Capital LTD does not have licences to carry out brokerage and investment
activities. He once wondered about this issue, but he learned from Zaitsev Alexander (former head of the sales
department) that the Russian licence of IC QBF was sufficient for them. He explained that he personally signed the
agreement on granting access to the securities market and the agreement on trust management with QB Capital LTD,
i.e. together with QB and only in such a set. By other means, he did not provide interests to QB Capital LTD. He signed
an agreement on providing access to the securities market and a trust management agreement with IC QBife with
clients with QB Capital LTD only with individuals. At present he remembers that he signed the above agreements with
Alexey Yuryevich Ivanov, Alla Evgenievna Ivanova, Alexander Viktorovich Petrovichev, Andrey Borisovich Skvortsov,
Oleg Nikolayevich Boyarentsev, Yakov Dmitrievich Kahn, Konstantin Viktorovich Poklonsky, Sergey Vladimirovich
Krivoruchenko, Evgeny Viktorovich Venitsianov, Boris Vladimirovich Rozhivin, Natalia Nikolaevna Musatova, Andrey
Vladimirovich Vlasov. On the settlement of debts of QBF Group to individuals, he communicated with clients Ivanov
Alexey Yurievich, Ivanova Alla Evgenievna, Petrovichev Alexander Viktorovich, Skvortsov Andrey Borisovich,
Boyarentsev Oleg Nikolayevich, Poklonsky Konstantin Viktorovich, Krivoruchenko Sergey Vladimirovich, Rozhivin
Boris Vladimirovich, Musatova Natalia Nikolaevna, Vlasov Andrey Vladimirovich. He was also involved in
communication with Borzenkov Ilya Alexandrovich, who was the father of Borzenkov's client M.I. He communicated
with these persons on the terms of withdrawal of funds. He is not personally acquainted with Mendzebrovsky Igor
Vadimovich, but he heard about him, the latter was also their client. In 2019 - 2020, Shpakov R.V. asked him to join
negotiations with Moscow lawyers of Mendzebrovsky I.B. The list of documents provided to a client of QBF Group of
Companies wishing to participate in trading on international stock markets includes an agreement on providing
access to the securities market with QB Capital LTD and a trust management agreement with QBF IC. The trust
management agreement was entered into with the client on behalf of QBIF, but whether it had the force of a "Trust
Deed", he could not explain exactly. Among the services provided to clients QB Capital LTD wishing to participate in
the trading of international stock markets, provided access to the securities market, he cannot explain more precisely
because he does not know. He knows that reports on behalf of QB Capital LTD were sent to clients automatically, but
he does not know by whom they were formed and by what indicators. A personalised trading account in the name of
the client was not opened in QB Capital LTD. He does not know who provided accounting support to QB Capital LTD
and where QB Capital LTD activity was administered from. All decisions were made by R.V. Shpakov. The third - party
partner of R.V. Shpakov was Athanasiadou Linda, a citizen of Cyprus, and in the past a citizen of Ukraine - Kovalenko
(Athanasiadou) Linda Alexandrovna. She was the co - founder and CEO of Constant Investments (until 2016 QB
Investments was a Cyprus licensed brokerage company). Clients made bank transfers to the account of QB Capital LTD
(in 80% of cases) and in cash (in 20% of cases) in the office, receiving in return a receipt from QB Capital LTD with the
signature of Gorobets E. The money transferred in the office was given to the management represented by Zaitsev A.,
Afer the client signed the notification on withdrawal of funds from his trading account, based on the clauses of the
agreements concluded on behalf of "QB Capital LTD", "White Lake" "SIMTELLIGENCE COMPANY LIMITED", "QCCI LTD",
"White Lake Management LTD", these companies are obliged to return the funds within 20 working days, but only afer
the client signs the notification on withdrawal, only afer a month the client can sign the application on withdrawal of
funds. There was no such thing as dividends. There was a partial or full withdrawal at the decision of clients. Clients
were given funds in cash only at the request of the client. There was also a non - cash form of withdrawal. For what
reason QB Capital LTD was liquidated, he does not know reliably. As he understood, the liabilities from QB Capital LTD
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were transferred firstly to "QCCI Ltd" and later to "White lake", "SIMTELLIGENCE COMPANY LIMITED", "White lake
Management Ltd". The beneficiary of QBF Company was R.V. Shpakov, who was the manager. Pakhomov V.S. was
responsible only for regional offices. The signatory of "SIMTELLIGENCE COMPANY LIMITED" was Munaev Z.M., and the
signatory of "White lake" was Padalko Nikolay. He re - signed some contracts of QB Capital LTD with clients Aleksandr
Viktorovich Petrovichev, Andrey Borisovich Skvortsov, Oleg Nikolayevich Boyarentsev, Konstantin Viktorovich
Poklonsky, Sergey Vladimirovich Krivoruchenko, Boris Vladimirovich Rozhivin, Andrey Vladimirovich Vlasov, with
"White Lake" and "SIMTELLIGENCE COMPANY LIMITED", because according to the words of Z.M. Munaev and R.R.
Spinko.M. and Spinko R.V. re - signing is strictly necessary to start withdrawing funds to clients. Each employee re -
signed the same agreements with their clients of QB Capital LTD. The following persons fulfilled the duties in the
group of QBF companies: Ruslan Valerievich Spinka was the head of sales in Moscow; Erzikyan Grigoryan was the
head of sales in Moscow. Spinka Ruslan Valeryevich was the head of sales in Moscow; Grigor Razmikovich Erzikyan
was a financial advisor to some large clients; Nikolay Sergeyevich Padalko was the director of "White Lake
Management Ltd"; Yuri Nikolayevich Orlov was the head of the It department; Rinat Felixovich Amerov was the head
of the partner network; Vladislav Olegovich Plitin was in charge of complicated withdrawals of clients who had been
withdrawing money for a long time; Andrey Vasilyevich Korzh was a subordinate of R.V. Spinak and was in charge of
one of the sales groups; Andrey Vasilyevich Korzh was a subordinate of R.V. Spinak. Zaitseva Yulia Sergeevna was the
head of the agent network; Meshkova Daria Yurievna was an employee of the support department; Frolov Vladimir
Georgievich about 3 - 4 years ago was the General Director of IC QBF at 6%, all regional offices were subordinated to
him; Maxim Stanislavovich Yudin was the Head of Moscow Sales Department; Roman Valeryevich Shpakov was the
main beneficiary of the group of companies at 88%; Zelimkhan Visaitovich Munaev co - founded the companies at 6%;
Stanislav Anatolievich Matyukhin was the CEO of QBIF since 2018; Evgenia Anatolievna Rossieva was Head of Legal
Department; Elena Vyacheslavovna Gorobets was a former signatory of QB Capital LTD; Dmitry Sergeyevich Lepeshkin
was Investment Director from 2014 to 2016 and since 2016 co - founder and CEO of Constans Investments (prior to
2016 QB Investments, a Cyprus licensed brokerage company); Athanasiadou Linda was the co - founder and CEO of
Constans Investments (until 2016 "QB Investments" Cyprus Licensed Brokerage Company); Alexey Sergeyevich
Golubev was the Head of QBIF's office in St. Petersburg until 2019. Golubev Alexey Sergeevich was the Head of the
QBIF regional offices in St. Petersburg, since 2018, subordinated to Pakhomov V.S.; Smirnova Yaroslava Gennadyevna
was the Director of QBIF Management Company since 2014; Shaban Yuri Vasilyevich was the Managing Partner of the
rental real estate funds direction since 2019; Vozhzhov Alexander Fedorovich was the Marketing Department
employee in the Group of Companies; Kharina Ekaterina Nikolaevna was the Project Manager in the Group of
Companies;
(Vol. No. 265, pp. 152 - 163)
- A.F. Vozhzhov's testimony,

- A.F. Vozhzhov's testimony, given by him as a witness, according to which he is an artist - designer, fulfils various
orders related to the development of website design, designs exhibitions. He has been engaged in this activity for
about 15 years. About 8 - 9 years ago he was at an exhibition. At this exhibition were present employees of Kyubey
company and one of them offered him to design a website for Kyubey company and other products: calendars,
booklets and other. When designing the website, Kyubey employees mainly contacted him through his email address,
which received various emails from Kyubey employees about making any changes to the website's electronic
resource. He communicates mainly with the marketing and IT staff of this company, he is not closely acquainted with
the founders and CEO, but he knows that one of the representatives of the board of directors is Roman Shpakov. He
has heard about the White Lake organisation from the employees of Kyubey and understands that this company is a
subsidiary of Kyubey. Roman Valeryevich Shpakov is familiar to him, as he is the director of the organisation, and
Shpakov offered him to engage in art and design activities. Y.N. Orlov is engaged in IT - development. Athanasiadou
Linda is engaged in co - operation with foreign companies. When he started working with the above company, it was
called Kyubi Finance, he was not officially employed there;
426
(Vol. No. 265, pp. 171 - 174)
- I. A. Gavrilova's testimon- I. A. Gavrilova's Testimony

given to her as a witness, according to which since 20.08.2018 she has been working as a back office manager in the
company QBF Asset Management LLC. In the middle of 2018, she was looking for a place of employment. On the
website "hh.ru" she saw an announcement that the company "QBF Asset Management" LLC required a back office
manager and sent her CV via the Internet. A short time later, she received a call back from a member of the human
resources department of QBG Asset Management LLC and was asked to come to the company for an interview. On one
of the days of that period, she arrived at the company's office located at 8 Presnenskaya Embankment, Capital City
Tower, 9th floor, Moscow. She was interviewed by Smirnova Yaroslava Gennadyevna, a member of the HR department
and General Director of QBF Asset Management LLC. During the interview she (I.A. Gavrilova) found out the direction
of the company's activities, questions about the company's funds, as well as other questions she was interested in
about the company's activities. Approximately 3 weeks afer the interview, she received another call from a member
of the HR department informing her that the company was ready to hire her. On 20 August 2018, she started her work
duties. Her workplace is an office in the premises of the office of QBF Asset Management LLC at 12 Presnenskaya
Naberezhnaya Street, floor 22, Moscow. Her direct supervisor is Yaroslava Gennadyevna Smirnova, General Director of
QBF Asset Management LLC. She (I.A. Gavrilova) has three employees under her command. Her job duties include:
organisation of department management, responsibility for internal accounting operations, control over preparation
and submission of reports on mutual funds to the Central Bank of the Russian Federation, interaction with
counterparties, banks, specialised depositories, tax service, auditors, appraisers, tenants and other organisations
within the framework of mutual funds activities. QBF Asset Management LLC has a licence issued by the Central Bank
of the Russian Federation to manage mutual funds and non - state pension funds. The company manages 13 unit
investment funds, 4 of which are open - end (open - end unit investment fund) and 9 closed - end investment funds.
QBF Asset Management LLC is a member of QBF Group of Companies. The only interaction between QBiEF Asset
Management LLC and QBiEF Investment Company LLC consists of agreements between the companies to provide
brokerage services for mutual funds. She has a valid power of attorney to represent the interests of QBIF Asset
Management LLC, according to which she can represent the interests of the company, sign contracts, interact with
counterparties on any issues, without the right of override. She has heard that there is a girl named Linda in the
company, but she does not know anything about her. Roman Valeryevich Shpakov is the group leader of QBF Ltd.
Munaev Zelimkhan Visaitovich is one of the managers of the company. Stanislav Anatolievich Matyukhin is the
General Director of an investment company. Evgenia Anatolievna Rossieva was the Group Legal Counsel of QBEEF and
was contacted on several occasions on work - related matters. Brokerage agreements, including those with QBEF
Investment Company LLC were signed by Yaroslava Gennadyevna Smirnova, Director of QBEF Asset Management LLC.
Brokerage agreements between QBiEF Asset Management LLC and IK QBiEF LLC were signed at the time the funds
were established and prior to her employment with QBiEF Asset Management LLC. The following funds were managed
by QBIF Asset Management LLC: QBiEF My Safe, a securities purchase; QBiEF Golden Section, a securities purchase;
and QBiEF Eurobonds, a securities purchase; and QBiEF Eurobonds, a securities purchase; QBIF RFI QBIF Future
Assets, acquisition of securities; QBIF Real Estate ZPIF (closed - end unit investment real estate fund) QBIF Real Estate,
land plots and trust management agreements of the Gribovsky Les housing estate; QBIF Regional Real Estate ZPIF,
flats in Severodvinsk; QBIF Regional Real Estate ZPIF, flats in Severodvinsk; QBIF Regional Real Estate ZPIF, flats in the
city of Severodvinsk; QBIF Regional Real Estate ZPIF, flats in the city of Severodvinsk. Северодвинск; ЗПИФ
недвижимости «Развитие регионов», договоры долевого участия в г. Северодвинск; ЗПИФ недвижимости
«Развитие регионов 2», договоры долевого участия в г. Северодвинск; ЗПИФ комбинированный «Время новых
ценностей», художественные ценности, картины; ЗПИФ недвижимости «Риф складской федеральный 1»,
недвижимости в г. Novorossiysk; real estate ZPIF "RIF mixed federal 2 qual", real estate in Zelenograd; combined ZPIF
"Basic Investments M", land plot and building in St. Petersburg"; combined ZPIF "New Investments", securities;
427
(Vol. No. 266, pp. 1 - 6)
- The testimony of Gadirli T.R.o.,

- The testimony of Gadirli T.R.o., given by him as a witness, according to which since 2014 he was employed at KF -
Finance LLC as a trader. The interview with him was conducted by Dmitry Kipa. In the QBF group of companies he was
also employed at 702 LLC, F - Experts LLC. In fact, he performed the functions of an analyst of shares of foreign
companies listed on stock exchanges. He analysed foreign companies that could be attracted for further investment.
These were mainly companies from the American, Canadian, European and Chinese markets. To a greater extent, of
course, he worked with the American market. His direct supervisor was R.V. Shpakov and Z.V. Munayev. He received
tasks for analysing specific companies from various top managers, but always Shpakov's instructions were the
priority, which had to be fulfilled as soon as possible and in the first place. The analyses took a long period of time,
the results of which were prepared in Excel format and then passed to Shpakov R.V. Afer some time the data on
analytics, with the permission of Shpakov R.V., were passed to the sales department. These investment ideas were
offered to 20 clients of "White Lake" group of companies. Sometimes, on the instructions of R.V. Shpakov, specific
information of some clients was received from the back office of WL to the general mail, to whom his (Gadirli T.R.O.)
division subsequently sent e - mail responses on the created investment ideas of the American stock market. There
were no more than 20 such clients in all, all of whom were clients of either WL or WL Management. Afer he emailed
his reports, the client would then make his own decision whether or not to further invest or not to purchase listed
securities. Between 2018 and August 2020, he sent his reports to about 5 clients, afer August 2020, the number
increased to 20, about 10 of whom called him back on the reports. About 6 - 7 people decided to invest in US
companies based on his reports. From approximately August 2020, at the direction of R.V. Shpakov, he headed the
advisory brokerage department, which included Alena Rudakova, Nikita Nesterenko, and Artur Meinhard. Since the
mentioned period, he and his department carried out analyses of the companies, which were further placed on the
stock exchange. These reports were sent only to R.V. Shpakov;
(Vol. No. 266, pp. 29 - 32)
- K.V. Hertsik's testimon K.V. Hertsik's Testimony

given by him as a witness, according to which he is a blogger and posts various publications in social networks. Afer
graduation, he posted his CV on the HH.ru website to search for a more interesting and prestigious vacancy. So, in
February 2020, he received a call from representatives of QBF Group and was invited to an interview, which took place
in several stages. He was interviewed by Julia, a QBF hr - specialist, Andrey Korzh, head of the QBF sales department,
and Yegor Laipanov, head of the QBF sales department. Subsequently, the position of Head of Sales Department was
taken by Javid Isaev instead of Egor Laipanov. Afer an interview at the following address: Moscow, 8, Presnenskaya
Nab. Presnenskaya, 8, Capital City building of the Moscow City business centre, he was hired by QBF in December
2019. No employment contract was concluded with him and in fact his position did not exist according to the staff
schedule of the organisation. His duties included posting promotional information regarding QBF on social media as
well as on his Instagram channel. On social media, he publicised QBF's business principles and promoted the
financial products sold by QBF. He mainly covered the company's "IPO" product on social media. He was paid a salary
of 80,000 roubles per month for his work. He received his salary in cash, mostly from Isayev Javid, or from the girls
who worked in the sales department, Christina or Tamila. He did not engage in any activities other than advertising
the company's financial products on social networks, but he had to communicate with certain employees of the
company, mainly financial advisors of QBF's sales department, who sold QBF's financial products that he advertised.
He communicated mainly with Isayev Javid, Lopukhova Anastasia, Dynda Ruslan, Lazarev (Sybikin) Anton, Murashev
Alexei, and Zaitseva Yulia, who could also cover QBF's activities on social networks. He knows that the head of the
sales department was Ruslan Spinka and the head of QBF was Roman Shpakov. He did not have to communicate
428
directly with these people, he mainly worked with Isayev Javid. QBF consisted of several companies, which formed
the QBF group of companies. The main activity of QBF group of companies was attracting clients for sale of
investment products and trust management of money invested by clients. He worked at QBF until May 2021, as the
company started to "fall apart" and he did not see further development of the company's activities. At that time, the
Central Bank of the Russian Federation revoked the company's licence to carry out professional financial activities
and the company's clients were no longer able to withdraw their investments or funds;
(Vol. No. 266, pp. 34 - 37)
A.S. Golubeva's testimony

- A.S. Golubeva's Testimony given to her as a witness, according to which on 13.01.2020 she was employed at LLC "K
Investment" as a specialist. In February 2021 she was transferred to LLC IC QBF to the position of a specialist of the
department of support and maintenance of clients, where she worked until 16.06.2021. Her workplace both at LLC K
Investment and LLC IC QBF was located at the following address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1,
multifunctional complex "City". 1, Capital City multifunctional complex, Moscow Tower, 11th floor. She found
employment by posting her CV on the HH.ru website. Anastasia Zaripova, a member of the HR department, called her
and offered her an interview. She was interviewed on the 9th floor of the southern block of the multifunctional
complex "City of Capitals". The interview was conducted by Maria Vladimirovna Kopylova (Head of Client Support and
Support Department of QBIF LLC), who was later her direct supervisor. Stanislav Anatolyevich Matyukhin was the
General Director of LLC IC QBF. Her direct supervisor and workplace (location of her desk and office equipment) did
not change in the above companies. She performed the same duties in LLC K Investment and LLC IC QBF. Her job was
that afer the sales department attracted a client, the manager entered the client's identification data and attached
photocopies of these documents to the database. She did not know the names of the legal entities of the sales
department. The said personal information of the client was entered into the NABICS programme. On the basis of the
templates available in the programme and the data entered by the manager, the programme prepared an application
for joining and a client questionnaire. Then it had to check the data about the client, indicated in the application for
accession and questionnaire with the photocopies of the client's personal documents. Having made sure that the
information was correct, she pressed the button to confirm the data correctness check, afer which the programme
put an electronic digital signature (EDS) of the General Director Matyukhin S.A. on the accession application. Then the
programme sent the accession application with the EDS and company data (details for transferring rubles and
currency, payment purpose) to the client's e - mail address. In the NABIS programme she worked both with trust
management and brokerage services. Her activities did not involve personal contact with the client. She was also
engaged in preparation of orders (client orders for withdrawal of funds, changes of data - profile and client details).
Preparation of orders was based on the request of the manager who provided consulting services to the client. She
sent the prepared order to the manager and the manager subsequently sent it to the client. M.V. Kopylova's workplace
was located at 8 Presnenskaya Naberezhnaya Embankment, bldg. 1, Moscow, multifunctional complex "City of
Capitals", Moscow Tower, 11th floor. The workplace of A.S. Golubeva, as well as three other specialists of the sales and
customer support department, was also located in the office of her immediate supervisor, M.V. Kopylova. The number
of employees of the department under the leadership of M.V. Kopylova was 4 employees. Roman Valeryevich Shpakov
and Zelimkhan Visaitovich Munaev are known to her as shareholders of QBF Group. Stanislav Anatolievich Matyukhin
was the General Director of IC QBF. Evgenia Rossieva was a lawyer of which company she does not know. She was not
related to the above persons in any way by her work, had no contact with them in the working process, and did not
maintain personal relations;
(Vol. No. 266, pp. 39 - 43)
429
I.S. Gorsheneva's Testimony given to her as a witness,
according to which, around 2014, she was employed by the QBF group of companies as a manager of the economic
and administrative department. She was offered employment in this company by her sister Margarita Sergeevna
Gorsheneva, who had been working in this company for a long time and held the position of development director.
She worked in this position until 2017 and performed her job duties on a part - time basis. Her duties included
administrative and housekeeping functions, ordering stationery, water and other necessary goods. Gorsheneva M.S.'s
main activity was PR and marketing. Gorsheneva M.S. resigned from the company around 2017. The head of QBF
Group was Shpakov R.V. Due to graduation from university in 2017, she resigned from QBF Group and got a job at
FGBU FMC Rosimuschestvo in Moscow. Around the summer of 2019, she received a phone call from R.V. Shpakov and
suggested that she come to his office in Moscow City. He did not explain the details of the visit to her over the phone;
she assumed that he wanted to hire her again. She agreed and went to the office of Shpakov R.V. In the office Shpakov
R.V. offered her to sign a contract. She does not remember what the agreement was about, who was the second party.
She did not read the agreement itself. She does not remember what exactly Shpakov R.V. explained at that moment.
Later, at the request of R.V. Shpakov, she came to the QBF office in Moscow City a couple of times to re - sign the
contract, and the date of the contract was changed. When this contract was being prepared, she informed Shpakov
R.V. of the details of her account in Sberbank PJSC, assuming that the account details were necessary for the
preparation of the contract. Some time later, R.V. Shpakov called her on her mobile phone and informed her that
money would be transferred to her account specified when signing the agreement. According to R.V. Shpakov, the
money was to come from LLC "QBF Management Company", but he did not tell her the exact amount. A little later she
received a little over 10 million roubles on her account. Afer that, R.V. Shpakov called her and told her to transfer
these funds in full to his account, which she did. Shpakov R.V. gave her the details of his account over the phone. Afer
this case she told Shpakov R.V. not to involve her in similar transactions, as such large sums frighten her. Afer this
case, they did not meet and did not communicate with Shpakov R.V.;
(Vol. No. 266, pp. 48 - 50)
E.A. Grabareva's Testimony

given to her as a witness, according to which she held the position of director of the agent network in LLC K -
Consulting. K - Consulting LLC was a partner of QBF OJSC and was engaged in attraction of partners and agents for
further attraction of clients for QBF IC. The actual address of this company was in Moscow in the building "Capital City
Tower" Moscow City on the 9th floor. Her duties as a director of the agent network included: recruiting and organising
the work of agents, attracting and organising the work of lead generators (websites that directly transfer clients to
QBF's website), as well as training agents and employees of QBF's partners. Personally, she was responsible for
soliciting partners by finding brokerage firms (partners) that would then solicit clients to invest in QB&EF Investment
Company. She searched for partners through personal acquaintances and through the Internet. Through the Internet,
she usually looked for companies that sold banking products (credit cards, RCO accounts and instalment cards).
Through personal acquaintances, she attracted partners because she had already encountered brokers before, afer
which she contacted the managers of the brokerage companies directly or obtained the managers' contacts through
someone else. In "K - Consulting" LLC she worked with only one product, namely individual investment account, it
was a state programme as safe as possible for attracted clients. She knows that the founder of QCCI LTD and White
Lake LTD was Shpakov R.V. The script of dialogue with the client was discussed with Munayev Z.V. The scheme
included how to start a dialogue with the client, how to offer him to open an IIS, how to fill in the questionnaire
together with him, to enter these actions into the program on the part of the partner, and then an employee of QBF
calls the client to open an IIS and depending on his reaction further actions. In February - March 2020, she was
approached by Z.V. Munayev with a proposal to become the general director and sole founder of JSC "Moi Finansy" on
the type of "market place", i.e. an internet platform for the purchase of financial and other products of various
430
directions for individuals. Z.V. Munayev explained that this was necessary in order to unite the sales of QBF products
and partner companies on a single platform on the Russian market. She refused this proposal because she had never
specialised in this type of activity and did not understand its essence, i.e. she understood that they wanted to put her
in the management of the company as a nominal manager. According to feedback from partner companies, there was
negative information about QBF's work, which consisted in the fact that clients' funds on the Russian stock market
were returned with a great delay, and she also heard rumours about withdrawal of clients' funds through companies
on the international stock market. Afer she refused the offer of Z.V. Munayev, conditions were created for her
dismissal, as she understood on Munayev's instructions. Subsequently, she knew that Amerov R.F. headed JSC "Moi
Finansy", it was he who was in charge of organising sales and concluding contracts with clients through Bank
Vostochny. In her opinion, her dismissal from K - Consulting LLC was provoked by her refusal to co - operate with
Munayev and Shpakov;
(Vol. No. 266, pp. 61 - 72)
- M.V. Danilenko's testimony,

given by him as a witness, according to which in early 2018, afer an interview at the QBF office, which is located at:
Moscow, Presnenskaya Naberezhnaya, 8, p. 1, 9th floor, South Block. 1, 9th floor, South Block, he was hired. He was
interviewed by Yulia Zaitseva and Nikolai Padalko. Nikolay was the head of the department, Yulia was the team leader.
Since at that time he was not a citizen of the Russian Federation and was not a resident of the Russian Federation, an
agency agreement was concluded with him. He went to work in the above office from about mid - February 2018. At
the end of 2018, he resigned because the figures for 2018, Q4, were poor. Afer that, he worked at Zerich Capital
Management as a client manager. In September 2019, Nikolay Padalko offered him to return to QBF. He (Danilenko
M.V.) agreed, and from October 2019 he rejoined QBF. He did not have proper documents at that time, an agency
agreement was concluded with him from K - Investment LLC. The company provided training for new employees,
several seminars on market knowledge. The training was conducted by Avetis Vartanov, who was the head of the
training department. He (Danilenko M.V.) was a member of the sales department. His supervisor was Yulia Zaitseva.
Apart from him, she had 3 - 4 people in her subordinate: Ilya Shakhov, Liya Vlasova - these were those who worked
steadily. The rest worked for a short time. Yulia Zaitseva was the head of the sales team. Yulia reported directly to
Nikolay Padalko, who was the head of the department. In addition to Zaitseva, Padalko had Spinka Ruslan and his
team. The most important head of the sales department was Yudin Maxim. His (Danilenko M.V.) job duties included
communicating with clients, selling the company's products, calling in reports with existing clients, and meeting in
the office. Zaitseva's job duties included supervising client managers. She also took part in meetings with clients on
her own initiative. Zaitseva also had her own clients. At the planning meeting, Yulia handed out current
responsibilities, as well as general plans - the number of client meetings to be held per week; calls to report - a client
had to be called at least once a month; daily calls - to potential clients and current clients. Yulia provided the
employees of her group with a contact database - electronically it was a database in the programme "CRM", which
contained information - full name and phone number. He (Danilenko M.V.) called people, introducing himself as an
employee of QBF. He explained that the company offered investment services in the securities market. If people were
interested, he invited them to the company's office for a conversation. If the client came to the company's office, the
conversation was conducted by the manager with whom the conversation was conducted, and Zaitseva was usually
present at the first meeting. During the conversation with the client, the client was asked to invest money in buying
portfolios: either stocks, bonds, mixed or other products, based on what the client was interested in. It was explained
to clients that there were licences issued by the Russian regulator, so clients could have confidence in the reliability of
the company. There was a stand in the DP (sales department) where booklets with information about a particular
product of the company were placed. During 2018, he attracted about 10 people to the company, who entered into
brokerage contracts with the QBF organisation. Yulia Zaitseva also referred some of her clients of the company to him
for support - these were clients of a Russian company and an international company (QB Capital). At the conclusion of
431
the contract, an application on joining the brokerage contract, an investment declaration, a standard client
questionnaire and an AML/CFT questionnaire (anti - money laundering and combating the financing of terrorism)
were signed. The client could write an application on joining the brokerage agreement, in this case every transaction,
purchase was made in coordination with the client. Or the client could conclude a trust management agreement, put
money on the account and then wait for the result. As for trust management agreements, each strategy had an
investment declaration, where it was specified what the portfolio manager could do within the portfolio, what assets
to buy. If the client concluded a brokerage agreement, he signed an application for joining. If the client wished to sign
the agreement, he had to provide his passport, TIN, SNILS, and ruble account details. Then he (Danilenko M.V.)
scanned all the documents and sent them to his colleagues in the "Middle Office" to prepare the contract. From this
department he knows Maria Kopylova, she came from the Middle Office to identify the client. Kopylova brought a
ready printed package of documents, where the Application for Accession and Declaration had already been signed
on behalf of the QBF representative. The Agreement was concluded on behalf of QBIF Investment Company LLC, and
the documents were signed by the General Director of QBIF Investment Company LLC, Stanislav Anatolievich
Matyukhin. In case the client concluded a trust management agreement (which is a type of brokerage agreement), the
client signed statements on joining the brokerage agreement and the Declaration. The draf trust management
agreement is also posted on the company's website. One copy of the signed Application and Declaration was lef with
the client, one copy was taken by Maria Kopylova, or he passed the documents through the receptionists for the
Middle Office. Afer the conclusion of the contract, he (Danilenko M.V.) was assigned to this client as a client manager.
He (Danilenko M.V.) had to call the client on reports afer the conclusion of the contract (he did not form reports
himself, did not send them to the client, the reports were formed in the programme). If the client wanted to replenish
the account, he provided him with up - to - date details. If the client wanted to withdraw money, he (the client) would
come and sign an application - an order to return the property, either partially or in full. The application was also
handed over to the "Middle Office". At the signing of the agreement were present: he (Danilenko M.V.), the client,
Zaitseva (could be, could not be) also was present an employee of "Middle Office" - a specialist of AML/CFT
department. At the conclusion of the contract, the client was provided with details, which the client used to top up his
account. He (Danilenko M.V.) received information from Middle Office by e - mail: the client's name, the amount of the
top - up and the date of the top - up. Afer that he would call the client and tell him that the money had arrived. Cash
transfer was not envisaged. If a brokerage agreement was concluded with the client, the dividends were transferred to
the client's brokerage account and the client could either withdraw or reinvest them. If the client wished to withdraw,
the client filled out an order to return (refund order) the funds, the broker sold the property; the return was made
within up to 10 working days. The funds were transferred to the client's bank account specified by the client when
opening the contract. As for the trust management agreement, dividends went to reinvestment by default. If the
client wanted to withdraw dividends, he wrote a similar application, specifying the amount (partially/completely),
withdrawal term up to 10 working days. The funds were transferred to the client's bank account specified by the client
when opening the contract. The mentioned procedure is the same for withdrawal of dividends and for withdrawal of
the main invested funds. Reports were provided to the client. On the Russian market, reports were provided to the
client once a quarter, but the client could request a balance sheet and a report at any date upon request. From
01.01.2015, the state programme IIS (individual investment account) was introduced. It meant the possibility to get a
tax deduction from investments. There are several types of IIS, according to one of them, a tax deduction is received
for the amount of investment of 13 per cent, but not more than 52 thousand rubles. To get a tax deduction, you need
to keep the money in investments for at least 3 years. The tax deduction is received for the amount of investment up
to 400,000 rubles. And the second type - an individual (client) is exempt from paying tax on profits. The formula is the
same, a tax deduction is filed for the amount of tax paid. When he (M.V. Danilenko) came to QBF afer a break in 2019,
he was hired as a specialist in the customer support department. His responsibilities included working with the
company's current clients, both Russian and international. His direct supervisor was Maslennikov Vladimir, this is the
vice - president of the company. Maslennikov also communicated with clients, managed the support department, it
was a matter of control - he (Vladimir Maslennikov) monitored the work of managers, gave instructions on meetings
with clients and communication. The following managers worked in the support department: Daria Meshkova,
Vyacheslav Morozov, Ruslan Sokolov, Artur Avanesyan, Olga Bataeva, Alexander Kholmanskikh, Elena Iosifova. The
staff of the support department was first located in the general Open Space, then in a separate office. In general, he
432
(Danilenko M.V.) knew about the availability of the international market since 2018. He (Danilenko M.V.) also received
information about strategies in 2018. He learnt detailed information on working with clients from Maslennikov. The
clients invested cash in shares of large foreign companies. Earlier, in 2018, the international market clients he
accompanied worked with QB Capital, a Cyprus - based company with which trust management agreements were
concluded. When he came in 2019, QB Capital Cyprus Company was no longer in existence and the clients had to re -
sign the contracts - entering into them with companies: "White lake" - a Cayman company, SIMTELLIGENCE - which is
Hong Kong, and VL - consulting - Russian (Russian company, the business representative of White lake). There was a
mail for contracts, he (Danilenko M.V.) wrote a letter with a request to prepare a package of documents for the client
with whom the meeting was scheduled, his full name. He received a letter in reply, which contained the prepared
contracts. Each client had to sign contracts with all three organisations - "White lake", SIMTELLIGENCE, VL - consulting
- instead of one previously concluded contract. The client signed a trust management agreement and investment
declaration with "White lake management", an agreement with SIMTELLIGENCE, and an agreement and investment
declaration with VL - consulting. Each contract had two columns, one in English and one in Russian. When he printed
out the contracts, all the contracts already had facsimiles of his signature and stamps. The contracts on behalf of the
company "White lake" were signed on behalf of E.V. or E.L. Gorobets, the contracts on behalf of VL - consulting were
signed by a facsimile on behalf of Nikolay Padalko. As to SIMTELLIGENCE, no specific name appeared in the contract,
although both the seal from the organisation and the signature of the representative of the facsimile were already
present. In meetings with clients from international markets, he explained that it had become unprofitable to operate
in Cyprus, as they began to increase duties there, and in order to optimise costs and tax burden, they decided to move
to the Caymans, which are considered one of the best jurisdictions where English law, which has weight in the
international arena, is in force. In addition, QB Capital was in liquidation and in order to legitimise the clients'
relationship with the companies, an updated set of documents had to be updated. He (Danilenko M.V.) learnt this
information from Maslennikov and Spinka. The company "White lake" is registered in the Caymans. The client became
a client of "White lake" when signing a contract with this organisation, but SIMTELLIGENCE had an account with
"White lake", within which each client had sub - accounts. VL - consulting is the Russian business representative of
White lake, the contract with which was signed in order to deal with clients' issues in the Russian Federation. All
details about the work of foreign organisations and their interaction were explained to him (Danilenko M.V.) by
Maslennikov Vladimir and Ruslan Spinka. On behalf of "White lake", "SIMTELLIGENCE COMPANY LIMITED" he
accompanied the signing of contracts by clients who had previously concluded contracts with QB Capital LTD to
update the package of documents. Maslennikov provided him with the list of clients who had concluded contracts
with QB Capital LTD. He (Danilenko M.V.) did not accompany the signing of the clients' contracts with "QCCI Ltd.", but
saw in the contracts the phrase about the termination of the client's relations with "QCCI Ltd." and about the
beginning of relations with SIMTELLIGENCE. According to information from Spinka and Maslennikov, Yurmaster Ltd. is
a layering organisation. Legally it was as follows: QCCI Ltd. could not directly transfer the management of funds and
accounts to SIMTELLIGENCE and White lake, so the management of accounts was transferred from QCCI Ltd. to
Yurmaster Ltd., i.e. through the Russian Federation, and then from Yurmaster Ltd. the management of accounts was
transferred to SIMTELLIGENCE and White lake. Regarding the receipt of dividends by the client under the concluded
agreement, he (Danilenko M.V.) explained that the client signed a notification on the sale of assets (the term of 30
working days for the sale of these assets), afer their expiry, when the assets were sold out - he signed an order for
withdrawal of funds. According to the regulations the term of execution of the second document was several weeks,
but in fact everything happened longer because (as the management explained) - problems with counterparties (they
do not withdraw as it is necessary to confirm the legality of the origin of funds, these documents they collected from
clients and sent to support@wl - mnt.com. This procedure concerned both the withdrawal of dividends and the main
invested funds. Dividends were issued both in cash and in non - cash form, at the client's request - this concerns the
international market. The client fills out an order to accept cash - writes a receipt that he received the money.
Maslennikov gave money in cash to clients under his (Danilenko M.V.) presence - he remembers at least 10 such cases,
among them there were clients whom he (Danilenko M.V.) accompanied. He personally had no dealings with cash.
Regarding JSC "QBF Financial Group", he (Danilenko M.V.) explained that it is the parent company of the Russian
business of the QBF group of companies, its founder is Roman Valeryevich Shpakov. In my work I have not come
across any documents signed on behalf of the said Company. QBIF Investment Company LLC is a Russian company
433
with 4 licences. Director General - S.A. Matyukhin, founder - R.V. Shpakov. On behalf of QBIF LLC with his (M.V.
Danilenko's) participation, trust management agreements and brokerage service agreements were concluded with
clients in 2018. QBF Asset Management LLC is a management company that deals with open - end and closed - end
mutual funds. It has funds with securities and with real estate - the facilities are located in Odintsovo and
Severodvinsk. The general director is Smirnova Yaroslava Gennadyevna, the founder is Shpakov R.V. He knows that
Shpakov R.V. was the founder and head of the company. As far as he knows Z.V. Munaev was the managing partner,
E.A. Rossieva was the chief lawyer, V.S. Pakhomov was engaged in development of regional branches, V.S.
Athanasiadou L.inda, knows by sight, her position is unknown to him, A.V. Korzh. Korzh A.V. was the director of the
sales department of the Moscow office of the subsidiary company QBEF, Matyukhin S.A. was the general director of IK
QBEF, Spinka R.V. was the director of the sales department (he supervised the sales staff, he was a more senior
manager than Maslennikov), Erzikyan G. R. was the client manager.R. was the client manager of the Sales
Department, N.S. Padalko was the head of the Sales Department (previously he was the General Director of "VL -
Consulting"), Y.N. Orlov was the head of the IT Department, R.F. Amerov is known to him as the head of the Legal
Entities Department, V.O. Plitin was a specialist of the Support Department, Y. Zaitseva was his (M.V. Danilenko's)
manager in 2018, afer that she was engaged in the development of the agent network, D.Y. Meshkova, was a financial
advisor - client manager, specialist of the support department, Frolov V.G. is known to him as the former CEO of LLC
"IC QBEF", Yudin M.S. was previously the head of the sales department, Maslennikov V. was a vice - president, his
(Danilenko M.V.) direct supervisor (is subordinated to Spinka R.). E.V. Gorobets was a signatory of the organisation
"White lake", P.Y. Vlasov was also the vice - president of the company, A.S. Golubev was known to him as the head of
the organisation "QBF" in St. Petersburg, Y.G. Smirnova was the general director of LLC "QBF Management Company",
Y.V. Shaban. Y.V. Shaban is known to him as the General Director of JSC RIF (it is a rental investment fund, which has
real estate objects, clients were offered to receive units of rental real estate funds of JSC RIF instead of investments on
the international market), E. Khanina is known to him as a productologist, she created new products for IC QBF.
Meshkova D.Y., Maslennikov V., Zaitseva Y., Padalko N.S., Korzh A.V., Spinka R.V., Erzikyan G.R., Padalko N.S., Plitin V.O.
communicated directly with clients;
(Vol. No. 266, pp. 77 - 92)
- E.Y. Dorokhina's Testimony

given to her as a witness, according to which, afer graduation, she moved to Novosibirsk, where she worked in the
financial sector, namely in the credit institutions "Sberbank" and "Uni Credit Bank". She had an advert posted on
the website "NN.ru" looking for vacancies. Around November 2019, representatives of QBF Group called her on her
advert and invited her to an interview at the office located at: Moscow, Nab. Presnenskaya 8 (Capital City building of
the Moscow City business centre). Afer the interview, in approximately December 2019, she became an employee of K
- Investment LLC as a financial advisor with a salary of approximately RUB 100,000. She received her salary in cash.
The money was handed over to her by her work colleagues as she was periodically absent from the company's office
during the payroll period, however, afer receiving her salary, she signed her pay slip to receive the money. Her duties
as a financial advisor included: searching and inviting clients, informing clients to sell the company's investment
products and trust management of the clients' invested funds, opening brokerage accounts. She, as a financial
advisor, sold the following products of the company: IPO - non - exchange - traded assets, trust management, opening
of brokerage accounts. Attracting clients to sell the company's products could be done through cold calls to potential
clients, or through social networks via various video bloggers. K - Investment LLC was part of the QBF group of
companies, but she does not know how many organisations were part of this group of companies. The office of QBF
LLC was located at the following address: 8, Presnenskaya Nab. Presnenskaya 8, Moscow City business centre, Capital
City building. The main activity of QBF Group was to attract clients for the sale of investment products and trust
management of funds invested by clients. Roman Shpakov was the head of QBF Group. In addition, the managers
were Munaev Zelimkhan and Matyukhin Stanislav. She does not know who her direct supervisor was, as all financial
434
advisors worked in small groups in an open shared office and each group had the most experienced financial advisor
who coordinated the work of a particular group. During her tenure, QBF changed several financial advisors who
coordinated the overall work. Her fellow financial advisors were: Stella Ramerovna, Izabella Klemeshova, Alexander
Trutnev, Elena Kirilova, Javid Isaev, Ara Balayan, Alexey Murashev, Anton Lazarev, Maxim Fedorov and lawyer Evgenia
Rossieva. She had a working relationship with all of the above people. At the beginning of her employment with QBF
Group, she did not suspect that QBF's activities might be illegal, as the company held a number of licences from the
Central Bank of the Russian Federation to carry out professional activities in the financial sector. Afer law
enforcement officers conducted investigative actions in December 2020 and May 2021 at the offices of QBF Group, she
decided to resign from QBF as she did not see any further prospects in the organisation;
(Vol. No. 266, pp. 98 - 101)
- A.V. Dracheva's Testimony

given to her as a witness, according to which, around 2021, in a common company, she met Tatiana Zavyalova, who
worked at K - Investment LLC. During the conversation, Tatiana explained that she needed an assistant and offered
her a job at K - Investment LLC. She (A.V. Dracheva) agreed with Tatiana Zavyalova's proposal and at the appointed
time came to the interview, which was held in two stages. She was interviewed by Tatiana Zavyalova, hr specialist
Anastasia and Ruslan Spinka. Afer the interview at the address: Moscow, Nab. Presnenskaya d.8 (building "Capital
City" of business centre "Moscow City"), namely 03.03.2021 she was hired as an assistant to the head of the client
support department in LLC "K - Investment". Her duties as an assistant to the head of the client support department
included general assistance to the manager, preparation of reports and schedules, generation of information on
clients for personal managers, who in turn sold the company's products. She had no other duties. Her direct
supervisor was Tatiana Zavyalova, from whom she (A.V. Dracheva) received instructions on her work and also reported
to her on the results of her work; Tatiana Zavyalova's supervisor was Ruslan Spinka. Her (A.V. Dracheva) salary was
approximately 45,000 roubles per month during the probationary period, which she received in cash from Tatiana
Zavyalova, and she did not sign for her salary in any statement. In turn, K - Investment LLC was part of the QBF group
of companies, but she does not know how many organisations were part of this group of companies. The office of K -
Investment LLC was located at the following address: 8, Presnenskaya Nab. Presnenskaya 8, Moscow City business
centre, Capital City building. The main activity of QBIF Group was attracting clients for the sale of investment products
and trust management of funds invested by clients. Roman Valeryevich Shpakov was the head of QBF Group of
Companies. In addition to Tatiana Zavyalova, her colleagues were Marina Burshtein and Lyubov Boltova.
Approximately two months afer her employment with K - Investment LLC, she decided to change the profile of her
activities and moved to the Middle Office of IC QBF LLC, also part of the QBF group of companies. The head of IC QBF
LLC was Stanislav Anatolievich Matyukhin, who was her direct supervisor and from whom she received instructions on
her work and reported to him on the results of her work. As well as all the companies of the QBF group of companies,
it was located at the following address: 8, Presnenskaya Nab. Presnenskaya 8, Moscow City business centre, Capital
City building. Her duties as a "Middle Office" specialist included reviewing and analysing messages from the
company's clients on the corporate mail, forming responses to clients' requests, or redirecting the client's request to a
specific specialist of the organisation. Her salary at OOO IK QBF was approximately 60,000 roubles, which she received
not in cash but on her debit bank card. Afer working at IK QBF LLC until approximately August 2021, she resigned
from IK QBF LLC at her own request due to an increase in the volume of work tasks outside of her competence. During
her employment with QBF, she had to communicate with various employees, namely: Kopylova Maria (formerly the
head of the Middle Office); Butkovskaya Vlada (a specialist of the BEC office); Hasanov Hasan (a specialist of the BEC
office); Kiseleva Kristina (a specialist of the BEC office); Matyukhin Ruslan (a specialist of the BEC office); Korneev
Vyacheslav (a specialist of the BEC office); Maslennikov Vladimir (head of the support department); Padalko Nikolay;
Marina Nikolaeva; Andrey Korzh (head of a number of different departments); Yuri Orlov (head of IT department);
Artem Tallerov; Maxim Fedorov (vice president of the company); Grigor Erzikyan (financial advisor); Yulia Zaitseva
435
(engaged in internet advertising to promote sales of the company's products); Oleg Timokhin (worked as head of BEC
office); Zelimkhan Munayev;
(Vol. No. 266, pp. 105 - 108)
R.V. Dynda's Testimony
as a witness, according to which, in September 2020, he saw an advertisement of the company QBF LLC in the social
network "Instagram". Then he met Murashev Alexei, who at that time was already working in the said company. While
communicating with Murashev Alexey, he (Dynda R.V.) asked whether it was possible to get a job in this company
without having a legal education. In response Murashev Alexey said that it is possible to try. Afer some time Murashev
Aleksey invited him for an interview. In October 2020, he (R.V. Dynda) came to the office of the company LLC IC QBEEF,
located in "Moscow City" in the tower "City of Capitals" at the address: Moscow Presnenskaya Naberezhnaya 8, page
1. He had several interviews. At the first interview there was a girl named Yulia, at the second interview there was also
Yulia, and there was also Isayev Javid, who was the head of the department and the head of the IPO movement
direction. During the interview he was presented the investment activities of the company, they said that the
company LLC IC QBF has four licences of the Central Bank of the Russian Federation. He was also told about the
financial products of the company, which were provided to clients, namely participation in IPO, IIS, trust management
agreements, brokerage services (Russian market), and from March - April 2021, the unit "RIF" (warehouse in
Novorossiysk). Afer the interviews, about a week and a half later he received a call from Alexey Murashev, who told
him that his candidature had been agreed upon by the company's management and that he could go to work. He was
officially employed only in November 2020 at K - Investment LLC. He did not ask the management why he was
employed by this company and not by QBIF LLC, as he did not pay attention to it. He also signed the employment
contract in November 2020. During the period of time from October 2020 to the end of May early June 2021, he
worked as a financial advisor. In the position of financial advisor, he had the following job duties: customer
acquisition, selling the company's products, supporting customer transactions, and advising customers. In addition,
one of the requirements of the heads of departments was that each financial advisor must raise client funds totalling
at least RUR 2,500,000 per month for the company. Afer employment, Avetis was trained for a week. During the
training, Avetis told him about the company's investment activities, the company's financial products, and the sales
of these products. Besides, during the whole period of his employment he (R.V. Dynda) passed various tests on
knowledge related to financial activities. His supervisor was Isaev Javid, also he was the head of IPO direction. Isayev
Javid was subordinated to Korzh Andrey, who in turn was subordinated to Spinka Ruslan, who held the position of
Director of Sales and Customer Service Department at IC QBF LLC. In order to conclude an agreement on the provision
of brokerage services, the client was required to obtain a copy of a passport of a citizen of the Russian Federation,
SNILS, e - mail details, and bank account details for the withdrawal of funds. The client sent the above documents to
his QBF work email, WhatsApp and Telegram application on his phone. Afer that he (R.V. Dynda) entered the client's
data through the Nabix programme. Then this programme formed a package of documents and sent them to the
client by e - mail (these documents were sent to the client for review). At the same moment the client received a sms
message with a code for confirmation to sign these documents, which the client reported. He (R.V. Dynda) entered this
code into the programme and afer that the signed copies of the agreement were sent to the client both from the side
of QBIF Ltd. and from the side of the client. On the side of QB&EF LLC the contract was signed by the General Director
Matyukhin S.A. with an electronic signature. At the same time it was necessary to sign a general agreement, which
was that QBroker LLC participates in the IPO with its own money on behalf of the client, the client ensures this with its
own money, as according to the Russian legislation QBroker LLC could participate in the IPO. In total, from October
2020 to the end of May early June 2021, it had 20 clients who transferred a total of 80 million roubles in cash to their
brokerage accounts. The said clients all participated in the IPO. A total of eleven people worked in his department
with him: Lazarev, Murashev, Lopukhova, Khmilev S., Manaenkov, Bashkirov, Treiman, Said Isaev, Chernyshova, and
Pirogov. He also knew the company QBroker LLC, which worked directly with the top broker, whose details were not
436
disclosed, citing commercial secrecy. Sometime afer the May 2021 holidays, clients began to file complaints about
delayed withdrawals. With this question he (R.V. Dynda) approached Isayev Javid and Korzh Andrey, who explained to
him that the regulatory deadlines were not exceeded and all clients would receive their funds on time. He
subsequently communicated this information to his clients. Afer the search, Korzh Andrei told all the employees not
to tell the clients that the company had been searched, but to say that there had been a failure in the fire - fighting
system, which had caused the servers to malfunction;
(Vol. No. 266, pp. 110 - 113)
- Testimony of G.R. Erzikyan,

given by him as a witness, according to which, from October - November 2018 to February 2019, he worked at F -
Experts LLC as a senior financial advisor. His job duties at both F - Experts LLC and K - Investment LLC included
attracting, counselling, and supporting clients (only individuals). His direct supervisor was Andrey Korzh. In early
December 2018, he received a call from Dianov E.G. who explained that he wanted to hear the terms offered by White
Lake in terms of asset management. They then met with E.G. Dianov in the Capital City BC, south block, 9th floor (8
Presnenskaya Naberezhnaya Street, bldg. 1, Moscow), where they discussed possible terms of cooperation. E.G.
Dianov offered different companies, not only "White lake", but also Russian companies with the possibility of
withdrawing funds in the shortest possible time (10 - 15 working days). E.G. Dianov insisted on "White lake",
explaining that there was no taxation and currency revaluation in this option. One of the following days, being at the
address: 8 Presnenskaya Naberezhnaya St., bldg. 1, Moscow, E.G. Dianov signed an asset management agreement,
which he (G.R. Yerzikyan) sent to White lake's e - mail. At the same time, before signing the agreement, Dianov E.G.
provided all the necessary documents (income confirmation certificate, flat sale and purchase agreement, which
confirmed the origin of Dianov E.G.'s funds). He (Yerzikyan G.R.) also sent these documents together with the contract
to the e - mail of "White lake". Afer verification by "White lake" and "SIMTELLIGENCE COMPANY LIMITED" he received
the invoice (exhibition invoice) and gave it to E.G. Dianov for transfer of funds. Further accompaniment of E.G. Dianov
was carried out by Vladimir Maslennikov. E.G. Dianov invested money in three strategies - stock fund, algorithmic
strategy (robot trading), real estate fund. These three strategies implied, among other things, market risks that could
cause losses of up to 40 per cent. Dianov E.G. had a sub - account (general account) in the company "White lake". No
individual account was opened in the name of E.G. Dianov. E.G. Dianov invested 68,000,000 roubles. The amount of
cash in Dianov E.G.'s account fluctuated depending on the market conjecture; at the end of 2019, the balance on the
portfolio was plus 12 per cent to the balance. During the pandemic, when the U.S. stock market collapsed, the
portfolio balance declined. E.G. Dianov then became actively worried and, by the end of the summer, filed the
necessary order to begin withdrawing funds. At the time of the application, he had approximately $930,000 remaining
in his account. E.G. Dianov wrote applications to foreign companies (regulators, banks), which take a long time to
review, and White lake also had problems with transferring funds from abroad to Russia. At the same time, the
company offered in every possible way to transfer assets to the Russian jurisdiction. At the beginning of December
2020, Vladimir Maslennikov proposed to E.G. Dianov to start repayment of funds from $100,000, to which E.G. Dianov
explained that he refused to receive less than $500,000. He (Yerzikyan G.R.) also explained that before signing the
agreement, the client provided all the necessary documents (income confirmation certificate, client's questionnaire,
passport of the Russian Federation, foreign passport, possibly a certificate of criminal record). He (Yerzikyan G.R.) sent
these documents together with the contract to the e - mail of "White lake". Afer verification by "White lake" and
"SIMTELLIGENCE COMPANY LIMITED" he received an invoice and gave it to the client for transfer of funds. The main
activity of "White lake" is asset management. On the territory of the Russian Federation, he (G.R. Erzikyan)
represented the interests of this company together with Andrey Korzh. The main activity of "SIMTELLIGENCE
COMPANY LIMITED" is treasury and brokerage activity, and the main activity of "QCCI Ltd" is asset management and
brokerage activity. The main activity of "White Lake Management Ltd." is asset management, brokerage activities. Also
he (G.R. Erzikyan) explained that the client could independently purchase shares through "White lake", as such an
437
opportunity was available through "QBF" LLC (Saint - Petersburg stock exchange). As for the employees of the
company "QBF", he knows that the owner of the company is Shpakov R.V. Spinka R.V. was the head of the sales
department, Padalko N.S. was the general director of LLC "VL - Consulting", Korzh A.V. was its head, Rossieva E.A. was
engaged in legal support of documents, Golubev A.S. was an employee of the office of St. Petersburg, Smirnova Y.S.
was a member of the staff of the company. St. Petersburg, Smirnova Y.G. was an employee of MC QBF LLC, Kharina
E.N. was in charge of marketing material of IC QBF LLC;
(Vol. No. 266, pp. 114 - 124, Vol. No. 286, pp. 43 - 49)
- Testimony of S.R. Ermolenko,

given to her as a witness, according to which, in early July 2019, she posted her CV on the website "HH.ru" and in the
same month she was invited for an interview at the company "QBF". The interview took place in the structure of the
Capital City tower on the 9th floor. The interview was conducted by Anastasia Zaripova, a recruitment officer.
According to the signed agreement, she (S.R. Ermolenko) was to be employed by QBF from 25.09.2019. She was
enrolled to the position of the Head of the Investment Services Department of K - Investment. In this position, she
worked till 10.06.2021. She was in charge of a department with a strength ranging from 1 person (at the time of
commencement of employment) to 6 persons later. The working day started with a meeting, during which she set
tasks for the employees of the department on cold calling and "incoming leads", holding meetings with potential and
existing clients. By "cold base" we mean an electronic database with lists of telephone numbers and full names. At the
time of the beginning of her labour activity the base was already available on the work computers. All clients from
"incoming leads" were also entered into this database. Under "incoming leads" is understood when a client
independently lef an application on the official website of IC QBF. She also trained her subordinate employees in
sales techniques and in the formation of reports on the results of the day (how many clients were called, how many
appointments were made, the total volume of attraction). K - Investment offered clients products of IC QBIF and MC
QBIF, namely: trust management, individual investment account, brokerage services, consulting and brokerage
services, open mutual funds, IPO (initial public offering on the stock market). Contracts with clients were concluded
either in the company's office or remotely by sending the contract to the client's e - mail address. When the contract
was sent by e - mail, it was already signed by the EDS of the General Director Matyukhin S.A. Clients opened a personal
brokerage account with IC QBF, to which the client subsequently transferred funds. Subsequently, the client could
independently manage using the QUIK platform, namely to purchase securities. The client could also use QUIK
(consulting and brokerage services), receive consultations from a "portfolio manager". In this case, the client makes
the decision to buy or sell securities independently. In addition, the client could use trust management services. In
this case, the client fully trusts the "portfolio manager" to manage his account. "The "portfolio managers" were
employees of QBIF. As for the employees of QBF Group, she knows that R.V. Shpakov was the beneficiary of QBF
Financial Group, Z.V. Munayev was known to her as the head of QBF Financial Group, S.A. Matyukhin was the General
Director of IC QBF, E.A. Rossieva was a lawyer;
(Vol. No. 266, pp. 126 - 130)
438
- Zavyalova T.G.'s Testimony
given to her as a witness, according to which, from March 2018 to December 2018, she worked at K - Investment LLC as
a manager of the client service department. She was invited to this department from PJSC Bank FC Otkrytie by Reimer
Natalia. In the period from December 2018 to September 2020, she was on maternity leave, and from September 2020
she took up the position of the Head of the Client Support Department for the Russian Securities Market at FG QBIF
LLC (General Director R.V. Shpakov). The main activity of LLC IC QBF and LLC MC QBF Asset Management was to
provide financial services to individuals and legal entities related to the investment of funds, clients were provided
with access to the stock exchange. Each client of the company joined the contract (public offer), which was posted on
the company's website, by signing a declaration of accession to the contract, a declaration of risks and a personal
data questionnaire. Each client signed a risk declaration, which contained all market and systemic risks that the client
may face, as a result of these risks the client may fully or partially lose the invested capital. The client of the company
could gain profit by depositing funds into a personal account for the selected product or to buy securities opened
with the company, provided that they were successfully invested. At the same time, each client of the company was
explained in detail all the risks associated with investing funds, according to the legislation of the Russian Federation
and the rules established by the Central Bank. QBIF LLC has obtained all necessary licences in accordance with the
legislation of the Russian Federation, namely four licences of the Central Bank of the Russian Federation were
obtained at different periods of time: depositary, securities management, brokerage and dealer licences. LLC MC QBF
Asset Management had a licence to manage investment funds, unit investment funds and non - state pension funds.
The office of the organisation where she worked was located at 8 Presnenskaya Naberezhnaya Street, Bldg. 1,
Presnenskaya Embankment, Moscow. The office was on the 9th floor of the Capital City building, south block. There
were five meeting rooms for clients. Also in the office there were offices: IT, HR department, marketing department, 2
support department, sales department, which had 60 - 70 employees and the office of the director. Its direct manager
was Spinka Ruslan Valeryevich. Her (Zavyalova T.G.) direct duties included: organisation and control of the support
department employees, selection of employees in her own team, adaptation of employees, development of the
system of material and non - material motivation of employees, development of standards of work of the support
department, training of employees on support of clients according to the regulations, which are posted on the
website of the companies LLC IC QBF and LLC MC QBF Asset Management during the probation period. Her salary
consisted of a salary and a performance bonus based on the number of meetings of the whole department with
clients, calls made by the employees of the department, and the data from the in - house appraisal. She received her
salary by statement at the end of the month. The statement and the money were brought to her office by the
accounting staff. Clients concluded the following types of agreements with the above companies: trust management
agreement, including an individual investment account, brokerage services agreement, including an individual
investment account, depositary services agreement; the client could also apply for the purchase of open - end,
exchange - traded and closed - end mutual funds from any management company, including LLC MC QBF Asset
Management. The client could conclude an agreement both by personally coming to the company's office and signing
a paper version of the application for joining (the form was also posted on the website in the information disclosure
section), and remotely by sending documents to the company's official mail and signing electronically. In this case,
the contract signed on both sides was sent to the client's e - mail address. Afer signing the application for joining the
main agreement posted on the websites, the client was assigned a number and the client had the right to top up his
account using the details specified in the application. Afer that, the client could track all transactions on his account
in two ways: online in his personal cabinet on the company's website (where he had to register, receive a login and
password) and through official reports sent to the company's client at the end of each reporting period. Under trust
management agreements the report was sent quarterly, under brokerage services the report was sent daily on the
days of any transactions on the account. At the same time, the client had the right to apply to the company and
receive a certified report on paper for any period. The client, being on brokerage service, could perform trading
operations on his account in the following ways: by signing a personal order to purchase the selected asset in the
company's office and by submitting a handwritten signed order from his authorised e - mail to the company's
(broker's) e - mail specified in the agreement; by calling, introducing himself and giving a code word to the broker's
dealing centre phone number specified in the agreement; by installing the QUIK trading terminal (Russian sofware
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package for arranging access to the trading platform); by using the QUIK trading platform (Russian sofware package
for arranging access to the trading platform). When signing statements, the client was provided with a telephone
number for voice orders to buy or sell securities. She knows that S.A. Matyukhin was the general director of QBIF LLC,
Y. Smirnova was the general director of QBIF MC LLC, and R.V. Shpakov was the general director of QBIF FG LLC;
(Vol. No. 266, pp. 134 - 139)
- E.G. Zolotova's Testimony
given to her as a witness, according to which, from January 2021 to 23 June 2021, she worked as a leading specialist in
the human resources department of the company F - Experts LLC. Her workplace was located at the following
address: 8 Presnenskaya Embankment, Moscow, business centre, Capital City Tower, south block. She had no
subordinates. Her immediate superior was Valeria Gubanova, HR Director. Her job duties included the full cycle of
personnel management, namely hiring, dismissal, work with sick leaves, registration of maternity leaves and so on. At
F - Experts LLC, she signed documents only relating to the company's personnel work. She never signed documents
related to financial matters. From March 2021, delays in the payment of wages began. Currently, the company has not
paid her in full her salary for May and June 2021. In connection with the above, she decided to resign from this
company. The company F - Experts LLC was listed on the website "NN.RU" under the logo of the company "QBF". She
was aware that QBF worked in the field of investment activities. Stanislav Anatolievich Matyukhin was one of the
managers of QBF LLC, Zelimkhan Visaitovich Munaev was a top manager of QBF LLC, and Evgenia Anatolievna
Rossieva was an employee of the legal department of QBF LLC;
(Vol. No. 266, pp. 141 - 144)
A.V. Zykov's Testimony

given as a witness, according to which, until October 2020, he lived in Tula, where he worked at BKS as a counsellor.
He placed his CV on the website "NN.ru" to find a more interesting and prestigious vacancy. In October 2020, he
received a call from representatives of QBF Group inviting him to an interview in Moscow. He was interviewed by
Artyom Tallerov, who is the Head of Sales in the Sales Department of the QBF Group. Afer the interview at the
address: Moscow, Nab. Presnenskaya 8, building "Capital City" of the business centre "Moscow City", namely in
October 2020, he was hired as a Financial Advisor of the Client Relations Department at K - Investment LLC. His duties
as a financial advisor included: searching and inviting clients, informing clients to sell the company's investment
products and trust management of clients' invested funds, opening brokerage accounts. As a financial advisor, he sold
the company's products: IPO - over - the - counter assets. He did not sell any company products other than IPOs. The
organisations on whose behalf the financial products were sold were QBroker LLC and QBIF LLC. The solicitation of
clients for the sale of the company's products may have been through cold calls to potential clients or through social
media via various video bloggers. His direct supervisor was Tallerov Artem, from whom he received instructions on his
work and reported on the results of his work. Artem Tallerov's supervisor was Javid Isayev, and Javid Isayev's
supervisor was Andrey Korzh. His (A.V. Zykov's) salary was approximately RUB 70,000 per month, which included fixed
payments based on the results of the plan, as well as a % of the amount of funds raised. He received his salary in cash
from Tallerov Artem, and he did not sign for his salary in any statement. During the entire time he worked at K -
Investment LLC, he attracted approximately 10 clients and funds totalling approximately RUB 15,000,000. In turn, K -
Investment LLC was part of the QBF group of companies, but he does not know how many organisations were part of
440
this group of companies. The office of K - Investment LLC was located at the following address: 8, Presnenskaya Nab.
Presnenskaya 8, Moscow City business centre, Capital City building. The main activity of QBIF Group was attracting
clients for the sale of investment products and trust management of funds invested by clients. The head of QBF Group
of Companies was Roman Valeryevich Shpakov. He began to have doubts about the legality of the actions of the
management of QBF Group of Companies afer law enforcement officers conducted investigative actions in December
2020 in the offices of QBF Group of Companies, and the company's clients began to file complaints and requests to
withdraw their invested funds. Afer the investigative actions, he asked Tallerov Artem about the legality of the
company's actions, to which Tallerov Artem explained that there was no cause for concern and the investigative
actions taking place in the company's office were the work of competitors who were trying to paralyse the activities of
the QBF Group of Companies. He (A.V. Zykov) worked at K - Investment LLC until approximately May 2021, afer which
he resigned from K - Investment LLC at his own request due to the fact that in May 2021 the company started to "fall
apart" and salary delays began. During his employment with QBF, he had to communicate with various employees
such as: Maria Kopylova - BEK office; Yulia Zaitseva - BEK office; Alexey Chentsov - financial advisor; Vladislav -
financial advisor; Ekaterina Dorokhina - financial advisor; Albert - financial advisor; Anton Lazarev - financial advisor;
Ara Balayan - head of sales department; Nikolay Padalko - was one of the managers; Stanislav Matyukhin - was one of
the managers; Maxim Fedorov - Vice President of the Company (Senior Financial Advisor); Alexey Trunyaev - Financial
Advisor; Avetis Vartanov - Financial Advisor Training Instructor;
(Vol. No. 266, pp. 148 - 151)
Ibrahimov E.E.'s Testimony
as a witness, according to which, around September 2020, while looking for a job, he posted his CV on the website
"HH.ru". Some time later, in October 2020, he received a call from Zaripova A., inviting him to an interview. The
interview took place in the company's office located in Moscow City in the City of Capitals Tower at the following
address: 8, Presnenskaya Embankment, 8, p. 1. The first interview was attended only by Mr Shkrut A., who was a
department head in the company. During the interview A. Shkrut presented the investment activities of the company,
explained that the company LLC IC QBF has four licences of the Central Bank of the Russian Federation. Also he (E.E.
Ibragimov) was told about the financial products of the company, which were provided to clients, namely
participation in IPO, IIS, trust management agreements, brokerage services (Russian market). At the end of the
interview he (E.E. Ibragimov) was informed that he would be contacted upon approval of the candidate. About a week
later on 16.10.2020 he was invited to the second interview, which was held with Spinka R., who was the director of the
sales department and Shkrut A. During the interview they also told him about the financial activities of the company.
Before communication he (E.E. Ibragimov) asked Shkrut A. about negative reviews about the company LLC IC QBF, as
these reviews were posted on the site "Banki.ru". In response, Shkrut A. said that these negative reviews were written
on purpose to spoil the reputation of the company. At the end of the interview Spinka R. said that he (Ibragimov E.E.)
was hired by the company. The first working day was 19.10.2020. Afer he started work, the training began, which
lasted two weeks. The first week of training was conducted by Beladed Sveta, who told about the history of the
company, said that the company QBF LLC has four licences from the Central Bank of the Russian Federation, that the
company has branches all over Russia, that career growth is possible, and so on. The second week of training was
conducted by Avetis, who spoke about the company's financial products and how to sell them. At the end of the
training he (E.E. Ibragimov) was tested and signed an agency contract and then a labour contract. However, this
contract was concluded between him (E.E. Ibragimov) and K - Investment LLC. He did not ask the managers why he
was employed in this company and not in LLC IC QBF, as he realised that LLC IC QBF was avoiding paying taxes in this
way. He was employed by the company as a junior financial advisor. As a junior financial advisor he had the following
job duties: attracting clients, selling the company's products, supporting transactions with clients, consulting clients.
441
In addition, one of the requirements of the heads of departments was that each junior financial advisor should attract
client funds to the company per month for a total amount of at least 3,000,000 roubles. Six people worked with him in
his department: Serov, Abass, Anelia, Mishin and Shayda. During further testing and training, Avetis and Fedorov M.
instructed the employees that if a client asked about negative feedback, they should tell them that they were not
working at the time and were not aware of it. Since about November 2020 he (E.E. Ibragimov) had doubts about the
recognition of the activity of the company LLC IC QBEF as legitimate. However, the management (Spinka R. and
Shkrut A.) did not give a precise answer to all his questions about the activities of the company, and sometimes
evaded the answer. In addition, in November 2020, during the withdrawal of funds belonging to gr. Volochkova and
the client (data not known) under the supervision of the financial advisor Samoilov V., Ermolenko Stella began to
make claims about these actions in the part that he did not persuade the client to leave the money in the company.
This client (whose details are not known) withdrew 30 million roubles. Afer these events, he (E.E. Ibragimov) was
contacted by his first client who wanted to participate in the IPO. In order to participate in the IPO, it was necessary to
conclude an agreement on the provision of brokerage services. From the client it was necessary to receive a copy of
the passport of a citizen of the Russian Federation, SNILS, e - mail data, and details of a bank account for withdrawal
of funds. The client sent these documents to him (E.E. Ibragimov) on his work email "QBF", application in the phone
"WhatsApp" and "Telegram". Afer that, he entered the client's data through the programme "Nabix". This programme
then generated a package of documents and sent it to the client via email. These documents were sent to the client
for familiarisation. At the same moment, the client received an SMS message with a code for confirmation to sign
these documents, which the client reported. This code he (E.E. Ibragimov) entered into the programme and afer that
the signed copies of the agreement were sent to the client both from the side of LLC IC QBF and from the side of the
client. On the part of QB&EF LLC, the contract was signed by S.A. Matyukhin, General Director, with an electronic
signature. In total, from November 2020 to April 2021, he had 7 - 8 clients who in total transferred funds in the amount
of 14 - 15 million roubles to their brokerage accounts. The said clients all participated in the IPO. Before he introduced
the first client into the company, he had a conversation with Ruslan Sokolov, who assured him that the company's
activities were legal and that there was no fraud on the part of the company's management. This conversation
occurred because he (Ibragimov E.E.) at that moment had doubts about the legality of the company and he did not
want the client to transfer money to an unknown place. Besides, from the moment he was employed by the company
the client was offered to sign a general agreement. This agreement consisted in the fact that it was another account of
the company to which the client's funds were transferred and from which the funds were allegedly later transferred to
the settlement account of QBroker Ltd. The funds were then transferred to the top broker. In the course of the
communication, Spinka R. informed him that the top brokers were: "Interactive Brokers", "Fidelity" and "Saxobank".
In January 2021, Korzh A. told at meetings that from January 2021 it was mandatory to sign a master agreement with
clients, explaining that the client would receive a higher allocation percentage for this and would be charged an
additional five per cent on the account balance during holidays. The financial advisors were also motivated by the fact
that they would be paid an additional bonus. However, the company did not fulfil these obligations towards the
clients as well as towards the financial advisors. During all the time he worked in the company he saw his direct
supervisor R.V. Shpakov, his deputy Z.V. Munayev, as well as the General Director of QBIF LLC S.A. Matyukhin, N.
Padalko, who supervised the activities of WhiteLake, Argento, D. Isaev, the head of IPO direction. The head of QBroker
LLC was Orlov Y., but he had never seen him in person. Sometime afer the May 2021 holidays, clients began to file
complaints about the delayed withdrawal of funds. Spinka R. and Shkrut A. explained that the regulatory deadline
had not passed and that all clients would receive their funds on time. He (E.E. Ibragimov) subsequently
communicated this information to his clients. On 25 or 26 May he met Shkrut A. Serov D. and others who told him that
the office was being searched. Then they met Maslennikov V., who said that since the office was being searched they
could go home. The next day, while in the office, in the morning, Shkrut A. called him (E.E. Ibragimov) and Serov D.
and suggested that they go outside on the pretext of talking. Once outside, they went aside to a neighbouring tower,
where Shkrut A. demanded that they switch off their phones and show him that they had actually done so. Having
done so, he said that it was a "Financial Pyramid". Then he (Shkrut A.) said that if there was an opportunity to
withdraw money, the money should be withdrawn now and he would not interfere. Then he (E.E. Ibragimov) returned
to the office and went to the personnel department to pick up his labour book. Serov D., having returned from the
personnel department, said that the woman in the personnel department from whom he took the labour book said
442
that it was a "Financial Pyramid". Serov D. specified that when the woman said this, she was surprised that the
company's employees did not know that QBF LLC was a "financial pyramid scheme". Salary in this organisation was
given in an envelope to each financial advisor, Isayev D.'s department received the most as he was the head of IPO.
Also around 25 - 26 January 2021 on the day of salary there was a situation when Korzh A. was standing with a case
with a volume of 20 litres, in which there were cash funds. He (E.E. Ibragimov) realised this because at that moment
Korzh A. was talking to an unknown man on the phone. During the conversation they discussed the money. Korzh A.
told the man on the phone that he had some money and was ready to give it to him, and the man was also told to take
this amount of money or nothing. That was the end of the conversation;
(Vol. No. 266, pp. 153 - 158)
- I. N. Ivanova's Testimony
given to her as a witness, according to which she was a founder of LLC "Trade House 89" with 100%, the size of the
authorised capital was 10,000 or 20,000 roubles. This company was established by her in 2017, the main type of
activity is "Operation of real estate objects". The company was registered with 46 Tax Inspectorate of Moscow. The
head of this company (general director) since summer 2020 was Vadim Nikolayevich Kuzmich. From the date of
formation of OOO Torgovy Dom 89 until the summer of 2020, she was the general director of the company. At the time
when she was the CEO of OOO Torgovy Dom 89, the company was not actually operating. At the moment, this area
was handled by the director Kuzmich V.N. In June 2020, she was hired by Millhouse Invest LLC as the general director.
According to the minutes of the meeting of the founders of the company, the initiator of her appointment as CEO was
three individuals and one legal entity, which are the founders of Millhouse Invest LLC. The representative of the legal
entity, Indep Smart LLC, at the time of her appointment was Shaban Y.V. She has known Shaban Y.V. since 2015, they
worked together in the Nezavisimost Group of Companies engaged in the sale of foreign - made cars. According to the
employment contract signed by her, the term of her duties as CEO of Millhouse Invest LLC was to be 1 year. The staff of
Millhouse Invest LLC consisted only of the position of general director. She has not managed the operations of
Millhouse Invest LLC since the summer of 2021. In August 2021 she wrote an application to Shaban Y.V. with a request
to dismiss her from the position of the general director of Millhouse Invest LLC. At the moment she continues to be the
general director of Millhouse Invest LLC, as the management of Indep Smart LLC has changed and she has not been
legally dismissed from the position of director of the company. She did not give powers of attorney to manage the
company to anyone. During the year of her work as a director of Millhouse Invest LLC, she signed the main sale and
purchase agreement for the kindergarten, the agreement between Millhouse Invest LLC and the developer's
company. During the period when she was the director of Millhouse Invest LLC, several payments were made by Indep
Smart LLC to the developer for the kindergarten building. The source of origin of these funds is not known to her. She
also signed agreements with the Moscow Energy Company (heating services) and Mosvodokanal, and corresponded
with the Prefecture of the Central Administrative District. She did not sign any other financial documents. Her salary,
according to her employment contract, was supposed to be 30,000 roubles per month, but she did not actually
receive a salary. She does not know the reasons for the failure to transfer her wages to her account. The salary has not
been paid to her;
(Vol. No. 266, pp. 159 - 162)
A.K. Ignatov's Testimony given as a witness,

according to which he has a qualification certificate of FFMS 1.0 since 2018, which confirms that he is a qualified
specialist in brokerage activities. At the beginning of 2017, he received an offer from a former colleague at VTB Bank,
443
Dmitry Ivanovich Rykov, to be employed by QBF Group as a Lead Financial Advisor with a salary of approximately RUB
85,000. He was interested in this offer, therefore, in September 2017, an agency agreement was concluded between
him (A.K. Ignatov) and a company from the QBF group, the exact name of which he cannot explain at the moment.
Within the framework of the concluded contract he did not have duties to visit the office as a regular employee, but
within the framework of this contract he could provide consulting services to clients and advertise products of the
group of companies. He was interviewed for employment by Vladimir Pakhomov, the then Director of the branch
network. From 2016 to 2020, Dmitry Ivanovich Rykov was the Director of the Tyumen Branch of LLC IC QBF. The Head
of the department from 2017 to 2021 was Igor Aleksandrovich Chupin, who in 2021 afer promotion became the
Director of the branch. The following persons were employed in this office at different times as financial advisors:
Cheban Nikita, Arina Butorina, Gopp Artem, Misak Abromyan, Lazovsky Sergey, Panov Denis, Kocherenko Evgeniya.
On the basis of an agency agreement, he engaged individuals who invested their funds in QBF Group products. Out of
all the clients consulted by him, about 20 clients were interested in the services of the companies, with 8 of them were
concluded "Agreements on direct access to the securities market" on behalf of "QCCI" and trust management
agreements of LLC IC QBF, under which the clients transferred cash funds in the office of LLC IC QBF, located at the
address: Tyumen, Maksim Gorky St., 74. The procedure for signing the agreement was as follows. Afer receiving a
verbal agreement from the client to co - operate with QBF Group, the client would come to the office. The contract
was signed sometimes in the presence of the head of department Chupin I.A. In absence of Chupin I.A. the contract
was handed over by him (Ignatov A.K.), however the contracts with signatures on behalf of "QCCI" he (Ignatov A.K.)
took from Chupin I.A. The representative - signer in the contracts on behalf of "QCCI" was Gorobets Elena, which he
did not see in his office, as it was explained by Golubev Alexey at the videoconference that Gorobets Elena is in
Moscow. Since there was no cash equipment in the said office, afer signing the contract, the client handed over the
cash to the manager, namely Chupin I.A., or put the money in the safe installed in the office cabinet. In return, Chupin
I.A. gave the client a cash receipt with the seal of the company "QCCI". These cash funds were neither collected by him
nor by Chupin I.A. and were not entered into the brokerage account of "QCCI", and according to the information
received from the branch management, they were taken by the representatives of LLC IC QBF - Pakhomov Vladimir
Sergeevich, Golubev Alexei Sergeevich, Maslennikov Vladimir, Orlov Yuri Nikolayevich, what happened with the
money in the future he does not know. A month afer the conclusion of contracts with clients, reports on transactions
on trading accounts were sent to their e - mail accounts, which reflected information on the state of the portfolio and
purchased assets. He does not know who exactly prepared the reports, these reports came from e - mail addresses,
from domains with the abbreviation "QCCI" or QBF in their names. The contracts were concluded for a period of 1
year with automatic prolongation if no withdrawal order was received from the clients. In 2019, some clients of "QCCI"
began to experience delays in withdrawing funds from "QCCI" accounts, according to Dmitry Ivanovich Rykov and Igor
Alexandrovich Chupin due to a temporary delay in transferring funds from foreign accounts to the Russian
jurisdiction. In turn, Rykov D.I. and Chupin I.A. received information from Pakhomov V.S. and Golubev A.S. Dividends
to clients were paid in cash, because during a video conference held by Golubev Alexey, he (Ignatov A.K.) became
aware that in the central office of QBF, located in Moscow, there is a cash register equipment in which clients' funds
are deposited, as well as paid in cash. At the end of May 2021 it became known from public sources that "QCCI" was
liquidated, but when the process of transferring clients to WL in the summer of 2019 at the video conference held by
Golubev Alexey, it was reported that the company "QCCI" is no longer operating, as the shareholders of the company
do not see the sense in obtaining a licence from the European regulator, because of the duration of this process, as
well as that clients can not receive their invested funds because the company has only illiquid assets, which are in the
process of the company Also during the videoconference Golubev Alexey explained that he would clarify the
information about the placement of clients' assets on trading accounts, but there were no clarifications on the assets
either from Golubev A. or from the official sources of the company. He (A.K. Ignatov) provided products of the
company's licence activity in LLC IC QBF, namely: trust management, brokerage services, OPIF "Euro Bonds" and OTC
option contracts. The company also had clients who invested in these products of the company and did not receive
funds afer the expiry of the contracts. The name of the structural product "On Demand" is a product with a fork of
two fixed rates, which are linked to the underlying asset index "RGBI", which tracks the average price dynamics of
federal loan bonds and is concluded for a different time period at the choice of the client from 6 months to 3 years. In
this product, the buyer of the option was QBIF LLC and the seller of the option was Q-BROKER LLC. The ultimate
444
obligations to clients under this option agreement are borne by Q-BROKER LLC due to the fact that Q-BROKER LLC is
the seller of the options and QBIF LLC is the executor of the client's instructions under the transaction in fulfilment of
its obligations. "IPO" was a structured product where the underlying asset was the company going public. This option
contract did not imply the actual acquisition of shares of companies in the initial public offering at the expense of the
client's funds. The following clients invested in "QCCI": Vyacheslav Yurievich Travin (approximately $20,000),
Alexander Yurievich Parfenov (approximately $120,000; RUB 7,000,000), Igor Vitalievich Minyailo (approximately
$30,000), Maria Sergeevna Zgrebneva (approximately $12,000), Vladimir Petrovich Protasov (approximately $500,000;
RUB 3,000,000), and Nikolai Alexandrovich Cheryatyev (approximately $30,000). The following clients invested in QBIF
IK LLC: Tatyana Pavlovna Karlysheva (approximately RUB 3,000,000), Vladislav Anatolievich Chebotnikov
(approximately RUB 2,500,000), Mikhail Vladimirovich Kazachek (approximately RUB 6,000,000), Elena Vladimirovna
Nikulina (approximately RUB 5,000,000), and Vladimir Leonidovich Troshin (approximately RUB 1,000,000). As far as
he knew, Yuri Orlov held the position of IT - specialist in QBF group of companies, however, he was surprised to learn
at the open conference of QBF group of companies in YouTube that he (Yuri Orlov) is the head of Q-BROKER LLC. He
also knows that Roman Valeryevich Shpakov was the main shareholder in QBF group of companies, the shareholders
were also V.S. Pakhomov and Z.V. Munayev;
(Vol. No. 267, pp. 1 - 6)
- A.V. Ilyin's Testimony given by him as a witness,

according to which he worked in QBF Group of Companies from 02.07.2018 to 01.07.2021, namely from 2018 in QBF
Investment LLC as Director of the Corporate Clients Department, then from 2019 - in K - Consulting LLC in the same
position, from 2020 - in K - Investment LLC, as a financial advisor. Afer his department was downsized in 2020, he took
a job in a department under Isayev Javid. His job duties included: receiving incoming client requests, consulting on
the company's products, opening a brokerage account for IPO transactions, as well as providing information on the
upcoming IPO. The principle of the OTC option agreement and its structure was explained to him by Isaev Javid, who
was the head of the IPO direction. The OTC option contract allowed the client to get an option on the difference of the
share price of the company participating in the IPO, and is designed for one year, that is, the client could hold the
option contract within one year, during the lock - up period of 93 days, the client can exit early on the 20th working
day from the date of acceptance of the transaction up to 93 days with a commission of 15% of the total amount of the
position. Before applying for participation in a particular IPO, the client's funds were on the brokerage account of
QBIF LLC, these funds could be withdrawn only by the client at any time to the bank account, within 1 - 2 working
days. There was also a general agreement under which the client's funds on the brokerage account of IC QBF LLC were
transferred to the settlement account of Q-BROKER LLC. Afer 26 May 2021, he began to receive orders from citizens to
close positions and withdraw funds, about which he informed Isayev Javid. When he (Ilyin A.V.) asked why there were
no funds on the accounts of Q-BROKER LLC, Ruslan Spinka explained that due to the current situation the top broker
and counterparty had restricted their account operations, and in order to start settling obligations with clients, the
company started to sell non - core assets, namely real estate and other valuables. Yuri Orlov held the position of Head
of IT department in QBF Group and Q-BROKER LLC, later he (Y. Orlov) took the position of General Director of Q-
BROKER LLC. Linda Athanasiadou was a director of Constants Investments, a Cyprus broker. Padalko Nicholas was
Vice President of the company and supervised Argento, Falko, Purity, White Lake Management Ltd. Of the accountants
he knows Ekaterina Gramza, he does not know what her duties were;
(Vol. No. 267, pp. 7 - 10)
445
Iosifova E.O.'s Testimony as a witness,
according to which she worked in the catering industry until 2015. For employment in a new sphere, she placed a
questionnaire on the resource "NN.ru" with a search for a job in banking, although she had neither education nor
work experience in this area. In August 2017, she received a call inviting her to an interview at the organisation QBIF
LLC. She came to the office located in the Moscow City building at the following address: 8 Presnenskaya Nab. 1. She
was interviewed by one of the managers named Aslan, whose surname she does not remember. She explained at the
interview that she had no experience in banking. The interview was conducted in several stages. She learnt
theoretical basic definitions - what are shares, bonds, brand name, who is the head of the Central Bank, etc. on the
instructions of the staff. Three weeks later, afer about the first interview, she (Iosifovna E.O.) was employed. The
name of the organisation she was employed by had the word "Investment" in it. By job title, she was employed as an
assistant manager. Her workplace was located at the following address: 8 Presnenskaya Naberezhnaya Naberezhnaya
Street, Moscow, p. 1, 9th floor, in the Open Office. 1, 9th floor, in an Open Space. At her workplace she had a working
mobile phone (she does not remember its number), a computer and a working e - mail account. All Open Space
employees worked in the sales department. Her direct supervisor was Aslan (Head of Sales) and her mentor was his
subordinate Andrey Korzh (Senior Financial Advisor). The career model of the department was as follows: an
incoming employee is placed in the position of a junior financial advisor. He had to build up a certain portfolio of
clients, and when he reached a certain number of clients, he was promoted to the position of financial advisor. Above
that was the position of Senior Financial Advisor (also attainment of the position depended on the number of clients).
The position even higher was senior financial advisor 2 category, who could already be a mentor. The highest
management position in the sales department was the director of the sales department, he managed the heads
(managers) of the sales department, each of whom had groups of employees under him. Her job description included:
to make appointments with clients afer being called through the "cold base", which was either a sheet with phone
numbers or a list in electronic form, there was information: surname, first name, patronymic, or only first name and
phone number. These lists - "cold base" employees of different groups of the sales department passed them to each
other for work. Aslan also explained at the interview that she would have to make calls on behalf of the QBF group of
companies, to interest a person in order for him to come to the company for a meeting. She had to first of all find out
from the client what he was interested in, if it was the Russian market, she would explain to him the possibility of
buying shares and bonds. If it was a foreign market, the client could be offered a foreign product, as well as stocks and
bonds. People who came for meetings in the office afer phone calls, came for meetings directly to Andrei Korzh. She
would explain to clients that trust management agreements would be concluded with them on behalf of the QBF
group of companies. She could not explain the exact form of ownership and the name of the organisation, as she did
not go into it. Employees were given a plan, and if they fulfilled it, they could be promoted, if they did not fulfil it, they
could be demoted or dismissed. The plans were sent out by e - mail. She does not know who made the plans and who
owned the mail. Afer about 3 - 4 months of working as an assistant manager, she started working as a financial
advisor. She (E.O. Iosifova) also made calls to databases, but she herself held meetings with clients. If afer the
conversation the client was ready to invest his money in investment products, he had to bring his passport, SNILS and
fill out a questionnaire. Then she would draw up a table on the computer, into which she entered the questionnaire
data and the product chosen by the client (e.g. "My Safe", "Golden Section", OFZ). Placement in any investment
product was assumed initially in the amount of at least RUB 500,000 (My Safe, Golden Section, other strategies from
RUB 300,000) and other products from RUB 10,000. She sent this table and scanned client documents by e - mail to
the middle office (the department in charge of drafing contracts, which was headed by S.A. Matyukhin). Of the
employees of this department, she remembers only Maria Kopylova. The client was then given an appointment to
sign a contract. Then, to sign the contract, the middle office employee would bring the contract already signed by the
head of QBF LLC or not yet signed, and the head would sign the contract afer the client (not the head of the sales
department), but on the same day. One copy of the contract remained with the company and one with the client. The
client lef with the contract signed by the manager (representative) of QBIF Ltd. and the organisation's stamp on the
contract. She does not remember which of the managers signed the trust management agreements. Together with
the contract, a declaration was signed, where the strategy was specified - the portfolio contained so many per cent of
shares or bonds. One copy was given to the client, one copy was kept by the company. The transfer of money by the
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client is made when it is convenient for the client. It was forbidden to receive cash from clients within the framework
of the contract. Three people were present at the signing of the contract: a member of the middle office staff who
prepared the contract and brought it signed and stamped; a member of the sales department of QBIF Ltd, starting as
a financial advisor; and the client. While in the position of financial advisor, she accompanied the execution of more
than 10 (10 to 30) trust management agreements. Some of her clients, afer writing withdrawal applications, withdrew
their funds quickly, some clients took a long time to withdraw their funds. In 2019, the management decided to create
a support department that worked only with existing clients and did not attract new ones. She joined the department
as a senior financial advisor in the support department. Her job duties in the support department included: calling
clients for reports, taking applications, etc., i.e. managing the clients assigned to the support department. The head of
the department also accompanied the clients and also monitored the activities and solved problematic issues with
the clients that arose. There was training available in the organisation which was conducted by an employee named
Avetis. The training took place in the beginning every day. Avetis taught how to make cold calls and also explained
how to sell IIS (individual investment account). During these trainings, role - playing games were held (financial
advisor - client), where mistakes were later sorted out. The trainings were attended by 2 - 6 to 10 people. In the course
of the training, she learned that QBIF LLC had a licence issued by the Central Bank, but she did not remember exactly
what activity it was for. I assume that the licence was issued for trust management. In order to offer the client some
products, the marketing department prepared brochures containing information about investment products, interest
rates, blue chip stocks, dividend calculation, etc. She knows that the heads of the company LLC IC QBF are Roman
Valerievich Shpakov, Zelimkhan (she does not remember his surname) and Pakhomov (Vladimir, I think). Which of
them signed the documents, she does not know. The name QB Capital LTD is familiar to her from contracts. She
represented the interests of QBF group and accompanied the signing of the agreement on behalf of QBF group of
companies, but she does not remember which organisation signed the trust management agreement, as she has not
been working for two years. She has heard the name of the organisation "White Lake Management Ltd" and knows
that it belongs to QBF and is an international organisation. It was explained to them that due to sanctions in Europe it
became difficult to work on this market and they made this company, but she does not know the details. Igor
Leonidovich Semenov is her client, she accompanied the conclusion of the trust management agreement. He
concluded the trust management agreement in 2018 - 2019. Who signed the agreement with Semenov and his sister
Semenova on behalf of IK QBF LLC and on behalf of which organisation from the group of companies signed the
agreement, she does not know. Andrei Korzh was with her at the transaction, he communicated with them and
answered all the questions. Since she does not know anything about contracts, she invited Andrei Korzh to explain
the details to the clients before signing the contract. Semyonov I.L. and his sister Semyonova L.L. were present at the
signing of the contract, and each of them signed the trust management contract on the same day. At the height of the
pandemic, when the market sagged, in the spring/summer of 2020, she received a call from Semenov (most likely
him, as he was communicating for the two of them) saying he wanted to withdraw the money. She arranged for
Semenov to meet Andrei Korzh afer the conversation, with whom they changed their minds about withdrawing the
money. At the initial meeting with the client, the client is given a brochure with information about QBF Group's
products. If the client requested it, she was given a draf trust management agreement and a declaration outlining the
strategy. She would print out this draf from her computer from the contracts folder. She was sure that the trust
management agreement was legally binding when making transactions. She trusted the company completely and
had no doubts about the legality of the company's activities and was sure that the income in QBIF LLC was much
higher than the income from placing money in banks. Due to the pandemic, the company's clients had problems
withdrawing their money. There was talk in the company that due to the large number of people who wanted to
withdraw money at one time, there were problems with returning to clients the money they had deposited. She
knows that QB Capital LTD under the guise of trust management could acquire shares on the international stock
market, but she does not know the process of acquisition of shares. Clients are provided with a report on the balance,
price and number of shares when buying and when selling them. Once a month a report for each client she
accompanied was sent to her work e - mail account, and the report was also sent to the client. She admits that the
reports were generated by the middle office, but she does not know which employee did it. She does not know the
details of how the reports were generated. From the middle office she received a message about the receipt of funds
from the client, indicating the surname, name, patronymic, date of receipt and the amount of the transferred funds.
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The regulations provide for the withdrawal of funds only in non - cash form. If a client wanted to withdraw money, he
had to submit a notice (she sent a template by mail) 1 month in advance, then he had to come with his passport, write
an application, which was filled out at her office, then an employee of the middle office came, checked the passport,
documents, identity of the citizen and took the application. The further procedure differed when placing money in
Russia and abroad. She knows that the following employees worked in the QBF group of companies in the following
positions: Ruslan Valerievich Spinka was an employee of the sales department, he was the head of the department;
Grigor Yerzikyan was an employee of the sales department; Nikolay Padalko was the head of the sales department
and was previously the head of Ruslan Spinka until the latter's promotion; Yuri Nikolayevich Orlov was an employee
of the IT department; Rinat Felixovich Amerov was an employee of the department, which was engaged in partnership
with the bank "Vostochny"; Vladislav Olegovich Plitin was an employee of the support department, her supervisor
was Maslenikov. Its head was Maslenikov Vladimir, Pakhomov Vladimir was one of the main managers, Yudin Maxim
worked as a manager in the sales department, then lef to another project, to another department of the company.
Shpakov Roman is the main manager, the owner of the company, as he congratulated the employees on New Year
from the whole company and communicates only with the main managers, he never communicated with ordinary
staff. Munaev 3elimkhan was the manager, he gave awards for the best sales. Stanislav Anatolievich Matyukhin was
the head of the middle office, Evgeniya Rossieva was a lawyer. She (E.A. Rossieva) helped her (E.O. Iosifova) when
clients' heirs came afer their deaths. Pavel Yurievich Vlasov is an old employee, previously he was a financial advisor,
but he lef the sales department. Kirill Sergeevich Sobolev is an employee of the company, but which department, she
does not know. Alexey Sergeevich Golubev was the head of the branch in St. Petersburg. Yaroslava Gennadyevna
Smirnova was an employee of the middle office or other department, which was related to QBF's line of business
related to mutual funds;
(Vol. No. 267, pp. 11 - 23)
- Kaminsky P.A.'s Testimony
as a witness, according to which in 2012 he got a job at the company QBIF LLC, where he was engaged in trading in
shares on the American securities market. The company's office, as well as his workplace with a computer and access
to trading platforms, were located at 8 Presnenskaya Naberezhnaya Street, Moscow. Trading was carried out on the
American market on the NYSE and NASDAQ exchanges via the Dastrader trading terminal. His direct supervisor was
Roman Shpakov, but he does not know what position Roman Shpakov had in QBF. Shpakov personally supervised his
(Kaminsky P.A.) work. He (Kaminsky P.A.) knows that Shpakov Roman was the main shareholder of QBF group of
companies. As a trader, his (Kaminsky P.A.) job was to profitably trade securities on the American market in order to
increase the company's capital. At the beginning of the working day, from his work computer, he logged into the
Dastrader trading terminal, which reflected the amount of funds with which he could buy and sell shares of American
companies during the working day in order to make a profit for QBF. All of the funds he had to work with were figures
reflected in the Dastrader sofware as a balance for making stock purchases and sales. Because he had an FFMS 1.0
certification, in approximately 2015, he was transferred to QBEF IK LLC as a dealer. LLC IC QBEEF had a certain staff of
employees who had to have a certificate of a professional stock market participant (it was a requirement of the
Central Bank of the Russian Federation on the required number of certified employees in an investment company).
The head of LLC IC QBEEF was Stanislav Matyukhin. In fact, he (Kaminsky P.A.) did not fulfil the functions of a dealer in
IC QB&EF LLC, but continued to work as a trader in IC QB&EF LLC. As he had experience in managing a bond portfolio,
he was appointed to the company MC KBF UA as a portfolio manager around 2016. QBF UA MC could also be part of
the QBF group of companies. One of the first OPIFs (Open - end Mutual Investment Fund), which was created in QBF
UA MC, was the Eurobonds OPIF (hereinafer referred to as the Fund), which he (Kaminsky P.A.) managed as a
portfolio manager until his dismissal from the company. The main assets of the Fund were Eurobonds of the Ministry
of Finance of the Russian Federation, in the amount of approximately 70% and the remaining part in the amount of
approximately 30% were Eurobonds of large city - forming elements: for example, such as Gazprom, Sberbank and
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others, which had the maximum rating (degree of reliability). The OPIF was managed through a programme - a
trading terminal on the MosBirge. Its computer with an equipped workplace and QUIK programme was located at the
address; Moscow, Presnenskaya Naberezhnaya Street, Moscow City DC "Moscow City" "Federation Tower". Yaroslava
Smirnova was the General Director of KBF UA Management Company, to whom he reported on the results of his work.
His main duties as a portfolio manager included managing the Eurobonds OPIF, namely: 1) Formation of the OPIF
strategy (what shares of certain issuers' bonds will be included in the fund); 2) Coordination of the management
strategy with the management; 3) Fundamental and technical analysis of the bond market; 4) Selection of bonds
suitable for purchase; 5) Coordination of the terms of transactions, namely: number of securities, purchase/sale price,
date of conclusion, which was necessary to comply with the CBR rules on the maximum permissible share in the OPIF
per issuer, as well as other CBR rules and internal restrictions; 6) Execution of transactions in the form of buying and
selling bonds on the organised market (on MosExchange) under the previously agreed terms of transactions. In
January 2021, he was fully transferred from QBF IK LLC to KBF UA Management Company as Lead Asset Manager.
During the entire period of his official tenure as a dealer in QBEF IK LLC, he was not engaged in dealing activities of the
company and did not take any decisions, however, he participated in several meetings, but even there he did not take
any decisions. In the said position of a dealer he was formally without performing any duties due to the fact that he
had a certificate of a professional participant of the stock market. In September 2021, he resigned from the CBF UA
Management Company at his own request, due to the fact that two investigative actions were carried out in the office
of QBF, in connection with which he assumed that QBF was found to be involved in possible illegal activities, which
could further lead to the revocation of his licence to operate on the securities market. Also, when the licence of the
management company was revoked, he could lose his qualifications and lose his certificates, therefore he decided to
leave QBF UA before the revocation of the company's licence. During the whole period of his employment in all the
above - mentioned organisations, which could be part of the QBF group of companies, he had different salaries, which
at the initial period was about 30 000 rubles, and already in the last period of activity reached about 150 000 rubles. At
the same time, he received his salary in two parts, as these conditions were negotiated with the management of the
company at the time of employment, one part in the amount of approximately 40,000 rubles was transferred to his
bank card, and the second part in the amount of approximately 110,000 rubles was given to him in an envelope,
mostly the envelope with his name on it he found on the desk of his workplace. He did not sign anywhere for the
second part of his salary received in the envelope;
(Vol. No. 267, pp. 29 - 33)
- The testimony of Kipa D.S., given by him as a witness,

according to which in the spring of 2011, at an event with the participation of representatives of professional
participants of the securities market, he got acquainted with Roman Valeryevich Shpakov. Some time later, in the
summer of 2011, he received a call from a representative of QBF group of companies and was invited for an interview.
Afer the interview, he was employed as the head of the analytical department in LLC IC QBF, the exact name of the
company he does not remember, his direct supervisor was Munaev Zelimkhan. His job duties included analysing and
evaluating the securities market, writing analytical reports on issuers, searching for investment ideas on the stock
market for managers of exchange products, as well as, if necessary, giving oral consultations to clients on the
situation on the stock market. He also fulfilled the functions of a sales team manager, whose duties included
maintaining and calculating KPIs. He worked in this position until 2014, then he was transferred to the position of the
Head of Investment Banking Department of QBIF LLC, where he worked until about 2016. His job responsibilities
included setting up the department itself, staffing the department, and the functions of the department itself are
related to corporate finance services, namely bond placement on the Russian securities market, business valuation,
and project appraisal. Today he is employed at Q-BROKER LLC, where he was initially headed by Roman Shpakov,
then Yuri Orlov. Denis Savrasov worked in the department of investment banking, where business and business
projects were evaluated. QB Capital company is familiar to him from conversations of employees. Sometimes he (Kipa
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D.S.) received requests from Munaev Zelimkhan to receive funds on his current account and transfer these funds
further on the details of an individual, from his (Munaev Z.V.) words, to the employee of the company. There was no
regular practice of transferring money to his (Kipa D.S.) personal current account, but there were episodes related to
this request. In addition, he (Kipa D.S.) remembers an episode when one of the employees of the accounting
department asked to receive money to his personal current account from a legal entity (which one he does not
remember) under a loan agreement in order to further transfer it to the details given to him. Upon receipt of the funds
on his account, the sender's destination of payment was "purpose of payment" - "loan agreement". The very fact that
a loan agreement was actually drawn up in his name, in accordance with which he was given money from the
organisation and which he subsequently handed over to the QBF accounting officer, did not embarrass him (Kipa
D.S.), as it was done on trust, and the request to accept the transfer in accordance with the drawn up loan agreement
came only from the managers (Munaev Zelimkhan and Shpakov Roman), whom he (Kipa D.S.) trusted. He (Kipa D.S.)
did not apply to the law enforcement agencies for the loan agreement to be drawn up without his (Kipa D.S.)
knowledge and according to his data. Wages, as well as bonuses before 2014 in the company, were sometimes given
in cash, against signature. The envelope with the salary was lef on his desk, later someone from the staff provided a
statement in which he signed. During the period of his employment, from approximately 2019 to 2020, he received an
assignment by corporate mail from his supervisors to investigate the company "Venture Finance Centre" for the
possibility of placing a bond loan on the Russian market. Having studied the received data of the annual financial
report of the company "Venture Finance Centre" came to the conclusion that the financial position of the company
does not meet the formal requirements of the regulator for registration of the bond loan and for its further placement.
The answer was provided verbally;
(Vol. No. 267, pp. 37 - 41)
- Kozlova M.V.'s Testimony given to her as a witness,

according to which she has a higher education, approximately 2020 graduated from the Moscow State Pedagogical
University (branch of the Institute of Foreign Languages, specialising as a teacher of German and English). Afer
graduation, she placed an advert in publicly available information sources to look for a job. Around October 2020, she
received a call from representatives of the QBF group of companies inviting her to an interview in one of the offices of
the Capital City building of the Moscow City business centre at the following address: Moscow, Nab. Presnenskaya 8.
During the interview, which was conducted by Olga Baranova, she was offered the position of a receptionist. From
October 2020, she became an employee of LLC 701, later transferred to LLC 702, a similar position with the same
functional duties. Her salary was 60,000 roubles, which she received in cash and was issued by Baranova Olga, Savidi
Marina or Bogdanova Kristina. She did not sign any statement for the money she received. She knows that LLC "701"
and LLC "702" were part of the QBF group of companies. The office of LLC "701" and LLC "702" was located at the
following address: Moscow, Nab. Presnenskaya 8, Moscow City business centre, Capital City building. The main
activity of QBF group of companies was attracting clients for sale of investment products and trust management of
money invested by clients. The heads of QBF group of companies were Roman Valeryevich Shpakov, Zelimkhan
Munayev, Vladimir Pakhomov, but the main head was R.V. Shpakov. Her direct head was Olga Baranova, from whom
she received instructions on her work, and also to her (Baranova O.) she reported on the results of the work done. In
turn, Olga Baranova was subordinate to Valeria Gubanova, head of the NR department. In addition to Olga Baranova,
her colleagues were Ksenia Kolmanskaya, Tamila Nabiullina, Kryachek Elizaveta, Marina Skripkina. Her duties as a
secretary included meeting guests, directing guests to the right specialist of QBF group of companies, issuing passes
for guests and guests' cars to the Business Centre "Moscow City", sending various corporate messages to the
necessary addresses, receiving various calls and forwarding these calls to the right department, making reports on
thermometry and the number of guests who came to the company during a certain period of time. She was employed
by 702 Ltd between October 2020 and 21 June 2021. She resigned at her own request due to the fact that in 2021 she
began to be paid late wages. During her employment with QBF, she interacted with various QBF employees such as:
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Anastasia Zaripova - specialist of NR department; Valeria Gubanova - head of NR department; Svetlana Beloded -
deputy head of NR department; Yulia Fomenko - specialist of NR department; Irina Ayatova - head of marketing
department; Ekaterina Gramza - chief accountant; Pakhomova - accountant; Nikita Glebov - employee of IT
department; Tural Godirli - trader; Vadim Skosorev - IT specialist; Stella Ermolenko - Head of Financial Advisors
Department; Andrey Korzh - Head of Financial Advisors Department; Isayev Javid - Head of Financial Advisors
Department; Shevchenko Maxim - Head of Financial Advisors Department; Padalko Nikolay - VEB developer; Ruslan
Spinka - head, but does not know which department; Avetis Vartanov - worked with financial advisors; Maslennikov
Vladimir - head of support department (who dealt with withdrawal of clients' funds, in case of contract cancellation,
communication with complaining clients); Stanislav Matyukhin - General Director of QBF IK LLC, which was part of the
QBF group of companies, and was presented as one of the main managers; Dmitry Lepeshkin - worked in the
company and was one of the main managers; Maxim Yudin - worked in the QBF group of companies, in the wing
where the management was located; Lyubov Kuranina - assistant to R. Shpakov.В.Linda - was the head of the Cyprus
branch, ofen worked with Dmitry Lepeshkin; Evgeny Mikhalevich - security representative of QBF group of
companies; Yuri Orlov - head of IT department; Artem Tallerov - head of client relations department; Maxim Fedorov -
financial advisor; Grigory Yerzikyan - financial advisor; Amerov Rinat - worked in the company, was engaged in the
project "Bank Vostochny"; Meshkova Daria - from the support department; Zaitseva Yulia - engaged in websites,
mounted advertising video; Rossieva Evgenia - chief lawyer of QBF group of companies; Kharina Ekaterina - worked in
the management wing, but we do not know her position; Pakhomov Vladimir - was one of the heads of the branch in
St. Petersburg; Munaev Zelim Zelimov - was one of the heads of the branch in St. Petersburg; Munaev Zelim Zelim
Zelim Zelim Zelim Zelim Zelim Zelim Zelim Zelim. Zelimkhan Munayev - was the head of QBF group of companies, as
well as a business partner of Roman Valeryevich Shpakov; Roman Valeryevich Shpakov - was the main head of QBF
group of companies;
(Vol. No. 267, pp. 43 - 47)
- A.V. Korzh's Testimony given by him as a witness,

according to which from April 2016 to 2019 he worked at K - Investment LLC, located at: Moscow, 8 Presnenskaya Nab,
str. 1, as a financial consultant. Since 2019, he has worked as head of the sales department. He is aware that the QBF
group of companies was established around 2018, the financial group of this organisation includes: QBF IK LLC, K -
Investment LLC, K - Consulting LLC, M1 - Invest LLC. LLC K - Investment, LLC K - Consulting was engaged in advising
clients on attracting investments, in particular investments in QBF products. Officially, he worked at K - Investment
LLC and liaised with QBF IK LLC. LLC "K - Investment" carried out its activities in the following areas: consulting
clients in order to attract group company products (trust management products, brokerage services) investment of
clients' funds (individuals and legal entities, mainly individuals) in stocks and bonds. At QBF Group, he held the
position of Head of Client Relations at K - Investment Ltd. His job responsibilities include fulfilling plans, metrics,
assisting in client meetings, monitoring department activity, in the period from 2016 to 2019 counselling clients. He
knows that the signatory of QB Capital LTD was Gorobets Elena Vyacheslavovna, who was listed in the contracts of this
company as an authorised person in 2017 - 2018. In 2016, the signatory was Munaev Zelemkhan Visaytovich (founder
of the company), and he (Munaev Z.V.) was the authorised person of the company. He was familiar with Munaev Z.V.
from his work when he was a manager of the company. His direct supervisor in 2016 was Aslan Daev (Head of Sales
Department), then Yudin Maxim Stanislavovich (Head of Sales Department). In K - Investment LLC, his supervisor is
A.Y. Polibin (head of the company), his immediate supervisor in his functional work is Ruslan Valeryevich Spinka, who
is the director of the sales department of the company. Until 2018, legally according to the documents QB Capital LTD
was located on the territory of Cyprus. The employee of QB Capital LTD was Linda Athanasiadou, she periodically
came to Moscow and personally attended the meetings where she gave information on changes in contracts
(additional agreements) concluded with clients or any innovations (appearance of new types of contracts concluded
with clients), however, he does not know what position Linda Athanasiadou held. The main activity of QB Capital LTD
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is trust management, i.e. investing in foreign securities (shares, bonds) and co - operation with K - Investment Ltd. on
the issues of advising QB Capital LTD clients, as well as advising new (potential) clients of the company. QB Capital
LTD has been out of business since 2018. He is aware that QB Capital LTD has no licences to carry out brokerage and
investment activities. He carried out the tasks assigned to him by the management - Daev Aslan and Yudin Maxim
Stanislavovich (Head of Sales Department). He attracted clients of QB Capital LTD, was engaged in counselling. QB
Capital LTD was presented as an agent (transaction agent) through which funds were invested in shares of a US
company and was not presented as a company that should have a brokerage licence. Clients were provided with
details to transfer their money to QB Capital LTD's bank accounts. He consulted clients about QB Capital LTD products
(trust management, brokerage services) and concluded agreements on "direct access to the securities market" on
behalf of QB Capital LTD, as well as agreements on behalf of "White Lake Management LTD", "SIMTELLIGENCE
COMPANY LIMITED", "QCCI Ltd", as well as with individuals, in particular with Semenov Igor Leonidovich and
Semenova Lyudmila Leonidovna. In the contracts on behalf of "White Lake Management LTD", "SIMTELLIGENCE
COMPANY LIMITED", "QCCI Ltd", which he provided to the clients for signature, the signature of the authorised person
was already stamped in the details. Afer signing the agreement by the client, one copy was lef with the client, the
second copy was returned to the head of his company, where he was employed, namely Daev A. or Yudin M.S. There
were cases when directly through him (Korzh A.V.) clients transferred funds for their further investment in the
company's products, afer which he transferred these funds to his managers - Daev A. and Yudin M.S. Since December
2018, he did not conclude agreements, contracts with these organisations and did not provide services to clients on
behalf of these organisations When concluding agreements with clients, he attached to the client's questionnaire the
client's enquiry about the product he wanted to purchase. At present, all client documents are executed in the
programme "Nabix" - remote acceptance (registration) of the client. A QBF Group client wishing to participate in
trading on international stock markets until 2018 was provided with the following documents: 1) on interaction with
QB Capital LTD - agreement on direct access to stock markets, trust management services agreement; 2) on
interaction with QBF IK LLC - trust management agreement. The trust management agreement was drawn up on
behalf of QBF Advisere LLC, which was legally binding. He saw these agreements in 2018, and until 2018 he concluded
these agreements on behalf of the company "QBi - F Edweiser" LLC, the signatory of which was Gorobets E.V. The
company QB Capital LTD provided a trust management product (the company itself forms the client's portfolio),
brokerage service (the client himself makes a decision on the purchase of certain shares). The process of purchasing
shares on behalf of clients on international stock markets, through QB Capital LTD, looked as follows: the client
transferred funds to the bank account of the company QB Capital LTD, then the management (Yudin) informed him
that the funds were received from the client, then the company sent the funds to its brokerage account, where the
funds received from the client begin to work. Trading on the client's accounts is carried out depending on the strategy
chosen by the client, with the client observing his financial result on trading in monthly reports provided to the client
by email on behalf of the legal entity. Who exactly generated the reports on behalf of QB Capital LTD is unknown. He
saw the overall total electronically. QB Capital LTD did not open a personalised trading account in the name of the
client. The client directly sends funds to the account of QB Capital LTD, afer which the company transferred these
funds to its brokerage account, and disposed of these funds at its own discretion, according to the concluded
agreements with the client. QB Capital LTD, afer signing the notification on withdrawal of funds, in about 1.5 - 2
months, was obliged to return the funds according to the agreement to the client. In the companies "White Lake
Management LTD", "SIMTELLIGENCE COMPANY LIMITED" and "QCCI Ltd", the funds were obliged to be returned afer 3
months, afer signing the notice of withdrawal of funds. The contracts stipulated that if market conditions were
unfavourable, the assets could be sold longer to avoid losses and the terms of withdrawal of funds could be longer.
QB Capital LTD and "White Lake Management LTD" had email accounts: [email protected] and support -
wlconsalting.com (respectively), which received information about changes in the company, as well as on the
contracts, and to which it was possible to write any questions and get answers. By mail, between 2016 and 2017, he
was in contact with Xenia Torres and Athanasiadou Linda, who were a specialist and representative of the office of QB
Capital LTD. Signed and prepared for conclusion of client agreements, he was given to him by Marina Konstantinovna
Savvidi, whose workplace was located in the sales department of K - Investment Ltd. The funds were transferred by
the client to the bank accounts of the companies according to the requisites, in rare cases the acceptance of funds was
carried out in the office, further the funds were credited to the brokerage accounts of the companies. The clients of
452
the company came for dividends afer the funds were received in the office of the company, the dividend distribution
was handled by the client relations department. He learnt about the liquidation of QB Capital LTD in 2018 from
Munaev Z.V. Yurmaster LLC (QB Capital LTD) was an intermediate link between one company of one jurisdiction and
another company of another jurisdiction, it became known to him from the client agreement provided to him for
conclusion by Marina Savvidi. He had conducted and concluded approximately 15 contracts with Yurmaster Ltd.
These were contracts for the transfer of an obligation of one jurisdiction from Cyprus to another jurisdiction, Hong
Kong. The CEO of QBF was Stanislav Anatolievich Matyukhin and the beneficiary was Roman Valeryevich Shpakov.
Vladimir Sergeyevich Pakhomov was previously a shareholder of the company. Munaev Zelimkhan Visaytovich was
also a shareholder of the company. He is not aware of any persons who were founders or general director or
representative of interests of "White Lake Management LTD", but the signatory in the contracts was Elena
Vyacheslavovna Gorobets. This company became known to him in 2018, and provided trust management and
brokerage services to clients wishing to participate in trading on international stock markets. The company's
registered office was located in the Cayman Islands. The main activity of the company was trust management and
brokerage services to clients. The company "White Lake Management LTD" had licences, the correct names of the
licences are indicated on the company's website, however, as they are foreign, he does not know what kind of
activities they were for. He did not have a power of attorney to represent the interests of the company "White Lake
Management LTD" on the territory of the Russian Federation, he only concluded contracts with the existing signatures
of the General Director of the company "White Lake Management LTD". A client of QBF Group of Companies wishing to
participate in trading on international stock markets was provided with a trust management agreement concluded on
behalf of "White Lake Management LTD" and a service agreement. The process of purchasing shares on behalf of
clients on international stock markets through "White Lake Management LTD" looked as follows: funds were
transferred to the company's bank account, further funds were transferred to the general broker's account. Reports
were generated automatically, and the client received a report on the results for the previous month of work from the
official mail. A personalised trading account was not opened in the name of the client in "White Lake Management
LTD", as the company's bank accounts were specified in the details. The accounting support of the company was
carried out by Athanasiadou Linda. He does not know the persons who were founders or general director or
representative of interests of "SIMTELLIGENCE COMPANY LIMITED", but the signatory in the contracts was Elena
Gorobets, the legal address of the company was located in Hong Kong, this company was an auxiliary for "White Lake
Management LTD" and had a connection with it. He knows that his colleagues also concluded contracts with clients
with signed contracts on behalf of the general director of the company. The client, QBF group of companies, wishing
to participate in trading on international stock markets was provided with a service agreement and documents
related to the general set of documents of "White Lake Management LTD". In the agreements as an authorised person
of "QCCI Ltd", in 2017 - 2018 was Gorobets Elena Vyacheslavovna, in 2016 the signatory was Munaev Zelemkhan
Visaytovich (founder of the company), was also an authorised person of the company. The company "QCCI Ltd" is
known since 2017, the legal address, was located in the territory of the Republic of Cyprus. The main activity of "QCCI
Ltd" is trust management and brokerage services. The company provided trust management and brokerage services
to clients wishing to participate in trading on international stock markets. The client of QBF group of companies
wishing to participate in trading on international stock markets was provided with a trust management agreement
concluded on behalf of "QCCI Ltd", direct access agreement, trust management services agreement. The process of
purchasing shares on behalf of clients on international stock markets, through "QCCI Ltd", looked as follows: funds
were transferred to the company's bank account, further funds were transferred to the general broker on the account
(according to the provided list of brokers). Reports were generated automatically, and the client received a report on
the results for the previous month of work from the official mail. Personalised trading accounts were not opened in
the name of the client in "QCCI Ltd", as the company's bank accounts were indicated in the details. Athanasiadou
Linda and back office representative Xenia Thores provided accounting support to the company. He is aware that the
QBF group of companies employs the following people in the following positions: Ruslan Valeryevich Spinka is the
head of sales department in "K - Investment" LLC; Grigor Razmikovich Erzikyan Grigor Razmikovich is a financial
advisor, communicates with clients, holds meetings with them; Zaitseva Yulia Sergeevna financial advisor, also
consulted clients on services of SIMTELLIGENCE COMPANY LIMITED, QCCI Ltd, White Lake Management LTD; Meshkova
Daria Yurievna manager, consulted clients on services of SIMTELLIGENCE COMPANY LIMITED, QCCI Ltd, White Lake
453
Management LTD; Pakhomov Vladimir Sergeevich known to him since about 2019, shareholder of QBF group of
companies; Yudin Maxim Stanislavovich Head of Sales Department till 2020 in "K - Investment" LLC; Shpakov Roman
Valeryevich main beneficiary of QBF group of companies, personally known to him since about 2018, received from
him recommendations on communication and interaction with clients, provided work plan, reported on the work
done; Munaev Zelimkhan Visaitovich, known to him since about 2016, was a shareholder of QBF Group; Matyukhin
Stanislav Anatolievich is the General Director of QBF IK LLC since 2017; Rossieva Evgeniya Anatolievna is the Chief
Lawyer of QBF Group; Elena Vyacheslavovna Gorobets is an official signatory in the contracts of QBF group of
companies under the contracts of "SIMTELLIGENCE COMPANY LIMITED", "QCCI Ltd", "White Lake Management LTD",
she started working around 2016 - 2017; Dmitry Sergeevich Lepeshkin is an employee of the company "M1 - Invest",
engaged in real estate, construction; Athanasiadou Linda is a co - signer of accounting documents of foreign
companies, I have known her since 2016;
(Vol. No. 267, pp. 49 - 69)
- The testimony of Kryachek E.I., given to her as a witness,

according to which, she placed an advertisement in publicly available sources of information to look for a job in
Moscow. Around October 2020, she received a call from representatives of QBF group of companies and was invited
for an interview at the office located at: Moscow, Nab. Presnenskaya 8, in the Capital City building of the Moscow City
business centre. She was interviewed by Olga Baranova and HR specialist Anastasia. Since October 2020, she was
employed as a receptionist in the company 701 LLC, and later she was transferred to 702 LLC, but her functional
duties remained the same. At both OOO "701" and OOO "702", she worked as a receptionist with a salary of
approximately 50,000 - 55,000 roubles. She received her salary in cash and it was issued by Baranova Olga or
Bogdanova Kristina. She did not sign any statement for the money she received. The office of LLC "701" and LLC "702"
companies was located at the following address: Moscow, Nab. Presnenskaya 8, Moscow City business centre, Capital
City building and were part of the QBF group of companies. The main activity of QBF group of companies was
attracting clients for sale of investment products and trust management of money invested by clients. QBF group of
companies was headed by Roman Valeryevich Shpakov and Shpakov's partner Zelimkhan Munayev. Her direct
supervisor was Olga Baranova, from whom she received instructions on her work and reported to her on the results of
her work. In addition to Olga Baranova, her colleagues were Maria Kozlova and Maria Skripkina. Her duties as a
secretary included meeting guests, directing guests to the right specialist of QBF group of companies, issuing passes
for guests and guests' cars to the Business Centre "Moscow - City", sending various corporate messages to the
necessary addresses, receiving various calls and redirecting these calls to the right department, keeping logs on
arrival and departure of employees to the workplace, as well as visiting guests who came to the company during a
certain period of time. Performing household tasks related to the companies activities. She worked at 702 Ltd
between October 2020 and May - June 2021. She resigned from "702" Ltd. of her own volition due to salary delays.
She knows that the following employees worked in QBF group of companies in the following positions: Ekaterina
Gramza - Chief Accountant of "QBF" company; Ruslan Spinka - Head of Sales Department; Stanislav Matyukhin -
General Director of LLC "IC QBF", which is a part of QBF group of companies, he was presented as one of the main
managers; Lyubov Kuranina - worked for Matyukhin and was also an assistant to R. Shpakov; Evgeniya Rossieva -
worked for Matyukhin and was an assistant to R. Shpakov.V.; Yevgeniya Rossieva - chief lawyer of QBF; Andrey Korzh -
head of the sales department. Lepeshkin Dmitry, Padalko Nikolay, Maslennikov Vladimir, Amerov Rinat and Shaban
Yuri worked in the company, but she does not know what positions they held;
(Vol. No. 267, pp. 77 - 80)
454
Kuznetsov S.A.'s testimony given by him as a witness,
according to which he has been employed at LLC "KF Estate SPB" since 13.05.2019 in the position of deputy head of
department. He got this position at the invitation of his former colleague Balan Oleg, with whom he had previously
worked in VTB Bank. He (Kuznetsov S.A.) was interviewed by Gevorg Gevorgyan, his direct supervisor. His (Kuznetsov
S.A.) job duties included searching for employees and clients, as well as fulfilment of the sales plan, but in fact he was
engaged in training of employees, conducting webinars, attracting clients from persons previously known to him. He
knows that LLC "KF Eiteit SPB" was not a professional participant of the stock market, according to OKVEDs the
mentioned legal entity was engaged in advertising activities. He personally attracted about 20 clients in two main
directions - international and Russian directions. 6 clients were attracted within the framework of conclusion of trust
management agreements, as well as providing direct access to international stock markets with "White Lake
Management LTD". The rest of the clients were attracted by it within the framework of the activities of QBIF LLC. The
principal line of business of QBIF LLC was the trust management of client money in the purchase of securities and the
construction of a portfolio of securities from the strategies offered. The portfolio of the clients he accompanied
included the following financial products: stocks and bonds, trust management, over - the - counter option contracts.
3 - 4 clients were offered a structured product, namely "OTC option contract" for IRO. This contract was concluded
with the client for the purchase of an option from Q-BROKER LLC, which acted as a seller under the contract. LLC
"Q.Broker", was affiliated to LLC IK "QBF" and belongs to the same group, nobody concealed it. Matyukhin Stanislav
Anatolievich Matyukhin acted as the General Director of LLC IC QBF. LLC IC QBF had obtained all necessary licences in
accordance with the current legislation of the Russian Federation, namely, four licences of the Russian Federation
were obtained at different periods of time: depositary, securities management, brokerage and dealer licences. LLC MC
QBF Asset Management had a licence to manage investment funds, unit investment funds and non - state pension
funds. This information on the licences held by the above companies was also posted on the official website of the
Central Bank of Russia. The office of LLC KF Elite SPB was located at the following address: St. Petersburg. Degtyarny
Pereulok, v. 11, litre B. In the sales department, approximately 40 employees were employed. His salary consisted of a
salary and a performance bonus based on the amount of funds raised, which he received in an envelope in cash. The
client, being on brokerage service, could perform trading operations on his account in the following ways: by signing a
personal order to purchase the selected asset in the company's office (the order form is available on the company's
official website in the "information disclosure" section; by submitting a handwritten signed order from his authorised
e - mail to the company's (broker's) e - mail specified in the contract. He had heard about RIF JSC and White Lake
Management LTD. JSC "RIF", was engaged in warehouse real estate. He knows the following employees working in
QBF group of companies: Shpakov R.V. - Vladimir Pakhomov and Zelimkhan Munaev, shareholders; Gevorgyan
Gevorg, head of the branch in St. Petersburg; Alexey Sergeyevich Golubev, head of the branch network; Ekaterina
Martsinyuk, Golubev's common - law wife, was responsible for cash receipts and also collected second copies of
documents on transactions with clients for White Lake Management LTD;
(Vol. No. 267, pp. 82 - 85)
- Testimony of Kuranina L.V., given to her as a witness,

according to which she worked as a receptionist in different organisations for about 10 years. In 2016, she placed a
questionnaire on the resource "HH.ru". She received a call and was invited to an interview at the investment company
"QBF", located at: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, floor 9. 1, floor 9. Afer three months of internship,
she was officially employed by the above - mentioned organisation as a receptionist. Her duties included: meeting
clients, escorting them to the meeting room, receiving correspondence, dispatching couriers, answering telephone
calls at the reception desk and other tasks. Her direct supervisor was senior secretary Kabanova Alyona Valentinovna,
455
who supervised secretaries. She worked at the reception desk for 2 - 3 years, afer which she wanted to quit, but when
she learned that the employees of the IT direction of the company "QBF" developed and began to promote some start
- up project in the IT direction, and within the framework of this organisation there appeared a new company LLC "DV
- Technolodges", which had nothing to do with investments. She got a job in this organisation as the head of the
administrative unit. Her duties included communicating with the landlord of the premises at the address: Moscow,
Nizhny Kislovsky pereulok, ul. 6 p. 1. Her direct supervisor was Trishin Gleb Sergeevich, who previously also worked in
the group of companies "QBF" Having worked in the company LLC "DV - Technologies" for about a year, as the start -
up project failed she together with her supervisor Trishin G.S. in mid to late 2019, returned to the group of companies
"QBF". There she was transferred to the company LLC "701" and (or) LLC "702", which were technical companies in the
group of companies "QBF", engaged in renting and subsequent leasing of premises. The general director of LLC "702"
is V.V. Smirnova, who was a nominal director. She (L.V. Kuranina) acted as an assistant to several managers of various
organisations located in the office at 8 Presnenskaya Naberezhnaya Street, p. 1, floor 9, and performed the function of
an assistant to several managers of various organisations. 1, floor 9, and performs general errands regarding order in
the office, purchasing tickets, etc., errands for various employees working in the QBF group of companies. In her work
she interacts with secretaries, office managers and general management, which includes Valeria Gubanova,
Zelimkhan Munayev, Roman Shpakov. She knows that the main income of "QBF" companies is trust management of
clients' assets. Clients put their money where and how she does not know, then the money is returned with interest,
with profit. Sales department works in this direction. Financial managers: Spinka R., Korzh A., as well as the main
management Zelimkhan Munayev and Roman Shpakov. She knows that the following employees work in QBF group
of companies: Spinka R.V. - Head of Sales Department in one of the companies of QBF group of companies; Padalko
N.S. - knows him since the beginning of his work in QBF; Orlov Y.N. - formerly with the IT department, now he is the
head of the department; Amerov R.F. - R.F. Amerov, head of department, I heard that his direction is connected with
some bank; V.O. Plitin - former financial advisor, currently does not work; A.V. Korzh - head of financial advisors,
supervises employees in the sales department; Y.S. Zaitseva - former financial advisor; D.Y. Meshkova - former
financial advisor, afer her dismissal she got a new job in the group of companies in the sales department; V.V. Frolov -
general director of QBef Ltd.G. - general director of QBF LLC, and then moved to another company; V.S. Pakhomov -
manager related to interaction with regions, he was a shareholder of the general group of companies and worked in
their office, setting up the sales department, the office is located separately, as far as she knows in St. Petersburg.
Yudin M.S. - was previously the director of the sales department, then moved to a separate direction related to IT;
Shpakov R.V. - R.V. Shpakov - shareholder of the company, the most important managerial link, Shpakov's workplace
was in the office in the eastern block, she also fulfilled his requests; Z.V. Munaev - was a shareholder, one of the
company's managers; S.A. Matyukhin - General Director of OOO IC QBF, had a separate office on the 11th floor of the
same building; E.A. Rossieva - chief lawyer of the general company, her office was on the 9th floor. She has her own
department; E.V. Gorobets. - knows that she is a nominee, but does not know in which company, she saw her in the
office once, when she met her on the ground floor of the building to take her to the office, Evgeniya Rossieva
explained that it was Gorobets; Lepeshkin D.S. is involved in the construction of the Gribovsky les Residential
Complex, admits that he is a director, Lepeshkin D. S. previously had an office in their office.S. used to have an office
in their office on the 9th floor, several years ago, in 2020 during the Central Bank inspection he first stopped coming to
the office and then moved out of it; an employee named Linda was seen several times in 2020, she has no office, she is
a Cypriot citizen; Vlasov P.Y. - was once listed as a vice - president, for her he is just a financial advisor in the sales
department; Sobolev - works in the group of companies in one of the branches in another city; A.S. Golubev - was a
financial officer in the St. Petersburg branch; Ya. - Smirnova Y.G. - currently General Director of QBF Management
Company LLC, previously worked with Matyukhin, then they moved to another office within Moscow City; Shaban Y.V. -
knows her as an employee of the company; Vozhzhov A.F. - deals with design, helps develop the website, printed
materials; Kharina E.N. - used to work under Zelimkhalin. - was subordinate to Zelimkhan Munayev, Kharina's
workplace is on the 9th floor; Timokhin O.Y. is an employee of IC QBF LLC, subordinate to Matyukhin Stanislav, worked
with Matyukhin in the same office; Trishin G.S. is engaged in development, worked with the IT department
employees. She knows about the construction project of the residential property of the apartment building Gribovsky
les LCD "Gribovsky les", located at the address: Moscow region, Odintsovsky district, v. Borodki, ul. Parkovaya, уч. 1,
from the conversations in the corridors of the company, that Roman Shpakov has a relation to this construction, as
456
well as from the conversation between Shpakov and Lepeshkin, which she heard, bringing tea and coffee, they
discussed the construction. The company has a department dealing with the construction of this residential complex.
Lepeshkin was in charge of the construction site;
(Vol. No. 267, pp. 86 - 100)
- The testimony of Legrova I.I., given to her as a witness,

according to which she from 02.12.2019 to 23.03.2020 was officially employed at LLC "K - Investment" in the position
of financial advisor in the department of work with clients. She got this position through the search engine "Hh" afer
the interview conducted by Laipanov Egor and Spinka Ruslan. And her direct supervisor was Stella Ermolenko. In fact,
her job duties included attracting new clients to the company. The main activity of QBIF LLC was to attract
investments from clients in order to invest in the stock market. During her employment, she attracted two people as
clients with a total investment amount of RUB 3,400,000, which was invested in Russian mutual funds and also placed
in a brokerage account. To date, all obligations have been fulfilled with these clients. She is aware that the following
employees worked in the QBF group of companies in the following positions: Ruslan Spinka was the head of the sales
department, and he was subordinated to the heads of sales departments Egor Laipanov, Stella Ermolenko, Andrey
Korzh, Artem Tallerov, Ara Balayan, and the managers were directly subordinated to them; Javid Isaev was the head of
IRO; an employee named Linda - known to her as a representative of the international market of the group of
companies "QBF"; Padalko Nikolay - several times conducted training on products of the company "White Lake
Management LTD"; Bogdanova Kristina - worked in the accounting department; Murashov Alexey - a manager who
actively attracted clients and funds to the company by making calls and personal meetings. She did not understand
the mechanism of work of QB Capital, "SIMTELLIGENCE COMPANY LIMITED" and in order to get information she
addressed Stella. The latter was unable to explain the working principle of the instruments of these companies;
(Vol. No. 267, pp. 106 - 108)
- D.S. Lepeshkin's Testimony given by him as a witness,

according to which he has two higher education degrees, specialising as a physical education teacher and an
economist. Approximately in 2012 - 2014 he was the General Director of LLC "M1 Invest", and also he was employed in
the QBF group of companies as a financial advisor and was engaged in analysing shares. He is also a director at
Konstansinvestmen, a company not located in the Russian Federation. He knows the following employees with whom
he is personally acquainted, but there was no labour relations: Ruslan Valeryevich Spinka - sales manager, engaged in
sales of services; Nikolay Sergeyevich Padalko - engaged in sales of services; Yuri Nikolayevich Orlov - employee of IT
department: Amerov Rinat Feliksovich - engaged in sales of services; Plitin Vladislav Olegovich - engaged in sales of
services; Korzh Andrey Vasilyevich - head of sales, also engaged in sales of services; Zaitseva Yulia Sergeevna -
engaged in sales of services; Frolov Vladimir Georgievich (nominal) - he was the general director of the Russian
Licence Company; Pakhomov Vladimir Sergeevich - head of the St. Petersburg branch, was a co - organiser and co -
founder; Yudin Maxim Stanislavovich - engaged in sales of services; Shpakov Roman Valerievich (organiser) - the main
founder; Munaev Zelimkhan Visaitovich - held a managerial position; Matyukhin Stanislav Anatolievich - was the
general director of the Russian Licensed Company; Rossieva Evgenia Anatolievna - the main lawyer of the company;
Athanasiadou Linda - co - organiser, kept accounting of foreign companies, he has personal relations with her; Vlasov
Pavel Yurievich - was engaged in sales of services; Kirill Sergeevich Sobolev - engaged in sales of services; Aleksey
Sergeevich Golubev - engaged in sales of services; Yaroslava Gennadyevna Smirnova - is the general director of LLC
457
"MC QBF"; Alexander Fedorovich Vozhzhov - designer; Oleg Yurievich Timokhin - works together with S. Matyukhin; S.
A. Matyukhin - works in the office of the chief lawyer of the company.А.;
(Vol. No. 267, pp. 109 - 115)
- A.Y. Lozhkina's Testimony given to her as a witness,

according to which she was looking for a job afer graduating from a higher education institution in the summer of
2018, having placed her CV on the website "Hh.ru". Around the end of August 2018, she received a call from a QBF staff
member. She had an interview at 8 Presnenskaya Embankment, Presnenskaya Embankment, Moscow, in the office on
the 9th floor of the City of Capitals Tower, afer which she was offered a position as a secretary in the office of a
company with the name QBF. In the summer of 2020, on the initiative of Irina Nikolayevna Shpakova, General Director
of LLC "KP turn 3", she (A.Y. Lozhkina) was transferred to the position of Project Manager of LLC "KP turn 3", as well as
Project Manager of LLC "KP turn 2" and LLC "KP turn 4" on a part - time basis, where she worked until 01.06.2021,
having resigned at her own request. Roman Valeryevich Shpakov was the head of QBF. Her immediate supervisor,
administrative department (secretariat) was Kabanova Alena. She was offered the position of project manager of LLC
"QBF turn 3", LLC "QBF turn 2" and LLC "QBF turn 4", the head of which was Shpakova I.N., by one of the employees of
the construction company. As a QBF secretary, her duties included: receiving incoming calls and their further
distribution to addressees, meeting visitors, organising the work of maids, checking meeting rooms for cleanliness
and availability of office supplies. The workstation was located at the reception desk, opposite the front door to the
office. About a year later, Ugryumova Olga, who was the sales and marketing director of a construction firm, asked for
technical assistance in the construction field. When she was hired, it was explained to her that there was an
opportunity for career growth, so she (A.Y. Lozhkina) accepted the offer and agreed to assist O. Ugryumova. She was
not paid for the additional workload. Ugryumova O.'s workplace was located on one of the floors of the Capital City
Tower. She (A.Y. Lozhkina) was scanning and printing documents. The documentation concerned the construction of a
residential complex in Severodvinsk. Of the names of the documents she processed, she remembers only the share
participation agreements. She provided this assistance to O. Ugryumova for a period of six months to a year. As a
project manager of KP turn 3 LLC, as well as a project manager of KP turn 2 LLC and KP turn 4 LLC, her duties included
administration of the process of obtaining project financing. Due to changes in 2019 in FZ - 214, it was impossible to
use shareholders' funds in the construction of the residential complex "Victory Quarter" in Severodvinsk and she was
engaged in the formation and submission of a package of documents to PJSC "Sberbank of Russia", and afer a while
to the bank "DomRF" as a source of construction financing. The package of documents was also sent to SME Bank
(Small and Medium Enterprises), where at the beginning of 2021, approximately in February - March, they received a
refusal with the wording "presence of negative information about the group of interrelated or affiliated persons". And
also an employee of SME Bank sent a letter to her corporate mail asking her to clarify whether KP turn 3 LLC, KP turn 2
LLC and KP turn 4 LLC were affiliated with QBF. There was also a question with a request to comment on negative
reviews on the Internet about the company "QBF". This letter was also read by the general director Shpakova I.N. The
answer was formulated by Shpakova I.N., having dictated to her (Lozhkina A.Y.) the text of the letter, which she
(Lozhkina A.Y.) printed and sent to the bank by e - mail. The text stated that LLC "KP turn 3", LLC "KP turn 2", LLC "KP
turn 4" are not affiliated with "QBF". Regarding comments about the activities of "QBF", it was replied that the said
company is not affiliated with "KP turn 3", "KP turn 2", "KP turn 4" Ltd. She had been working as a project manager for
about 11 months, and all that time she was involved in the administration of the process of obtaining project
financing. At the time of her dismissal, no funding had been received. Her workplace was also located on the 9th floor
of the Capital City Tower. She heard about the construction of the Gribovsky Les project from some of her colleagues,
it was also called a "club house" and was a high - class project, while the Victory Quarter was an economy class
project. Roman Valeryevich Shpakov is known to her as the head of the company "QBF"; Zelimkhan Visaitovich
Munaev is a co - owner of the head of the company "QBF" R.V. Shpakov; Stanislav Anatolievich Matyukhin is the
general director of LLC IC "QBF"; Evgeniya Anatolievna Rossieva is a lawyer;
458
(Vol. No. 267, pp. 118 - 123)
- A.V. Lopukhova's Testimony given to her as a witness,

according to which she was employed at K - Investment LLC as a junior financial advisor from 13.07.2020 to
29.06.2021. When she was employed, she was interviewed by Isaev Javid, who became her immediate supervisor. Her
job duties included receiving incoming client requests, consulting on the company's products, opening a brokerage
account, maintaining the client portfolio, which involves settlement of IRO transactions, calculating allocation, free
balance for participation in the transaction, as well as providing information on the forthcoming withdrawal from IRO.
The procedure of opening a brokerage account looked as follows: client applies to the company, she (A.V. Lopukhova)
conducts consultations on products, namely she explained that the commission on entry will be from 2 to 3 per cent
of the entry amount and 0.5 per cent on exit of the total amount, taking into account the profitability, as well as 15 per
cent for early exit from the position on the 20th working day. The process of calculating the allocation was conducted
as follows: every Monday, Isaev Javid was given a list of companies that had entered IROs that week. Next, the day
before the opening of bidding, the bids were collected from the clients, to participate in the specific IRO given. The
next day the bidding for the companies started, the allocation was known at 21h. 00min. of that day, the data on
allocation was provided by Andrey Korzh. The process of calculating the free cash balance in the client's portfolio was
carried out in the Excel table, with the help of summarised formulas, taking into account the amount of the order,
allocation percentage, commission, share placement price, current share price, dollar exchange rate, calculations on
the cash balance in the client's portfolio were made. The principle of the option contract and its structure was
explained to her by Isaev Javid, who was one of its developers at QBF. The OTC option contract allows the client to
receive an option on the difference of the share price of the company participating in the IRO. The OTC option contract
is for one year, i.e. the client can hold the option contract for one year. There is a lock up period which is 93 days,
however the client can exit early on the 20th business day from the acceptance of the trade and up to 93 days with a
commission of 15 per cent of the total position amount. Prior to applying for a particular IRO, the client's funds are
held in the brokerage account of QBIF LLC and only the client could withdraw them at any time to a bank account,
within 1 - 2 business days. However, around September 2020 Andrey Korzh and Javid Isaev informed that a general
agreement was introduced under which the client's funds on the brokerage account of IC QBF LLC were transferred to
the settlement account of QBroker LLC, and therefore the time of withdrawal of funds from the settlement account of
QBroker LLC to the client's brokerage account increased and amounted to 10 days. Initially, when introducing the
general agreement, in the structure of the OTC option contract, on the instructions of the managers, the clients were
offered to sign the document voluntarily, but since October 2020, on the instructions of Andrey Korzh and Javid Isaev,
this agreement became mandatory for all clients. During the entire period of her employment, she attracted about 40
clients, to the tune of about 100 million rubles. Afer 25 May 2021, she started receiving orders from citizens to close
positions and withdraw funds. She addressed this information to Dzhavid Isaev, to which he replied that at the
moment he could not make the withdrawal of funds. Javid Isaev referred to this fact until her dismissal from "QBF",
until 19.06.2021. During this period of time, she repeatedly approached him with the question of the possibility of
making payments to clients. She was provided by Javid Isaev with a document certifying the size of the assets of QBF
LLC, which included "ZPIF" RIF "Warehouse Federal", bonds of the foreign company "Argento", "PAI" RIF, real estate,
"Purity fund units", with the total value of 4 755 917 996 rubles This document was signed by Orlov Yu.Y.N. Orlov
initially held the position of IT specialist in the group of companies "QBF" and LLC "QBroker", later he took the
position of General Director of LLC "QBroker". Isayev Javid had the following employees under his command: Alexey
Murashov, Anton Lazarev, Sergey Khmelevoy, Alexander Ilyin, Vladislav Manaenkov, Artem Treiman, Said Isayev,
Ruslan Dynda, Dmitry Bashkirov, Veronika Chernyshova, Kirill Gertseg, Artem Pirogov. Linda Athanasiadou was the
head of international organisation activities at QBF Group. Bogdanova Kristina was engaged in accounting support for
clients' payrolls. They were paid in cash as salaries, officially the salary of ordinary managers was 20,000 roubles, but
459
in fact the managers received about 70,000 roubles without bonuses. She knows R.V. Shpakov as the main owner of
the QBF group of companies, while V.S. Pakhomov and Z.V. Munayev are shareholders in the business;
(Vol. No. 267, pp. 127 - 131)
Manaenkov V.K.'s Testimony given by him as a witness,

according to which he worked in the period of time from May 2019 to January 2021 as a leading manager of the
controller of Otkritie Bank. His acquaintance Sergey Khmileva offered to work in LLC IC QBF and gave him (V.K.
Manenkov) the telephone number of the personnel department of LLC IC QBF. Afer calling the HR department, in the
twentieth days of January 2021, he was invited to an interview at QBF LLC, which took place in the company's office
located in the City of Capitals Tower in the Moscow City business centre at 8, page 1, Presnenskaya Naberezhnaya
Embankment, Moscow. The interview was conducted by Mr Isayev Javid, who held a position in the company as Head
of the IRO movement. In the course of the interview Isayev D. presented to him the investment activities of the
company, informing him that the company is engaged in participation in IRO, as well as provides financial products
such as IIS (Individual Investment Account) and trust management and IPF (Unit Investment Fund) and others. It was
also reported by D. Isaev that QBIF LLC has four licences from the Central Bank of the Russian Federation. On or about
27.01.2021, he was employed as a financial advisor at K - Investment LLC. He had the following job duties: attracting
clients, selling the company's products, supporting transactions with clients, consulting clients. The job description of
the financial advisor stated that the financial advisor should attract at least 3,000,000 roubles from clients to the
company per month. The department in which he worked was headed by Isaev Javid, and the following employees
worked in the department: Khmilev S., Murashev A., Bashkirov D., Treiman A., Pirogov A., Chernysheva V., Dynda R.,
Lazarev A., Lopukhova A., Ilyin A.. In addition to the above - mentioned employees, he saw Shpakov R., Munayev 3.,
Korzh A., Spinka R. and Rosiyeva E. During the period of his employment in the above position, he attracted 11 clients
totalling RUB 27,934,000. All of his clients participated in IROs. In order to conclude an agreement on the provision of
brokerage services, the client needed a passport of a citizen of the Russian Federation, SNILS, e - mail details, and
details of a current account for withdrawing funds. The client sent these documents to his work e - mail. The
documents were prepared by the middle office. Afer that the prepared agreement and other documents were sent to
the client for signing. The signed copy of the agreement was also sent by the client by e - mail to the company's work
e - mail. On the part of QBF IK LLC the contract was signed by the General Director Matyukhin S.A. Afer the contract
was concluded with the client, a personal account was opened for him on the QBF website, where the client could
track his funds. Reports on the client's brokerage account were sent by the middle office. The client transferred funds
to the brokerage account opened for him, and from that account the funds were transferred to the master agreement.
As Korzh A. informed him, it was another company account, from which the funds were subsequently transferred to
the current account of QBroker LLC. The counterparty working with QBroker LLC was not disclosed, citing commercial
secrecy. Since clients periodically withdrew funds, he did not have any problems, as well as suspicions about the
financial activity of the company QBIF LLC. In May 2021, law enforcement officers searched the company QBIF Ltd.
Afer the search, he found on the Internet that a criminal case had been opened against the managers of QBF LLC. At
that time, the company had already started to delay the salaries of financial advisors. On the day when the company
was searched Isayev D. said that he (Isayev D.) did not know why the money was not returned. He explained that the
clients' money had most likely been stolen. Thus, afer the search and conversations with both Isaev D. and Korzh A.,
he (Manaenkov V.K.) concluded that the involvement of clients' funds in the company was such a fraudulent scheme.
He knows Nikolay Padalko from the employees of QBIF LLC, who dealt with offshore companies and the company's
funds; he sat in the office separately from all departments. He also knows the general director of Q-BROKER LLC, Yuri
Orlov. He saw a woman named Linda, who had a foreign surname, who was mostly in the rooms where R. Shpakov's
office was located;
460
(Vol. No. 267, pp. 132 - 136)
- Markina M.S.'s Testimony given to her as a witness,

according to which she started working in investment companies in Moscow as a second income in 1997 - 2018. In
2015, she passed, courses received qualification certificates, having obtained basic knowledge of the device and work
of investment and management companies. In 2018, she joined KBF UA LLC (QBF Asset Management) as a back office
specialist. This position was offered to her by Yaroslava Smirnova, whom she knew from her joint work at Univer LLC.
Ya Smirnova was the general director of KBF UA LLC. Her (Markina M.S.) duties as a back office specialist of CBF UA LLC
included: processing primary documents (bank statements, brokers' reports, depository reports), liaising with
specialised depositories, registrars, auditors and appraisers, preparing daily and monthly reports. The back - office
specialist generates reports based on the above - mentioned data, which shows how well the management company
manages the funds of shareholders. These reports were checked by depositaries and subsequently the information
was sent to the Central Bank. She did not work specifically with clients. She knows that the following employees
worked in the company in the following positions: Roman Valeryevich Shpakov - Head of QBF; Zelimkhan Visaitovich
Munaev - Head of QBF Group of Companies; Stanislav Anatolievich Matyukhin - General Director of LLC IC QBF;
Evgenia Anatolievna Rossieva - Lawyer of QBF Group of Companies. She knows that brokerage agreements are signed
by Yaroslava Smirnova on behalf of QBF Asset Management LLC and Stanislav Matyukhin on behalf of QBF IK LLC. The
contract is concluded only afer agreement with the specialised depository. The shareholder deposits money to the
transit account of the fund, each fund has its own separate transit account. Further, afer comparing the data on the
shareholder, the specialised depository gives its consent to transfer the shareholder's money from the transit account
to the settlement account of a certain fund. This money, again with the permission of the specialised depository, is
transferred to the brokerage account, where the money is used to purchase securities. The following funds are
managed by QBF Asset Management LLC: 1) OPIF RFI (hereinafer - open - end unit investment fund of market
financial instruments) "QBIF My Safe", purchase of securities; 2) OPIF RFI "QBIF Golden Section", purchase of
securities; 3) OPIF RFI "QBIF Eurobonds", purchase of securities; 4) QBIF RFI QBIF Future Assets, acquisition of
securities; 5) ZPIF Real Estate (closed - end unit investment real estate fund) QBIF Real Estate, land plots and trust
management agreements of Gribovsky les Residential Complex; 6) ZPIF Real Estate QBIF Regional Real Estate, flats in
Severodvinsk; 7) ZPIF Real Estate QBIF Regional Real Estate, flats in Severodvinsk; 7) ZPIF Real Estate QBIF Regional
Real Estate, flats in Severodvinsk; 7) ZPIF Real Estate QBIF Regional Real Estate, flats in Severodvinsk. 7) Real Estate
Development of Regions ZPIF, share participation agreements in Severodvinsk; 8) Real Estate Development of Regions
2 ZPIF, share participation agreements in Severodvinsk; 9) Real Estate Development of Regions ZPIF, share
participation agreements in Severodvinsk; 9) Real Estate Development of Regions 2 ZPIF, share participation
agreements in Severodvinsk. 9) ZPIF combined "Time of New Values", art values, paintings; 10) ZPIF real estate "RIF
warehouse federal 1", real estate in Novorossiysk; 11) ZPIF real estate "RIF mixed federal 2 quals"; 12) ZPIF combined
"Basic Investments M", land plot and building in St. Petersburg; 14) ZPIF combined "Basic Investments M", land plot
and building in St. Petersburg; 14) ZPIF combined "St. Petersburg", land plot and building in St. Petersburg; 14) ZPIF
combined "Basic Investments M", land plot and building in St. Petersburg; 14) ZPIF combined "St. Petersburg St.
Petersburg"; 14) ZPIF combined "New Investments", securities;
(Vol. No. 267, pp. 137 - 141)
- The testimony of Meshkova D.Y., given to her as a witness,

according to which she has been working at K - Investment LLC as a financial advisor since 2020. Her workplace is
located at the following address: Moscow, Presnenskaya Embankment, 8, Building 1, Capital City Tower, 9th floor. This
461
company is part of the QBF group of companies. Her duties at K - Investment LLC include supporting and advising
clients on existing portfolios (products), namely trust management of clients' assets. Her activities were related to the
support of clients on previously issued products in the form of consultations. According to her colleagues, she knows
that the company "QB Capital LTD" was managed by Munaev Zelimkhan Visaitovich. She works only with the clients of
"White Lake Management LTD" company and provides consultations on previously offered products by former
financial advisors. The company "SIMTELLIGENCE COMPANY LIMITED" is known to her, it is a counteragent of the
company "White Lake Management LTD", but she does not know what it actually does. The clients concluded a trust
management agreement with the company "QBF" LLC. She knows this because she had clients who are serviced by
the company QBIF Ltd. This type of transaction was handled by the client support department of the said company.
She knows that at the moment the reporting is made by the company "White Lake Management LTD". She is aware of
the company Yurmaster LLC, she was informed at the training that the company Yurmaster LLC is an intermediary of
the transaction for the transfer of clients' assets to White Lake Management LTD. The signatories of the company
"White Lake Management LTD" are Gorobets and Korshunov, the company "VL - Consulting" LLC is the representative
of the company "White Lake Management LTD", the general director of which was previously Podalko Nikolay, and
now Tartanukh Denis. "White Lake Management LTD is an investment company, which holds brokerage licences and is
regulated by the local regulator in the Cayman Islands (SIMA). SIMTELLIGENCE COMPANY LIMITED is a counterparty to
White Lake Management LTD (a transaction agent). According to the words of the managers, she knows that the
company "White Lake Management LTD" has a broker's licence. In Russia clients concluded trust management
agreements with the company QBF LLC, this type of transaction was handled by the client support department of this
company. On the international market, trust management agreements were concluded with White Lake Management
LTD. White Lake Management LTD concluded trust management agreements with clients wishing to participate in
trading on international stock markets. On disputable issues received from the clients it consulted with its manager
Vladimir Maslennikov. The reason for signing additional agreements with clients was mainly prolongation of co -
operation with the company. The reasons for extending the agreements were communicated to her by her manager,
Vladimir Maslennikov. Ignoring problem clients was due to the failure to resolve the issue on the part of the managers,
as she did not actually make any decisions. She met with the client Labudin Stepan and his lawyer in February 2021.
She dealt directly with the cancellation documents. Apart from her, the meeting was attended by Vladimir
Maslennikov, who is the head of her department, and periodically the company's lawyer Evgeniya Rossieva was
present during the conversation. The reason for the meeting was Labudin's appeal regarding the return of the
invested funds in connection with the cancellation of the contract with "White Lake Management LTD". During the
conversation it was decided to return the funds to the client, which were returned the same day. The scheme of
relations on assignment of rights between "White Lake Management LTD" and "QB Capital" was explained to
Labudinov S. and his lawyer by lawyer Rossieva Evgenia. She (Meshkova D.Y.) executed documents related to the
cancellation of relations between "White Lake Management LTD" and the client. Instructions on interaction with
complaining clients were given to her directly by her supervisor Maslennikov. Back - dated documents to be signed
with problem clients before disbursement of funds were prepared by the company's back office. She was also
responsible for providing the documents to the client for signing. The documents with client Labudin were
backdated. The instruction came to her from Maslennikov and the other from Ruslan Valerievich Spink, who is the
director of the sales department of QBF group of companies. She knows that the following employees worked in QBF
group of companies in the following positions: Ruslan Spinka - Head of Sales Department of QBF group of companies,
currently he is the Director of Sales Department; Grigor Razmikovich Erzikyan - Financial Advisor of QBF group of
companies, in the sales department he was in direct contact with clients; Rinat Felixovich Amerov - engaged in
projects, worked in QBF group of companies; Vladislav Olegovich Plitin - was its Head of Support Department for a
small period of time; Andrey V. Korzh - Head of Sales Department of QBF group of companies, currently he is the
Director of Sales Department of QBF group of companies.
(Vol. No. 267, pp. 144 - 154)
462
- Testimony of E.V. Mikhalevich, given by him as a witness,
according to which in March 2017 he was looking for a place of work and someone from his acquaintances informed
him about a vacancy in the company LLC IC QBF, which works in the financial market and needs a specialist in
recruitment. He was invited to an interview at the company QBF LLC with Vladimir Sergeevich Pakhomov, regional
director, and Roman Sergeevich Shpakov, general director. The company's office is located in one of the buildings of
the Moscow - City office centre. At the interview he indicated to Pakhomov V.S. and Shpakov R.S. that he was ready to
work in the sphere of work with personnel, work with clients, psychological assistance to employees, resolving
conflicts between employees, assistance and interaction of the organisation with law enforcement agencies. During
the interview, he accepted the position of General Counsellor. His workplace was an office in the office premises of
QBIF LLC at the following address: 8 Presnenskaya Naberezhnaya Naberezhnaya, bldg. 1, 9th floor, Moscow. In March
2017, he started to fulfil his work duties. His immediate supervisor was Stanislav Anatolyevich Matyukhin, General
Director of QBIF LLC. He (E.V. Mikhalevich) has no one in his subordination. He received most of his work instructions
from S.A. Matyukhin. His job duties included working with personnel, conducting job interviews, and working with the
employees of QB&EF Ltd. QBEF LLC is engaged in investment activities, fundraising and investment in various
projects. The owner of the company is Roman Valeryevich Shpakov. The company has branches in St. Petersburg,
Kaliningrad, Ufa, Tyumen and Yekaterinburg. The main office of the company is located in Moscow in the business
centre "Moscow City". The activities of the regional centres were headed by Vladimir Pakhomov. The main activity of
the company is to attract funds from individuals for further investment in securities and projects. The company is also
engaged in construction of residential buildings in Odintsovo, Moscow region and Severodvinsk. In Moscow in the
central office there are legal department, sales department, accounting department, IT department, human resources
department, client support department, marketing department, analytical departments, construction department.
Shpakov R.V. did not involve him in the organisation's brokerage and investment activities. In 2017, the company IK
QBF LLC started to experience delays related to untimely payments to clients under the contracts. According to the
contracts, the company was supposed to pay individuals monies within the contractually agreed timeframe. He
believed that the late payments were due in part to changes in the securities market and the company's lack of
available cash. Cash payments were made with delays, sometimes lasting six months or more. Since this period the
company continued to receive appeals from clients about untimely receipt of funds from QBIF LLC, however, most of
the appeals were settled amicably and clients were paid in full. He knows only Vasyukova from the staff of
accountants of LLC IC QBF. For a long time he has known persons who are employees of LLC QBF: Munaev Z.V. and
Rossievoy E.A., Athanasiadou Linda has seen several times in the office of the company;
(Vol. No. 267, pp. 160 - 165)
- Mkrtchyan D.G.'s Testimony as a witness,

according to which she started looking for a permanent job afer the start of the pandemic in 2020. Through her
acquaintance Yulia, an employee of the organisation "F - Experts", located in one of the "towers" in the business
centre of Moscow City on Presnenskaya embankment of Moscow, she sent a link of her application form on the
resource "Hh.ru", afer which she was invited for an interview. The interview was conducted by a member of the HR
department of the F - Experts organisation named Svetlana. She explained that "F - Experts" is a brokerage company
and afer a number of questions offered her a job as a business administrator (paralegal) to assist the employees of
the legal department. On 01.12.2020, she went to work, and on 17.12.2020, an employment contract was concluded
with her She was hired by F - Experts LLC as a business administrator. The company's office was located at the
following address: Moscow, Presnenskaya Naberezhnaya, 8, pp. 1, South Block, 9th floor, Capital City Tower. Her
direct supervisor was Evgenia Rossieva, who was a lawyer and head of the division where she worked. Apart from her
463
(E. Rossieva), she was given various assignments by other employees of the legal department who worked with E.
Rossieva: Nadezhda, Arina, Madina. In total, there were quite a lot of people working in the office. Many people came
to the office where the legal department was located. At the beginning of May 2021, she wrote a statement (to
Rossieva E.) about resignation at her own request. She knows the name "QBF", she saw this logo on the documents
handed over to her. She heard that the company carries out brokerage activities;
(Vol. No. 267, pp. 169 - 175)
- The testimony of Montes A.A.,

given to her as a witness, according to which on 01 November 2020 she was invited to work in the company IK QBF
LLC as a financial advisor. At the time of employment she was interviewed by Anastasia (HR manager), Shkrut Anton
(Head of Sales Department) and Spinka Ruslan (Head of Sales Department). Afer 2 weeks of training from 16.11.2020
she was to be officially employed by QBIF Ltd. in accordance with the Labour Code. When signing the contract, she
found out that she was employed by K - Investment LLC, where the General Director is Polibin S.S. with a salary of
21,000 rubles. These circumstances alarmed her, as no one had warned her about these details. Her manager Anton
Shkrut assured her that these were temporary measures and afer the New Year all new employees would be
transferred to the permanent staff, as the company is now planning to expand and move to other floors of the
Business Centre (Moscow City). Later she and all new employees will be properly registered. Later it turned out that
90% of the staff was registered with K - Investment LLC and this has been a common practice in the QBF group of
companies for many years. The first salary was given to her in an "envelope" and it turned out that this is also a
standard practice in the company. Despite the fact that her and her colleagues' labour contracts stipulated that they
would be paid to a bank card, in fact all employees were always paid their salaries and bonuses exclusively in
"envelopes" and without any documents from the accounting department. Bonuses were paid separately from
salaries and they were calculated on the amounts raised by financial advisors. The percentage was different for each
financial product. For example, attracting clients for trust management, the percentage was up to 7 per cent of the
amount deposited by the client, bonuses were paid immediately. Attracting clients for participation in IRO the system
of encouragement was complicated: the salary part (from 70 to 200 thousand rubles, in case of overfulfilment of the
plan it was possible to receive up to 300% of the salary in addition) of the financial adviser was formed from the total
amount of the attracted client's money, from each client's participation in IRO bonuses were accrued in the form of
0.3 to 0.7% of the allocation amount, also the financial adviser was encouraged for early closing of the transaction
(earlier than 90 days) by the client in the form of 0.7% of the transaction amount. As in this case the client paid 15% to
the company on early closing. In QBIF Ltd. there was a system of KRI, which indicated minimum plans per month,
from which the salary was calculated, and bonuses were paid from the turnover of clients' funds and depending on
the products that he bought. The highest bonuses were for attracting clients on trust management - the bonus was
10% of the amount attracted. These products were the most interesting for the company because they meant "long
money" - clients signed trust management contracts for a year or more. From the moment they started working for
the company, it became clear that their duties included first of all attracting clients to invest in the company's
products, the full cycle of their management, i.e. registration of brokerage accounts, informing them about upcoming
IROs, explanations on working with the company, transferring their applications for participation in IROs to the
middle office and transferring back the documents already prepared by the middle office to the clients themselves. All
of the training for the financial advisors was conducted using sales techniques and persuasive skills. From a financial
literacy perspective, the training was extremely superficial and more about making their words sound convincing in a
sales pitch. The head of the training department from the beginning was Avetis, the employee was Smirnova Yulia.
The employees were trained to tell clients that in addition to the main brokerage account at NSD Bank from the
licensed company QBIF LLC, they should sign a general agreement with the partner company Q-BROKER LLC to credit
clients' funds to the account of Q-BROKER LLC. This enabled clients to receive additional allocations when
participating in IROs, but greatly lengthened the timeframe for withdrawing client funds. For comparison - withdrawal
464
of funds from a brokerage account at NSD was from 1 - 10 business days, and from Q-BROKER 20 business days to an
account at NSD and another 1 - 10 business days to the client's current account. If financial advisors asked questions
as to why such long withdrawal terms were so long, as in other brokerage companies it is usually much shorter, the
management said that this is their working condition and it is not negotiable. Since the new year 2021, Andrey Korzh
announced that the company's plan for the quarter is to attract 1 billion rubles "net" and to fulfil this plan, the
company must attract 300 million every month. To implement this plan, without consulting the employees, the KPIs
were increased and sales of new products were included, which the financial advisors did not know anything about.
The initiators of these changes in the company's work were Ruslan Spinka, Andrey Korzh, and Maxim Fedorov. In the
future, the plans were exceeded by a margin on the occasion of which the company organised a holiday for
employees. In February 2021, the company abruptly started to change internal regulations for employees and
introduced fines for non - compliance with company policy. Financial advisors were pressurised to lure clients into
unsuccessful IROs that were guaranteed to drag clients' deposits into minus. It was also strictly forbidden to criticise
any of the company's actions and products in public under threat of dismissal. Previously, clients could participate in
IROs from NSD's brokerage account, but now it is mandatory to sign a general agreement with Q-BROKER LLC and
transfer funds to its account. This measure was explained by the management, represented by Isayev Javid, Andrey
Korzh and Ruslan Spinka, as mandatory and assured that the shares of the IRO companies were held in the depository
of Q-BROKER LLC in Cyprus and they bought them through their old partner Constance Investment. Internally, there
were regular operational issues related to errors in documentation, incorrectness of reports provided to clients.
Sometimes items appeared or disappeared in the reports, which made her (Montes A.A.) and other employees believe
that these reports were fake and did not correspond to real bookkeeping. She was under the impression that the
middle office was doing them manually. With all questions they were sent to the employees of the middle office and
to their manager Maria Kopylova and two of her (M. Kopylova) department employees, Katerina Alekseeva and Anna
Golubeva. They denied any allegations of discrepancies in the accounting reports and said that they in turn were sent
data from the back office, which they (the employees of the middle office) had never seen, as it was located outside
the business centre and only the management had access to it. From the month of February 2021, the agitation of
financial advisors for personal pools of clients in the employees' own accounts also started. Such canvassing was
carried out by the IRO department headed by Isaev Javid and Alexey Murashev. Murashev explained how to
circumvent the law on admitting only qualified investors to complex products by creating a pool in which persons
with deposits of 400,000 roubles or more could participate. He (A. Murashev) organised such a pool himself and
shared his skills with others. Alexey Chentsov, a financial advisor from another department, also organised such a
pool. All the work with implementation of the IRO product and arrangements with Cyprus for obtaining shares was
supervised by Isaev Javid and his main employees of the department: Alexey Murashev and Anton Lazarev. Javid had
extensive experience in the promotion of such projects, as he had previously worked at Teletrade and was a director
of that company. His (D. Isaev) duties included conducting training seminars to increase client loyalty and involve
them in investment activities. He (Javid) introduced these technologies while already working at QBIF, initially
conducting training webinars, where he spoke about the advantages of IROs and organised the work of his
department from scratch. Isayev Javid also told how exactly it is necessary to attract clients with large cheques and
what arguments to stimulate the deposit of new funds. During the time of work the main reason for attracting clients
to QBIF Ltd. was the promise of higher allocations. How the company managed to get such allocations against the
background of other competitors was unknown to her and most of the employees. Andrei Korzh and Javid Isaev were
responsible for this information, as they were the ones who published it afer the IRO was released. Afer the
allocations to failed companies became huge despite the fact that the number of clients and the total number of
participation requests was growing, she and other employees began to believe that the company was committing
fraud and "inventing" allocation data in order to deliberately steer clients' portfolios into negative returns, thus
preventing withdrawal of profits and forcing clients to keep their money with the company for as long as possible.
Also, the regular errors in the reports confirmed their speculation that there was no official accounting department
and that all calculations were done arbitrarily by the middle office staff. Observing the managers - Andrei Korzh,
Maxim Fedorov, Ruslan Spinka and Javid Isayev - she came to the conclusion that the money transferred by clients to
Kubroker accounts is used by the company at its own discretion. The concurrent emergence of new projects and talk
of the company buying property indicated that the company was acquiring the property from the funds entrusted to it
465
by unsuspecting clients. In addition to IRO products, the company sold other services: trust management services,
ZPIFs and OPIFs, Argento structured products under the guise of Eurobonds and promissory notes. The trust
management offerings were made on the Russian market through NSD's brokerage account (white scheme) or
through White Lake Management LTD and Argento (grey schemes). The head of this area and CEO of White Lake
Management LTD was Nikolay Padalko, and the financial advisors were tasked with getting clients with portfolios of
300,000,000 roubles or more into these products. However, the products themselves looked extremely unreliable, as
statistics on trust management showed negative returns and those products that Padalko called "Eurobonds" with
100% reliability were in fact structural products with embedded risks. And the very scheme of working with offshore
could not guarantee the client safety, which is why she and some of her colleagues categorically did not work with this
area. Also, since February 2021, the company started to actively offer its new products in RIFs (units of closed - end
real estate funds organised by the company). The following employees were actively engaged in this area: Maxim
Fedorov, Andrey Korzh, Ruslan Spinka. The partner in this project was Sergei Shaban, who actually owned the legal
entities to which the mutual funds were registered. In general, the product was unattractive, as the estimated value of
units was 350 thousand rubles, and the company sold them for 600 thousand rubles and promised unrealistic returns,
and many employees also refused to work with these products. Further it turned out that in some projects created by
the company the co - founders were the heads of the following departments: Andrey Korzh, Ruslan Spinka, Artem
Tallerov, Maxim Fedorov, Olga Matyukhina and other employees. Having their own stakes and personal interests in
the development of their projects, these individuals exerted special pressure on financial advisors forcing them to sell
their products and services and changed the system of CRI and remuneration of financial advisors without any
agreement with employees. Such games of the company led to internal conflicts, but no one from the company's
management team made explanations. In March, she was contacted by a client of the company who sought help in
trying to recover his funds from White Lake Management LTD. This was the first case of non - return of funds she had
encountered and she sought help in resolving the issue from her personal supervisor Ruslan Spinka, who was the
head of the sales department. She was assured that it was a mistake and all clients always get their funds back and
this mistake is due to the fault of the company's office in St. Petersburg and was promised that the issue would be
solved, but other clients started to appear with claims about non withdrawal of funds. The managers of the company
kept repeating that the main task of financial advisors is to dissuade clients from withdrawing funds and heavily
penalised the employees if their clients did apply for withdrawal. Due to such strong pressure, lack of transparency in
the company's work, non - compliance with agreements, misleading employees and using them to attract money to
an unreliable company, she decided to terminate her employment with the said company. The dismissal also violated
all legal norms of labour legislation, did not pay all the funds in full and the dismissal took place in one day;
(Vol. No. 267, pp. 192 - 198)
- A.V. Murashev's Testimony given by him as a witness,

according to which he worked in various positions in the field of finance afer graduating from university. In
December 2019, afer posting his CV on the website "NN.ru", he received a call from representatives of the group of
companies "QBF" and was invited for an interview. The interview was conducted in three stages. At one stage he was
interviewed by Padalko Nikolay, who was responsible for transactions on the international securities market of QBF
Group. In December 2019, afer being interviewed in one of the offices of the Capital City building of the Moscow City
business centre, located at: Moscow, Nab. Presnenskaya 8, he was hired as a Financial Advisor in the Client Relations
Department of K - Investment LLC. His duties as a financial advisor included: searching and inviting clients, informing
clients for the sale of investment products and trust management of clients' invested funds, opening brokerage
accounts, and as a financial advisor he sold the following products of the company: IRO - OTC assets, repo
transactions, trust management, RIF mutual funds. The organisations on whose behalf the financial products were
sold were QBroker LLC and IK QBF LLC. Clients could be solicited for the sale of the company's products through cold
calls to potential clients or through social networks and various video bloggers. His direct supervisor was Dzhavid
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Isayev, from whom (D. Isayev) he received instructions on his work and reported to him on the results of his work.
Dzhavid Isayev was supervised by Korzh Andrei and Spinka Ruslan. His salary was approximately RUB 80,000 per
month, which included fixed payments based on the results of the plan, as well as a % of the amount of funds raised.
He received his salary in cash from Dzhavid Isayev; he did not sign any pay slip. During the entire period of his
employment with K - Investment LLC, he attracted approximately 30 clients and funds totalling approximately RUB
40,000,000. Until May 2020, the company had virtually no sales due to the difficult epidemiological situation in the
world, but around July 2020, the company's sales began to increase. One of the reasons for the increase in sales was
IRO's new product - over - the - counter assets, which Javid Isaev proposed to introduce into the company's products.
The mentioned IRO financial products were widely used by other companies all over the world, but QBF Group had
not had this product before. Thanks to the IRO financial product, the company's sales have grown, the number of
clients has increased and the number of employees of QBF Group has expanded. In turn, K - Investment LLC was part
of the QBF group of companies. The office of K - Investment LLC was located in one of the offices of the Moscow City
business centre, Capital City building, at the following address: Moscow, Nab. Presnenskaya 8. The principal activity of
QBF Group of Companies was attracting clients for the sale of investment products and trust management of funds
invested by clients. The head of QBF Group of Companies was Roman Valeryevich Shpakov. Roman Shpakov's
business partner was Munaev Zelimkhan. Spinka Ruslan reported directly to Shpakov on all activities of the Sales
Department, and Spinka Ruslan was subordinated to Korzh Andrey. At the beginning of his employment with QBF
Group, he did not suspect that the company's management, represented by Roman Shpakov, Zelimkhan Munaev,
Ruslan Spinka and Andrey Korzh, could carry out fraudulent actions with clients' money, as the company had a
number of licences from the Central Bank of the Russian Federation to carry out professional activities in the financial
sphere, and many of his acquaintances were QBF clients. He began to have doubts about the legality of the actions of
the above - mentioned management of the QBF group of companies afer law enforcement officers conducted
investigative actions in December 2020 in the offices of QBF companies. He asked Ruslan Spinka and Andrei Korzh
about the legality of the company's actions, to which Spinka and Korzh explained to him that there was no cause for
concern and the investigative actions taking place in the company's offices were the work of competitors who were
trying to paralyse the activities of QBF Group. He also asked Spinka and Korzh about the necessity of withdrawal of
funds by the clients, as there were many of his acquaintances among the clients and in order to minimise possible
damage to his (Murashev A.V.) acquaintances, he could offer them to withdraw their invested funds, to which Korzh
and Spinka assured him that there were no reasons for emergency withdrawal of funds. In case of such a situation the
clients who are his (Murashev A.V.) acquaintances will have an opportunity to withdraw their invested funds as a
priority. He worked at K - Investment LLC until approximately May 2021, afer which he resigned from K - Investment
LLC at his own request. During his employment with QBF, he had to communicate with various employees of the
company: Baranova Olga - head of reception, she was also the cohabitant of Munaev Zelimkhan; Lazarev (Sibikin)
Anton - financial advisor; Hertsik Kirill - financial advisor; Khmelev Sergey - financial advisor; Tallerov Artem - head of
sales department, on the latter the management of the company withdrew shares for 300,000,000 roubles, but he
(Tallerov A.Lubov (probably Kuranina) - Shpakov's assistant, who was friends with Baranova Olga, with whom they
repeatedly flew to the UAE to Shpakov Roman and Munaev Zelimkhan; Balayan Ara - head of sales department;
Trutnev Alexander - financial advisor; Maslennikov Vladimir - head of support department, whose task was to retain
clients on the international market; Bogdanova Kristina - responsible for issuing salaries to all employees, which she
received from Spinka Ruslan, and subsequently transferred in the required amounts to the heads of departments for
transfer to the employees; Orlov Yuri - General Director of QBroker, who previously held the position of Head of IT
Department; Padalko Nikolay - supervised the Cyprus and Caymans business; Linda Athanasiadou - representative of
the Cyprus branch, who communicated with Lepeshkin Dmitry; Stanislav Matyukhin - General Director of IC QBF LLC;
Maxim Fedorov - Vice - President of the company (Senior Financial Advisor); Stella - Head of Sales Department;
Evgenia Rossieva - lawyer of QBF Group, who prepared passports of the company's products, coordinated with the
Central Bank of the Russian Federation; Oleg Timokhin - Head of BEC office; Maria Kopylova - Head of Middle Office,
who formed transactions with clients; Alexey Trunyaev - financial advisor; Ekaterina Dorokhina - financial advisor;
Alexey Chentsov - financial advisor; Marina Burshtein - financial advisor, who afer the departure of many employees
continued to respond to clients' requests; Yulia Zaitseva - financial advisor; Rinat Amerov - responsible for
cooperation with Vostochny Bank; Alexey Golubev - one of the managers of the branch in St. Petersburg; Vladislav
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Pakhomov - financial advisor. Vladimir Pakhomov - one of the regional managers; Yuri Shaban - supervised the
direction of UIF activities; Pavel Vlasov - sales department; Tural Godirli - head of analytics department; Avetis
Vartanov - instructor for training of financial advisors. He also explains that around October 2021 he received a call
from lawyer Ekaterina (8 - 909 - 913 - 27 - 04) offering her legal services in case he (A.V. Murashev) would be summoned
for questioning as a witness in a criminal case against the management of QBF Group. Ekaterina explained that her
services would be free of charge for him (A.V. Murashev), but she did not explain who paid for her services. He refused
her offer assuming that the lawyer could act in the interests of the management of QBF group of companies in order
to prevent disclosure of information defaming the management of QBF group of companies;
(Vol. No. 267, pp. 199 - 203)
- K.R. Mustafina's Testimony

given to her as a witness, according to which in 2020 she placed an advertisement in publicly available sources of
information to find a job. Around the summer of 2020 she received a call from representatives of QBF group of
companies on her ad and was invited to an interview in the office located in the building "Capital City", business
centre "Moscow City", at the address: Moscow, Nab. Presnenskaya 8. She was offered the position of a receptionist.
The interview was conducted by Olga Baranova. In July 2020, she became an employee of QBF LLC with a salary of
60,000 roubles. The salary was received in cash and given to her by Bogdanova Kristina. She did not sign any
statement for the money she received. QBF LLC was part of the QBF group of companies and was located in one of the
offices in the Capital City building of the Moscow City business centre at the following address: 8 Presnenskaya Nab.
Presnenskaya 8. The main activity of QBF Group of Companies was attracting clients for the sale of investment
products and trust management of funds invested by clients. The head of QBF Group of Companies was Roman
Valeryevich Shpakov. Her direct supervisor was Olga Baranova, from whom she (K.R. Mustafina) received instructions
and reported to her (O. Baranova) on the results of her work. In addition to Olga Baranova, her colleagues were
Kryachek Elizaveta and Kozlova Maria, and previously Dodukh Marina. Her duties as a secretary included meeting
guests, issuing passes for guests and guests' cars to the Moscow - City Business Centre, sending various corporate
messages to the necessary addresses, receiving various calls and forwarding these calls to the right department. She
had no other duties. She was employed by QBF Ltd from July 2020 to April 2021 and resigned from QBF Ltd at her own
request due to the fact that her salary started to be delayed in 2021. She knows that the following employees worked
in the QBF group of companies in the following positions: Avetis Vartanov - instructor for training of financial advisors,
he was given information about clients who called with complaints about possible loss of invested funds; Tural Godirli
- head of analytics department; Ekaterina Gramza - chief accountant; Vladimir Maslennikov - head of support
department (withdrawal of funds and cancellation of contracts at the request of clients); Stanislav Matyukhin - general
director of one of the companies included in the group of companies.
(Vol. No. 267, pp. 205 - 209)
Nabiullina T.A.'s Testimony

given to her as a witness, according to which, in Moscow, she worked in various positions that did not require special
education, and in addition, she posted her CV on the website "NN.ru" to find a more interesting and prestigious
vacancy. Around May 2019, she received a call from representatives of the QBF group of companies and was invited to
an interview. The interview took place in several stages in the Capital City building of the Moscow City business
centre, located at 8 Presnenskaya Embankment, Moscow. Afer an interview, she was hired as a receptionist, and a
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short time later she was transferred to the position of assistant to the head of OOO IC QBF, but she was actually
employed by OOO 701. Her manager was Stanislav Matyukhin. The assistant manager's duties included general
administrative functions, organising meetings and other assistance to the employees of the organisation. Afer
working with Matyukhin Stanislav, afer about three months she was transferred to the sales department as an
assistant manager. By that time she was already employed at K - Investment Ltd. Her supervisor was Ruslan Spinka,
head of the sales department. Her authority was similar to her previous authority as an assistant manager. She
received work instructions from Stanislav Matyukhin, and later from Ruslan Spinka, and reported to them on the
results of her work. In turn, Spinka reported to Roman Shpakov. Her salary was approximately 60,000 - 70,000 roubles
per month and she received it in cash from either Spinka Ruslan or Bogdanova Kristina. She did not sign for the
receipt of her salary in any statement. K - Investment LLC was part of the QBF group of companies. The office of K -
Investment LLC was located at the following address: Moscow, Nab. Presnenskaya 8, Moscow City business centre,
Capital City building. The principal activity of QBIF Group was attracting clients for the sale of investment products
and trust management of funds invested by clients. The head of QBF Group of Companies was Roman Valeryevich
Shpakov. Shpakov's business partner was Zelimkhan Munayev. Vladimir Pakhomov was also one of the managers of
the group of companies. In addition to the above - mentioned managers, she remembers a number of other
employees, but does not know their positions. These employees were: Nikolai Padalko, Andrei Korzh, Yuri Orlov, Linda
Athanasiadou, Yuri Shaban, Artem Tallerov, Vladimir Maslennikov, Oleg Timokhin, Maxim Fedorov, and Javid Isaev.
Evgeniya Rossieva is the company's lawyer and Ekaterina Gramza is the chief accountant. At the beginning of her
employment with the QBF group of companies, she did not suspect that the company's management, represented by
Roman Shpakov, Zelimkhan Munaev, and Ruslan Spinka, could carry out fraudulent actions with clients' funds, as the
company had a number of licences from the Central Bank of the Russian Federation to carry out professional activities
in the financial sphere. She began to have doubts about the legality of the actions of the above - mentioned
management of the QBF Group of Companies afer law enforcement officers conducted investigative actions in
December 2020 in the offices of the QBF Group of Companies. Afer the investigative actions, Roman Shpakov spoke
remotely via video link and explained that there was no cause for concern and that the investigative actions taking
place in the company's office were the work of competitors who were trying to paralyse the activities of the QBF
Group of Companies. Having worked at QBF Group until approximately June - July 2021, she resigned at her own
request because the organisation had started to fall apart and there were delays in wages;
(Vol. No. 268, pp. 1 - 4)
A.V. Nepomnyashchy's testimony,

given by him as a witness, according to which he is the General Director of NOA LLC. He has been fulfilling his duties
since the moment of registration of the Company up to the present time. The main activity of the Company is
consulting on tax and legal issues of individuals and legal entities, registration of foreign companies, accounting and
audit. The staff of the Company consists of 9 persons. The office of the Company is located at: Moscow, Khilkov
pereulok d. 1, sq. 19. 1, sq. 19. The premises are non - residential, rented under a lease agreement with the owner of
the above flat. Two offices in this premises were occupied by employees of Simon Jesso Ltd. without a contract,
namely offices No. 1 and No. 5. As far as he knows, there are only two employees in this company, the manager
Lepeshkin Dmitry Sergeevich and the manager Anita Chepiuk. On the relationship between LLC NOA and LLC IC QBF,
he explained that Dmitry Lepeshkin is the founder of LLC NOA with a current share of 10%. He (Dmitry Lepeshkin) was
interested in the development of the Company, as he was previously an employee of QBF LLC and had the
opportunity to attract agents from the above company, and QBF LLC employees provided contacts of their clients.
The employees of NOA LLC subsequently offered their services to said persons on their own. NOA LLC did not
conclude contracts with the clients of IK QBF LLC, as the Company's services were quite expensive and highly
qualified. Potential clients were generally not satisfied with the price of the services. There were no other
relationships between QB&E LLC and NOA LLC. The only time in February 2021, the bank account of NOA LLC received
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money in the amount of 700,000 rubles from IC QBF. According to Dmitry Lepeshkin, LLC IK QBF owed him (D.
Lepeshkin) this amount personally and he wished that the money was not given to him personally, but was
transferred to the account of LLC NOA for business development. Subsequently, the money was used to purchase
office equipment for employees. The documentation related to the activities of the organisations "168 Kvartal", "KP
turn 2", "M1 Invest" and others, which were seized during the search in office No. 5 and the round seal seized in office
No. 1, belong to Dmitry Lepeshkin and relate only to the activities of Dmitry Lepeshkin. He (Nepomnyashchy A.V.) has
known Munaev Z.V. since 2010. In 2019 Munaev Z.V. asked to get him a job at NOA Ltd. He (Nepomnyashchy A.V.) knew
that Munaev Z.V. was familiar with a number of bank managers, so he accepted him as a director of NOA LLC. His (Z.V.
Munaev) duties included searching for clients in Russian banks. Z.V. Munaeva worked until December 2020, when he
resigned at his own request. Munayev Z.V. failed to attract clients, therefore his salary was low, which apparently was
the reason for his dismissal. Afer that, Mr Munayev Z.V. worked at QBF IK LLC;
(Vol. No. 268, pp. 6 - 9)
- Nesterenko N.S.'s testimony ,

given by him as a witness, according to which, in 2020, according to his advertisement on the website "hh.ru",
representatives of the group of companies "QBF" called him and invited him for an interview at the office located at:
Moscow, Nab. Presnenskaya 8, Capital City building of the Moscow City business centre. During the interview, he
was offered the position of an analyst. His first interview was conducted by HR manager Anastasia, and the second
stage of the interview was conducted by Tural Godirli, Head of one of the departments of QBF Group. From July 2020,
he became an employee of F - Experts LLC with a salary of RUB 80,000. He received his salary in cash and received it
directly from his manager Tural Godirli. He did not sign in any statement for the money received. F - Experts LLC was
part of the QBF group of companies. The office of OOO F - Experts was located at the following address: 8,
Presnenskaya Nab. Presnenskaya 8, Moscow City business centre, Capital City building. The main activity of QBF
Group was attracting clients for the sale of investment products and trust management of the money invested by
clients. His direct supervisor was Tural Godirli, from him (Tural Godirli) he received instructions on his work and
reported on the results. He knows who Tural Godirli was subordinate to. Apart from Tural Godirli, his colleague was
the analyst Arthur Meinhard, and he (Nesterenko N.S.) communicated with Alena Gudakova, an employee of the
Middle Office. His duties as an analyst included financial analysis of shares of American companies on the world
securities market, information on which he entered into a special programme and sent to his manager. He sent the
analyses to his supervisor as soon as they were ready, as some companies could take several days to analyse. He
worked at F - Experts LLC from July 2020 to August 2021, afer which he resigned at his own request due to the fact
that in 2021 the Central Bank of the Russian Federation revoked the licence of one of the organisations within the QBF
group of companies to carry out its core activities, and in the absence of this licence, the organisation where he
worked could not carry out its core activities. Roman Valeryevich Shpakov is not personally known to him, but he has
seen him in the office. In addition, he (Nesterenko N.S.) knows that Shpakov R.V. held the highest position in the group
of companies "QBF";
(Vol. No. 268, pp. 12 - 15)
- A. S. Oberman's Testimony
given by him as a witness, according to which he worked in the investment sphere in 2020. In order to find a more
interesting and prestigious vacancy, he placed his CV on the website "hh.ru". In December 2020, he received a call
470
from representatives of the QBF group of companies and was invited to an interview. The interview was conducted
with him by Artyom Tallerov, who is the Head of Sales in the Sales Department of the QBF Group of Companies. The
interview was held at the following address: 8 Presnenskaya Naberezhnaya Embankment, Moscow, Capital City
building, Moscow City business centre. In January 2021, he was hired as a Financial Advisor in the Client Relations
Department of K - Investment LLC. His duties included: searching and inviting clients, informing clients to sell the
company's investment products and trust management of clients' invested funds, opening brokerage accounts. As a
financial advisor, he sold the following products of the company: IPO - over - the - counter assets. He did not sell any
other company products other than IPOs. The organisation on whose behalf the financial products were sold was
QBIF LLC. The solicitation of clients for the sale of the company's products may have been through cold calls to
potential clients, or through social media via various video bloggers. His direct supervisor was Tallerov Artem, from
whom he (Oberman A.S.) received instructions on his work and reported on its results. Tallerov Artem's supervisor
was Korzh Andrei, and Korzh Andrei's supervisor was Spinka Ruslan. His (A.S. Oberman's) salary was approximately
45,000 - 65,000 roubles per month, which included fixed payments based on the results of plan fulfilment, as well as a
% of the amount of funds raised. He received his salary in cash from Tallerov Artem, and he did not sign any statement
for receiving it. During all the time he worked at K - Investment LLC, he attracted approximately 3 - 4 clients and funds
totalling approximately RUB 5,000,000. K - Investment LLC was part of the QBF group of companies. The office of K -
Investment LLC was located at 8 Presnenskaya Naberezhnaya Street, Moscow, Moscow City business centre, Capital
City building. The main activity of QBIF Group was attracting clients for the sale of investment products and trust
management of funds invested by clients. The Head of QBF Group of Companies was Roman Valeryevich Shpakov. At
the beginning of his labour activity in the group of companies "QBF" he (A.S. Oberman) did not suspect that the
management of the company represented by Roman Valerievich Shpakov could carry out fraudulent actions with
clients' money, as the company had a number of licenses of the Central Bank of the Russian Federation to carry out
professional activities in the financial sphere. Doubts about the legality of the actions of the above - mentioned
management of the QBF Group of Companies began to appear in his mind afer law enforcement officers conducted
investigative actions in the offices of the QBF Group of Companies in May 2021. Artem Tallerov explained to him that
there was no cause for concern about the searches and that the investigative actions taking place in the company's
office were the work of competitors who were trying to paralyse the activities of the QBF Group of Companies. He (A.S.
Oberman) worked at K - Investment LLC until approximately June 2021, afer which he resigned at his own request
due to the fact that in May 2021 the company began to "fall apart" and delays in payment of wages began. In addition
to Roman Valeryevich Shpakov, Zelimkhan Munayev and Stanislav Matyukhin were also managers of QBF Group.
During his employment with QBF, he had to communicate with various employees of the company, namely: Alexey
Chentsov - Senior Financial Advisor; Maxim Fedorov - Vice President of the Company; Alexey Zykov - Financial Advisor;
Anton Lazarev - Financial Advisor; Ekaterina Dorokhina - Financial Advisor; Alexander Ilyin - Financial Advisor; Nikolay
Padalko - Head of one of the company's business lines; Avetis Vartanov - Financial Advisor Training Instructor; Alexey
Trunyaev - Financial Advisor; Tural Godirli - Financial Manager; Marina Burshtein - Financial Advisor; Alexander
Trutnev - Financial Advisor;
(Vol. No. 268, pp. 19 - 22)
- The testimony of Y.Y. Olifirenko, given to her as a witness,

according to which in March 2021, she was looking for a place of work and on the website "hh.ru" saw an
advertisement that the company "QBF" requires a head of the direction of work with corporate clients. She sent her
CV to the company via the Internet. A short time later she received a call back from a member of QBF's human
resources department who suggested that she come to the company for an interview. In the company's office located
at 8 Presnenskaya Naberezhnaya Naberezhnaya, bldg. 1, Moscow City Business Centre, 9th floor, south block, Capital
City Tower, she was interviewed by Anastasia Zaripova, an employee of the recruitment company. During the
interview she (Y.Y. Olifirenko) found out the main directions of the company's activity, as well as other questions she
471
was interested in about the company's activity. She learnt that QBF works in the field of investment activities. She was
also interviewed by Ekaterina Zaitseva, Deputy Executive Director of QBF. She was informed that the company was
ready to hire her and she started her work duties from 29 March 2021. The employment contract stated that she was
employed by K - Consulting LLC. Her workplace was an office in the premises of the office of K - Consulting LLC on the
5th floor of the Capital City building; her supervisor was Ekaterina Zaitseva, Deputy Executive Director of K -
Consulting LLC. She (Y.Y. Olifirenko) did not receive work instructions from other persons. Her job duties included:
attracting legal entities for financing by issuing exchange bonds through the Moscow Exchange. Her task was to use
the available "cold" bases to make telephone calls to legal entities that were ready to issue exchange bonds through
the Moscow Exchange. There were publicly available databases "Spark" "Sbiz", in which she found legal entities and
made phone calls. If the legal entity agreed to issue exchange - traded bonds, a contract was signed to organise the
issue of exchange - traded bonds. She knows this process only in theory, as she has not involved any legal entities
during her labour activity. The management of the company represented by Zaitseva E.V. explained that the company
has no existing clients - legal entities, therefore the main task is to attract clients and create a base of clients - legal
entities for the company K - Consulting LLC. K - Consulting LLC is a member of the QBF group of companies, as she
represented herself on behalf of QBF when making calls. She knows that Roman Valeryevich Shpakov is the owner of
the company and Stanislav Anatolievich Matyukhin is the general director. Evgenia Anatolievna Rossieva is known to
her as the chief lawyer of the company;
(Vol. No. 268, pp. 24 - 27)
- The testimony of Y .N. Orlov, given by him as a witness,

according to which he worked in the financial company "QBF" from 2015 to 2018. In 2020, he opened the sole
proprietorship "Orlov Yuri Nikolaevich". He has a 6.9 % stake in LLC "MC "Moi Finansy", the CEO of which is Rybalko I.V.
He acquired the stake approximately at the end of summer - beginning of autumn 2020. The owner put the company
LLC MC Granat (LLC MC Moi Finansy) up for sale. This offer interested R.V. Shpakov. Since the transfer of ownership of a
licensed professional participant of the securities market (licence of the Central Bank of the Russian Federation for
trust management and management of mutual funds) required a certain number of participants, R.V. Shpakov asked
him (Y.N. Orlov) to become a holder of a part of LLC MC Moi Finansy, afer which the transaction was made. The size of
the participants' share was determined by Shpakov R.V. Since 2017, he worked at QBF as the head of the information
support department, managing the department, namely: recruitment of personnel, personnel management,
development of sofware for groups of companies, provision of network and server infrastructure, ensuring
information security. In 2018, he resigned from this company. At present, he has an IE "Orlov Yuri Nikolaevich", which
manages the legal entity Q Broker LLC. In LLC "Q Broker" he was engaged in operating the legal entity, recruiting staff
to create a mobile application "Q Broker", which should provide information and analytical service on the stock
market. The staff consisted of three people: a director, a deputy director (engaged in attracting investment projects)
and a specialist in transaction accounting (accompanying the transaction). The office was located in the building of
Moscow City MFC "Capital City", Moscow Tower, 5th floor, room 56. During his work in QBF company, he provided
consultancy in the field of IT technologies, namely: procurement of equipment, information security, support of the
company's group infrastructure and its development, personnel management, setting tasks for the staff of the IT
department. From the companies QB Capital LTD, "White lake", "SIMTELLIGENCE COMPANY LIMITED", "QCCI LTD",
"White Lake Management Ltd" he knows many employees, as he helped with consultations on the purchase of
domains, as well as at the request he carried out their purchase. For "White lake" he bought a domain name, also
served e - mail, interaction from this company with him was carried out by Kovalenko (Athanasiadou) Linda and
Munaev Z.V. Also he bought a domain name for "SIMTELLIGENCE COMPANY LIMITED" at the request of Kovalenko
(Athanasiadou) Linda on the account of "White lake". For the company "White Lake Management Ltd" he bought a
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server and opened access, the domain was opened in his name (Orlova Y.N.). The company "White Lake Management
Ltd" was located in the Cayman Islands. He provided this company with an "empty" server and gave the credentials to
Kovalenko (Athanasiadou) Linda, afer which the employees of "White Lake Management Ltd" published an official
website with the location: Cayman Island. As an IT specialist he advised "White lake" and "White Lake Management
Ltd" organisations, namely he offered free domain names, carried out registration of these domain names. For "White
Lake Management Ltd" he ordered an "empty" server to host a website and an e - mail server. Also Kovalenko
(Athanasiadou) Linda asked him about the possibility of purchasing a subscriber number with a prefix of a foreign
country (Cayman). He found a service (Frizvon.com), with the help of which he was able to register this subscriber
number and made redirection to it. Regarding the formation of reports on behalf of QB Capital LTD, "White lake",
"SIMTELLIGENCE COMPANY LIMITED", "QCCI LTD", "White Lake Management Ltd", he (Y.N. Orlov) explained that there
was a handwritten programme for the formation of reports, and an error was found in it: mismatch of date types.
Kovalenko (Athanasiadou) Linda applied to him for help in eliminating the error. He eliminated this error by changing
the date type from a numeric value to the "datetime" type. He (Y.N. Orlov) also explained that R.V. Shpakov was the
main shareholder of the company JSC FG QBF and he (R.V. Shpakov) repeatedly consulted with him (Y.N. Orlov) about
equipment, infrastructure, ensuring the reliability of sites and networks. He (Y.N. Orlov), knows that R.V. Shpakov has
a certificate of FFMS 5.0 (management of mutual funds). Pakhomov V.S., is also one of the shareholders of JSC FG QBF,
supervised the regional offices. He (Y.N. Orlov) communicated with him about and assisted in providing IT support to
the branches of the financial group. Munaev Z.V., is a managing partner, he supervised the Moscow office;
(Vol. No. 268, pp. 31 - 36)
- I.S. Pankov's Testimony

as a witness, according to which, around February 2021, his acquaintance Elizaveta Taran invited him to work at QBF
as a programmer. He accepted the offer and at the appointed time went to the interview, which was conducted with
him by specialists Anastasia and Boldyrev Maxim, who was at that time a team leader in the IT department of QBF.
The interview was held at the following address: 8 Presnenskaya Naberezhnaya Naberezhnaya Street, Moscow,
Capital City building of the Moscow City business centre. In February 2021, he was hired as a programmer in the
organisation F - Technologies Ltd. He mainly worked remotely and was rarely in the office. His duties as a programmer
included the development of a "Web" application for maintaining internal documentation and systematisation of
internal and working documents. Support of the company's clients was not included in his functions, this area of
activity was assigned to another programmer. His direct supervisor was Maxim Boldyrev, from him (M. Boldyrev) he
received instructions on his work and also reported on the results. His salary was approximately 70,000 roubles per
month during the probationary period. He received his salary in cash from Maksim Boldyrev, and he did not sign any
salary receipt slip. F - Technologies LLC was part of the QBF group of companies. The office of LLC F - Technologies
was located at 8 Presnenskaya Naberezhnaya Street, Moscow, Moscow City business centre, Capital City building. The
main activity of QBF Group was attracting clients for the sale of investment products and trust management of funds
invested by clients. At the beginning of his labour activity in the group of companies "QBF" he did not suspect that the
management of the company could carry out fraudulent actions with the money of clients. He began to have doubts
about the legality of the actions of the above - mentioned management of the QBF group of companies afer law
enforcement officers conducted investigative actions in the QBF office in May 2021. He worked at F - Technologies LLC
until approximately 02 July 2021, afer which he resigned at his own request due to the fact that his salary payment
delays began;
(Vol. No. 268, pp. 42 - 45)
473
- A.V. Pashinyan's Testimony
given to her as a witness, according to which in December 2020 she was employed by the company F - Experts LLC as a
corporate lawyer. Her job duties included preparation of documents for registration and liquidation of companies, for
share purchase and sale transactions, for making changes to information in the Unified State Register of Legal
Entities, approval of lease agreements and fulfilment of other minor assignments. She performed her duties at the
office of F - Experts LLC located at 8 Presnenskaya Naberezhnaya Street, 9th floor, Moscow. She was employed by the
organisation through the website "hh.ru". From the moment of her employment, her direct supervisor was Evgenia
Rossieva, whom she met afer she was hired. She does not know how many lawyers worked at F - Experts LLC. There
were only 6 people working in the legal department, she cannot explain in which organisations the other lawyers were
employed. The direct supervisor of the other lawyers was also Evgeniya Rossieva. All the lawyers were located in one
office. The following persons worked in the legal division (department): Yevgeniya Rossieva, she (A.V. Pashinyan),
Nadezhda Firsova, Maxim, Madina, Diana. She (A.V. Pashinyan) had corporate work, such as changing the general
director's documents or changing the address, or other assignments. The tasks and assignments were given to her
only by Evgenia Rossieva and she (A.V. Pashinyan) reported only to E. Rossieva. Apart from the legal department
(department) in this organisation there was a sales department, HR department, IT department, accounting
department, some other departments. She saw people sitting in the office, but she does not know what activities they
were engaged in. Evgenia Rossieva worked the longest in the legal department. She knows the names of the
organisations QBIF Investment Company LLC, QBIF LLC, QBIF Asset Management LLC. These names of companies she
met in the documents on which she was given assignments by Evgenia Rossieva, for example, when drafing the new
charter of QBIF Investment Company LLC. In the course of her employment, she conducted transactions involving the
purchase and sale of shares. These were transactions between legal entities on both sides, individuals on both sides,
and between legal entities and individuals. These are corporate transactions, they involved organisations. Individuals
were the founders of companies. In part she supported the transaction of purchase and sale of a share of Simon -
Jesso LLC, the agreement was signed by agreement on behalf of Shpakov R.V. She received the task to support this
transaction from Evgeniya Rossieva. The support included preparation of the agreement, making arrangements with
a notary, and conducting the transaction at the notary's office. She also knows the following employees of the
company: Spinka R.V. - worked in the sales department; G.R. Erzikyan; A.V. Korzh - worked in the sales department;
V.G. Frolov - previously was the General Director of QBIF Investment Company Ltd. - owner of the company; Munaev
Z.V.; Rossieva E.A.; Gorobets E.V.; Padalko N.S. - was General Director of VL - Consulting LLC; Orlov Yu. - General
Director of JSC MarketPlace Moi Finansy; S.A. Matyukhin - General Director of LLC QBIF Investment Company; Y.G.
Smirnova - General Director at QBIF Asset Management; Y.V. Shaban - General Director and founder of JSC RIF; R.V.
Feoktistov; E.N. Kharina. The procedure for changing the General Director is as follows: the decision of the general
meeting of the company's participants is taken and drawn up either in the form of a resolution (if the participant is the
only one) or in the form of minutes of the general meeting (if there are several participants); the company prepares an
application to the tax authority according to the tax form, an application on behalf of the General Director, newly
appointed - the sole executive body; then this application is obligatory certified by a notary, the General Director can
submit this application through the notary and register it with the tax authorities. It accompanied about two or three
procedures of changing the general director. In particular, this procedure was carried out in LLC Q-BROKER around
February - March 2021. On the instructions of Evgeniya Rossieva, she prepared a draf resolution of the general
meeting of the Company's participants on the change of the general director and an application in the form of a tax
inspection. Previously in Q-BROKER LLC the general director was R.V. Shpakov. According to the decision of the
General Meeting, a sole executive body was appointed - a manager in the form of IE Orlov Yuri Nikolaevich. She with
Y.N. Orlov and the package of documents met at the notary, where Y.N. Orlov signed the application and the notary
himself submitted the documents to the tax inspection. When drafing documents for the transaction of sale and
purchase of the Company's shares, the notary first signed an offer from the seller on behalf of the General Director of
the Company stating that he intended to sell the share. If the share is sold to a third party, it is necessary that the
other members waive the pre - emptive right to buy out the share, if such is provided for by the Articles of Association.
In such a case, the other participants of the Company signed a waiver of the share purchase at a notary's office. If the
Company has a pre - emptive right of redemption by the Charter, then afer all participants have refused, the
474
Company writes a refusal to redeem the share at the notary's office. Afer that all constituent documents and
documents on the formation of the share are directly sent to the notary, the list of participants is sent to the notary on
the day on the date of the transaction. On this day at the notary is signed the contract of sale and the notary himself
sends an application for changes in the Unified State Register of Legal Entities to the tax inspection. The Seller and the
Buyer must come to the notary to sign the contract. On the assignment of Evgeniya Rossieva she accompanied the
sale of R.V. Shpakov's share - his part of the share in the authorised capital of the company Simon - Jesso Ltd. to a
third party. On the day of the transaction she signed the contract on behalf of Shpakov R.V. by power of attorney, his
mother Shpakova I.N. The buyer was a third party, a man came, acting without a power of attorney. She (A.V.
Pashinyan) had encountered this man only once that day. This transaction was particularly memorable for her, as it
was conducted with the participation of R.V. Shpakov's mother and was prepared for a long time;
(Vol. No. 268, pp. 52 - 59)
A.V. Pirogov's Testimony

as a witness, according to which he moved to Moscow in January 2021. Even before his move, he tried to find a job in
Moscow. He learnt from his acquaintance Anton Lazarev, who works at K - Investment LLC, that this company is
engaged in investment activities and he (A.V. Pirogov) became interested in employment in this company and asked A.
Lazarev to find out about vacancies. Subsequently, he was contacted by an employee of the human resources
department of QBF Company. In the course of correspondence "Anastasia" asked him questions concerning the
activities of QBF Company, whether he had work experience in investment companies. He was then offered a second
stage of the interview with his personal participation. About a week and a half later, he was interviewed at QBF's office
on Presnenskaya Embankment, Building 8, afer which he was offered training and an internship, afer which a final
decision on his employment would be made. He was interviewed by his future direct supervisor Isayev Javid. Until
mid - February 2021 he (A.V. Pirogov) underwent training and internship. During this period his duties included calling
clients who were offered the company's products, namely IPO (initial public offering), trust management products.
Phone numbers printed on a sheet of paper were provided to him by Isaev Javid. During a working day he (A.V.
Pirogov) "worked" about 30 - 50 subscriber numbers. Upon completion of the traineeship, from 02.03.2021 he was
enrolled as a junior financial advisor of K - Investment LLC. He had an agency agreement with QBF. He continued to
perform the same duties as during the internship period. He used, among other things, a "cold" database of
telephone numbers. Under this term it is understood that the base was formed on the basis of open sources received
from Internet search engines, social networks, messengers, when a person on the Internet was interested in
investment activities and there was information about his subscriber numbers. There was also a "hot" base. Its
essence was that there were blogs on the Internet that covered the investment activities of QBF and Freedom. The
bloggers had agency contracts with these campaigns. If any of the subscribers of the channels or other persons who
viewed the channels contacted a blogger about investment activities, the blogger would provide the client with
contacts for contacting QBF and Freedom employees. The bloggers received remuneration for the "provided" clients
according to the agency agreement. He worked in this company until 10.06.2021, resigning at his own request. The
reason for his resignation was that the Central Bank of Russia restricted the company's activities, so his salary was
reduced. His salary was 20,000 roubles (salary). Other payments totalled interest from the agency contract, and he did
not know the settlement procedure. The average monthly salary for the entire period of his employment with the
company was 70,000 - 80,000 roubles. During the above period of work he opened up to 30 brokerage accounts, of
which about 10 accounts were involved in IPOs. In case a client needed the company's services, the client remotely
informed him (A.V. Pirogov) by telephone of his personal data (full name, passport details, TIN, etc.), which he entered
into Nabix's database, and the client's e - mail address was also entered into the database, through which the
company subsequently contacted him. Afer that, the client's phone receives a code in SMS - message, which he
informs, and he (Pirogov A.V.) entered this code into the database. Afer that the client was considered registered.
Further, a department known to him as "Midlofis" worked with the client. The client was sent an accession
agreement, a questionnaire, and the company's regulations by e - mail. Subsequently, the client had to confirm the
status of a "Qualified Investor" by providing QBF with information (bank statement) on the availability of at least
6,000,000 roubles in his bank or brokerage account. The client submitted this information to Midlofis, where it was
475
checked for accuracy within 10 working days. Subsequently, if the verification was positive, the client was allowed to
participate in the IPO (initial public offering). Then the financial advisor (the employee of the company, who carried
out the registration of the client) informs the client weekly about the upcoming IPO, afer which the client
independently decided in which IPO he would participate and for what amount he entrusted his financial advisor to
carry out this or that operation. The client himself funded the brokerage account by transferring funds from his
personal bank account to QBF's brokerage account opened with Alfa - Bank and NSD (National Settlement
Depository). The details of the brokerage account were shown in the accession agreement. The Company understood
from whom the funds were received, as it was visible from whom the payment was received. His (A.V. Pirogov) direct
supervisor was Isayev Javid, with whom he (A.V. Pirogov) had contact in connection with his labour activity. In the
office where he worked there were constantly about 70 - 80 employees of the company. In the department to which he
belonged there were about 14 employees. On one occasion he attended a company conference where he saw Z.V.
Munayev, who labelled himself as a manager when speaking;
(Vol. No. 268, pp. 65 - 69)
- Testimony of Plitin V.O., given by him as a witness,

according to which from 04.04.2012 he worked in "QBF Finance" LLC as a financial advisor, from 13.01.2014 in the
same company as a senior financial advisor, from 20.10.yu2014 as a leading financial advisor, from 22.02.2016 he was
transferred to "FC KBF" LLC as a back office manager, from 22.02.2016 he was employed in the sales department of
"FC KBF" LLC as a leading financial advisor. From 01.11.2017, he was employed in the customer service department of
QBF Advisers Ltd, on 31.01.2019, the employment contract was terminated. From 06.02.2019 he was employed at K -
Investment LLC as a Lead Financial Advisor, 06.03.2020 the employment contract was terminated. In LLC "K -
Investment" he was engaged in consulting clients on compliance issues (consultations on the list of documents
required for the transfer (receipt) of funds). In addition, in QBF Adviser Ltd. and in K - Investment Ltd. he was engaged
in personnel training. He is aware that the company "QB Capital LTD" provided access of clients to the securities
market. Around 2013 - 2014, he brought one of the clients to sign documents mentioning this organisation, what the
document was about, he does not remember. Regarding the term of refund to the clients, he explained that the term
of refund depended on the terms of the contract, afer notification was from 15 to 30 working days. Until 2014, to
participate in trading on international stock markets, a client had to provide a Russian passport, a foreign passport,
and dollar details. Funds were transferred by the clients themselves by bank transfer to the settlement account of the
company whose services they used. The vast majority of money transfers as dividends were made by wire transfer to
the accounts from which the clients sent the funds. The actual managers of the company "QBF" were the
shareholders Roman Valeryevich Shpakov, Zelimkhan Visaitovich Munaev, Vladimir Sergeyevich Pakhomov. In the
course of his labour activity he had to face the following employees: Spinka R.V.; Padalko N.S.; Korzh A.V.; Zaitseva Y.S.;
Meshkova D.Yu.Z.V. Munaev; S.A. Matyukhin; E.A. Rossieva; D.S. Lepeshkin; D.S. Athanasiadou Linda; P.Y. Vlasov; K.S.
Sobolev; A.S. Golubev; Y.G. Smirnova. He is familiar with the above persons, but their relation to the Kyubi group of
companies is unknown to him;
(Vol. No. 268, pp. 75 - 95)
476
- Radchenko A.S.'s Testimony
given to her as a witness, according to which in 2020 she placed her advert in publicly available sources of information
to look for a job. In October 2020, representatives of the QBF group of companies called her ad and invited her to an
interview at the office located at 8 Presnenskaya Naberezhnaya Naberezhnaya Street, Moscow. Capital City building of
the Moscow City business centre. During the interview, she was offered the position of Financial Advisor. She was
interviewed by Tatyana Zavyalova. Afer the interview, from October - November 2020, she became an employee of K -
Investment LLC with a salary of approximately 100,000 roubles. She received her salary in cash, which was issued by
Tatyana Zavyalova. She did not sign for the money received anywhere. K - Investment LLC was part of the QBF group
of companies. The office of QBF LLC was located at 8 Presnenskaya Naberezhnaya Naberezhnaya Street, Moscow,
Moscow City business centre, Capital City building. The principal activity of QBF Group was to attract clients for the
sale of investment products and trust management of funds invested by clients. The head of QBF Group of Companies
was Roman Valeryevich Shpakov. Her direct supervisor was Tatyana Zavyalova, from whom she (Radchenko A.S.)
received instructions on her work and reported on the results. Tatiana Zavyalova was subordinate to Ruslan Spinka. In
addition to Tatiana Zavyalova, her (Radchenko A.S.) colleagues were: Korzh Andrey - head of sales; Maxim Fedorov -
vice president of the company; Tomila Nabiullina - financial advisor. Roman Shpakov's business partner was Munaev
Zelimkhan. Spinka Ruslan reported directly to Shpakov, and Spinka Ruslan reported to Korzh Andrey. Spinka reported
directly to Roman Shpakov on all activities of the Sales Department. At the beginning of her employment with QBF
Group, she did not suspect that the company's management, represented by Roman Shpakov, Zelimkhan Munaev,
Ruslan Spinka and Andrey Korzh, could carry out fraudulent actions with clients' money, as the company had a
number of licences from the Central Bank of the Russian Federation to carry out professional activities in the financial
sphere, and many of her acquaintances were QBF clients. She began to have doubts about the legality of the actions
of the above - mentioned management of the QBF group of companies afer law enforcement officers conducted
investigative actions in the offices of the QBF group of companies in December 2020. According to Tatyana Zavyalova,
she learnt that there is no cause for concern and that the investigative actions taking place in the company's offices
are the work of competitors who are trying to paralyse the activities of the QBF Group of Companies. In addition,
Zavyalova T. asked her (Radchenko A.S.) not to tell anyone that the office of the company "QBF" was searched. She
(Radchenko A.S.) worked at K - Investment LLC until approximately March - April 2021, afer which she resigned from K
- Investment LLC at her own request due to the fact that the company began to "fall apart" and delays in payment of
wages began;
(Vol. No. 268, pp. 98 - 101)
- The testimony of Romanenkova D.D., given to her as a witness,

according to which approximately in October 2020, she received a call from representatives of the QBF Group of
Companies and was invited for an interview at the office located at: Moscow, Presnenskaya Naberezhnaya 8, building
"Capital City" of the business centre "Moscow City". During the interview, she was offered the position of assistant
manager. She was interviewed by Tatiana Zavyalova. Afer the interview, from October 2020, she became an employee
of K - Investment LLC with a salary of approximately RUB 60,000 as an assistant to Tatiana Zavyalova, who was the
head of the support department in the Russian Federation. She (D.D. Romanenkova) received her salary in cash, and
Tatiana Zavyalova gave it to her. She did not sign for the money she received. K - Investment LLC was part of the QBF
group of companies. The office of QBF LLC was located at 8 Presnenskaya Naberezhnaya Street, Moscow, Moscow City
business centre, Capital City building. The principal activity of QBF Group was to attract clients for the sale of
investment products and trust management of funds invested by clients. The Head of QBF Group of Companies was
Roman Valeryevich Shpakov. Roman Shpakov's business partner was Munaev Zelimkhan. Shpakov was directly
subordinated to Spinka Ruslan, and Spinka Ruslan was subordinated to Korzh Andrey. Her (Romanenkova D.D.) direct
supervisor was Tatiana Zavyalova, from whom she received instructions on her work and reported on the results of
477
her work. Tatiana Zavyalova was subordinate to Andrey Korzh and Ruslan Spinka. Around December 2020, she (D.D.
Romanenkova) was transferred to the position of a "middle office" specialist, where her supervisor was Maria
Kopylova. The functions of the "middle office" are as follows: receiving an application from a financial advisor
(opening of a brokerage account, an iPO application for a certain ticker of the company - purchase of an option, an
application for withdrawal of client's funds from the general agreement "framework agreement" or from the
brokerage account to the settlement account of an individual) to the working e - mail, processing and execution of the
application. She (D.D. Romanenkova), as a "middle office" specialist, communicated with financial advisors through
the Smurf programme, where some requests were processed. In addition, she had to communicate with the client
when approving a transaction for withdrawal of funds. Withdrawal of funds or closing of an option was done through
the programme "ZhRPK". At the beginning of her employment with QBF Group, she did not suspect that the
company's management represented by Roman Shpakov, Zelimkhan Munaev, Ruslan Spinka and Andrey Korzh could
carry out fraudulent activities with clients' funds, as the company had a number of licences from the Central Bank of
the Russian Federation to carry out professional activities in the financial sphere, and many of her acquaintances
were QBF clients. In December 2020 and in May 2021, law enforcement officers conducted investigative actions in the
offices of QBF Group, and many clients were unable to withdraw their invested funds. Afer the investigative actions,
she addressed her supervisor M. Kopylova, as well as Irina Shpakova (Roman Valeryevich Shpakov's mother) with a
question about the legality of the company's actions. Zavyalova T. and Shpakova I. explained that there was no cause
for concern and that the investigative actions taking place in the company's office were the work of competitors who
were trying to paralyse the activities of the QBF group of companies. In addition, Zavyalova T. and Shpakova I.
explained that she (Romanenkova D.D.) should not tell anyone that the office of the company "QBF" was searched.
Afer that, her doubts about the legality of QBF management's actions were confirmed, as she had previously
surmised that in the IPO, the money received from clients may not have been used to purchase OTC options, but may
have been transferred to other accounts and purposes, and clients may have been provided with inaccurate
information about the expenditure of their money. In May 2021, there were numerous withdrawal requests from
customers, but the requests were not executed because the customers' funds were no longer in the accounts where
they should have been. She worked at K - Investment LLC until approximately the beginning of June 2021, afer which
she resigned from K - Investment LLC at her own request due to delays in payment of her salary;
(Vol. No. 268, pp. 108 - 111)
- T.V. Rudakova's Testimony given to her as a witness,

according to which in 2014 she was employed by the Central Bank of Russia as Chief Economist of the Department for
Supervision of Professional Securities Market Participants. She worked in this position until 2016. In 2016, she
resigned from the Central Bank of Russia and was employed by QBIF LLC as Head of the Depositary Department,
where she worked until mid - 2017, afer her resignation she was employed back to the Central Bank of Russia as Chief
Expert of the Securities and Commodity Market Department of the Bank of Russia. In this position she worked until
June 2020, from June 2020 she was employed as a consultant, Financial Market Infrastructure Department of the
Bank of Russia. When she was employed by QBIF LLC, she was interviewed by Munaev Zelimkhan Visaitovich and
Rimma Viktorovna Rutinish. During her employment with QBIF Ltd, she prepared a set of documents required to
apply for a licence to carry out depository activities. Her immediate supervisor was Yuri Minaev and her superior was
Zelimkhan Visaitovich Munayev. One of the reasons for her dismissal was complaints from clients against QBIF LLC
regarding the failure to return funds to clients. She also did not like the approach to the organisation of the company's
activities on the financial market, namely the unfair performance of financial obligations to clients. During the period
of her employment she learned about the incoming complaints from clients and the incoming instructions from the
Bank of Russia regarding the company's activities from the controller of the organisation. The name QB Capital is
familiar to her, the Central Bank requested information on this company, requests were sent to QBIF LLC within the
framework of consideration of complaints and appeals of citizens by the Bank of Russia's NWPFU. On the part of LLC
478
IC QB&EF, in accordance with its official duties, the company's controller prepared responses to the requests and
prescriptions. In 2021, due to a large flow of citizens' appeals and complaints regarding brokerage activities and
trustee activities of QBIF IC LLC, an inspection was initiated. Based on the interim inspection report of QBIF LLC, the
company violated the requirements established for depository activities: - Clause 2.1 of Regulation No. 542 - P in
terms of failure to register in the system of record keeping of documents of the Company's depository a document,
the registration of which is stipulated by Clause 2.1 of Regulation No. 542 - P (1 case); - Clause 3.2 of Regulation No.
542 - P (1 case); - Clause 2.2 of Regulation No. 542 - P (1 case); - Clause 3.2 of Regulation No. 542 - P (1 case)..2 of
Regulation No. 542 - P in terms of reflecting an incorrect unique number of the document on the basis of which the
depositary operation is conducted, assigned when registering the document in the document accounting system; -
Clause 4.2 of Regulation No. 542 - P in terms of not indicating the name of the organisation from which the amount of
income in monetary form and (or) other monetary payments on securities was received;
(Vol. No. 268, pp. 113 - 116)
- The testimony of D.I. Rykov, given by him as a witness,

according to which from 2011 to 2016 he was employed by PJSC VTB 24, where he worked as Managing Director for
the Tyumen Region. In July 2016, he received a job offer from Vladimir Sergeevich Pakhomov, a shareholder of the
investment company LLC "FC" KBF INN 7703406600, to work in the said company. For the interview, among other
candidates, he travelled to the company's head office located at 8 Presnenskaya Naberezhnaya Street, Bldg. 1,
Moscow. Afer the interview and testing, he was introduced to Roman Valeryevich Shpakov, the beneficiary of FC KBF
LLC, Munaev Zelimkhan Visaitovich. During the meeting, he realised that they, together with Vladimir Sergeevich
Pakhomov, were the owners and group managers of the company "QBF". On 19 January 2017, he was employed as
Vice President for Corporate Clients of QBF LLC. The employment relationship was formalised by an employment
contract with the said organisation. His (D.I. Rykov) duties included: overhaul of the rented premises, which later
housed the office of the representative office, organisation of the work of the representative office in Tyumen,
recruitment of employees, carrying out promotional activities, marketing research in order to attract clients
interested in investing money in financial products offered by the company. Afer the branch was opened on 3 July
2017, he was transferred to the position of the branch director of QBIF LLC. The Director was responsible for recruiting
staff, organising training with the regional centre in St. Petersburg and individual employees in Moscow. He was also
responsible for promoting the QBF brand in the Tyumen and regional markets, organising marketing events involving
head office specialists, traders, portfolio managers and attracting a wide range of potential clients to these events.
Additionally, his duties included organising the work of financial advisors, decomposing plans communicated by the
regional centre, as well as implementing plans for attracting clients and investing clients' money. His immediate
supervisors were Vladimir Sergeevich Pakhomov, who was acting head of the branch network; subsequently, since
2018, V.S. Pakhomov transferred his authority to Alexey Sergeevich Golubev. The tasks on the planned attraction of
funds for international and Russian market products were initially given by V.S. Pakhomov, and the priority of
attraction of funds was on the international market, by attracting them to the trust management of IC QBF in
conjunction with QB Capital. In 2018, "QB Capital" was renamed "QCCI", and subsequently by order of the
management represented by Pakhomov V.S. and Golubev A.S., all clients were transferred to the service of "White
Lake Management" with the transaction agent "Simtelligence". The process of signing the agreement and providing
documents to the client was as follows: the head of the regional office and Ekaterina Martsinyuk, a BEC employee,
was informed about the upcoming transaction, namely the type of product, amount, transaction date, client's full
name, passport copy, KYC, profile data, client's personal data, mobile phone number. This set of documents was
required while transferring funds from the customer in cash. When transferring funds in non - cash form, the package
of documents was expanded, additionally requested the source of origin of funds and documents confirming their
origin, a notarised copy of a foreign passport and its translation, the law firm's characteristic of the client's reliability.
Aferwards, Ekaterina Marciniuk prepared contracts, which she sent to the email account of the responsible financial
479
advisor, a copy of which she duplicated to the manager, and the originals of the signed documents from QBF and QB
Capital were sent by post. Since July 2017, the contracts for QBIF LLC were signed by him (D.I. Rykov) in accordance
with the power of attorney issued to him by the General Director of QBIF LLC, Stanislav Anatolievich Matyukhin.
According to A.S. Golubev and V.S. Pakhomov, the increased volume of documents for non - cash payments was
explained by the fact that it was a requirement of the Russian bank when the client sends money to the accounts of
foreign companies. Sometimes, afer the clients had provided all the necessary documents, problems could arise,
banks requested additional documents on transfers of funds to other details, namely other jurisdictions where the
company's account was located. Afer a client's request to withdraw funds from QBF and QB Capital LLC, a similar
package of documents with up - to - date data was requested, in case of clients' requests to transfer funds by cashless
transfer, the company requested an extended package of documents: namely, documents of origin of funds with
translation into English, certificate of presence/absence of criminal record, lawyers' characterisation of
trustworthiness, KYC, copies of Russian and foreign passports with notary certification. In his opinion and the opinion
of his employees, this list of documents was artificially invented to lengthen the terms of withdrawal of funds and
complicate the procedure for clients to receive their money. He (D.I. Rykov) and his employees repeatedly expressed
to V.S. Pakhomov and A.S. Golubev the clients' dissatisfaction on this matter. Afer receiving cash from clients,
Pakhomov V.S. or Golubev A.S. personally organised the arrival of a regional office employee or an employee from
Moscow to collect the cash. For this purpose, V.S. Pakhomov or A.S. Golubev would drop contact details of the
employee who would come to collect the money. During his employment, the following persons came to collect
money: Yuri Orlov, Alexei Golubev, Vladimir Pakhomov, Maxim Fedorov, Vladimir Maslennikov, and these persons
came systematically. He also explained that during his working career there were cases of payment of funds to
previously invested clients at the expense of funds received from new clients, A.S. Golubev made decisions on this,
and this order was given by Yekaterina Martsinyuk, motivated by optimisation of logistics costs of employees
transporting funds. There were such cases in 2018, in fact, the funds transferred to the new attracted client were not
encashed to Moscow for deposit to the settlement account of "QB Capital", but were given to the old clients as
dividend payments. He (D.I. Rykov) repeatedly told Alexey Golubev and Ekaterina Martsinyuk about the
unacceptability of these actions in the future, the representatives of the Tyumen branch refused to carry out these
manipulations. Also, once, on the instructions of Martsinyuk Ekaterina, he (Rykov D.I.) was supposed to make a salary
payment to the Tyumen branch at the expense of funds received from the client, but he refused. Therefore the
following scheme of salary payments was invented: he sent by mail an additional debit card of the bank PJSC "VTB" to
which the employer represented by Alexey Golubev through his assistant Ekaterina Martsinyuk transferred monthly
salary to the whole Tyumen branch, so in fact he did not know the origin of the money. On 30.03.2020 he wrote an e -
mail to Pakhomov V.S. and Golubev A.S. with a motivated judgement that it was impossible to continue working with
the company QBF LLC. This reasoned judgement related to its reputation risks and risks of its employees, systematic
delay in fulfilling obligations to clients, for a period of about half a year, on the fact of return of funds taken in trust
management. Since the beginning of 2019, the amounts of refunds on the obligations to clients have decreased and
were split into small parts, given to those clients who strongly resented and could appeal to law enforcement
authorities. These decisions on payments were made by Golubev A.S. His (Rykov D.I.) family represented by his
grandfather Melnikov Vladimir Pavlovich (academician of the Russian Academy of Sciences) invested USD 750,000,
and USD 170,000 was returned to him. Partial repayment of the amount of USD 40,000 was made afer a personal
meeting with Shpakov R.V. in the office of the city of. Moscow in September 2020. The meeting was initiated by him
(D.I. Rykov) in order to get answers from the main shareholder of the QBF Group of Companies on the fact of delays
and failure to make payments to large clients in Tyumen and Surgut;
(Vol. No. 268, pp. 117 - 121)
480
Ryazanov S.A.'s Testimony
as a witness, according to which in February 2020 his acquaintance Boldyrev Vladimir offered him (Ryazanov S.A.) a
job at QBF. He accepted the offer and at the appointed time came for an interview at the following address: 8
Presnenskaya Embankment, Moscow, building "Capital City", business centre "Moscow City", which was held in
several stages. One of the representatives of QBF who conducted the interview was the head of the international sales
department, where he (Ryazanov S.A.) was hired around 17 - 18 February 2020 as a junior financial advisor at K -
Investment LLC. Afer about a month of his work, the international sales department was disbanded and all
employees, except for the head of the department, were transferred to the sales department in the domestic market.
Later on, a sales department appeared, which included several sales departments, with each department having its
own head. He remembers some of the heads of sales departments, such as: Ara Balayan, Javid Isayev, Artem Tallerov,
Bella. Also an independent employee of the sales department was Maxim Fedorov, the vice - president of the
company, who had no financial advisors in his subordination, but sold financial products of the company himself and
reported directly to Ruslan Spinka. His (Ryazanov S.A.) direct supervisor was Ara Balayan, from whom he received
instructions on his work and reported on its results. Ara Balayan was supervised by Korzh Andrei and Spinka Ruslan.
His (Ryazanov S.A.'s) salary was approximately 60,000 roubles per month, plus an additional salary, which included
fixed payments based on the results of plan fulfilment and % of the amount of funds raised. His average salary was
approximately 130,000 to 140,000 roubles. He received his salary in cash from Ara Balayan and did not sign for it on
any statement. His duties as a financial advisor included: searching for and inviting clients, informing clients to sell
investment products and trust management of clients' invested funds, opening brokerage accounts. He sold the
company's following products: IPOs - non - exchange traded assets, repurchase transactions, and Trust Management.
The organisation on whose behalf the financial products were sold was QBroker Ltd. The funds were placed on the
accounts of IK QBF LLC. Clients could be attracted to sell the company's products through cold calls to potential
clients or through social networks via various video bloggers. During the entire period of his employment with K -
Investment LLC, he attracted approximately 15 clients and funds totalling approximately RUB 60,000,000. In turn, K -
Investment LLC was part of the QBF group of companies. The office of K - Investment LLC was located at 8
Presnenskaya Naberezhnaya Street, Moscow, Moscow City Business Centre, Capital City building. The main activity of
QBIF Group was attracting clients for the sale of investment products and trust management of funds invested by
clients. The Head of QBF Group of Companies was Roman Valeryevich Shpakov. Roman Shpakov's business partner
was Munaev Zelimkhan. Shpakov was directly subordinated to Spinka Ruslan, and Spinka Ruslan was subordinated to
Korzh Andrey. Spinka reported directly to Roman Shpakov about all the activities of the sales department. He began
to have doubts about the legality of the actions of the above - mentioned management of the QBF Group of
Companies afer law enforcement officers conducted investigative actions in the offices of the QBF Group of
Companies in December 2020. According to Ara Balayan there was no cause for concern and the investigative actions
taking place in the offices of the company are the intrigues of competitors who are trying to paralyse the activities of
QBF Group of Companies. He also asked Ara Balayan about the necessity of withdrawal of funds by clients, as there
are many of his (Ryazanov S.A.) acquaintances among the clients, in order to minimise the possibility of causing
damage to them. Balayan assured him that there were no reasons for emergency withdrawal of funds and in case of
such a situation the clients, who were his (Ryazanov S.A.) acquaintances, would have the opportunity to withdraw
their invested funds as a priority. In addition, Korzh Andrey organised a meeting with the participation of Ara Balayan
and financial advisors, at which he (Korzh A.) said that there is no need to worry because soon the company's
activities will be restored and those who remain in the company despite the existing difficulties will be guaranteed
career growth and financial incentives. The investigative actions carried out in the company "QBF" confirmed his
(Ryazanov S.A.) doubts about the legality of the actions of the management of the company "QBF", namely on the
following grounds: many customers complained about the low information content of the mobile application "QBF"
to track the movement of the financial status and balance of their accounts, placed on the resources of "QBF" under
the contract. Thus, the client could not fully independently dispose of their assets and funds. Also he could not see
the actual amount of funds on his balance. QBF's management deliberately did not provide customers with detailed
and complete information on their accounts, as the customer's funds may no longer be in the accounts to which they
should have been deposited under the contract concluded with QBF. In approximately December 2020, QBF
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management had a need to provide QBF's account statements reflecting QBF's then current assets. QBF management
provided the required statement in the form of a photograph posted on QBF's work chat room, however, said
statement did not contain complete information, but only an introductory portion, as the basic information was
covered by a sheet of white paper. QBF management deliberately concealed important information about the
company's assets from the company's employees and the company's customers. The head of QBF company Shpakov
Roman, afer the clients of the company could not withdraw their invested funds, did not address the clients of the
company in order to try to explain the reasons for these events. Apparently, Shpakov Roman wanted to make the
company's employees, of all categories, guilty of causing damage to citizens, and to protect himself from negative
comments from clients, since according to available information Shpakov Roman was already outside the Russian
Federation at the time of the searches. Afer people could no longer withdraw their invested funds, the management
of QBF began to offer clients, in order to preserve the capital invested by clients mainly in the financial product "IPO",
to become a participant in the mutual fund "RIF" in the amount that they had invested in other financial products of
the company. He (S.A. Ryazanov) believes that the mutual fund "RIF" as well as the product "IPO" were fictitious
products of the company, because if the mutual fund "RIF" was real, the management of the company "QBF" could
have sold the available units and repaid the resulting debt to the clients of the company, but such actions were not
taken. A similar situation as with RIF UIF occurred with the participation of clients in the construction of the
residential complex "Gribovsky les", which the management of QBF did not sell in order to repay the existing debt to
clients. He (S.A. Ryazanov) believes that the company's management offered clients to contribute money to this
project, realising that they would no longer be able to fulfil their obligations to clients. He (Ryazanov S.A.) worked in
"K - Investment" LLC until approximately June 2021, afer which he resigned at his own request because the company
began to "fall apart" and delays in payment of wages began;
(Vol. No. 268, pp. 122 - 126)
Samoilov V.R.'s testimony , given by him as a witness,

according to which, around 2019, his acquaintance Valeria Gubanova invited him to work at the QBF Group of
Companies in the human resources department. In the office located at the address: Moscow, Presnenskaya
Naberezhnaya 8, building "Capital City" of the business centre "Moscow City" he had an interview, during which he
was offered the position of deputy head of the HR department. In January 2019, he became an employee of F -
Management LLC with a salary of approximately RUB 60,000. He received his salary in cash from the receptionists or
from the head of his department. He did not sign for the money received anywhere. QBF LLC was part of the QBF
group of companies. The office of QBF LLC was located at 8 Presnenskaya Naberezhnaya Street, Moscow, Moscow City
business centre, Capital City building. The principal activity of QBF Group was to attract clients for the sale of
investment products and trust management of funds invested by clients. Roman Valeryevich Shpakov was the head of
QBF Group of Companies. His (V.R. Samoilov) direct supervisor was Valeria Gubanova, from whom he received work
instructions and reported on the results of his work. His duties as deputy head of the department included:
recruitment, search for candidates, checking candidates' references, preliminary interviews with candidates for
various positions, but mainly in the sales department of LLC "K - Investment", part of the group of companies "QBF".
Afer about 7 - 8 months of his employment in the HR department, namely in July - August 2019, he resigned from the
QBF Group of Companies at his own request due to family reasons. Soon, around November 2019, he again decided to
take up employment with the QBF Group of Companies, but due to the fact that the positions in the HR department
were filled, he was offered the position of Junior Financial Advisor in the Sales Department. He accepted the offered
position and in November 2019, he became a junior financial advisor in the sales department at K - Investment LLC, a
member of the QBF group of companies, with a salary of approximately RUB 22,400, as well as periodic bonuses
depending on the number of products sold by the company. His supervisor in the sales department was Nikolai
Padalko, who afer about three months moved to another position, and instead of Padalko N., Stella Ermolenko was
appointed as his supervisor. His (V.R. Samoilov) duties as a financial advisor included: search and invitation of clients,
482
informing clients for sale of investment products and trust management of invested money of clients, opening of
brokerage accounts. His workplace was located in the main office of QBF in the Moscow City Business Centre. He
worked at K - Investment LLC until approximately July 2021, and resigned at his own request because his salary began
to be delayed in 2021. During his employment with QBF, he had to interact with various of its employees, some of
whom he remembers, namely: Tural Godirli - trader, asset management on the international market; Avetis Vartanov -
personnel training instructor; Vladimir Maslennikov - worked for a long time in the company in the sales department,
conducted training of employees; Stanislav Anatolievich Matyukhin - General Director of LLC IC QBF, part of the QBF
group of companies; Spinka Ruslan - Deputy Head of Department at Padalko Nikolay; Lepeshkin Dmitry - worked in
the company; Arzhaev Alexander - worked in IT direction; Padalko Nikolay - Head of Sales Department; Vlasov Pavel -
worked in QBF; Yudin Maxim - was Director of Sales Department; Marina Nikolaeva - worked in BEK Office; Christina
Bogdanova - worked in the company; Linda Athanasiadou - worked in the international market, ofen worked with
Dmitry Lepeshkin; Andrey Korzh - head of one of the departments; Evgeny Mikhalevich - was a representative of the
security service of QBF group of companies; Yuri Orlov - employee of IT department, and later head of QBroker Ltd;
Artem Tallerov - head of one of the sales departments; Grigor Erzikyan - worked in the sales department; Rinat
Amerov - engaged in the development of the regional network; Daria Meshkova - financial advisor; Yulia Zaitseva -
financial advisor and later head of the remote client network; Alexey Golubev - one of the heads of the branch in St.
Petersburg; Vladimir Pakhomov - one of the heads of the branch in St. Petersburg; Vladimir Pakhomov - one of the
heads of the branch in St. Petersburg. St. Petersburg; Vladimir Pakhomov - one of the partners of R.V. Shpakov,
Vladimir Pakhomov - one of R.V. Shpakov's partners, was one of the heads of the St. Petersburg branch. Yevgeniya
Rossieva - lawyer of QBF Group; Yuri Shaban - head of real estate activities of the ZPIF; Ekaterina Kharina - worked in
the company; Oleg Timokhin - worked in the company; Zelimkhan Munaev - one of the main managers of QBF Group,
business partner of Roman Valeryevich Shpakov; Roman Valeryevich Shpakov - one of the main managers of QBF
Group; Roman Valeryevich Shpakov - one of the main managers of QBF Group;
(Vol. No. 268, pp. 128 - 132)
- D. A. Serov's Testimony
given as a witness, according to which he worked as a junior advisor at K - Investment LLC during the period from
December 2020 to May 2021. His job responsibilities included client support. All of the employees worked at QBIF LLC,
but were employed formally through K - Investment LLC. He was employed in this company through his acquaintance
Eldar Ibragimov, who at that time was already working in K - Investment LLC. Since he (Serov D.A.) had previously
been trading independently via the Finam and BKS platforms from 2018 to December 2020, he became interested in
trying to work at QBIF. At the beginning of December 2020, he was invited to an interview at K - Investment LLC with
Anton Shkrut, Head of Department. The interview took place in the office at 8 Presnenskaya Naberezhnaya
Embankment, bldg. 1, 9th floor of Moscow City, Moscow. During the interview Anton Shkrut informed that the
company QBIF LLC is a promising company, licensed by the Central Bank of Russia. He (Serov D.A.) agreed to be
employed, but was told that he would be employed by K - Investment LLC and would have to undergo another
interview with the head of the office, Ruslan Spink. Approximately one week later, he had a second interview, also at
the office located at 8 Presnenskaya Naberezhnaya Street, Bldg. 1, 9th floor, Moscow City, where he met with Ruslan
Spinka, the head of the office. Afer the second stage of the interview, he (Serov D.A.) filled out the necessary
documents for employment. One of the reasons he agreed to be employed by the company was that the company
was participating in an IPO. The department he worked in had a total of seven people for the entire period. The office
included Ibragimov Eldar, Anelia Montes, Shayda Vladislav, Mishin Andrey, Zaitseva Yulia, and a man named Abbas. He
(Serov D.A.) subsequently moved to the client support department. Zaitseva Yulia was engaged in attracting partners
who referred clients to QBIF LLC. In addition to the above persons, Padalko Nikolay also worked in the department
and managed the offshore and cash assets of the company. He (Serov D.A.) did not communicate with the others,
although they were all in a common office. Subsequently, afer the searches, he (Serov D.A.) learnt that Padalko
483
Nikolai was allegedly involved in the transfer of funds from QBIF LLC to QBroker LLC and made transfers of funds to
international companies such as WhiteLake. During his employment and the first month of work, he (Serov D.A.) saw
Roman Shpakov many times, who at that time was always in the office. Afer the New Year holidays in January 2021
he did not see Shpakov R.V. anymore. Throughout the time of his work he saw the director of QBIF LLC, Stanislav
Anatolievich Matyukhin. In the course of his (Serov D.A.) labour activity, clients contacted him and informed him that
they wanted to participate in the IPO. As a junior financial advisor he advised the client and informed him that it was
necessary to send the documents to the e - mail [email protected] (which is assigned to a particular financial
advisor), namely a copy of the passport of a citizen of the Russian Federation, SNILS. Subsequently, he logged into the
Nabix programme, where he created a client account. The "middle office" then prepared a package of documents and
sent it by e - mail to the client. The contract on the part of the company was signed with the electronic signature of
the director. Then the client confirmed that he was a qualified investor and sent him (Serov D.A.) the information, and
he (Serov D.A.) in turn sent the data to the "middle office". The client himself chose in which currency he would
transfer funds to the current account. In this connection, the current account was opened in currency or in roubles.
Then, on his (D.A. Serov's) advice, the client deposited a minimum amount of $10,000 or 700,000 roubles into NSD's
current account. He (D.A. Serov) advised the client to minimise its risks. However, each client subsequently funded his
current account with different amounts. In total, he had approximately 8 clients during his entire time with this
company. The total amount of clients' funds raised was approximately 22,000,000 roubles. The presentation of the
"Option Agreement" and the mechanism of this agreement was handled by Isaev Javid, who was in charge of the IPO
in the company. During the whole time he (Serov D.A.) was only at one presentation (class) on IPO, as Isayev Javid
seemed to him not quite experienced in the issue of IPO. At the same time he (Serov D.A.) communicated with Isayev
Javid only once, when he asked Isayev D. for advice, naming the name of the company and asking what percentage of
allocation will be. In response, Isayev Javid gave an approximate percentage of allocation of the company. Having
heard this answer, he (Serov D.A.) concluded that Isayev Javid was not quite competent in this matter. The second
party to the contract was always the top broker, its name was not disclosed, because according to Anton Shkrut, it
could harm the company, explaining that other companies may find out about him and start working with him. Afer
the company was searched in May 2021, he (Serov D.A.) decided to find out where the clients, including him,
transferred their funds. So during the search of the Internet information he realised that the funds were used for the
purchase of real estate. For example, Roman Shpakov owned the Gribovsky les LCD, as well as other immovable
property. This property belonged to Korzh A., Tallerov A., Spinka R., Vartanov A., and others. Having seen this
information, he realised that the money was not used to purchase shares in the companies. The process of calculating
allocation was as follows. On the day of the company's IPO at about 10 p.m., information about the percentage of
allocation was received in the chat room of the QBF group from Korzh Andrei. A few days before the IPO he (Serov
D.A.) received information on companies, which he studied, analysed and made his approximate percentage of
allocation of this company. Afer the information on the company's allocation to the IPO came from Korzh A. and if
this information seemed doubtful to him (Serov D.A.), he warned his clients not to participate in the IPO. At the same
time, he also concluded that the allocation information provided by Korzh A. was not quite correct and doubtful.
Around 03.06.2021 or 04.06.2021 he (Serov D.A.) was in the office, where he was assisting clients with refunds. Anton
Shkruti approached him and suggested that he (D.A. Serov), V. Shayda and Abbas go outside to have a conversation.
During the conversation Shkrut A. told them that the company "QBF" was a pyramid scheme, that the money would
not be returned and that everyone should resign. A woman was present during this conversation and she also
confirmed this fact. Thus, he (Serov D.A.) realised that it was a fraudulent scheme aimed at stealing clients' money;
(Vol. No. 268, pp. 134 - 138)
- A.V. Sidorova's Testimony given to her as a witness,

according to which she was employed in 2016 at QBF Advisery LLC as a leading financial advisor, her direct supervisor
was Aslan Daev, who was in the position of head of the sales department. Daev Aslan was her supervisor until mid -
484
2017, then her supervisor was Korzh Andrey, who took the position of Head of Sales. Yudin Maxim was the head of the
sales department from 2017 to January 2019. The structure of the sales department included 4 sales departments,
where in the time period from 2017 to 2019 the heads were Spinka Ruslan Valeryevich, Korzh Andrey Viktorovich,
Padalko Nikolay, Shkrut Anton. She was employed as a financial advisor until January 2018. Her duties included
advising clients on the company's products, initial engagement, and prior to the establishment of the support
department. She accompanied clients on counselling and current portfolio status. From January 2018, she was
promoted to the position of Deputy Head of Sales. At that time, the Head of Sales was also Korzh Andrey. In August
2018, Vladimir Sergeyevich Pakhomov was appointed Head of the Moscow Branch, whose responsibilities included
general management of the sales department. In 2016, Andrey Korzh and Aslan Daev presented a scheme to attract
clients' funds to the foreign company QB Capital, the mechanism and scheme of interaction between the companies
was explained to her by Avetis Vartanov. So initially the client signed a trust management agreement with QBIF LLC
and an agreement on direct access to the securities market with QB Capital, and also attached an investment
declaration. In accordance with these agreements, the client could transfer funds in non - cash form to the QB Capital
account through two jurisdictions, namely through a current account opened with a bank in Armenia, or through a
current account opened with a bank in Vanuatu. The client could also deposit funds in cash. The funds were accepted
in the office of QB Capital LLC on the 8th floor, and in return the client was presented with a cash receipt with the QB
Capital stamp and the signature of Elena Gorobets. She (A.V. Sidorova) never saw Elena Gorobets, and the payment
documents were prepared by Marina Savvidi. Further, according to Kord Andrei, these funds were transferred from QB
Capital settlement accounts to brokerage accounts opened with IB. When making a payment, the client was asked for:
Russian passport, foreign passport, bank statement, simplified KYC form. The schemes of signing agreements
between clients and QCCI LTD were as follows: the client signed a trust management agreement with QCCI LTD and an
agreement on direct access to the securities market with QCCI LTD, as well as an investment declaration. Client funds
were also accepted in both non - cash and cash in the name of QCCI. Around the end of 2017 changed the Russian
counterparty side to QCCI Investment LTD. In 2018 with new clients started signing agreements with a foreign
company White Lake and "Simtelligence". By agreement, the agreements on behalf of QBF Advisery LLC and QBF
Investment LLC were signed by Munaev Zelimkhan Visaitovich and Yudin Maxim. Cash payments were made both in
non - cash and cash form. If the client received funds in cash, the client signed a confirmation of receipt of funds.
Vladislav Plitinh was in charge of client withdrawal support. V. Plitinh communicated with clients, he had a register of
client withdrawals, which reflected the terms and amounts of funds submitted for withdrawal. She knows that
initially the money was paid to clients not according to the order and terms, but according to the persistence of
clients, namely, if the client did not agree to wait voluntarily for withdrawal, began to threaten to report to the police
or other supervisory authorities, then this client in order to avoid possible consequences, the money was paid to this
client. Yudin Maksim, Plitin Vladislav and Munaev Zelimkhan were engaged in the collection of funds from the safe.
Until mid - 2017 Andrey Korzh, Yudin Maxim, Vartanov Avetis convinced her that QB Capital had a licence to carry out
brokerage activities and that these activities were controlled by the Kiprovsky regulator. Approximately since May
2017, the scheme of attracting funds and foreign office representing direct access to the securities market has
changed (became QCCI LTD). From the words of Yudin Maxim, she learnt that the reason for the change of
counterparty was due to improper client processing. In January 2019, she resigned due to a conflict with Pakhomov
V.S., as well as due to increasing delays in withdrawing funds to clients. The reasons for the delays in withdrawals
were explained to her by Plitinj Vladislav, who said that the delays were due to poor communication between the
foreign partner QCCI LTD and Russian banks. She was aware of a case when a client Burkova Tatiana Mikhailovna was
provided with a false SWIFT (payment confirmation) by Plitin Vladislav, but the payment was not credited to the
client's account. Afer her dismissal, she was approached by clients whom she had previously attracted with a
problem of withdrawal of funds. She asked Korzh Andrei, Plitinj Vladislav and Spinka Ruslan about the non - payment
of funds to the clients and when they would be paid, to which the above mentioned persons delayed the payment
terms by promises. She explained to Andrey Korzh that she would announce the situation on the "Banki.ru" portal.
Afer that Andrei Korzh persuaded her to meet with him and at the meeting offered to solve the issue peacefully and
not to announce the situation for a monetary reward. The specific amount he did not name. She replied that the funds
should be returned to the clients. The clients never received their funds back and she provided information about the
failure to return the funds to the investors to the Banki.ru correspondent;
485
(Vol. No. 268, pp. 143 - 147)
- Ya.G. Smirnova's Testimony

given to her as a witness, according to which she carried out her employment in QBG Asset Management LLC from
August 2014 to 26 January 2018 as a back office manager, and from 26 January 2018 as a general director. Until 2017,
the CEO of the company was Vladimir Georgievich Frolov, who was a nominal manager and did not fulfil the duties of
the CEO. The actual management of LLC QBF Asset Management was performed by Nikolay Valeryevich Mikhailov. In
the period from July 2017 to early 2018, S.A. Matyukhin was the CEO of the Company, combining his position with the
CEO of LLC IC QBF. The decision to appoint general directors in the Company has always been made by R.V. Shpakov.
In addition, from early 2016 to January 2018, she combined the position of Deputy General Director of PJSC "CEF". Her
duties as the head of the back office included: accounting, preparation of reports on mutual funds, reception of
clients, execution of applications, document flow on mutual funds. Her job duties as General Director of QBF Asset
Management LLC included: control over the implementation and execution of financial and economic activities,
control over compliance of activities with legislation, search, analysis and selection of counterparties. The company
has 9 ZPIFs, 2 of which were client funds and 4 OPIFs. The first ZPIF was QBIF Real Estate. The assets of the fund
property include CDA in the Gribovsky les Residential Complex, these are 19 flats in the residential complex, which
were purchased from the developer Simon Jesso LLC, for approximately 100,000,000 roubles in 2016. Land plots in
the village Lipunikha, Odintsovsky district, the owner of the land was LLC Nizhnee and later renamed to LLC Finbutik -
its shareholder. This land was later changed through numerous contractual transactions to 51 plots of agricultural
land in the Vladimir region, where the owner was OOO Ledokol and several individuals, as well as receivables from
OOO Profi for approximately 50,000,000 roubles. The entire fund was divided into 6,000 units with a total value of RUB
300,000,000. Approximately 4,000 units were transferred to Finbutik LLC, for which land he was a member of the fund.
Finbutik sold its units to QB Capital (Cyprus) and later bought them back. Thereafer, Finbutik placed its units in the
depository accounts of QB Capital LLC. The actual beneficiary of Finbutik LLC was Shpakov R.V. The remaining 2,000
units were sold to individuals. The remaining flats of the Gribovsky les Residential Complex belong to the developer
Simon Jesso LLC, except for those sold to individuals under CDA. The land plot on which the LCD was built is also
owned by Simon Jesso LLC. The founders of OOO Simon Jesso were R.V. Shpakov and V.E. Arsenchuk. V.E. Arsenchuk
is the father of N.V. Mikhailov. The assets included property rights from the Contract of Arrangement for 11 flats in the
housing estate "Victory Quarter" located at 15 Parkovaya Street, Severodvinsk, with a total value of approximately
RUB 52,000,000. The remaining flats belong to the developer OOO Severspetsstroy. The actual beneficiary of the
developer is R.V. Shpakov. The third ZPIF was called QBIF Development of Regions. The assets consisted of property
rights from the concluded contracts for 17 flats in the housing estate "Victory Quarter" located at the address:
Severodvinsk, Parkovaya Street, with the total value of approximately 59,000,000 roubles. The remaining flats are
owned by the developers LLC KP Queue 2 and LLC KP Queue 3. The actual beneficiary of the developers is R.V.
Shpakov. The fourth ZPIF was called QBIF Development of Regions. The assets included property rights from the
concluded contracts for 21 flats in the housing estate "Victory Quarter" located at the address: Severodvinsk,
Parkovaya St., with the total value of approximately RUB 59,000,000. The remaining flats are owned by the developers
LLC KP Queue 3 and LLC KP Queue 4. The actual beneficiary of the developers was R.V. Shpakov. The fifh ZPIF was
named "Time of New Values". Around 2017, the First Deputy Chairman of the Board of JSC "QBF Financial Group"
Rutiņš Rimma and Shpakov Roman instructed her (Smirnova Y.G.) to form a closed - end unit investment combined
fund related to art works. It took Rutiņš Rimma about 2 years to study this direction. Around the summer of 2018 she
(Smirnova Y.G.) started to form the fund. In about half a year, thanks to the work of financial advisors of QBF, 5
investors were attracted and purchased units of the fund. The units were purchased by Yushkevicius Henrikas -
Algirdas Zigmo - 4 units, Oksana Bukharova - 6 units, Ilshat Fargatovich Talipov - 3 units, Olga Vladimirovna Melikhova
- 4 units, Mikhail Vladimirovich Ivanov - 5 units. The value of one unit was approximately just over 500,000 rubles. Igor
Konstantinovich Gurevich joined the fund with shares of JSC "CEF" in the amount of 35 units. I.K. Gurevich was a
486
financial advisor of the QBF Group. On the instruction of R.V. Shpakov I.K. Gurevich entered this fund with the purpose
of its additional formation. At the time when the fund was fully formed, she (Smirnova Y.G.) informed Shpakov R.V.
about it, but Shpakov R.V. informed her that he had dismissed Rutins Rimma. In this connection she (Smirnova Y.G.)
suggested to Shpakov R.V. to close the fund and distribute their money back to the shareholders. Shpakov R.V. forbade
her to do so, informing her that he himself would deal with the fund and the search for paintings. About a few months
later Shpakov R.V. informed her that he had found the paintings, he also gave her an e - mail address, explaining that
this person would deal with the issues of the ZPIF "Time of New Values" together with her. Who this person was, she
does not know. From this person she began to receive photos of paintings by the artist Yurlov Valery Ivanovich, born in
1932, there were more than 50 photos. She began to look for appraisers, storage places for the paintings, insurers, to
agree on the necessary conditions between all the parties mentioned. These actions took several months. Shpakov
R.V. explained to her that for the earlier rendered help to the community of artists, he (Shpakov R.V.) was given free of
charge the paintings of the artist Yurlova V.I., but these paintings he would give to Bakhtiarova I.S., and already from
Bakhtiarova Irina Sergeevna under the contract of sale the fund will have to buy paintings of Yurlova V.I. With Shpakov
R.V. and the fund the contract could not be concluded, due to the fact that Shpakov R.V. is the beneficiary of LLC "MC
QBF" and besides he did not want to appear in any documents. In this regard, a contract was drawn up with
Bakhtiarova on 14.08.2019 with a description of the paintings attached. The additional agreements to it were re -
signed several times, in which the delivery dates of the paintings themselves were changed. At one signing of the
additional agreement she (Smirnova Y.G.) was personally present and saw Bakhtiarova. According to the contract
Bakhtiarova I.S. was to transfer the paintings to Yurlova V.I. according to the list of the supplementary agreement in
the amount of 26 pieces. On 15.08.2019 the payment of 10,314,346 roubles for the paintings of Yurlova V.I. was
transferred to the account of Bakhtiarova I.S. in Sberbank. These funds were further transferred to Shpakov R.V. Afer
several months, approximately in the summer of 2020, she (Smirnova Y.G.) informed Shpakov R.V. that the ZPIF was
ready to accept V.I. Yurlov's paintings and start exhibiting them. Since the mentioned period Shpakov R.V. did not
provide the paintings, in fact she never saw the paintings of Yurlov V.I.. As the official seller of the paintings of Yurlova
V.I. - Bakhtiarova I.S., she (Smirnova Y.G.) repeatedly sent notifications to the address of registration about readiness
to accept the paintings, but Bakhtiarova I.S. did not contact her. In some e - mails, the e - mail address of which she
(Smirnova Y.G.) had been given earlier by Shpakov R.V. to receive help on the ZPIF "Time of New Values" at the end of
the text sometimes had a signature - "Margo". From that moment she began to realise that she was corresponding
with Gorsheneva Margarita Sergeevna. In the end she received pictures of paintings by Yurlov V.I. from Gorsheneva
M.S., consultations and correspondence on this ZPIF, on the issue of valuation of paintings, insurance and storage
were also conducted with Gorsheneva. The sixth ZPIF was called "RIF Warehouse Federal 1". The assets included
commercial real estate objects - a warehouse complex in the Raevskaya station in the Krasnodar Territory and the
land under it with a total value of over 300,000,000 roubles. The sole shareholder of Logopark Raevskoye LLC entered
the fund with its real estate, these warehouses, and was presented with 100% of shares in the amount of
approximately 1,400 units, which were sold in full to RIF JSC or Q-BROKER LLC. At present, RIF JSC or Q-BROKER Ltd.
holds 727 units, the remaining units have been purchased by individuals, of which there are approximately 40
persons. The beneficiary of Q-BROKER LLC was R.V. Shpakov, and all actions that were connected with the
abbreviation RIF (rent investment fund) are necessarily coordinated with R.V. Shpakov and Y.V. Shaban. At present the
warehouses belong to the fund, and the fund assets belong to the shareholders. The seventh ZPIF was called "Mixed
Federal First Quall". The assets included commercial property - a small shopping centre in Zelenograd and the land
under it with a total value of about 500,000,000 roubles. LLC QBF Asset Management paid its clients quarterly income
on the units of the real estate ZPIF "Reef Mixed Federal 1" and exclusively in non - cash form. The only shareholder is
Q-BROKER LLC, which entered the fund with the specified real estate. The shopping centre in Zelenograd and the land
under it belong to Q-BROKER LLC by right of ownership. The registrar of all units of the ZPIF is JSC "United Specialised
Depository" INN 7723811155. QB Capital was a shareholder in one of the mutual funds managed by QBF Asset
Management LLC. QB Capital purchased investment units of QBF Real Estate ZPIF on the secondary market. Irina
Shpakova was in charge of the construction of the housing estate "Pobedy Quarter" in Severodvinsk. A number of
companies belonging to the QBF group of companies own part of the units of the funds investing in construction. The
construction of the Gribovsky Les housing estate in Odintsovsky district was also managed by Irina Shpakova. Part of
the units of the funds investing in the construction are owned by a number of companies belonging to the QB&EF
487
group of companies, including K.S. Sobolev and Z.V. Munayev. All rights to part of the units invested in the
construction of the housing estate "Victory Quarter" were acquired for cash. K.S. Sobolev owns part of the units in the
interests of another person, Z.V. Munaev acquired them for his own money. The General Director and employees of
QBIF LLC rented premises at 12 Presnenskaya Naberezhnaya St., Moscow, floor 22, office 2210. This address was used
for the cancellation of contracts with clients, as well as for the transfer of assets to other brokers. As for the
complaining clients, if they contacted QBF Asset Management Ltd directly, she first of all checked whether she had
such a client, and if so, she negotiated with him independently. If there was a client of a third - party organisation, she
gave him the e - mail address of the said organisation. In the course of her labour activity she encountered the
following employees: Spinka R.V. - Spinka R.V. was the head of the sales department; Padalko N.S. was in charge of the
Cyprus direction; Orlov Y.N. was the general director of QBroker; Amerov R.F. was in charge of projects - banks,
insurance companies, etc. - managed projects - banks, insurance companies, QBroker and Marketplace; Plitin V.V. -
financial advisor; A.V. Korzh - engaged in sales; Y.S. Zaitseva - financial advisor; V.G. Frolov - General Director of "F -
Technology"; V.S. Pakhomov - Head of regional offices; M.S. Yudin - Operations Director in charge of IT; R.V. Shpakov -
Chief Operating Officer of "QBroker"; R.V. Shpakov - Director of "QBroker". - beneficiary of QBF Group; Z.V. Munayev -
Managing Partner; S.A. Matyukhin - General Director of QBF; E.A. Rossieva - Head of Legal Department; E.V. Gorobets. -
E.V. Gorobets, formerly General Director of QB Group; D.S. Lepeshkin, formerly engaged in construction in
Severodvinsk and Odintsovo; Athanasiadou Linda , supervised the Cyprus direction, she always reported on her
activities to R.V. Shpakov; P.Y. Vlasov, Vice - President, was in charge of investment sales. - Vice - President, engaged in
sales of the group's investment products; K.S. Sobolev - middle level sales manager, at one time he headed the office
in Ekaterinburg; A.S. Golubev - head of the office in St. Petersburg; Y.V. Shaban - RIF project manager; E.N. Kharina -
creator of ideas for investment products; A.S. Golubev - head of the office in St. Petersburg; A.S. Golubev - head of the
office in St. Petersburg; Y.V. Shaban - head of the RIF project; E.N. Kharina - head of the RIF project. - Creator of ideas
for investment products; Timokhin O.Y. - Head of the back office at QBIF LLC;
(Vol. No. 268, pp. 148 - 159, 161 - 164, 165 - 168, 181 - 183)
R.V. Spinka's Testimony as a witness,

according to which afer graduating from university, between August 2013 and January 2014, he worked as an
operative commissioner of the OEB and PC of the MIA of Russia "Pushkinskoe" of the Moscow region. Afer leaving the
service, he posted his CV on the website "hh.ru" in search of work for the positions of Commercial Property Specialist
and Financial Analyst. In April - May 2014, he interviewed at QB Finance LLC for the position of Junior Financial
Advisor and went out for an internship, by the end of the year he was employed as a Financial Advisor at QB Finance
LLC. He remained with the company until approximately 2017 - 2018, afer which he worked at QBF Advisors LLC as a
deputy department manager. In early 2019, he was employed as a department manager at K - Investment LLC. A
couple of months later, he was employed at QBeef Investment Company LLC, where he worked for a few months
before returning to K - Investment LLC. During his time as a financial advisor his professional task was to advise
potential and current clients on investment products such as: brokerage services, trust management, mutual funds
(open and closed), residential property investments, individual investment accounts. If the client was interested, he
helped to complete the procedure of registration of the relevant investment product. During his tenure as Deputy
Head of the Sales Department and Head of the Sales Department, he was engaged in general management of the
department, which in turn was engaged in advising potential and current clients on investment products such as:
brokerage services, trust management, mutual funds (open and closed), residential property investments, individual
investment accounts;
(Vol. No. 268, pp. 186 - 189)
488
- The testimony of Sukhanov E.O., given by him as a witness,
according to which approximately in May - June 2019, his acquaintance Alexander Rybarchuk invited him to work in
the company QBF for the position of system administrator. At the appointed time, he (E.O. Sukhanov) came to the
interview, which was conducted with him by the "hr" specialist Svetlana, as well as Yuri Orlov, who at that time was
the acting head of the IT Department of the company "QBF". The interview took place at the following address: 8
Presnenskaya Naberezhnaya Embankment, Moscow, Capital City building of the Moscow City business centre. In May -
June 2019, he was hired as a system administrator in an organisation that was part of the QBF group of companies,
and later transferred to F - Technologies LLC, but the job functions, supervisor and team remained the same. His
responsibilities included creating a computer - based user workstation for QBF employees, setting up and
maintaining network equipment. He was not engaged in customer support, this area of activity was assigned to Q -
admin Alexey Stepanov, who was a system administrator for the programme "Qwick". The specified programme was
intended for the clients of the company, where personal accounts of the clients were created and the clients of the
company could track their status and the state of their assets through their personal accounts. His (E.O. Sukhanov)
direct supervisor was Yuri Orlov, from whom he received instructions on his work and also reported on its results. His
(E.O. Sukhanov) salary at different periods of time was approximately 120,000 - 170,000 roubles per month. He
received his wages in cash from Yuri Orlov, and he did not sign any pay slips. F - Technologies LLC was also part of the
QBF group of companies, and its office was located at 8 Presnenskaya Naberezhnaya Street, Moscow, Moscow City
business centre, Capital City building. The principal activity of QBF Group of Companies was attracting clients for the
sale of investment products and trust management of funds invested by clients. The managers of QBF Group of
Companies were Roman Valeryevich Shpakov, Zelimkhan Munaev, Vladimir Pakhomov. Roman Shpakov was the
Chairman of the Board of Directors of QBF. In the course of his labour activity in the group of companies "QBF" he
(Sukhanov E.O.) did not suspect that the management of the company, represented by Shpakov Roman Valerievich,
could carry out fraudulent actions with clients' money, as the company had a number of licenses of the Central Bank
of the Russian Federation to carry out professional activities in the financial sphere. He began to have doubts about
the legality of the actions of the above - mentioned management of the QBF group of companies afer law
enforcement officers conducted investigative actions in December 2020 and May 2021 in the QBF office. He worked for
F - Technology LLC until approximately June - July 2021, at which time he resigned from F - Technology LLC at his own
request due to delays in salary payments. During his employment with QBF, he had to communicate with various
employees of the company, such as: Ekaterina Gramza - worked in the accounting department; Evgenia Rossieva - was
the chief accountant at QBF; Evgeny Gudkov - system administrator, 1C specialist; Tural Godirli - worked in the trading
department; Christina Bogdanova - issued salaries to the heads of departments to be passed on to all employees;
Oleg Timokhin - one of the specialists at QBF IR; Anastasia Koval - one of the managers at QBF IR; Maxim Fedorov, a
sales employee; Nikolay Padalko, the head of one of the company's business lines; Stanislav Matyukhin, the head of IC
QBF LLC, a member of the QBF group of companies; Rinat Amerov, the head of Marketplace; Ara Balayan, the head of
the sales department; Vladimir Maslennikov, the head of the support department; Lyubov Kuranina, the assistant of R.
Shpakov; Olga Baranova, the head of the marketing department; and Olga Baranova, the head of the sales
department.V.; Olga Baranova - Head of Reception; Marina Nikolaeva - Middle Office employee; Maria Kopylova -
Middle Office employee;
(Vol. No. 268, pp. 196 - 199)
- Testimony of Tereshenkova E.V., given to her as a witness,

according to which at the end of 2017 she was employed by QBF Advisor LLC as a financial advisor, where her job
duties included: searching for individuals who were interested in investing money. She solicited individuals to act as
489
investors through personal contacts made at various public events. Within the framework of her official duties, she
provided QBIF trust management products: "Golden Section", which implied trust management of clients' assets
when acquiring shares and bonds issued on the Moscow Exchange, IIS, opening brokerage accounts on the Moscow
Exchange; "My Safe" strategy, which implied investing in corporate bonds and OFZ; "Balanced" strategy, which
implied investing in shares of leading companies on the international market. White Lake Managment" details were
provided for investing in shares of leading companies of the international market. At conclusion of the contract
between the client and "White Lake Managment" this company was engaged in management of the client's funds.
She personally held meetings with potential clients and Ara Balayan was always present at the meetings. The client
was informed of the strategy within the framework of which the management would be carried out. She received
information about White Lake Managment products on the general resource of the company, if she did not
understand something, she asked Ara Balayan for clarification. Sometimes clients gave her orders and explained that
they wanted to terminate the contract with "White Lake Menedgment" and withdraw funds from the management,
but she does not know the results, as she did not follow up the execution of these orders. Her direct mentor was Ara
Balayan and her supervisor above Balayan A. was Anton Shkrut. At the end of 2019, she was offered a promotion to K -
Consulting LLC. At the office of K - Consulting LLC, located on the 9th floor of the Capital City office building of the
Moscow business centre, she was offered the position of project manager at the interview. Her job duties included
searching for legal entities and conducting educational activities with employees, namely seminars on financial
planning, individual investment accounts, improving financial literacy of employees for the employees of the
organisation. On 16 January 2020, she started her work duties. Her workplace was an office in the office of K -
consulting LLC on the 9th floor of the office building. Her immediate supervisor at the time of her employment was
Elena Anatolievna Grabareva, followed by Fedor Vladimirovich Peshko. Her duties at that time included searching for
partner organisations to hold the above - mentioned seminars. These seminars are necessary for the organisation for
educational activities and promotion of programmes with state participation. She herself developed the presentation
of the seminars, which was agreed with her direct supervisor. She searched for partner organisations on her own,
usually at open events and exhibitions. During the seminars she touched upon the following issues: financial
planning, including budget planning for future pensions; individual investment accounts and investment instruments.
During the period of her work she has held seminars with the following organisations: "Peoples' Friendship University
of Russia", "Russian University of Tourism and Service", she does not remember other organisations due to their
significant number. The legal department was in charge of drawing up the contracts. She knows the company QBF
LLC, the general director of this company is Stanislav Anatolievich Matyukhin. This company is engaged in brokerage
services for legal entities and individuals. She found more detailed information on the official website on the Internet,
as well as on the website of the Central Bank of Russia. She heard that QB Capital LTD, "White lake", "SIMTELLIGENCE
COMPANY LIMITED QCCI LTD", "White Lake Management LTD" companies are engaged in investment activities,
securities market. She knows Roman Valeryevich Shpakov, General Director of JSC QB Financial Group, Zelimkhan
Visaitovich Munaev and Evgeniya Anatolievna Rossieva;
(Vol. No. 268, pp. 201 - 204, 211 - 215)
O.Y. Timokhin's Testimony

given as a witness, according to which in 2014 he graduated from the S.Y. Witte Moscow University with a degree in
economics. Simultaneously with his studies, he carried out labour activity in LLC MC Otkritie, which was engaged in
trust management of assets of clients of individuals and legal entities. He worked in this company until August 2017
as a specialist. During this period of time he also worked part - time at LLC MC Nomos - Bank, his work was of a
nominal nature as it was aimed at maintaining the licence requirements of LLC MC Nomos - Bank. In August 2017, he
moved to LLC IC QBF INN 7733673955, as a leading specialist of the department of ensuring support of professional
activities on the securities market. This company was a professional participant of the securities market in
accordance with the licences issued by the Federal Financial Markets Service of Russia. This company carries out
490
brokerage activity and trust management of clients' assets. The essence of brokerage activity is as follows: clients
transfer funds to the company's brokerage accounts for the purpose of further submission of orders for securities
transactions, and the company executes these orders for commission fees. The essence of trust management is the
following: an individual or a legal entity transfers funds to the accounts of a trust manager, afer which the company
at its own discretion, but within the framework of the strategy chosen by the client concludes transactions on the
Exchange. No company or individual without the appropriate licence can purchase securities. Thus, the company IC
QBIF LLC was actually an intermediary between the client and the Exchange and executed transactions for a
commission. The General Director of IC QBF was Stanislav Anatolyevich Matyukhin. A trust management agreement
was concluded with clients on behalf of IC QBF LLC acting as a trustee within the framework of licensed activities. The
main organisation in this company is JSC Financial Group QBF, its owner is Shpakov R.V. From the group of companies
he knows LLC Q.Broker, MC QBF Asset Management. Olga Vasyukova was the chief accountant. The ultimate
beneficiary of QBF LLC was R.V. Shpakov, and Z.V. Munayev was one of the managing partners of the company.
According to his (Timokhin O.Y.) job description, his duties included: managing and organising the work of the
subdivision, developing internal documents within the framework of professional activities, interacting with other
subdivisions of the company within the framework of professional activities, preparing reports for the Bank of Russia,
organising reconciliation of cash and securities balances on clients' accounts, controlling primary documentation,
interacting with trade organisers, exchanges and clearing organisations. He had 9 people under his command. His
supervisor in accordance with his job description was S.A. Matyukhin, his direct supervisor was Anastasia Kovol -
Operations Director. By the nature of his activity he (Timokhin O.Y.) was the person responsible for internal accounting
of the company, he signed reports (trustee and brokerage service reports) sent to clients, also they were signed by the
general director. As part of brokerage services, funds were transferred to special brokerage accounts of QBIF LLC
opened with NSD (National Settlement Depository), Alfa - Bank JSC, and Sberbank of Russia. Further, the funds were
transferred to the Exchange for trading on behalf of the client, or the funds in the bank were used to conclude
transactions on the OTC market on behalf of the client. Within the framework of the activities of QBIF LLC, funds were
not credited to the accounts of non - resident companies. Dividends were paid to clients to special brokerage
accounts, which he indicated when he opened an account with the depository. Payments were made in non - cash
form. The process of withdrawal of funds from brokerage accounts was as follows: the client submitted an order for
withdrawal of funds, specifying the amount and details, afer which the company withdraws the funds, but not later
than the day following the date of receipt of the order. Thus, the client could not independently dispose of special
brokerage accounts, any actions were performed by order. Ofen there were appeals or complaints of "complaining"
clients, each appeal was dealt with, the essence was checked, whether there was a breach of contract, whether there
was a liaison with the client to settle the issues. In general, the following complaints were received: clients did not
fully understand the essence of the service and did not fully familiarise themselves with the terms and conditions of
the contract, sometimes there were complaints about operational errors. All arising issues were resolved through co -
operation with the client. In the course of his labour activity he had to deal with the following employees: Spinka R. V.
- Spinka R.V. was an employee of the company with which he concluded an agency agreement on attracting clients to
the company, he (Timokhin O.Y.) personally interacted with him on issues related to clients; Padalko N.S. - he knows
from working correspondence; Orlov Y.N. - the manager of the company "Q.Broker" LLC, which was a client and
counteragent of the company; Amerov R.F. - was in charge of attracting new agents to offer services and expand the
client base; Korzh A.V. and Zaitseva Y.S. were in charge of attracting new clients to offer services and expand the client
base; Frolov V.G. was the previous General Director of the investment company; Pakhomov V.S. was the head of the
regional network, one of the managers of the group of companies; Yudin M.S. was in charge of sales, afer IT issues;
Shpakov R.V. was the ultimate beneficiary of the company. - final beneficiary of LLC IC QBF; Munaev Z.V. - one of the
managing partners of the company; Matyukhin S.A. - General Director of LLC IC QBF; Rossieva E.A. - dealt with legal
issues in the parent company of JSC Financial Group QBF; Gorobets E.V. - General Director of one of the counterparties
of the company. - was the General Director of one of the counterparties to the transactions; Lepeshkin D.S. - co -
operated with him on working issues, but does not know what position Lepeshkin holds; Golubev A.S. - an agent of his
(Timokhin O.Yu.Golubev A.S. - an agent of his (Timokhin O.Y.) company, engaged in sales in the regions; Smirnova Y.G. -
was the general director of the management company LLC MC QBF Asset Management; Shaban Y.V. - was their (the
company's) client and at the same time a counterparty to transactions; Kozyreva E.Yu. - co - operated with agents;
491
Kharina E.N. - Athanasiadou Linda was the director of the company "constance investment", through which attempts
were made to gain access to foreign markets, but this company failed to open client accounts;
(Vol. No. 268, pp. 216 - 223, 230 - 232)
- Testimony of Treiman A.S., given by him as a witness,

according to which at the end of 2020 his acquaintance Khmeleva Sergey informed him that the organisation K -
Investment LLC, where Khmeleva S. worked for about 1 year, requires employees to work with clients. He (Treiman
A.S.) applied to the personnel department of K - Investment LLC and in January 2021 in the office of K - Investment
LLC, located in one of the buildings of the office centre "Moscow City" was interviewed for the vacancy of junior
financial advisor. Yulia, a member of the human resources department, explained to him that K - Investment LLC
operated under an agency agreement with QBF LLC, whose clients entered into brokerage and trust management
agreements. A few days later, he came for the second stage of the interview, which was attended by the head of the
office, Javid Issaev. Approximately two days afer the interview, Julia informed him that his (Treiman A.S.)
candidature for the position of Junior Financial Advisor had been approved and he could go to work. His workplace
was the office premises of the company K - Investment LLC, located on the 9th floor in one of the buildings of the
business centre. His duties included working with clients who called the office and further accompanying and
redirecting them to the back department of K - Investment LLC, which was directly involved in the execution of
contracts and other documents with clients. He himself did not call anyone to attract clients and worked only with
incoming calls from clients. The internship period for the position was about 1 month and afer the internship he was
finally appointed to the position. He received calls from customers on a daily basis. During the phone call he had to
tell the clients about the terms and conditions of investing money, commissions, terms of participation in the
contract, minimum limits of applications, as well as other issues of interest to the client. He told the clients the
following: the company K - Investment LLC is engaged in trust management of client capital, brokerage services, the
minimum commission for participation in the initial public offering is from 2.5 - 3.0 per cent of the allocated amount.
Afer the client preliminarily agreed with the terms of the agreement he (Treiman A.S.) opened a brokerage account
for the client through the Nabix programme. To open the account, the client would give him his personal details. The
clients never came to him personally, but transferred their personal data via e - mail. Once all personal details had
been entered, the customer was deemed to be registered. Subsequently, the client had to confirm the status of
"qualified investor", which is required by Russian legislation. In order to do so, he had to provide K - Investment with
information that his brokerage account contained funds in the amount of at least 6,000,000 roubles or a certificate of
the Federal Service for Financial Markets. Subsequently, if the result of the check was positive, the client was allowed
to participate in the IPO (initial public offering). Afer that he (Treiman A.S.) notified clients weekly about IPO news.
The replenishment of the brokerage account was made by the client himself from his bank account. The specified
details were sent by the Nabix programme automatically to the client's e - mail. He did not sign any contracts with
clients. He received e - mail notifications that the client credited funds to his brokerage account, but he does not know
the further movement of funds. The notification on the receipt of funds included the number of the agreement with
the client and the date of account opening. He knows that the general director of QBF LLC was Sergey Matyukhin, and
he also knows that since 2008 QBF LLC has been operating in the field of investments. His direct supervisor was Javid
Issaev;
(Vol. No. 268, pp. 234 - 237)
492
- The testimony of Ulanova K.S.,
given to her as a witness, according to which she has a higher education in economics and marketing, is an individual
entrepreneur and provides consulting services on a paid basis to various companies. One of such companies was the
company QBF LLC. In July 2017, her acquaintance Vadim Skosyrev, at that time an employee of QBF LLC, offered her
to work for this organisation, specifically to engage in the PR of the company, organisational work with journalists of
business publications to publish articles about the company, as well as the organisation of public relations. During
this period, she arrived at the office of QBF LLC located at 8 Presnenskaya Naberezhnaya Naberezhnaya, bldg. 1,
Capital City Tower, to the office on the 9th floor. She was met by Skosyrev Vadim and during the conversation
confirmed that he intended to employ her (Ulanova K.S.) as a "press secretary". Since September 2017, she started
working for QBF LLC, a company engaged in capital management for the securities markets. Her position was formal
in nature; in fact, she was an outside consultant to the company on public relations matters. There was no contract of
employment with QBF LLC. Her duties included verbal advice, as well as consulting via the Internet with experts in the
analytical and sales departments on the preparation of comments for the media. She worked with the following
business publications: "RBC", "Kommersant", "Vedomosti", "Forbes", "Time" and others. These publications wrote
articles on certain issues and, when writing them, contacted QBF LLC as experts in the financial industry. She had no
direct manager, her services were paid for by Skosyrev Vadim. In addition, she had heard of the company "White
Lake", which was engaged in activities related to capital management and registered in Cyprus. She also knows such
persons as Roman Valeryevich Shpakov, Zelimkhan Visaitovich Munaev, who are the main shareholders of the
company QBF LLC, with whom she has repeatedly communicated on working issues. Stanislav Anatolievich
Matyukhin is the general director of the company, she has almost never had any contact with him. Evgenia
Anatolievna Rossieva is the leading lawyer of the company. In addition, she has heard several times a conversation
where the girl Athanasiadou Linda was mentioned;
(Vol. No. 269, pp. 1 - 4)
- The testimony of Frolov V.G., given by him as a witness,

according to which from 2010 to 2017 he worked as a general director in QBF LLC, which was offered to him by
Shpakov R.V. At the time of his employment, the company employed about 5 - 7 people. Later on, the company started
to grow and by 2015 the staff totalled about 300 people. The financial burden on the company in terms of tax
deductions and contributions to the pension fund increased. In this regard, he proposed to R.V. Shpakov to transfer
part of the staff to other companies, which would reduce the financial burden. Thereafer, Shpakov established the
Kyubi Group of Companies. In the period from 2014 to 2017, he was also the CEO of the managing company QBF Asset
Management LLC. His job responsibilities included the organisation of work on the MICEX market, services in banking
organisations and notaries, personnel work, as well as general management of the company's activities. In spite of
the fact that he (V.G. Frolov) was the general director of the company, his functions were limited and were limited to
fulfilment of specific instructions given by Shpakov R.V. The accounting department reported to Shpakov R.V. on the
financial performance of the company, but he (V.G. Frolov) did not manage the financial activities of the company and
had no access to the company's finances. On the instructions of R.V. Shpakov, he (V.G. Frolov) implemented a payroll
project for the company's employees. The company's seal was kept in the accounting department of the chief
accountant, Tatyana Petrovna Voronova, on the instructions of R.V. Shpakov. In case of signing any agreements on
behalf of the company, he (V.G. Frolov) was put in front of the fact that he had to sign, and the documents were
stamped by the chief accountant Voronova T.P. In QBF LLC ("QBF") and QBF Asset Management LLC, he was paid his
salary as a person holding the position of general director in the companies in fixed amounts of 50,000 rubles per
month, these funds were received by transfer to a bank card. At the same time, these companies had the same
accounting department. As general director of QBF LLC, he concluded brokerage contracts with clients, exclusively
with individuals and only on behalf of QBF LLC. QBF LLC usually had at least two accounts opened with credit
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(banking) organisations, the company's current account and the clients' brokerage account. Clients' funds were
transferred only to the brokerage account, and from the brokerage account funds could be transferred only to the
specific client who had previously transferred them. QBF LLC ("QBF") could not dispose of client funds that were in
the brokerage account. To which brokerage account and which credit organisation the clients were to transfer the
funds were informed by the employees of QBF Ltd., this function was performed by the employees of the "Back -
office" (internal office) of QBF Ltd. and no particular employee was assigned to any particular client. In addition,
dividends are never issued in the form of cash payments. When dividends are accrued, they are transferred non - cash
to the brokerage account of a particular client. QBF LLC, has never issued dividends in the form of cash payments to
anyone. He does not know how the participants of QBF LLC divided the profit from commercial activities. He always
visited tax authorities and credit institutions with the chief accountant Voronova T.P., who performed the tasks in his
presence. In the spring of 2021 he received a phone call from the lawyer Rossieva Evgenia, who informed him that
there was a problematic situation with a Cypriot client, which she did not say, and in this connection he (Frolov V.G.)
was put before the fact that a lawyer was assigned to him in case of a visit of law enforcement authorities. He did not
personally pay for the lawyer's services, but they were paid for by the company. The girl named Linda is familiar to
him, she actually lived on the island of Cyprus, but he had no personal contact with her. Shpakov R.V. communicated
directly with Linda. He has known Munaev Zelimkhan Visaitovich since 2014, Munaev was previously a member of
QBF LLC ("QBF") with a share of 5 or 7 per cent until about 2017. Munayev's activities at the company consisted of
attracting clients to work on the stock market in Russia and on the island of Cyprus. Cyprus;
(Vol. No. 269, pp. 11 - 18)
- E. N. Kharina's Testimony
given to her as a witness, according to which from 23.07.2018 she worked at F - Expert LLC as the head of product
development and part - time at K - Investment LLC as a consultant. However, she was actually carrying out work for
the group of companies of QBF Ltd. Her direct supervisor was Munaev Zelimkhan Visaitovich and his position at QBF
LLC was Managing Partner of the organisation. Since March 2020, she has been working as Director of Investment
Products Department at F - Expert LLC. Her job duties as the Head of Product Development at QBIF LLC and her job
duties as the Director of Investment Products Department at the same organisation were the same, namely: to
monitor products of competitors - Tinkoff Investments LLC, BKS LLC, Finam LLC and others, to request from the
investment desk ideas for product development companies by industry, to submit these proposals to the
management for approval, to receive tasks for the development of product documents, to agree on product
documents, to coordinate the development of product documents, and to submit them to the management for
approval. The only difference was that as the Director of the Investment Products Department she could take an
assistant Chubchenko Sofia Andreevna. She was familiar with the name of the organisation "White lake", as she
prepared marketing material for this organisation. Around 2019, Roman Valeryevich Shpakov, one of the founders of
the organisation QBF LLC, gave her a task and a list of products for which she had to prepare marketing material for
White lake. He also said that the main graphics and text fragments should be taken from Denis Ikonnikov, head of the
analytical department of QBF LLC, who was territorially located in St. Petersburg. On Shpakov R.V.'s instructions, she
compiled a product presentation for "White lake", which she repeatedly forwarded to Shpakov R.V.'s e - mail
[email protected], and then printed it out on paper and personally brought and gave it to Shpakov R.V. Afer Shpakov R.V.
had approved this material. approved the material, he instructed her to email the material to the organisation's
employees at [email protected] and [email protected], as well as to Ruslan Spinka, who holds the position of head of one
of the sales department groups at [email protected] and Nikolai Padalko, head of one of the sales department
groups. She also uploaded the material to the network folder "QBF" subfolder Prudusts on the organisation's product
resource, from where the sales department could take these materials. In the future, Padalko N sometimes came into
contact with this organisation on work - related tasks, but these were design tasks on products. In the summer of 2020
she received an assignment from Munaev Zelimkhan Visaitovich by phone that she was to assist Kovalenko
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(Athanasiadou) Linda and Dmitry Sergeevich Lepeshkin in drafing a descriptive document about Constance
Investment. She does not remember exactly what positions Kovalenko (Athanasiadou) Linda and Lepeshkin D.S. held
in this organisation, but everywhere and always they were together. Subsequently, she received a brochure in English
by e - mail from Kovalenko (Athanasiadou) Linda or D.S. Lepeshkin, which contained a descriptive part about the
company "Constance Investment", to which markets there is an opportunity to enter and give access. In the process of
preparing the Russian version of this brochure she had to translate this brochure into Russian, also to request the
missing information from Spinka R. and Padalko N., voiced by Kovalenko (Athanasiadou) Linda and Lepeshkin D.S.
about the sections of the necessary information to be provided by the client in order to become a client of Constance
Investment and open an account. Spinka R. and Padalko N. provided a list of documents required for clients, which
she included in this brochure and sent the received document by e - mail to Spinka R., Padalko P., Kovalenko
(Athanasiadou) Linda, Lepeshkin D.S., and Munayev Z.V. As far as she could judge from the brochure provided to her
by Constance Investment, this organisation was engaged in attracting clients' funds for investment and providing
clients with income as a result of this investment. In the future she also sometimes encountered this organisation in
her work on assignments of Kovalenko (Athanasiadou) Linda., Lepeshkin D.S., Padalka N., but these were product
design assignments. She from the legal department and Padalka N. received blank, without signature and without
specifying the client's data forms of client contracts "White lake LTD", in which her task was to set product parameters:
product name, for example "growth modules", "algorithmic" or "repo", minimum investment amount and
commission, which were provided to her by Shpakov R.V. That is, in each specific product (contract with the client), for
example "growth modules", she, on the instructions of Shpakov R.V., supplied a specific certain investment amount
and commission. Later she sent these forms of contracts with the client by e - mail to the legal department of Rossieva
Evgeniya and Padalko N. and had nothing more to do with the forms of contracts. The founder of "White lake LTD" is
R.V. Shpakov, the general director is N. Padalko. The offices of R.V. Shpakov and N. Padalko are located at: Moscow,
Presnenskaya naberezhnaya, 8, p. 1, 9th floor. 1, 9th floor. The main activity of "White lake LTD" was attraction of
clients' funds to ensure profitability and payment of income to the client. The trust management agreements with the
client were concluded on behalf of IK QBF LLC and for acting on the Russian market. She has only seen the list of
documents to be submitted by a client of QBIF LLC group of companies wishing to participate in trading on
international stock markets in a brochure she prepared for Constance Investment. The following persons fulfilled their
official duties in the group of companies of IC QBF LLC: R.V. Spinka holds the position of Director of the Sales
Department of the group of companies of QBF LLC; N.S. Padalko holds the position of General Director of White lake
LTD; Y.N. Orlov holds the position of Managing Partner of QBF LLC. holds the position of Managing Partner of Q-
BROKER LLC; Amerov R.F. holds the position of Director of Banking and Partnership Sales Department of QBF LLC
group of companies; Korzh A.V. holds the position of Deputy Director of Sales Department of QBF LLC group of
companies; Zaitseva Yu.S. holds the position of Group Head of the Sales Department of the group of companies of
QB&EF LLC; Pakhomov V.S. is one of the beneficiaries of the group of companies of QB&EF LLC and holds the position
of Director of the branch network; Yudin M.S. holds the position of Director of the Operations Department of the group
of companies of QB&EF LLC; Shpakov R. V. is the main beneficiary of the group of companies of QB&EF LLC.V. is the
main beneficiary of the group of companies of QBF LLC and the actual owner of this organisation; Z.V. Munayev is one
of the beneficiaries of the group of companies of QBF LLC and holds the position of managing partner; S. Matyukhin
holds the position of general director of QBF LLC.A. holds the position of General Director of LLC IC QBF; E. Rossieva
holds the position of Director of Legal Department in the group of companies of LLC QBF; Kovalenko (Athanasiadou)
Linda holds the position of General Director of Constance Investment; Vlasov P.Y. holds the position of an employee of
the sales department in the group of companies of QBF LLC; K.S. Sobolev does not know what position he holds, but
he worked in the team of Kovalenko (Athanasiadou) Linda in Constance Investment and permanently resides on the
island of Cyprus; A.S. Golubev. A.S. Golubev is the director of the branch network in the group of companies of QBF
LLC; Y.V. Shaban works in some financial group, which company she does not know; A.F. Vozhzhov is engaged as an
external design specialist in the group of companies of QBF LLC; E. Grabareva.A. is an employee of the department of
banking and partnership sales in the group of companies of QBF LLC; Timokhin O.Y. holds the position of the head of
the back office in QBF IK LLC; Smirnova Y.G. holds the position of the general director of QBF MC LLC. As far as she
knows, Spinka R.V., Padalko N.S., Korzh A.V., Zaitseva Y.S., Pakhomov V.S., Yudin M.S., Shpakov R.V., Munaev Z.V.,
Rossieva E.A. concluded contracts with clients and provided services on behalf of "White lake LTD", Lepeshkin D.S.,
495
Kovalenko (Athanasiadou) Linda., Vlasov P.Y., Sobolev K.S., Golubev A.S., Grabareva E.A. Amerov R.F. could conclude
this type of contract only with Russian clients and worked only with legal entities;
(Vol. No. 269, pp. 25 - 38)
- S.A. Khmilevoy's Testimony

as a witness, according to which he posted his CV on the Head Hunter website in order to look for a job. At the end of
January 2020 he received a call on his mobile phone from a girl Julia, a representative of the company QBF LLC and
invited him to an interview conducted via video link. His first interview was held at the end of April 2020 together with
Julia, and the second interview was held with Laipanov E. During the interviews he was presented the investment
activities of the company QBIF LLC, which has four licences from the Central Bank of the Russian Federation. He was
also told about the financial products of the company, which were provided to clients, namely participation in IRO,
IIS, trust management agreements, brokerage services on the Russian market, RIF shares. About a week later Yulia
informed him that he was hired as a trainee at QBIF LLC from 15.06.2020. During the period of time from 15.06.2020 to
September 2020, he worked as an intern at QBF IK Ltd. His job duties included searching for future clients and he was
provided with a list of contacts to whom he was supposed to call and offer the company's financial products. In
addition, during the period of time specified by him, he was also trained by Avetis and Beladed S., who told him about
the investment activities of the company. His sales training was conducted by Chepurkova A. His supervisor was
Isayev Javid, also Isayev was the head of IRO. Isayev D. in turn reported to Ruslan Spinka, who held the position of
Director of Sales and Customer Service at QBIF LLC, and his deputy was Korzh A. In total, QBIF LLC officially employed
ten people. In August 2020, due to the fact that he was not very successful in attracting clients, he was given two
clients who wanted to participate in the IRO and with whom it was necessary to conclude agreements and open a
brokerage account. He was transferred to the position of junior financial advisor, but at that time he was not officially
employed by QBEEF LLC. In order to conclude an agreement on the provision of brokerage services, the client was
required to obtain a copy of his passport as a citizen of the Russian Federation, his SNILS, e - mail details, and details
of a bank account for withdrawing funds. The client sent these documents to his QBF work email, WatsApp and
Telegram phone application. He then entered the client's details through the Nabix programme. This programme then
generated a package of documents and sent them to the client via email. The documents were sent to the client for
review. At the same moment the client received a sms message with a code for confirmation to sign these documents,
which the client informed him. This code he (Khmileva S.A.) entered into the programme and afer that the signed
copies of the agreement both from the side of QBIF Ltd. and from the side of the client were sent to the client. On the
side of QB&EF LLC, the contract was signed with an electronic signature by the general director Matyukhin S.A. His
first clients were Bazaev M. and Kulagin A. In total, from September 2020 to the end of March - beginning of April 2021,
he had 30 - 35 clients, who in total transferred funds in the amount of 45 - 50 million roubles to their brokerage
accounts. The said clients all participated in the IRO. Since September, the management represented by Spink R. and
Korzh A. said that the company had developed a master agreement, which was that the top broker IRO provider sees
the total amount of money and enables the clients to participate in the IRO. This was also mentioned in class by the
head of the legal department, Russeva E., that financial advisors should explain this in roughly the same way to their
clients about the master agreement. In approximately November 2020, he was formally employed by K - Investment
LLC as a junior financial advisor. As a junior financial advisor, he had the following job duties: client acquisition,
selling the company's financial products, supporting client transactions, and client counselling. In addition, one of
the requirements of the department heads was that each financial advisor should attract client funds to the company
totalling at least 2,500,000 roubles per month. When he asked Anastasia Zaripova why he was employed at K -
Investment LLC and not at QBIF LLC, Zaripova A. and Isaev Javid replied that this was done so that QBIF LLC would
pay less taxes. A total of eleven people worked in his department with him: Lazarev, Murashev, Lopukhova, Dynda,
Manaenkov, Bashkirov, Treiman, Said Isaev, Chernyshova, Pirogov. During his work in the company he saw Shpakov
R., Munayev 3., Lepeshkin D., a woman named Linda, Padalko N. Lepeshkin D. was the director of the company
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Constance Investment, located on the island of Cyprus, Linda was his assistant. S.A. Matyukhin was the General
Director of LLC IC QBEEF. Padalko N. was engaged in the withdrawal of funds abroad and supervised the work of the
company WhiteLake and the Luxembourg company Argento. This became known to him in the course of
communication between work colleagues. He also knew the company QBroker LLC, which worked directly with the
top broker, the data of which were not disclosed, referring to commercial secrecy: the General Director of this
company was Orlov Y. Afer the May holidays in 2021, clients began to apply with claims about the fact of delayed
withdrawal of funds. With this question he approached Isayev D. and Korzh A., who explained that the regulatory
period was not exceeded, that all clients will receive their funds in time. He subsequently communicated this
information to his clients. On 25 - 26 May at about 10 a.m. he came to work, where Isayev D. announced to everyone
present that in a short while law enforcement officers would come to the office to conduct a search. At the same time
he saw that the employees of the company, including Javid I. began to destroy some documents with the help of a
paper shredder. Some time later, law enforcement officers entered the office and started the search. Subsequently,
Korzh A. told all the employees not to tell the clients about the searches in the company, but to explain that there was
a failure in the fire extinguishing system, which led to the malfunction of the servers. However, he (S.A. Khmileva) in
turn told the clients how things actually happened, that there were searches in the company. About 29.06.2021 their
entire department of the remaining people - him, as well as Treiman A., Manaenkov V., Lazarev A., Chernyshev V., Ilyin
A. and Murashev A. gathered Korzh A. and invited one by one to the classroom, where he said that the staff is being
reduced, as there are no sales at the moment. Also Korzh A. said that in the near future the salaries would be paid,
afer which they all resigned of their own accord. At the same time, Korzh A. and Spinka R. told them (employees) to
sign a prolongation of commitment, an annex to the general agreement with the clients. This commitment was that
the client would be okay with their remaining funds remaining in the company's accounts for three or six months at
the client's discretion. As this requirement did not seem quite right to him (S.A. Khmilevov), he refused to offer it to
the clients, as he realised that this was done in order to keep the clients' money inside the company longer and not to
return it to the client. In addition, Korzh A., when asked when all payments - salary and payments to clients - would be
made, said that law enforcement officers had seized "the keys to the client's bank" and therefore there was no access
to the company's current account. It was not explained which company. He (Khmileva S.A.) understood perfectly well
that Korzh A. was misleading them, as he (Khmileva S.A.) worked in the bank and knows that there is no "key to the
bank client" as such. Further in the course of conversation Korzh A. said that the company has real estate, which will
be sold in order to close obligations to customers and employees. Afer these words he (S.A. Khmileva) concluded that
the company IK "QBF" Ltd. had stolen clients' funds and disposed of them. On the day of the search in the company
Isayev D. said that for what reason the money was not returned he did not know how and where the clients' money
had gone, he explained that the money had most likely been stolen. Afer the search and conversations with Isayev D.,
Korzh A. and Spinka R., he concluded that all the involvement of clients' money in the company was a fraudulent
scheme;
(Vol. No. 269, pp. 45 - 49)
- The testimony of A.V. Chentsov, given by him as a witness,

according to which in May 2020, afer he placed an advertisement on the website ".hh.ru", about job search, he
received a call from a representative of the group of companies "QBF" and invited for an interview in the office
located at the following address: Moscow, Presnenskaya Naberezhnaya, 8, tower "Capital City", business centre
"Moscow City". During the interview, he was offered the position of Financial Advisor for the Sales Department at QBF
Group. On 26 May 2020, he became an employee of K - Investment LLC with a salary of approximately RUB 60,000,
which could reach RUB 100,000 depending on the fulfilment of the plan (KRI). He received his salary in cash, which
was given to him by various employees of the QBF group of companies. During the entire time he worked for QBF
Group, only six employees of the company issued salaries. He did not know these employees personally, but
periodically saw them in their offices. He signed for the money he received in the statement provided to him. QBF LLC
497
was part of the QBF group of companies, but he did not know the number of organisations in this group of companies.
The office of QBF LLC was located at 8 Presnenskaya Embankment, Moscow, Moscow City Business Centre, Capital
City Tower. The principal activity of QBF Group was attracting clients for the sale of investment products and trust
management of funds invested by clients. Roman Valeryevich Shpakov was the head of QBF Group of Companies. His
(A.V. Chentsov) mentor was Artem Tallerov, but he does not know what position Tallerov held. From Tallerov Artem he
received instructions on work, and also reported to Tallerov on the results of work done. His (A.V. Chentsov) duties as
a financial advisor included: searching and inviting clients, informing clients to sell the company's products, assisting
clients in collecting documents for further conclusion of a contract with the company, meetings with the company's
clients, making calls to the company's clients, redirecting clients to the BEC office, whose employees directly
concluded contracts with the company's clients and opened brokerage accounts for them. The work plan (KRI) in the
organisation was not permanent and could change quarterly. It mainly included the number of meetings held with
the company's clients, the number of calls made to the company's clients, the number of brokerage accounts opened
for the company's clients for further trust management, the money invested by the clients, but opening a brokerage
account for a client of the company did not guarantee the placement of funds in it. His workplace was located in QBF's
main office in the Moscow City Business Centre. He worked at K - Investment LLC until 26 May 2021. He resigned from
K - Investment LLC at his own request due to the fact that in 2021 his salary became delayed. In addition, in May 2021,
in the office of the group of companies "QBF" conducted investigative activities, which also prompted him to resign
from LLC "K - Investment".During his employment in the company "QBF" he had to communicate with various
employees: Katya D., Orlov Vladislav, Stella, Isabella, Maxim, Ara, Sergey Khmelev, Grigor Erzikyan, Avetis Vartanov,
Tural Godirli, Ekaterina Gramza, Vladimir Maslennikov, Ruslan Spinka, Nikolay Padalko, Pavel Vlasov, Marina
Nikolaeva, Christina Bogdanova, Andrey Korzh, Maxim Fedorov, Yulia Zaitseva. Some of them he knew as financial
advisors, some of them as employees of the company, but what positions they held he does not know. Roman
Valerievich Shpakov was the main head of QBF Group, Zelimkhan Munaev was the head of the Moscow branch of QBF
Group, Stanislav Matyukhin was the general director of QBF IK LLC, and Evgenia Rossieva was the chief lawyer of QBF
Group;
(Vol. No. 269, pp. 50 - 53)
- The testimony of Chepiuk A.F., given to her as a witness,

according to which from 2015 to 2019 she worked in LLC "Kyubi Finance" as a secretary. Her job duties included
working at the reception desk, meeting guests, receiving calls, scanning and copying documents, sorting out mail,
and working with couriers. The office of QB Finance LLC was located at 8 Presnenskaya Naberezhnaya Naberezhnaya
Street , Moscow, bld. 1, floor 9. 1, floor 9. Her workplace was located at the reception desk. In addition to her,
Kabanova Alena, Kuranina Lyubov, Marina Nikolaeva, Kristina Shestakova and other employees also had a
workstation at the reception desk. The reception desk had a landline telephone which was used by all its employees.
Her workplace had only a shared work email account, which was used by all secretaries. Her supervisor was Dmitry
Sergeevich Lepeshkin, who could ask her to scan something, copy something, and bring him tea and coffee in his
office at his request. She performed the same duties for the other supervisors, Munaev Zelimkhan and Shpakov
Roman. According to her observations these were the two most important people in the office. However, the direct
supervisor was senior secretary Kabanova Alyona, mainly Kobanova A. gave her tasks. She (Chepyuk A.F.) knows that
QB Finance Ltd. is an investment company, this organisation had a sales department, accounting department and
personnel. In the sales department she remembers Maxim Yudin and Alexander Zaitsev, both of them were heads of
the department and had been working there for a long time, the other employees of the sales department changed
frequently. She also remembers Tatyana Voronova, who worked in the accounting department, possibly holding the
position of chief accountant. Ekaterina Gramza also worked in the accounting department. In addition, the company
had a legal department. In 2019, Lepeshkin D.S. offered her another job, the position of project manager of M1 Invest
LLC, she accepted. Lepeshkin D.S. was related to QB Finance LLC, but what kind of relation she did not know.
Lepeshkin D.S. was the general director of M1 Invest LLC. The office of LLC M1 Invest was located there on the 9th
498
floor. Her workplace in this organisation was in the reception area, which was a workplace in the corridor. Alena
Kabanova joined her in the reception area. Her duties included essentially the same work, but previously she had
been a general secretary, but now she was directly secretary to Lepeshkin D.S. On Lepeshkin's instructions she
scanned and copied documents, confirmed appointments, and did other secretarial work. Alena Kabanova worked
with other duties, Lepeshkin D.S. was not her supervisor. The organisation of LLC M1 Invest was small. At the
beginning of her employment with M1 Invest LLC, her salary was in the region of 60,000 roubles and reached up to
80,000 roubles in 2021. In addition, from 2019 she also worked at Simon Jesso LLC, starting as an assistant manager.
From 2020 until now, she has been a project manager at Simon Jesso LLC. Her job duties include: liaising with
contractors, government agencies regarding permitting and more. The staff of Simon Jesso LLC consists of about five
people, the general director of Simon Jesso LLC is Arsenchuk Valeriy Evgenyevich and the functions of the chief
accountant of Simon Jesso LLC are performed by him. Also, the general director of OOO Simon Jesso has an advisor,
Dmitry Sergeevich Lepeshkin, who advises V.E. Arsenchuk on construction issues. The main activity of OOO Simon
Jesso is the construction of residential property in the Moscow region. She has never been officially employed by OOO
Simon Jesso. OOO Simon Jesso owns a land plot on which the construction of residential real estate is taking place,
the apartment building Gribovsky Les Residential Complex located at the address: Moscow region, Odintsovsky
district, v. Borodki, Parkovaya street, уч. 1. This organisation is the developer of the Gribovsky Les housing estate.
Settlement accounts of LLC "Simon Jesso" are opened in PJSC "Sberbank" at the address: 25 Molodezhnaya St.,
Odintsovo, Moscow region, JSC "Alfa - Bank". Around 2018 - 2019, Lepeshkin D.S. asked her to help in preparing
documents on LLC "Simon Jesso" for obtaining a construction loan, fill out questionnaires, bank forms in PJSC
"Sberbank". She filled out the entire required set of documents and sent them to Lepeshkin D.S. To complete the task,
Lepeshkin D.S. gave her some documents and also sent her something by e - mail, provided her with a list of
documents for Simon Jesso LLC that she needed to collect, namely, statutory documents, questionnaires, forms.
Some of the documents she found in open sources on the Internet, some documents she requested from the general
director of "Simon Jesso" LLC Arsenchuk Valery Evgenyevich by e - mail, which were sent to her in response. She saw
Arsenchuk V.E. several times, he came to Moscow to Lepeshkin's office. D.S. Arsenchuk V.E. himself worked in
Yekaterinburg. The general contractor was OOO "Association Stroyinterservis", the technical customer was OOO
"Stroitelnye Sistemy". There may be other contractors. In order to apply to PJSC Sberbank for a loan, she needed all
the data of OOO Association Stroyinterservis and OOO Stroitelnye Sistemy. Lepeshkin D.S. gave her contacts of
persons representing these organisations and she contacted them and requested the necessary documents. All
communication was carried out via e - mail. She knows from the documents that the general director of "Association
Stroyinterservis" Ltd. is Alexander Mikhailovich Kolodny, the general director of "Stroitelnye Sistemy" Ltd. is Valery
Vitalievich Arsenchuk. She knows that the authorised capital of Simon Jesso LLC includes a land plot at the address:
Moscow region, Odintsovsky district, v. Borodki, ul. Parkovaya, уч. 1. According to the documents, the legal address of
"Simon Jesso" LLC is located at the address: Moscow, 5th Parkovaya Street, house No. 46. From the documents she
knows that the construction permit for the Gribovsky Les housing estate was obtained in 2016. Currently, according to
the legislation all developers can sell flats only through escrow accounts, including Simon Jesso LLC. From the
statutory documents she knows that in 2019, at the time of her filling out the application Shpakov Roman Valerievich
was the founder of LLC "Simon Jesso" together with Arsenchuk V.E., there were two founders in total. She knows R.V.
Shpakov from her work in QB Finance Ltd. when she worked as a secretary. In addition, she knows that there is LLC
Investment Company QBF. The office of this organisation was located there, on the 9th floor, at the following address:
8 Presnenskaya Naberezhnaya Embankment, bld. 1, Moscow, Presnenskaya Naberezhnaya. 1. The QB group of
companies included other companies, their names beginning with "QB" and then different endings. During the period
of her employment with QB Finance LLC, the following persons worked in the office located at 8, Presnenskaya
Naberezhnaya Naberezhnaya, 8, p. 1, 9th floor, Moscow. 1, 9th floor, the following persons were employed, namely:
Ruslan Valeryevich Spinka, who was a member of the sales department; Nikolay Sergeyevich Padalko worked in the
sales department; Yuri Nikolayevich Orlov worked in the IT department; Rinat Felixovich Amerov and Vladislav
Olegovich Plitin were members of the sales department; Andrey Vasilyevich Korzh was a member of the sales
department; Yulia Sergeevna Zaitseva was a member of the sales department; Daria Yuryevna Meshkova was a
member of the company; Frolov Vladimir Georgievich general director of QB Finance LLC; Pakhomov Vladimir
Sergeevich was a manager, but what he was in charge of, she does not know; Yudin Maxim Stanislavovich sales
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employee, he worked in a managerial position; Shpakov Roman Valeryevich is the most important manager of the
whole group of companies, the founder of the group of companies; Munaev Zelimkhan Visaitovich is also a high - level
manager. It assumes that Munaev Z.V. and Shpakov R.V. are the main shareholders, Matyukhin Stanislav Anatolievich
is also a manager. Rossieva Evgenia Anatolievna held a managerial position, and the name Gorobets Elena
Vyacheslavovna has heard but never seen this person. Athanasiadou Linda is a manager, but she (Chepiuk A.F.) does
not know her affiliation with the company. Athanasiadou Linda came to the office about once every few months. From
her (Chepyuk A.F.) observations, Athanasiadou Linda communicated with Roman Shpakov and with Lepeshkin D.S.,
went to the offices of these persons. Pavel Yuryevich Vlasov and Kirill Sergeevich Sobolev worked in the sales
department. V.S. Pakhomov worked in the St. Petersburg branch, but ofen travelled to Moscow. There were also
branches in Ekaterinburg and other cities. Yaroslava Gennadyevna Smirnova is currently the Director of QBF Asset
Management, whose office used to be also on the 9th floor, then moved. Yuri Vasilievich Shaban was seen in the
office, Alexander Fedorovich Vozhzhov worked as a designer. She knows the organisations 168 Kvartal LLC, KP turn 3
LLC, KP turn 2 LLC, KP turn 4 LLC, Kubief Financial Group JSC, KBF Asset Management LLC, Kubief Group LLC, M1
Invest LLC, Format Development LLC, Kubief JSC, M4 Invest LLC, Kubief LLC, Severspetsstroy LLC, 702 LLC, Vysota LLC.
Simon Jesso LLC has contractual relations with the organisations 168 Kvartal LLC, KP turn 3 LLC, KP turn 2 LLC, KP
turn 4 LLC, M1 Invest LLC, Format Development LLC, Severspetsstroy LLC, 702 LLC, Vysota LLC. The organisations JSC
QBF Financial Group, LLC QBF Group, LLC QBF Asset Management, LLC QBF Group are part of the QBF group of
companies The above - mentioned organisations are investment organisations. M4 Invest LLC carried out an
advertising campaign for Simon Jesso LLC;
(Vol. No. 269, pp. 57 - 61, 62 - 72)
- Chisluk O.R.'s Testimony given to her as a witness,

according to which, from approximately October 2018 to December 2018, she worked at K - Consulting LLC as a
business assistant. From April - May 2021, she was promoted to the position of General Manager of Sales Support. The
General Manager of K - Consulting Ltd was Polybin, this name she has seen in the organisation's documents. Her
direct supervisor is Renat Amerov, who was the director of "Marketplace My Finance" LLC. The organisation "QBF" is
familiar to her, as LLC "K - Consulting" is a part of the group of companies "QBF". K - Consulting Ltd. is engaged in
company project management, integration, customer interaction, mobile application management and other
activities. In addition, she is familiar with the organisation Q.Broker, as it was located in the same premises as K -
Consulting Ltd. The manager of "Q.Broker" is Yuri Orlov, whom she has known since November 2019. Also, QBF Group
included the following companies M1 Investment LLC, QBF Financial Group JSC, My Finance Marketplace JSC, VL -
Consulting LLC, QBF Investment Company LLC, QBF Asset Management LLC, Q - Investment LLC, Q - Consulting LLC, Q
- Consulting LLC, Q.Broker, QB Group LLC, QBief LLC, MC Granat LLC, F - Management LLC, F - Technologies LLC, White
Lake Management Ltd, QB Capital, 701 LLC, 702 LLC, 776 LLC, QBGroup LLC. The owner of all the above organisations
is Roman Valeryevich Shpakov. His (Shpakov R.V.) deputy is Munaev Zelimkhan Visaitovich, with whom all important
processes of the company were coordinated, Munaev Z.V. gave instructions in various areas of activity. E.A. Rossieva
was the head of the legal department, she solved all legal issues of the company, any projects were necessarily agreed
with her, E.A. Rossieva checked absolutely all documents, nothing passed by her. E.A. Rossieva's assistant was
Nadezhda Firsova. The general director of LLC "IC QBF" was Matyukhin S.A., the general director of LLC "MC QBF" was
Smirnova Y.G. The top managers of the group of companies were Yudin, the operating director of the company, who
coordinated developers and IT - employees, and Spinka, the head of the sales department, who made all decisions in
this area and coordinated everything with him. Spinka gave instructions to his subordinates in the sales direction.
Padalko was in charge of activities related to White Lake Management Ltd, Amerov supervised the agency network
and project activities, Kharina supervised financial products and developed them. Orlov was the director of the IT
department, later, at the suggestion of Z.V. Munayev, he took the position of the director of Q-BROKER Ltd. Timokhin
was head of the back office, Shaban was also in charge of something. Gramza was the chief accountant, Gramza was
500
in charge of everything related to accounting. Kuranina Lyubov worked in the direction of finance, Vasyukova was the
chief accountant of IC. Heads of sales departments were Korzh and Isaev (IRO direction), Zaitseva (agency network),
Ermolenko Stella, Balayan Ara, Maslennikov. Isaev had Murashev Aleksey, Anton Lazarev in his subordination. Also in
the office there was Linda, who was constantly doing something in a foreign jurisdiction. Linda's assistant was Marina.
Besides, Irina Nikolaevna Shpakova ofen came to the office from time to time, but she (O.R. Chisluk) does not know
what Shpakova was doing. Shpakova I.N. constantly told everyone off, scolded and everyone was afraid of her, tried
not to get in her sight. Her (O.R. Chisluk) salary was paid in "envelopes" and totalled 90,000 roubles a month. She was
paid her salary by different people: assistant girls, Amerov, Kuranina. At present, the company has not paid her two
months' salary;
(Vol. No. 269, pp. 78 - 81, 82 - 85)
I.A. Chupin's Testimony given as a witness,

according to which he started his labour activity in QBF Group of Companies in 2017 on the basis of an agency
agreement with LLC KF Estate SPB. Based on the employment contract No. KF070 dated 09.01.2018, he started to
perform the duties of the Head of Investment Services Department of LLC "KF Estate SPB", where the director was
Pakhomov Vladimir Sergeevich, who is a co - owner of QBF Group and responsible for the development of the
company's branch network in the regional RF. The place of work was in Tyumen. On the basis of employment contract
No. 09 - 21 dated 15.03.2021, he was employed by OOO IC QBF as director of the Tyumen branch. His job duties at
OOO IC KyoBeef as a branch director included managing the activities of the subdivision, representing the company's
interests in organisations and state authorities, organising the subdivision's participation in the development of new
and modification of existing regulatory documents, controlling the correct, timely and qualitative performance of the
subdivision's activities, and other duties in accordance with the requirements of the job description of the branch
director. At the time he entered into his employment contract, Stanislav Anatolyevich Matyukhin was the General
Director of QBIF LLC. The head of the company's branch network is Alexey Sergeevich Golubev, whom he has known
since January 2019, when A.S. Golubev was appointed head of the company's branch network. A.S. Golubev's job
duties included opening new offices of the company in the regions of the Russian Federation, material and technical
support of the company's offices, control over the activities of existing regional divisions, financing the activities of
regional divisions. A.S. Golubev also supervised the provision of monthly reports to the company's clients and co -
operation with the Moscow office, controlled the inflow of funds from clients. A.S. Golubev agreed with V.S. Pakhomov
on the strategy of development of regional subdivisions. The order of accepting clients for servicing depended on the
chosen investment product or the direction of the company's work and was regulated by the Central Office. All new
employees were provided with the relevant regulations for concluding contracts. In addition, regular training was
conducted to update the knowledge of all employees of the company in working with clients. Brokerage, advisory and
trust management services were offered to clients. These services were offered both within the Russian jurisdiction
and outside it (Cyprus - QCCI, former name QB Capital LTD; Cayman Islands - White lake Managejment, simultaneously
with the conclusion of agreements with Simtelligence Company LTD - Hong Kong and VL Consulting LLC - RF).
Brokerage service implies providing the client with access to trading on stock exchanges all over the world. Orders to
purchase specific securities are given directly by the client. Advisory management implies brokerage service with
additional service in the form of consultations of specialists and offering specific investment ideas to the client. Trust
management implies management of the client's funds by a portfolio manager within the framework of an
investment strategy with a certain level of risk agreed upon and fixed in the contract, with the aim of receiving income
from investment activities. The client is provided with information on all investment products of the company for
further independent choice. Since 2020, QBIF Ltd. started to offer its clients participation in IROs of foreign
companies. For this purpose, the client opened a brokerage account and concluded a framework agreement for the
structural product "IRO.XXX". This agreement described the general terms and conditions for the purchase of OTC
options on behalf of the client. This option reflected a change in the quoted share price of the company's stock that
501
went public on the IRO. The seller of the options was Q-BROKER LLC. The purchase on behalf of the client was carried
out by QBIF IK LLC. In addition, the company's investment products offered clients PAIs in open - end and closed - end
mutual funds managed by QBIF Asset Management LLC. OPIFs involved investments in shares and bonds traded on
Russian stock exchanges. ZPIF assumed investments in residential and commercial property. The company had both
an incoming flow as a result of marketing activity of the Moscow office and active attraction by the employees of the
branch. Cold calls were made to databases of potential clients, and there were contacts with clients with whom there
had been previous co - operation at previous places of work. In addition, personal and family connections of the
company's employees were involved. In the course of work with a potential client, as a rule, there was a meeting in
the company's office, where the client received information about the company and the investment products offered
by it. That is, information about the potential profitability and possible risks of investing. Afer making a decision, the
client would provide the financial advisor with documents (Russian/foreign passport, SNILS, TIN) and contact
information (email and mobile phone). On the basis of this, the financial advisor formed an application for
preparation of contracts and sent it together with the client's documents to the appropriate address of the company's
"middle" office or "back" office, depending on the investment products. In the reply letter the financial advisor
received a set of documents to be signed with the client. During the personal meeting with the client the contracts
were signed. Scan - images of signed agreements were sent to "mid" or "back" offices, original documents were
regularly sent to the central office. The signatory in Tyumen before the introduction of the electronic digital seal for
contracts of QBIF LLC was only Rykov D.I. Afer the introduction of the electronic digital seal, each employee could
enter the data of a new client into the database and Matyukhin S.A.'s electronic digital signature was placed. To
execute the OPIF, the client signed an application for the purchase of units, which was stamped with the signature of
Smirnova Yaroslava Gennadyevna, the General Director of QBF Asset Management LLC, and also stamped with the
organisation's seal, which confirmed the fact that the application had been accepted. For the strategy of investing in
international markets, a set of already signed documents with stamps was sent. Under the agreements with QBIF LLC
and QBIF Asset Management LLC, the client transferred funds to the details specified with reference to the concluded
agreement in the purpose of payment. The funds were then credited to his (the client's) brokerage account or trust
management account. For contracts with foreign companies, the client was issued an invoice with details for money
transfer to the company that is a party to the contract. To transfer funds in foreign currency, the client made a transfer
via the Swif system. Clients were also offered an alternative method of depositing funds with the company: the
relevant foreign company issued a receipt to the cash receipt order, which confirmed the fact of accepting cash for
further crediting to the brokerage or trust management account. These receipts were sent to regional staff together
with a set of contracts. The cash was accepted by the financial advisor working with the client. Then a courier sent by
the central office of IC QBEF LLC picked up the cash within a business day. This option was positioned as an additional
service for clients. The organisation's cash voucher to confirm acceptance of cash was issued from QCCI until the end
of 2017, from 2018 it was issued by White lake Managejment. Cash was encashed by Vladimir Maslennikov, V.S.
Pakhomov, A.S. Golubev, and Y.N. Orlov. He does not know who exactly prepared and executed reports to clients on
transactions on their brokerage account. One of the companies' e - mail addresses was used to send reports to clients
on Russian market products, while the other e - mail address was used to send reports on international markets.
There was a certain date when the report was to be sent to clients. All clients received mailings on the status and
changes in their brokerage or trust management accounts. Everything was uploaded from the sofware for the
Russian and international market, for the international market. Y.N. Orlov was responsible for the sofware (uploads)
(from the technical point of view), Maria Kopylova was responsible for the Russian market for the correctness of
compiling and filling in reports, and she was the head of the "middle" office. Areas of supervision were distributed
among the co - owners of the group of companies of QBIF LLC, namely, Munaev Zelimkhan Visaitovich was
responsible for the company's activities in Moscow, and Pakhomov V.S. was in charge of activities in St. Petersburg,
Yekaterinburg and Tyumen. V.S. Pakhomov was responsible for the overall coordination of activities for the
development of the region. At the beginning of 2019, V.S. Pakhomov started travelling frequently to the central office
located at: Moscow, Presnenskaya Naberezhnaya St., 8, p. 1, City Capital Tower. 1, Capital City Tower, and
subsequently remained in a management position at the head office in Moscow. A.S. Golubev, who previously headed
the St. Petersburg branch, was appointed to replace him in charge of the regional network. A.S. Golubev's deputy was
Gevorgyan Gevorg. His (Chupin I.A.) direct supervisor since 2017 was the director of the Tyumen branch D.I. Rykov,
502
who was officially employed by QBIF LLC. Afer D.I. Rykov was dismissed from the organisation, a formal employment
contract No. 09 - 21 dated 15.03.2021 was concluded with him (I.A. Chupin). He (Chupin I.A.) concluded contracts with
clients and he personally led his own clients, as there was a certain "pool" of contacts, acquaintances, which he did
not pass to anyone, and he himself led from the beginning to the end. The recommended term of conclusion of
contracts with clients is not less than 12 months. Trust management agreement is a three - year agreement with the
possibility of automatic prolongation, IPO was a regular brokerage account - an open - ended agreement, if the client
did not give an order to withdraw funds. To the best of his knowledge Q-BROKER Ltd did not hold a brokerage licence,
but there were plans to obtain such a licence in the future to use as a broker at a later date. At the end of 2019 and the
beginning of 2020, the first customer complaints were received under contracts in offshore projects about non -
fulfilment of obligations regarding the return of funds invested in stock markets. There were delays in the withdrawal
of funds, but the withdrawals were made - sometimes in instalments, sometimes with delays. On the Russian trust
management market all orders submitted by clients are also not executed. The organisation LLC IC QBF drops some
funds to the client's account, but it cannot sell securities, explaining it by a technical malfunction of the company.
Clients are offered to open any other brokerage account in third - party organisations engaged in brokerage services
with further transfer to the newly opened brokerage account from the account in QBIF LLC, thus the invested money
can be returned. Alexey Golubev or his deputy Gevorg Gevorgyan, both located in St. Petersburg, were the source of
information on any issues, including problems with the return of funds to clients. Questions were always addressed to
them and out of the many reasons given for the refund problem were as follows: pandemic, a foreign company is
being audited by the local regulator and this is slowing down the processes of the organisation, banks that serve the
company asked questions on compliance. In the Tyumen branch about 65 clients suffered from illegal activities. The
amount of money not returned to clients on the Russian market is about 150 million roubles, on the foreign market
about 400 million roubles. Roman Valeryevich Shpakov saw him once at the opening of the Tyumen branch. The
authorised person of R.V. Shpakov is Dmitry Vladimirovich Moskalyuk, he (D.V. Moskalyuk) has been working in OOO IC
QBF for more than 5 years and his place of work is in the branch of the company in St. Petersburg. According to the
information he received from clients, Moskalyuk D.V. proactively calls clients of the Tyumen branch in order to induce
them to continue investment activities with an unidentified investment fund, allegedly registered in the UK in London.
In addition to the facts known to him that R.V. Shpakov and Y.N. Orlov purchased real estate objects on the balance
sheet of OOO Q-BROKER using client funds, he learnt from social networks that the employees of OOO IC QBF
Vladimir Maslennikov and Maxim Fedorov became co - owners of a restaurant in Moscow. These persons were directly
related to the turnover of client funds;
(Vol. No. 269, pp. 86 - 92)
Evgeny A. Shalimov's Testimony as a witness,

according to which in 2021 his acquaintance Afanasyeva Yulia Sergeevna recommended him to come for an interview
for employment in the group of companies "QBF" for the position of junior financial adviser. Yulia Afanasieva worked
at QBF Group in the training department. In March 2021, he came for an interview at QBF Group. The interview was
conducted in several stages, at one of the stages he was interviewed by Ermolenko Stella, who was the head of one of
the sales departments of the group of companies "QBF", in one of the offices of the building "Capital City", business
centre "Moscow City", at the address: Moscow, Nab. Presnenskaya 8. On 16 March 2021, he was hired as a Junior
Financial Advisor in the Client Relations Department at K - Investment LLC. His duties included: searching and inviting
clients, informing clients for the sale of investment products and trust management of clients' invested funds,
opening brokerage accounts, analysing the financial portfolio. As a financial advisor, he sold the following products of
the company: IPO - over - the - counter assets, promissory notes. The organisations on behalf of which financial
products were sold were QBroker LLC and QBIF LLC. Attracting clients for the sale of the company's products could be
done through cold calls to potential clients or through social networks via various video bloggers. His direct
supervisor was Stella Ermolina, from whom he (E.A. Shalimov) received instructions on his work and also reported to
S. Ermolina on the results of his work. Stella Ermolina's supervisor was Korzh Andrei, and Korzh Andrei's supervisor
was Spinka Ruslan. His (E.A. Shalimov) salary was supposed to be approximately 80,000 roubles per month, but he
did not receive his full salary. The salary included fixed payments based on the results of plan fulfilment in the
503
amount, as well as % of the amount of funds raised. He received his salary in cash from Stella Ermolina, and he did
not sign any pay slip. Also in July 2021, he received a salary from Tatiana Zavyalova, who is the head of the Russian
Market Support Department. In turn, the wages were handed over to the employees by Bogdanova Kristina. During
the entire time he worked at K - Investment LLC, he attracted only one client and funds totalling approximately RUB
13,000,000. K - Investment LLC was part of the QBF group of companies. The office of K - Investment LLC was located
at the following address: 8, Presnenskaya Nab. Presnenskaya 8, Moscow City business centre, Capital City building.
The main activity of QBF Group was attracting clients for the sale of investment products and trust management of
funds invested by clients. The head of the group of companies "QBF" was Roman Valeryevich Shpakov. Roman
Shpakov's business partner was Munaev Zelimkhan. Spinka reported directly to Roman Shpakov about all activities of
the sales department. At the beginning of his working activity in the group of companies "QBF" he did not suspect
that the management of the company represented by Shpakov Roman, Munaev Zelimkhan, Spinka Ruslan and Korzh
Andrey could carry out fraudulent actions with the money of clients, as the company had a number of licences of the
Central Bank of the Russian Federation to carry out professional activities in the financial sphere. He began to have
doubts about the legality of the actions of the above - mentioned management of the "QBF" group of companies afer
law enforcement officers conducted investigative actions in the offices of the "QBF" group of companies in May 2021.
Afer unsuccessful attempts to withdraw their funds, the company's clients complained to QBF itself, and many clients
also went to court and law enforcement agencies to restore their violated rights. He worked at K - Investment LLC
until August 2021, and in September 2021, at the request of Stanislav Matyukhin, he was transferred to work at MC Moi
Finance LLC. On 20 September 2021, he was employed by MC Moi Finance LLC as a specialist in the support
department. He resigned from MC Moi Finance Ltd on 17 December 2021 at his own request. When Matyukhin
resigned from MC Moi Finansy LLC on his own volition in December 2021, upon payment of the two official salaries
due to him, he contacted Roman Shpakov and explained that Roman Shpakov was against the payment and only
approved the payment of one official salary. He (E.A. Shalimov) eventually resigned from MC Moi Finance LLC with a
payment of two official salaries by agreement of the parties, as I.V. Rybalka had given her consent to the payment of
two official salaries to him. LLC "MC Moi Finansy" was controlled by the management of the group of companies
"QBF" and directly by Roman Shpakov. In turn, Shpakov Roman appointed Matyukhin Stanislav, who was not legally
recognised as a member of MC Moi Finansy LLC, but the management of MC Moi Finansy LLC represented by Rybalka
I.V. reported to him. In addition, on the instructions of Matyukhin Stanislav, the director of LLC "MC Moi Finance"
Rybalka I.V. registered the telephone number of Matyukhin Stanislav in the bank where the current account of LLC
"MC Moi Finance" was opened to confirm the operations on the account. Thus, without the approval of Stanislav
Matyukhin, transactions on the account of LLC "MC Moi Finance" were not carried out. In LLC "MC Moi Finansy"
management of the group of companies "QBF" introduced participants affiliated to them and directly to Roman
Shpakov, which included Spinka Ruslan, Korzh Andrey, Frolov Vladimir, Gramza Ekaterina, Fedorov Maxim, Amerov
Rinat, Tallerov Artem, Bogdanova Kristina, as well as Matyukhin Stanislav's mother. Thus, by the unanimous decision
of the majority of participants of the Company favourable decisions were made for the management of the group of
companies "QBF" and directly to Roman Shpakov, and the director of LLC "MC Moi Finansy" Rybalka I.V. in turn
fulfilled the will of the majority of participants. During his work in "MC Moi Finance" LLC, he (E.A. Shalimov) repeatedly
fulfilled the requests of Stanislav Matyukhin to meet with Ivan Andreyevich Somov on the subject that at that time
Somov I.A. was the general director of "QBroker" LLC, on behalf of which various contracts were concluded with the
clients of "QBF" company, and the clients' funds were accumulated on the settlement accounts of "QBF" LLC. The
subject of his meetings with I.A. Somov was as follows: he (E.A. Shalimov) would hand over to I.A. Somov for signing
the documents prepared and handed over to him (E.A. Shalimov) personally by Stanislav Matyukhin, and afer the
documents were signed by I.A. Somov himself, he would bring them back and hand them over to Stanislav Matyukhin.
These documents, which he handed over to Somov I.A. for signature, were client applications, where on behalf of a
client of QBF company a statement was drawn up on the client's wish to transfer the funds on the accounts of IK QBF
LLC under agreements with QBroker LLC to the accounts of MC Moi Finansy LLC. He suggests that in this way the
management of QBF represented by Roman Shpakov had the opportunity to further withdraw client funds through
organisations controlled by Roman Shpakov and involving persons affiliated to Roman Shpakov, including Stanislav
Matyukhin and Ivan Somov. In approximately July - August 2021, at work, he communicated with one of QBF Group's
financial advisors, Alexey V. Chentsov, who offered to assist his (E.A. Shalimov's) clients. Chentsov Alexey's help
504
consisted in the following: he (E.A. Shalimov) had to find a client of the company who was ready to get his money back
on condition of payment to A.V. Chentsov directly in the amount of 20 per cent of the money he had invested.
According to Chentsov's terms, it was necessary for the client to transfer or hand over 50% of the amount of
remuneration due to Chentsov A.V., afer which the client could expect to receive his invested money. Afer the client
received the invested funds, the client (E.A. Shalimov) would remit or transfer the remaining 50% of the remuneration
to A.V. Chentsov;
(Vol. No. 270, pp. 18 - 22)
A.A. Shoshin's Testimony given by him as a witness,

according to which since 19 October 2020 he has been the head of the Sales and Business Development Department
of the marketing direction of Noa LLC. His workplace is the office premises at the address: Moscow, Khilkov pereulok,
d. 1, office 19, room 4. He was interviewed for employment by Alexander Nepomnyashchy, general director of Noa
LLC. The above organisation provides consulting services, namely assistance to individuals in filing declarations with
tax authorities, other activities of the organisation. His job duties include the development of social networks
(Facebook, Instagram, and others), as well as the organisation and conduct of webinars, seminars, namely he (A.A.
Shoshin) had to notify the listeners of the time, date and subject of the seminar, as well as if necessary to collect
questions from participants about the seminar for the speaker. He did not directly participate in the seminars, but was
only the administrator of the seminar. He (A.A. Shoshin) received all tasks directly from the General Director Alexander
Nepomnyashchy. The topics of future seminars were given to him by Nepomnyashchy Alexander, and he looked for
individuals - participants of the seminar himself through advertising on the Internet, mailings in social networks, as
well as individuals on the recommendation of the general director. These seminars are necessary for business
development, as well as for attracting new customers. So he remembered that the seminars were held on the
following topics: "Changes in personal income tax in 2021", "Taxation of individuals in the Russian Federation", other
topics related to economic topics. These seminars were held free of charge. No contracts were signed for these
seminars. The seminars were held on the open platforms "YouTube", "May On Conference", where everyone could join
the viewing. He has heard the name of the organisation QBEEF LLC, he knows that it (QBEEF LLC) works in the field of
finance. He is aware that Noah Ltd employs a woman called Linda, he does not know her (Linda's) surname;
(Vol. No. 270, pp. 24 - 27)
Yudin M.S.'s Testimony given by him as a witness,

according to which he has a higher education as an information technology engineer. Prior to QBF LLC, he was not
officially employed anywhere. In 2011, while looking for a job on one of the Internet sites, he became aware of the
company QBF LLC. He contacted an employee and was invited for an interview, which took place at the following
address: Moscow, Krasnaya Presnya Street. Afer the interview, he signed an employment contract in May 2011. From
May 2011 to May 2012, he held the position of a financial advisor and his job duties included communicating with
clients and searching for clients. From May 2012 to 2014, he held the position of Head of Sales and his duties included
communicating with clients, advising them on QBIF LLC's products, such as "trust management" (which involved
managing clients' assets) and "brokerage services" (self - trading by clients), and training employees. From 2014 to
December 2015, he worked as Deputy Director of the Sales Department, where his job duties included communicating
with clients, advising them on QBiEF IK LLC products, and training employees. From 2015 to August 2019, he served as
Director of Sales Management. There, his job duties included communicating with customers, advising them on QBIF
LLC's products. In August 2019, he resigned from QBIF LLC at his own request and was subsequently employed by
Eleon LLC as an operations director, where there were more attractive working conditions. He could sign contracts
505
with clients who wanted to buy QB Capita products with access to the foreign market on the basis of a power of
attorney issued by QB Capita LTD in the absence of a back officer whose duties included signing the contract. He could
also sign contracts with customers who wanted to buy products of QB Capita LTD with access to the Russian market
on the basis of a power of attorney issued to QB Capita LTD in the absence of a back officer whose duties included
signing this contract. His direct supervisor at OOO IC QBF was Stanislav Anatolyevich Matyukhin, before him Vladimir
Georgievich Frolov. His (Yudin M.S.) subordinate was Nikolai Sergeyevich Padalko. In his work he (Yudin M.S.) followed
the instructions of Matyukhin S.A. To sign contracts in Russia and to buy Russian products, he was given a power of
attorney from the company QBIF LLC, provided that the client buys products with access to the Russian market and a
power of attorney from QB Capita LTD if the client buys products with access to a foreign market. The specificity of QB
Capita LTD activity was access to foreign markets when clients wish to buy products on a foreign market. He may have
encountered the name QCCI Ltd in documents when working for QB Capita LTD. In order to sign contracts, when the
client wanted to participate in trading on international stock markets, he signed contracts on the basis of existing
powers of attorney issued by QB Capita LTD and QCCI Ltd, in the absence of a back officer whose duties included
signing these contracts. The client was provided with two documents: a "direct access to the securities market"
agreement on behalf of QB Capita LTD and a "trust management" or "brokerage" agreement on behalf of IC QBiEF
Ltd. If the client, wishing to participate in trading on international stock markets, concluded a "trust management"
agreement with the company IC QBife Ltd, then in the future, all issues related to the purchase and sale of shares on
behalf of the client were handled by the employees of IC QBife Ltd. He knows the following employees of the
company in the following positions: Ruslan Valeryevich Spinka, Grigor Razmikovich Erzikyan, Andrey Vasilyevich
Korzh, Yulia Sergeevna Zaitseva, Daria Yuryevna Meshkova, Pavel Yuryevich Vlasov, Kirill Sergeevich Sobolev -
financial advisors; Nikolay Sergeevich Padalko - head of sales department; Yuri Orlov - IT department employee; Rinat
Amerov - sales manager; Vladislav O. Plitin - head of sales department; Vladimir G. Frolov - general director of OOO IC
QBF; Roman V. Shpakov - owner of OOO IC QBF; Munaev Zelimkhan Visaitovich - engaged in sales, but it is difficult to
name his position; Matyukhin Stanislav Anatolievich - General Director of OOO IC QBF; Rossieva Evgenia Anatolievna -
lawyer; Lepeshkin Dmitry Sergeevich - engaged in sales; Smirnova Yaroslava Gennadyevna - General Director of QBF
Management Company; Vozhzhov Alexander Fedorovich - marketing specialist; Kozyreva Ekaterina Yurievna -
engaged in sales; Kharina Ekaterina Nikolaevna - productologist; Timokhin Oleg Yurievich - back office document
officer. The positions of the following employees: Vladimir Sergeyevich Pakhomov, Elena Vyacheslavovna Gorobets,
Linda Athanasiadou , Yuri Vasilievich Shaban, Alexei Sergeyevich Golubev are difficult to name;
(Vol. No. 270, pp. 34 - 48)
- I. A. Yurlova's Testimony given to her as a witness,

according to which her husband Valery Ivanovich Yurlov, born on 03.10.1932, is an artist and is a member of the
Moscow branch of the Creative Union of Artists. About the end of 2018 - beginning of 2019 their acquaintance Ivan
Dmitrievich Yakusikin asked to accept an American photographer who wanted to make a portrait of Yurlov V.I. At the
meeting with Yurlov V.I. together with the American photographer came a Russian girl who introduced herself as
Gormeneva Margo. Afer some time, she (Yurlova I.A.) received a phone call from Ivan who informed her that
Gormeneva Margo was interested in the works of Orlov V.I. and wanted to create a fund where these works would be
presented and since they (Yurlova I.A. and Yurlov V.I.) were not against Gormeneva Margo.) were not against
Gormeneva Margo came to the studio of Yurlov V.I. There Gormeneva M. photographed in their presence more
paintings, and also expressed a desire to buy some works of Yurlov V.I. for the amount of 40 - 50 thousand U.S. dollars.
Afer this visit Margo disappeared. I.A. Yurlova began to look for information about the photographer who had visited
them and about Margo Gormeneva. Her acquaintances advised her (Yurlova I.A.) not to get in touch with this fund and
also not to get in touch with Gormeneva Margo. A few months later Gormeneva Margo called back, but she (Yurlova
I.A.) explained that they (Yurlov V.I. and Yurlova I.A.) would not sell the paintings. Afer that Gormeneva M. called them
several more times with an offer to buy the paintings;
506
(Vol. No. 270, pp. 55 - 58)
- The testimony of N.G. Yakubova, given to her as a specialist,

according to which she is an associate professor at the All - Russian State University of Justice (RPA of the Ministry of
Justice of Russia). She graduated from Volgograd State University with the qualification "Lawyer, speciality
"Jurisprudence" and from the All - Russian Academy of Foreign Trade of the Ministry of Economic Development of the
Russian Federation with the qualification "Economist with knowledge of a foreign language, speciality "World
Economy" (diploma with honours), defended her thesis for the degree of Candidate of Legal Sciences, speciality
12.00.10 "International Law. European Law" at the Peoples' Friendship University of Russia. She has more than 20
years of practical experience in the field of jurisprudence. On 25 February 2021, at the request of V.S. Gorkavtsev,
Deputy Head of the Main Department of Economic Security and Anti - Corruption of the Ministry of Internal Affairs of
Russia, dated 10 February 2021, No. 7/18 - 2040, she prepared a specialist's opinion. This opinion consists of two
parts, conclusions and annexes (108 pages in total). The first part contains a legal assessment of the factual situation
of the relationship between Borzenkov M.I., QBF LLC and the Cypriot company QB Capita LTD. The second part
provides an answer to the question of whether the activity of QBMF LLC and the Cypriot company QB Capita LTD with
the funds of Borzenkov M.I. is an investment activity. The conclusions set out the results of the study. Four documents
from open sources used by the specialist are added as annexes to the conclusion. As a result of the conducted
research on the basis of the presented documents and available information, it is concluded that M.I. Borzenkov's
funds cannot be considered as investments both from the point of view of Russian law and international investment
law. The activities in relation to these funds of both Borzenkov M.I. himself and IK QBF LLC and QB Capita LTD cannot
be regarded as investment activities. The factual circumstances testify to unlawful and unfair behaviour of the
participants of the legal relations under consideration. In her opinion, here they faced with an elaborate scheme
aimed at withdrawal of funds from the hands of their owner to unknown structures, as evidenced in particular by the
following circumstances: Borzenkov M.I. transferred funds totalling $17,000,000 under contracts with interrelated
companies having one beneficial owner and the alleged one circle of related persons. During the entire period of
validity of the contracts, M.I. Borzenkov did not receive any proper report on the activities declared by the companies,
which would allow to establish a legal connection between M.I. Borzenkov as a subject of law and the securities
constituting the investment portfolio as an object of law. M.I. Borzenkov had no independent access to the accounts.
There are no documents confirming M.I. Borzenkov's ownership of securities. Possible placement of M.I. Borzenkov's
funds on accounts possibly belonging to him is not an investment activity. Investment activity is the actual placement
of funds in securities, which must be confirmed by appropriate documents. In this case, there are no such documents,
nor is there any document that would confirm that this activity was carried out. M.I. Borzenkov as an individual was
misled by QB Capita LTD and the company. Firstly, when entering into agreements with QB Capita LTD on the
provision of trust management services, M.I. Borsenkov obviously believed that he was entering into a securities trust
management agreement with a professional participant of the securities market, the activities of which are regulated
and controlled by the Central Bank of the Russian Federation. In reality, according to the content of the agreements,
under the guise of trust management agreements, M.I. Borzenkov entered into assignment agreements. Display in the
title and subject of these contracts of contradictory wording, affecting the legal nature of the contract and misleading
the counterparty - individual, is evidence of illegal actions and bad faith on the part of LLC IC QBF. Secondly, according
to the information from the Extract from the Unified State Register of Legal Entities No. SE 9965 - 21 49982414 dated
11 February 2021 in respect of IC QBF LLC, the licences of the Central Bank of the Russian Federation for dealer
activities, brokerage activities and securities management activities of IC QBF LLC started to be valid on 22 June 2016,
the licence of the Central Bank of the Russian Federation for activities of professional securities market participants -
on 8 August 2019. This information suggests that at the time of conclusion of the first contract with M.I. Borzenkov on
28 April 2016, QBIF LLC did not have a licence to carry out dealer activities in securities management and activities of
507
a professional securities market participant. It is unlawful to carry out licensed activities without a licence. Thirdly,
the actual conclusion of assignment agreements with QBIF LLC in relation to the management of Borzenkov M.I.'s
trading accounts opened by QB Capita CY LTD in his (Borzenkov M.I.'s) name did not comply with the requirement of
the agreements concluded between Borzenkov M.I. and QB Capita LTD that the transfer of account management
rights can be carried out only on the basis of a trust management agreement. QBIF LLC had no legal grounds to
conclude agreements with Borzenkov M.I., the subject of which is the execution of purchase and sale transactions of
securities, derivatives and other instruments within the framework of the trading account opened in accordance with
the agreements concluded by Borzenkov M.I. with QB Capita CY LTD. Firstly, the company QB Capita CY LTD had the
signs of an organisation actually not carrying out financial and economic activities, which was established by the
Decision of the Ramenskiy City Court of the Moscow Region in case No. 2 - 5956/2017 of 11 December 2017. Secondly,
QB Capita CY LTD had no legal grounds to engage in the type of activity related to the performance of transactions
with securities, as this type of activity in accordance with the legislation of the Republic of Cyprus is subject to
compulsory licensing, and QB Capita CY LTD did not have a statutory licence from the Cyprus Securities and Exchange
Commission (CYSEC), as established by the Decision of the Court of 11 December 2017. Thirdly, QB Capita CYҮ LTD was
not actually located at its registered office, as established by the Court Decision of 11 December 2017. The address
indicated in the agreements with Borzenkov M.I. did not coincide with the legal address of the company QB Capita
LTD, which is registered in the public database of the Republic of Cyprus. Fourthly, according to the information about
the company QB Capita CY LTD, which is contained in the public database of the Republic of Cyprus on 7 August 2018
in respect of the company in the Register there is a record: "Dissolution following Voluntary Liquidation" (dissolved,
due to voluntary liquidation), about which no one officially notified Borzenkov M.I.. Fifh, contracts and agreements
with M.I. Borzenkov were signed on behalf of QBIF LLC and QB Capita CY LTD by the same persons (K.S. Sobolev and
M.S. Yudin) under powers of attorney. Sixthly, the signs of affiliation of IK QBlife LLC and QB Capita CY LTD, established
by the Court Decision of 11 December 2017, were expressed, in particular, in the following. Both companies operate
under the abbreviation (brand) "QB". On behalf of both companies (both QB IC QBiEF LLC and QB Capita CY4AE↩
LTD), the contracts with the plaintiff were signed by the same person who, according to the data of the Unified State
Register of Legal Entities, owns 6% in the authorised capital of QBUBI GROUP LLC, which is the sole participant
(founder) of QB IC QBiEF LLC. In addition, according to the response to the judicial enquiry received from the Joint
Stock Company "Regional Network Information Centre" both domain names qbfin.ru (the domain name of the
Respondent QB IF LLC, which is reflected directly in the Agreements with the Complainant) and qbcap.com (domain
name QB Capita CY LTD) are registered to the same individual, who according to the data of the Unified State Register
of Legal Entities owns 88% in the authorised capital of QB GROUP LLC, being the sole participant (founder) of the
Respondent QB IC QBF LLC. The conclusion of the forensic computer - technical expertise established that there are
indications that electronic messages from the mail addresses @qbfin.ru and @qbcap.com were actually sent using
the same infrastructure, mail servers and IP addresses. Seventh, QB IC QBfin LLC could not have been unaware of the
stated violations of the law committed by QB Capita CY LTD due to the clearly expressed signs of affiliation of QB IC
QBfin LLC and QB Capita CY LTD, as established by the Court Decision dated 11 December 2017. Eighth, the presented
financial documents on the cash flow on the account of QB Capita CY LTD in Direktna Banka a.d.Kragujevac (Serbia)
allow to assume that it was at the expense of the funds received by Borzenkov M.I. on this account during a certain
period that QB Capita CY LTD made its payments. In addition to the above, the study was based on the documents
and information provided at the time of preparation of the Conclusion (10 - 25 February 2021). At that time certain
circumstances required additional clarification, which was indicated by the specialist in the text of the Conclusion. In
the expert's opinion, for the legal assessment of the factual situation of the relationship between M.I. Borzenkov, QBF
LLC and the Cypriot company QB Capita CY LTD, the materials of the case No. 2 - 5956/2017, which is similar in factual
composition and in which the Ramenskiy City Court of the Moscow Region issued a decision on 11 December 2017,
are of interest;
(Vol. No. 270, pp. 59 - 63)
508
- A. A. Khairullin's testimony, given by him as a witness,
according to which, he worked in the period from February 2017 to August 2021 in LLC "776" as a sales manager,
analyser of services provided by the group of companies QBF. The number of employees of the regional office of the
group of companies located at the address: Ekaterinburg, B. Yeltsina St., 1a, office. 1204 at different times was about 5
- 8 people, namely: Iskhakov Evgeny Valeryevich - deputy branch manager, Kirill Sergeevich Sobolev - branch
manager, Kirill Bogdanov - branch supervisor, Venera Azatovna Zhdanova - sales manager, Evgeny Balabukha - branch
manager, Evgeny Viktorovich Shipitsin - sales manager. His (Khairullin A.A.) duties in accordance with his position
included consulting clients on the company's products, assistance in execution of an electronic contract in the Nabix
system. He consulted the following clients: Irina Viktorovna Eromova, Konstantin Sergeyevich Perminov, Elena
Sergeevna Tkachuk, Olga Nikolaevna Kozhevnikova. By e - mail or by simple mail the head office (in Moscow or St.
Petersburg) under existing contracts sent documents with details of foreign companies, which had to be signed by the
clients, stipulating that the clients were familiarised. He invited these clients to a meeting and they signed these
documents. Letters and instructions of this kind to be signed by clients were handed to him in paper form by Yevgeny
Iskhakov. Seminars in the company were held mainly in the format of videoconference by different employees of the
head office, mainly by the main Pakhomov Grigory on the subject of "Stock Market", several times employees of the
head office - Golubev Alexey and Ikonnikov Denis came. They conducted tests at the end of the trainings. The client of
Kyobi group of companies, wishing to participate in trading on international stock markets, was provided (with QB
Capital LTD documents) with a contract signed by EDS on both sides, these documents were sent by e - mail from the
head office directly to the client. The documents were prepared on the basis of data (passport data, bank details and
TIN) which he entered into the Nabix system. He had no access to client data. He saw the contracts signed by both
parties with the clients. The trust management agreement was concluded on behalf of IK QBIF LLC, as the
organisation was licensed by the Central Bank of the Russian Federation for trust capital management. Documents
with the names of companies "QCCI Ltd.", "White Lake Management Ltd" and "SIMTELLIGENCE COMPANY LIMITED"
were sent by e - mail or regular mail with the instruction "to sign from clients". He did not personally handle client
cash himself, but he had heard that there were occasional instances of cash being accepted at their office. He was
subordinate to Alexei Sergeevich Golubev, the director of the regional network. R.V. Shpakov, V.S. Pakhomov, Z.V.
Munayev were introduced to him as founders and shareholders of QBF group of companies. He is aware of the
following employees in the following positions: Ruslan Valeryevich Spinka - manager from the head office, employee
of QBF IK LLC; Yuri Nikolayevich Orlov - General Director of QBF.Broker"; Korzh Andrey Vasilyevich - an employee from
the head office, which company, he does not know; Zaitseva Yulia Sergeevna - an employee from the head office;
Pakhomov Vladimir Sergeevich - one of the shareholders of the group of companies; Yudin Maxim Stanislavovich - an
employee of the head office; Roman Valerievich Shpakov - one of the shareholders of the group of companies;
Zelimkhan Visaitovich Munaev - one of the shareholders of the group of companies; Stanislav Anatolievich Matyukhin
- General Director of OOO IK QBF and he was in Moscow, I saw him only once at a conference in Yekaterinburg, S.
Matyukhin's electronic signature is on all documents of the company.A. is on all the documents of IC QBF LLC; Evgenia
Anatolievna Rossieva is an employee of the head office; Kirill Sergeyevich Sobolev is the head of the office of IC QBF
LLC; Aleksey Sergeyevich Golubev is the director of the regional network, he is in St. Petersburg, I communicated with
him only within the framework of his activity report; Yaroslava Gennadyevna Smirnova is the head of CBF UA LLC;
(Vol. No. 270, pp. 93 - 100)
- The testimony of V.A. Zhdanova, given to her as a witness

, according to which, she worked in the period from September 2020 to June 2021 on the basis of an employment
contract at LLC "776" as a consultant - as a counsellor. Her duties included counselling clients in person and
over the phone on QBF financial products, assisting in the execution of an electronic contract in the Nabix system. The
509
headcount of the regional office located at the following address: Ekaterinburg, B. Yeltsina St., 1a, office 1204 at
different times was as follows. 1204 at different times was about 4 people: Iskhakov Evgeny - financial advisor,
Khairullin Artem - financial advisor, Lomakina Olga - secretary, Balabukha Evgeny - branch manager. Training
seminars were held mainly in video conference format by various employees of the head office, mainly by Grigory
Pakhomov on the subject of "Stock Market". The trust management agreement with the client was concluded on
behalf of IK QBF LLC, which had a licence from the Central Bank of the Russian Federation for trust management of
capital. She (V.A. Zhdanova) was subordinate to the regional head, Alexey Golubev. Shpakov R.V., Pakhomov V.S.,
Munaeva Z.V. were introduced to her as owners of QBF group of companies. She knows that the following employees
worked in the QBF group of companies in the following positions: Roman Valeryevich Shpakov - one of the owners of
QBF companies; Zelimkhan Visaitovich Munaev - one of the owners of QBF companies; Stanislav Anatolievich
Matyukhin - General Director of LLC IK KyoBiEF; Alexey Sergeevich Golubev - Regional Head of QBF, located in St.
Petersburg;
(Vol. No. 270, pp. 101 - 107)
- The testimony of Lukisha V.V., given by him as a witness,

according to which, from 2019 to June 2020, he was employed as the head of the branch of QBF in Murmansk. At the
time of his employment, the branch had 2 employees - Dmitry Stetsenko and him (Lukisha V.V.). His duties included
managing one employee, organising work, attracting clients. He knew the following employees of the group of
companies "QBF": Alexey Golubev - sales director of the St. Petersburg branch; Gevorg Shakespevich Gevorgyan -
director of the St. Petersburg branch; Vladimir Sergeyevich Pakhomov - head of the branch network; Ekaterina
Marcinyuk - chief accountant of the St. Petersburg branch. He was in contact with potential (current) clients through
means of communication and personal meetings on the issues of placement of funds in securities on the stock
markets of the Russian Federation and abroad. Among the clients he remembers only Samuil Zakharovich Raizman,
born on 30.11.1945 in Maykop, Krasnodar Territory. Training in the areas of selling the company's products, attracting
clients was conducted and managed by Alexey Golubev and Gevorg Gevorgyan. He communicated with clients on the
settlement of debts of Kyubi Group, accepted, sent an application for withdrawal of funds, and then clients applied to
the St. Petersburg office. The process of receipt of funds received from clients was as follows: the client was provided
with details of the payment order for transfer of funds under the trust management agreement non - cash through the
bank, and when it was convenient for the client in cash, an application for preparation of documents was formed, this
application was sent by e - mail to the chief accountant (Martsenyuk), the date of the transaction was set, then on the
appointed date a courier in the person of Gevorg Shakespyrovich Gevorgyan or Golubev Alexey Golubev arrived at the
branch office in St. Petersburg. In the branch office located in Murmansk the funds as dividends in cash were not given
to the clients, but were credited to the settlement accounts in the bank. Within 30 days, based on the clauses of the
contracts concluded on behalf of White Lake Management LTD, afer the client signed a notice of withdrawal of funds
from his trading account, the companies were obliged to return the funds. The managers of the company QBF were
R.V. Shpakov, V.S. Pakhomov, Z.V. Munayev. The actual address of the representative office of the company "White
Lake Management LTD" was in Moscow, he does not remember the exact address. The main activity of the company is
placement of clients' funds in securities on the international market. They (Lukisha V.V. and Statsenko D.) were shown
the licences of the company "White Lake Management LTD" by the management of the company by reference, which
they in their turn subsequently showed to the clients on their working laptop. He and his subordinate familiarised the
clients with the services of "White Lake Management LTD" in the city of Murmansk, but were represented by Gevorg
Gevorgyan and Alexey Golubev. A client of the Kyubi Group of Companies, wishing to participate in trading on
international stock markets, was provided with the following documents (indicating on behalf of "White Lake
Management LTD"): trust management agreement, strategy, questionnaire and other documents. The trust
510
management agreement was concluded on behalf of IK QBF LLC, it was signed by him (Lukisha V.V.). The client of
"White Lake Management LTD" wishing to participate in trading on international stock markets was provided with
services on placement of clients' funds in securities. The process of purchasing shares on behalf of clients on
international stock markets through "White Lake Management LTD" looked as follows: the client concluded an
agreement, transferred funds according to the details, the client received a report by e - mail, which reflected what
securities and assets and their value the client had. Alexey Golubev and Gevorg Gevorgyan provided accounting
support for the Murmansk branch from St. Petersburg;
(Vol. No. 270, pp. 109 - 115)
- D.N. Statsenko's testimony, given by him as a witness,

according to which from April 2019, he (D.N. Statsenko) was employed by the director of the branch of IC QBF in
Murmansk Lukisha V.V. to the position of deputy head of the office, working until October 2020. He was not legally
employed by QBIF as there was limited recruitment at QBIF LLC, but in fact he helped to attract and advise clients at
QBIF LLC. The staff number of the branch was 2 persons, he (D.N. Stetsenko) and V.V. Lukish. He knows the following
employees of LLC IC "QByEF": Alexey Golubev, Gevorg Shekspirovich Gevorgyan. During his employment, his duties
included attracting and consulting potential clients. He contacted potential clients through means of communication
and at personal meetings, on issues related to placement of funds in securities on the stock markets of the Russian
Federation;
(Vol. No. 270, pp. 139 - 142)
- Stepanov A.N.'s testimony, given by him as a witness,

according to which in the period from 13.04.2021 to 12.07.2021 he was the head of the Kazan branch of the company
LLC IC QBF, located in one of the offices on the 2nd floor of BC "Suvar" at the address: 6 Spartakovskaya Street, Kazan.
His job responsibilities included managing the branch office and representing interests before state and commercial
organisations. Officially, he was alone in the staff of the company, as well as he was assisted by his assistant -
secretary Ermolaeva Anastasia, whom he paid himself. Directly from the QBF group of companies he had contact with
A.S. Golubev, who introduced himself to him at the first meeting in Moscow as the head of the branches. He also
knows his (A.S. Golubev's) assistant Gevorg Gevorgyan. The head of the Kazan branch before him (A.N. Stepanov) was
Denis Mikhailovich Kharlashin. He also communicated with a girl named Zarina, who worked in the St. Petersburg
branch. At the time of the existence of the Kazan branch there were about 18 clients. The branch had no authority to
conclude contracts. From the branch office they sent the clients' data to the back office of the company, then from
there they sent a contract to the client's mailbox, which was signed with an electronic signature or handwritten. This
document was scanned and sent back. He communicated with clients of the Kazan branch to withdraw money from
QBIF LLC using other assets. He initially told A.S. Golubev that he would work with them only within the framework of
QBF LLC, which is regulated by the Central Bank. In fact, Roman Shpakov was the head of QBF company. He has heard
about Pakhomov V.S. and Munayev Z.V. that they are also managers, but he does not know their exact positions. He
knows that the following employees worked in the QBF group of companies in the following positions: Ruslan
Valeryevich Spinka - Head of Sales, known as an asset manager; Grigor Razmikovich Erzikyan - Senior Advisor; Yuri
Nikolayevich Orlov - Director of "QBF" LLC; Andrey Vasilyevich Korzh - Deputy of Ruslan Spinka; Roman Valeryevich
Shpakov - major shareholder of "QBF" financial group; Zelimkhan Visaitovich Munaev - one of the managers of "QBF"
financial group; Stanislav Anatolievich Matyukhin - General Director of QBF IK LLC; Evgenia Anatolievna Rossieva -
511
company lawyer; Linda Athanasiadou - co - organiser and also did accounting for foreign companies; Alexey
Sergeevich Golubev - head of QBF branch network; Yaroslava Gennadievna Smirnova - General Director of QBF Asset
Management Company; Yuri Vasilievich Shaban - engaged in mutual funds in the company;
(Vol. No. 270, pp. 145 - 153)
- The testimony of D.M. Kharlashin, given by him as a witness,

according to which from 2008 to 2021 he worked in the banking sector. From March to April 2021 he worked in the
company LLC IC QBF as a director of the Kazan branch. His duties included general management of the branch,
consulting clients of the branch. The branch was located at 6, Spartakovskogo Street, Kazan, 2nd floor, office 201 and
was engaged in securities activities. In addition to him, the branch office was staffed by Artem Nikolaevich Stepanov,
who held the position of agent and initiator of the Kazan branch of QBIF LLC, as well as his (Stepanov A.N.) assistant
Ermolaeva Anastasia Viktorovna. During his work, from the group of companies QBF he co - operated with A.S.
Golubev, who was the head of the network of branches of LLC IC QBF and was located in St. Petersburg. Also he (D.M.
Kharlashin) knew his direct supervisor Gevorg Shekspirovich Gevorgyan, who supervised the organisation of sales of
branches, he (Gevorgyan G.Sh.) was located in St. Petersburg. I also knew Zarina, who worked in the St. Petersburg
branch and helped the Kazan branch in the part of client registration in the accounting system of QBIF LLC. According
to his job description, he interacted with clients of the branch both in person and by telephone or any other internet
messengers. During the period of his work, approximately 10 - 15 clients contacted QB&EF LLC, the data on which is
stored in the accounting systems of QB&EF LLC. All documentation was prepared and signed by the back office
located in St. Petersburg. During his employment there was one training in the format of video - conference "Skype",
where he was told about the company LLC IC QBF, the company's opportunities for clients. This training was
conducted by Anton Porfiriev, who was responsible for training new employees. In order to work on the Russian stock
market, clients who opened brokerage accounts were obliged to deposit money by bank transfer to the details of QBF
LLC, which indicated the number of the brokerage account and information about the date of opening the brokerage
account, the purpose of payment. The actual head of QBF company is Roman Shpakov. He (D.M. Kharlashin) knows
the following employees of the company who held the following positions: Yuri Nikolayevich Orlov - Director of QBF
Broker LLC; Roman Valeryevich Shpakov - beneficiary of QBF Financial Group; Stanislav Anatolievich Matyukhin -
General Director of QBF IC; Aleksey Sergeevich Golubev - Head of the branch network;
(Vol. No. 270, pp. 155 - 163)
- A. V. Ermolaeva's Testimony given to her as a witness,

according to which she was not officially employed in the group of companies "QBF". Her acquaintance Stepanov
Artem Nikolaevich, who from April 2021 to July 2021 was the head of the branch of the company "QBF" invited her
(Ermolaeva A.V.) to become an assistant. She worked unofficially. The office of the branch office of the company was
located on the 2nd floor of BC "Suvar", located at 6 Spartakovskaya Street, Kazan. She assisted in the labour activity of
Stepanov A.N., who gave her (Ermolaeva A.V.) contacts of persons unknown to her who were interested in the
activities of the company "Qubifef". She telephoned the clients and voiced the list of necessary documents to
conclude contracts with the company "QBEEF". The client would then contact QBEEF representatives with the help of
her email counselling, provide their personal data and sign the contract. She got 5 customers who came to the branch
office. As the branch office had no authority to conclude contracts, the clients' data was sent to the main office and
512
from there the contract was subsequently sent to the client's e - mail account. The contract was signed by the client
using an electronic signature or handwritten, the document was scanned and sent back;
(Vol. No. 270, pp. 166 - 174)
- E.E. Pasenko's Testimony given to her as a witness,

according to which, in the summer of 2020, her CV posted on the website "hh.ru" was responded to by the HR
specialist of the QBF Group, Alexandra Lvova. She invited her (E.E. Pasenko) to an interview at the company's office,
which was located at: St. Petersburg, 11 Degtyarny Lane, St. Petersburg, Russia. At the meeting Alexandra told her
about the position of a secretary for which she (E.E. Pasenko) was being considered. She (E.E. Pasenko) was interested
in the offer. Alexandra told about the principles of work, as well as the responsibilities of the position. At that moment
she (E.E. Pasenko) was satisfied with everything, so she agreed. The selection process took place in two days, afer
which the chief HR specialist Dina Munasypova and then the head of the administrative department Kateryna
Martsinyuk communicated with her. On the second day, Ekaterina Marcinyuk informed her that she (E.E. Pasenko) was
accepted for the position. Her duties included: receiving and sending correspondence, ordering stationery, keeping
the office clean, meeting clients. Periodically she was puzzled by Pakhomov Vladimir Sergeevich - shareholder of the
company "QBF". He called himself the general director of the branch network "QBF" (he managed all the offices of the
network, not counting the office located in Moscow). He would ask her to order his cat a suit for a holiday or to order
him clothes from the DLT shop. Her workplace was in the office at the above address (on the 6th floor). Her direct
supervisor was Ekaterina Olegovna Martsinyuk. The head of the St. Petersburg office of QBF Group of Companies was
nominally Alexey Sergeevich Golubev. He set tasks for the office staff and held meetings. One of A.S. Golubev's
deputies was Gevorgyan Gevorg Shekspirovich, he was in charge of financial advisors, i.e. sales department. In fact,
the head of the entire branch network of the St. Petersburg office was V.S. Pakhomov. Her monthly salary was 40,000
roubles, which was given to her in cash by Ekaterina Martsinyuk. As a rule, there were various difficulties in making
these payments, as the "salary" was delayed each time. No one explained why this happened. In May 2021, police
officers came to the office of QBF Group and searched the office as part of a criminal case, seizing servers and other
office equipment. Afer the search, Golubev A.S. and Gevorgyan G.Sh. informed that everything was in order at "QBF"
Group of Companies, that what had happened was only an unscheduled inspection and that in the future the
company would be fine. From about March 2021 the management stopped paying the office rent. From May 2021,
employees stopped being paid their salaries. At the end of June 2021, she resigned. She later learnt from the media
that QBF was a "financial pyramid scheme", that criminal proceedings had been initiated and that QBF Group
executives were under investigation. Throughout her employment with QBF, she saw how the company's office was
regularly visited by citizens - clients of the QBF group of companies - who were interviewed and consulted by the
company's employees (financial advisors);
(Vol. No. 271, pp. 6 - 8)
- A. A. Senina's Testimony given to her as a witness,

according to which, in 2018 from her acquaintance named Bogdanov Kirill she learnt about the group of companies
"QBF". At that time Bogdanov K. worked as a financial advisor and told her about the open vacancy and the
opportunity to get a job as a secretary in the company. She was interested in the offer, so she went for an interview to
the office of the group of companies "QBF" at the address: St. Petersburg, Maloohtinsky prospect, 64, lit. B. The
interview with her was conducted by the personnel manager named Irina, who told her about the principles of work,
513
as well as about the duties of an applicant for the position of a secretary. At that time she was satisfied with
everything, so she agreed and was employed as a secretary in the group of companies "QBF". Her (Senina A.A.) duties
included: receiving and sending correspondence, ordering stationery, keeping the office clean, meeting clients. Her
workplace was located in the office at the address: St. Petersburg, Maloohtinsky pr, 64, lit.B. At first her supervisor was
Irina - HR manager. In 2019 QBF office moved to the address: 11 Degtyarny per., Lit.B. In July 2019, she (A.A. Senina)
changed her position to a specialist of the Operations Support Department and Ekaterina Olegovna Martsinyuk
became her manager. The head of the St. Petersburg office of QBF Group of Companies was Alexey Sergeyevich
Golubev. It was Golubev who set tasks for the office staff and held meetings. One of A.S. Golubev's deputies was
Gevorgyan Gevorg Shekspirovich, who managed financial advisors. Her monthly salary was 65,000 roubles, which was
given to her in cash by Ekaterina Martsinyuk at the office of the QBF Group of Companies at 11 Degtyarny Lane, Lit. B,
St Petersburg. In May 2021, police officers came to the office of the QBF Group of Companies and conducted a search
as part of a criminal case. They seized servers and other office equipment. Afer the search Golubev A.S. said that the
group of companies "QBF" everything is in order, that what happened is only an unscheduled inspection and in the
future the company will be fine. In this A.S. Golubev continued to convince them further. At the beginning of June
2021 she went on a planned holiday and flew to Egypt for a fortnight. When she returned, the office had already
stopped its work. She later learnt from the media that QBF was a "pyramid scheme", that criminal proceedings had
been initiated and that the managers of the QBF group of companies were under investigation. During her working
activity in the group of companies "QBF" she saw how citizens - clients of the group of companies "QBF" regularly
come to the office, with whom employees (financial advisors) of the group of companies "QBF" had discussions and
consultations;
(Vol. No. 271, pp. 12 - 14)
- Kiseleva E.S.'s Testimony given to her as a witness,

according to which, around November 2020, she saw an advertisement on the Internet about a vacancy for a junior
securities market analyst in the group of companies "QBF". She was interested in the possibility of employment in the
mentioned company, so she went for an interview to the office of the group of companies "QBF" at the address: St.
Petersburg, Degtyarny Lane, 11, Lit. B. The interview with her was conducted by HR manager Lvova Alexandra, who
told her about the principles of work, as well as about the duties. She (E.S. Kiseleva) was satisfied with everything, so
she agreed to be employed by QBF Group of Companies as a junior securities market analyst. Her duties included:
analysing the stock market in Russia and the USA, writing analytical reviews on companies listed on stock exchanges.
Her workplace was located at 11 Degtyarny Lane, Lit.B, St. Petersburg. Her boss was Ksenia Lapshina, who was Acting
Head of the Stock Market Analyst Department of QBF Group. The head of the St. Petersburg office of the "QBF" group
of companies, located at 11 Degtyarny Lane, Lit.B, St. Petersburg, was Gevorkyan Gevorg Shakespeirovich, who
managed all employees of the "QBF" office. The second head of the St. Petersburg office of the group of companies
"QBF" was Alexey Sergeyevich Golubev, who also managed the employees of the office, set them tasks and held
general meetings. Alexey Sergeyevich Golubev managed regional offices of "QBF" group of companies. The third head
of the St. Petersburg office of the "QBF" group of companies was Vladimir Sergeevich Pakhomov, who also managed
the office staff, set them tasks and held general meetings. Her monthly salary was 45,000 roubles, which was issued by
Lapshina Ksenia and once by Dina Radikovna Munasypova, the head of the HR department of QBF Group. She (E.S.
Kiseleva) knows that the duties of a cashier in the office of the "QBF" group of companies, located at 11 Degtyarniy
Lane, St. Petersburg, Lit. B, were performed by a girl named Ekaterina. Ekaterina accepted cash from depositors. In
May 2021, police officers came to the office of QBF Group at 11 Degtyarny Lane, Lit. B, St. Petersburg, and searched
the office as part of the criminal case. Afer them Golubev A.S. told the employees of the office of the group of
companies "QBF" that the company is doing well and it is just a "competitors' attack". In June 2021, she stopped
going to work and performing her duties, according to her employment contract, as the office ceased to operate and
her salary was stopped from April 2021. During her working activity in the group of companies "QBF" she saw how
514
various citizens - clients of the group of companies "QBF", with whom the employees of the group of companies
"QBF" conducted conversations and consultations, came to the office at the address: St. Petersburg, Degtyarny per.,
11, lit. B. She heard from the employees that cash had been paid in cash. She heard from the employees that
Ekaterina accepted cash from clients;
(Vol. No. 271, pp. 17 - 20)
- A. A. Abanov's testimony, given by him as a witness,

according to which, approximately in October 2018, someone from among his acquaintances advised him to get a job
in the group of companies "QBF". He was interested and came for an interview to the office of the group of companies
"QBF" at the address: St. Petersburg, Degtyarny per., 11, lit. B. The interview was conducted by the deputy head of the
branch of the group of companies "QBF" Gevorkyan Gevorg Shekspirovich, who told him (Abanov A.A.) about the
principles of work, as well as about the duties. He (Abanov A.A.) was satisfied with everything, so he agreed to be
employed as Deputy Head of Department of the St. Petersburg branch of "QBF" Group of Companies. In October 2018,
in the office of QBF Group of Companies at 11 Degtyarny Lane, Lit.B, St. Petersburg, he signed an employment
contract with KF Estate Spb LLC for the above position. His duties included developing the product line, meeting with
clients, and training employees. During meetings with clients, he counselled them on the availability of financial
products from the QBF group of companies, which were offered to clients for registration or purchase. He never
accepted or disbursed cash from clients. His direct supervisor was Oleg Oleg Olegovich Balan, director of the
corporate block in St. Petersburg of the QBF group of companies. He never met or communicated with the General
Director of QBF Estate SPb LLC. His monthly salary was 90,000 roubles, which was handed over to him by the head of
the office of the "QBF" group of companies Golubev Aleksey Sergeevich, in the office of the "QBF" group of companies
at the address: 11 Degtyarny Lane, Lit. B, St. Petersburg. In May 2021, police officers came to the office of the "QBF"
group of companies at the address: 11 Degtyarny Lane, Lit. B, St. Petersburg, and searched it as part of the criminal
case. Afer that Golubev A.S. told the employees of the office of the group of companies "QBF" that the company was
doing well and that it was just a "competitors' attack", in which Golubev A.S. continued to convince them further. In
June 2021, he (Abanov A.A.) stopped going to work and fulfilling his duties, according to the labour contract, as the
office ceased its work and he stopped paying his salary. During his working activity in the group of companies "QBF",
he saw various citizens - clients of the group of companies "QBF", with whom the employees of the group of
companies "QBF" had conversations and consultations, coming to the office at the address: St. Petersburg, Degtyarny
per. 11, lit. B;
(Vol. No. 271, pp. 23 - 25)
- The testimony of N.I. Khekalo, given to her as a witness,

according to which in July 2017, approximately, her acquaintance invited her (N.I. Khekalo) to work. She had just
graduated from university and needed a job. She was interested in the possibility of employment in the proposed
company. She came for an interview to the office of the "QBF" group of companies at the following address: 64
Maloohtinsky Ave, St. Petersburg. Maloohtinsky, 64 "B". The interview with her (N.I. Khekalo) was conducted by Irina,
whose surname she does not remember. The second stage of the interview was conducted by A.S. Golubev and the
last stage by Vladimir Pakhomov. All of them told her about the principles of work, as well as her (N.I. Khekalo) duties.
She was satisfied with everything, so she (N.I. Khekalo) agreed to be employed as an assistant to A.S. Golubev. The
515
employment contract was signed there in the office located at 64 "B" Maloohtinsky Prospekt, St. Petersburg. Her
duties included carrying out personal errands of A.S. Golubev, who was her immediate superior and he (A.S. Golubev)
was the head of the office in the company "QBF" at the address: St. Petersburg, Maloohtinsky Ave. Maloohtinsky, 64
"B". In the summer of 2018, the office moved to the following address: 11 Degtyarny Per., Lit. B. She received a salary
of 75,000 rubles per month, which she, like all office employees, was paid directly by Alexey Golubev in an envelope in
cash. She was not allowed to work with clients (depositors), she was not aware of the conditions of realisation of
financial products of "QBF" companies and their procedures. In the spring of 2020 she fell ill with Covid - 2019 and
stopped coming to work, and subsequently resigned altogether. Whether she wrote a resignation letter she does not
remember, at that time period many organisations were working remotely. In May 2021, police officers searched the
office of the "QBF" group of companies at 11, Lit. B, Degtyarny Lane, St. Petersburg, as part of a criminal case; she also
learnt on the Internet that criminal proceedings had been initiated against the managers of "QBF" and that the "QBF"
group of companies was no longer operating;
(Vol. No. 271, pp. 28 - 30)
- Testimony of N.A. Kadymaliev, given by him as a witness,

according to which, approximately in October 2020 in the Internet, on the website "hh.ru", he saw an advertisement
about a vacancy in the group of companies "QBF". He was interested in the possibility of employment in the
mentioned company, so he came for an interview to the office of the group of companies "QBF" at the address: St.
Petersburg, Degtyarny per. 11, lit. B. There were several interviews, he came to the office about 7 times. He was
interviewed by Alexandra Lvova, Dina Monasypova and Gevorkyan Gevorg Shakespearevich, who told him (N.A.
Kadymaliev) about the principles of work, as well as his responsibilities. He (N.A. Kadymaliev) was satisfied with
everything, so he agreed to be employed as a junior financial advisor. He repeatedly raised the issue of signing a
labour contract, but the contract was never signed. He worked like all other employees in the office located at 11
Degtyarny Lane, Lit. B, St. Petersburg. His duties included: attracting new depositors, working with existing depositors
(client management, constant consultations and communication). His direct supervisor was Meri Baghdasaryan. The
head of the office of "QBF" company at the address: 11, Lit. B, Degtyarny per., St. Petersburg, was Gevorkyan Gevorg
Shakespeirovich. Also he (N.A. Kadymaliev) knows that A.S. Golubev was the head of the St. Petersburg branch as a
whole and developed offices in other regions, which he does not know. He (Kadymaliev N.A.) received an average
salary of 90,000 roubles per month, which was paid to him directly by Golubev Alexei, in an envelope in cash. During
his (Kadymaliev N.A.) employment (from October 2020 to June 2021) in the "QBF" group of companies, he attracted
12 clients with whom he was in constant contact. When he attracted clients and they made deposits, the depositors
received from him details of settlement accounts and transferred funds by cashless transfer. In May 2021, police
officers searched the office of QBF Group of Companies at 11 Degtyarny Lane, Lit. B, St. Petersburg, as part of a
criminal case. Afer that, they (the company's employees) were shown a video message of the owner of the QBF Group
of Companies R.V. Shpakov, in which he (R.V. Shpakov) explained that these were temporary difficulties and intrigues
of competitors. Until the middle of June 2021 he (Kadymaliev N.A.), as well as many employees of the office, came to
work expecting new work instructions, but they were informed that the office is closed and will not work anymore.
Afer that, he learnt from the Internet that criminal proceedings were initiated against the managers of the "QBF"
group of companies and that the "QBF" group of companies was no longer operating;
(Vol. No. 271, pp. 33 - 35)
516
R.A. Khlebnikov's testimony, given by him as a witness,
according to which, around November 2018, his acquaintance Oleg Balan invited him (R.A. Khlebnikov) to work in the
group of companies "QBF". He got acquainted with Oleg Balan when he worked in PJSC Bank "VTB". The interview
with him (R.A. Khlebnikov) was conducted by Oleg Balan and Gevorkyan Gevorg, who told him about the principles of
work, as well as about his (R.A. Khlebnikov) duties. He was satisfied with everything, so he agreed to be employed as a
Leading Financial Advisor. In April 2021, at the office of QBF Group of Companies located at 11 Degtyarny Lane, Lit. B,
St. Petersburg, he signed an employment contract with LLC QF Estate SPb for the position of Lead Financial Advisor.
His (R.A. Khlebnikov) duties included: creation of financial products to be sold to legal entities, search for potential
clients, their consultation and further implementation of the products. His direct supervisors were Oleg Balan and
Alexander Abanov. Alexey Sergeevich Golubev was the head of the office at QBF at 11 Degtyarny Lane, Lit. B, St.
Petersburg. He (R.A. Khlebnikov) received his salary in the amount of 90,000 roubles per month, which was paid to
him directly by Alexei Golubev, in cash in an envelope. During his working activity (from November 2018 to June 2021)
in the group of companies "QBF", he (R.A. Khlebnikov) worked with only a few clients (four clients). He never worked
with individuals. In May 2021, in the office of the group of companies "QBF" at the address: St. Petersburg, Degtyarny
Lane, 11, Lit. B, police officers searched the office as part of a criminal case. Afer that they (company employees) were
shown a video message of the owner of the "QBF" group of companies R.V. Shpakov, in which R.V. Shpakov explained
that these were temporary difficulties and intrigues of competitors. Till the middle of June 2021 he (Khlebnikov R.A.)
as well as many employees of the office, came to work and expected new introductions, however soon they
(employees) were informed that the office is closed and will not work anymore. Afer that, he learnt from the
information and telecommunication network "Internet" that criminal proceedings were initiated against the
managers of the group of companies "QBF" and the group of companies "QBF" no longer carries out its activities;
(Vol. No. 271, pp. 38 - 40)
- The testimony of Leonov D.V., given by him as a witness,

according to which, approximately in April 2021 in the information and telecommunication network "Internet" he saw
an advert about a vacancy in the group of companies "QBF". He was interested in the possibility of employment in the
mentioned company, that's why he came from Novosibirsk for an interview to the office of the group of companies
"QBF" at the address: St. Petersburg, Degtyarny per., 11, lit. B. The interview was conducted by the personnel
manager, a girl named Diana, as well as Gevorkyan Gevorg, who told him (Leonov D.V.) about the principles of work,
as well as his duties. He (Leonov D.V.) was satisfied with everything and agreed to be employed as a manager. In April
2021, at the office of QBF Group of Companies at 11 Degtyarny Lane, Lit. B, St. Petersburg, he signed an employment
contract with LLC "QF Estate SPb" for the above - mentioned position. His (Leonov D.V.) duties included: searching for
new clients, opening reports, consulting with potential clients. Afer he was employed, he (Leonov D.V.) and his
acquaintance Vlasov Evgeny, who was also employed by QBF Group, lef for Novosibirsk, where they planned to open
a branch to attract clients. His (Leonov D.V.) immediate superior was Vlasov Evgeny. During the period from April to
the beginning of June 2021 in Novosibirsk he (Leonov D.V.) attracted several clients. Vlasov Evgeny was looking for a
property to rent and open a branch. The head of the office in the company "QBF", located at 11 Degtyarny Lane, Lit. B,
St. Petersburg, was Golubev A.S. He (Leonov D.V.) received a salary from (Leonov D.V.) only once in the amount of
50,000 roubles, which was transferred to him in non - cash form through his direct supervisor - Vlasov Evgeny. In May
2021, in the office of the "QBF" group of companies, located at the address: St. Petersburg, Degtyarny per., 11, lit. B,
police officers conducted a search in the framework of the criminal case. Afer that he (D.V. Leonov) learnt from the
Internet that criminal proceedings had been initiated against the managers of the "QBF" group of companies and that
the "QBF" group of companies was no longer operating. During his working activity (from April to the end of May
517
2021) in the group of companies "QBF", the clients attracted by him in Novosibirsk for the purchased financial
products transferred money in non - cash form to remotely opened by them (clients) settlement accounts;
(Vol. No. 271, pp. 43 - 45)
- Baghdasaryan M.A.'s Testimony given to her as a witness,

according to which, in March 2018, she received a call from an HR specialist of the QBF Group, who invited her to an
interview at the company's office located at: St. Petersburg, 64 Maloohtinsky Ave, Lit. B. At the meeting, she
(Baghdasaryan M.A.) was interviewed by one of the HR employees, who she does not remember. The employee told
her (M.A. Baghdasaryan) about the position of a trainee in the sales department for which she was being considered.
She (M.A. Baghdasaryan) was interested in the offer. The girl told her (M.A. Baghdasaryan) about the principles of
work, as well as the responsibilities of the position. At that moment she was satisfied with everything, so she agreed.
The selection took place in three stages. A few days later she received a phone call informing her that she was
accepted for the position. Her (M.A. Baghdasaryan) duties included: consulting clients on the company's products.
Her workplace was in the office at the above address. Her direct supervisor was Anton Parfiriev. The head of the St.
Petersburg office at the time was Alexei Sergeyevich Golubev, who held meetings and set tasks for the office staff. Her
monthly salary was about 40,000 roubles, which was given to her in cash by Mr Golubev. Her salary was paid every
month on a specific date, without delays. In the summer of 2018, they (the employees) moved to a new office in BC
"Nevskaya Ratusha", located at 11 Degtyarny per., Lit. B. In the new office, she (M.A. Baghdasaryan) became a financial
advisor. The head of the sales department was Gevorg Shekspirovich Gevorgyan. In the new office the salary was
issued exclusively by A.S. Golubev, also by statement and in cash. In May 2021, the office of "QBF" group of companies
was searched by police officers within the framework of a criminal case. Afer the search Golubev A.S. and Gevorgyan
G.Sh. said that everything was in order at "QBF" group of companies, that what happened was only an unscheduled
inspection. Later she learnt from the media that "QBF" company is a "financial pyramid";
(Vol. No. 271, pp. 48 - 50)
- Testimony of M.Y. Zhuk, given to her as a witness,

according to which, approximately in June 2016, she saw an advertisement on the Internet about a vacancy for an
assistant to the general director in the group of companies "QBF". She was interested in the possibility of employment
in this company, so she came for an interview at the office of the group of companies "QBF", located at the address:
St. Petersburg, Maloohtinsky prospect, 64, lit. B. The interview was conducted by the General Director of LLC "QF
Estate SPb" Pakhomov Vladimir Sergeevich, who told her about the principles of work, as well as about her (Zhuk M.Y.)
duties. She was satisfied with everything, so she (Zhuk M.Y.) agreed to be employed as a personal assistant to the
General Director. Her duties included: preparation of Pakhomov V.S.'s schedule of meetings, fulfilment of his personal
assignments, planning business trips, etc. Her workplace was located at 64 Maloohtinsky pr., Lit. B, St. Petersburg. Her
(Zhuk M.Y.) boss was Pakhomov V.S., who was also the head of the St. Petersburg office of QBF Group. At that time
Pakhomov V.S. single - handedly managed the work of the office, the office staff, held meetings. Her monthly salary
was about 60,000 roubles, which was given to her by Pakhomov V.S. in hand at the office of the "QBF" group of
companies. She knows that the duties of a cashier in the office of the "QBF" group of companies were performed by a
woman who reported to Pakhomov V.S. and carried out his instructions. She worked in the mentioned office of the
group of companies "QBF" for about 5 months, afer which she went on maternity leave to take care of her children.
518
About 2 years afer that, she received a call from the group of companies "QBF" and was offered to resign at her own
will. She agreed, one of the employees of the "QBF" group of companies prepared and brought her the documents for
dismissal, she signed them, afer which she was given a final payment. She did not come to the office of the "QBF"
group of companies for her labour book, as she (Zhuk M.Y.) did not need it. Since about 2019 she stopped having
information about the "QBF" group of companies, as she actually resigned from it. During her labour activity in the
group of companies "QBF", she saw various citizens - clients of the group of companies "QBF", with whom the
employees of the group of companies "QBF" had conversations and consultations, come to the office at the address:
St. Petersburg, Maloohtinsky prospect, 64, lit. B;
(Vol. No. 271, pp. 53 - 55)
- Semenishchenkova S.V.'s Testimony given to her as a witness,

according to which, around April 2018, she (Semenishchenkova S.V.) learnt from Margarita Krotova about the vacancy
of a marketing specialist in the group of companies "QBF". She was interested in the possibility of employment in the
mentioned company, so she went for an interview to the office of the group of companies "QBF" at the address: St.
Petersburg, Maloohtinsky prospect, 64, lit. B. The interview was conducted by the employees of the marketing
department Julia Eskina and Lyubov Suranova, who told her (Semenishchenkova S.V.) about the principles of work, as
well as about her duties. Later on there was another interview with Vladimir Sergeyevich Pakhomov. She was satisfied
with everything, so she agreed to be employed as a regional marketing specialist. Her duties included: monitoring the
media, liaising with the media, developing a marketing plan and marketing concept, determining expenses according
to the marketing plan, developing concepts for awarding sales units, developing and coordinating office navigation.
Her workplace was located at the address: 64 Maloohtinsky Ave, Lit. B, St. Petersburg. Her boss was Julia Eskina, who
was the head of the marketing department of the QBF group of companies and reported directly to Pakhomov V.S.
The head of the St. Petersburg office of the QBF group of companies was Golubev Alexey Sergeevich, who supervised
all employees of the QBF group of companies office. The second head of the St. Petersburg office of "QBF" group of
companies was Gevorgyan Gevorg Shekspirovich, who also managed the employees of the office, set tasks and held
general meetings. The third manager of the St. Petersburg office of "QBF" group of companies was Vladimir
Sergeyevich Pakhomov, who also managed the employees of the office, set tasks and held general meetings. She
(Semenishchenkova S.V.) also knows that Pakhomov Vladimir Sergeevich managed the regional offices of the group of
companies "QBF". Her monthly salary was 70,000 roubles, which was handed over to her by Ekaterina Martsenyuk in
the office of the group of companies "QBF", located at the address: St. Petersburg, Degtyarny per. 11, lit. B. In early
February 2019, she (S.V. Semenishchenkova) went on maternity leave, and in October 2021 she was dismissed from
the group of companies "QBF" at her own request. During her working life, she saw various citizens - clients of the
"QBF" group of companies coming to the company's office located at 11 Degtyarny Lane, Lit. B, St. Petersburg, and
being interviewed and consulted by employees of the "QBF" group of companies;
(Vol. No. 271, pp. 58 - 60)
- E.A. Zelenskaya's Testimony as a witness,

according to which, in March 2020, Christina Stashko, an HR specialist of QBF Group, responded to her CV posted on
the hh.ru website. The latter invited her (E.A. Zelenskaya) for an interview at the company's office, which was located
at 11 Degtyarny Lane, Lit. B, St. Petersburg. At the meeting she was interviewed by Daniil Vetrov, who told her about
the position of financial advisor offered to her. She was then interested in the offer. Vetrov D. told her about the
519
principles of work, as well as the responsibilities of the position. At that time she was satisfied with everything, so she
agreed. The selection took place in two days. Afer that the head of sales department - Gevorg Shakespevich
Gevorgyan - communicated with her. On the second day the girl from HR informed that she (E.A. Zelenskaya) was
accepted for the position. Her duties included: attracting clients, consulting and forming investment portfolio, selling
investment products of the companies. Her workplace was in the office at the above address. Her direct supervisor
was Daniil Vetrov. The head of the St. Petersburg office of QBF Group of Companies was Gevorgyan G.Sh. The
shareholder of the branch network was Pakhomov V.S., his workplace was in their office. Her monthly salary was
64,000 roubles, which was given to her in cash by A.S. Golubev. As a rule, there were various difficulties in making
these payments, as the salary was delayed each time. No one explained why this happened. The company's
accountant was Ekaterina Olehovna Marciniuk, and it was she who calculated the wages and transferred them to A.S.
Golubev for further settlement with the employees. In May 2021, police officers searched the office of the QBF group
of companies as part of the criminal case. Afer the search, Golubev A.S. and Gevorgyan G.Sh. informed that
everything was in order at "QBF" Group of Companies, that what had happened was only an unscheduled inspection
and that in the future the company would be fine. From about March 2021 the management stopped paying the office
rent. From May 2021, employees stopped being paid their salaries. In June 2021, she resigned. She later learnt from
the media that QBF was a "pyramid scheme", that criminal proceedings had been initiated and that the managers of
the QBF group of companies were under investigation;
(Vol. No. 271, pp. 64 - 66)
- A. Y. Alekseevsky's testimony, given by him as a witness,

according to which, at the end of 2018, a specialist (girl) "HR" of QBF group of companies responded to his CV on the
website "hh.ru". She invited him (A.Y. Alekseevsky) for an interview at the company's office, which was located at the
address: St. Petersburg, Degtyarny per. 11, lit. B (BC "Nevskaya Ratusha"). At the meeting he was interviewed by Denis
Ikonnikov, an analyst of the department, and a female HR employee. They told him (A.Y. Alekseevsky) about the
analyst position for which he was being considered, told him about the principles of work, as well as about the
responsibilities of the job applicant. At that time he was satisfied with everything, so he agreed. The selection process
took place in three stages. Afer a few days, the girl from HR informed him that he was accepted for the position. His
(Alekseevsky A.Y.) duties included: preparation of annual stock market reviews, preparation of analytical reviews of
the company, fulfilment of incoming reviews. His workplace was located in the office at the above address. His direct
supervisor until the summer of 2020 was Ikonnikov D. The head of the St. Petersburg office at that time was Golubev
A.S., who held meetings with the sales staff - financial advisors and set them work tasks. His (A.Y. Alekseevsky)
monthly salary was 60,000 roubles, which was given to him in cash by Ekaterina Martsinyuk. In the summer of 2020,
his direct supervisor was Lapshina Ksenia due to the fact that Ikonnikov D. had resigned. In May 2021, the office of the
QBF Group of Companies was searched by police officers as part of a criminal case. Afer the search A.S. Golubev said
that the group of companies "QBF" had everything in order, that what happened was only an unscheduled inspection.
Later he (A.Y. Alekseevskim) learnt from the mass media that the company "QBF" is a "financial pyramid scheme", that
criminal cases have been initiated, and that the heads of the group of companies "QBF" are under investigation.
During his working activity in the company "QBF" he saw how citizens - clients of the group of companies "QBF"
regularly applied to the office, with whom the financial advisors had conversations and consultations;
(Vol. No. 271, pp. 69 - 71)
520
- A.S. Moroz's Testimony as a witness,
according to which, in the summer of 2016, an HR specialist (a girl) of the QBF Group of Companies responded to his
CV posted on the website "hh.ru". She invited him (Moroz A.S.) for an interview at the company's office, which was
located at the address: St. Petersburg, Maloohtinsky pr. 64, lit. B. At the meeting he (Moroz A.S.) was interviewed by
Kisin Gennady Vladimirovich, who told him about the position of a trainee in the sales department, for which he
(Moroz A.S.) was considered. At that time he was interested in the offer. G.V. Kisin told about the principles of work, as
well as about the responsibilities of the applicant for the position. At that time he (A.S. Moroz) was satisfied with
everything, so he agreed. The selection took place in three stages. A few days later G.V. Kisin informed him that he
(A.S. Moroz) was accepted for the position. His duties included: attracting clients through cold calls, scheduling
meetings with managers. His workplace was in the office at the above address. His direct supervisor was G.V. Kisin.
The head of the St. Petersburg office at that time was Vladimir Sergeyevich Pakhomov, who regularly came to the St.
Petersburg office from Moscow, held meetings and set tasks for the office staff. His (A.S. Moroz) monthly salary was
25,000 roubles, which he received in cash from G.V. Kisin. The salary was paid every month on a specific date, without
delay. Afer some time G.V. Kisin lef the company, or rather switched to an agency contract and rarely appeared in the
office. His (Moroz A.S.) manager became Alexei Sergeyevich Golubev. In winter 2018, he lef QBF and returned to a new
office, which was located in the Nevskaya Ratusha BC, located at 11 Degtyarny Lane, Lit. B. In the new office, he (A.S.
Moroz) became a financial advisor, and his manager was Gevorg Shekspirovich Gevorgyan, who later became the
head of the entire St. Petersburg office. Frolova Evgenia Sergeevna became the head of the sales department. In the
new office the salary was given exclusively by A.S. Golubev, also in an envelope. Afer Frolova E.S. its head was
Kuznetsov Sergey, and in April 2020. Moskalyuk Dmitry Vladimirovich. In May 2021, police officers searched the office
of QBF Group as part of the criminal case. Afer the search Golubev A.S. and Gevorgyan G.Sh. said that the group of
companies "QBF" everything is in order, that what happened is only an unscheduled inspection and in the future the
company will be fine. Later he learnt from mass media that "QBF" company is a "financial pyramid", that criminal
cases have been initiated and the investigation is underway against the managers of "QBF" group of companies;
(Vol. No. 271, pp. 74 - 76)
- Testimony of E.S. Tsybenko, given to her as a witness,

according to which, approximately in November 2018, she saw an advertisement on the Internet about the vacancy of
a secretary in the group of companies "QBF". She was interested in the possibility of employment in the mentioned
company, so she (E.S. Tsybenko) went for an interview to the office of the group of companies "QBF", located at the
address: St. Petersburg, Degtyarny per. 11, lit. B. The interview was conducted by the head of the administrative
department Marzenyuk Ekaterina, who told her (E.S. Tsybenko) about the principles of work, as well as about the
duties. She (E.S. Tsybenko) was satisfied with everything, that is why she agreed to be employed in the group of
companies "QBF" as a secretary. Her duties included: meeting clients, booking car parks, running errands for
managers, scanning documents. Her workplace was located at 11 Degtyarny Lane, Lit. B, St. Petersburg, and her boss
was Ekaterina Martsenyuk, who was the head of the administrative department of QBF Group. The head of the St.
Petersburg office of "QBF" group of companies was A.S. Golubev, who managed all employees of the office of "QBF"
group of companies. The second head of the St. Petersburg office of the group of companies "QBF" was Gevorgyan
Gevorg Shekspirovich, who also managed the employees of the office, who set tasks for the employees and held
general meetings. The third head of the St. Petersburg office of "QBF" group of companies was Vladimir Sergeyevich
Pakhomov, who also managed the office employees, set tasks for them and held general meetings. She (E.S.
Tsybenko) also knows that Vladimir Sergeyevich Pakhomov was in charge of the regional offices of the "QBF" group of
companies. Her monthly salary was 40,000 - 45,000 roubles, which was handed to her in the office of the group of
companies "QBF" by Martsenyuk Ekaterina. In April 2021, she was dismissed from the QBF Group of Companies at her
521
own request. During her working activity in the QBF group of companies, she saw various citizens - clients of the QBF
group of companies - come to the office at 11 Degtyarny Lane, Lit. B, St. Petersburg, and were interviewed and
counselled by employees of the QBF group of companies;
(Vol. No. 271, pp. 79 - 81)
Ginosyan M.S.'s Testimony given to her as a witness,

according to which, in approximately April 2018, on the recommendation of Irina Orlekovskaya, she was employed by
the "QBF" group of companies. She had an interview in the office of the group of companies "QBF", located at the
address: St. Petersburg, Maloohtinsky pr., 64, lit. B. The interview was conducted by Alexey Sergeyevich Golubev, who
told her about the company in general. The second interview was conducted by Ekaterina Martsenyuk, who told her
about the principles of work, as well as her (Ginosyan M.S.) responsibilities. At the third interview, which was
conducted by A.S. Golubev, she was hired for the position of Operations Support Specialist. Her duties included:
processing requests from managers, filling in the template, sending the prepared documents to Moscow, working
with the document flow related to the company's personnel. Her workplace was located at 11 Degtyarny Lane, Lit. B,
St. Petersburg. Her direct supervisor was Ekaterina Martsenyuk, who held the position of Head of the Administrative
Department of QBF Group. The head of the St. Petersburg office of the "QBF" group of companies, located at 11
Degtyarny Lane, Lit. B, St. Petersburg, was Alexey Sergeyevich Golubev, who supervised all employees of the office of
the "QBF" group of companies. The second head of the St. Petersburg office of "QBF" group of companies was
Gevorgyan Gevorg Shekspirovich, who also managed the employees of the office, set tasks for them and held general
meetings. The third head of the St. Petersburg office of "QBF" group of companies was Vladimir Sergeyevich
Pakhomov, who also supervised the employees of the office, set tasks and held general meetings. Her (M.S. Ginosyan)
monthly salary was 75,000 rubles, which was given to her by Ekaterina Martsenyuk in hand at the office of the "QBF"
group of companies at 11 Degtyarny Lane, Lit. B, St. Petersburg. In May 2021, police officers searched the office of the
"QBF" group of companies at 11 Degtyarny Lane, Lit. B, St. Petersburg as part of a criminal case. Afer that, she
decided to resign, and in June 2021, she stopped going to work and performing her duties under her employment
contract. At that time, the office stopped working and she stopped being paid her salary, as early as May 2021;
(Vol. No. 271, pp. 85 - 87)
- The testimony of N.A. Chernysheva, given to her as a witness,

according to which, in September 2017, the head of the department Pakhomov Grigory Gennadyevich invited her to
the company "QBF" for the position of a financial advisor. She had met Pakhomov G.G. earlier, he was her colleague at
Sberbank PJSC. On Pakhomov G.G.'s advice, she came for an interview at the office of QBF Group, located at 64
Maloohtinsky Ave, Lit. B, St. Petersburg. The interview was conducted by Pakhomov G.G., Golubev A.S. and a
personnel officer, who told her about the principles of work and her responsibilities. She was satisfied with the
conditions offered, so she agreed to be employed by the QBF Group of Companies as a financial advisor. Her duties
included: attracting clients, closing transactions. Her workplace was located at the above address, and her boss was
Pakhomov G.G., who held the position of the head of the department of the group of companies "QBF". The head of
the St. Petersburg office of the "QBF" group of companies was Alexey Sergeyevich Golubev, who managed the
employees of the office of the "QBF" group of companies, set tasks for them and held general meetings. Also she (N.A.
Chernysheva) knows that A.S. Golubev managed the regional offices of the group of companies "QBF". Her monthly
522
salary was 40 000 roubles, which was given to her by A.S. Golubev or Ekaterina Martsenyuk in the office of the group of
companies "QBF". She knows that the duties of the cashier in the office of the group of companies "QBF" in St.
Petersburg were performed by Ekaterina Martsenyuk, she also distributed the money of the company to its needs. In
July 2018, the office of the "QBF" group of companies moved to the address: 11 Degtyarny per., Lit. B. On 28.06.2019,
she resigned from the "QBF" group of companies at her own request, and later, on 21.02.2020, she returned to work in
the "QBF" group of companies as a financial advisor. In May 2021, in the office of the group of companies "QBF",
located at the address: St. Petersburg, Degtyarny per. 11, lit. B, police officers conducted a search. Afer the search,
A.S. Golubev told the employees of the office of the "QBF" group of companies that the "QBF" group of companies
was doing well and it was just a "competitor attack", and A.S. Golubev continued to convince them (the employees) of
this further. In June 2021, she stopped going to work and performing her duties, as the office ceased to operate and
she stopped being paid her salary from April 2021. During her working activity in the group of companies "QBF", she
saw how various citizens - clients of the group of companies "QBF" came to the offices at the following addresses: St.
Petersburg, Maloohtinsky pr. 64, lit. B and St. Petersburg, Degtyarny per. 11, lit. B, with whom the employees of the
group of companies "QBF" had discussions and consultations. She (N.A. Chernysheva) saw how Martsenyuk E. and
Golubev A.S. accepted cash from clients to invest them in foreign companies. She was also an investor of the group of
companies "QBF", but the contract, by power of attorney, was made out to her daughter Victoria Yuryevna Vasilyeva,
born on 12.04.2000;
(Vol. No. 271, pp. 91 - 94)
- The testimony of Maricheva E.Y., given to her as a witness,

according to which, approximately in October 2012, she saw an advertisement on the Internet about the vacancy of a
secretary in the group of companies "QBF". She was interested in the possibility of employment in the mentioned
company, so she went for an interview to the office of the group of companies "QBF", located at the address: St.
Petersburg, Maloohtinsky prospect, 64, lit. B. The interview was conducted by the head of the St. Petersburg office of
the group of companies "QBF" Pakhomov Vladimir Sergeevich, who told her (Maricheva E.Y.) about the principles of
work, about her duties, afer which she agreed to be employed as a secretary in the group of companies "QBF". Her
duties included: purchasing of office supplies, meeting and accompanying office guests, making tea and coffee for
visitors. Her workplace was located at the address: 64 Maloohtinsky Ave., Lit. B. Her boss was Vladimir Sergeyevich
Pakhomov, who was the head of the St. Petersburg office, and he managed all the office staff, set tasks for them and
held general meetings. During her employment with QBF Group of Companies, Alexey Sergeevich Golubev held the
position of Financial Advisor to the Group of Companies. Her monthly salary ranged from RUB 30,000 to RUB 50,000
and was given to her by Pakhomov Vladimir Sergeevich, in hand at the office of the "QBF" group of companies. In
early 2017, she went on maternity leave to care for her child, then gave birth to her second child and continued to be
on maternity leave. In November 2021, she received a call from an employee of the Moscow office of the QBF Group of
Companies, telling her that the QBF Group of Companies was having serious difficulties and that she (E.Y. Maricheva)
needed to resign at her own request. She (Maricheva E.Y.) agreed and wrote an application, she was given a final
financial settlement. Throughout her labour activity in the group of companies "QBF" she saw how various citizens -
clients of the group of companies "QBF" came to the office at the address: St. Petersburg, Maloohtinsky prospect, 64,
lit. B, with whom conversations and consultations were held by the employees of the group of companies "QBF";
(Vol. No. 271, pp. 98 - 100)
523
- Solomatov M.E.'s Testimony given as a witness,
according to which, approximately at the end of July - beginning of August 2020, he saw an advertisement for a
vacancy in the group of companies "QBF" on the Internet site "hh.ru". Subsequently, an employee of the group of
companies "QBF", Alexandra Lvova, called him on his mobile phone and invited him (Solomatova M.E.) for an
interview at the office of the group of companies "QBF" at the address: St. Petersburg, Degtyarny per. 11, lit. "b". The
interview was conducted by the head of the personnel department of the St. Petersburg office of the group of
companies "QBF" Munasypova Dina Radikovna, who told him about the principles of work, as well as his (Solomatov
M.E.) duties. He was satisfied with everything and agreed to be employed as an HR manager in the group of
companies "QBF". His (Solomatov M.E.) duties included: searching for employees, telephone interviews with
candidates, holding corporate events. His workplace was located at 11 Degtyarny Per., Lit. B, St. Petersburg, and his
boss was Munasypova Dina Radikovna. The head of the St. Petersburg office of QBF Group of Companies was Alexey
Sergeyevich Golubev, who managed the office staff, set tasks for them and held working meetings. He (Solomatov
M.E.) also knows that A.S. Golubev, among other things, managed the regional offices of the group of companies
"QBF". Vladimir Sergeyevich Pakhomov was the sales manager of the St. Petersburg office of the group of companies
"QBF", who trained junior sales staff, conducted sales trainings and training on investment products offered by the
group of companies "QBF". Gevorkyan Gevorg Shakespeirovich was the Director of Sales Department of the St.
Petersburg office of "QBF" group of companies, located at 11 Degtyarny per., Lit. B, St. Petersburg. His (M.E.
Solomatov) monthly salary was 55,000 roubles, which was handed to him in the office by Ekaterina Martsenyuk.
Ekaterina Martsenyuk was the chief accountant of the St Petersburg office of QBF Group. In May 2021, police officers
searched the office of the QBF Group of Companies located at 11 Degtyarny Per., Lit. B, St. Petersburg, as part of a
criminal case. Afer that Golubev A.S. told them - employees of the office of the group of companies "QBF" that the
group of companies "QBF" was doing well. A.S. Golubev continued to convince them of this further. In June 2021 he
(Solomatov M.E.) stopped going to work and fulfilling his duties, as the office stopped its work and he (Solomatov
M.E.) stopped paying his salary. During his working activity in the group of companies "QBF" he saw various citizens -
clients of the group of companies "QBF" coming to the office, located at the address: St. Petersburg, Degtyarny Lane,
11, lit. B, with whom the employees of the group of companies "QBF" had discussions and consultations;
(Vol. No. 271, pp. 104 - 106)
- A. A. Lvova's Testimony given to her as a witness,

according to which, around April 2019, she saw an advert for a vacancy in the group of companies "QBF" on the
Internet. She was interested in the possibility of employment in the mentioned company, so she (Lvova A.A.) went for
an interview to the office of the group of companies "QBF", located at the address: St. Petersburg, Degtyarny per. 11,
lit. B. The interview was conducted by the head of the personnel department of the St. Petersburg office of the group
of companies "QBF" Munasypova Dina Radikovna, who told her (Lvova A.A.) about the principles of work, as well as
about her duties. She (Lvova A.A.) agreed to be employed in the group of companies "QBF" as a personnel manager.
Her (Lvova A.A.) duties included: selection of personnel to work in the group of companies "QBF". Her workplace was
located at the following address: 11 Degtyarny Lane, Lit. B, St. Petersburg. Her boss was Munasypova Dina Radikovna.
The head of the St. Petersburg office of QBF Group of Companies was Alexey Sergeevich Golubev, who managed the
office staff, set tasks for them and held working meetings. She (A.A. Lvova) also knows that Alexey Sergeevich Golubev,
among other things, managed some regional offices of the "QBF" group of companies. The second head of the St.
Petersburg office of the group of companies "QBF" was Pakhomov Vladimir Sergeevich, who also managed the office
staff, set tasks and held working meetings. The head of the sales department of the St. Petersburg office of the group
of companies "QBF", located at the address: St. Petersburg, Degtyarny per. 11, lit. B, was Gevorkyan Gevorg
Shakespirovich. Her (A.A. Lvova) monthly salary was approximately 40,000 roubles, which was given to her by
Ekaterina Martsenyuk, a member of the financial department of the QBF group of companies, in hand at the office of
524
the group of companies. In May 2021, she (A.A. Lvova) was on holiday and was contacted by D.R. Munasypova, who
informed her that the office of the "QBF" group of companies, located at 11, lit. B, Degtyarny per., St. Petersburg, had
been searched by police officers. On or about 6 June 2021, she (A.A. Lvova) came out of leave. At the general meeting
A.S. Golubev told the employees of the office of the "QBF" group of companies that the employees of the company
were still working and the proceedings were underway. On 29.06.2021 she wrote an application on dismissal at her
own will from the group of companies "QBF". At the time of her resignation, the office of the "QBF" group of
companies continued to be rented, but no labour activity was carried out there. During her working activity in the QBF
group of companies, she saw various citizens - clients of the QBF group of companies - coming to the office at 11
Degtyarny Lane, Lit. B, St. Petersburg, with whom QBF group of companies' employees held discussions and
consultations;
(Vol. No. 271, pp. 109 - 111)
- The testimony of Lapshina K.A., given to her as a witness,

according to which, approximately in August 2018, she saw an advertisement on the Internet about the vacancy of a
junior analyst in the group of companies "QBF". She was interested in the possibility of employment in the mentioned
company, so she went for an interview to the office of the group of companies "QBF", located at the address: St.
Petersburg, Degtyarny per., 11, lit. B. The interview with her was conducted by the analyst of the group of companies
"QBF" Denis Ikonnikov and the employee of the HR department Margarita Krutova, who told her (Lapshina K.A.) about
the principles of work, as well as about her duties. She (Lapshina K.A.) was satisfied with everything, so she agreed to
be employed as a junior analyst at QBF Group. Her duties included: writing analytical reviews on stock markets,
financial analyses of companies and other stock market analyses. Her workplace was located at 11 Degtyarny Lane,
Lit. B, St. Petersburg. Her boss was Denis Ikonnikov. The head of the analytics department was located in Moscow, her
name was Madina. The head of the St. Petersburg office of QBF Group of Companies was Vladimir Sergeevich
Pakhomov, who managed the office staff, set tasks for them and held working meetings. She (Lapshina K.A.) also
knows that Pakhomov V.S., among other things, managed the regional offices of the group of companies "QBF". The
second head of the St. Petersburg office of the group of companies "QBF" was Golubev A.S., who also managed the
office staff, set tasks, held working meetings, managed the regional offices of the group of companies "QBF". She
knows that Pakhomov V.S. was more important than Golubev A.S., and was one of the main managers of the group of
companies "QBF", the same as Shpakov R.V. The director of the sales department of the St. Petersburg office of the
group of companies "QBF", located at the address: St. Petersburg, Degtyarny per. 11, lit. B, was Gevorkyan Gevorg
Shakespirovich. Her (Lapshina K.A.) monthly salary was about 70,000 roubles, which was given to her by Ekaterina
Martsinyuk in hand at the office of the "QBF" group of companies. Ekaterina Martsinyuk, in addition to issuing salaries
to the employees of the St. Petersburg office of the "QBF" group of companies, kept financial and accounting records
and prepared tax returns. In May 2021, police officers searched the office of the QBF Group of Companies located at 11
Degtyarny Lane, Lit. B, St. Petersburg, as part of a criminal case. Afer that Golubev A.S. told the employees of the
office of the "QBF" group of companies that the "QBF" group of companies was doing well, and Golubev A.S.
continued to convince them of this. In June 2021, she (Lapshina K.A.) stopped going to work and performing her
duties, as the office ceased to operate and she was no longer paid her salary. During her working activity in the group
of companies "QBF", she saw various citizens - clients of the group of companies "QBF", with whom the managers of
the group of companies "QBF" had conversations and consultations, come to the office located at the address: St.
Petersburg, Degtyarny per. 11, lit. B;
(Vol. No. 271, pp. 124 - 127)
525
- E.A. Maleeva's Testimony given to her as a witness,
according to which, around September 2020, one of her acquaintances advised her to get a job at the "QBF" group of
companies. The acquaintance told about the available vacancy and she was interested in it, afer which she came for
an interview to the office of the group of companies "QBF", located at the address: St. Petersburg, Degtyarny per. 11,
lit. B. The interview was conducted by the head of the personnel department of the group of companies "QBF"
Munasypova Dina Radikovna, who told her (Maleeva E.A.) about the principles of work, as well as about the duties.
She (Maleeva E.A.) agreed to be employed in the group of companies "QBF" as a financial advisor. Her duties
included: cold calling citizens in order to attract them as clients of the group of companies "QBF" and consultations at
face - to - face meetings. The database for the calls was provided by the "QBF" group of companies and was installed
on her work computer. She does not know which of the employees of the "QBF" group of companies formed this
database. Her workplace was located at the address: 11 Degtyarny Lane, Lit. B, St. Petersburg. Her (E.A. Maleeva) boss
was Daniil Vetrov, who was the head of the department of the QBF group of companies. The head of the St. Petersburg
office of the group of companies "QBF", located at the address: St. Petersburg, Degtyarny Lane, 11, Lit. B, was
Gevorkyan Gevorg Shekspirovich, who managed all employees of the office of the group of companies "QBF". The
second head of the St. Petersburg office of the group of companies "QBF" was Alexey Sergeyevich Golubev, who also
managed the employees of the office, set tasks for them, held general meetings. She is also aware that Alexey
Sergeevich Golubev managed the regional offices of QBF Group of Companies. The third head of the St. Petersburg
office of the group of companies "QBF" was Pakhomov Vladimir Sergeevich, who also managed the employees of the
office, set them tasks, held general meetings. Her (E.A. Maleeva) monthly salary was 20,000 rubles, which was given to
her in the office of the group of companies "QBF" Golubev A.S. In May 2021 she (E.A. Maleeva) was on holiday, and at
the end of May she went on maternity leave without going to work. She learnt from her colleagues that the office of
the QBF Group of Companies had been searched by police officers. Around June - July 2021, she received a call from
Munasypova D.R. and offered to resign at her own request, but she (Maleeva E.A.) refused because she was on
maternity leave, which was to be paid by QBF Estate SPb LLC. Around October 2021, she realised that the QBF Group
office had stopped working as she was no longer paid for her maternity leave. During the course of her employment
with the QBF Group of Companies, she saw citizens - clients of the QBF Group of Companies - coming to the office
located at 11 Degtyarny Lane, Lit. B, St. Petersburg, to be interviewed and counselled by QBF Group of Companies
employees, including her;
(Vol. No. 271, pp. 131 - 134)
- A.V. Spiridonov's Testimony as a witness,

according to which, around 2014, he met Vladimir Sergeyevich Pakhomov while working in a taxi. He came to call
Pakhomov V.S. several times and Pakhomov V.S. liked the way he (Spiridonov V.S.) drove the car, in connection with
which he (Pakhomov V.S.) periodically used his (Spiridonov V.S.) services. In August 2018, Pakhomov V.S. offered him
(Spiridonov V.S.) employment with the QBF organisation owned by him (Pakhomov V.S.) as a driver. In September
2018, he was employed as a receptionist in a remote job in the administrative department, and actually performed
the functions of a driver. His (Spiridonov V.S.) duties included: transporting Pakhomov V.S. and other employees, as
well as routine errands to purchase necessary things for the office (various office supplies, foodstuffs). At that time the
office of the company was located at the address: 11 Degtyarny per., Lit. B. While in the office he (V.S. Spiridonov)
never went further than the reception, he was met by administrators and was given instructions. He waited for
instructions near the reception desk on a chair. While performing his duties, he drove a BMW 530 car, registration
mark B888BBV (Moscow region), which was leased to the organisation. The head of the St. Petersburg office of the
"QBF" group of companies, located at 11 Degtyarny Lane, Lit. B, St. Petersburg, was Alexey Sergeevich Golubev, who
managed all employees of the office of the "QBF" group of companies. Another manager was Gevorgyan Gevorg
Shekspirovich, who managed the employees of the office, set tasks and held general meetings. The third manager of
526
the St. Petersburg office of "QBF" Group of Companies was Vladimir Sergeyevich Pakhomov, who also managed the
office staff, set tasks and held general meetings. His (Spiridonov V.S.) monthly salary was 60,000 roubles, which was
given to him by Ekaterina Martsenyuk in hand at the office of the "QBF" group of companies located at 11 Degtyarny
Lane, Lit. B, St. Petersburg. In May 2021, police officers came to the office of the "QBF" group of companies located at
11 Degtyarny Lane, Lit. B, St. Petersburg and conducted a search as part of a criminal case. In June 2021, he stopped
going to work and fulfilling his duties, as the office ceased to operate and he stopped being paid his salary as early as
May 2021. During his working activity in the "QBF" group of companies, he saw clients of the "QBF" group of
companies coming to the office located at 11, Lit. B, Degtyarny Lane, St. Petersburg, but he does not know for what
purpose;
(Vol. No. 271, pp. 136 - 138)
- Deeva E.I.'s Testimony given to her as a witness,

according to which her CV for job search was posted on the Internet on the website "hh.ru". In April 2021, she received
a call and was offered an interview at the company "QBF", located at the following address: St. Petersburg, Degtyarny
pereulok, d., 11 lit. 11 litre B. The first stage of the interview was conducted via ZOOM video link with Irina Ayatova, a
marketing director from Moscow, and the latter sent her (E.I. Deeva) a test task at the end of the interview. She (E.I.
Deeva) successfully completed it and aferwards also passed the second stage of the interview with Dina, HR Director
of the St. Petersburg office. The third stage of the interview also took place in April 2021 in the St. Petersburg office,
and the interview was conducted by Vladimir Pakhomov. She was hired for the position of "Public Relations Manager"
at QBF. Her employment contract was concluded on behalf of LLC KF Estate SPB. In response to her (E.I. Deeva)
question about her employment with this particular organisation, Dina replied that LLC KF Estate SPB was one of the
legal entities of the QBF group of companies. QBF's office occupied a whole floor in the Nevskaya Ratusha business
centre and employed at least 50 people. Its direct supervisor was Irina Ayatova, who was based in Moscow. She (E.I.
Deeva) saw Ayatova once in St. Petersburg and a second time in Kazan, where a hybrid investment forum with QBF
was held on 28 May 2021. Ayatova in the general chat of the marketing team of various regions of Russia via
messenger gave instructions, orders for work. She (E.I. Deeva) and other marketing employees reported on their
fulfilment in the chat room or by email. Her (E.I. Deeva) workplace was located in an "open space" - an open
workspace. There were also workplaces of the secretary, marketing manager, line employees - financial advisors. She
does not know the names of the financial advisors, as she worked in the company for a short period of time, from
April to 01 June 2021. The workplaces of the managers were located in one place behind a glass partition and usually
there were three managers there: Alexey Golubev (Director of the branch of QBF in St. Petersburg), Vladimir
Pakhomov (one of the shareholders, representative of the Board of Directors), the head of the financial advisors -
Gevorgyan Gevorg Shekspirovich. All three executives were in their places constantly and on a daily basis. She (E.I.
Deeva) was in the messenger Telegram in the group of LLC "Investment Company QBF" for work with the media,
where 5 people were included: she (performed the function of PR - manager, was responsible for the organisation of
work with the media of St. Petersburg and all other regions of the Russian Federation. St. Petersburg and all other
regions of the Russian Federation, including Tyumen, Murmansk, Ufa, Kazan, Kaliningrad), Vadim Skosyrev (PR -
director of QBIF Ltd.), Ksenia Ulanova (PR - manager) and Inna (also PR - manager). Mila, the group's copywriter, sent
media requests to the group and they sorted them out for execution. Her (Deeva E.I.) task was to promptly see the
request, contact the speaker (a person who is competent in this or that issue or on a given topic) in the region or in St.
Petersburg, request comments from him and send the comment to this chat. Since her job involved working online,
working with speakers, she (E.I. Deeva) did not actually communicate with other office staff, except for financial
analysts Ksenia Lapshina, Ekaterina and Alexei. She was aware that LLC IC QBF worked in the investment direction,
attracted clients' funds for trust management, and also worked in the direction of forming an investment portfolio.
Financial advisors were constantly in the mode of telephone conversations. When clients visited the company's office,
the financial advisors went to work with them in the meeting rooms. She does not know what the office managers
527
were doing. They were at their workplaces at all times. At the end of May 2021, the company's office was searched by
police officers. The next day, the office staff was gathered in the meeting room, where Alexei Golubev explained the
following to those gathered: "A search is not such a rare event in the life of financial organisations, it is a standard
measure of employees to maintain economic security, and the articles in the media about fraudulent actions of QBF
in relation to clients are commissioned". She (E.I. Deeva) was very concerned about the events that happened, as she
did not want to work in an organisation associated with problems in law enforcement agencies. In addition, she
worked closely with the media and had little faith that the articles about fraud by QBF were commissioned, as the
media provided many facts, names and figures. She also learnt that the company was being evicted from the office in
June 2021 for rent arrears. This also alerted her. For this reason, she wrote an application to the director for leave of
absence at the beginning of June 2021. At the end of the leave, the company office was no longer at its location. In
August 2021, she wrote a resignation letter and was dismissed from KF Estate Spb in the same month;
(Vol. No. 271, pp. 142 - 145)
- The testimony of Sysoeva V.M., given to her as a witness,

according to which, in approximately 2020, Oleg Timokhin, who had previously known her, offered her a job at QBF.
She was interested in Timokhin O.'s offer and in February 2020 she was invited for an interview at the office located at
the following address: 8 Presnenskaya Naberezhnaya Naberez, Moscow, Capital City building of the Moscow City
business centre. She was interviewed by a "hr" specialist Anastasia, whose surname she does not remember. Afer
passing the interview in February 2020, she (V.M. Sysoeva) became an employee of LLC IC QBF as a specialist of the
BEC office with a salary of approximately 50,000 - 70,000 rubles. She received her salary in two instalments, namely
the main part in the amount of approximately 20,000 - 30,000 roubles, as stipulated in the employment contract, she
received on her bank card with the designation "salary crediting". The second part of her salary, which was not
provided for in the employment contract, was received in cash in an envelope. The second part of her salary could be
given to her by Timokhin Oleg, as well as other employees of the company, who she does not remember. Her (V.M.
Sysoeva) direct supervisor was Oleg Timokhin, who in turn was subordinate to Stanislav Matyukhin. Timokhin Oleg
was the head of the BEK office. In turn, QBF LLC was part of the QBF group of companies, but she does not know
exactly how many companies and which companies were part of the QBF group of companies. The office of LLC IC
QBF was located at 8 Presnenskaya Naberezhnaya Naberezhnaya Street, Moscow, Moscow City business centre,
Capital City building. The principal activity of OOO IC QBF was attracting clients for brokerage services and trust
management of funds invested by clients. The head of LLC IC QBF was Stanislav Matyukhin. The principal manager of
QBF Group was Roman Shpakov, and his partners were Zelimkhan Munaev and Vladimir Pakhomov, but she does not
know any of them personally. As a specialist in the Back Office, her duties included entering information about clients
and their account status into the Fancy programme from client contracts and bank statements of QBF LLC on
accounts opened with various banks. Information about client contracts and information from them was sent to her
by employees of the Middle Office of QBIF Ltd. The Fancy programme reflected information on clients, their financial
portfolio, assets, account balances and other information relating to the subject matter of the contract concluded
between the client and QBF LLC. Her (Sysoeva V.M.) task was to analyse the statements on settlement accounts for the
receipt and debiting of funds of the company's clients on the settlement accounts of IC QBF LLC and to enter this
information into the Fancy programme. In addition, she made "withdrawals" of clients' funds, namely transfers from
the settlement account of QBF LLC to the client's personal account, if the client wished to withdraw his funds.
Information on the amount of money transfer to the client was reflected in the Fancy programme. Each employee
individually logged in to the Fancy programme with a personal login and password. Viewing and downloading of bank
statements, as well as operations on transfer of funds to the client on the settlement account of the company IC QBF
LLC were performed by means of using the bank - client key, which she did not have physically, probably, because the
said key was a virtual one, however, she does not know to whom exactly this electronic key belonged. During her
employment with QBIF Ltd, her colleagues were Anastasia Koval, Miroslav Radišić, Hasanov Hasan, Mikhail Polnikov,
528
Daniil Hoves, Vyacheslav Korneev and other people whose names she does not remember. The chief lawyer of QBF
Group was Evgeniya Rossieva and the chief accountant was Ekaterina Gramza. In April 2021, she resigned from QBF
LLC due to the fact that since January 2021, her workload increased, she had to constantly stay at work afer the end
of the working day, there was practically no automation of the system and it was necessary to enter information
about clients and various operations manually, and salary delays began;
(Vol. No. 271, pp. 153 - 156)
-G .A. Hasanov's Testimony as a witness,

according to which he had an advert on the website "hh.ru" for job vacancies. Around October 2020, he received a call
from representatives of QBF and was invited for an interview at the office located at 8 Presnenskaya Naberezhnaya
Naberez, Moscow, Capital City building of the Moscow City business centre. The interview took place in two stages.
The first stage of the interview was conducted by a "hr" - specialist. The second stage of the interview was conducted
by Timokhin Oleg. Afer the interview, on 31 October 2020, he became an employee of QBF LLC as a junior specialist of
the BEC office with a salary of approximately RUB 60,000. He (G.A. Hasanov) received his salary on his bank card with
the designation "salary crediting". His direct supervisor was Timokhin Oleg, who in turn reported to Matyukhin
Stanislav. He (G.A. Hasanov) worked in the BEC office of the company, and Timokhin Oleg was the head of the BEC
office. IC QBF LLC was part of the QBF group of companies, but he does not know exactly how many and which
companies were part of the QBF group of companies. QBF's office was located at 8 Presnenskaya Naberezhnaya
Naberezhnaya Street, Moscow, Moscow City business centre, Capital City building. Later the office was located in the
Federation Tower building. The main activity of OOO IC QBF was attracting clients for brokerage services and trust
management of funds invested by clients. The head of LLC IC QBF was Stanislav Matyukhin. His (G.A. Hasanov) duties,
as a specialist of the Back Office, included entering information on clients and their account status into the Fancy
programme from client contracts and bank statements of QBIF LLC for accounts opened with NSD, BKS, Bestfards,
Alfa - Bank, and Sberbank. Information about client contracts and information from them was sent to him by
employees of the Middle Office of QBIF LLC. The Fancy programme reflected information on clients, their financial
portfolio, assets, account balances and other information relating to the subject matter of the contract concluded
between the client and QBF LLC. His (Gasanov G.A.) task was to analyse the statements on settlement accounts for
receipt and write - off of funds of the company's clients on settlement accounts of IC QBF LLC and to enter this
information into the Fancy programme. Fancy was accessed using a personal login and password by each employee
individually, however, afer 26 May 2021, Fancy was accessed using universal logins and passwords. Viewing and
downloading of bank statements on the current account of the company IC QBF LLC was carried out through the use
of a bank - client key, which he (Hasanov G.A.) did not have physically, probably because the said key was virtual, this
access was provided by installing a number of special programmes, the names of which he does not remember. In
December 2020 and later in May 2021, law enforcement officers conducted investigative actions in the offices of the
company QBIF LLC and QBIF Group, afer which most of the company's employees resigned. He continued his
employment with the company until 15 September 2021, afer which he resigned at his own request;
(Vol. No. 271, pp. 158 - 161)
- A. V. Tumilovich's Testimony given to her as a witness,

according to which, she had an advert placed on the website "hh.ru" for an accountant vacancy. Around November
2019, she received a call from representatives of QBF and was invited to an interview at the office located at 8
Presnenskaya Naberezhnaya Naberezhnaya Street, Moscow (she does not remember the number of the office) in the
Capital City building of the Moscow City business centre. The interview took place in several stages. The first stage of
529
the interview was conducted by Svetlana Beloded, a "hr" - specialist. The next stages of the interview were conducted
by the chief accountant of QBF company Ekaterina Gramza and the director of the companies KP Queue - 2, KP Queue
- 3, KP Queue - 4 Irina Shpakova, who is the mother of the main head of QBF company Roman Shpakova. Afer being
interviewed, in approximately November 2019, she became an employee of KP Queue - 3 LLC in the position of chief
accountant with a salary of approximately 70,000 - 100,000 rubles. She received her salary in two instalments. The
first part of her salary, the official part, in the amount of approximately 40,000 roubles, was received in cash from
Ekaterina Gramza, and the second part of her salary, the additional part, in the amount of approximately 40,000 -
60,000 roubles, was received in cash in an envelope, mainly from Ekaterina Gramza. The latter in turn received these
funds from Bogdanova Kristina. Bogdanova Kristina worked in the same office with Savvidi Marina Konstantinovna.
She (A.V. Tumilovich) signed the official part of the salary, which is stipulated by the labour contract, in the salary slip,
and for the second, additional part, she did not sign anywhere, as no slips were provided. She was not interested in
the format of payment of her salary and the source of replenishment of this item of expenditure, as when she was
hired for this job, they discussed the final amount of salary in the amount of 70,000 - 100,000 roubles. Her direct
supervisor was I. N. Shpakova, from whom she (A. V. Tumilovich) received instructions on her work and reported on its
results. To whom I.N. Shpakova was actually subordinate in her work, She (A.V. Tumilovich) worked in the same office
with Ekaterina Gramza, but sometimes Shpakova I.N. worked in the same office with them.N. Shpakova I.N. mainly
worked in Severodvinsk, Arkhangelsk region, where the construction of apartment buildings was carried out by the
following organisations: "KP Queue - 2" Ltd, "KP Queue - 3" Ltd, "KP Queue - 4" Ltd. The offices of OOO KP Ocheriad -
2, OOO KP Ocheriad - 3, OOO KP Ocheriad - 4 were located at the following address: Moscow, Presnenskaya nab. 8,
Moscow City business centre, Capital City building, 11th floor. In turn, LLC KP Queue - 2, LLC KP Queue - 3 and LLC KP
Queue - 4 were part of the QBF group of companies, but she does not know the number of organisations that were
part of this group of companies. The main activity of the QBF group of companies was attracting clients for the sale of
investment products and trust management of money invested by clients. The main activity of LLC KP Queue - 2, LLC
KP Queue - 3 and LLC KP Queue - 4 was construction of apartment buildings in Severodvinsk, Arkhangelsk region. In
addition, the QBF group of companies included Simon Jesso LLC, which was building the Gribovsky Les residential
complex in Odintsovsky district. Several times she (A.V. Tumilovich) had to travel together with R.V. Shpakov to the
construction site of the residential complex "Gribovsky les" to monitor the construction process and meet with
contractors. She (A.V. Tumilovich) had to travel with R.V. Shpakov to the construction site of the residential complex
"Gribovsky les" in his car "Range Rover", the car was driven by R.V. Shpakov. Her (A.V. Tumilovich) duties as the chief
accountant of construction companies included: checking and accounting of certificates of completed works,
reconciliation certificates, writing off materials according to estimates. Only Gramza Ekaterina and Shpakova I.N. had
access to the current account in these organisations. Sometimes she (Tumilovich A.V.) had to replace Gramza E. in her
activities at the time of absence from the office, due to her departure, but the confirmation of payments and
transactions was approved directly by Gramza Ekaterina or Shpakova I.N.N. Around December 2020, law enforcement
officers conducted investigative actions in the offices of QBF Group of Companies, during which she (A.V. Tumilovich)
was not present. Afer the investigative actions, she (A.V. Tumilovich) started looking for work in other companies, as
she saw no point in continuing her career in QBF Group. In March 2021, she resigned from the QBF Group of
Companies;
(Vol. No. 271, pp. 163 - 166)
- A.S. Voitenko's Testimony given to her as a witness,

according to which she had an advert placed on the website "hh.ru" for vacancies. In approximately February 2021,
she received a call from representatives of QBF and was invited to an interview at the office located at 8 Presnenskaya
Naberezhnaya Naberezhnaya Street, Moscow (she does not remember the office number), Capital City building of the
Moscow City business centre. The interview took place in two stages. The first stage of the interview was conducted by
Anastasia, a "hr" specialist. The second stage of the interview was conducted by Timokhin Oleg. Afer the interview, in
approximately February 2021, she became an employee of QBroker LLC at 0.5 rate as a specialist in accounting of
530
client operations with a salary of approximately 60,000 - 70,000 rubles. She (A.S. Voytenko) received her salary on her
bank card opened in Sberbank, with the purpose of payment "salary crediting". Her direct supervisor was Yuri Orlov,
General Director of QBroker LLC. In addition, she had to combine her work in QBroker LLC with her work in QBF LLC,
where her direct supervisor was Timokhin Oleg, who in turn was subordinate to Koval Anastasia, and the latter was
subordinate to Matyukhin Stanislav. She (A.S. Voytenko) worked in the BEK office of the company, the head of which
was Timokhin Oleg. LLC IC QBF and LLC QBroker were part of the QBF group of companies, but she does not know the
total number of organisations that were part of this group of companies. In the course of their activities, QBIF LLC and
QBroker LLC interacted with each other, namely, money transfers were made between the accounts of these
organisations, including for the participation of the company's clients in the financial product "ipo". The main activity
of QBF group of companies was attracting clients for sale of investment products and trust management of money
invested by clients. The Head of QBF Group of Companies was Roman Valeryevich Shpakov. The office of LLC IC QBF
was located at the following address: 8 Presnenskaya Naberezhnaya Naberezhnaya, Moscow, Moscow City business
centre, Capital City building, 11th floor. The principal activity of OOO IC QBF was operational servicing of clients on
brokerage services and trust management of funds invested by clients. The head of LLC IC QBF was Stanislav
Matyukhin. QBroker LLC was located on the 9th floor and later on the 5th floor of the said building. The general
director of QBroker LLC, Yuri Orlov, was also located there. She (A.S. Voytenko) regularly had to move between the
floors, combining her work in QBF IK LLC and QBroker LLC. As a specialist in accounting of client operations, her
duties included forming counter payment orders for the transfer of funds received from the company's clients from
the settlement accounts of OOO IC QBF to the settlement accounts of OOO QBroker, or from the settlement accounts
of OOO QBroker to the settlement accounts of OOO IC QBF. She took information on the required transfer amount
from the Fancy programme, which contained information on the company's clients, their assets and personal
accounts, and financial portfolios. The Fancy programme was accessed by other employees of the company, whose
names she does not remember. These employees uploaded all the information from the programme to her in Excel
format, which she subsequently worked with. She (A.S. Voytenko) does not remember what information, apart from
the amount of the transfer, she entered into the payment order. Around May 2021, law enforcement officers
conducted investigative actions in the offices of the QBF group of companies. Afer the investigative actions, Roman
Shpakov made a statement remotely via video link, explaining that the investigative actions in the company would
not affect the company's activities in any way and the company's work would continue as before, all employees
would receive their promised salaries. In addition, R. Shpakov explained in his speech that none of the employees
should take photos and video recordings of this speech. At the time of his speech via videoconference, as she knows,
R. Shpakov had already been in the United Arab Emirates for a long time. In May 2021, she resigned from the QBF
Group of Companies;
(Vol. No. 271, pp. 168 - 171)
- The testimony of Meshalkina Y.A., given to her as a witness,

according to which she had an advert on the website "hh.ru" for vacancies. Around the beginning of 2020, she
received a call from representatives of QBF and was invited for an interview at the office located at 8 Presnenskaya
Naberezhnaya Naberez, Moscow, in the Capital City building of the Moscow City business centre. The interview took
place in two stages. The first stage was conducted by Fomenko Yulia, a hr specialist, and the second stage was
conducted by Timokhin Oleg. Afer the interview, around the beginning of 2020, she became an employee of QBF LLC
as a specialist in providing support for professional activities on the securities market with a salary of approximately
RUB 80,000. She received her salary in two instalments. The first part, approximately 40,000 roubles, was paid to her
bank card with the payment designation "salary crediting". The second part of her salary, in the amount of
approximately 40,000 roubles, was received in cash in an envelope, mainly from Timokhin Oleg. She did not sign for
531
the receipt of wages in the envelope in the statements. Her (Meshalkina Yu.A.) direct supervisor was Timokhin Oleg,
who in turn reported to Matyukhin Stanislav. Timokhin Oleg was the head of the BEC office where (Meshalkina Y.A.)
worked. LLC IC QBF was part of the QBF group of companies, but she does not know exactly how many organisations
were part of this group of companies. The main activity of the QBF group of companies was attracting clients for the
sale of investment products and trust management of money invested by clients. The head of the QBF group of
companies was Roman Valeryevich Shpakov. The office of LLC IC QBF was located at the following address: 8
Presnenskaya Naberezhnaya Naberezhnaya, Moscow, Moscow City business centre, Capital City building, 11th floor.
The principal activity of OOO IC QBF was attracting clients for brokerage services and trust management of funds
invested by clients. The head of LLC IC QBF was Stanislav Matyukhin. Her duties, as a specialist in providing support
for professional activities on the securities market, included mainly entering information into the Fancy programme
on the company's clients, their assets and personal accounts, and financial portfolios. She took this information from
other programmes of QBF, which contained this information. Each employee logged in to the Fancy programme with
a personal login and password individually. At the beginning of her employment with the QBF group of companies,
she did not suspect that the company's management could carry out fraudulent actions with clients' funds, as the
company had a number of licences from the Central Bank of the Russian Federation to carry out professional activities
in the financial sphere. She had doubts about the legality of the actions of the above - mentioned management of
QBF Group when she was informed during the signing of the employment contract that she would receive part of her
salary in an envelope, the so - called "grey salary", as well as afer she tried to understand the whole process of
providing financial products to the company's clients. During her own analysis of the company's actions, she had
doubts about the fact that financial products were to be sold to clients by QBIF LLC, but for some reason QBroker LLC
acted as an intermediary. She and other employees collected and compiled information on each of the company's
clients, but upper management was interested in the total amount of money invested by the clients, not the number
of financial products and portfolios sold. In addition, there was no information ("bounce back") that the option was
eventually concluded from the higher management, most likely R.V. Shpakov. On the basis of her own observations,
she concluded that the company's management may have collected money from clients under the guise of financial
products, but did not spend it for its intended purpose. All of the above information is purely speculative and based
on her own observation. Afer about 2 months of work in the company LLC IC QBF, namely on 26 March 2021, she
decided to resign from this company, as she was not satisfied with the work regime, had to work overtime, and
overtime was not paid, as well as due to circumstances related to the "grey salary" and her doubts about the legality
of the actions of the management of QBF in the implementation of the main activities of the company. At the time
when she was communicating with the employees of the "hr" department about her dismissal, they offered her to
transfer to work in "QBF Asset Management" LLC. She (Meshalkina Yu.A.) agreed to the proposal, afer which she was
interviewed in two stages. The first stage of the interview was conducted by Smirnova Yaroslava, General Director of
QBG Asset Management LLC, and the second stage of the interview was conducted by Irina Gavrilova, Head of the BEC
Office. Afer the interview, namely on 29 March 2021, she was transferred to the position of a BEC Office Specialist at
QBG Asset Management LLC. Her duties in this position included: compiling reports for the Central Bank, entering
accounting data into the Fancy programme. In approximately May 2021, law enforcement officers conducted
investigative actions at the offices of QBF Group. Following the investigative actions, Roman Shpakov spoke remotely
via video link and explained that those employees who would decide to quit afer the searches had been conducted
from the company were weak people and no one would keep them. She was not present at this speech, but was
informed of the essence of the speech by colleagues who were present. At that time, as she knows, R.V. Shpakov had
already been in the United Arab Emirates for a long time. She resigned from QBF Group on 07 June 2021;
(Vol. No. 271, pp. 173 - 176)
532
- The testimony of Korneev V.S., given by him as a witness,
according to which, during the period of study and afer receiving education, he worked at LLC MC "Granat", which
was later renamed to LLC MC "Moi Finansy". He worked at MC from approximately 2015 - 2016 to August 2020, starting
as a courier and later as an economist. Around 2020, the MC changed members who may have acted for QBF, which
was a large financial services company. Afer the change in the composition of the participants, I.V. Rybalka, director
of the MC, offered him (V.S. Korneev) to transfer to the company LLC IC QBF to the position of a specialist of the BEC
office. He agreed with the proposal and went to work in the said company. His direct supervisor and the head of the
BEC office was Oleg Timokhin. Stanislav Matyukhin was the General Director of QBIF LLC. His (Korneev V.S.) salary was
approximately 50,000 roubles, which over time, with career growth, totalled approximately 70,000 roubles. He
received his salary on his bank card with the purpose of payment "salary crediting". He did not know whether QBF LLC
was part of the QBF group of companies, but he thought that QBF LLC was the QBF group of companies. The office of
LLC IC QBF was located at 8 Presnenskaya Naberezhnaya Naberezhnaya Street, Moscow, Moscow City business centre,
Capital City building, 11th floor. The principal activity of OOO IC QBF was attracting clients for brokerage services and
trust management of money invested by clients. In addition, he knows that the main head of the QBF group of
companies was Roman Shpakov. His (Korneev V.S.) duties, as a specialist of the Back Office, included entering
information into the Fancy Spectr programme from bank statements of IC QBF LLC on accounts opened with NSD, Alfa
- Bank and Sberbank. The Fancy Spectr programme reflected information on clients, their financial portfolio, asset
holdings, account balances and other information related to the subject matter of the contract concluded between
the client and QBIF LLC. His task was to analyse current account statements with regard to the receipt of funds from
the company's clients to the company's current accounts and to enter this information into the Fancy Spectr
programme, so that the company's employees who worked with the clients (employees of the middle office of QB&EF
LLC) could see up - to - date information on the deposited and debited funds of each client, since the employees of
the middle office may not have had access to the company's current accounts. Each employee logged in to the "Fancy
Spectr" programme with a personal login and password individually. Viewing and downloading of bank statements
on the settlement account of the company QBF LLC was done by using the bank - client key, which he (Korneev V.S.)
did not have physically. He does not know to whom exactly this key belonged, he did not receive this key in the bank
and did not sign for it. Besides, his functions included the formation of payment orders when withdrawing clients'
funds. He used the bank - client key to generate payment orders, but the final confirmation of the transaction on the
company's current account took place afer an additional check by a superior, probably Timokhin Oleg. QBIF LLC had
several settlement accounts opened with NSD, Alfa - Bank, and Sberbank, namely ruble and foreign currency
accounts for trust management and ruble and foreign currency accounts for brokerage services. He had access to all
of these accounts of the company and a bank - client key, as it was his job duty to check settlement accounts and
generate payment orders for transactions on these accounts. In December 2020 and later in May 2021, law
enforcement officers conducted investigative actions at the offices of QBIF Ltd and QBIF Group, and the company's
professional licences were revoked shortly aferwards, while the company still had obligations to its clients. Afer the
investigation by law enforcement officials at QBF, many of QBF's clients began requesting refunds of their
investments, but these clients had difficulties in getting their money back. In addition, at that time he learnt that
many of the company's clients were elderly people and were clients of the Bank Vostochny project, these clients were
deceived because they were promised to open a deposit for the money they had invested, but in fact their money was
used to buy options and for this reason these clients could not receive their (clients') invested money on demand. He
does not know who exactly managed the project of "Bank Vostochny" company. In addition, around November -
December 2021, a general meeting was held in the office of QBIF LLC, where lawyer Ekaterina Silaeva was present,
who informed that in case QBIF employees were summoned to law enforcement agencies, they should contact her in
order to have her represent their interests. He did not keep this business card and did not consider it necessary to
seek the services of this lawyer, as he had nothing to hide;
(Vol. No. 271, pp. 178 - 181)
533
- M.I. Polnikov's testimony, given by him as a witness,
according to which, in the period from 2018 to 2020, he worked in various financial companies, mainly related to the
special depository and mutual funds. He obtained an FDIC 6.0 certification allowing him to work with mutual funds,
with Pension Funds, with insurance companies and others. In approximately the second half of 2020, following his job
advertisement on hh.ru, he received a call from representatives of QBF and was invited for an interview at the office
located at 8 Presnenskaya Naberezhnaya Naberez, Moscow, in the Capital City building of the Moscow City business
centre. The interview was conducted in two stages. The first stage of the interview was conducted by hr - specialist
Anastasia, and the second stage of the interview was conducted by Timokhin Oleg. Based on the results of the
interview, in approximately the second half of 2020, he (Polnikov M.I.) became an employee of QBF LLC as a specialist
in transaction support with a salary of approximately RUB 80,000 - 90,000. His direct supervisor was Oleg Timokhin,
who in turn reported to Stanislav Matyukhin. He (M.I. Polnikov) worked in the company's BEK office, and Timokhin
Oleg was the head of the BEK office. He (Polnikov M.I.) does not know reliably whether IC QBF LLC was part of the QBF
group of companies. The office of LLC IC QBF was located at the following address: 8 Presnenskaya Naberezhnaya
Naberezhnaya, Moscow, Moscow City business centre, Capital City building, 11th floor. The principal activity of OOO IC
QBF was attracting clients for brokerage services and trust management of funds invested by clients. The head of LLC
IC QBF was Stanislav Matyukhin. He (Polnikov M.I.) was responsible for entering data into the Fancy Spectr
programme from the bank statements of QBF LLC for accounts opened with NSD Bank. The Fancy Spectr programme
included information on clients, their financial portfolio, asset holdings, account balances and other information
related to the subject matter of the contract between the client and QBF LLC. His task was to analyse current account
statements with regard to the receipt of funds from the company's clients to the company's current accounts and to
enter this information into the Fancy Spectr programme so that the company's employees who worked with the
clients (employees of the middle office of QB&EF LLC) could see up - to - date information on the deposited and
debited funds of each client. Each employee individually logged in to the Fancy Spectr programme with a personal
login and password. Viewing and downloading of bank statements for the current account of QBIF Ltd. was performed
by using the bank - client key, which he did not have, probably because the said key was a virtual one. He did not
receive this key from the bank and did not sign for it. In addition, his functions included forming payment orders
when withdrawing clients' funds. He used the bank - client key to generate payment orders, but the final confirmation
of the transaction on the company's current account was made afer an additional check by a superior manager, by
whom exactly, he does not know. QBIF LLC had several settlement accounts opened with NSD, namely a ruble and
foreign currency account for trust management and a ruble and foreign currency account for brokerage services. He
had access to all the above accounts of the company and a bank - client key, as it was part of his job duties to verify
the current accounts and generate payment orders for transactions on these accounts. In December 2020, and later in
May 2021, law enforcement officers conducted investigative actions in the offices of QBIF LLC and QBIF Group, and
information appeared in publicly available sources of information that QBIF LLC may soon have its licence to carry out
professional financial activities revoked, in connection with which he decided to resign from the company;
(Vol. No. 271, pp. 183 - 186)
- Testimony of Nevskaya Zh. V., given to her as a witness,

according to which she posted her CV on the website "hh.ru" to find a vacancy for herself. Around April 2021, she
received a call from representatives of the QBF group of companies inviting her to an interview. The interview was
conducted by a "hr" specialist and Stanislav Matyukhin, who is the General Director of QBF LLC. The interview took
place at the following address: 8 Presnenskaya Naberezhnaya Naberezhnaya Street, Moscow, office number she does
not remember, the Capital City building of the Moscow City business centre, and in April 2021 she was hired as an
accountant at LLC IC QBF. At the time of her employment at LLC IC QBF, the company had only one accountant, Fillina
Daria, and no chief accountant. Her (Nevskaya Zh.V.) duties as an accountant included: generation of information in
534
the 1C programme by transferring existing information from the FANCY programme. In the FANCY programme the
depository specialists working in QBIF LLC entered information on clients, financial portfolio purchased by them
(clients), information on clients' personal accounts, information on assets sold and purchased by clients for the past
period, mainly the previous day. The FANCY programme was accessed by several employees, but she does not know
who. The FANCY programme was accessed with a specific login and password, but whether this password was
individual for each person or one for all, she does not know. At the time of her employment at QBF LLC, all
information and passwords were provided to her by Daria Fillina. Payroll and work with the company's clients were
not part of her functions and she (Nevskaya J.V.) did not work with them. In addition, during the period of her activity
in the company, she had nothing to do with the clients' funds, the sales department in general and the depository of
QBF. Her direct supervisor was Stanislav Matyukhin, but she received some instructions from Daria Fillina, as D. Fillina
was a more experienced accountant than she (J.V. Nevskaya) and could fulfil the functions of the chief accountant
during the latter's absence. S. Matyukhin's supervisor was Roman Shpakov, who was the head of the entire QBF group
of companies. Matyukhin Stanislav was assisted by Jennifer Strax, who was given documents to sign and had them
signed by her (Strax D.). She (Nevskaya J.V.) received her salary by transferring money to her bank card in the amount
of approximately 20,000 - 30,000 roubles per month, but when she was employed Matyukhin told her that her salary
would consist of two parts, namely the official part, which would be transferred to her bank card in the amount of
approximately 20,000 - 30,000 roubles, and the unofficial part, which would be given to her at work in an envelope in
the amount of approximately 20,000 - 30,000 roubles. However, she was never paid the unofficial part of her salary.
LLC IC QBF was part of the QBF group of companies, but she does not know how many organisations were part of this
group of companies. The office of QBF IK LLC was located at the following address: 8 Presnenskaya Naberezhnaya
Naberezhnaya, Moscow, Moscow City business centre, Capital City building, 11th floor. The main activity of QBF Group
was attracting clients for the sale of investment products and trust management of money invested by clients. She
worked at K - Investment LLC until approximately June 2021, and resigned at her own request because the company
she worked for began to "fall apart" in May 2021;
(Vol. No. 271, pp. 190 - 193)
- Strax D.I.'s Testimony given to her as a witness,

according to which, she placed her CV on the website "hh.ru" to search for an interesting and prestigious vacancy. In
September 2019, she received a call from representatives of QBF Group and was invited to an interview, which took
place in several stages. The interview with her was conducted by "hr" - specialists Zaripova Anastasia, as well as
Baranova Olga, who is the head of the reception. The interview took place at the address: 8 Presnenskaya
Naberezhnaya Naberezhnaya Street, Moscow, she does not remember the number of the office in the Capital City
building of the Moscow City business centre. In September 2019, she was employed at LLC "701" as a receptionist, and
later transferred to LLC "702" to a similar position and with similar duties and team, in fact, only the legal entity was
changed. Her duties included: telephone calls, meeting guests, fulfilment of personal orders from managers, the
orders were of a mundane nature. Her supervisor was Baranova Olga, who gave her instructions on her work. Her
(Strax D.I.) salary was approximately 50,000 - 55,000 roubles, which she received in cash from Bogdanova Kristina, an
employee of QBF. In approximately June 2020, she (Strax D.I.) was transferred to the position of assistant to the head
of QBF LLC, but she was still employed at 702 LLC, in the same position of receptionist. Her supervisor was Stanislav
Matyukhin. Her duties as assistant manager included general administrative functions in the company LLC IC QBF,
organisation of meetings and other assistance to the employees and manager of the organisation, including, inter
alia, drawing up various schedules as instructed by Matyukhin, drawing up tables and keeping records as instructed
by Matyukhin, sending and receiving correspondence, fulfilling requests of a domestic nature. She received work
instructions from Mr Matyukhin S. and reported to him on the results. She did not work as an assistant manager with
the finances and clients of QBF Company and QBF IK LLC, and she was not informed about the essence of these
activities. In turn, Matyukhin S. reported to Roman Shpakov. She (D.I. Shtrax) was paid approximately 80,000 roubles
535
per month, which she also received in cash from Bogdanova Kristina. Bogdanova Kristina also issued salaries to all
employees of LLC IC QBF. When receiving wages from Bogdanova K., she (Shtrax D.I.) signed in some kind of statement
provided to her by Kristina. LLC "701", LLC "702", LLC IC "QBF" were part of the group of companies "QBF", but she
does not know what total number of organisations were part of the group of companies. The offices of LLC 701 and
LLC 702 were located at the following address: 8 Presnenskaya Naberezhnaya Naberezhnaya, Moscow, Moscow City
business centre, Capital City building, 9th floor, and the office of LLC IC QBF was located at the same address, but on
the 11th floor. The main activity of QBF Group of Companies was attracting clients for sale of investment products and
trust management of money invested by clients. The head of QBF Group was Roman Valeryevich Shpakov. Shpakov
R.'s business partner was Zelimkhan Munayev. Also, one of the managers of the group of companies was Pakhomov
Vladimir. During her (D.I. Strax) employment with QBF, she had little or no contact with senior management, as R.
Shpakov did not show much interest in communicating with the company's rank and file. Shpakov could ofen and
confidentially communicate with Zelimkhan Munayev, Vladimir Pakhomov, as well as with Bogdanova Christina,
Linda Athanasiadou , Rossieva Evgenia (the chief lawyer of QBF), and his assistant Kuranina Lyubov. In addition,
Roman Shpakov's mother, Irina Nikolayevna Shpakova, was ofen present at the QBF office. Shpakova I.N. spent a lot
of time in the accounting department of the company and was very worried about the company's activities, was
constantly interested in many issues of the company. She (D.I. Strax) began to have doubts about the legality of the
actions of the above - mentioned management of the QBF Group of Companies afer law enforcement officers
conducted investigative actions in the offices of the QBF Group of Companies in December 2020. Afer this event,
Shpakov R. spoke remotely via video link and explained that there was no cause for concern and that the investigative
actions taking place in the company's office were the work of competitors who were trying to paralyse the activities of
the QBF Group of Companies. Eventually, afer the next investigative actions in the offices of QBF Group in May 2021,
she decided to resign from the company, but Matyukhin S. persuaded her to stay and work. She worked for the
company until June 2021, afer which she resigned at her own request because the organisation was "falling apart"
and there were delays in her salary;
(Vol. No. 271, pp. 195 - 198)
- Testimony of Y.A. Fomenko, given to her as a witness,

according to which, she placed an advert on the website "hh.ru" on the search for vacancies. Around September 2019,
she received a call from representatives of the QBF group of companies and was invited for an interview at the office
located at the following address: Moscow, Presnenskaya Naberezhnaya, Capital City building of the Moscow City
business centre. She was interviewed by Svetlana Beloded, who was the head of the recruitment department of QBF
Group. Svetlana's supervisor was Valeria, Head of HR Department. Afer passing the interview, in 2019, she (Y.A.
Fomenko) became an employee of LLC "F - Experts" in the position of "hr" - specialist with a salary of approximately
60,000 rubles, which she received in cash in an envelope. The salary was handed over to her by employees of the
accounting department with whom she was not personally acquainted. When receiving her salary, she (Y.A. Fomenko)
recalculated the amount and signed the statement provided to her, where her details were indicated. According to her
labour contract, the amount of her salary was approximately the same as she actually received. In addition to this
amount of salary, she could receive a bonus of approximately 5,000 roubles, which was paid when the "KPi" plan was
fulfilled, i.e. under these conditions it was necessary to select and engage 2 employees per month. When the plan was
fully implemented, she was paid an additional part of her salary in the form of a bonus. On employment she was
initially put on probationary period which was three months. Her duties as a "hr" - specialist included: searching for
employees for QBF, initial conversation with the candidate, determining the expected direction of his further work in
the company, taking into account the candidate's desire and skills, as well as personal qualities. Mostly employees
were required in QBF company in the sales department for the positions of financial advisors and sometimes at the
reception desk for the positions of secretaries. F - Experts LLC was part of the QBF group of companies, but she does
not know the total number of organisations that were part of this group. The office of F - Experts LLC was located at 8
536
Presnenskaya Naberezhnaya Naberezhnaya Street, Moscow, Moscow City business centre, Capital City building. The
main activity of QBF Group was to attract clients for the sale of investment products and trust management of the
money invested by clients. Roman Valeryevich Shpakov was the head of QBF Group and the main shareholder of the
company, and one of the main managers of QBF was Zelimkhan Munayev. In addition, she had heard of Vladimir
Pakhomov, an employee of the St. Petersburg branch of QBF, but did not know him personally. Her fellow "hr"
specialists were: Zaripova Anastasia, Maria, Ekaterina. Afer investigative actions by law enforcement officers in the
office of QBF in December 2020, the company managers explained that the reason for the appearance of employees in
the office of the company is a routine check, which many financial companies are subjected to, and there is no cause
for concern. She began to have doubts about the need for further employment with QBF afer law enforcement
officers conducted another investigation at the QBF office in May 2021 and wage delays began. She worked at F -
Experts LLC until 03 June 2021, afer which she resigned from F - Experts LLC at her own request;
(Vol. No. 271, pp. 200 - 203)
- I. O. Abramova's Testimony given to her as a witness,

according to which, afer graduating from university, she searched for a vacancy for a marketing specialist interesting
for herself on various resources. In January 2019, she found in social networks a vacancy of a marketing specialist in
QBF company that interested her. She (Abramova I.O.) contacted the initiator of the advertisement and arranged a
meeting in the office located at the address: Moscow, Presnenskaya Nab., office number she does not remember, the
building "Capital City" of the business centre "Moscow City". The interview with her was conducted by "hr" -
specialists in several stages. At the interview they discussed that she (I.O. Abramova) would be engaged in preparation
of events for clients and employees, development of various marketing materials - printed products for employees,
notepads, pens, folders. On 16 January 2019, she became an employee of LLC "F - Experts" in the position of
"marketing and communications manager" with a salary of approximately 30,000 rubles according to the contract,
but the employment contract itself did not specify the above position. Her salary was fixed and did not depend on her
performance. In addition to the salary specified in the contract, other payments were made from time to time, but she
does not remember the exact frequency and amount of these payments. The salary was brought by the receptionists
twice a month. She did not know the receptionists personally and did not know their names. She also does not know
who handed the money to the secretaries. The secretaries went around the office with bags and handed out
envelopes with salaries to the employees. The money was mostly paid between the 10th and 15th and 20th and 25th
of each month. Later on, the payment of salaries became irregular, and later the money started to come from other
employees and line managers by card transfer. The fact that she worked for F - Experts and not QBF, despite the fact
that all the company signs bore the abbreviation "QBF", did not bother her. There was no question in her mind that
the company was different and not QBF as it is a common situation when there are multiple subsidiaries. Her
workplace was directly in QBef's office in the Capital City building on the 9th floor. She was aware that QBF was a
group of companies, but she did not know which companies might be part of the group. She received all tasks
personally from Irina Ayatova, her (I.O. Abramova) direct supervisor, or from another department directly, for example
from the HR department or from a neighbouring department. Irina Ayatova was a line manager. In total, she (I.O.
Abramova) was involved in organising and running 2 events during her employment. These were an entertainment
event in honour of the 23rd of February celebration, and one event in the company office related to some business
part. Her (Abramova I.O.) function was to organise the event, promote it, inform about it. She did not develop
materials for the event, she only performed the functions of a manager. She does not know for which clients the
events were organised. She handed over the invitations that she prepared for the speakers - financial advisors of QBF,
namely Murashev Alexei and Fedorov Maxim, as well as for other financial advisors, and they contacted the clients.
The drafs of the presentations were given to her by the financial advisors themselves and these employees were the
event organisers for her (I.O. Abramova), and her function was to make the design. She knows that Vladimir
Pakhomov was a regional manager who was later transferred to St. Petersburg. There was also an employee of QBF,
537
Munaev Zelimkhan, but she does not know what his position was. She considers only Roman Shpakov to be a high -
ranking manager of QBF. She resigned from QBF around the end of July 2021 at her own request, as her salary had
stopped being paid since May 2021;
(Vol. No. 271, pp. 207 - 211)
- The testimony of Tarakanovskaya M.V., given to her as a witness,

according to which, she placed her CV on the website "hh.ru" to look for a job and around September 2020 she
received a call from representatives of the group of companies "QBF" and was invited for an interview. The interview
was conducted by a "hr" - specialist and Yuri Orlov, who is the head of the "IT" department of QBF. The interview was
held at the following address: 8 Presnenskaya Naberezhnaya Naberez, Moscow, Capital City building of the Moscow
City business centre. In September 2020, she was hired as a junior information security specialist at F - Technologies
LLC. Her duties included: drafing organisational and administrative documentation in the field of IS and IT for QBIF
and QBIF Asset Management LLC, as well as bringing the documentation into compliance with the requirement of the
Central Bank of the Russian Federation Regulation No. 684 - p of 17.04.2019 "On Establishing Mandatory
Requirements for Non - Credit Financial Organisations to Ensure Information Protection in Financial Market Activities
to Prevent Illegal Financial Transactions". Support of the company's clients was not part of its functions, it did not
work with clients. F - Technologies LLC, under an outsourcing agreement, provided services to QBF IK LLC and QBF
Asset Management MC LLC, which in turn carried out the main activity in the QBF group of companies, selling the
company's financial products and accumulating the company's clients' funds on their accounts. The head of QBIF LLC
was Stanislav Matyukhin and the head of QBIF Asset Management LLC was Yaroslava Smirnova. Her (Tarakanovskaya
M.V.) direct supervisor was Yuri Orlov, from whom she received instructions on her work and reported on the results of
her work. Yuri Orlov reported on the results of his work and reported directly to the Chairman of the Board of
Directors of QBF, and because F - Technologies LLC provided services for QBF IK LLC and QBF Asset Management LLC,
Orlov could interact with Stanislav Matyukhin and Yaroslava Smirnova. In approximately March 2021, Yuri Orlov
moved to another position, and instead of Y. Orlov, her supervisor was Nikolay Kosarev. Her salary was fixed at
approximately 40,000 roubles per month. In addition to her work, she was still pursuing her master's degree and
spent part of the day studying. She received her salary in cash from Yuri Orlov and signed a document when she
received it, but she does not remember what document it was. The amount of wages under the contract was much
less than the amount she actually received, as these conditions for receiving wages were agreed upon at the job
interview. She was officially employed by OOO F - Technologies. LLC F - Technologies, LLC IC QBF and LLC MC QBF
Asset Management were part of the QBF group of companies; she does not know the total number of organisations
that were part of this group of companies. The office of F - Technologies LLC was located at the following address: 8
Presnenskaya Naberezhnaya Naberezhnaya, Moscow, Moscow City business centre, Capital City building. The main
activity of QBF Group was to attract clients for the sale of investment products and trust management of the money
invested by clients. The heads of the QBF group of companies were Roman Valeryevich Shpakov, Zelimkhan Munaev
and Vladimir Pakhomov. She began to have doubts about the legality of QBF's actions afer law enforcement officers
conducted investigative actions in the QBF office in May 2021. She worked at F - Technology LLC until approximately
July 2021, at which time she resigned from F - Technology LLC at her own request as delays in salary payments began.
During her employment with QBF she had to communicate with various employees of the company, some she
remembers, such as: Evgenia Rossieva, who was QBF's chief lawyer; Nikolai Padalko; Rinat Amerov; Olya Baranova;
Ruslan Spinka, head of the sales department; Tural Godirli, head of the analytics department; Vladimir Maslennikov;
Maxim Yudin, operations director; Gleb Trishin; Andrei Korzh, head of the sales department; Evgeny Mikhalevich, who
was a security representative of QBF Group; Artem Tallerov; Rinat Amerov; Oleg Timokhin;
538
(Vol. No. 271, pp. 215 - 218)
- The testimony of M.V. Bugaev, given by him as a witness,

according to which, in February - March 2019, according to his advertisement on the website "hh.ru" about the search
for vacancies in the financial sector, representatives of the group of companies "QBF" called him and invited him to an
interview in the office located at the following address: Moscow, Presnenskaya Naberezhnaya, building "Capital City"
of the business centre "Moscow City". He was interviewed by Alexey Korolenko. Afer the interview, in February -
March 2019, he (M.V. Bugaev) became an employee of QBIF LLC as an analyst with a salary of approximately RUB
70,000. The amount of his salary was fixed and did not depend on the results of his work. His salary was transferred to
his bank card in two instalments. As he had the FSFM 1.0 certificate, he was transferred to the position of trust
manager at QBF LLC in the autumn of 2020 and further, in February - March 2021, to the position of dealer at QBF LLC.
However, despite holding these positions, he continued to perform the functions of an analyst, combining them with
his duties as a dealer and trustee. His duties as an analyst included: analysing the Russian securities market, namely,
gathering information on Russian companies whose securities are currently traded on the exchange, analysing the
revenues of the companies represented on the market, and the prospects for the development of these companies.
QBIF LLC was part of the QBIF group of companies, but he does not know the number of organisations that were part
of this group of companies. The office of QBF was located at 8 Presnenskaya Naberezhnaya Naberezhnaya Street,
Moscow, Moscow City business centre, Capital City building. The principal activity of QBF Group was attracting clients
for the sale of investment products and trust management of funds invested by clients. QBF realised the following
financial products: Trust management, Brokerage services, ipo (participation in the American market, as well as to
some extent in the Russian market). Roman Valeryevich Shpakov was the head of QBF Group and the main
shareholder of the company. While working in the company, he (M.V. Bugaev) heard about such persons as Munaev
Zelimkhan and Pakhomov Vladimir, but he does not know who they were in the company. He (M.V. Bugaev) reported
on the results of his work to Alexei Korolenko, who in turn reported to Stanislav Matyukhin. Stanislav Matyukhin was
the General Director of QBIF LLC. LLC IC QBF had licences to carry out brokerage activities, dealer activities,
depository activities and trust management. His (M.V. Bugaev) fellow analysts with whom he had the opportunity to
work were Yulia, Pyotr, Nikita, Artur, he does not remember their surnames. At the end of 2020 and in May 2021, law
enforcement officers carried out investigative actions in the office of QBF, but he does not know the reason for them.
He worked at QBF LLC until August 2021, afer which he resigned at his own request, as the CBR withdrew the
company's professional licences and therefore the company could no longer function, and he saw no point in
remaining at QBF LLC;
(Vol. No. 271, pp. 220 - 223)
- A. S. Zaripova's Testimony
given to her as a witness, according to which, in 2016, she moved to Moscow and placed an advertisement on the
website "hh.ru" to find vacancies. Around 2018, she received a call from representatives of the QBF group of
companies and was invited for an interview at the office located at the following address: Moscow, Presnenskaya
Naberezhnaya, Capital City building of the Moscow City business centre. She was interviewed by Svetlana, who was
the head of the recruitment department of QBF Group. Following the interview, in 2018, she became an employee of F
- Experts LLC as a recruitment specialist with a salary of approximately RUB 80,000. She received her salary in cash, in
an envelope handed to her by the accounting department. When she received her salary, she recalculated the amount
and signed the statement provided to her, where her surname, first name and patronymic were indicated. According
539
to her labour contract, the amount of her salary was less than the amount she actually received, as the difference in
the amount of salary was a condition for fulfilling the "KPi" plan, i.e. she had to select and engage about 5 - 7
employees per month according to these conditions. On full fulfilment of the plan, she was paid an additional part of
her salary in the form of bonus. She does not remember the amount of bonuses and the full amount of salary under
the labour contract. When she was employed, there was a probationary period of three months. Afer the expiry of the
probationary period, she had an attestation for compliance with her position. Svetlana, who was the head of the
recruitment department of the QBF Group of Companies, conducted the certification with her. Her (Zaripova A.S.)
duties as a recruitment specialist included: searching for employees for QBF, initial conversation with the candidate,
obtaining from the candidate documents confirming the candidate's education and work experience, orienting the
candidate to a specialist or manager of the line of business for which the candidate expressed his/her desire. Mostly
employees were required in QBF company in the sales department, marketing department, IT department for various
positions, including: manager, specialist, financial advisor. F - Experts LLC was part of the QBF group of companies,
but she does not know the number of organisations that were part of this group of companies. The office of F - Experts
LLC was located at 8 Presnenskaya Naberezhnaya Naberezhnaya Street, Moscow, Moscow City business centre,
Capital City building. The main activity of QBF Group was to attract clients for the sale of investment products and
trust management of the money invested by clients. Roman Valeryevich Shpakov was the head of QBF Group and the
main shareholder of the company. Her fellow recruitment specialists were Yulia and Marina, whose surnames she
does not remember. In the summer of 2021, she resigned from QBF of her own volition as she had found another job;
(Vol. No. 271, pp. 227 - 230)
- N.S. Burlakova's Testimony

given to her as a witness, according to which, in 2012, she graduated from the Moscow Law Academy with a
specialisation in civil - law relations. From the summer of 2017 until the beginning of November 2020, she was
employed by JSC "QBF Financial Group" as a lawyer. She received an offer of employment afer posting her CV on the
website "HH.ru". She dealt with legal issues related to the Company's activities: drafing contracts, opening bank
accounts, replacing Articles of Association of Companies, preparing documents regarding the opening and closing of
Companies in Russia, participating in various courts on behalf of the Company, dealing with technical issues related
to changing company data and so on. She did not make decisions on all working issues, all tasks and assignments
were received from her supervisor E. Rossieva. Her (Burlakova N.S.) strategy of behaviour in courts, her (Burlakova
N.S.) direct supervisor Evgenia Anatolievna Rossieva always indicated to her (Burlakova N.S.) strategy of behaviour in
courts, striving to achieve a certain (beneficial to the Company) result. At the time she was hired by the company, E.
Rossieva was already the head of the legal department. The legal department had a staff of at least 6 people. She
remembers Madina Bederdinova, Antonina Shebukova, and a young man named Maksim from the legal department.
Her workplace was located on the 8th or 9th floor of the City of Capitals Tower, at 8 Presnenskaya Street, Building 1,
Moscow. At the time of her employment, she was given a SIM card with a personal corporate subscriber number 8 -
903 - 100 - 51 - 33, which she used personally. E.A. Rossieva was engaged in interaction with the Central Bank of Russia
(holding meetings at the Central Bank of Russia, where E.A. Rossieva travelled together with S.A. Matyukhin;
supporting inspections conducted by the Central Bank of Russia; supporting inspections conducted by S.A. Matyukhin
and S.A. Matyukhin.She participated in court sessions of civil courts (formed the Company's position, personally
participated in court sessions, personally drafed procedural documents), participated in meetings with clients of JSC
"QBF Financial Group", made decisions on creation of new companies and liquidation of existing companies, changed
information about companies (addresses, charters), replaced directors of companies, was engaged in legal evaluation
of new financial products created by the Company and planned to offer them to the clients of JSC "QBF Financial
Group". Her (Burlakova N.S.) workplace was located in the same room together with Rossieva E.A. Feoktistov R.V., who
from 26.02.2020 was the General Director of the Limited Liability Company "QUBIEF" (INN 7703458823) is familiar to
her. At the beginning of 2020 Rossieva E. gave her (Burlakova N.S.) his (Feoktistov R.V.) mobile phone number and
instructed her to call him and organise a personal meeting. Rossieva E. made a decision to appoint Feoktistov R.V. as
540
the General Director of LLC "QUBIEF" and she (Burlakova N.S.) had to meet Feoktistov R.V., receive from him the
necessary package of documents with personal data, to form a package of documents for the appointment of
Feoktistov to this position. She (Burlakova N.S.) also accompanied Feoktistov to a notary to draw up notarised
applications and possibly powers of attorney. She was engaged only in the technical component, and she was not
interested in the reasons and necessity of Feoktistov's appointment as general director. She met with O.V. Vasyukova,
who was registered as the General Director of LLC "M1 Invest" (INN7701367560) and possibly engaged in her
employment as the General Director of LLC "M1 Invest". On instructions of Rossieva E. she was engaged in preparation
of documents related to employment for the positions of general directors, directors of the Companies in respect of a
large number of candidates and she is physically unable to remember them all. Probably, the data about the
mentioned person, subscriber number is available on the sheets of the work notebook, which was seized on
25.03.2022 during the search at her place of residence. Choporov Dmitry Alexandrovich, Kochetkova Natalia
Vladimirovna, Melnikova Maria Alexandrovna, Zvarin Evgeny Nikolaevich, Diordits Alexander Veniaminovich, Polibin
Ivan Alexandrovich are familiar to her, on the instructions of Rossieva E.A. she was engaged in the preparation of
documents on these persons for employment in management positions or their inclusion in the founders of one of
the Companies. She no longer remembers the names of these companies. She knows the data of Syuksyumov Maxim
Mikhailovich, most likely he was excluded from one of the companies according to the working task assigned to her by
Rossieva E. during the court session. The companies QB Capital LTD, Yurmaster LLC (QCUSISIAI LLC), White Lake,
SIMTELLIGENCE COMPANY LIMITED, QCCI Ltd., White Lake are "on her ear", she heard about them from Rossieva E.,
from employees of the accounting department, possibly from other employees of the company. She also knows that
Rossieva E. ordered a round seal for a company in the Cayman Islands called "WLM" on the territory of the Russian
Federation. During her work in the company, she knew the following employees who held the following positions and
performed the following duties: Ruslan Spinka - an employee of the company in which she (Burlakova N.S.) was
employed, engaged in activities related to sales and contacts with clients; Nikolai Sergeyevich Padalko - an employee
of the company, engaged in activities related to contacts with clients; Yuri Nikolayevich Orlov - an employee of the
company, programmer; Rinat Felixovich Amerov - an employee of the company, engaged in activities related to the
bank. Since her (Burlakova N.S.) workplace was located in the same room with Rossieva E.A., she (Burlakova N.S.)
heard how Rossieva E.A. addressed Berezka Andrei regarding the acquisition of Yurmaster Ltd;
(Vol. No. 272, pp. 24 - 29)
- Protocol of the search of 25 March 2022, carried out in the dwelling of Burlakova N.S., located at the following
address: Moscow, 6, Sumskaya str. 2, k. 185, during which items and documents containing information relevant to
establishing the circumstances of the criminal case were seized;
(Vol. No. 272, pp. 14 - 18)
- Protocol of examination of items and documents dated 25 March 2022, seized on 25 March 2022 in the course of the
search in the dwelling of Burlakova N.S., located at: Moscow, Sumskaya str. 2, k. 185, during which the documents
relevant to the criminal case were examined, some of the documents were attached to the case file;
(Vol. No. 272, pp. 34 - 91)
541
- physical evidence -
54 pages from a diary and 2 stickers, seized on 25 March 2022 during the search in the dwelling of Burlakova N.S.,
located at the address: 6, Sumskaya str. in Moscow, k. 2, sq. 185, with handwritten notes of addresses of electronic
mailboxes, passwords, mobile phone numbers and identification data of individuals who were appointed nominal
directors and participants of companies under the control of the company. 2, sq. 185, with handwritten records of
e - mail addresses, passwords, mobile phone numbers and identification data of individuals who were appointed as
nominal directors and participants in companies controlled by the participants of the criminal association (criminal
organisation);
(Vol. No. 272, pp. 92 - 93)
N.V. Modin's Testimony as a witness,

according to which in 2008 - 2009 he got a job as a consultant at MainStreamConsulting LLC, where he met Roman
Valeryevich Shpakov. The main activity of MainStreamConsulting LLC was dealer activities, brokerage activities,
securities management activities, activities of professional securities market participants. Afer about one year of
work, having found common interests with R.V. Shpakov, he and R.V. Shpakov decided to leave MainStreamConsulting
LLC and establish their own organisation, Qubey Finance LLC, with a similar type of activity. R.V. Shpakov involved
Sergei Lvovich Kuzin, who was also a founder of Qubey Finance LLC, in the organisation. He (Modin N.V.) was a
founder of Qubey Finance LLC in terms of 24.5 per cent of shares and held the position of director of Paradise.
Shpakov was the commercial director and founder of Qubey Finance LLC, and Kuzin held the position of financial
director and founder of Qubey Finance LLC. Frolov Vladimir Georgievich held the position of the General Director of
LLC "Kyubey Finance", but he (Frolov V.G.) was not a founder. Frolov V.G. was a nominal director who did not make any
independent decisions in this organisation. The actual head of LLC "Kyubi Finance" was R.V. Shpakov, who
independently conducted all financial and economic activities of the organisation. His (Modin N.V.) functional
responsibility included the general organisation of the Company's activities, namely the rent of premises, control of
payment of bills, payment of salaries to the employees of the organisation. Roman Valerievich Shpakov was directly
involved in and controlled all financial issues related to the main type of financial and economic activity of the
Company. Initially, the office of Qube Finance LLC was located at Krasnopresnenskaya metro station in Moscow, and
later the organisation changed its address to another one located in the Moscow City business centre at the address: 8
Presnenskaya Embankment, bldg. 1, Moscow. Several similarly named organisations were subsequently registered in
this office. The composition of the founders and management of these organisations was virtually the same as that of
Qubey Finance LLC. To register Qubey Finance LLC, he (Modin N.V.) personally went to the Federal Tax Service on
Tushinskaya Street in Moscow. In the course of the activity of Qubey Finance LLC, Shpakov R.V. and Kuzin S.L.
established other organisations similar in name and type of activity, where the composition of founders and
management may have been similar to Qubey Finance LLC. Afer about one year of joint work with R.V. Shpakov and
S.L. Kuzin in LLC "Kyubey Finance" and other organisations similar in name and type of activity, he (N.V. Modin) and
other founders had a conflict on the grounds of mutual misunderstanding of each other, and he (N.V. Modin) was
offered by S.L. Kuzin to withdraw from the founders of LLC "Kyubey Finance" and other organisations, as well as to
resign from the position of development director. He agreed to Kuzin S.L.'s decision on the condition that he (Modin
N.V.) pay him (Modin N.V.) $50,000 in compensation. Kuzin S.L. agreed to pay him (Modin N.V.) the backpay. Afer his
resignation and dismissal, Kuzin S.L. paid him (Modin N.V.) USD 40,000 in cash and has not paid the remaining USD
10,000 to date. LLC "Kyubi Group" INN 7701876374 was established without his participation, probably by R.V.
Shpakov and S.L. Kuzin;
(Vol. No. 272, pp. 96 - 99)
542
- The testimony of Kuzin S.L., given by him as a witness,
according to which he has two higher education degrees, previously worked in various managerial positions in
commercial enterprises. Approximately at the end of 2010 he was approached by Roman Valerievich Shpakov,
previously unknown to him, with a group of 2 - 3 persons with a proposal to become a client of his organisation, which
carried out dealer, brokerage activities, securities management activities and activities of professional participants of
the securities market. He (Kuzin S.L.) was not interested in this proposal, as he needed to independently monitor the
movement of his invested funds. He set his own conditions before Roman Shpakov, namely that he (Kuzin S.L.) was to
become a business partner and be a co - founder in the organisation KG LLC (Kyubi Group) INN 7701876374. Some
time later he was again approached by Roman Shpakov and his partner Nikolay Vitalievich Modin, who agreed with
his (Kuzin S.L.) conditions and provided him (Kuzin S.L.) with their business plan. The business plan provided by
Shpakov and Modin satisfied him and he (Kuzin S.L.) became a co - founder of LLC "KG" (Kyubi Group) INN
7701876374 in shares of more than 51 %. Since he is aware of and has experience in dealer and broker activities,
securities management activities and activities of professional participants of the securities market, he invested his
personal funds in the amount of approximately 200,000 - 300,000 US dollars in the development of KG (Kyubey Group)
LLC, becoming a participant and co - owner of Shpakov R.V.'s business, as well as became the financial director of KG
(Kyubey Group) LLC. At the time when he (Kuzin S.L.) joined the founders of LLC "KG" (Kyubey Group), this
organisation had no clients and no company licensed to carry out stock exchange and brokerage activities. He (Kuzin
S.L.) together with other participants of KG LLC found a suitable organisation with a licence on the market and
purchased it. Perhaps this organisation could be called LLC Investment Company Kybief. Afer acquiring an
organisation with a licence, they needed a manager who had the appropriate licence to carry out this type of activity.
Vladimir Georgievich Frolov, who had a licence, was selected for the above purposes. Frolov was appointed general
director of an organisation which they had acquired with a licence to carry out stock exchange and brokerage
activities, possibly LLC Investment Company Kybief. V.G. Frolov was the nominal director of this organisation and did
not make any decisions on his own. All decisions were made by Roman Valeryevich Shpakov. Frolov did not sign any
documents on his own, because afer his appointment as general director Frolov issued a power of attorney in the
name of Shpakov R.V. The power of attorney gave Shpakov the right to sign all documents, including financial
documents on behalf of the director of LLC "KG" (Kyubi Group) Frolov Vladimir Georgievich. Frolov received a regular
salary for his position as general director and hardly ever appeared in the office. Initially, the organisation's office was
located in premises located in Moscow on 1905 Year Street, afer which they rented an office in the Moscow City
business centre, presumably on the eighth floor of the building. Having joined the founders of LLC "KG" (Kyubi
Group), he (Kuzin S.L.) attracted several depositor clients, afer which the clients came on their own and invested their
funds. The organisation developed and brought profit. Roman Shpakov was personally involved in all the activities of
the organisation and decisions, including financial ones, related to the activities of KG LLC (Kyubi Group) were made
directly by Roman Shpakov. He (Kuzin S.L.) and Modin Nikolay helped Shpakov in organising the general activities of
KG LLC (Kyubi Group), making their proposals as members of the Company. Soon Modin and Shpakov had
disagreements on the implementation of the Company's activities and Modin decided to withdraw from the founders
of KG LLC (Kyubey Group) on the condition that he (Modin N.) received a certain amount of money. About six months
afer Modin Nikolay lef the founders of KG (Kyubey Group) LLC, he (Kuzin S.L.) also had disagreements with Shpakov
Roman on the implementation of the Company's activities. In 2013, he decided to withdraw from the founders of KG
LLC (Kyubey Group) on the condition of receiving a certain amount of money, which is not less than the amount he
contributed to the development of KG LLC (Kyubey Group). He remembers Vladimir Sergeyevich Pakhomov and
Zelimkhan Visaitovich Munaev, they were former managers of KG (Kyubi Group) LLC;
(Vol. No. 272, pp. 106 - 109)
543
A.A. Kuznetsova's Testimony given to her as a witness,
according to which she had the surname Ananyeva until December 2020, in November 2020 she got married and
changed her surname to Kuznetsova. She has no knowledge of dealing and brokerage activities, securities
management activities and activities of professional securities market participants. In about 2015 she met Munaev
Zelimkhan in the social network "Instagram" and afer some time of communication with him, she (Kuznetsova A.A.)
and Munaev Z. began to live together. They lived with Munaev Zelimkhan for about 3 years, from 2015 to 2018. She
knows that Munaev Zelimkhan worked in an organisation called QBF, which was engaged in investment and
brokerage activities, where the head was Shpakov Roman. Munaev Zelimkhan held the position of director of sales
department or financial director in the above organisation, however, she did not know his (Munaev Z.) salary, in
conversation Munaev Zelimkhan said that the level of salary depends on the amount of work done in the current
month. The office of QBF was located in the Moscow City business centre at 8 Presnenskaya Naberezhnaya
Naberezhnaya Street, Moscow, page 1, 9th floor. She did not know all the employees and managers of this group of
companies personally, but together with Munaev Zelimkhan she attended various corporate events where employees
and managers of the QBF group of companies were present. During corporate events, Munaev Zelimkhan introduced
her to his colleagues and work partners, including Roman Shpakov, Vladimir Pakhomov, Nikolai Mikhailov, Ekaterina
Gramza (accountant), and Olga Bataeva, Svetlana Beloded (HR officer), Vetis Vartanov, Madina Abaeva (analyst),
Stanislav Matyukhin, Maxim Fedorov, Nikolay Padalko, Maxim Yudin, Dmitry Lepeshkin, Ruslan Spinka, and Linda
Athanasiadou, whose husband was also present at corporate events.15 March 2018, on the proposal of Munaeva Z.
became a participant of LLC "Kyubi Group" INN 7701876374 in the share of 6% of the share capital. She did not
contribute any money, as she had previously transferred USD 25,000 to Munayev Z. Her share in the authorised capital
was a guarantee of repayment of the money lent to Munayev. The director of LLC "Kyubi Group" INN 7701876374 was
Elena Vyacheslavovna Gorobets. She (A.A. Kuznetsova) did not meet E.V. Gorobets at the notary when signing the sale
and purchase agreement, as the agreement already had Gorobets' signature. The participants of LLC "Kyubi Group"
were Roman Shpakov and Vladimir Pakhomov, with whom she had been personally acquainted earlier by Zelimkhan
Munayev. According to the oral agreement with Munaev Zelimkhan, she was not required to participate in the
activities of LLC Kyubi Group and make any decisions. She did not receive any dividends from participation in the
Company. She (A.A. Kuznetsova) did not read the title of the documents and their content, and the person who
provided her with the documents for signature informed her that these documents are the constituent documents of
LLC "Kyubi Group" INN 7701876374. On 21 June 2019, at the request of Munaev Zelimkhan, she withdrew from the
membership of LLC "Kyubi Group", as Munaev Zelimkhan promised to return to her (Kuznetsova A.A.) the money
transferred earlier to him (Munaev Z.) in the total amount of 25 000 USD. Afer leaving the founders of LLC "Kyubi
Group" the money was not returned to her;
(Vol. No. 272, pp. 110 - 113)
- M. M. Khripunov's testimony , given by him as a witness,

according to which he has been working at M - Video since 2013 to date. Approximately in the middle of 2017 or 2018,
Dmitry Choporov, who was newly hired at the M - Video shop, told him during a conversation that he (D. Choporov) is
the director of the firm and receives a salary there. In fact, he (D. Choporov) does not carry out any activities in the
said firm, only signs documents at the request of someone approximately once a month. He (M.M. Khripunov)
personally observed how a courier came to Choporov D. with documents and Dmitry signed them. Choporov D. also
had a round seal with him. From Choporov D.'s explanations it followed that "doing nothing, he (Chopornov D.)
receives additional income". During one of the conversations Choporov D. offered him (Khripunov M.M.) to try to get
additional income and told him the number 8 - 985 - 173 - 43 - 21, the subscriber of which was a woman named
544
Eugenia, as well as the second number 8 - 903 - 100 - 51 - 33, which was an office number and its subscriber was a
woman named Natalia. As he later realised, Natalia was a lawyer and Evgenia was her manager. He had his first
conversation with Eugenia during the summer of 2017 or 2018. In 2021, he learnt from official sources on the internet
about Yevgeniya's detention, recognised her (Yevgeniya) from published photos and found out that her surname was
Rossieva. The first meeting with her (E. Rossieva) took place in a café in one of the towers of Moscow City. As she
(Evgenia) explained, she (E. Rossieva) needed him (M.M. Khripunov) to set up a legal entity. According to Eugenia's
words, the company is "legal" and "legitimate", does not engage in illegal activities and does not evade taxes. Eugenia
explained that there were already many companies registered with "them" and "new blood" was needed. He was
promised a salary of 30,000 roubles a month as a founder for setting up the company. According to the agreement
with Evgeniya, he (M.M. Khripunov) was to be paid his salary afer the company became aware of the company and
started its activity, when the company started to earn money. He met with Evgeniya and her assistant named Natalia
about 10 times in total, the last meeting took place around July 2019. He (M.M. Khripunov) was required to sign the
documents on the establishment of the firm prepared by Evgeniya. At the above meetings with Eugenia or Natalia, as
well as at their joint presence, of which there were about 7 - 8, he (M.M. Khripunov) was brought to the notary. The
notary was located in a building in Moscow City, where he (M.M. Khripunov) signed the completed forms of
documents. He did not pay for the services of the notary, he saw that Natalia handed the money to the notary. During
the period from the first meeting with Evgeny until the present moment, he personally did not apply to the tax
authorities for the creation of legal entities, he did not apply anywhere for electronic signatures and did not receive
them. He has never personally performed any other actions related to the registration, operation and liquidation of
legal entities. Around the end of 2019, he received a call from the tax authority informing him that Vysota LLC, of
which he is the founder, had some problems with providing information on the company. From a conversation with
an employee of the tax authority, he learnt that Vysota LLC had already been formalised and was operating, which he
(Khripunov M.M.) had not been informed about by Evgeniya. He tried to call Evgeniya for several days, but she
"dropped" the calls and replied with SMS messages saying that she would call back later. He had the impression that
Evgeniya did not want to communicate with him. He (M.M. Khripunov) managed to get information to E. Rossieva only
by means of SMS messages. Subsequently, he (M.M. Khripunov) had a telephone conversation with Eugenia, during
which he (M.M. Khripunov) expressed his claims to her (E. Rossieva) about concealing from him (M.M. Khripunov)
information about the start of the company, the lack of payment of wages to him (M.M. Khripunov), suggesting that
Eugenia exclude him from the founders of the company. She (E. Rossieva) replied that the issue with the tax
authorities would be closed in the near future, and that it would take time to remove him (M.M. Khripunov) from the
founders' structure, as it was necessary to find a person to whom the authorised capital would be transferred.
Subsequently, the issue of his withdrawal from the founders of the above company was not resolved and he tried to
contact Eugenia again until the end of spring 2021. Rossieva E. ignored him, did not answer his calls, and later her
(Rossieva E.) subscriber number became unavailable. Around the end of spring 2021, he learnt from a letter he
received from the tax authority that he was also the founder of KG LLC. Afer that, he began to look for information
about legal entities to which he had any relation in open sources, using his TIN number. It turned out that he is related
to the following legal entities: 31.10.2018 he was the liquidator of JSC QBF (TIN 7703399818); in the already liquidated
LLC "Vysota" (TIN 7734371675) from 24.06.2019 he was the head; according to the charter obtained from the tax
authority he is the founder with a share of 6% in LLC "KG" (Qubi Group); he is the founder of LLC "M4 Invest" (TIN
7701973890) and the liquidator of LLC "Techconsulting" (TIN 7703464305). He did not actually manage these
companies, did not carry out financial and economic activities in them, and did not contribute money to the
authorised capital. According to the agreement reached earlier with Evgeny, he agreed to participate in the creation of
two legal entities, with their subsequent re - registration within six months to another person and the liquidation of
one legal entity, the names of which he no longer remembers;
(Vol. No. 272, pp. 118 - 122)
545
- The testimony of E.V. Gorobets, given to her as a witness,
according to which in 1984 she graduated from a polytechnic trade school as a cashier - controller and at the time of
the interrogation works as a maid in LLC "Agro Moscow". In 2017 - 2018, due to her poor financial condition, her
distant relative, namely her niece Voronova Tatyana, offered her additional income, at that time what kind she
(Voronova T.) did not specify. Afer that, at her (Voronova T.) invitation, she (Gorobets E.V.) came to the office of the
company QBF LLC at the address: Moscow, Krasnopresnenskaya naberezhnaya, 8, p. 1. 1. In the office room, Tatyana
Voronova introduced her (E.V. Gorobets) to the owner of QBF LLC, Roman Valeryevich Shpakov, born 12.10.1988, who
said that she (E.V. Gorobets) was suitable for their work. Later Voronova Tatiana explained to her that they were
looking for people for the position of nominee directors of various companies, this situation was connected with the
need to reduce the taxable base for the main company, namely QBF LLC. Voronova also informed her that in fact she
(E.V. Gorobets) would not perform the duties of the General Director, but she (E.V. Gorobets) would have to go to the
tax authorities (hereinafer - NO) to register the Companies for herself and possibly to a notary to certify the
documents to be submitted to the NO. For this service she (E.V. Gorobets) will receive monetary remuneration. She
agreed to this proposal. Due to her legal illiteracy, she (E.V. Gorobets) did not realise that these actions would be
performed by a lawyer.) did not realise that these actions were unlawful, so she subsequently became a nominee
director in the following companies: KG LLC (INN 7701876374), Qubi Credit LLC (INN 7703740234), Sintez LLC (INN
7708270984), F - Technologies LLC (INN 7725726949), Avalon LLC (INN 7718970625), Profkonsult LLC (INN
7715974759). She has nothing to do with the financial and economic activities of the above - mentioned companies,
she did not sign contracts, receipts for PKOs and other financial documents on behalf of the companies. She also
travelled to the LE and to a notary to register herself as a general director in the above - mentioned companies. She
received the documents for filing from the lawyer of "QCCI LTD" Evgenia Anatolievna Rossieva, born 18.05.1974 and
her assistant Natalia Burlakova. She (E.V. Gorobets) does not know anything about "QCCI LTD", "QB Capital LTD" and
their activities, she did not transfer money to these companies according to the receipts to the PKO and did not sign
the receipts. Earlier she was not aware that employees of QBF group of companies concluded contracts with clients
on behalf of foreign companies "QCCI LTD", "QB Capital LTD", providing cash receipts with a facsimile of her signature.
The money in the form of salaries was transferred to her bank card opened with PJSC Uralsib Bank and also
transferred in cash to various secretaries of the QBF company. She travelled to the QBF Group office up to 10 times in
total;
(Vol. No. 272, pp. 132 - 137, 143 - 145)
R.V. Feoktistov's Testimony as a witness,

according to which he has a specialised secondary education in the field of construction. Around February 2020, a girl
named Natalia called him on his mobile phone from the subscriber number 8 - 903 - 100 - 51 - 33 and offered him the
position of deputy general director in a construction company. To get the job, he came to the Moscow City tower in
Moscow and provided Natalia with his passport and SNILS, from which he made photocopies. She also asked him
(Feoktistov R.V.) to take a "selfie" with his passport unfolded; according to Natalia, this photo was necessary for
accounting purposes. Afer that the girl offered to go to a notary and draw up a power of attorney on his (Feoktistov
R.V.) behalf for employment, so that in the subsequent employment in the construction company did not require his
personal presence. He was familiarised with this power of attorney, it stated that he (Feoktistov R.V.) entrusted the
notary to register him (Feoktistov R.V.) as deputy director of the construction company when submitting
documentation to the tax inspection. In the power of attorney, the position was stated as "director/deputy director".
About a month and a half later, Natalia called him and informed him that he (R.V. Feoktistov) was not suitable for a
managerial position in the construction company due to his lack of higher education. She (Natalia) informed him
"that they have many companies" and they would find him another job. Also during the conversation, Natalia asked
him (Feoktistov R.V.) if he knew anyone who had a higher education in construction. He said that his father Valery
546
Pavlovich Feoktistov was such a person. At Natalia's request, he (Feoktistov R.V.) sent her photos of his father
Feoktistov V.P.'s passport, work record book, SNILS and TIN via the WhatsApp application. 1, the southern block of the
Capital City Tower. Natalia met them and took my father to a notary, where he (my father) executed a power of
attorney necessary for employment. He and his father never met Natalia in person again. He (R.V. Feoktistov)
personally did not sign any documents related to the activities of any legal entities, including powers of attorney and
financial documents. During the summer - autumn of 2020, Natalia called him several times and asked if he
(Feoktistov R.V.) had any acquaintances with technical education, referring to the fact that the company was creating
companies that needed people for employment as directors and deputy directors. The firms were new and financial
and economic activity was not conducted on them (firms), employment was supposed for one year, maximum for one
and a half years. Afer the firms would work, competent specialists of the management staff would take the place of
management. He realised that he needed nominal managers of the firms for 1 - 1.5 years. He provided Natalia with the
details of the following persons: Elena Mikheeva, Alexander Veniaminovich Diorditz, Marina Alexandrovna Tochilova,
Olga Vasyukova, Dmitry Belov, Alexei Anatolievich Panov, and Alexander Ivlev. Around the end of September 2020.
Natalia in the course of a telephone conversation asked for assistance in the transfer of funds to the above persons, as
he understood the salary. The courier was given his (Feoktistov R.V.) phone number. The courier handed him
(Feoktistov R.V.) a large sealed envelope. This envelope contained money in sealed smaller envelopes, and each
envelope was signed with the name of the recipient. When he received the envelope with the money, he did not sign
anywhere, the envelope was simply handed to him. He handed the envelopes with his salary to Diordits A. several
times, and then Diordits A. personally travelled and received the money in the "City of Capitals" and also received it
by courier. He (V.P. Feoktistov) gave envelopes with money to M. Tochilova, O. Vasyukova and D. Belov to D. Belov, and
he (D. Belov) himself gave money to M. Tochilova and O. Vasyukova. He (V.P. Feoktistov) also personally handed
envelopes with money to A. Panov. He handed money to Mikheeva E. not more than twice, the other times she took
the money herself. The money was handed over approximately once every two or three months, the amounts were no
more than 20,000 roubles each. The money was always brought by different couriers. The last time the envelopes with
money were handed over was in September 2021. Natalia also asked him if he had any acquaintances for future
employment with the necessary conditions: an economic education, preferably with a legal background and a
mandatory requirement - a foreign passport. I was also interested in whether he (Feoktistov R.V.) had acquaintances in
the Leningrad region for employment. He knows only Irina Nikolayevna Shpakova. He has never met Shpakova I.N. in
person, he only talked to her by phone. Shpakova I.N. called him about 5 times, the conversation at her request took
place in the application "WhatsApp". She introduced herself to him as Irina Nikolayevna Shpakova, former director of
LLC "168 quarter" and wanted to communicate with his (Feoktistov R.V.) father. Shpakova I. demanded that his father
go to the nearest branch of Alfa Bank and sign the necessary documents to unblock the current account, as she
(Shpakova I.N.) said that there had been a change of director. She remembers exactly, Shpakova I. demanded to fill in
some card with signatures and to take away the Charter of the Company. Afer a call from Shpakova I., he (Feoktistov
R.V.) realised that there was some illegal activity with the said Company and explained to Shpakova I. that his father
(Feoktistov V.P.) would not take any action;
(Vol. No. 272, pp. 146 - 151)
- D. G. Buryakovsky's Testimony given as a witness,

according to which he has a higher education, does not have any knowledge of dealer activities, brokerage activities,
securities management activities and activities of professional participants of the securities market. He has previously
worked in various positions that do not require specialised education. Around 2018, he placed an advert on an online
job site to look for a job. In the same 2018, he was invited to the Moscow City Business Centre and offered a job as a
general manager. There he was met by a woman who introduced herself as Evgenia Rossieva and explained that he
(D.G. Buryakovsky) was offered the position of general director in LLC "Qubief" INN 7703458823 with a salary of 10,000
rubles per month. In fact, he would not have to do anything in this organisation and would not have to make any
decisions. He (D.G. Buryakovsky) was only needed as a nominal person in this position until the organisation was
547
established, afer which he was to be replaced by another manager who would actually perform his duties. He was
interested in this proposal and agreed to become a director of the Limited Liability Company. In order to do so, he had
to sign a number of documents and provide his personal documents. In the business centre "Moscow City" he
provided Rossieva Evgeniya with his documents, including his passport, education diploma, SNILS, etc., afer which in
the same business centre he was escorted to a notary, where he (D.G. Buryakovsky) signed the founding documents
for LLC "Qubeef" INN 7703458823 and executed a notarial power of attorney in his own name to perform all actions in
respect of LLC "Qubeef". Afer executing all the documents, he lef the office located in the Moscow City business
centre and Rossieva said that she would contact him when necessary. It was not explained to him what specific type
of activity the Company would be engaged in. For approximately two years, namely from 2018 to February 2020, he
came to the Moscow City Business Centre once every two months, where in the lobby of one of the buildings of the
complex, Evgenia Rossieva paid him the previously agreed remuneration in the amount of 20,000 rubles at the rate of
10,000 rubles per month. In February 2020, he called Evgenia Rossieva and asked her to dismiss him (D.G.
Buryakovskiy) from the position of general director of LLC "Kyubief" at his own request because he had found another
job that was not compatible with this position. At the agreed time he and Evgenia Rossieva met in the lobby of the
Moscow City business centre, where he signed the necessary documents, afer which he and Evgenia Rossieva never
saw each other or called again. For the entire period of his participation in the position of general director of Qubief
LLC, he was paid approximately 180,000 - 200,000 roubles as remuneration. He received these funds from Yevgenia
Rossieva in cash;
(Vol. No. 272, pp. 155 - 158)
- Bogdanova K.V.'s testimony as a witness,

according to which in 2014 she moved to Moscow to look for a job and placed her ad on the website "hh.ru". She
received a call from representatives of LLC "Qubey Finance" and was offered the position of junior financial advisor in
this organisation, and invited to an interview in the office located on the 9th floor at the following address: Moscow,
Nab. Presnenskaya 8 bldg. 1. Afer the interview, she became an employee of LLC Qubey Finance as a junior financial
advisor with a salary of 24,000 roubles per month. Qubey Finance LLC is part of the QB Group of companies. The main
activity of the QB group of companies was attracting clients for the sale of investment products and trust
management of money invested by clients. Her duties as a financial advisor included: attracting clients to the
organisation by making cold calls to telephone numbers provided to her by her supervisors at work or she could
obtain a list of telephone numbers via corporate email to which all employees of the organisation had access. Her
direct supervisor was Munaev Zelimkhan Visaitovich, but she did not see him much at work and did not receive any
instructions from Munaev Z.V.. Most of her instructions came from other managers or through electronic messages.
She worked as a junior financial adviser until about 2015, afer which she decided to resign from this position. She
was offered the position of KPI Sales Administrator with different functional responsibilities, namely, recording the
implementation of work plans, taking minutes of the meeting. Also in 2020, she was added to her duties the function
of drawing up contracts on behalf of the management of QB Group, between the organisation and the client by
entering the client's details into a special program, which already had a prepared contract template. Afer entering the
information from the electronically submitted copies of documents into the programme, it sent the completed
contract and the request generated by the programme to the initiator via corporate e - mail. She had no contact with
direct clients of the QB Group, possible cash and non - cash clients. She had no partners or assistants at work and
performed all her functional duties independently. Her salary increased periodically and was approximately R80,000
by 2021. Since about August 2021, she has not been working at QB Finance LLC since her resignation, as a lot of
negative information began to appear in the media regarding the QB group of companies, and law enforcement
officers periodically searched the offices of the QB group of companies. LLC "MC "Moi Finansy" TIN 7725682730 is
familiar to her, approximately in September 2020 she was offered to become one of the founders of this organisation
under the pretext of financial incentives in the form of bonuses at her main place of work. She agreed to become one
of the founders of LLC MC Moi Finansy, as under the terms of the verbal agreement she was not required to participate
548
in the activities of LLC MC Moi Finansy and make any decisions. Afer preparing the necessary documents, she signed
them. She does not know which documents they were, as she did not read their content, and the person who
provided her (Bogdanova K.V.) with these documents said that these documents were the constituent documents of
LLC "MC "Moi Finansy". In the end, she never received the promised development and dividends from the activity. LLC
"MC "Moi Finansy". Currently, she is still a member of the founders of "MC "Moi Finansy" LLC. She is aware that the
following employees have worked in the QBF group of companies in the following positions: G.R. Erzikyan - financial
advisor; S.A. Matyukhin - head of another organisation; N.S. Padalko - initially head of sales; R.F. Amerov - possibly a
member of the sales department; V.O. Plitin - possibly a member of the sales department; Y.S. Zaitseva - a member of
the sales department; D.Y. Meshkova - a member of the sales department; V.S. Pakhomov - head of the QB branch in
St. Petersburg; M.S. Yudin - initially head of the sales department, but later on - a member of the sales department.
initially head of the sales department, but later changed jobs; R.V. Shpakov - chairman of the board of directors of QB
Corporation; P.Y. Vlasov - financial advisor; K.S. Sobolev - financial advisor; A.S. Golubev - possibly head of a QB
branch in St. Petersburg; Y.G. Smirnova - head of another QB branch; E.A. Rossieva - head of the legal department of
QB Corporation. head of legal department of QB; Vozhzhov A.F. - worked in marketing; Korzh A.V. - manager of sales
department, Orlov Y.N. - manager of IT department; Spinka R.V. - Sales department manager; M.S. Fedorov - sales
department manager; A.O. Talerov - sales department manager. She has heard about the employees with the data
Shaban Y.V. and Athanasiadou Linda at work, but she does not know what they have to do with Kubi Finance Ltd;
(Vol. No. 273, pp. 9 - 13)
I.V. Rybalka's Testimony given to her as a witness,

according to which she has a higher economic education, has knowledge of dealer activity, broker activity, securities
management activity and activity of professional participants of the securities market. On 03.12.2009 she was
accepted to the position of the General Director of LLC "MC "Granat" INN 7725682730, as she had three specialised
certificates by that time, which included: Professional activities (trust management, brokerage activities, dealer
activities), Mutual funds, Depository activities. The principal activity of LLC MC Granat was trading in securities,
mutual funds and other financial activities, for which LLC MC Granat obtained the relevant licence from the Central
Bank of the Russian Federation. LLC MC Granat till 01.11.2021 was located at the following address: Moscow, 4th
upper Mikhailovsky proezd 5 floor 2 pom.1 kompn.8. Currently it is located at the following address: Moscow, proezd
2nd Roshchinsky, 8 p.2. The founders of LLC MC Granat until 2020 were LLC MibInvest, soon afer which LLC MibFin
was added. In the future, MibInvest LLC was renamed Kratos LLC. The organisation was created by the founders
specifically for certain purposes related to mutual funds and the founders of LLC MC Granat determined the main
direction of the company's activities. In 2020, the participants of LLC MC Granat began to experience financial
difficulties, as a result of which they decided to sell their shares in the amount of 99% at auction for the amount of
RUB 24,000,000. IC QBF LLC acted at the auction as the official representative of 11 individuals, new participants of
the Company, who were the buyers of the shares sold at the auction. She did not see any powers of attorney for IK
QBF LLC from the 11 individuals, but the transaction itself implies their presence. The buyer's representative was
Stanislav Matyukhin, but he was not an official person for LLC MC Granat. Matyukhin did not provide any power of
attorney, but claimed that he was the representative of the ultimate beneficiary Roman Shpakov. Stanislav Matyukhin
first came to the office of LLC MC Granat in approximately July 2020. The new participants of LLC MC Granat afer the
sale of shares to date are: Kratos LLC in the amount of 1 %, Bogdanova Kristina Vladislavovna (9.9 %), Gramza
Ekaterina Valeryevna (9.9 %), Korzh Andrey Vasilievich (9.9 %), Maslennikov Vladimir Alexandrovich (9.9 %),
Matyukhina Olga Dmitrievna (3 %), Mikhalevich Evgeny Vladimirovich (9.9 %), Orlov Yuri Nikolaevich (6.9 %), Spinka
Ruslan Valerievich (9.9 %), Fedorov Maxim Sergeyevich (9.9 %), Talerov Artem Olegovich (9.9 %), Marketplace My
Finance LLC (9.9 %). The head of Marketplace My Finance LLC is Ruslan Amerov, who was previously a participant of
this company, a natural person. She does not know who these persons are, she is not familiar with them. Kratos LLC
had 1 per cent of shares and about a year and a half ago Kratos LLC started bankruptcy proceedings. She has only
549
seen Rinat Amerov and Evgeny Mikhalevich among the founders. Afer purchasing the shares and introducing Amerov
into the founders, she saw him (Amerov) for the first time in November 2020 at a video conference with the Central
Bank, and afer that Amerov sometimes called her about working in the organisation. In the spring of 2021, Amerov
informed her that he (Amerov) did not like the activities of IK QBF LLC and could not influence the decision of other
members of MC Granat LLC including. In the early days of September 2021, she was sent a copy of Mikhalevich's
passport to apply to the CBR for a change of CEO. She thus learnt that her likely successor in the position could be
Mikhalevich, as her position as CEO of the management company involved prior approval from the CBR. The CBR
eventually agreed on Mikhalevich's candidature. Afer that, about a month later, she saw Mikhalevich for the first time
at her office; Matyukhin had brought him there. On the evening of the same day, Mikhalevich stated that he could not
be the general director and she did not see Mikhalevich again. Since 2020, meetings have been held in the Company,
but in the form of absentee voting, there have been no in - person meetings of participants. She does not know what
the participants of the Company look like. All the sheets of absentee meetings and voting were handed over by
Stanislav Matyukhin through a courier. Further, in September 2020, Stanislav Matyukhin required her (I.V. Rybalka) to
come to his office in the business centre Moscow City with the plans of the organisation's work and further prospects,
mainly she visited Matyukhin's office in BC Moscow City on Fridays. Also, around August 2020, at the request of
Stanislav Matyukhin, she transferred funds in the amount of approximately RUB 1,240,000 from the current account of
LLC MC Granat to the Company, the name of which she does not remember, for legal services that were not actually
provided to the organisation. All details of the organisation and documents signed by the second party were provided
by Matyukhin Stanislav, in fact, she did not see the head of the second party under this contract. 23.04.2021 LLC MC
Granat was renamed LLC MC Moi Finansy by the decision of the participants. Currently, Rinat Amerov is the Chairman
of the Board of Directors of MC Moi Finansy. Around 20.09.2021, on the verbal recommendation and request of
Matyukhin Stanislav to be hired as a customer service specialist, Shalimov Evgeny came to her and was hired by her.
On 08.07.2021 the Central Bank forcibly cancelled the licence of LLC IC QBF to carry out professional activities with
securities, afer which Matyukhin Stanislav instructed her to accept all clients of LLC IC QBF into LLC MC Moi Finansy
by renegotiating contracts. She refused to accept these offers, as she had to bear the responsibility to the client, and
the conditions were not favourable for LLC MC Moi Finansy. Matyukhin explained to her that LLC MC "Granat" was
purchased for this very purpose, afer which Matyukhin put pressure on her throughout July 2021 in terms of
instructions to change the activities of the organisation, with which she did not agree. Moreover, when Matyukhin
Stanislav gave any instructions to me, the latter referred to the fact that he was fulfilling the will of the ultimate
beneficiary and was his unofficial representative, namely Roman Shpakov. Matyukhin wanted MC My Finance LLC to
take all clients in one pool, but this is not the way to do it. At the end of November 2021, she was contacted by
Stanislav Matyukhin and demanded that she sell all assets held by the organisation for a total of approximately RUB
18,500,000, but she refused to comply with this instruction on the grounds that this transaction would put the
Company into pre - bankruptcy. Around July 2021, she decided to resign from my position as CEO of MC Moi Finansy
LLC as she was not comfortable working with Matyukhin Stanislav and fulfilling his demands. In addition, since the
sale of shares in the Company, namely since 2020, the activities of the organisation MC Granat LLC (MC Moi Finansy
LLC) did not bring the previous profit, and even worked at a loss. Matyukhin ignored all her proposals to improve the
quality of the organisation's work in every possible way, and since she had no communication with the members of
the Company, all issues were discussed directly with Matyukhin. In the end, the activity of LLC "MC Moi Finansy"
under the supervision of Matyukhin Stanislav led to the fact that the Central Bank of the Russian Federation
withdraws from 17.12.2021 licence to carry out professional activities. Rossieva Evgenia Anatolievna is familiar to her,
as she (Rossieva E.A.) contacted her (Rybalka I.V.) when discussing issues related to the legal side of transactions.
Rossieva, as the head of the legal department of QBF Group, was introduced to her by Matyukhin. Smirnova Yaroslava
Gennadyevna is familiar to her, as she (Rybalka I.A.) contacted Smirnova Y.G. at the request of Matyukhin, she
(Smirnova Y.G.) was the head of LLC "MC QBF". She does not know Roman Shpakov personally, but she has read
various articles about him in the public domain and heard about him from Stanislav Matyukhin that R.V. Shpakov is
the ultimate beneficiary of the QUBIEF group of companies. Matyukhin Stanislav himself has repeatedly informed her
(Rybalka I.V.) that he (Matyukhin) represents the interests of Roman Shpakov because Roman Shpakov is on
international wanted list and cannot negotiate with representatives of organisations controlled by him (Shpakov R.V.)
in the QBF group of companies. At present, LLC MC Moi Finance has its own funds totalling approximately 18,000,000
550
roubles, which consist of the approximate market value of securities in the form of shares and bonds of various
companies, including Rosnef, Tatnef and others, the names of which she no longer remembers. In addition, OOO MC
Moi Finansy has in trust management a fund belonging to OOO MIB Investments for the total amount of 55,000,000
rubles, which do not belong to the company's own funds, but are only contractual work for the specified amount.
Currently, the said fund is being transferred to another management company for management. There are no clients,
namely individuals and legal entities in LLC "MC "Moi Finansy" since December 2021 due to the fact that the Central
Bank of the Russian Federation has revoked the licence to carry out professional activities. Thus, the main source of
income of LLC MC Moi Finance is the management of one fund, which is planned to be transferred to another
management company, as well as dividends from shares and bonds. Earlier, namely before the moment when LLC MC
Granat became a controlled organisation of QBF group of companies, the Management Company Granat owned a
sufficient number of securities necessary for the Company to have a stable income, however, on the instructions of
Stanislav Matyukhin, LLC MC Granat chose as a broker LLC QBroker, which possibly under the leadership of Roman
Shpakov decided to sell liquid and constantly profitable securities. Afer that, the income of LLC MC Granat fell
sharply. As soon as QBF LLC sold liquid and constantly profitable securities belonging to Granat MC Ltd, she decided
that their (the company's) broker would be Sberbank PJSC, as she did not trust QBF LLC. Around 15.02.2022 she
received a message from Stanislav Matyukhin on her personal mobile phone in the messenger application
"WhatsApp" with a repeated demand to sell all assets of the organisation, namely securities in the form of own funds
of LLC "MC "Moi Finansy". In his message, Stanislav Matyukhin referred to the fact that he regularly communicates
with Roman Shpakov and keeps in touch with him, and this decision was made by Roman Shpakov, which should be
executed immediately. Matyukhin Stanislav sent her an e - mail address ([email protected]) through which she could
contact Shpakov Roman on her own, but Matyukhin Stanislav did not provide her with Shpakov Roman's telephone
number or the address of his (Shpakov R.) whereabouts. She refused to keep in touch with Roman Shpakov, who
legally had nothing to do with My Finance Management Company Ltd. Subsequently, she proposed to Matyukhin
Stanislav to ensure a meeting of participants of the company LLC "MC "Moi Finansy" to make a decision on her
(Rybalka I.V.) dismissal and election of a new general director of LLC "MC "Moi Finansy". In addition, she informed that
all employees of LLC "MC "Moi Finansy" will be dismissed with her, to which Matyukhin Stanislav asked that she
persuade the employees to stay in the staff of the organisation until all the issues that want to implement Shpakov
Roman and Matyukhin Stanislav are settled;
(Vol. No. 273, pp. 16 - 20, 21 - 26)
O.D. Matyukhina's testimony

, given to her as a witness, according to which in the middle of 2020 she had a free conversation with her son Stanislav
Matyukhin, where they discussed the issue of obtaining additional income. In the course of the conversation, her son
Stanislav Matyukhin informed her that there was an opportunity to acquire a participation interest in LLC "MC Granat"
in order to receive dividends from the activities of this organisation, that this organisation was promising and actively
developing. She agreed to become a participant of LLC "MC Granat" in the amount of 3% of shares of the authorised
capital. Later, LLC MC Granat was renamed LLC MC Moi Finansy. She was assisted by her son Stanislav Matyukhin
Matyukhin in all matters relating to joining LLC "MC Moi Finansy". The amount of her contribution to the authorised
capital of the company was approximately 1,300,000 roubles. As she did not have this amount of money at her own
disposal, she asked her son Stanislav Matyukhin to help her obtain a loan for this purpose. Stanislav Matyukhin
informed her (O.D. Matyukhina) that it was possible to obtain a loan from Q Broker LLC. She received a loan from Q
Broker LLC, with the assistance of her son Stanislav Matyukhin Matyukhin. She received the money as an interest - free
loan from Q Broker LLC for a period of approximately 5 years. She believes that her son Matyukhin Stanislav has
nothing to do with Q Broker Ltd. Since receiving the loan, she has not made any payments as repayment of the debt,
and Q Broker LLC has not sent her any demands or notices about repayment of the loan taken earlier. The loan was
transferred between the companies in non - cash form. Earlier her son (S. Matyukhin) worked in the Federal Financial
551
Market Service, later in OOO IK QBF in a managerial position. Since her employment with MC Granat LLC (later MC Moi
Finansy LLC), she has never been at the address of the Company. The General Director of LLC "MC Moi Finansy" is Irina
Vasilievna Rybalka, but she has never seen her (I.V. Rybalko) personally. She has never received any money as
dividends from MC Moi Finance LLC;
(Vol. No. 273, pp. 35 - 38)
- A.O. Tallerov's Testimony

given by him as a witness, according to which in 2017 he posted his CV in open sources on job search websites. He
received a call with an offer to have an interview at QBF Investment Company. The interview took place in an office
room on the 9th floor at the following address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1. 1. Afer passing all
stages of the interview process, in 2018 he entered into an employment contract with QBF Investment LLC
(subsequently renamed F - Experts LLC) for the position of Senior Financial Advisor. His direct supervisor at QBF
Investment LLC was Andrey Korzh. His (A.O. Tallerov) duties included advising clients on the product line of the
Russian company QBIF Investment Company LLC, telling them about the products, how they work, assisting them in
formalising their interaction with QBIF Investment Company LLC if the client was interested in the services and
products. He offered clients those products of the company for which QBIF Ltd. had licences - brokerage services and
trust management. Brokerage service is opening a personal account for a client and trading either independently or
by a broker, buying shares and bonds on MICEX and RTS stock exchanges for a portfolio on a personal account. Trust
management is ready - made strategies on the Russian market. He took information for working with clients directly
at his workplace. They (information) were presented both in printed form (brochures) and electronically. There were
also periodic training sessions with various employees. In 2020, he actually remained employed in the same position
but at the suggestion of the management of the organisation, he was asked to take charge of one of the customer
service departments. He became head of the department and had one financial advisor, Ekaterina Dorokhina,
reporting to him, and he continued to work under Andrei Korzh, acting deputy director of the customer service
department. The majority of matters were discussed mainly with Andrey Korzh. Clients who had concluded an
agreement with QBIF LLC could address him (A.O. Tallerov) in case of any questions, and he, in his turn, in case he was
unable to answer them or provide them with information of interest, would address his colleagues in related
departments. During the period of 2020 - 2021 the department under his (A.O. Tallerov) leadership expanded to 6 - 9
people. He did not have any other duties, he did not solve any additional issues. As a rule, clients already oriented to
the Russian market came to him, i.e. the clients imagined what product they wanted to invest money in. The client
provides documents: passport, SNILS, TIN, on the basis of which he (A.O. Tallerov) filled out applications according to
the template and sent them by e - mail to the back office for drawing up contracts for clients. The contracts already
signed by QBIF Ltd. are brought to the meeting room for signing with the clients. Since 2021 the signing of contracts
by means of electronic digital signature has been started. The following types of agreements were signed: an
agreement of adherence to the brokerage service regulations; an agreement of adherence to the trust management
regulations. Upon conclusion of the agreement, the client transfers funds, in case of a brokerage service agreement,
to his personal brokerage account opened with IC QBF LLC, whereby the account of IC QBF LLC, as a licensed
company, is opened with NSD. In the case of trust management agreements, the transfer was made to the settlement
account of IC QBF LLC, but the payment designation specifies the number of its agreement. Further, the clients' funds
are transferred from the settlement account of IC QBF LLC to the exchange account of the stock exchange, and then
the trader buys securities according to the strategy. In May 2021, before the searches in the company's office, he
received an offer to formalise the share of the LLC MC Moi Finansy Management Company, which had lef the
company. This request was made to him by someone from the management, whom he does not remember. He gave
his consent, as at that time there was nothing suspicious in the context, the company was developing. For the re -
registration of shares he himself went to the notary, where 2 other persons were present: one employee - a girl, from
the legal department of QBF, and the second person - a person unknown to him, who ceased to be a participant of the
552
LLC "MC My Finance", the previous owner, whom he had seen in the office of QBF at least once before. He (A.O.
Tallerov) did not receive any remuneration, dividends or payments for the transfer of his (A.O. Tallerov's) share in the
above - mentioned company, nor was he promised any. Until the moment when he agreed to sign the documents
about LLC "MC "My Finance" he did not know. Later he found out from the Internet in open sources that this company
has licences for trust management and fund management. One of these licences was revoked in November -
December 2021. Apart from the documents signed by the notary, he did not sign any documents related to LLC MC
"Moi Finansy" and does not know any other persons - founders, director, representatives of the company. Since the
spring of 2020, he has opened a brokerage account with QBIF Ltd. on which he has performed transactions, including
on the IRO structured product. In the spring of 2021, he received an offer from one of his work colleagues to receive
remuneration for finding a buyer for the sale of investment units of the real estate ZPIF "RIF Mixed Federal 2 Qual".
These units were to be credited to his brokerage account for their subsequent sale. He studied the main contract of
sale between the buyer (im Tallerov A.O.) and the seller LLC "QBroker". According to the agreement there was a period
of 1 or 2 months from the moment of signing the agreement, afer the expiration of which, if the units are not sold by
that time, they (units) are returned to the account of "Q.Broker" Ltd. He agreed to the transaction and believes that
this transaction was offered to him because he had an open brokerage account in LLC "IC QBF" and was a qualified
investor. According to the terms of the agreement, he was entitled to an agency fee in case of sale of units. The
number of units was just over 336,000. According to the agreement, the units were sold to him at a price of
approximately 660 or 690 roubles per unit, totalling approximately 221,000,000 roubles. He (A.O. Tallerov) was
supposed to sell the units for an amount higher than the purchase price, but the matter did not come to a discussion
of the sale price. At that time, afer the conclusion of the contract, he had to prepare an offer. Afer signing the
contract, some time later, the units of the real estate ZPIF "Reef Mixed Federal 2 qual" were credited to his brokerage
account opened with IC QBF LLC. In July 2021, he transferred the units on his own initiative to his brokerage account,
which was opened with JSC Otkritie Broker. He had potential buyers for these units, whose accounts were also
opened in JSC Otkritie Broker, for this reason he made this transfer, so that later it would be faster and easier to sell
them (the units). From the extract of the Unified State Register of Legal Entities presented to him in respect of LLC MC
"My Finance", where the participants of the company are indicated, he knows the following employees: Bogdanova
Christina - one of the employees in the office of "QBF", he knows her only visually; Gramza Ekaterina - he saw her in
the office of "QBF"; Korzh Andrey - his (Tallerov A. O.) manager; Maslenova - one of the employees in the office of
"QBF"; Maslenova - one of the employees in the office of "QBF", he knows her only visually.O.) supervisor; V.A.
Maslennikov - visually acquainted, saw him in QBF office; Y.N. Orlov - employee of financial group, related to QBF; R.V.
Spinka - his (A. Tallerova's) supervisor; M. Fedorov. - Korzh A's manager; M.S. Fedorov, an employee of QBF, worked
with clients. He (O.A. Tallerov) learnt about the fact that these persons are participants of LLC MC Moi Finance
Management Company from the extract of the Unified State Register of Legal Entities. I.V. Rybalka, the director of LLC
MC Moi Finansy, as well as Krotos LLC and JSC Marketplace Moi Finansy are not familiar to him. The managers of QBF
group of companies were: Roman Valeryevich Shpakov - managing partner; Zelimkhan Munayev - managing
employee of the company; Vladimir Pakhomov - managing partner, working in the office of LLC Investment Company
QBF in St. Petersburg. Stanislav Matyukhin was the General Director of QBIF LLC; E.A. Rossieva - worked at QBIF as a
lawyer; Linda Athanasiadou - he saw her once in the lobby on the 9th floor of the office and the second time at a QBIF
corporate event/presentation; A.S. Golubev - an employee of the QBIF branch in St. Petersburg;
(Vol. No. 273, pp. 42 - 49)
- Fedorov M.S.'s Testimony

given by him as a witness, according to which on 01 June 2016 he got a job as an intern at QBEF Group of Companies,
which was engaged in brokerage and dealer activities. Afer a three - stage interview, he started his internship. He was
recommended to the group of companies by someone he knew who was already working there. He was interviewed
by a girl named Svetlana, as well as his mentors Ruslan Spinka and Nikolai Padalko. The internship lasted for six
553
months, during which time he did not receive a salary and was not officially employed by the company. In January
2017, he was enrolled as a junior financial adviser at K - Investment LLC, which was located at 8, Presnenskaya
Naberezhnaya, 8 p. 1, 9th floor, Moscow. 1, 9th floor. Around the end of 2018, he was appointed to the position of
Financial Advisor at the same company, and at the end of 2019 to the position of Senior Financial Advisor. He resigned
from K - Investment LLC at the beginning of June 2021 at his own request. Prior to 2020, his duties as a financial
advisor, both junior and senior, included calling potential clients from a cold database of phone numbers who were
offered the company's products. He also worked with clients who contacted the company on their own initiative. If
the client was interested in the company's products, he (the client) was invited to a meeting in the office, where the
client personally chose the product offered to him, choosing Russian or foreign markets. He (M.S. Fedorov) personally
worked mainly with the Russian market. Afer the client's package of documents was formed, they were sent by
internal e - mail. For the international market the client had to provide a more extended package of documents.
Basically, the company secretary would then receive a contract with the client, which had already been signed by an
officer on behalf of the company and which had to be signed by the client. In the Russian jurisdiction the contracts
were signed on behalf of QBIF LLC and in the foreign jurisdiction on behalf of other companies, the names of which he
does not remember. The contracts were few and were concluded at the beginning of his career at MC - Moi Finance
LLC. Either a trust management agreement (TMA) or a brokerage service agreement (BS) was concluded with the
client. Thereafer, the client was only provided with advisory services on issues arising for the client. Around the end
of 2020. - Early 2021, one of the managers of one of the companies, who exactly does not remember, offered him (M.S.
Fedorov) to participate in the project - to become a co - founder of LLC "MC - Moi Finance". According to the words of
the head, this proposal was made to him (M.S. Fedorov) as a reward for a long period of work in the company. The
share of the authorised capital, which he owned was about 4%. Co - founders of LLC "MC - Moi Finance" were also
Bogdanova Kristina, Ruslan Spinka, Artem Tallerov, Vladimir Maslennikov, Andrey Korzh and other employees who
had approximately equal shares in the authorised capital of LLC "MC - Moi Finance". Bogdanova Kristina, Ruslan
Spinka, Artem Tallerov, Vladimir Maslennikov, Andrey Korzh were ordinary employees of the company. Apart from the
fact that he (M.S. Fedorov) was formally a founder of LLC "MC - Moi - Finance" had nothing to do with the activities of
this company, including not contributing money to the authorised capital, not participating in the meeting of the
founders of the company and so on. He was a nominal founder of LLC "MC - Moi Finance", he did not receive dividends
from the company's activities. He does not know whether there were any clients in the company and whether
financial and economic activities were conducted in LLC "MC - Moi Finance";
(Vol. No. 273, pp. 56 - 59)
The testimony of Smirnov S.B., given by him as a witness,

according to which in 2006, afer passing an examination in the Federal Financial Markets Service, by order of the
Federal Financial Markets Service No. 06 - 121/pz - i he was awarded the qualification "Financial Market Specialist" in
the field of financial market specialisation: investment funds, unit investment funds and non - state pension funds
management activities (certificate KA No. 005567). In addition, by Order No. 06 - 425/pz - i of the Federal Financial
Markets Service, he was awarded the qualification "Financial Market Specialist" in the field of financial market
specialisation: brokerage, dealer activities and securities management activities (KA certificate No. 006284). By the
decision of the Attestation Commission No. 365 dated 12.03.2008 he was awarded the qualification of a financial
market specialist in keeping the register of securities owners (certificate ASH - 001 No. 004104), by the decision of the
Attestation Commission No. 001 dated 17.10.2006 he was awarded the qualification of a financial market specialist in
depositary activity (certificate A1U - 001 No. 004617). For a long time he could not find a job. At that moment, in order
to look for a job, he started frequenting the Internet forum "Russian Trading System" (forum.rts.ru). On this site there
were frequent adverts seeking persons who could nominally take up positions of director, specialist, controller in
554
various investment companies. This employment was mostly of a formal nature and was required for the subsequent
resale of the investment company in question. In order to sell a ready - made investment company, it (the company)
had to meet the legal requirements. Therefore, even for formal employment in the Investment Company, a valid
certificate of the Federal Financial Markets Service was required. Since he had these certificates, he started
responding to these advertisements and periodically started travelling to Moscow to apply for the required positions.
His employment was always of a formal nature. For this purpose, he mainly cooperated with the Vermont Group of
Companies, whose office was located at 9 Protopopovsky Lane, Moscow. This group of companies has always had
many such orders. He mainly interacted on these matters with Irina Velichko, an employee of the Vermont Group of
Companies, and someone from the management or the owner of the Vermont Group of Companies named Lyubov.
He was mostly employed as a specialist or controller. He was paid about three to five thousand per job. The money
was usually paid in cash, unofficially. He was engaged in this integrity until 2014, then by order of the Federal Service
for Financial Markets these certificates were cancelled. He cannot explain anything about LLC "Investment Company
QBIF" TIN 7733673955, he knows nothing about this company. In 2009 - 2010 he could be the General Director of LLC
"Investment Company QBIF" INN 7733673955 only nominally, in fact he did not participate in the activities of this
company, he did not sign any documents on this company. He did not sign any powers of attorney on behalf of LLC
Investment Company QBF. He was not officially employed by LLC "QBIF Investment Company". Most likely, this
company was registered to him in the course of his cooperation with the Vermont group of companies. He has never
been at the legal address of QBIF Investment Company LLC. He went to the tax authorities, including MI FTS of Russia
No. 46 for Moscow, to the notary in the course of his activity on nominee arrangement with investment companies on
several occasions. He admits that he has been to the tax authorities regarding the registration of LLC Investment
Company QBF. He himself did not go to banks to open current accounts for the company. He does not know where the
documents on financial and economic activities of LLC "Investment Company QBF" were kept. In fact, he did not hold
any positions in QBIF Investment Company LLC;
(Vol. No. 273, pp. 72 - 77)
- Testimony of T.O. Shabunina, given to her as a witness,

according to which she was married to Pavel Vyacheslavovich Shabunin since 1991, who died on 19.05.2012.
Previously, her husband worked in various positions that did not require special education. From about 2008 - 2009 he
worked in an investment company, the name and address of which she does not know. Her husband did not work in
this company as a manager, but as an ordinary executive. She does not know what functions her husband performed
at his work, as she never discussed his work with him. He (her husband) did not receive a high salary in this
organisation and his income level was not high;
(Vol. No. 273, pp. 82 - 84)
- D. V. Golovanova's Testimony
given to her as a witness, according to which she has a higher technical education, has no knowledge of dealer
activities, brokerage activities, securities management activities and activities of professional participants of the
securities market. Around 2014, her son Dmitry Golovanov decided to establish LLC "Format Development" INN
555
7708243109 for the purpose of further acquisition of a land plot and construction of a real estate object on it for
renting out. When establishing Format Development LLC, it was decided to proceed as follows: Dmitry Aleksandrovich
Golovanov is the general director; she is the founder; Tatiana Nikolayevna Cherezova is the founder; LLC "M1 Invest",
where Dmitry Lepeshkin is the general director, is also the founder. She is not personally acquainted with Lepeshkin.
LLC "Format Development" was registered on 24.12.2014 at the address: 46, 5th Parkovaya Street, Moscow, but the
Company did not carry out its activities at this address, in fact this Company did not have an office. The whole activity
should have consisted in acquiring a land plot, erecting a non - residential building there and subsequently leasing
out premises in this building. This Company was not established for any other purpose. An agreement was reached
between her son and a representative of M1 Invest LLC on financing in equal proportion between the parties. In 2016,
her son Dmitry Golovanov found a land plot suitable for the needs of Format Development LLC located at the
following address: Moscow Region, Odintsovsky District, Chastsovskoye settlement, Chastsy village. In the same year,
Format Development LLC purchased the land plot for approximately RUB 20,000,000. The payment was to be made by
two parties, 50 per cent from Format Development LLC and 50 per cent from M1 Invest LLC. She (D.V. Golovanova)
deposited her part of the money as a loan to "Format Development" LLC, giving it to her son, as the director of
"Format Development" LLC, in cash, afer which Dmitry Golovanov deposited the funds into the organisation's
account. She received the funds from her husband A.N. Golovanov. Afer purchasing the land plot, her son and his
partners started preparing engineering works, the costs of which were also shared equally between the parties
involved. Approximately in March - April 2020 there was a reorganisation of LLC "Format Development", afer which
the shares in LLC "Format Development" were distributed as follows: she (D.V. Golovanova) - 85%, Tatyana Cherezova
- 15%, LLC "M1 Invest" withdrew from the founders. Roman Shpakov acted as a representative of M1 Invest LLC. In
approximately March 2021, another reorganisation of LLC Format Development took place, afer which the shares in
LLC Format Development were distributed as follows: she - 85%, Dmitry Lepeshkin - 10%, Tatyana Cherezova - 5%. In
approximately February - March 2021, her son (D. Golovanov) and her husband A.S. Golovanov decided to increase the
authorised capital of Format Development LLC to RUB 8,100,000, which previously amounted to RUB 20,000. The
authorised capital was increased by transferring the lease right to a land plot previously owned by her (D.V.
Golovanova) for a long time, located in the Balashikha District of the Moscow Region. In the future, approximately
since September - March, the said land plot in Balashikha district is again in her use. Afer the transfer of lease rights
from her (D.V. Golovanova) to the Company, the administration of Balashikha district expressed claims that the owner
of the land plot was a Moscow organisation and not the former individual and it was decided to return the said land
plot back to her (D.V. Golovanova). The authorised capital of Format Development LLC has not changed and amounts
to RUB 8,100,000;
(Vol. No. 273, pp. 86 - 89)
- D. A. Golovanov's Testimony
given as a witness, according to which approximately in 2013 he started receiving calls on his personal phone from
representatives of the QBF group of companies with an offer to become their client, to invest money in securities and
shares. He refused, but afer consulting with his father, he decided to come to the office of the QBF group of
companies, which was located on the 9th floor of the Capital City building in the Moscow City business centre at
Presnenskaya Embankment in Moscow, in order to discuss the securities issue. In the course of the conversation,
QCBF representatives suggested that he (D.A. Golovanov) meet with one of QCBF Group's executives for the purpose
of possible further cooperation in the field of commercial property. The meeting was with Dmitry Sergeevich
Lepeshkin, with whom he (D.A. Golovanov) further co - operated. Eventually it was decided to establish LLC "Format
Development" TIN 7708243109 for joint acquisition of a land plot and construction of a real estate object on it, leasing
it out later. An agreement was reached between him (D.A. Golovanovanov) and Lepeshkin on financing in equal
proportion between the parties. At the same time, according to Lepeshkin from their side the financing will be
provided from personal funds of the main shareholder of the group of companies QBF. In addition, an agreement was
556
reached on the division of functions, under which Lepeshkin's party was to undertake the development of initial
permitting documentation, selection of land plots, accounting and legal functions, and, if necessary, the attraction of
bank loan financing. For his part, he (D.A. Golovanov) was to select a suitable plot of land from those found by
Lepeshkin, develop a commercial concept for the facilities, form a task for design, and select tenants. When
establishing LLC "Format Development" they decided to do the following: he (D.A. Golovanov) is the general director;
his mother Golovanova Dolores Vasilievna - the founder - 35 % of shares; Tatyana Cherezova - the founder - 15 % of
shares; LLC "M1 Invest", where Lepeshkin is the general director - 50 %. An accountant, lawyer and other specialists
should be provided by Lepeshkin. He (D.A. Golovanov) has seen these employees in the office of the Kyubi group of
companies, and they (the employees) have never worked in the staff of Format Development LLC. LLC "Format
Development" was registered on 24.12.2014 at the address: 46, 5th Parkovaya Street, Moscow, but the Company did
not carry out its activities at the specified address and there was actually no office. All activities should have consisted
in acquiring a land plot, erecting a non - residential building there and leasing out premises in this building. The
Company was created for other purposes. All negotiations on the Company's activities took place in various offices,
including the office of the QBF group of companies in BC "Moscow City". The settlement accounts of Format
Development LLC were opened in Sberbank JSC and Alfa Bank JSC, but the account opened in Sberbank JSC was
never used. Afer establishing Format Development LLC, he and Lepeshkin started searching for a suitable land plot.
While searching for a land plot, Lepeshkin explained to him (D.A. Golovanov) that the main shareholder of the QBF
group of companies would like to consult with him (D.A. Golovanov) on the possibility and liquidity of an unfinished
property in Serpukhov, Moscow Region, on Privokzalnaya Square. He (D.A. Golovanovanov) agreed to help Lepeshkin,
afer which they agreed to meet in the vicinity of the property in Serpukhov. Lepeshkin was not present at the
meeting, but two men unknown to him (D.A. Golovanov) arrived, who turned out to be Vladimir Pakhomov and
Roman Shpakov, he had seen their photos posted in the public domain on the Internet. Together with Pakhomov and
Shpakov they inspected the presented property, afer which they discussed the liquidity of purchasing the said
property. Afer this meeting he saw Shpakov and Pakhomov several more times in the office of QBF group of
companies in BC "Moscow City", but he did not have any personal meetings with Pakhomov. I saw Shpakov about 5 - 6
times in the office of QBF Group, but I had all interactions on current issues with Lepeshkin. In 2016, a land plot with
cadastral number 50:20:0060532:3724, located at the address: Moscow region, Odintsovsky district, Chastsovskoye
settlement, Chastsy village, was found suitable for the needs of Format Development LLC, which Format
Development LLC purchased for approximately RUB 22,000,000 in 2016. Payment was to be made from two parties, 50
per cent from him and his (Golovanov D.A.) family and 50 per cent from M1 Invest LLC represented by Lepeshkin. On
his part he (D.A. Golovanov) deposited the money in cash into a bank account for further transfer to the seller as a
loan, as they purchased the plot on similar terms. There was a delay in the transfer on Lepeshkin's part, but soon the
money was transferred to the seller by M1 Invest LLC, also as a loan. His mother Golovanova D.V. contributed her part
of the money to "Format Development" LLC as a loan, giving it to him (Golovanov D.A.) as the director of "Format
Development" LLC in cash, afer which he (Golovanov D.A.) deposited these funds into the account opened in "Alfa
Bank" JSC. Afer the acquisition of the land plot, they started preparing engineering works, the costs of which were
also shared equally between the parties, him and Lepeshkin. In addition to the expenses for the needs of the
Company, Roman Shpakov repeatedly approached him (D.A. Golovanov) to borrow money. As a result, he (D.A.
Golovanov), as an individual, lent Roman Shpakov money totalling approximately 14,000,000 roubles, for which
Shpakov prepared receipts. In the course of the activities of LLC "Format Development" related to the land plot in
Odintsovsky district, Shpakov, according to Lepeshkin, repeatedly delayed the deadlines for his obligations and thus
created certain difficulties in further development, afer which he (D.A. Golovanov) proposed to Shpakov and
Lepeshkin to withdraw from the business of LLC "Format Development". Shpakov agreed on the condition that he
(R.V. Shpakov), as an individual, be given another loan. The loan of funds decided to issue promissory notes on behalf
of Roman Shpakov in his (D.A. Golovanov) name in the amount of 8 pieces for the total amount of 200,000 US dollars.
The last promissory note was finally repaid in January 2021. In the course of the transaction of sale and purchase of
shares of LLC "Format Development", the sale of shares was executed by LLC "M1 Invest" with the assignment of
claims on previous loans, which were taken from him (D.A. Golovanov) Shpakov and the assignment of the loan,
which was granted to the Company "Format Development" by LLC "M1 Invest". The above transaction for the sale and
purchase of shares in LLC Format Development took place in approximately March - April 2020. Afer the sale and
557
purchase transaction, the shares in LLC "Format Development" were distributed as follows: Dolores Golovanova - 85
%, Tatyana Cherezova - 15 %, and M1 Invest LLC withdrew from the founders. In approximately February - March 2021,
he was again contacted by Dmitry Sergeevich Lepeshkin and offered his services in helping to complete the
improvement of the land plot in the Odintsovsky district and carrying out further construction. Lepeshkin explained
to him (D.A. Golovanov) that he was no longer working with Shpakov, but that he continued to work in the real estate
business. He agreed to Lepeshkin's help on the condition that he (Lepeshkin D.) would not receive payment for his
services, but would become a participant of LLC "Format Development" in the amount of 10 per cent of shares. Thus
from 19.03.2021 the shares in "Format Development" LLC were distributed as follows: Dolores Golovanova - 85 %,
Dmitry Lepeshkin - 10 %, Tatyana Cherezova - 5 %. Around the same time, in February - March 2021, he (D.A.
Golovanov) and his father decided to increase the authorised capital of "Format Development" LLC, which previously
amounted to 20,000 roubles to 8,100,000 roubles. The authorised capital was increased by transferring the lease right
to a land plot located in the Balashikha District of the Moscow Region, which had previously belonged to his mother
Dolores Golovanovanovova for a long time. Later, around September - March, the land plot in question was again used
by Dolores Golovanova, because the administration of the Balashikha district raised complaints about the change of
tenant. Afer the lease rights were returned to Golovanova from Format Development LLC, the authorised capital of
the Company did not change and amounted to RUB 8,100,000. Work on preparing a land plot for construction in the
Odintsovsky district was carried out with the participation of Dmitry Lepeshkin. He (D.A. Golovanov) has nothing to do
with the activities of QBG. Munaev Zelimkhan is familiar to him, he met him (Munaev Z.V.) in the office of the QBF
group of companies. In addition, during the time when he (D.A. Golovanov) and Lepeshkin went to lunch together, a
girl named Linda was periodically with Lepeshkin D.. He (D.A. Golovanov) also met Evgenia Rossieva at the office of
the QubeyEf group of companies, as Evgenia Rossieva was accompanying the sale of a share in M1 Invest LLC;
(Vol. No. 273, pp. 94 - 99)
- T.N. Cherezova's Testimony

given to her as a witness, according to which, around 2013, her husband proposed to her to become a founder of LLC
"Format Development" INN 7708243109, which was founded by his (her husband's) friend Dmitry Alexandrovich
Golovanov. Her husband was approached by Golovanov for help as a specialist in the field of construction. Her
husband in turn offered her (T.N. Cherezova) candidacy as a founder of Golovanov's company, as they did not take
money from Golovanov for their services, but could count on profit in the form of dividends to the organisation. She
agreed to become a co - founder of Format Development LLC with a 15% share. In addition to her, the co - founders
included Dolores Vasilyevna Golovanova, the mother of Dmitry Golovanov, with a 35 per cent stake, and M1 Invest LLC
with a 50 per cent stake. LLC "Format Development" was registered on 24.12.2014 at the address: 46, 5th Parkovaya
Street, Moscow, but in fact this Company did not have an office. The whole activity should have consisted in acquiring
a land plot, erecting a non - residential building there and subsequently leasing out premises in this building. This
Company was not established for any other purposes. To carry out the activities of Format Development LLC, the
management of the Company in 2016 purchased a land plot located at the address: Moscow region, Mozhaiskoye
Highway, Odintsovsky district, Chastsovskoye settlement, Chastsy village. The cadastral value of the land plot was
approximately 7,000,000 roubles. Afer the purchase of the land plot, preparatory work for construction began on it,
which continued until approximately August - September 2021, as from that time the land plot was seized.
Approximately in March - April 2020, the composition of the management board of Format Development LLC changed,
namely Dolores Golovanova - 85%, Tatyana Cherezova - 15%, and M1 Invest LLC withdrew from the founders.
Approximately in February - March 2021, the composition of the Management Board of Format Development LLC
changed again and was distributed as follows: Dolores Golovanova - 85 %, Dmitry Lepeshkin - 10 %, Tatyana
Cherezova - 5 %. By that time, the authorised capital of the company was already 8,100,000 roubles, whereas
previously it had been 20,000 roubles. The authorised capital was increased by transferring the lease right to a land
plot previously owned for a long time by Dolores Golovanova, located in the Balashikha district of the Moscow region.
558
Subsequently, in approximately September - March 2021, the said land plot located in Balashikha district was again
used by Golovanova Dolores. Afer the transfer of the lease rights to Golovanova from LLC Format Development, the
authorised capital of the Company did not change and amounted to RUB 8,100,000. No profit is made by Format
Development LLC and no profit distribution meetings or other board meetings are held. She does not receive any
money for her participation in Format Development Ltd;
(Vol. No. 273, pp. 102 - 105)
- O.V. Maricheva's Testimony

given to her as a witness, according to which in approximately 2018 she experienced financial difficulties and was
looking for a source of additional income, in connection with which she turned to various acquaintances for help. Her
acquaintance Choporov Dmitry Alexandrovich offered to become the founder and general director of a limited liability
company for monetary remuneration, which amounted to 15,000 rubles per month, but she did not need to engage in
any organisational, financial and economic activities of this company. It was on such terms that she agreed to provide
her documents for the formation of a legal entity in her name and the entry of her (O.V. Maricheva) information in the
Unified State Register of Legal Entities. Dmitry Choporov explained that both he (Choporov) and his cohabitant
Natalia Kochetkova are also general directors of other limited liability companies and also receive monetary
remuneration for this. Also, in addition to her (Maricheva O.V.), her husband Marichev A.N. agreed with the proposal to
become a fictitious general director on similar terms. She (Maricheva O.V.) does not know in which companies
Marichev A.N., Choporov Dmitry and Kochetkova Natalia were fictitious general directors. D.A. Choporov explained
that his acquaintances working in the group of companies "KiyuBiEf" were in charge of all the issues related to the
registration of the legal entity, afer which he introduced her to Evgeniya Rossieva. Afer the first meeting with
Evgeniya Rossieva, which took place around December 2018 in the Moscow City Business Centre at Presnenskaya
Embankment 8 in Moscow, she (O.V. Maricheva) agreed with Evgeniya Rossieva's proposal and gave her (E. Rossieva)
her documents to be entered into the Unified State Register of Legal Entities, where she (O.V. Maricheva) will be the
founder and CEO of LLC "VL Consulting" INN 7706463476. Later she (Maricheva O.V.) did not see Rossieva Evgeniya,
but she (Rossieva E.) talked to her about monetary remuneration for her (Maricheva O.V.) participation in the LLC "VL
Consulting". Afer the meeting with Rossieva Evgenia, she (Maricheva O.V.) was already contacted and met with
Burlakova Natalia, who periodically invited her (Maricheva O.V.) to the Business Centre "Moscow - City" to sign pre -
prepared documents related to LLC "VL Consulting". She (Maricheva O.V.) did not read the signed documents, as she
trusted Rossieva and Burlakova and had no doubts about their decency. She did not go to the Federal Tax Service to
sign any documents, she did not go to credit and other institutions to open accounts and sign any documents related
to LLC "VL Consulting". She (Maricheva O.V.) signed, among other things, various powers of attorney on her own
behalf for people she does not know. All information about the persons included in the powers of attorney was
provided by Burlakova Natalia. Some documents were signed at the notary's office at the Moscow City Business
Centre. She does not know what kind of activity VL Consulting LLC was engaged in. She also does not know the staff of
VL Consulting LLC, information on the Company's settlement accounts, the address of the Company and other
information related to it (the Company). She did not make any independent decisions related to the activities of VL
Consulting LLC. She received money for her participation in VL Consulting LLC for approximately one and a half to two
years. Basically, the money for participation in VL Consulting LLC was transferred to her bank card from Burlakova
Natalia, the details of which she (Maricheva O.V.) had previously provided to Burlakova N. Sometimes the money was
paid to her in cash by Burlakova Natalia and her husband Marichev A.N. received it for her (Maricheva O.V.);
(Vol. No. 273, pp. 106 - 109)
559
The testimony of Taranukh D.V.
, given by him as a witness, according to which, in approximately March 2021, he received a phone call from Svetlana,
previously unknown to him, informing him that she represented the interests of a large investment company
recruiting candidates for vacant positions. On or about 11 - 12 March 2021, he was invited for an interview at the
organisation's office located on the 9th floor of the Moscow City Business Centre on Presnenskaya Embankment in
Moscow. There he met Svetlana, who introduced herself as the head of the Human Resources Department of the QBF
Group of Companies. She (Svetlana) asked him to provide all available documents confirming his education, work
experience, citizenship and other documents. On the same day he was approached by Ruslan Spinka, who introduced
himself as one of the top managers of the QBF group of companies and explained that in the future he (D.V. Taranukh)
would co - operate with him (R. Spinka) on all working issues directly. Spinka Ruslan also introduced him (Taranukh
D.V.) to Padalko Nikolay, one of the top managers of the QBF group of companies. In addition, he had to communicate
with Evgenia Rossieva, who is the head of the legal department of the QBF group of companies. In conversation with
Spinka R. and Padalko N., the latter explained to him that the QBF group of companies is a large investment company
and has a number of different lines of business and independent projects, and one of such projects was VL -
Consulting LLC INN 77006463476, where the founder was White Holdings Limited Liability Company, registered in
Hong Kong, and whose director was Nikolai Sergeyevich Padalko. He (Taranukh D.V.) was offered to become the
General Director of VL - Consulting LLC and to develop the planned line of business, which included consulting the
public on securities markets, stock trading, mutual funds, and financial products of QBF Group. These activities were
supposed to be carried out on a paid contractual basis. He (Taranukh D.V.) was interviewed in various ways to improve
his level of knowledge in the field of finance. As a result of the interviews, around April 2021, he (Taranukh D.V.) was
informed that he had passed the selection competition and was offered a salary of RUB 120,000 per month, with the
possibility of increasing it if the organisation's sales level increased. He agreed with the proposal of Spinka R. and
Padalko N., afer which he signed a labour contract, on the basis of which he (Taranukh D.V.) became the general
director of LLC "VL - Consulting" INN 77006463476. At a notary located in the building of the Moscow City Business
Centre, he signed the founding documents in respect of VL - Consulting LLC. Afer receiving information from the
Federal Tax Service that he (Taranukh D.V.) is the General Director of LLC "VL - Consulting", which became known to
him on 28.05.2021, he issued an EDS (electronic digital signature) in his name and re - registered the Company's
current account opened in PJSC "Sberbank". Every day he (Taranukh D.V.) went to the office of QBF Group of
Companies located in the Moscow City Business Centre, where he studied the regulatory framework related to the
activities of VL - Consulting LLC. The company did not carry out its core business activities. Spinka R. and Padalko N.
said that in the near future the Company would start carrying out its activities. According to them (Spinka R. and
Padalko N.) LLC "VL - Consulting" is a non - functioning organisation with a zero balance sheet, which was formed for
the project. He knows nothing about the fact that "VL - Consulting" LLC carried out any activities, including accepting
money from citizens. Spinka R. and Padalko N. promised to provide him with about 6 - 10 employees, who are already
experienced financiers. In addition, Padalko N. and Spinka R. promised to provide a separate office to carry out the
activities of LLC "VL - Consulting", but the employees and the office were never provided. In May - June 2021, the
offices of QBF group of companies were searched, afer which, when he asked about the future of the company,
Spinka R. and Padalko N. explained that VL - Consulting LLC had no legal relation to QBF LLC and he (Taranukh D.V.)
had nothing to worry about. Further, he continued to come to the office of QBF Group of Companies in Moscow City
on a daily basis. In July - August 2021, he was no longer allowed into the office of QBF Group of Companies in Moscow
City. On 25.12.2021, he resigned as CEO of VL - Consulting LLC, afer which he notified the Federal Tax Service through
a notary about the unreliability of the information available in the Unified State Register of Legal Entities, as he
(Taranukh D.V.) was no longer a director, and no one appointed a new director instead of him. He notified Spinka R.
and Padalko N. about his decision, but they did not make any proposals to replace the general director. He notified
the founder in Hong Kong and Padalko Nicholas by post of his action to withdraw his authority. For all the time he
(Taranukh D.V.) was in the position of the General Director of LLC "VL - Consulting", he (Taranukh D.V.) did not receive
any salary and was not paid any money for participation in the activities of this Company. He did not sign any
financial and economic documents on behalf of the General Director of LLC "VL - Consulting" and did not conclude
any agreements. He also did not receive any documents from Spinka R. and Padalko N. relating to the activities of VL -
560
Consulting LLC. He knows that Roman Shpakov was the main head of the QBF group of companies, but he has never
seen R. Shpakov;
(Vol. No. 273, pp. 112 - 115)
- The testimony of Shaban Y.V., given by him as a witness,

according to which in 2018 he became an individual entrepreneur "Shaban Y.V." and is engaged in business consulting
and advertising. In 2020 he opened and still operates the company "RIF" JSC, where he is also the general director.
This company was created to manage non - profit real estate, buy and sell units of already established funds ZPIF RIF
Warehouse Federal 1, ZPIF RIF Mixed Federal 2 quarters. He has been cooperating with QBIF since 2020 in the field of
brokerage, namely, the purchase and sale of units of ZPIFs, as well as structuring of real estate objects into funds
when working with QBIF UA. He knows: Stanislav Anatolievich Matyukhin - is the General Director of the investment
company; Smirnova Yaroslava Genadievna - is the General Director of the management company QBF; Pokhomov
Vladimir - is the managing partner; Munaev Zelimkhan Visaitovich - is the managing partner, top manager. These
individuals are employees of QBF, which is engaged in brokerage and investment activities. Its interaction with QBF
company takes place through two transaction paths. In the first case, the fund units are transferred from the OSD to
the broker's depository; accordingly, the client deposits funds into the broker's account for the corresponding
brokerage purchase and sale transaction and gives a power of attorney and instruction for such transaction. He (Y.V.
Shaban) as a seller also gives an order to sell and on the basis of these orders the unit is bought and sold. He (Y.V.
Shaban) receives the money in the brokerage account and the client receives the unit. He (Shaban Yu.V.) has the right
to withdraw the money to a personal account, and the client has the right to leave the unit on the broker's depository
or on application to withdraw it to the OSD, subsequently once a quarter on the unit is accrued dividends, which are
formed on the basis of the rent flow of the property. The second way without participation of a broker, representatives
of QBF company find a client to buy units, he (Shaban Y.V.) and the client conclude a sale and purchase agreement,
the client pays for the unit to the settlement account, in return for the contract receives a transfer order for transfer
from his (Shaban Y.V.) account in OSD to the client's account in OSD. Accordingly, in case of such transactions,
remuneration is paid for the client. He (Y.V. Shaban) has a company "Idep Smart" Ltd. and a loan was issued to this
company by "Q.Broker" Ltd. for the purchase of a property in the Headliner Residential Complex. According to the
loan agreement, Q-BROKER Ltd. put an encumbrance on the alienation of the share in Idep Smart Ltd. The ultimate
purpose of the transaction was that Millhouse Invest Ltd. has a sale and purchase agreement from the developer for
the property, Idep Smart Ltd. is the founder of Millhouse Invest Ltd. Afer registration of ownership and launch of the
object into commercial use, it is planned to transfer this object to ZPIF and receive units with revaluation according to
the market price of "Idep Smart" LLC. Subsequently, Idep Smart LLC will close the loan with accrued interest by
transferring the units for the amount of liabilities or with the cash received for the realisation of these units in the free
market. Also Q-BROKER LLC is the primary holder of the units. He interacted with Munaev Z.V. on the creation of real
estate funds of KBF UA Ltd, on the construction of agency sales, real estate units to clients of the financial group. The
last time he interacted with Munaev Z.V. was in 2020. He interacted with S.A. Matyukhin on operational issues of unit
sales and purchases. Of the employees of the group of companies "QBF" he knows the following persons: Spinka
Ruslan Valeryevich, Korzh Andrey Vasilyevich and Padalko Nikolay Sergeevich are sales managers, with him he
(Shabana Yu.) got acquainted with him during the interaction with the shareholders during the discussion of the role
of the financial group as a sales agent; Yuriy Nikolaevich Orlov is the head of Q-BROKER and he (Y.V. Shaban) interacts
with him, the essence of which is that Y. Orlov is a signatory on the contracts of purchase and sale of units, Q. Broker
sells them to FE.broker sells them to IE "Shaban Yu.", JSC "RIF" and "Idep Smart", then the units of real estate funds
are sold to end clients; with Pakhomov Vladimir Sergeevich interacted on the sale of units, only in the regions; Yudin
Maxim Stanislavovich is a top manager of the company; Shpakov Roman Valerievich is a shareholder of the company
and participated in the initial negotiations on the launch of interaction between RIF and QBF; Rossieva Evgenia
Anatolievna is the chief lawyer of his (Shaban Yu.V.) counterparty; Dmitry Sergeevich Lepeshkin is related to
561
construction projects; Linda Athanasiadou is a top manager of the company; Kirill Sergeevich Sobolev introduced him
(Y.V. Shaban) to the company in 2013; Alexey Sergeevich Golubev is a manager in St. Petersburg, he (Y.V. Shaban)
interacts with Golubev.V.) interacts with A. Golubev in the process of agreeing and signing an agency agreement for
the sale of units; Yaroslava Gennadyevna Smirnova is the General Director of QBIF USA, interacts with her on the
creation of new ZPIFs, as well as operational support;
(Vol. No. 273, pp. 159 - 164)
- Nesterova I.S.'s Testimony

as a witness, according to which, in October 2010 or so, her acquaintance Kuzin Sergey Lvovich offered her a job at QB
Finance Ltd. as head of the personnel department. She has known Kuzin S.L. for a long time, as Kuzin is the husband
of her sister. Kuzin S.L. worked in this company and was a co - founder together with Roman Valeryevich Shpakov,
who was the direct manager of this company. She agreed to Kuzin S.L.'s proposal and then had an interview with
Shpakov R.V., who approved her candidature. Her salary was approximately 25,000 per month, which was given to her
in an envelope directly by R.V. Shpakov, and she did not sign her pay slips. Her work duties included being an office
manager. As part of her work duties, she supervised the organisation's advertising, the appearance of employees, the
organisation of employee catering, the supervision of employees and secretaries and clearing companies, record
keeping and personnel work. She did her work independently, but reported on the results of her work directly to
Shpakov R.V. The office of QB Finance LLC was located at the following address: Moscow, Krasnopresnenskaya metro
station, Business Centre, 24 Krasnaya Presnya Street. Around February 2011, the office of QB Finance LLC changed its
address and was moved to the Moscow City Business Centre at 8 Presnenskaya Embankment. She worked at QB
Finance LLC from October 2010 to 2013 - 2014 and resigned at her own request. The reason was that she did not agree
in character and opinion with Shpakov R.V. During her employment with QB Finance LLC, the following employees,
whom she knows personally, worked in the organisation at various times: Roman Valerievich Shpakov - the head of
the organisation; Sergey Lvovich Kuzin - participated in important meetings of the organisation, but she does not
know his position; D. Lepeshkin - the head of the management team.S. - head of a team of account managers; Maxim
Yudin - head of a team of account managers; Dmitry Sergeyevich Kipa - head of a team of account managers, including
analytics; Zelimkhan Visaitovich Munaev - head of a team of account managers; Vladimir Pakhomov - assistant to R.
Shpakov; Nikolay Mikhailov - assistant to R. Shpakov.V.; Mikhailov Nikolai - head of the team of account managers;
Voronova Tatiana - chief accountant; Modin Nikolai - co - founder, possibly technical director; Gorsheneva Margarita -
was engaged in the development of the company's brand, and could also be in close relations with Shpakov R.V.;
Gramza Ekaterina - performed the functions of a secretary in the reception; Selivanov Yuri - trader; Gonchar Dmitry -
manager in the group at Kipa D.S., Gurevich Igor - manager in the group at Kipa D.S.; Zarechnev Vladimir - trader;
Valiev Renat - manager in the group at Kipa D.S.; Rossieva E.A. - lawyer, I have never seen her, with Rossieva E.A. there
was only business correspondence. In addition, Alexei Ovsyannikov, Arseny Rukhov and Daniil Roschupkin worked as
brokers at QB Finance LLC. Alexey, Arseniy and Daniil did not work in the company afer the change of the office
address. Shpakov R.V. initially organised his activities with the above people, but later on they also stopped finding a
common language with Shpakov. Around 2012, she was offered to develop a project, which was Kyubi Consulting Ltd.
In this company she was the general director and co - founder, the second founder was Kuzin S.L. Despite her position
as the general director of Kyubi - Consulting LLC, she did not participate in the financial and economic activities of the
company and did not make any decisions. R.V. Shpakov dealt directly with all organisational and financial issues of
this organisation, while she opened accounts for Qubey - Consulting LLC in Alfa Bank and went to the tax service on
issues related to the activities of Qubey - Consulting LLC. She soon withdrew from the founders of Kyubi - Consulting
LLC and resigned from the position of general director. She did not receive any money for her participation in the
activities of Kyubi - Consulting LLC;
562
(Vol. No. 273, pp. 169 - 172)
Rumak S.E.'s testimony, given by him as a witness,

according to which he had been working in OJSC Region - Invest as a stock broker for 17 years. He worked in this
organisation until about 2008 - 2009. The head of OJSC "Region - Invest" was Mukhamedgaliev Ramazan Gabidovich,
with whom he (Rumak S.E.) had trusting relations and he (Mukhamedgaliev R.G.) periodically addressed him (Rumak
S.E.) with various requests not related to the duties of a stock broker. Thus, at the request of R.G. Mukhamedgaliev, he
(S.E. Rumak) was a founder or participant, as well as the general director of various JSCs and LLCs, but he does not
remember the names of the companies, as he was a nominal director and participant of the companies, did not make
any independent decisions, did not participate in the financial and economic activities of the companies. At the
request of R.G. Mukhamedgaliev, he (S.E. Rumak) signed various documents relating to the activities of those
organisations where he (S.E. Rumak) could be a director or participant. For example, at the request of R.G.
Mukhamedgaliev, he (S.E. Rumak) could have been the general director and participant of KBF Asset Management LLC
in the period of 2013 - 2014, but he does not know what activities this company carried out. In addition, he
remembers the organisation of PJSC "Venture Finance Centre". He does not exclude the fact that at the request of R.G.
Mukhamedgaliev he (S.E. Rumak) could have been a participant or general director of this company at some time. At
the request of R.G. Mukhamedgaliev in approximately 2013 - 2014, he (S.E. Rumak) participated in a transaction for
the sale and purchase of promissory notes issued by a bank, possibly "Sberbank", which were purchased by
representatives of the group of companies "QBF". He was present at this transaction as a seller of bank promissory
notes, and Mikhailov Nikolay and Lepeshkin Dmitry were present as buyers on behalf of the group of companies
"QBF". He (Rumak S.E.) brought the promissory notes to the transaction by hand, and the funds under the transaction
were transferred in non - cash form from the account of the buying organisation to the account of the selling
organisation;
(Vol. No. 273, pp. 174 - 177)
- The testimony of N.V. Mikhailov, given by him as a witness,

according to which in 2010 he was temporarily unemployed and placed a questionnaire on the website
"HeadHunter.ru" on the search for a vacancy for the position of sales assistant. In the same year, around October -
November, he received a call on his mobile phone and was invited to an interview at the company QB Finance (later
renamed QBF). At the interview, he spoke to Vladimir Lipatnikov, who held the position of head of sales at the
company. During the interview he (N.V. Mikhailov) informed Lipatnikov V. of his intention to work in sales, spoke about
his experience and skills he possessed. In turn, Lipatnikov V. told what the company "QB Finance" does, it carries out
activities in asset management on the stock market in America. Afer the interview, afer a short time he (N.V.
Mikhailov) received another call and was informed that his (N.V. Mikhailov) candidature was agreed for the position of
a consultant. In fact, his duties in the company included making phone calls to the numbers provided by the
employees of the organisation. During these telephone calls he (N.V. Mikhailov) told about the activities of QB Finance
Company according to the information provided to him by the management, afer which he invited the interlocutors
to the company for a consultation. He did not take part in the consultations themselves; this was done by the heads of
departments. The head of QB Finance was Frolov Vladimir Gennadyevich. He (N.V. Mikhailov) had a direct superior
Lipatnikov V. Later Shpakov R.V. became the head of the company and he (R.V. Shpakov) became his (N.V. Mikhailov)
direct superior. He (N.V. Mikhailov) worked as a consultant until about 2013. Thereafer, he held various positions in
QB Finance: he was a financial advisor, development director, and held other positions. Subsequently, his function in
563
the organisation changed, on the order of R.V. Shpakov, he (N.V. Mikhailov) began to search for projects interesting for
the development of the company, in which it would be possible to invest or organise a joint business that would bring
profit to the organisation. He worked in the company until about 2017. During this time he conducted many
negotiations to attract business companions, for example, projects for the construction of a mushroom farm,
shopping centre, bakery, but the final negotiations and final decision - making always rested with Shpakov R.V. He
stopped working at QBF on the instructions of Shpakov R.V. so that he (Mikhailov N.V.) would not be listed in two
positions. During the period of time from 2013 - 2014 to 2021, he worked for the company "VCF" (Venture Capital
Finance Centre). Initially, he worked part - time, and later it was his direct employment, in the capacity of General
Manager. R.V. Shpakov was appointed to the said position. R.V. Shpakov instructed him (N.V. Mikhailov), as his
subordinate, to get a job in the said company. He (N.V. Mikhailov) had no choice but to agree, otherwise he (N.V.
Mikhailov) would have been dismissed and would have lost his job. His workplace did not actually change and was
still located in the Capital City Tower. In this company the staff sometimes changed from 3 to 10 people. The
accountant was Ekaterina Gramza, who had good relations with R.V. Shpakov. During the period of his (N.V. Mikhailov)
being in the position of the general director of the company "CEF" he did not actually manage, he knew nothing about
the financial and economic activities of the company, as he was a nominal manager. He could sign some documents
on behalf of the general director of the company, which were provided to him either by Gramza E. or other employees
of QBF. Instructions to sign any documents were given to him by both Shpakov R.V. and the accountant Gramza E., as
well as other office employees, referring to the instructions of Shpakov R.V. At the same time, he (Mikhailov N.V.)
repeatedly noticed documents drawn up on behalf of the company "QBF" and signed on his behalf, although he did
not personally sign them. He did not study the documents he signed, as he realised that all of them were agreed with
R.V. Shpakov, the actual head of the company "CEF". R.V. Shpakov made decisions on the company's activities, and he
(N.V. Mikhailov) was formally their signatory as the general director of the company. Around July - August 2021, he was
dismissed from the company "CEVF" by the decision of the Board of Directors. He (N.V. Mikhailov) believes that the
reason for his dismissal was his refusal to carry out transactions with the assets of the company "VCF" in June 2021,
when law enforcement agencies became interested in the activities of the group of companies Shpakov R.V. He (N.V.
Mikhailov) was listed as General Director of PJSC "Venture Finance Centre" INN 7734682254 since 2013, he was never
the founder of this company. In LLC "Profi" INN 7703447860 he (N.V. Mikhailov) was nominally the founder and general
director from the moment of the establishment of the company, also on the instructions of R.V. Shpakov, actually did
not manage the company, did not participate in its activities. He does not exclude that he (N.V. Mikhailov) signed
powers of attorney for the management of PJSC Venture Finance Centre and LLC Profi. He knows the following
persons who worked at QBF: Ruslan Spinka and Nikolay Sergeyevich Padalko - employees of the company; Yuri
Nikolayevich Orlov - an employee of the company who worked in the IT department; Vladislav Olegovich Plitin - an
employee of the company who worked with its clients; Andrey Vasilievich Korzh - an employee of the company;
Vladimir Georgievich Frolov - at the time of his (Mikhailov N. V.) employment, the General Director of QBF.V.)
employment general director of "QBFinance"; Pakhomov Vladimir Sergeyevich - top manager, what he (Pakhomov
V.S.) was doing specifically does not know, ofen saw Pakhomov V.S. together with Shpakov R.V.; Shpakova Irina
Nikolaevna - mother of Shpakov R.V., Zelimkhan Visaitovich Munaev - top manager of the company; Stanislav
Anatolievich Matyukhin - he knows her, assumes that he is a top manager; Evgenia Anatolievna Rossieva - he knows
her, her workplace was in the legal department; Linda Athanasiadou - he saw her in the office, he does not know what
she was doing; Pavel Yuryevich Vlasov - employee of the company; Kirill Sergeevich Sobolev - employee of the
company in the sales department; Aleksey Sergeevich Golubev - he heard that he is a manager in St. Petersburg;
Aleksey Sergeevich Golubev - he heard that he is a manager in the city of St. Petersburg. St. Petersburg;
(Vol. No. 273, pp. 179 - 184)
- Agafonov S.V.'s testimony, given by him as a witness,

according to which in about 2018, the date he does not remember exactly, his wife Smirnova Yaroslava Gennadyevna
offered him to earn money - to become the general director of a limited liability company for monetary remuneration.
564
Previously, he had never been a director or founder of companies. This proposal interested him and he agreed to
become the director of the Company on condition that he would be paid approximately 10,000 roubles per month. It
was explained to him (S.V. Agafonov) that the organisation should deal with real estate transactions. His wife
(Smirnova Y.) introduced him to Natalia, whom he first met at the Moscow City BC in the Federation Tower on
Presnenskaya Embankment in Moscow around May 2018. Natalia took him to a notary, who was also located in BC
"Moscow City" and there he (S.V. Agafonov) was given a number of documents to sign, which he signed. What
documents they were, he does not know, he did not read them. According to the verbal agreement with Natalia, he
(S.V. Agafonov) became director of Limited Liability Company LLC "701" INN 7703456375 for monetary remuneration
in the amount of approximately 10,000 rubles per month, but he would not make any organisational and
administrative decisions. Afer signing the documents, he lef the office of the organisation and subsequently came to
the building of the Moscow City DC on Presnenskaya Embankment in Moscow when he received calls. He was also
aware that the company he headed was controlled by the management of the QBF group of companies, which was
engaged in brokerage and securities operations. In turn, the head of the QBF group of companies was Roman
Shpakov, but he did not know him personally. To carry out the activities of the Company, he (S.V. Agafonov) could sign
a power of attorney at the notary's office on his own behalf as the General Director of LLC "701" INN 7703456375,
entrusting all his powers to another person. When signing the documents and the power of attorney at the notary, he
did not see the person to whom I entrusted the management of the Company, as well as other possible participants of
the Company. He did not go to any offices in the building, all negotiations with Natalia were held in the lobby of the
building except for the meeting that took place at the notary's office. Among the employees of the QBF group of
companies, he met several times with Evgenia Rossieva, who gave him money as remuneration for his participation as
a director of the Company. Rossieva Evgenia transferred the money to him through his wife Smirnov Yaroslava in cash.
The payments were made irregularly. He also knew Ekaterina Gramza, who was an employee of the QBF group of
companies. With Gramza E. he went to banks in Moscow to open settlement accounts for LLC "701". He gave all the
information and passwords he received at the bank to Ekaterina Gramza. LLC "701" TIN 770345637 was registered in
his name on 17.05.2018. Natalia further accompanied him (S.V. Agafonov) in signing constituent and other documents
in respect of LLC "701", where he was subsequently the director. He does not know whether LLC "701" had any
financial and economic activities. He never went to the Federal Tax Service to draw up documents in respect of LLC
"701" and did not sign any documents there. He was a nominal director of LLC "701" and did not make any decisions,
he did not proactively sign financial, organisational, economic and administrative documents on behalf of the
director of LLC "701". All signing of documents in the interests of LLC "701" took place on the instructions of Natalia
and Evgenia Rossieva, and they prepared these documents in advance. He does not know what these documents
were, he did not read them when signing them. He does not remember how many times he signed the documents
prepared by Natalia and Evgeniya Rossieva. He did not sign for the receipt of money in the statements;
(Vol. No. 273, pp. 190 - 193)
Maznichenko P.L.'s Testimony given by him as a witness,

according to which, around 2016, he and his acquaintance Shaban Yuri decided to create a company, the main activity
of which would be the purchase and sale of cars. The company was called LLC "Indep.Auto" TIN 7735159230 and had
two participants, Shaban Yuri and him, with equal shares. He (P.L. Maznichenko) was the general director of the
company. While carrying out their main activity, they got acquainted with Roman Shpakov, who turned to them as
specialists in the sphere of automobile business, in order to analyse the activity of the Company LLC "AvtoAlia", which
Shpakov R. decided to buy out, but the transaction did not take place. Afer that he may have seen Shpakov Roman
several times, but he does not remember the circumstances any more. Around 2018, in order to increase the prestige
of the organisation, "Indep.Auto" LLC was renamed to "Indep.Smart" LLC. In approximately 2018, he (P.L.
Maznichenko) decided to withdraw from the Company and resigned from the position of CEO. Afer his resignation
from "Indep.Smart" LLC, it (the Company) was headed by Shaban Yuri, who was the sole participant of "Indep.Smart"
565
LLC. Currently, he (P.L. Maznichenko) co - operates with the general director of "Simon Jesso" LLC, Valery Evgenyevich
Arsenchuk, and assists in the activities of V.E. Arsenchuk as a consultant to the head on the issue of increasing the
level of sales. He is not on the staff of "Simon Jesso" Ltd. and does not receive salary in this organisation. He (P.L.
Maznichenko) was recommended to this position by Roman Shpakov at the end of 2019. The main activity of Simon
Jesso LLC is the construction of apartment buildings and one of these buildings is located in Odintsovsky district of
Moscow region. He is aware of the activities of QBF and other organisations of the same name, as Simon Jesso LLC
cooperated with the group of these companies in terms of IT and marketing until the end of 2020. He knows that
Roman Shpakov was the main manager of the QBF group of companies. In addition, he (P.L. Maznichenko) co -
operated with some employees of the QBF group of companies in managing the fund on behalf of Rif JSC, which was
managed by Rif JSC in Novorossiysk. The head of JSC "Rif" was and is Yuri Shaban. He (P.L. Maznichenko) did not
make any independent decisions when carrying out the above activities, but was only a consultant, as the
Management Company for the above fund was MC QBF LLC. While managing the above fund he had to communicate
with the following persons: Smirnova Ya. G., an employee of QBF Asset Management LLC; R.V. Spinka. - R.V. Spinka, an
employee of QBF LLC responsible for sales; Y.N. Orlov, an employee of QBF LLC responsible for IT; R.F. Amerov, an
employee of QBF LLC. - R.F. Amerov, an employee of QBF LLC. In addition, he has heard about some of the employees
of QBF Group, but he does not know them personally. These include: A.V. Korzh; V.S. Pakhomov; O.Y. Timokhin; M.S.
Yudin; Z.V. Munayev; S.A. Matyukhin; S.A. Athanasiadou Linda; A.F. Vozhzhov;
(Vol. No. 273, pp. 195 - 198)
Arsenchuk V.E.'s testimony, given by him as a witness,

according to which he has been a shareholder of Simon Jesso LLC since 2013, the size of his share in the company is
50%. This company previously belonged to Shpakov R.V. On his (Shpakov R.V.) initiative he (Arsenchuk V.E.) joined the
founders. He (Arsenchuk V.E.) was interested in participating in the implementation of the construction project of the
Gribovsky les LCD "Gribovsky les" in connection with which he decided to join the founders. Initially, the land plot
located at the address: Odintsovsky district, v. Borodki, Parkovaya street, 1, on which the construction of the project
LCD "Gribovsky les" is carried out, belonged to him (Arsenchuk V.E.) as an individual. He purchased this land plot in
2011, also from an individual, for 120,000,000 roubles, while looking for partners to implement the project. His son
Nikolay Valeryevich Mikhailov worked for QBF from approximately 2011 - 2012 until 2019, developing and
implementing various QBF projects. In about 2013, his son proposed to co - operate with his (son's) manager and
beneficiary of QBF companies Shpakov R.V. Afer communication with Shpakov R.V., he (Arsenchuk V.E.) considered it
possible to co - operate with Shpakov R.V., in connection with which he (Shpakov R.V.) eventually became a founder of
Simon Jesso LLC. As far as he (V.E. Arsenchuk) remembers Shpakov R.V. paid him half of the cost of the land plot - 60
000 000 roubles, this was the fulfilment of the condition for Shpakov R.V. to enter the Gribovsky les LCD project. The
land plot was appraised by specialists hired by Shpakov R.V. The land plot was valued at more than 500,000,000
roubles and with this amount the plot was included in the authorised capital of Simon Jesso Ltd. Afer he (V.E.
Arsenchuk) joined the founders of Simon Jesso LLC, he was appointed general director and chief accountant of the
company. The second founder of the company with a 50% share was Shpakov R.V. The responsibilities were divided,
he (Arsenchuk V.E.) was responsible for the design and implementation of the construction of the facility, and
Shpakov R.V. was responsible for financing the project and maintaining the financial records of the company. All
financial and accounting documents were prepared by a person from R.V. Shpakov. - Voronova Tatiana. She worked
for a short period of time, and afer her Ekaterina Gramza was in charge of the company's accounting. The accounting
documents were mainly located in the QBF office in Moscow City and, as he was informed, some of the accounting
documents were carried by Gramza E. in her car at all times. Shpakov R.V. transferred two loans to Simon Jesso LLC in
approximately 2016 - 2017: one from an individual in the amount of approximately 40,000,000 rubles; the other from
the company M1 Invest LLC in the amount of possibly 50,000,000 rubles. On his (V.E. Arsenchuk's) side, as an
individual, funds were also deposited into the accounts of Simon Jesso LLC, totalling approximately 50,000,000
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rubles. Additional funds were needed to continue construction and in this regard, around the beginning of 2019, he
(Arsenchuk V.E.) applied to Srednerussky Sberbank with a loan application, and around June 2019, an agreement was
concluded between "Simon Jesso" LLC and PJSC Sberbank. The total amount of the loan was RUB 1,050,000. LLC
StroyInterService won the tender for the construction of the Gribovsky Les Residential Complex and was the general
contractor. An investment contract worth 36 million roubles was concluded between Simon Jesso LLC and the
Odintsovo District Administration. Under the terms of the contract, OOO "Simon Jesso" has to allocate a room for a
doctor's office in the LCD, transfer to the Administration 2 flats with a total area of about 100 square metres, as well as
agricultural tractors worth a total of 6,000,000 roubles. Around the end of November - December 2020 he (V.E.
Arsenchuk) became aware of the fact that R.V. Shpakov sold his (R.V. Shpakov's) 50% shares in "Simon Jesso" LLC to
Denis Vitalievich Sorokin, who is now actually blocking the activity of the enterprise. As the second founder with a
50% stake, D.V. Sorokin refuses to finance the construction of the facility and refuses to sign any documents, including
the guarantee agreement with the bank. According to D.V. Sorokin, he did not receive a "command" for the above
actions, and he did not explain from whom exactly the command should come. He does not know Sorokin D.V. to the
present time, he has not seen him (Sorokin D.V.) and has not communicated with him, he does not know what kind of
person he is. He (Arsenchuk V.E.) does not know the circumstances of the contract between Shpakov R.V. and Sorokin
D.V., as well as its conditions. Initially R.V. Shpakov offered him (V.E. Arsenchuk) to buy 50% of the shares of the
company, but he refused for the reason that it was important for him to finish the construction project and he tried to
use any free money for its implementation. In order to complete the construction, the project needs additional
funding of approximately 200,000,000 roubles. During the implementation of the Gribovsky Les LCD project, Shpakov
R.V. initially had a representative - Lepeshkin Dmitry Sergeevich, who did not work for Simon Jesso LLC, but was
actually fully engaged in the project, representing Shpakov R.V. Lepeshkin D.S. communicated with network
organisations and communicated with representatives of the Odintsovo Administration. He (Arsenchuk V.E.) does not
keep in touch with Shpakov R.V. at present, the last time he spoke by phone was in April 2021. Shpakov R.V. wanted to
reissue some flats to persons affiliated to him (Shpakov R.V.), afer which he would refinance the project. He (V.E.
Arsenchuk) refused Shpakov R.V. and did not communicate with the latter afer that. Until the beginning of July 2021
the keys of the bank - client and 1C Accounting programme were in the possession of Gramza E., but in June she
(Gramza E.) stopped submitting accounting reports and blocked payments. In this regard, he (V.E. Arsenchuk) re -
issued the bank - client and "Accounting 1C" keys to himself. All accounting documents are also at Gramza E.'s place;
(Vol. No. 274, pp. 1 - 5, pp. 7 - 9)
- The testimony of D.V. Sorokin, given by him as a witness,

according to which he has known Roman Valeryevich Shpakov since about 2010, who until recently was a family
friend. They got acquainted through his (Sorokin D.V.) sibling Sorokin Andrey Vitalievich, who is closely acquainted
with Shpakov R.V.'s mother. - Shpakova Irina Nikolaevna. In the process of communication Shpakov R.V. offered him
(Sorokin D.V.) to invest in his (Shpakov R.V.) commercial activity, he (Sorokin D.V.) knew that Shpakov R.V. was engaged
in trading on stock markets. He (D.V. Sorokin) in 2010 - 2011 transferred to R.V. Shpakov. 10,000,000 roubles as an
investment. These funds were his personal savings, which had been accumulated and stored in US dollars since about
1996, i.e. since he started his entrepreneurial activity. At the moment he does not remember where exactly the
transfer of funds took place, it was done in instalments of 2 - 3 million at a time. Most likely, the money was
transferred in Severodvinsk, as R.V. Shpakov periodically appeared in Severodvinsk, and he (D.V. Sorokin) never
travelled to Moscow. At the time of transferring the money, receipts on receipt of the money by R.V. Shpakov were
drawn up, but he does not remember their text at the moment. However, there was an oral agreement that the money
was given to R.V. Shpakov as an individual as a loan with the condition of interest accrual at the rate of 7 per cent per
annum and with the condition of indexation depending on changes in the US dollar exchange rate. In late January -
early February 2021, during a telephone conversation, he asked Shpakov R.V. about the possibility of receiving his
(Sorokin D.V.) money that had been transferred to Shpakov R.V. as loans. R.V. Shpakov explained that he could transfer
in his (D.V. Sorokin's) favour a share in the authorised capital of OOO "Simon Jesso" in the amount of 50%, with a total
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value of 60,000,000 roubles. Shpakov R.V. explained to him that the purchase and sale of the share in the authorised
capital of Simon Jesso LLC would not be for cash, but by transferring to him (Sorokin D.V.) securities - promissory
notes. At the end of February 2021 he (D.V. Sorokin) received a phone call from I.N. Shpakova and informed that in
order to carry out the transaction of purchase and sale of a share in the authorised capital of OOO "Simon Jesso" he
should arrive in Moscow to execute all the documents. On 25.02.2021, he arrived at the central office of Sberbank PJSC
in Odintsovo, he does not remember the exact address, where he had an appointment with Shpakova I.N. At the bank,
the documents for the transaction of sale and purchase of a share in the authorised capital were executed. At the
same time in the office of PJSC "Sberbank" in addition to him was present Shpakova I.N. Afer registration of
documents in PJSC "Sberbank" went to the notary Kvitko A.F. in Odintsovo, where the transaction of sale and
purchase of a share in the authorised capital of LLC "Simon Jesso" was registered and the contract of sale and
purchase of a share in the authorised capital of the Company series 77 AG 5062560 was issued. Later it became known
to him that the transaction was conducted under a notarial power of attorney issued by Shpakov R.V. in favour of
Shpakova I.N. Shpakov R.V. himself was not present during the transaction of sale and purchase of a share in the
authorised capital. As far as he (Sorokina D.V.) knows, the information about his entry as a founder of LLC "Simon
Jesso" was transferred to the tax inspection by the notary Kvitko A.F. Afer making information in the Unified State
Register of Legal Entities about the change of the founder, Shpakov R.V. ceased to have any relation to the activity of
LLC "Simon Jesso". The office of OOO Simon Jesso is located in Odintsovo. He visited this office once on 25 February
2021 on his personal initiative already in the status of a founder, as he was interested in the activities of the Company.
The object of capital construction of the Residential Complex "Griboedovsky les" located at the address: Moscow
region, Odintsovo district, v. Borodki, Parkovaya street, plot No. 1 is known to him, he visited it twice: on 25 February
2021 and in June 2021. As far as he remembers, the developer of the Residential Complex "Gribovsky les" is LLC
"Simon Jesso". At the time of the site visit, approximately 90 per cent of the building frame was completed. The
general director of "Simon Jesso" LLC is Valery Arsenchuk, who is also a co - founder of "Simon Jesso" LLC with a 50%
share in the authorised capital. He (Sorokin D.V.) met Arsenchuk V.E. on 25.02.2021 during his (Sorokin D.V.) visit to the
construction site of the Gribovsky les Residential Complex. At the moment he and Arsenchuk V.E. periodically
maintain working relations, communicate on the issues of activities of Simon Jesso LLC;
(Vol. No. 274, pp. 19 - 24)
- A.V. Sorokin's testimony , given by him as a witness,

according to which he has been living with Irina Nikolayevna Shpakova for more than 10 years up to the present time.
He knows Roman Valeryevich Shpakov, the son of I.N. Shpakova. He did not live together with R.V. Shpakov and they
rarely saw each other. He (A.V. Sorokin) knows that R.V. Shpakov was the owner of the investment company "QBF",
whose office was located in Moscow City and he visited him several times on personal matters. I.N. Shpakova is
engaged in activities related to the construction of the Victory Quarter Residential Complex. The organisations that
are building the above - mentioned housing estate are LLC "KP - 2", LLC "KP - 3", LLC "KP - 4" and as far as he knows
she is the head of the above - mentioned organisations. There are financial and economic relations between LLC "KP -
2", LLC "KP - 3", LLC "KP - 4" and LLC "Venas", approximately from 2017 - 2018, and supplies of construction materials
for the construction of the housing estate. The total amount of financial relationships does not exceed RUB
20,000,000. Denis Vitalievich Sorokin is his (A.V. Sorokin) brother - in - law. The brother from the late 90s - early 2000s,
about 5 years was engaged in retail trade of construction materials, then performed various works on construction
sites as a labourer. During his (Sorokin A.V.) joint residence with Shpakova I.N. his brother Sorokin D.V. got acquainted
with Shpakov R.V. What financial relations between them were he does not know. Only Sorokin D.V. borrowed from
him (Sorokin A.V.) a large sum of money for some investments. He (A.V. Sorokin) transferred to him (his brother)
several million roubles in instalments, he does not remember the total amount and finds it difficult to name the dates
and place of transfer of funds. As he (Sorokin A.V.) understood, his brother Sorokin D.V. invested these funds
somewhere through Shpakov R.V. Subsequently, Shpakov R.V. incurred a debt to Sorokin D.V. for the amount of the
investment and Shpakov R.V. offered to repay the debt by selling his (Shpakov R.V.) share in the authorised capital of
OOO "Simon Jesso". As far as he remembers, his brother Sorokin A.V. agreed to this transaction. He (A.V. Sorokin) owns
Mercedes - Benz GL and Lexus RX200 cars. As an individual entrepreneur and physical person he has opened
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settlement accounts in PJSC Sberbank, PJSC VTB. At present he (A.V. Sorokin) is the general director of JSC "Beauty
Salon", founder of LLC "Venas", LLC "Nordhim", LLC "Brasi", shareholder of "Beauty Salon", JSC "TorgTech", and is also
an individual entrepreneur. JSC Beauty Salon leases non - residential premises with a total area of approximately 250
square metres, the premises are owned by the Company. Venas LLC is engaged in the sale and purchase of
construction materials. The addresses of the shops are 4 Zaozerny Ave. and 68 Lomonosova St., Severodvinsk, the
ground floor of the building belongs to OOO Venas. OOO "Brasi" was previously engaged in the sale and purchase of
construction materials, it owns the land plot and the building at 9 Chapaeva St., Arkhangelsk. OJSC "TorgTech" rents
out non - residential premises at the address: 23 Timme St., Arkhangelsk, an office building with a total area of about
6 thousand square metres. As an individual entrepreneur he (A.V. Sorokin) rents out the following premises:
Severodvinsk, Zaozerny Prd. Zaozerny, 4 and 4A - warehouse and commercial premises. 4A - warehouse and
commercial premises with the area of more than 4 thousand square metres, which are in his ownership; Arkhangelsk,
23 Timme St., which are subleased from OJSC "TorgTech"; Severodvinsk, 116 Lomonosova St. - non - residential
premises of the ground floor of a residential building, with the area of about 125 square metres, which are in his
ownership; Arkhangelsk, 23 Timme St., which are subleased from OJSC "TorgTech"; Severodvinsk, 116 Lomonosova
St. - non - residential premises of the ground floor of a residential building, with the area of about 125 square metres,
which are in his ownership; Severodvinsk, Belomorsky Ave. 43 - a commercial building with a total area of more than
1400 square metres, which are in his shared ownership. He (A.V. Sorokin) also owns commercial premises on the 2nd
floor of a residential building at the address: 20 Loginova St., Arkhangelsk, with the area of about 600 sq. m. and a flat
at the address: Moscow, 2 Gzhatskaya St., bldg. 10, sq. 55, with the area of 76 sq. m. All the above - mentioned real
estate, except for the above - mentioned property, is owned by him. All of the above real estate, except for the flat in
Moscow, is co - owned 50/50 with A. L. Shilov, the general director of OOO Venas;
(Vol. No. 274, pp. 62 - 64)
- Testimony of V.A. Zarechnev, given by him as a witness,

according to which in 2012 he was looking for a job that did not require special education and placed an advert on the
website "hh.ru", At that time he was a student and was only receiving education. Following the advert, he received a
call from representatives of QBF Group and was invited for an interview at the office located at 8 Presnenskaya
Naberezhnaya Naberezhnaya Street, Moscow, where he was offered the position of financial advisor. So in 2012, the
exact date he does not remember, he became an employee of QBF LLC with an unfixed salary, which was a certain
percentage of the amount of attracted funds of the company's clients under trust management agreements. He
received his salary in cash and received it directly from his (Zarechnev V.A.) manager, Munaev Zelimkhan. He (V.A.
Zarechneva) did not sign any statement for the money received. QBF LLC was part of the QBF group of companies. The
main activity of the QBF group of companies was attracting clients for the sale of investment products and trust
management of money invested by clients. The head of QBF LLC was Roman Shpakov. His (V.A. Zarechnev) duties as a
financial advisor included attracting clients to participate in the above activities under trust management
agreements. About 3 - 4 months afer the beginning of work, the management of QBF group of companies decided to
expand its activities, afer which a "Currency Department" was created, where he (Zarechnev V.A.) was the head.
There was one more specialist on the staff, but the staff of the department gradually increased. The employees were
located in the office of the Moscow City Business Centre on Presnenskaya Embankment. Later the "Currency
Department" was renamed "Algorithmic Trading Department", where he (V.A. Zarechneva) and his colleagues wrote
various sofware products, including trading robots. Trading robots were sofware algorithms that analysed the
information occurring on the trading exchange and independently made the purchase and sale of securities, in case
of coincidence of certain factors and achievement of specified goals. Thus, a trading robot, being a sofware
algorithm, actually performed the functions of a trader. For correct operation of trading robots, they were linked to a
brokerage account to carry out operations on purchase and sale of securities. Information on the accounts was
provided by Roman Shpakov, Head of QBF Group of Companies. Activities on purchase and sale of securities were
569
carried out, including from brokerage accounts of the legal entity "QB Capital", registered in the territory of the
Republic of Cyprus. The department, which he (Zarechnev V.A.) headed, was in charge of the brokerage accounts of
the legal entity "QB Capital", but there were not many funds on these accounts compared to the amounts deposited
by the company's clients under trust management agreements. He does not know where the funds received from the
clients of the group of companies "QBF" could be distributed and spent. His department traded on the international
forex brokers AlPari and AlfaForex, as well as on the Russian broker BKS. In parallel to the above mentioned activities
in the "Algorithmic Trading Department" the management of QBF Group of Companies proposed to launch a new
project on "Venture Direction". For the development of this project was created LLC "Faidin.Mi", where he (Zarechnev
V.A.) was the General Director. He (V.A. Zarechnev) did not make any organisational and administrative decisions as
the general director of LLC "Fandin.Mi". In addition to Fandin.Mi LLC, which never started its work, the management of
the QBF group of companies established DV Technologies LLC, where Trishin Gleb was the general director. G. Trishin
was directly subordinate to the management of QBF Group. All decisions were made directly by Shpakov R. The
nature and content of decisions made by Shpakov R., the legal and financial part of the project did not interest him
(Zarechnev V.A.), as he was engaged in his work on the technical part of the project. He (V.A. Zarechnev) was a project
manager in "DV Technolodges" Ltd. To carry out the Company's activities, the management of the QBF group of
companies rented and paid for office premises located on Nizhny Kislovsky pereulok in Moscow. His employment with
QBF Group lasted until approximately 2017 - 2018, before the Company started delaying salary payments. Thereafer,
he and his entire team of programmers resigned from the QBF Group of Companies. In addition to the above -
mentioned executives, he (Zarechnev V.A.) remembers the surnames and names of some employees: Vladimir
Pakhomov - director of the branch network of the group of companies "QBF"; Avetis Vartanov - financial advisor,
personnel training instructor; Ivan Auguston - administrator, computer adjuster, director of the IT department; Maria
Gorsheneva - financial advisor, development director; Tural (name) - trader; Nikita Selivanov - trader, head of the
trading department; Sergey Gusev - trader; Alexander Rakunov - algorithmic trading, his (Zarechnev V. A.) colleague;
Grammatov - trader, head of the trading department; Aleksandr Rakunov - trader, head of the trading department;
Alexander Rakunov - algorithmic trader, his (Zarechnev V. A.) colleague.A.) colleague; Ekaterina Gramza - secretary,
chief accountant; Vladimir Maslennikov - financial advisor; Stanislav Matyukhin - general director of a company in the
QBF group; Ruslan Spinka - financial advisor; Dmitry Lepeshkin - financial advisor of the investment department;
Alexander Arzhaev - algorithmic trading; Nikolai Padalko - financial advisor; Pavel Vlasov - financial advisor; Maxim
Yudin - financial advisor, head of financial advisors. Kuranina Lyubov - receptionist; Marina Nikolaeva - receptionist;
Bogdanova Christina - financial advisor; Athanasiadou Linda - representative of the Cyprus branch; Apollon (name) -
representative of the Cyprus branch; Trishin Gleb - financial advisor, project manager; Berezka Andrey - financial
advisor; Gorobets Elena - director of various Companies within QBF Group;
(Vol. No. 274, pp. 76 - 80)
- The testimony of G.S. Trishin, given by him as a witness,

according to which, afer graduating from university in 2012, he started looking for a job by placing an advertisement
on the website "hh.ru", afer which he received a call from representatives of a brokerage organisation with the name
"QBF" and was invited for an interview at the office located at: Moscow, Presnenskaya Naberezhnaya, 8, p. 1. Afer the
interview, he entered into an employment contract and became an employee of QBF LLC in a minimum position,
possibly as a consultant, with a salary of approximately 15,000 to 20,000 roubles per month. The main activity of the
QBF group of companies was to attract clients for the sale of investment products and trust management of the
money invested by clients. He does not know how many employees there were in QBF LLC and what their positions
were. In his position as a consultant, he only scheduled other people's meetings with clients, and he knew nothing
about the content of the meetings. Around 2015, he took up the position of manager and was involved in marketing
and later took up the position of project manager. His direct supervisor was Roman Shpakov, as he (G.S. Trishin)
received all instructions personally from R. Shpakov. His (G.S. Trishin) duties as a project manager included: general
coordination of the activities of a particular project, namely gathering workers for meetings, inviting lawyers,
570
ensuring communication. In fact, he (G.S. Trishin) acted as an administrator of a particular project, but did not
manage or participate in any of the projects under development. R. Shpakov was the Chairman of the Board of
Directors of QBF Group and instructions from R.V. Shpakov could be received through various communication
channels, including personal meetings. Around February - March 2018, an initiative was voiced from Roman Shpakov
that the project team should move to a separate office for greater efficiency. Shpakov told him (G.S. Trishin) during
working meetings that it would be easiest to create a new legal entity to close the office lease issue as soon as
possible. The employees entrusted to him (G.S. Trishin) were IT specialists, but R.V. Shpakov presented him (G.S.
Trishin) to these employees as an outside manager. The companies that he (G.S. Trishin) was entrusted with for the
development of IT projects were DV Technologies LLC INN 7703442478 and Sintez LLC INN 7708270984. In these
companies he (G.S. Trishin) was the general director at the request of R. Shpakov, but he did not perform any
managerial functions and did not make organisational and administrative decisions. R. Shpakov explained that it was
necessary for him (G.S. Trishin) to be the general director of these organisations for the convenience of coordinating
and directing the activities of the organisations. He (G.S. Trishin) did not make all decisions, including financial
decisions in the above - mentioned companies, but signed various documents at the request of R. Shpakov, he did not
know the nature and essence of the documents signed by him (G.S. Trishin). He was brought documents with
bookmarks on the pages, where there were marks for signature and he signed without reading. He did not choose the
name, bank, form of activity, taxation regime of legal entities, nor did he deal with the preparation of documents,
registration, etc. On behalf of R. Shpakov, this was handled by the legal department. Accordingly, the Legal
Department prepared the documents and a meeting was scheduled at the notary's office. The lawyer went with him
(G.S. Trishin) to the notary for a few minutes to sign the documents. These circumstances relate to DV Technolodge
LLC, where he (Trishin G.S.) was the founder and general director, and to Sintez LLC, where he was only the general
director. He received the client bank account and gave it to QBF's accounting department. He did not track the
movement of funds in the account. The bank - client was linked to his work phone and he always sent SMS messages
to the accounting department, he did not manage the movement of funds on the account. He did not monitor how
much money was on the account, he did not control what payments were made. He received his wages at QBF LLC in
cash, mostly directly from Shpakov R. He did not sign the statements when receiving money. Shpakov R. could also
give the money to any employee and the latter would distribute the money among all of them, in the amount
specified by Shpakov R. Shpakov R. also gave cash money for the rent for LLC "DV Technolodge", sometimes on behalf
of Shpakov R. he (Trishin G.S.) deposited the money to the company's account, from where it was written off as rent
for the office premises. When the rent money was debited from the company's account, he (G.S. Trishin) received an
SMS - message with a digital code on his personal mobile phone, which he provided to the accounting department of
QBF LLC, mainly via mobile communication to the mobile phone number of the accountant Ekaterina Gramza. He did
not submit reports for the legal entity, did not go to any state bodies or to the website in order to control the activities
of the said legal entities. He (G.S. Trishin) did not employ or recruit workers. If it was necessary to sign a contract, he
(Trishin G.S.) performed this technical function without reading or checking the contract, as these functions were
performed by the employees of the Human Resources Department of QBF LLC. Since December 2018, they stopped
renting the office because the employees of DV Technologies LLC decided to proactively stop working for Shpakov R.
Afer that, Shpakov R. offered him (Trishin G.S.) to take up another project in Sintez LLC. At the same time, he was not
fired from the old legal entity, it remained in his name. In the spring of 2019, he (G.S. Trishin) started raising questions
about his dismissal from DV - Technologies, he told Shpakov about it, in the accounting department, HR, lawyers. In
fact, he was removed from this legal entity in August - September 2020. His official salary was approximately 40,000
rubles per month, but he received more in cash, exactly how much he does not remember. Sitnez LLC had 1 employee
- an IT specialist, and the company was supposed to be engaged in mining cryptocurrencies. As far as he understands,
the company bought equipment for mining. The equipment was not bought and selected by him, he signed the
relevant contract on the instructions of Shpakov R. He saw the equipment both at the time of delivery and aferwards.
Shpakov R. was informed that the equipment was missing, afer which he (Shpakov) explained that he would solve
the issue himself. Afer this incident, he (Trishin G.S.) realised that the company did not do anything, but he continued
to be registered in it and constantly asked to be excluded from it and dismissed. He (Trishin G.S.) worked in QBF LLC
from 2012 to mid - July 2021. He lef QBF LLC at his own request due to the delay in payment of wages, as well as the
negative reputation of this organisation, as he became aware from publicly available sources of the law enforcement
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authorities' inspections of the company's management. During the period of his (G.S. Trishin's) labour activity in QBF
LLC, many employees worked in the QB group of companies, some of them he remembers, namely: Lepeshkin Dmitry
- one of the managers in the real estate department; Munaev Zelimkhan - managing partner; Athanasiadou Linda -
international lawyer; Rossieva Evgenia - lawyer; Spinka Ruslan - one of the heads of the client relations department;
Padalko - manager; Orlov - one of the heads of IT projects; Amerov Rinat and Plitin - employees of the company, but
where they worked he does not know; Yulia Zaitseva and Korzh - worked with clients; Yudin - carried out operational
activities in the IT department; Matyukhin - general director of LLC "IK KBF"; Vlasov, Golubev, Shaban, Vozhzhov -
knows these employees, but does not remember where they worked; Kharina - employee with financial products;
Timokhin - worked in the back office of LLC "IK"; Pakhomov - managing manager; Fedorov M. S. - worked with clients;
Pakhomov - managing manager; Pakhomov - managing director of LLC "IK KBF".S. - worked with clients;
(Vol. No. 274, pp. 91 - 96)
- The testimony of S.A. Kharitonov, given by him as a witness,

according to which in approximately 2017 he found a job offer for a courier - registrar in publicly available sources of
information on the Internet. Afer his call on the advert, he (S.A. Kharitonov) was given an appointment for an
interview. The meeting took place in the Federal Tax Service No. 46 in Moscow, where he was met by an unfamiliar
woman who offered to become the founder and general director of a limited liability company for a monthly
remuneration of 10,000 roubles. According to the stranger, he would not have to participate in the company's
activities and would not have to make any organisational and administrative decisions. He agreed to become a
participant and general director of the Company on condition that afer the registration of the Company, he (S.A.
Kharitonov) would be removed from the position of general director and removed from the founders. He handed over
his documents to the Federal Tax Service (IFTS) - his passport, ID, INN, to register Vysota LLC INN 7734371675 in his
name, where he (Kharitonov S.A.) became a founder and general director afer the registration. He personally signed
the constituent and other documents for the registration of LLC "Vysota" at the Federal Tax Service, however, he did
not take them from the Federal Tax Service afer the registration, he may have issued a power of attorney in his own
name to another person who could represent his (Kharitonov S.A.) interests in the Federal Tax Service and other
organisations and receive documents on the basis of the power of attorney. Afer signing the documents at the
Federal Tax Service, the above - mentioned woman paid him 10,000 roubles in cash. Some time later, in the same year
2017, he was contacted by people he did not know, who asked him to come to the Moscow City Business Centre,
located on Presnenskaya Embankment in Moscow, to make changes to the constituent documents of Vysota LLC.
Upon his arrival at the above address, he was met by a woman he did not know, not the same woman he had
previously met at the Federal Tax Service No. 46. The woman accompanied him (S.A. Kharitonov) to the notary, which
was located in the Moscow City Business Centre, and there he signed the documents prepared in advance for him
(S.A. Kharitonov). He did not read the content of the signed documents and did not go into the details of the
documents. Afer that, the woman who met him (Kharitonov S.A.) paid him 10,000 roubles in cash. He did not sign for
the receipt of the money. It was explained to him at this meeting that the documents being signed concerned his (S.A.
Kharitonov) dismissal from the position of general director of Vysota LLC and his withdrawal from the founders. When
signing the documents, he did not see the person to whom he entrusted the management of the Company, as well as
other possible participants of the Company. He does not know the main type of activity of Vysota LLC, where the
settlement accounts are opened, the staff, the legal and actual addresses;
(Vol. No. 274, pp. 110 - 113)
572
- Testimony of Zherdeva E.S., given to her as a witness,
according to which she has incomplete secondary education, currently works as a salesperson at LLC "LTK". In 2013
she decided to move from Volgograd region to Moscow for permanent residence. She searched for a job in Moscow on
publicly available resources on the Internet and, finding suitable options, called the telephone number indicated in
the advert. One such offer was for a courier position, which she was interested in. When she called the phone number
indicated in the advertisement, she was invited to an interview at the Moscow City Business Centre, located in
Moscow on Presnenskaya Embankment Street, the number of the building she does not remember. There she (E.S.
Zherdeva) was met in the lobby of one of the buildings of the Moscow City Business Centre by a woman whose name
she no longer remembers. During the conversation, the woman explained to her (Zherdeva E.S.) that her job duties
would be to deliver documents to the Tax Service and in order for her (Zherdeva E.S.) to be an official representative
of this organisation, she (Zherdeva E.S.) needed to become a participant and general director of Ver - Mont LLC, TIN
7718304946. She (E.S. Zherdeva) agreed to become a participant and general director of LLC "Ver - Mont", afer which
the above - mentioned woman prepared the necessary documents related to LLC "Ver - Mont", and she (E.S.
Zherdeva) independently signed the documents. She does not know what kind of documents they were, she did not
read them, she signed on the pages that were presented to her. She (E.S. Zherdeva) agreed to the position of Director
General of LLC "Ver - Mont" on the condition that she would not participate in the financial and economic activities of
the company and would not make any decisions. She did not know the type of activity of Ver - Mont LLC, as well as the
staff, the location of the office and the bank institutions where the company's current accounts were opened.
Subsequently, she came to the Moscow City Business Centre several times to sign documents at the notary's office
and to receive documents for submission to the Tax Service. She does not remember which tax office she had to take
the documents to. She does not know what kind of documents they were. She does not remember the number of
trips to the Business Centre "Moscow - City", but she went there on a preliminary call from a representative of the
above - mentioned organisation. She worked in the above organisation for approximately one and a half years and
she (Zherdeva E.S.) was regularly paid remuneration for her work in the amount of 10,000 roubles per month, which
was transferred to her bank card. The money came from unknown individuals and legal entities. About a year and a
half later, she (E.S. Zherdeva) received another phone call informing her that she (E.S. Zherdeva) should be replaced
as general director of Ver - Mont LLC and removed from the founders. She was taken to a notary in the Moscow City
Business Centre and there she (E.S. Zherdeva) transferred her shares in the authorised capital to another woman.
Afer the above meeting, she (Zherdeva E.S.) did not carry out her previous activities with the functions of a courier in
Ver - Mont LLC;
(Vol. No. 274, pp. 130 - 133)
- Testimony of Syuksyumov M.M., given by him as a witness,

according to which he worked together with Shpakov Roman and Modin Nikolay as sales managers at Business
Wednesday Ltd. in 2009 - 2010. The main activity of Business Wednesday LLC was attracting investments to
international stock exchanges. Soon he decided to change the place of work and lef "Business Wednesday" Ltd. and
engaged in brokerage activities in the field of lending. Later, afer he (Syuksyumov M.M.) lef "Business Wednesday"
LLC, Shpakov R. and Modin N. changed jobs and established their own organisation in the field of stock trading. In the
course of communication with Shpakov R. in March 2011, they decided together to create an additional organisation
LLC "Qubi Credit" TIN 7703740234, where he (Syuksyumov M.M.) would be the founder and general director. He
(Syuksyumov M.M.) opened this organisation independently, for which he applied to the Federal Tax Service and
submitted the necessary documents, and also independently opened a current account for this organisation in the
credit institution JSC "Alfa - Bank". He did not issue a power of attorney for the management of this company to
anyone. The main purpose of the creation of LLC "Qubey Credit" was to attract clients in the credit sphere, namely
Shpakov R. was to provide potential clients who need borrowed money, and LLC "Qubey Credit" as a broker was to
find a suitable product (credit) for the client and receive a commission from this transaction. A girl helped with all
constituent documents and she was provided by Shpakov R. as a specialist to assist. To ensure the activity of LLC
573
"Qubey Credit" Shpakov R. provided him (Syuksyumov M.M.) with about 5 workers who were not employees of LLC
"Qubey Credit". He (Syuksyumov M.M.) does not know reliably who could pay the salaries of these workers. He trained
the workers in the basics of the brokerage market in the field of lending. The office of Qubey Credit LLC was located in
the premises rented by R. Shpakov in the Moscow City Business Centre, where Qubey Credit LLC was registered. About
2 months afer the establishment of Qubey Credit LLC, he (Syuksyumov M.M.) decided to stop further co - operation
with Shpakov R. due to the unprofitability of this business in this area, as a result of which he (Syuksyumov M.M.)
withdrew from the founders of the LLC.) withdrew from the founders of LLC "Qubey Credit", but resigned from the
position of the general director of LLC "Qubey Credit" approximately in 2016 - 2018. During the entire period of his
(Syuksyumov M.M.'s) tenure as general director of Qubey Credit LLC, the Company did not carry out any financial
operations and no documents were signed on behalf of Qubey Credit LLC. Vladimir Georgievich Frolov is not
personally known to him, but as far as he remembers, this citizen was a nominal director in one of Shpakov R. Munaev
Zelimkhan Visaitovich is not personally known to him, but a certain Zelimkhan once worked together with him
(Syuksyumov M.M.), Shpakov and Modin in Business Environment LLC as a manager;
(Vol. No. 274, pp. 148 - 151)
- Kozhevnikova T.N.'s Testimony given to her as a witness,

according to which in early 2019 she was approached by a woman named Natalia, whom she (Kozhevnikova T.N.) met
through mutual friends, who offered her (Kozhevnikova T.N.) to earn money by forming an organisation in her
(Kozhevnikova T.N.) name. As Natalia explained, she (Natalia) would be in charge of all management and
administration, as well as bookkeeping, and the organisation would be formally registered in her (Kozhevnikova T.N.)
name. In addition, Natalia convinced her that it was all legal and there was nothing criminal in it. She (Kozhevnikova
T.N.) was interested in this proposal because she needed money and there was nothing illegal, according to Natalia.
Natalia promised her (Kozhevnikova T.N.) a cash reward in the amount of 10,000 roubles for the registration of the
company and to pay her (Kozhevnikova T.N.) 10,000 roubles every month thereafer. He (T.N. Kozhevnikova) agreed to
Natalia's proposal. In early February 2019, Natalia called her and asked for her passport and TIN certificate to
formalise the organisation, afer which she (Kozhevnikova T.N.) sent Natalia the necessary documents. She (Natalia)
explained that she herself would prepare all the necessary documents to register the organisation. Around the
summer of 2019, Natalia called again and asked her (Kozhevnikova T.N.) for a copy of her (Kozhevnikova T.N.) labour
book, which she also sent to her via messenger. She (T.N. Kozhevnikova) received about 67,000 roubles for the
registration of LLC "776". These funds were transferred to her bank card opened in Sberbank of Russia PJSC.
Subsequently, she had nothing to do with the financial and economic activities, management of LLC "776". She does
not know who exactly managed this organisation. She also does not know how tax returns were submitted for this
organisation. She has no skills in managing organisations, conducting financial and economic activities of the
Companies. She has not signed any contracts on behalf of LLC "776". If any agreements were concluded on behalf of
LLC "776", it was without her participation and knowledge. She does not know the circumstances of the registration of
this company, she only provided Natalia with copies of the necessary documents. She knows Yaroslava Smirnova and
maintains friendly relations with her. She knows that Smirnova Y. permanently resides in Moscow;
(Vol. No. 274, pp. 160 - 164)
- Testimony of S.V. Goltyaev, given by him as a witness,

according to which since 2000 he has been engaged in legal activities - private practice. In the course of this activity he
got acquainted with the lawyer Kukhmazova Nargiz Nazimovna, from whom in 2019 he learnt that she (Kukhmazova
N.N.) bought a flat in the residential complex "Headliner", the developer of which was the Residential Complex
"Stolichny". From the words of N.N. Kukhmazova I learnt that on the territory of this residential complex there is a
574
building intended for its use afer commissioning as a preschool educational institution (pre - school general
education institution). N.N. Kukhmazova also explained that there was a conflict situation between the residents of
the Headliner Residential Complex and the developer, which consisted in the fact that the territory around the
preschool was enclosed by a fence and could not be used by the residents of the Residential Complex, although it was
their common shared property. N. Kukhmazova was a member of the initiative group of residents of the housing
complex, which negotiated with the developer to dismantle the fence in order to gain access to the territory of the
preschool for the residents of the housing complex. In the course of negotiations, the initiative group of residents
made a decision and reached an agreement with the developer to acquire ownership of the building in question in
order to change the purpose of the building and, accordingly, to remove the fence. For this purpose there was a need
to create an organisation that would acquire ownership of the building. N.N. Kukhmazova offered him to take the
position of director in this organisation, to which he agreed. 19.11.2019 the organisation Millhouse Invest LLC was
established with the authorised capital of 170,000,000 rubles, and its founders were the residents of the Headliner
Residential Complex: Chirukhina Anastasia Alexandrovna, owning a 0.59% share; Sinyagina Tatiana Vladimirovna,
owning a 1.18% share; Kukhmazova Nargiz Nazimovna, owning a 1.18% share; and Millhouse Invest LLC, owning a
nominal value of RUB 165,000,000, which is 97.05% of the Company's authorised capital. The legal address of
Millhouse Invest LLC is 3/15 Letnaya St., 3/01, office 3/01, Mytishchi, Moscow region. He (S.V. Goltyaev) has been the
General Director since the establishment of the Company and, accordingly, as the Director, he submitted the
necessary documents to the tax inspectorate for the registration of Millhouse Invest LLC, as well as to a credit
institution for the opening of a settlement account. There were no other employees in Millhouse Invest LLC, and only
he, as the sole employee and general director, received his salary. The amount of payment was the minimum wage
corresponding to the minimum wage in the Moscow region at that time. The general direction of activity was set by
the founders, and he, as director, performed organisational and administrative functions and carried out financial and
economic activities. Between the founders of the company and the developer of the Headliner Residential Complex,
an agreement was reached to conclude a contract of equity participation in the construction of the DPU building for
the purpose of its subsequent registration to the company Millhouse Invest LLC. In November 2019, he, as CEO on
behalf of Millhouse Invest LLC signed an agreement of participation in shared construction with Residential Quarter
City LLC represented by Yusupov R.T., according to which the only participant of shared construction of Millhouse
Invest LLC, afer obtaining a permit to put the object of shared construction into operation, should pay the price of the
contract and take ownership of the object of shared construction. According to the Contract, Millhouse Invest LLC was
to pay the full cost of the building, which amounted to RUB 200,000,000 by the deadline established by the Contract -
31.12.2020. According to the clauses of the Contract: 4.3.1. within 5 days from the date of state registration of the
contract 5 000 000 RUB should be transferred to the developer's account; 4.3.2. not later than 30.12.2019 - 25 000 000
RUB; 4.3.3. not later than 31.01.2020 - 25 000 000 RUB; 4.3.4. not later than 25.02.2020 - RUB 35,000,000; 4.3.5. not
later than 25.03.2020 - RUB 25,000,000; 4.3.6. not later than 25.04.2020 - RUB 25,000,000; 4.3.7. not later than
25.05.2020 - RUB 25,000,000; 4.3.8. not later than 30.06.2020 - RUB 35,000,000. The amount of money specified in
clause 4.3.1 shall be paid by the participant of the shared construction at its own expense in the form of settlements
under the letter of credit opened by the participant of the shared construction in Promsvyazbank Bank (PAO) not later
than 3 working days afer the signing of the Contract. Afer the conclusion of the contract, as part of its execution, the
Company transferred RUB 5,000,000 to the account of OOO Zhiloy Kvartal City; this amount was the result of the
Company's founders contributing their own funds. As originally envisaged, in the future the participants of Millhouse
Invest LLC would sell the Company's shares to other participants and use the proceeds from the sale of the shares to
pay the developer under the terms of the agreement. When Millhouse Invest LLC was formed, many residents of the
housing estate expressed a desire to become participants in the future, however, when the matter came to realisation,
there were none of those who really wanted to contribute money and become participants of the Company. The
founders looked for different opportunities to involve other organisations. In January 2020 the building of the
preschool was completed and commissioned in accordance with the current norms, afer which the relevant
certificate of registration of the building into the ownership of Millhouse Invest LLC was obtained. Meanwhile, the
dates of the next payments under the contract were approaching. One of the participants of Millhouse Invest LLC
found Indep Smart LLC under the leadership of Yuri Shaban, which became a founder of Millhouse Invest LLC. The
value of the share of OOO "Indep Smart" was calculated in accordance with the payment schedule, according to the
575
remaining debt to the developer, i.e. in the amount of 195,000,000 roubles. One of the conditions was the change of
the director of Millhouse Invest LLC, as a result of which the sale of the Company's share and the change of the
director took place simultaneously. During the change of director on 30.06.2020 he (S.V. Goltyaev) handed over the
documentation to the new director of Millhouse Invest LLC Ivanova Irina Nikolaevna, while the change of the general
director of the Company took place a little earlier. Information about Indep Smart LLC as a founder of Millhouse Invest
LLC was entered on 10.07.2020. Further, he knows the situation with Millhouse Invest LLC only from the words of N.
Kukhmazova. From Nargiz's words he (Goltyaev S.V.) knows that Shaban Y. has not contributed the full amount of
money, which he had to contribute, in this regard, the obligations to the developer under the equity participation
agreement were not fulfilled in time and not for the full amount of money. Shaban Y. went to multiple negotiations
with the Developer in order to postpone payments, and then disappeared altogether. Later it became known that he
(Shaban Y.) resold his share in Millhouse Invest LLC to another organisation with the word "Kyubi" in its name, the full
name of which he does not know;
(Vol. No. 275, pp. 6 - 10)
The testimony of N.N. given Kukhmazova, to her as a witness,

according to which her family owns a flat in the Headliner Residential Complex at the address: Moscow, Shmitovsky
Proezd 39, Bldg. 1, flat 244. Before moving in, she got acquainted with the future neighbours and discussed various
issues, including the issue of the unfinished kindergarten building located on the territory of the Headliner Residential
Complex. The kindergarten is surrounded by a high fence, is located in the yard of the house and occupies almost the
entire territory of the yard. In order to clarify the further development of the construction of the building, the
possibility of dismantling the fence and the use of the territory of the yard by all residents, appealed to the developer
and the owner of the LCD LLC "ZhKS" (Residential Quarter City). Representatives of the developer offered the
residents to buy the building from them (the developer) and operate it independently. This proposal interested her
and the residents of the building, afer which they began to look for those willing to implement the above idea by
creating on 19.11.2019 LLC "Milhaus Invest" INN 5029252176, which consisted of: Tatyana Vladimirovna Sinyagina,
who contributed the amount of 2,000,000 rubles to the authorised capital; Anastasia Alexandrovna Chirukhina, who
contributed the amount of 1,000,000 rubles to the authorised capital; she (N. N. Kukhmazova), who contributed the
amount of 2,000,000 rubles to the authorised capital. Sergey Vladimirovich Goltyaev was appointed director of the
Company by the general meeting of founders. Initially, more than 100 residents of the building were interested in
buying the kindergarten and were ready to contribute money. Subsequently, these residents refused to participate in
the purchase of the property, and the funds they (Sinyagina, Chirukhina, Kukhmazova) had invested were insufficient
for the implementation of the project. Violation of the payment schedule threatened to impose a fine. They
(Sinyagina, Chirukhina, Kukhmazova) decided to look for an investor who would be ready to invest in the
implementation of the project and would deal with the project itself and the documentation. One of the neighbours
suggested Shaban Yuri as an investor. Shaban Yuri agreed to finance the project and became a co - founder of
"Milhouse Invest" LLC INN 5029252176, having joined the founders of "Indep Smart" LLC INN 7735159230. OOO
"Indep Smart" provided OOO "Milhaus Invest" with a loan in the amount of RUB 195,000,000, and subsequently RUB
51,000,000 was offset against payment for the share in the authorised capital. OOO "Indep Smart" joined OOO
"Milhaus Invest" as a participant with a share of RUB 51,000,000. Yuri Shaban planned to create an investment fund
and transfer the building to the fund, subsequently selling the fund's units to third parties, including residents. The
commercial interest was in the natural appreciation of the building's value over time, with the development of
infrastructure and the realisation of the Big City project. On approximately 18.06.2020, Irina Nikolaevna Ivanova was
appointed director of Milhouse Invest LLC on the recommendation of Yuri Shaban. She does not know from what
sources Shaban Yuri contributed funds. Shaban Yuri was the director and sole participant of LLC "Indep Smart".
Milhouse Invest LLC was created with the sole purpose of purchasing the building (new construction) of the
kindergarten, finishing its internal premises, and putting it into operation;
576
(Vol. No. 275, pp. 27 - 30)
- Testimony of T.V. Sinyagina, given to her as a witness,

according to which in 2018 she and her husband purchased a flat in the under - construction housing estate
"Headliner" at the address: Moscow, Shmitovskiy proezd 39/2. Before moving in, she discussed with her future
neighbours the issue of an unfinished kindergarten building located on the territory of the Headliner Residential
Complex and surrounded by a high fence, which took up a lot of space in the yard and prevented any movement in
the yard. In order to find out the further development of the construction of the building, she and her neighbours
approached the developer of the housing estate - KortRos LLC, who offered them to buy out the building and
complete it themselves. This proposal interested her and her neighbours, and they began to look for those willing to
implement the above idea. On 19.11.2019, LLC "Milhouse Invest" INN 5029252176 was established, which consisted of:
she (T.V. Sinyagina), who contributed the amount of 2,000,000 roubles to the authorised capital; Anastasia
Alexandrovna Chirukhina, who contributed the amount of 1,000,000 roubles to the authorised capital; Nargiz
Nazievna Kukhmazova, who contributed the amount of 2,000,000 roubles to the authorised capital. What shares each
participant had, she (T.V. Sinyagina) no longer remembers. The director of the Company was Sergei, whose surname
she does not remember. Since there was not enough money invested to implement the project, they decided to look
for an investor who would be ready to invest in the implementation of the project and would deal with the project
itself and the documentation. One of the owners of the premises, namely Anna Shumskaya, suggested Shaban Yuri as
an investor and provided his contact details. Shaban Yuri agreed to finance the project and became a co - founder of
Milhaus Invest LLC INN 5029252176, having joined the founders of the company Indep Smart LLC INN 7735159230,
having contributed a share in the authorised capital in the amount of 51,000,000 roubles, as well as having
contributed a share in the authorised capital in the amount of 114,000,000 roubles, which belonged to the company
Milhaus Invest LLC. Afer the reorganisation of Milhaus Invest LLC on 20.07.2020, the shares were distributed in the
following order: Milhaus Invest LLC - 67.05 %, Indep Smart LLC - 30 %, Sinyagina Tatiana Vladimirovna - 1.18 %,
Kukhmazova Nargiz Nazievna - 1.18 %, Chirukhina Anastasia Aleksandrovna - 0.59 %. The total amount of the
authorised capital was RUB 170,000,000. This amount was intended for the purchase of an unfinished kindergarten
building located on the territory of the Headliner Residential Complex and its commissioning. Irina Nikolaevna
Ivanova was appointed director of Milhouse Invest LLC on the recommendation of Yuri Shaban. Milhouse Invest LLC
does not bring any profit and meetings on profit distribution, as well as other meetings of the board are not held. She
(T.V. Sinyagina) does not receive any money for her participation in Milhouse Invest LLC. Periodically Shaban Y.
reported on the activities of Milhaus Invest Ltd. At present, the kindergarten building located on the territory of the
Headliner Residential Complex is not completed and has not been put into operation. About September - October
2021 she (T.V. Sinyagina) learned from some documents related to the kindergarten building that the building has
been seized and that an organisation with the abbreviation "QB" in its name is related to this building. She does not
know the reason for the seizure. She, as a co - founder of Milhouse Invest LLC, did not give her consent to the
participation of the company with the name "QBi" in the activity of Milhouse Invest LLC. She does not know exactly
who made the decision, but assumes that this decision was made by Shaban Y. without notifying the co - founders of
Milhouse Invest LLC;
(Vol. No. 275, pp. 53 - 56)
577
- A. A. Chirukhina's testimony , given to her as a witness,
according to which in 2018 her father Chirukhin Alexander Sergeevich purchased a flat in the under - construction
housing estate "Headliner" at the address: Moscow, Shmitovsky proezd 39/1. Before moving into the flat, she began to
get acquainted with future neighbours and discuss issues related to the Headliner Residential Complex, including the
issue of an unfinished kindergarten building surrounded by a high fence, which prevented movement in the yard. In
order to clarify the further development of the construction of this building, the residents applied to LLC "KortRos",
the developer of the housing estate. The representatives of the Company offered the residents to buy out the building
and complete it on their own. This proposal interested her and her neighbours, the search for those willing to
implement the above idea began. On 19.11.2019 was established LLC "Milhouse Invest" INN 5029252176, which
consisted of: Chirukhina Anastasia Alexandrovna, who contributed the amount of the authorised capital in the
amount of 1 000 000 rubles; Sinyagina Tatiana Vladimirovna, who contributed the amount of the authorised capital in
the amount of 2 000 000 rubles; Kukhmazova Nargiz Nazievna, who contributed the amount of the authorised capital
in the amount of 2 000 000 rubles. The director of the company was Sergei, whose surname she does not remember.
Since the money they had invested was not enough to implement the project, he decided to look for an investor who
would be ready to invest in its implementation and would be engaged in the project itself and the documentation.
Anna Shumskaya suggested Shaban Yuri as an investor and provided his contact details. Subsequently, Shaban Y.
agreed to finance the project and became a co - founder of Milhaus Invest LLC INN 5029252176, having joined the
founders of the company Indep Smart LLC INN 7735159230, having contributed a share in the authorised capital in
the amount of 51,000,000 roubles, as well as a share in the authorised capital in the amount of 114,000,000 roubles,
which belonged to Milhaus Invest LLC. Afer the reorganisation of Milhaus Invest LLC on 20.07.2020, the shares were
distributed in the following order: Milhaus Invest LLC - 67.05 %, Indep Smart LLC - 30 %, Sinyagina Tatiana
Vladimirovna - 1.18 %, Kukhmazova Nargiz Nazievna - 1.18 %, Chirukhina Anastasia Aleksandrovna - 0.59 %. The total
amount of the authorised capital was 170,000,000 roubles and was intended for the purchase of an unfinished
kindergarten building located on the territory of the Headliner Residential Complex and its commissioning. On the
recommendation of Shaban Y., Irina Nikolaevna Ivanova was appointed director of Milhouse Invest LLC. Milhouse
Invest LLC does not bring any profit. There are no profit distribution meetings or other board meetings. She (A.A.
Chirukhina) does not receive any money for her participation in Milhouse Invest LLC. Periodically Shaban Y. reported
on the activities of Milhaus Invest Ltd. Currently, the kindergarten building located on the territory of the Headliner
Residential Complex is not completed and has not been put into operation;
(Vol. No. 275, pp. 58 - 61)
- I. N. Shpakova's Testimony given to her as a witness,

according to which she has been the founder and general director of 168 Kvartal LLC since 2016. The initiator of the
creation of this Company was her son Shpakov R.V. This organisation was created to carry out activities on
construction of residential buildings, in particular on the territory of Severodvinsk. The authorised capital is 10
thousand roubles. Since about January 2021, the general director and founder in this organisation was Valery
Pavlovich Feoktistov, to whom she (I.N. Shpakova) sold shares in the company and transferred the powers of the
general director. She does not remember how she met Mr Feoktistov. The office of 168 Kvartal LLC is located in
Moscow City next to the premises occupied by QBF Group. Since about 2019, she (I.N. Shpakova) has been the founder
and CEO of KP Queue 2 LLC, KP Queue 3 LLC, and KP Queue 4 LLC. She was the initiator of the creation of these
organisations. The authorised capitals of these organisations amounted to RUB 10 million each and were formed by
shares in PJSC CEF. These shares were given to her by her son R.V. Shpakov, where he (R.V. Shpakov) got them she
does not know. Since May 2021 she is not a founder in these organisations, the founder has changed, it became
578
Povalyukhin Maxim Andreyevich, who is her (Shpakova I.N.) acquaintance. She (I.N. Shpakova) offered M.A.
Povalyukhin to buy out the shares in the above - mentioned companies, and he (M.A. Povalyukhin) agreed. For this
purpose M.A. Povalyukhin paid 30 million roubles in cash, 10 million roubles for each organisation. She does not
remember exactly where the offices of the Companies are located, in Zelenograd in the Business Centre. The
accounting of LLC "168 Kvartal", LLC "KP Queue 2", LLC "KP Queue 3", LLC "KP Queue 4" was performed by Olesya
Tumilovich, Ekaterina Gramza, and since April 2021 the accounting of these organisations has been performed by Irina
Pakhomova. At present "KP Queue 2" Ltd. is building a 9 - storey building with approximately 200 flats at the address:
Severodvinsk, landmark Pobedy Ave. 15, the 4th floor is under construction. OOO "CP Queue 3" is building a 9 - storey
building, approximately 148 flats, at the address: Severodvinsk, landmark Pobedy Ave. 15, the 5th floor is under
construction. OOO "KP Queue 4" is building a 9 - storey building with approximately 200 flats at the address:
Severodvinsk, landmark Pobedy Ave. 15, the 1st floor is under construction. The house built by LLC "168 Kvartal"
consists of 9 floors, 3 entrances, 148 flats. The house is to be commissioned in December 2020. All flats in the house
were transferred to the shareholders under share participation agreements. About 40 flats were sold in the second
phase, about 20 flats are registered with R.V. Shpakov, but they have not been paid for. The remaining 20 flats were
paid for by individuals under share participation agreements with individuals obtaining mortgages in Severodvinsk
banks: "Sberbank, Rosselkhozbank, VTB. About 50 flats have been sold in the third stage, about 20 flats under share
participation agreements have not been paid for. The remaining 30 flats have been paid for by individuals under share
participation agreements with individuals obtaining mortgages in Severodvinsk banks. In the fourth stage about 40
flats have been sold, about 20 flats under share participation agreements have not been paid for. The remaining 20
flats have been paid for by individuals under share participation agreements with individuals obtaining mortgages in
Severodvinsk banks. LLC MC QBF under CDA purchased flats in favour of 29 individuals in the above houses under
construction. The houses were built by subcontractors, of which there are more than 20 organisations. The said
houses were and are being built with the funds of the shareholders under the CDA in accordance with 214 - FZ, the
Company did not obtain any loans for construction from banks. Initially, the construction of the above - mentioned
residential complex, approximately since 2016, was engaged in her son - Shpakov R.V. As a hired worker was engaged
her son's acquaintance - Onegin Alexander. In 2017 Onegin A. resigned. In this regard, she (Shpakova I.N.) offered to
help her son Shpakov R.V. and became engaged in construction. Since 2017, Shpakov R.V. has no relation to the above
organisations;
(Vol. No. 275, pp. 63 - 66)
- Testimony of V.F. Shpakov, given by him as a witness,

according to which from March 2009 to 28 March 2020 he worked at JSC PO Sevmash as a ship fitter. From 28 March
2020 he retired. From approximately August - September 2020 he is an individual entrepreneur and his commercial
activities are in the real estate sector. His business consists of assisting property developers in handing over flats to
shareholders and rectifying shareholders' comments on real estate properties. He (V.F. Shpakov) is not a participant,
director or employee of any organisations. At present his income is a pension of about 20,000 roubles, he has no other
income. He knows LLC "168 Kvartal" (Taxpayer Identification Number 7703769272). This company is the developer of
the housing estate "Pobeda Quarter", which includes residential buildings in Severodvinsk at the following addresses:
15 Pobeda Ave. Pobeda, 15, k.2; 15, k.2, Pobeda Ave. Pobedy, 15, k. 3; 15, k. 3; Pobedy Ave. 15, k.4. He (V.F. Shpakov),
as an individual entrepreneur, provided gratuitous assistance to the developer LLC "168 Kvartal" for the transfer of
flats to the shareholders at 15 Victory Ave. in Severodvinsk. In case of revealing any remarks from the shareholders he
(V.F. Shpakov) controlled the contracting organisations of OOO "168 Kvartal" to eliminate these remarks, and also
579
independently assisted in their elimination. He knows that the names "KP turn 2", "KP turn 3", "K11 turn 4" are used
to designate construction projects in Severodvinsk at the addresses 15, Pobedy Ave. Pobedy, 15, k. 3 and 15, k. 3,
Pobedy Ave. Pobedy, 15, k. 4 respectively. He does not provide assistance to the developer in the construction of these
objects. He owned immovable property located at the following address: 15 Victory Ave., Severodvinsk, flats: 6, 11, 15,
21, 21, 26, 35, 40, 74. He bought this property in about 2016 with his personal funds, which he had been saving
throughout his life. At the moment he does not remember to whom exactly these flats were sold. Payment for the
property was made in cash. He has not kept any documents of purchase and sale and transfer of funds. Immovable
property - non - residential premises located at the address: Severodvinsk, 15 Pobedy Ave. H1. and room. H2, was
purchased by him approximately in 2016 for personal funds, which he also saved during his labour activity. At the
moment he does not remember to whom exactly these premises were sold. The payment for this immovable property
was made in cash. He has not retained any documents of sale and transfer of funds. The above - mentioned facilities
and other real estate were sold to him for a total of 25,000,000 roubles;
(Vol. No. 275, pp. 73 - 76, 82 - 85)
- The testimony of V.P. Feoktistov, given by him as a witness,

according to which approximately in September 2020 he found an advertisement in the public domain for a job as
deputy general director of a limited liability company. This offer interested him and he contacted the representative of
the organisation, who appointed him (V.P. Feoktistov) a meeting in the business centre "Moscow City". In the course of
the telephone conversation he was informed about the necessity to bring his passport, snils, labour book, education
diploma and other documents. During a conversation with a representative of the organisation, who was a man, he
(V.P. Feoktistov) was offered the position of Deputy General Director of LLC "168 Kvartal" INN 7703769272 with a salary
of approximately 100,000 - 120,000 roubles per month. The main activity of the Company was the construction of
facilities for various purposes. Since he (V.P. Feoktistov) had experience in construction, he agreed to the offer and
provided all the necessary documents. Further, having signed all the documents he (V.P. Feoktistov) lef the building
of the business centre "Moscow - City", and the representative of the organisation explained that he (V.P. Feoktistov)
would be contacted soon. Some time later he (V.P. Feoktistov) received a phone call informing him that he had to
come to the MFC to obtain an electronic signature as the deputy general director of LLC "168 Quarter", as he (V.P.
Feoktistov) had already received an application for a signature. At the appointed time at the Balashikha central MFC
he received the electronic signature, the data of which he later gave to the same representative with whom he had
spoken earlier. Approximately in January - February 2021, he was again contacted by a representative of the
organisation regarding the activities of OOO 168 Kvartal and explained that he (V.P. Feoktistov) was planned to be
later appointed to the position of General Director of OOO 168 Kvartal. There was no talk that he (V.P. Feoktistov)
would be a founder of this organisation. He never signed any founding documents of OOO "168 Kvartal", as well as
any agreements and payment orders on behalf of OOO "168 Kvartal". No labour contract between him (V.P. Fioktistov)
and OOO "168 quarter" has been drawn up. At the moment he has revoked the electronic signature of OOO 168
Kvartal. He does not know whether 168 Quarter LLC had any financial and economic activities, in which banks
accounts were opened, the number of employees of the Company;
(Vol. No. 275, pp. 95 - 98)
- The testimony of A.V. Diordits, given by him as a witness,

according to which he has a secondary technical education, and previously worked in various positions that do not
require specialised education. He does not have any knowledge of dealer activities, brokerage activities, securities
management activities and activities of professional participants of the securities market. Around April 2020, during a
580
conversation with his acquaintance Roman Feoktistov, he (A.V. Diordits) told R. Fioktistov that he was experiencing
financial difficulties and would like to earn some money somewhere. Roman offered to help in this matter and gave
him (A.V. Diordits) Natalia's telephone number - 8 903 100 5133. During the conversation on the phone, Natalia offered
him (A.V. Diordits) to become a director of a limited liability company for a monetary reward. He had never been a
director or founder of a Limited Liability Company before, but the proposal interested him and he agreed to the deal
on condition that he would be paid 20,000 roubles a month for about one year. It was not explained to him what
specific type of activity the organisation he would be heading would be engaged in. He was not told that he would be
the founder of any organisation. Afer the meeting with Natalia, the LLC "KF Estate SPB" was registered in his (A.V.
Diordits) name with TIN 7840472851. Natalia subsequently accompanied him to various organisations to execute
documents in relation to LLC "KF Estate SPB", where he later became the director. All document signings took place in
the Moscow City business centre in Moscow at 8 Presnenskaya Embankment. There was also a notary there, where he
(A.V. Diordits) also signed documents. He does not know which documents he signed, as he did not read them. Later
he learnt that an electronic signature had been issued in his name in respect of LLC "KF Estate SPB", but he had never
used this signature. He never went to the Federal Tax Service to execute documents in respect of LLC KF Estate SPB
and never signed any documents at the Federal Tax Service. In BC "Moscow - City" Natalia introduced him to
Anastasia and Valeria, who later accompanied him (A.V. Diordits) in all actions related to LLC "KF Estate SPB". For the
entire period of his participation as the general director of LLC "KF Estate SPB", he was paid approximately 180,000 -
200,000 roubles as remuneration. He received the money both in cash and by transferring it to a bank card from
Roman Feoktistov or Valeria in the office of BC Moscow - City. Also, in August 2021, at Valeria's request, he signed an
agreement to buy back a leased BMW 3 - series car, which had previously been purchased by the Company from KF
Estate SPB LLC;
(Vol. No. 275, pp. 99 - 102)
- Zvarin E.N.'s testimony , given by him as a witness,

according to which in September 2018, in a conversation with his acquaintance Choporov Dmitriy, he told the latter
that he was currently experiencing financial difficulties and would like to earn some money. Choporov D. explained
that he could help in this matter and gave him (Zvarin E.N.) Eugenia's phone number - 8 985 173 4321. During a
telephone conversation with Evgenia, as Rossieva later learnt, the latter offered him (E.N. Zvarin) to become the
director and founder of a limited liability company for monetary remuneration. This proposal interested him and he
agreed to the deal on condition that he would be paid 15,000 roubles a month. It was explained to him that the
organisation was to deal with advertising. The meeting with Eugenia took place in the lobby of the Capital City
building of the Moscow City Centre, he did not go to any offices in the building, all negotiations with Eugenia took
place in the lobby of the building, except for one meeting, which took place at a notary in the same Moscow City
Centre. At the notary he (Zvarin E.N.) signed the founding documents, but whether he signed the power of attorney he
does not remember. On 13.09.2018 on his (Zvarin E.N.) name registered LLC "KF Estate SPB" TIN 7840472851. Rossieva
E. further accompanied him in signing founding and other documents in respect of LLC "KF Estate SPB", where he was
subsequently the director and founder. Before him (Zvarina E.N.), the founder of LLC "KF Estate SPB" was R.V.
Shpakov, who was also present at the notary's office when signing the documents. At Evgeniya's request, as the
general director of LLC "KF Estate SPB", he went to JSC "Alfa Bank" to provide signature samples. He never went to the
Federal Tax Service to execute documents in respect of LLC KF Estate SPB and did not sign any documents at the
Federal Tax Service. He was a nominal director and founder of LLC "KF Estate SPB" and did not make any decisions,
he did not sign financial and organisational documents on behalf of the director of LLC "KF Estate SPB". By prior
agreement with Rossieva E. in September 2018, he brought his wife Maria Alexandrovna Melnikova to Rossieva E., who
also agreed to become the nominal director of LLC Finbutik INN 7731610156 and LLC Format Construction INN
771401659163. On all matters relating to the organisations' activities, Melnikova M.A. contacted Rossieva Eugenia's
assistant Natalia, a woman of Asian appearance. At one of his meetings with Rossieva E. in 2019, he was introduced to
Natalia, who used the subscriber number 8 903 100 5133. Natalia provided him with documents for him to sign, which
were disposition documents for the issue of corporate bank cards from LLC KF Estate SPB for several persons. He (E.N.
Zvarin) refused to sign these documents because he was concerned about possible negative consequences of the
581
transaction. He informed Natalia that he did not wish to continue co - operation and asked to be removed from the
founders of LLC "KF Estate SPB" and removed from the position of director. He also asked to remove his wife
Melnikova M.A. from the position of director. Natalia replied that when they found a replacement for him (Zvarin E.N.),
they would remove him from the position. In August 2020 he learnt that he was no longer the director of LLC "KF
Estate SPB", the director was Diordits Alexander Veniaminovich, but he (Zvarin E.N.) did not sign any documents on
this fact. At the same time, he remained a founder of LLC "KF Estate SPB", which he informed Evgenia about and
asked to remove him from the founders of LLC "KF Estate SPB". E. Rossieva explained that they would soon remove
him (E.N. Zvarina) from the founders of LLC "KF Estate SPB", but this did not happen. During the entire period of his
participation in the position of general director and founder of LLC "KF Estate SPB", he was not paid any money that
had been promised earlier. He knows nothing about the activities of QBF and other organisations of the same name
and is not familiar with these organisations;
(Vol. No. 275, pp. 103 - 106)
- M.A. Tochilova's Testimony given to her as a witness,

according to which she does not have any knowledge of dealing activities, brokerage activities, securities
management activities and activities of professional participants of the securities market. Around September 2020, in
a conversation with her acquaintance Roman Feoktistov, she informed him that she was currently experiencing
financial difficulties and would like to earn some money. R. Feoktistov explained that he could help her (M.A.
Tochilova) in this matter and gave her the telephone number 8 903 100 5133, of which Natalia was a subscriber.
Having contacted Natalia on this telephone number, she (M.A. Tochilova) received an offer from Natalia to become a
director of a limited liability company for a monetary reward. This proposal interested her and she (M.A. Tochilova)
agreed to become the director of the company on condition that she would be paid 20,000 roubles per month for
approximately one year. It was not explained to her what specific type of activity this company would be engaged in.
In addition, she (M.A. Tochilova) was told that the organisation would have a zero balance sheet and would not carry
out any transactions. She was not told that she would be a founder of any organisation. Afer the meeting with
Natalia, on 17.09.2020 on her (Tochilova M.A.) name was registered LLC "Qubife Advisery" TIN 7703426941. She signed
a power of attorney on her own behalf in the Moscow - City shopping centre relating to the activities of Qubief
Advisery LLC, however, she does not remember the content of this power of attorney. She never went to the Federal
Tax Service to draw up documents in respect of LLC "Qubief Adviszeri" and did not sign any documents in the Federal
Tax Service. She (Tochilova M.A.) also learnt that an electronic signature was issued in her name, but she never used
this signature. All the activities related to the activities of QUBEEF Advisery LLC took place in the Moscow City
Business Centre, mainly in the lobby on the ground floor. For the entire period of her participation as general director,
she was paid approximately 60,000 to 80,000 roubles as remuneration. She (M.A. Tochilova) received the money in
cash or by transfer to a bank card from Roman Feoktistov. She does not know whether Qubief Advisery LLC had any
financial and economic activities and what the number of employees of the company was;
(Vol. No. 275, pp. 108 - 111)
V.V. Smirnova's Testimony given to her as a witness,

according to which she has a secondary education and is currently on an old - age pension. She does not have any
knowledge of dealer activities, brokerage activities, securities management activities and activities of professional
participants of the securities market. In 2018, she (Smirnova V.V.) was offered by her daughter Smirnova Yaroslava
Gennadyevna to earn money by becoming the general director of a limited liability company for monetary
remuneration. She (Smirnova V.V.) agreed to this deal on condition that she would be paid 10,000 - 15,000 roubles a
month for how long. It was explained to her (Smirnova V.V.) that the organisation should deal with real estate
582
transactions. Her daughter introduced her (V.V. Smirnova) to Natalia, whom she (V.V. Smirnova) met for the first time in
the Federation Tower in the Moscow City Centre. Natalia took her (V.V. Smirnova) to a notary, who was also in the
Moscow City Centre, where she (V.V. Smirnova) was given a number of documents to sign. She signed them, but she
does not know what documents they were, she did not read them. According to the verbal agreement with Natalia,
she (Smirnova V.V.) would become the director of RentInvest Ltd. for monetary remuneration in the amount of
approximately 10,000 - 15,000 rubles per month, but she would not make any organisational and administrative
decisions. Afer signing the documents, she lef the office of the organisation and subsequently, if necessary, when
she (Smirnova V.V.) received a call, she came to the building of the Moscow City Centre on Presnenskaya Embankment
in Moscow. She was also aware that the company she headed was controlled by the management of QBF LLC, which
was engaged in brokerage and securities operations. She (V.V. Smirnova) signed a power of attorney in her own name
at the notary's office, where she entrusted all her powers of the general director of RentInvest LLC to a man not known
to her, most likely with the surname Frolov. When signing the documents and the power of attorney at the notary's
office, she did not see the person to whom she entrusted the management of the company. All negotiations with
Natalia took place in the lobby of the building. She received money for her position as general director of RentInvest
LLC in the amount of approximately 10,000 - 15,000 roubles per month on a regular basis. These funds were handed
over to her by her daughter, Yaroslava Smirnova. She does not know who transferred the money to Yaroslava for her
(Smirnova V.V.). Shortly afer the registration of RentInvest LLC, she (Smirnova V.V.) was offered to become a founder
and general director of another company, also for monetary remuneration of approximately 10,000 - 15,000 rubles per
month. Afer the meeting with Natalia, LLC "702" TIN 7703474800 was registered in her (Smirnova V.V.) name on
19.04.2019. Natalia further accompanied her (Smirnova V.V.) in signing constituent and other documents in respect of
LLC "702", where she (Smirnova V.V.) was subsequently the director and founder. Afer signing the documents in
respect of LLC "702", she was introduced to Ekaterina Gramza, with whom she (V.V. Smirnova) visited PJSC "Sberbank"
and opened a current account there. She (V.V. Smirnova) gave all the information she (V.V. Smirnova) received at the
bank and passwords to Ekaterina Gramza. As in the case of RentInvest LLC, she signed a notarised power of attorney,
probably also for Frolov, under which she delegates to him all her powers as general director of 702 LLC. She also
received payment for her participation in LLC "702" from her daughter Smirnova Yaroslava. She never went to the
Federal Tax Service to execute documents in relation to LLC "702" and LLC "RentInvest" and did not sign any
documents at the Federal Tax Service. She was a nominal director of LLC "702" and LLC "RentInvest" and did not
make any decisions, did not sign financial and organisational and economic documents on behalf of the director of
LLC "702" and LLC "RentInvest". In approximately 2020, at Natalia's request, she came to the Moscow City Centre due
to the need to sign additional constituent documents in relation to LLC "702" in connection with the change of the
company's legal address. At one of the meetings with Natalia, she (V.V. Smirnova) asked to remove her (V.V. Smirnova)
from the position of the General Director of the Company, but to date she continues to be the General Director and
founder of LLC "702". She does not remember the exact amount of payments to her for the entire period of her
participation in the positions of general directors of OOO "702" and OOO "RentInvest". She did not sign for the receipt
of these funds in the statements;
(Vol. No. 275, pp. 117 - 121)
- Choporov D.A.'s testimony, given by him as a witness,

according to which in 1995 - 1996 he got acquainted with Epifantsev Mikhail Mikhailovich. Around 2018. Epifantsev
M.M. approached him (Choporov D.A.) with an offer to earn money, and since he (Choporov D.A.) was experiencing
financial difficulties, he agreed to Epifantsev M.M. Epifantsev M.M. introduced him to his colleague named Victoria,
who in turn introduced him (Choporov D.A.) to Rossieva Evgenia. Around 2018, he (D.A. Choporov), together with his
wife N.V. Kochetkova, travelled to Moscow City, to the ground floor of one of the skyscrapers, where they were met by
E. Rossieva and offered to register his wife as a nominal general director in various legal entities. Rossieva E. also
suggested that he (Choporov D.A.) look for acquaintances who could be trusted and who wanted to earn money in a
583
similar way - to register legal entities for themselves. He does not remember in which organisations he and his wife
were registered as general directors, liquidators or founders. For all the time of interaction with Rossiyeva E. he
(Choporov D.A.) brought to her 4 persons: Marichev Alexey Nikolaevich 21.12.1973, Zvarin Evgeny Nikolaevich
15.05.1981, Khripunov Maxim Mikhailovich 18.03.1982; his wife Kochetkova N.V. For the services rendered to Rossiyeva
E. on selection of the above mentioned citizens he received monetary remuneration in the amount of about 5 000
roubles for each of them. The money was handed to him personally in an envelope during his next visit to Moscow
City by Rossieva E. or her colleague, whom he recognised from the photograph provided as Burlakova N.S. He has
trusting relations with all the persons mentioned and knows with certainty that Marichev A.N., Zvarin E.N., Khripunov
M.M. and Kochetkova N.V. have never conducted financial and economic activities and do not do so. Afer about a year
of interaction with Rossieva E., his wife Kochetkova N.V. received a call from a colleague of Rossieva E. and asked to
send a scan - copy of her (Kochetkova N.V.) passport, allegedly for some transactions, but did not explain what kind.
This alarmed him and Kochetkova N.V. and they refused to provide their documents, also it prompted them to break
off any relations with Rossieva E. and her colleague. In the photograph of Yevgenia Anatolievna Rossieva provided to
him during the interrogation, he recognised Yevgenia Rossieva, with whom he had met and interacted on several
occasions in accordance with his testimony. In the second photograph of Natalya Sergeyevna Burlakova, provided to
him, he (D.A. Choporova) recognised the same colleague of Evgeniya Rossieva, who accompanied Evgeniya Rossieva
at all their meetings and called his wife N.V. Kochetkova with a request to provide documents;
(Vol. No. 275, pp. 122 - 125)
- The testimony of Kochetkova N.V., given to her as a witness,

according to which her husband Choporov D.A. worked as a courier in a commercial organisation, and as of July 2017
was employed in one of the shops of the chain "M.Video" on the position - "warehouse manager". In the summer of
2018, her husband offered her (Kochetkova N.V.) a way to earn money, in which she had to sign certain documents
necessary for the organisation of a legal entity. Dmitry explained to her that it was necessary to simply sign a number
of documents, the legal nature and content of which Choporov D.A. did not explain to her, and that would be the end
of her participation. According to Choporov D.A., she would not actually work, but would only receive money in the
amount of 10,000 roubles once a month. D.A. Choporov also explained that he had an acquaintance named Yevgenia
who could help with this easy income. Given her difficult financial situation, she (Kochetkova N.V.) decided to agree to
this way of earning money. In the summer of 2018, she and her husband Choporov D.A. came to the building at 8
Presnenskaya Embankment, Moscow, where she met with a notary and a girl who introduced herself as Evgenia
Rossieva. Eugenia explained to her that she (E. Rossieva) was a representative of the company and she (N.V.
Kochetkova) was offered to become the general director of the company. Also Rossieva E. explained that this
company needs a nominal general director to reduce the company's expenses, that in fact the organisational and
administrative functions assigned to her (Kochetkova N.V.) as the general director of the Limited Liability Company
she (Kochetkova N.V.) will not perform, financial and economic activities of the company and work with any
documentation will not actually carry out. For this registration as the general director of the company Rossieva E.
offered her (Kochetkova N.V.) monetary remuneration in the amount of 10 000 rubles monthly. During the
conversation she (Kochetkova N.V.) asked Rossieva E. about the legality of these actions, to which Rossieva E. assured
her (Kochetkova N.V.) that this procedure is completely legal and legitimate. Rossieva E. conducted the dialogue
convincingly and persistently. Having received her (Kochetkova N.V.) positive answer Eugenia provided a number of
documents for signature, which she (Kochetkova N.V.) signed, the legal nature and content of these documents
Rossieva E. did not explain to her, thus, in her opinion, Rossieva E. misled her (Kochetkova N.V.) about the legality of
these actions. Afer signing the documents she (Kochetkova N.V.) with her husband Choporov D.A. lef the building.
584
Subsequently, she (N.V. Kochetkova) did not sign any documentation on behalf of the General Director of QBF Advisor
LLC in the framework of attracting money from citizens under the pretext of investments. On the photograph
presented to her she (Kochetkova N.V.) recognised a girl who introduced herself to her as Rossieva Evgenia. From
Rossieva E., she (Kochetkova N.V.) received monthly money in the amount of 10,000 rubles on her (Kochetkova N.V.)
debit card. In August 2018, she (Kochetkova N.V.) received a call on her mobile number from a woman who introduced
herself as Burlakova Natalia Sergeevna and explained that it was necessary to send her (Burlakova N.S.) a photo of her
(Kochetkova N.V.) face together with her passport. To what she (Kochetkova N.V.) replied with a refusal. Further she
(Kochetkova N.V.) repeatedly contacted Burlakova N.S. and asked her (Kochetkova N.V.) to withdraw her (Kochetkova
N.V.) from the LLC "QBF Advisery" INN 7703426941, where she was listed as a general director as a result of previously
signed documents provided by Rossieva E. Burlakova N.S. rejected her (Kochetkova N.V.) requests in every possible
way and also refused to fulfil her (Kochetkova N.V.) demands to terminate her activity as the general director of LLC
"QBF Advisery". At the end of September Burlakova N.S. fulfilled her (Kochetkova N.V.) demands. In the photograph
presented to her for review, she (Kochetkova N.V.) recognises the girl who introduced herself as Burlakova Natalia
Sergeyevna;
(Vol. No. 275, pp. 128 - 131)
- D.E. Belov's testimony as a witness,

according to which he has a secondary education. Around September 2020, in a conversation with his acquaintance
Feoktistov, he (Belov D.E.) said that he (Belov D.E.) is currently experiencing financial difficulties and would like to
have additional income. Feoktistov R. explained that he (Belov D.E.) could help him (Belov D.E.) in this matter and
provided the telephone number 8 903 100 5133, to which Natalia was a subscriber. During the telephone conversation
Natalia offered him (D.E. Belov) to become a director of a limited liability company for a monetary reward. This
proposal interested him and he agreed to become a director of the Company. In order to do so, he had to sign a
number of documents and provide his personal documents. He agreed to this deal on the condition that he would be
paid 20,000 roubles a month for about 1.5 - 2 years. He was not told what specific type of activity the company would
be engaged in, he was told that the organisation would have a zero balance sheet and would not carry out any
transactions. He was not told that he would be a founder of any organisation. Afer the meeting with Natalia, OOO
"Severspetsstroy" TIN 7703769579 was registered in his name on 17.09.2020. Natalia further accompanied him (D.E.
Belov) to various organisations to draw up documents in relation to OOO Severspetsstroy, in which he was
subsequently the director. He also became aware that an electronic signature was issued in his name, but he never
used this signature and cancelled it around the summer of 2021. He signed a power of attorney on his own behalf in
the Moscow City Centre relating to the activities of OOO Severspetsstroy, but he does not remember the content of
this power of attorney. He never went to the Federal Tax Service to execute documents in relation to OOO
Severspetsstroy and did not sign any documents at the Federal Tax Service. By prior arrangement with Natalia, he
visited a credit institution - "Alfabank" or "Sberbank", he does not remember the address and exact name. At the bank
he (D.E. Belov) was waited for by a girl named Anna, who could work with Natalia. Anna provided him with documents
relating to the activities of OOO "Severspetsstroy", possibly for opening a current account, which he signed. Afer
signing the documents, he handed them over to Anna. All registration actions related to OOO Severspetsstroy took
place in the Moscow City Business Centre, mainly in the lobby on the ground floor, he went up to the third floor of the
Moscow City Business Centre at Natalia's request only once, possibly to sign a notarial power of attorney. He does not
know where and in which credit institutions OOO "Severspetsstroy" opened its settlement accounts. He also does not
know whether OOO Severspetsstroy had any financial and economic activities. He does not know whether OOO
Severspetsstroy had any employees. For the entire period of his participation in the position of general director of
OOO Severspetsstroy, he was paid approximately 60,000 - 80,000 roubles as remuneration. He received these funds in
cash or by transfer to a bank card from Feoktistov R. He has not received any money for his participation in the
management of OOO Severspetsstroy since about spring - summer 2021;
585
(Vol. No. 275, pp. 136 - 139)
O.V. Vasyukova's Testimony given to her as a witness,

according to which she has a secondary specialised education as a seamstress. For the last 13 years she has been
working as an accountant - cashier in JSC CB "Unistream", she does not have any economic education and experience
in managing legal entities. In October - November 2020, she received a call from her acquaintance Marina
Aleksandrovna Tochilova and offered her a job as a general director of a company, without mentioning the name of
the company. Tochilova M. explained to her (Vasyukova O.V.) that she (Vasyukova O.V.) did not need to actually
perform any activities in this position, but would be paid the minimum wage. According to Tochilova M.: "You don't
need to do anything". Tochilova M. also agreed to work nominally as a general director in one of the firms. She (O.V.
Vasyukova) gave her consent. About a week later she (O.V. Vasyukova) received a call on her mobile phone from
Roman Feoktistov, who verified her consent to be employed as a general director. Feoktistov R. also said that she
(Vasyukova O.V.) would be called later about her employment. About 4 - 5 days later, a woman called her from the
subscriber number 8 - 903 - 100 - 51 - 33, introduced herself as Natalia and suggested that she (O.V. Vasyukova) drive
to the Moscow City tower in Moscow. There Natalia met her (O.V. Vasyukova) and explained that she (O.V. Vasyukova)
was about to be employed as a general director of a construction company, the name of the company was not
mentioned. Regarding her concerns about the legality of these actions, Natalia explained that everything was legal.
From her (Natalia's) words, the company has just been established and during the year the company's activity is
monitored for profit. If there is no profit, the firm is closed afer a year. She does not know who will "monitor" the
company, she (O.V. Vasyukova) discussed with Natalia her (O.V. Vasyukova) employment for only 1 year. Natalia
suggested that she go to a notary and draw up a power of attorney on her (O.V. Vasyukova) behalf for employment, so
that in the future, when applying for employment with the company, her personal presence would not be required.
Before doing so, she (O.V. Vasyukova) provided Natalia with her passport, SNILS and TIN, from which she (Natalia)
made photocopies. In the premises of one of the towers of Moscow City, Natalia took her (O.V. Vasyukova) to a notary,
where a power of attorney was drawn up. She (O.V. Valyukova) read the power of attorney, but she does not remember
the contents, and Natalia paid for the notary's services in the amount of 15,000 roubles. About a week later, she (O.V.
Vasyukova) received another phone call from Natalia and explained that she needed to go to Alfa Bank to obtain an
electronic signature. She (O.V. Vasyukova) also travelled to the Moscow City Tower, where she was met by Natalia. She
(Natalia) explained the necessity of the trip to the bank and said that from now on she (O.V. Vasyukova) would be paid
a salary of 20,000 roubles per month. Afer that, Natalia handed some documents to a girl unknown to her (O.V.
Vasyukova) and she (O.V. Valyukova) was taken by car to the Alfa Bank office. There she signed some documents
concerning the authorisation of an electronic signature. Afer that she went home. She received her salary for the
whole 3 months in amounts of 20,000 roubles. Then the payments stopped. At her request, the money in an envelope
was given to Feoktistov and the latter to Belov, and Belov sent the money to her once in cash and twice transferred it
to her bank card. Later she learnt that she was registered as the general director of LLC "M1 Invest" INN7701367560.
She was a nominal manager in this company, she did not personally participate in the financial and economic
activities of the company, did not make any decisions on the company's activities and did not sign any documents;
(Vol. No. 275, pp. 140 - 143)
I.A. Polibin's Testimony given as a witness,

according to which he has a secondary education and does not have any knowledge of dealer and broker activities,
securities management activities, activities of professional participants of the securities market. In early 2019, he
learnt from his acquaintance Dmitry about the possibility of additional income. Dmitry gave him a phone number - 8
586
985 173 4321, the subscriber of which was Rossieva Evgenia. During the conversation, Rossieva E. offered him (Polibin
I.A.) to become the director and founder of a limited liability company. He agreed to become the director and founder
of the Company on condition that he would be paid 15,000 roubles for each organisation. In order to do so, he had to
sign a number of documents and provide his personal documents. It was also explained to him that the organisations
where he would be a founder and which he would head were operating in the field of stock trading and securities
trading. Rossieva E. introduced him to Natalia, using the subscriber number 8 903 100 5133, who later accompanied
him in drawing up documents in relation to K - Investment LLC INN 7703470098 and K - Consulting LLC INN
7703471373. He was subsequently a director and founder of these organisations. He provided his personal documents
to the building of the Moscow City business centre and signed the documents handed to him. The representative of
the organisation with whom he spoke explained that he (Polibin I.A.) would be contacted shortly. Further, at Natalia's
request, he made an electronic signature through the MFC. He did not use the electronic signature himself, as he
immediately passed the information on it to Natalia. He does not remember whether he signed any power of attorney
on his own behalf. He never went to the Federal Tax Service to draw up documents in relation to K - Investment LLC
and K - Consulting LLC and did not sign any documents there. From time to time, by prior arrangement, he saw
Natalia. She provided him with documents relating to the activities of K - Investment LLC and K - Consulting LLC,
which he signed, but he does not remember which documents were provided. He only remembers that there were
documents related to the employment and dismissal of employees of these organisations. Afer signing the
documents, he immediately gave them to Natalia. In addition, Natalia went with him to Sberbank in the Afimall
shopping centre to obtain a statement of accounts for K - Investment LLC and K - Consulting LLC. All of his activities
relating to the activities of K - Investment LLC and K - Consulting LLC took place in the Moscow City Business Centre,
mainly in the lobby on the ground floor. He went up to the upper floors of the Moscow City Business Centre at
Natalia's request only once, possibly to prepare the organisation's seal. There he was photographed and asked to sign
a signature identical to the one in his passport. The people who photographed him and whose documents he signed
on that day are unknown to him. He does not know whether K - Investment Ltd. and K - Consulting Ltd. conducted
financial and economic activities. He also does not know anything about the staff of K - Investment LLC and K -
Consulting LLC. Since October 2021, he started to receive notifications in his personal account on the website of
Gosuslugi that the mobile operator "Beeline" received information from "F - Experts" about the issuance to him
(Polibin I.A.) of a corporate SIM - card with a corporate SIM - card.) a corporate SIM card with the number +7 903 289
6806", as well as identical messages, but only in relation to K - Investment LLC with the numbers: 8 968 408 8205, 8 968
408 8220, 8 968 408 8214, 8 968 408 8210, 8 968 408 8206, 8 968 408 8223, 8 968 408 8203, 8 968 408 8207, 8 968 408
8217, 8 968 408 8208, 8 968 408 8221, 8 968 408 8219 и 8 968 408 8215. The above telephone numbers were never
used. Subsequently, he was never paid remuneration for his participation in K - Investment LLC and K - Consulting
LLC;
(Vol. No. 275, pp. 146 - 149)
A.A. Panov's Testimony given by him as a witness

, according to which he has a secondary technical education in the speciality "engineer developer of technological
lines for the manufacture of parts" and has no knowledge of dealer, brokerage activities, securities management
activities, activities of professional participants of the securities market. In August 2020, during a conversation with
his acquaintance Feoktistov Roman, he learnt about the possibility of additional income. He (Feoktistov R.) told him
(Panov A.A.) the phone number 8 903 100 5133, which belonged to Natalia, and she was to be contacted. During the
conversation, the latter offered him (A.A. Panov) to become a director of the Limited Liability Company for monetary
remuneration. He agreed to become the director of the Company on the condition that he would be paid 20,000
roubles a month for about one year and that he would not be the actual head of the organisation. He was to be the
nominal head of the Company, but he did not know who was to be the actual head of the organisation he headed. He
was also not told what specific type of activity the organisation he headed would be engaged in. He (A.A. Panov) had
587
to provide his personal documents and sign a number of documents. Afer a meeting with Natalia in the Moscow City
Centre, in September 2020, LLC "Qusisiai" was registered in his name with INN 7708786218. He does not know
Natalia's surname. Natalia further accompanied him in the execution of documents in relation to LLC "Kusisiai", where
he was subsequently the director. Natalia also introduced him to Anna, who has the subscriber number 8 903 289
7737, who also assisted him (Panov A.A.) in signing the necessary documents in relation to Kusiai LLC. All signatures of
the documents provided to him took place in the Moscow City business centre in Moscow, located at 8 Presnenskaya
Embankment. He does not remember the number of the building and the number of the office. There was also a
notary there, from whom he signed documents. He does not know what documents he signed, he did not read them.
In the course of the activities of Qusisiai LLC, at the request of Natalia and Anna, he issued an electronic signature in
his name, he never used the signature, and he gave all the data on it (the signature) to Natalia. He did not carry out
any financial and economic activities in Quesiai LLC and did not sign any financial and administrative documents. He
signed a notarised power of attorney on his own behalf in the Moscow City Centre relating to the activities of Qusiai
LLC. He does not remember the content of this power of attorney. He never went to the Federal Tax Service to execute
documents in relation to Kusiai LLC and did not sign any documents there. For the entire period of his nominal
participation in the position of general director of Qusiai LLC, he was paid approximately 180,000 roubles as
remuneration. He received these funds in cash from Anna or Natalia, or from Feoktistov R.;
(Vol. No. 275, pp. 150 - 153)
- I.A. Zotova's Testimony given to her as a witness,

according to which she has a specialised secondary education, worked as an accountant in various institutions, and
retired around 2016. She has a son Zotov Vladimir Aleksandrovich, who in 2013 established LLC "YurMaster" INN
7708786218. In this Company, her son offered her the position of general director. She agreed to her son's proposal,
but the company did not carry out any activities, she did not sign any contracts on behalf of the company. In 2018, her
son decided to sell YurMaster LLC for lack of use, as there had been no activity in the organisation for the entire period
of its existence;
(Vol. No. 275, pp. 154 - 157)
V.A. Zotov's Testimony given by him as a witness,

according to which he does not have any knowledge of dealer and broker activities, securities management activities,
activities of professional participants of the securities market. Around 2013, he established LLC "YurMaster" LLC, TIN
77008786218, in which he was also the general director. This Company was established to provide various legal
services. Afer the formation of YurMaster LLC, the Company did not actually conduct financial and economic
activities. Around 2018, at his suggestion, his mother Zotova Irina Anatolievna became the general director of
YurMaster LLC. This organisation at that time did not conduct financial and economic activities, his mother Zotova I.A.
did not draw up or sign contracts on behalf of the Company. Afer some time, he decided to sell the said company due
to the fact that it had not conducted any activity for a long time and there were no transactions on the accounts. He
does not remember who exactly was the buyer of YurMaster LLC, and he does not remember how he found the buyers.
He has not kept any information about the buyer. The whole transaction of sale and purchase of shares in the
Company was notarised and subject to mandatory registration. During the execution of the sale and purchase
transaction of YurMaster LLC and registration, the buyers decided to change the name of the Company, renaming it to
QC LLC. In addition, when changing the name of the Company, the buyers also changed the legal address of the
organisation, presumably this address could be the Moscow City Business Centre on Presnenskaya Embankment in
Moscow. He does not know what happened to the Company afer he (V.A. Zotov) lef it, and who is currently the
director and participants of QCIA Ltd. He also does not know what kind of activity QC - Siai LLC was and is engaged in;
588
(Vol. No. 275, pp. 158 - 160)
The testimony of Marichev A.N.,

given by him as a witness, according to which he met Choporov Dmitry during the period of time from 1988 to 1992,
while studying at the Moscow Electromechanical College. In the spring of 2016, he (A.N. Marichev) had a difficult
financial situation and needed additional income On the topic of additional income he repeatedly talked to Choporov
D. The same spring of 2016. Choporov D. sent him (Marichev A.N.) a message in messenger "WhatsApp" with contact
details of Rossieva Eugenia. He recorded Rossieva E.'s contact as follows: "Evgeniya Work Zits.", Rossiyeva E.'s
subscriber number: 8 985 173 43 - 21. Further, he (A.N. Marichev) contacted E. Rossieva and during the telephone
conversation she explained that she was a representative of the company and offered him (A.N. Marichev) to become
the general director of the Company. Also Rossieva E. explained that the Company needed a nominal general director
to reduce costs, that in fact he (Marichev A.N.) would not perform organisational and administrative functions, work
with any documentation. For this registration by the general director of the Company Rossieva E. offered him a
monetary reward in the amount of 15,000 rubles with a subsequent monthly payment of 15,000 rubles. During the
conversation, he (A.N. Maricheva) asked Rossieva E. about the legality of the actions offered to her, to which she
assured him that the procedure was completely legal and legitimate. Having received his (A.N. Marichev's) consent, E.
Rossieva offered to come to the notary office located near the metro station "Krasnoselskaya" to sign the relevant
documents and to send her the following documents: a photo of his pension insurance certificate (SNILS), a photo of
his passport of a citizen of the Russian Federation. During the conversation Rossieva E. also explained that he
(Marichev A.N.) would have to co - operate with Burlakova Natalia on all issues, and later she (Rossieva E.) sent him
the contact details of Burlakova N.. At the end of the telephone conversation, using the Whats Arr application, he sent
Rossieva E. a photo of the said documents. The contact details of Burlakova N. sent by Rossieva E. contained
information about the subscriber number: 8 903 100 51 - 33". A short time later, he called and then met Burlakova N.
at the notary's office near Krasnoselskaya metro station, where he signed the documents. He does not remember the
content of the documents. In spring 2017, he also visited a notary with Burlakova N., but already in the office located
at the address: Moscow, Presnenskaya Embankment, "Moscow City" complex, where in the presence of Burlakova N.
signed a number of documents, the content of which he also does not remember. He was regularly paid 15,000 rubles
for fictitious registration as the general director of LLC "QUSISIAI" INN 7708786218 since spring 2016. Initially, he
received the money on the settlement account of a Sberbank bank card issued in his name, and then exclusively in
cash at the office located at the address: Moscow, Presnenskaya Embankment, Moscow City complex. He cannot
explain the exact address, floor and number of the office premises. The money was handed over to him by different
persons, of whom he currently remembers only a girl named Olga. During the interrogation, he (A.N. Marichev)
provided his mobile device "ORRO" with images of contacts of Rossieva E., Burlakova N. and Choporov D., photos of
contacts attached to his testimony;
(Vol. No. 275, pp. 161 - 164)
- M.V. Leshchev's Testimony given by him as a witness,

according to which he has a secondary education. He was independently engaged in business, mainly in the sphere of
purchase and sale of land plots, construction and purchase and sale of real estate. Approximately in 2014 - 2015 he
received an agricultural land plot located in the village of Lipunikha, Mozhaisky district, Moscow region, which was
transferred to him as repayment of his (M.V. Leshchev) debts. He does not remember who exactly gave him the land
plot. The land plot was an asset of an organisation, presumably OOO Nizhnee, where he (M.V. Leshchev) could later
become a founder. He does not remember who was the founder and director of LLC Nizhnee. He (M.V. Leshchev) and
589
his partners put the land plot in question up for sale, but the condition was that the land plot should still remain an
asset of the Organisation, namely Nizhnee LLC. The transaction for the sale of the land plot was to take place on the
terms of the sale of shares in Nizhnee LLC with the transfer of the company's assets - an agricultural land plot in the
village of Lipunikha, Mozhaisky district, Moscow region. Approximately in 2015 he (M.V. Leshchev) was approached by
Dmitry Sergeevich Lepeshkin in the person of LLC Kyubi Finance, who wished to purchase the land plot on the terms
that he (D.S. Lepeshkin) was told - the purchase of shares in the organisation LLC Nizhnee with the land plot. The cost
of the land plot, taking into account the sale of shares in OOO Nizhneye, was approximately 2,000,000 - 6,000,000
roubles, he does not remember the exact amount. All issues related to the transaction were discussed directly with
Lepeshkin D.S. and eventually Lepeshkin D.S. independently purchased shares in Nizhnee LLC and the assets of the
organisation on behalf of Kyubi Finance LLC. In 2015 - 2016 he again met with Lepeshkin D.S. The meeting was
accidental. In the organisation Flat Market LLC, the main activity of which was the sale of real estate objects and was
constantly selecting real estate objects for sale, one of the employees of Flat Market LLC, whose name and surname
he no longer remembers, addressed him (Leshchev M.V.) with a proposal to consider an organisation that was
building a residential complex in Odintsovo, Moscow region, for cooperation. He does not remember the name of the
developer's organisation, but one of the representatives of the developer was Lepeshkin D. S. С. Afer negotiations on
possible co - operation of the enterprises, the contract was never concluded and he (M.V. Leshchev) did not see
Lepeshkin again on work issues, however he met D.S. Lepeshkin several times accidentally on the street. In addition,
he (Leshchev M.V.) has known Pavel Yurievich Vlasov since 2017. He met him at the project "Business Youth". With
Vlasov P.Y. he (Leshchev M.V.) found common interests and further decided to organise his own business on the
implementation of the project of construction of cottage village LLC "Yurievo". Apart from Vlasov P.Y. and him
(Leshchev M.V.), there were two other partners involved in this business, whose details he does not remember. Later
on, he lost interest in this line of business and withdrew from the founders of Yurievo LLC, while Vlasov P.Y. continued
to develop the business;
(Vol. No. 275, pp. 171 - 174)
- M.A. Melnikova's Testimony

given to her as a witness, according to which in October 2018 her husband Zvarin Evgeny Nikolayevich offered her
(Melnikova M.A.) to earn money by becoming the general director of a limited liability company for monetary
remuneration. It was necessary to provide her personal documents and sign a number of documents. For this deal
she was offered a payment of 10,000 roubles per month. It was explained to her (M.A. Melnikova) that the organisation
was to engage in clearing services. She was interested in the proposal and agreed to it. Her husband introduced her to
Natalia, with whom she (M.A. Melnikova) kept in touch by telephone at 8 903 100 51 - 33 and, if necessary, came to the
building of the Moscow City Centre on Presnenskaya Embankment in Moscow. The first meeting with Natalia took
place in October 2018 in the lobby of one of the Moscow City DC buildings. She (M.A. Melnikova) did not go to any
offices in the building, all negotiations with Natalia were held in the lobby of the building In the same DC "Moscow
City" there was a meeting at a notary, where she (M.A. Melnikova) signed the founding documents. On 15.11.2018 on
her (Melnikova M.A.) was registered LLC "Finbutik" TIN 7731610156, where she was further a director. Natalia further
accompanied her (Melnikova M.A.) in signing founding and other documents in relation to Finbutik LLC. She
(Melnikova M.A.) discussed with Natalia that she (Melnikova M.A.) would be a director in the same organisation,
however, in December 2021 she (Melnikova M.A.) became aware from publicly available sources of the Russian Federal
Tax Service that she (Melnikova M.A.) was also a director of LLC "Format Konstraksh" INN 771401659163. She assumes
that Natalia (M.A. Melnikova) could have provided her (M.A. Melnikova) with documents to sign in respect of the two
organisations. She (Melnikova M.A.) was a nominal director of Finbutik LLC and Format Konstraksh LLC, she
(Melnikova M.A.) did not make any decisions in the companies, she did not sign financial and organisational
documents on behalf of Finbutik LLC and Format Konstraksh LLC, and she does not have any information in relation
to these companies. During the entire period, she was never paid any money that was promised to her for the position
of general director of Finbutik LLC;
590
(Vol. No. 275, pp. 175 - 178)
- E.G. Sorokina's Testimony

given to her as a witness, according to which before 26 January 2020 her surname was "Lazarenko", at present it is
"Sorokina". From 2006 to 2016, she worked as a sales manager and assistant director of Geo Development LLC, whose
director was Leshchev Maxim Vadimovich. Her (E.G. Sorokina) duties included wholesale of land plots. In 2013, a
company, possibly named "Platina", paid for services under an agency agreement with a plot of agricultural land
measuring about 6 - 8 hectares. This plot of land was on the balance sheet of LLC Nizhnee, INN 7731610156, so as
payment for services, LLC Nizhnee also became the property of LLC Geo Development. Since the director decided to
realise the said plot, M.V. Leshchev appointed her as the general director and founder of Nizhnee LLC. Her
appointment as the head of the company had only one purpose - to sell the land plot to her. For about a year and a
half she was engaged in issues related to finding buyers for the land plot. The market value of the land plot at that
time was not more than RUB 800,000, as the plot was located in a swampy area. Before the summer of 2015, the land
plot together with Nizhneye LLC was sold to a new owner. Before the interrogation, she learnt from open sources that
Nizhneye LLC was renamed Finbutik LLC, in 2015. Nizhnee LLC with authorised capital and the land plot were
purchased by M4 Invest. Afer the sale of the Company and the land plot, in accordance with Russian law, she was
dismissed from the position of the general director of Nizhnee LLC no later than two weeks later;
(Vol. No. 275, pp. 180 - 182)
- Testimony of G.V. Suzdaltsev,

given by him as a witness, according to which he worked in various managerial positions in the field of agriculture.
Approximately in the period of 2013 - 2015, he held the position of executive director at the state farm located in the
Mozhaisky district of the village of Tsvetkovsky, central farmstead. Tsvetkovsky, the central farmstead. The state farm
belonged to CJSC Tsvetkovsky, which was part of the Rodnoye Pole Agro - Industrial Holding Company. The managers
and co - founders of the company changed from time to time. This holding included other organisations. In the
process of carrying out activities in this Company, he (G.V. Suzdaltsev) was summoned to the management of the Agro
- Industrial Holding "Rodnoe Pole" and asked to sign various documents, which could include founding documents,
where he could be a co - founder of various organisations related to agricultural activities. Before signing the
documents, the management told him about the essence of the documents he was signing, but he no longer
remembers all the details. He (G.V. Suzdaltseva) did not take any actual part in the activities of the companies in which
he could be a co - founder, and he did not receive any money from the activities of these companies. His participation
as a co - founder was required for some time, but for what purposes, he does not know. It is possible that one of these
companies was Nizhniye LLC, which could be the owner of agricultural land;
(Vol. No. 275, pp. 187 - 190)
591
- A.P. Cherdintseva's Testimony
given to her as a witness, according to which, in the period 2013 - 2014, less than one year, she was the General
Director of LLC MC "FTS" INN 7704835400 (Limited Liability Company Management Company "Fintrusti"). During the
said period, she worked at Financial Investment Centre LLC as a back office manager and as a back office manager at
MegaTrustOil LLC. At that time she already had 3 qualification certificates of series 1,4,5 of the Federal Financial
Markets Service. She does not remember who exactly offered her the position of the General Director of LLC MC FTS at
the moment due to the old age of the events. The founders of LLC MC "FTS", the previous and subsequent general
director she does not know, she has never met with him. She does not know the location of the office of LLC MC FTS.
The staff of this organisation consisted of only one person, her as general director and an accountant. Before her
dismissal, the FTS Management Company had no financial and economic activity, the company's balance sheet was
zero, and her salary was minimal, approximately 10,000 roubles. The documents on her appointment as the head of
LLC MC "FTS" were handled by a woman Lyubov Sergeevna (8 - 963 - 782 - 71 - 90) her last name she does not
remember. Lubov Sergeevna handed over the documents to her by courier about 4 times. Lyubov Sergeevna was an
employee of the company "Ver - Mont". She does not know what Ver - Mont has to do with LLC MC FTS. When she was
appointed head of LLC MC FTS, she hoped that the company would work and earn money. She was required to obtain
a licence as a professional participant of the securities market with the certificates she had. However, around May -
June she was dismissed from LLC MC FTS. The dismissal was on her initiative. She collected her labour book from
Lyubov Sergeyevna in the office of a former winery near the Kursk railway station in Moscow;
(Vol. No. 276, pp. 1 - 3)
- I.A. Bolshakova's Testimony

given to her as a witness, according to which, during the period 2012 - 2013, approximately six months, she was the
General Director of PJSC "Venture Finance Centre" INN 7734682254. During this period, she worked for LLC
"Management Company Centre" as a back office manager. The activities of Managing Company Centre LLC were
related to the purchase and sale of promissory notes. PJSC "Venture Finance Centre" was a newly established
company, the line of activity - investment projects. The founders of the company were RFG LLC (Russian Financial
Group) and Managing Company Centre LLC. She does not remember who exactly offered her the position of director
of PJSC Venture Finance Centre due to the long history of events. She was the only employee of the company, as far as
she remembers, the company did not carry out any activities. She was dismissed from the position of the director of
PJSC "Venture Finance Centre" in early 2013 due to the sale of the company. She does not know who exactly made the
decision to sell the company. PJSC "Venture Finance Centre" was acquired by the company "Zolotaya Milya" and non -
resident "Dormitor". As far as she knows, Golden Mile and non - resident Dormitor belonged to the QBF group of
companies;
(Vol. No. 276, pp. 19 - 21)
- A.S. Berezk's Testimony

as a witness, according to which, since 2017, he has been the General Director of LLC Rentinvest (Taxpayer
Identification Number 7703423933) and LLC Vysota (Taxpayer Identification Number 77343716754). These positions
were offered to him by Rossieva E., a lawyer of the company "QBF". He has known Pakhomov V. since he was 18 years
old and met him through a mutual acquaintance. He knew that Pakhomov V., worked in the company "QBF", where,
according to him (according to Pakhomov V.,) was one of the owners. He (A.S. Berezka) needed additional income and
asked Pakhomov V. about its availability. Rossieva Evgenia Rossieva, a lawyer of QBF, was in charge of preparing and
executing the documentation for his appointment to the above companies. With regard to LLC "Rentinvest" and LLC
"Vysota", he was informed that the activities of these companies were related to the lease of immovable property. At
592
the time of his appointment, both companies had zero balance sheets and no business activities. He was the only
employee in both companies. He did not give any powers of attorney to third parties in respect of these companies.
For Rentinvest LLC, an account was opened in Alfa Bank, to which only he had access. He did not receive any salaries
from Rentinvest LLC and Vysota LLC, as he indicated above that no activity was carried out in these companies. He
held the positions of general directors of LLC "Rentinvest" and LLC "Vysota" for about half a year in the first company
and about 1 year in the second company. In addition, on one occasion Rossieva E. asked him for access to the account
of LLC "Rentinvest", in connection with which he decided to give up the management of LLC "Rentinvest" and LLC
"Vysota". He voiced this decision to Rossieva E., and subsequently, on his initiative, he was removed from the
positions of general director of Rentinvest and Vysota LLC. He knows Roman Valeryevich Shpakov as the owner of the
company "QBF". He did not and does not maintain relations with him. When he was employed in LLC "Rentinvest" and
LLC "Vysota" he communicated with R. Shpakov regarding the activities of these companies. Irina Nikolayevna
Shpakova is familiar to him. He helped her with the registration of construction companies, of which he remembers
"KP Queue 1", "KP Queue 2", "KP Queue 3", "KP Queue 4". He knows that she was the director of these companies.
These companies were engaged in the construction of a residential complex in Severodvinsk. Munaev Zelimkhan
Visaitovich is familiar to him. What position and position in the company "QBF" he (Munaev Z.V.) held he does not
know. According to him, Munayev Z. was one of the founders of "QBF" company. He did not and does not maintain
relations with him. He helped him with the preparation of letters to Bank "Vostochny" regarding interaction with the
bank in the sale of products of the company "QBF". Stanislav Anatolievich Matyukhin was not known to him at that
time. He learnt about him from the media when he was detained. On 26.05.2022 Pakhomov V. came to the clinic of
LLC "Berezka" to provide medical assistance to a dentist. He learnt about his visit about 4 days before his arrival,
about which there was a preliminary record in the clinic. Pakhomov V. was at the doctor's office for about 10 - 15
minutes, he does not know the details of the disease and the amount of services rendered to Pakhomov V... He learnt
about the fact that Pakhomov V. had gone to the clinic from his wife Valeria in a messenger message received from
her. He decided to offer Pakhomov V. to sit in the clinic and communicate, as he had not seen him for a long time. For
this purpose, he personally bought alcohol and food products. Pakhomov V. agreed to his proposal, and therefore on
26.05.2022 at about the time from 15:30 to 19:15 the two of them together with Pakhomov V., in the back room of the
clinic drank alcohol and ate food products purchased by him (Berezka A.S.). They communicated on everyday
matters. Pakhomov V. did not tell him anything about his activity in the company "QBF", for the last six months it was
his only meeting with Pakhomov V. In the beginning of January 2021 he received a request from Pakhomov V. to find
out whether Shpakov R.V. had a travel ban in Vatsap. He did not find any bans. He also contacted his acquaintance
Mikhail Khabarov (+7 - 999 - 205 - 86 - 87), a security officer of one of the companies (he does not know the name of
the companies) to obtain this information. Khabarov M. with regard to Shpakov R.V. replied: "There are no bans yet".
He became aware of the fact that a criminal case had been initiated against R.V. Shpakov at that time during the
interrogation; he had not previously had this information. Earlier, V. Pakhomov repeatedly asked him to obtain
information on the existence of arrests on his property. He always looked for information in open sources. On a
regular basis, he also turned to Dima, nicknamed "Big" (8 - 964 - 780 - 56 - 69, 8 - 985 - 617 - 99 - 19) to obtain
information. For 2,500 rubles, Dima provided him with a voluminous certificate regarding Pakhomov V., with
information on his flights, records, fines, information on movable and immovable property, and registration actions.
Around the end of 2020 one day Munaev Z., called him and asked him if there were people from his social circle to
appoint them as managers of the companies. The condition was that the candidates had to be ill or of advanced age,
i.e. they had to die in the near future. He explained to Z.V. Munayev on this issue that he did not know of any such
candidates. Rossieva E. also addressed him with a similar request, to whom he responded in the same way as to
Munaeva Z. On the issue of assistance in the acquisition of companies, at the request of Rossieva E., in about 2018 -
2019, he searched the Internet for a company to be acquired by QBF. He found Yurmaster LLC and called the person
acting on behalf of this company, found out whether the company was indeed for sale and the price of the
transaction. Subsequently, he gave the contact details of the representative of Yurmaster LLC to Rossieva E. and never
touched the matter again;
(Vol. No. 276, pp. 74 - 78)
593
E.O. Mikheeva's Testimony
given to her as a witness, according to which she knows LLC DV Technolodges (Taxpayer Identification Number
7703442478). Her distant relative Ivlev Alexander offered her to become the General Director of LLC "DV
Technologies". As he explained to her, it was not necessary to manage the company, it was necessary to formally be a
manager there for about half a year. According to him, the company had a zero balance sheet. Afer half a year "DV
Technolodges" LLC was to be closed down. She agreed to Ivlev A.'s proposal. Subsequently, a girl named Natalia
invited her during a telephone conversation to an office located in the Federation Tower of Moscow City on Moscow's
Presnenskaya Embankment. She did not know which company owned the office. There were about 6 people in the
office, including a notary. She was given a package of documents in which she put her signatures. She does not know
the name of the documents, she did not familiarise herself with them. Afer signing the documents she lef. About 4
months later she was again invited to the Federation Tower in Moscow City to sign the documents. She was called and
met by another girl. The meeting was in a different office. She was signed the documents related to the electronic
signature. She agreed to be employed only as general director of DV Technolodges LLC; she became aware of the fact
that she was also the founder of DV Technolodges LLC during the interrogation. In the position of Director General,
she twice received a salary of 20,000 roubles each. When she was employed, the amount of her salary was agreed
upon. The first payment was on her first visit to the Federation Tower in Moscow City, where, afer completing the
paperwork, Natalia handed her 20,000 roubles in an envelope. The second payment was during her second visit when
she signed the electronic signature. Another girl, whose name she does not know, also handed her 20,000 roubles in
an envelope afer signing the documents. She did not sign any documents on receipt of the money. She fulfilled the
position of Director General of LLC "DV Technolodges" formally, did not perform any financial and economic activities,
did not sign any documents on behalf of the company. She does not know the number of employees of the company
and the type of its activities;
(Vol. No. 276, pp. 111 - 113)
- I.V. Levina's Testimony

given to her as a witness, according to which, in 2013 she was employed at QB Finance LLC as an accountant. She was
assisted in her employment by Tatyana Voronova, who at that time worked in the company as chief accountant. She
had known Tatyana Voronova since about 2000, she and her sister maintained friendly relations. At that time she
(Levina I.V.) was looking for a job with the possibility to work remotely and Voronova T. offered her the above position.
About once a year she was transferred from one company to another, but all of them belonged to the QBF group of
companies. Of the said companies, she remembers "F - Technologies". In IC QBF she worked as the head of the
personnel service, she executed the documentation on dismissal of the Company's employees. During the period of
her employment with the QBF Group of Companies, since 2013, due to the illness of her child, she worked
permanently remotely. The office of the group of companies was located in the Moscow City Tower in Moscow, but she
did not have a workplace there. She sometimes came to this office to print out accounting documents and deliver
them to the Pension Fund and Social Insurance. During this period she worked all the time as a salary accountant in
the ZUP (payroll and personnel management) programme. Her duties included the calculation of wages and other
payments to employees and the calculation of insurance contributions. She performed these activities for 17
companies belonging to the QBF group of companies. These companies were entered into the ZUP by employees
from the office and she calculated salaries for all companies that were in the database to which she had access, i.e. a
total of 17 companies). In 2017, at the company where she worked, she voiced that she needed additional income. At
that time, as the child had grown up, she already had the opportunity to work additionally, including in a full - time
format, outside the home. In the same year Voronova T. offered her the position of general director of the newly
established LLC "Rentinvest" (INN 7703423933). This company was established within the QBF group of companies.
The main type of activity is the rental and management of immovable objects. Voronova T., knew that she had
594
previously worked for 10 years in several companies in Moscow as a property agent and that this type of activity was
familiar to her. She agreed and came to the office located on the 13th floor of Moscow City in Moscow, where the
notary also arrived. The package of documents for the establishment of the Company was already ready and she
signed them. She did not check the documents, as she trusted Voronova T. completely and the time of the notary's
visit was limited (there was no opportunity to familiarise herself with the documents). She gave her consent only to
work as the General Director of OOO Rentinvest. She learnt about the fact that she was also the founder of this
company only from the police officers during the interrogation. She was the general director of LLC "Rentinvest" from
approximately March to October 2017. During this period, she did not conduct any financial and economic activities in
the company, she did not sign financial documents, and there were no employees in the company except her. During
these six months, she sent e - mails to Ekaterina Gramza's e - mail account and asked her to send me the balance
sheets of the company "Rentinvest". From her e - mail address she received balance sheets with zero indicators, which
she considered reliable, as she realised that Crow T. could control their reliability. She does not know whether these
reports were reliable. Around September - October 2017, Voronova T. was dismissed from the group of companies,
and she realised that she would not be able to control the reliable activity of Rentinvest LLC without Voronova,
besides, for six months the Company did not carry out any activity, she did not receive a salary, she decided to give up
the position of general director of Rentinvest LLC. In the autumn of 2017, she came to the office of QBF Group and
addressed Gramza E., and Shpakova E.N., who were there, with a request to relieve her of the position of the general
director of LLC "Rentinvest". About two or three weeks later, she was invited to the office of the QBF group of
companies in Moscow City, where in the legal department she was introduced to a guy named Berezka as the person
who would be the next general director of Rentinvest LLC. She then went with him to the neighbouring tower of
Moscow City to the office of a notary. The package of documents for OOO Rentinvest was already at the notary's office.
She and Berezka signed them there, the documents themselves remained at the notary's office. At present, she and
her sister are co - founders of LLC Stroykomplex Altair. The company was established in mid - 1990, and its activity is
related to the manufacture of metal structures. The head of the company was her mother. Since about 2006, the
company has not carried out economic activities and is not liquidated at the moment. In the course of her labour
activity she had to deal with the following employees: Frolov Vladimir Georgievich - she is not personally acquainted
with him, she has communicated with him several times by phone, she knows that he was a director in QB Finance
LLC, was a director in several companies belonging to the QBF group of companies; Pakhomov Vladimir Sergeevich -
for some time was a director of a branch in St. Petersburg, an employee in some companies of the QBF group of
companies; Pakhomov Vladimir Sergeevich - for some time was a director of a branch in St. Petersburg, an employee
in some companies of the QBF group of companies. Shpakov Roman Valerievich - she saw him in the office of the
companies, she did not communicate with him personally, according to the company, Shpakov R. was represented as
the most important and owner of the company, was represented as the most important and owner of the group of
companies "QBF"; Shpakova Irina Nikolaevna - mother of Shpakov R., when visiting the office, she was always in the
accounting department and it was understood that she managed the employees; Zelimkhan Visaitovich Munaev - she
did not know him, he was an employee of one of the companies; Stanislav Anatolievich Matyukhin - known to her as
the general director of LLC "IC QBF"; Evgenia Anatolievna Rossieva - a lawyer of the company; Elena Vyacheslavovna
Gorobets - was a director of several companies; Alexei Sergeevich Golubev - director of the branch in St. Petersburg
and then of the whole branch in St. Petersburg and then of the company. Golubev Alexey Sergeevich - director of the
St. Petersburg branch and then of the entire branch network. As she explained earlier, she worked remotely, she did
not visit the office ofen and only the accounting and human resources departments, so she does not know the
employees of the companies where she worked;
(Vol. No. 276, pp. 119 - 123)
- The testimony of Shaarani Sh.T., given by him as a witness,

according to which, he has a friend Polezhaev Andrey Vyacheslavovich, whom he knows for more than 20 years, the
circumstances of acquaintance he does not remember, they have been on friendly terms for a long time. In addition to
595
friendship, they are united by one sphere of activity - construction. In 2017 Polezhaev A.V. during their meeting, spoke
in raised tones on the phone, afer which he asked A.V. Polezhaev with whom he was in conflict, he (A.V. Polezhaev)
replied that in early 2012 he met through mutual friends with Vladimir Pakhomov, who is one of the managers of the
investment company LLC "Kyubi Finance" and who persuaded A. Polezhaev.V. to invest his free money in the business
project of this company, which consisted in brokerage activities on the international securities market. He (Shaharani
Sh.T.) asked A.V. Polezhaev what amount of money he contributed as an investment, to which A.V. Polezhaev told him
that in April 2012 he (A.V. Polezhaev) met with V.S. Pakhomov at the Hotel Ukraine, where A.V. Polezhaev handed over
to V.S. Pakhomov money in the amount of 600,000 US dollars for the purpose of receiving benefits, without signing
any documents. He simply handed the money over to Pakhomov personally; no one else was present at the meeting
and when the money was handed over, according to A.V. Polezhaev. V.S. Pakhomov did not give A.V. Polezhaev any
receipts for receiving the money. A.V. Polezhaev explained that when they handed over the money they did not agree
with Pakhomov that the money received from him would be invested in any particular project or the purchase of any
particular securities. The agreement between them was that Pakhomov V.S. would use A.V. Polezhaev's money, and
for the use of the money he would pay him monthly 3% interest in cash, as far as he (Shaarani Sh.T.) remembers A.V.
Polezhaev said that it was about $18,000 monthly. A.V. Polezhaev said that V.S. Pakhomov convinced him in every
possible way about the reliability of the investment, A.V. Polezhaev seemed to him to trust V.S. Pakhomov very much
and without concluding any agreements handed over the cash to him. Later he (Shaarani Sh.T.) learnt that Pakhomov
V.S. paid interest to A.V. Polezhaev. He was surprised by the fact that the entire transfer of funds took place without
any documentary evidence. Around September 2012, during their personal meeting with A.V. Polezhaev, he (A.V.
Polezhaev) said that V.S. Pakhomov asked A.V. Polezhaev if he (A.V. Polezhaev) had any more money to invest, to
which A.V. Polezhaev replied that he did. Further A.V. Polezhaev told that Pakhomov came to him (A.V. Polezhaev) to
work, conducted negotiations and persuaded him to invest money, explained to him (A.V. Polezhaev) that it was
necessary to increase the amount of investments in order to increase the monthly interest. Further he (Shaarani Sh.T.)
learnt from A.V. Polezhaev that in June 2012 A.V. Polezhaev concluded an agreement with some Cyprus investment
company and in February 2014 transferred funds from his current account opened in a foreign bank in Germany in the
amount of €1,050,000 to the current account. In August 2019, he (Shaarani Sh.T.) met with A.V. Polezhaev in Aviapark,
as far as he remembers they had a business meeting. During their conversation A.V. Polezhaev's mobile phone rang, at
that moment A.V. Polezhaev told him that his fellow countryman from the company that owed A.V. Polezhaev money
was allegedly calling, then he (Shaharani Sh.T.) suggested that A.V. Polezhaev, to talk to him, as his surname Munaev is
Chechen, he (Shaarani Sh. T.) picked up the mobile phone and entered into a dialogue in Chechen, during the
conversation Munaev explained that he was a Chechen from Grozny, he (Shaarani Sh. T.) offered to meet and have a
talk with him.Munayev told him that he was in the Moscow City business centre, and he (Shaharani Sh. T.) told him
that he was ready to come over. Then he and A.V. Polezhaev went to the "Moscow City" business centre, when they
arrived there A.V. Polezhaev called Munayev and asked about a specific meeting place, then he (Shaharani Sh.T.) got
out of the car, approached the veranda and saw a young man of Chechen appearance, tall, thin. They greeted each
other, chatted, found common acquaintances in the person of Salambek Munayev, Munayev explained that Salambek
was his relative, and he (Shaarani Sh.T.) in turn said that he knew him well. Munayev told him that he (Munayev) had
received a summons from the CJSC Department of Internal Affairs and he wanted to discuss the matter with Andrei.
Munaev explained that he did not participate in this transaction, did not negotiate with A.V. Polezhaev, to which he
(Shaharani Sh.T.) objected and showed him (Munaev) the payment order for the transfer of funds by A.V. Polezhaev to
the account of the Cyprus company where Munaev was the head. He (Munayev) said that he was not aware of this and
that he needed time to sort it out. He (Shaharani Sh.T.) told Munayev to organise a meeting with Pakhomov V.S., to
which he (Munayev) agreed. About two days later he (Shaarani S.T.) received a call from Munaev Zelimkhan and said
that today he could arrange a meeting between A.V. Polezhaev and V.S. Pakhomov, then he (Shaarani S.T.)
immediately called A.V. Polezhaev and told the latter to come to the Moscow City business centre. He (Shaarani Sh.T.)
met with Pakhomov V.S. and asked him what was the difficulty in returning the money to A.V. Polezhaev, to which
Pakhomov V.S. said that all the finances were managed by Shpakov Roman, who was the general director of Qubey
Finance LLC, and that all the money deposited by A.V. Polezhaev had been credited to the settlement account of
Qubey Finance LLC. At that moment A.V. Polezhaev was waiting in the car. He (Shaarani Sh.T.) informed Pakhomov V.S.
that it was necessary to inform Shpakov R.V. about the need to return the money, to which Pakhomov V.S. showed him
596
his mobile phone and Polezhaev A.V.'s messages about the requirement to return the money sent to Shpakov A.V.,
where he (Shaarani Sh.T.) saw that there were no responses from Shpakov R.V.. Then he called Polezhaev to come up
to them, afer which they talked, at which point he (Shaarani Sh.T.) stepped aside with Munayev. As it became known
to him later from A.V. Polezhaev the conversation led to nothing, Pakhomov V.S. insisted that all finances were
managed by Shpakov R.V. and he could not influence him in any way, Pakhomov V.S. explained that he informed
Shpakov R.V. that it was necessary to fulfil obligations, to which he (Shpakov R.V.) did not react in any way. Then he
(Shaarani Sh.T.) asked Munayev to organise their meeting with Shpakov R.V., to which Munayev responded positively.
He learned from Zelimkhan that Shpakov was avoiding meeting with him and A.V. Polezhaev. A week later he
(Shaarani Sh. T.) received a call from Munaev saying that Shpakov R.V. had received a summons from the Department
of Internal Affairs of ZAO and he had a desire to meet with him (Shaarani Sh. T.), through Zelimkhan.T.) to meet with
him (Shaarani Sh.), through Zelimkhan he learnt that Shpakov R.V. had asked to organise a meeting without A.V.
Polezhaev, He asked Andrei to wait in the car and went to the veranda near the business centre, where he met
Munayev and Shpakov, they started a dialogue with Shpakov R.V., Shpakov R.V. started to tell him why to interfere in
negotiations with law enforcement officers, to which he (Shaarani Sh.T.) said that he knew nothing about it, then
Shpakov R.V. started to refer to Pakhomov V.S., Shpakov R.V. allegedly was to blame for this situation, that he had not
conducted negotiations with A.V. Polezhaev correctly and that he (Shpakov R.V.) had no information about A.V.
Polezhaev. Shpakov R.V. referred to the fact that the company has a rule that an employee who attracts an investor
fully accompanies him in the future. Then Shpakov R.V. said that this was his employee and he would deal with him
himself, he also said something about the Peter branch of the company that he would send him there as a sign of
punishment. Munaev Zelimkhan told him (Shaarani Sh.T.) that his interest in solving this issue is that he was also sent
a summons from the Department of Internal Affairs of ZAO and he does not want to get into trouble with the law.
Further, at the end of August 2019, a meeting was held between him, Munaev Zelimkhan, Polezhaev, and Shpakov at
the Moscow City Cafe, Moscow, Presnenskaya Embankment, 8, pp. 1, at which the issue of returning money to A.V.
Polezhaev was discussed. Shpakov confirmed the existence of the debt of Qubey Finance LLC to A.V. Polezhaev,
Shpakov confirmed the receipt of USD 1,000,000 from A.V. Polezhaev. Shpakov agreed to return USD 875,000 to A.V.
Polezhaev with instalment payments for 3 years. A.V. Polezhaev agreed to these terms, and all the documents on the
arrangements were drawn up by Munaev, i.e. a notarised repayment agreement between Polezhaev and Pakhomov,
and Shpakov was to be the guarantor of the repayment. The agreement was never executed. At this meeting, a
decision was made between R.V. Shpakov and A.V. Polezhaev to return to A.V. Polezhaev the funds in the amount of
USD 200,000 for a period until 01 October 2019, until 01 November 2019 another USD 200,000. Starting from 01
December 2019, USD 15,000 each month for a total of USD 475,000. A.V. Polezhaev wrote a statement that he would
have no claims afer the above amount was transferred to him. Around October 2019, there were about 3 - 4 meetings
between him (Shaarani Sh.T.), Polezhaev, Shpakov, Munaev, during which Munaev handed him (Shaarani Sh.T.),
money, he accepted them, as Andrei was afraid of provocation from their side, at each meeting they handed over
about 50,000 USD, afer which Polezhaev A.V. in front of everyone wrote a receipt on receipt of money in ruble
equivalent. He (Shaharani Sh.T.) did not count the money in front of everyone, as he trusted Munayev. Before the New
Year he (Shaarani Sh.T.) went to Pskov, in December 2019 he received a call from an unknown number and introduced
himself as Aslambek Munayev, Zelimkhan Munayev's brother - in - law, asking what was the issue with Zelimkhan and
why he was summoned to the law enforcement agencies. He explained to him that he had an acquaintance Andrei
Polezhaev, to whom Qubey Finance LLC owed money, and Zelimkhan Munayev worked there. Aslambek said that he
had a conversation with R.V. Shpakov, who said that he did not owe any money to A.V. Polezhaev. Aslambek also
explained that he did not want his younger brother to take part in these disputes, and he was ready to become an
intermediary in these negotiations, to which he (Shaarani Sh.T.) did not object. He called R.V. Shpakov and he
confirmed that Aslambek would be involved in the negotiations. Then he (Shaarani Sh.T.) Aslambek said that he
would not mind receiving a reward for the support of the transaction in the amount of $200,000, this information he
gave to A.V. Polezhaev, to which the latter refused. Afer that he (Shaharani Sh.T.) called Shpakov R.V. and asked why
Aslambek demanded remuneration from Polezhaev A.V., Shpakov R.V. said that Aslambek was authorised to negotiate
with Polezhaev A.V. About two weeks later he met with Aslambek and they held negotiations, he was interested in the
position of Shpakov R.V., Aslambek said that R.V. Shpakov's position was to bribe certain persons and that it was
easier for him to give 50% of A.V. Polezhaev's debt to certain persons so that they would close the issue;
597
(Vol. No. 286, pp. 11 - 15)
Iskhakov E.V.'s testimony

, given by him as a witness, according to which from 19.10.2017 he worked at QBF IC LLC. His workplace was located
at the following address: Ekaterinburg, Boris Yeltsin St., 1 a - Business Centre "President", office 1204. His job duties
included consulting clients on the company's products, offering the company's products, consulting support on the
company's products. Stanislav Anatolyevich Matyukhin was the General Director of QBIF LLC. There is no head of the
office in Ekaterinburg, this position has been vacant for about 2 years. He is the deputy head and reports directly to
the General Director of QBIF LLC, Stanislav Anatolievich Matyukhin. He has no relation to financial and economic
activities. OOO IC QBF was engaged in consulting activities. According to the register, the company's main bank is JSC
Alfa Bank. In the course of its activities, the company entered into a trust management agreement with its clients (an
individual) on the Russian stock market. The company opened brokerage accounts on the Russian Stock Market for
individuals. The Central Bank of Russia monitored the activities of Qubi Finance LLC for compliance with the
legislation on the securities market. The procedure for entering into a trust management agreement between the
company and an individual was as follows: (the individual) provided documents (passport, personal bank account
details, contact telephone number, e - mail). Afer that he (E.V. Iskhakov) filled in a questionnaire for opening a trust
management (brokerage) agreement in the company's Nabix computer programme and sent it to the company's head
office in Moscow. Employees of the Company's head office in Moscow checked this questionnaire. Afer verification of
the agreement, the employees of the head office of the company in Moscow sent the draf agreement to the client by
e - mail. The company generated an electronic digital signature, which was provided to the client. If the client was
satisfied with the terms of the agreement, the trust management agreement signed by the company was sent to the
client by e - mail. The client, in turn, also signed the agreement with his personal electronic digital signature, which
was sent to the head office of the company. For the last 2 years or so, the trust management agreement was executed
electronically. About 2 years ago the trust management agreement was executed in the following way: the Client sent
the questionnaire by e - mail to the employee of the head office of the company in Moscow. Afer the approval of the
head office of the company and the client's consent to conclude a trust management agreement, the client received 2
original copies of the trust management agreement by mail or courier, signed by an employee of the head office in
Moscow, who is authorised to sign these agreements. He would give the client 2 copies of the agreement, which the
client would sign. The 1st copy was lef with the client, the 2nd copy of the trust management agreement was sent
back to the head office of the company in Moscow. Later on the client could consult him on his trust management
agreement and other products of the company. The company had the following products: trust management, mutual
funds, initial (public) placement of shares on the Russian stock exchange. The client received a quarterly (once in 3
months) report on the contract by e - mail, which was sent to the staff of the company's head office in Moscow.
Transfer of funds by an individual (client) under the trust management agreement was made in Russian roubles or US
dollars depending on the strategy of the trust management agreement. The return of funds under the trust
management agreement was made at the client's request to the client's current account. The application was sent by
the client to the company's e - mail. Return and procedure of return of funds is stipulated by the trust management
agreement (in case of full return - 15 working days, in case of partial return - 10 working days). The individual under
the trust management agreement has risks, the investment products of the company are not guaranteed, not insured.
The client bears the market risk and is warned about it. The trust management agreement explains to the client the
investment risks and profitability is not guaranteed;
(Vol. No. 286, pp. 33 - 39)
598
- Testimony of S.N. Loginov,
given by him as a witness, according to which, in the period from 2010 to 2020, he carried out labour activity in the
field of insurance of movable and immovable property of both individuals and legal entities. At present he is not
officially employed due to the liquidation of the company "GUTA - insurance" LLC, at the time of the liquidation of the
company he was one of the vice - presidents, this position was of a formal nature, as his actual activity consisted in
the direct insurance of property. He has a friend - Andrey Vyacheslavovich Polezhaev, whom he has known for more
than 10 years, he was one of his clients, to whom he insured property, namely: cars, buildings. He has been on friendly
terms with A.V. Polezhaev for a long time. He has a large number of acquaintances who operate in various spheres,
including banking and investment. About 2012 - 2013, during a personal conversation with A.V. Polezhaev, he became
interested in the topic of investing his money and asked him (S.N. Loginov) about the options of investing his own
savings in the international securities market and whether he (S. N. Loginov) had any acquaintances in this field.N.)
knew people in this field, to which he (Loginov S.N.) replied that he had acquaintances who represented investment
companies, due to the antiquity of events, he probably told A.V. Polezhaev about Qubey Finance LLC (hereinafer
referred to as the Company). A.V. Polezhaev further asked him for the mobile phone number of the representatives of
the Company. He gave him the mobile phone number of Vladimir Pakhomov, whom he had met under similar
circumstances as A.V. Polezhaev, i.e. in the course of his insurance activities; Pakhomov V.S. had also been his client
for some time. In the course of personal conversation Pakhomov V.S. told him about the nature of his activity, namely
that he (Pakhomov V.S.) is an employee of the investment company "Qubey Finance" LLC, which is engaged in
attracting funds of individuals and legal entities in the international securities market. Pakhomov V.S. is not his
comrade or friend, he knows him as his client. As far as he (S.N. Loginov) understood at that moment, A.V. Polezhaev
at that time had a certain capital in the form of cash and non - cash funds, which he wanted to invest somewhere in
order to get profit. He knows nothing about the circumstances of interaction between A.V. Polezhaev and Qubey
Finance LLC, as A.V. Polezhaev was a very secretive person who rarely told specific things about his life. His close
communication with A.V. Polezhaev stopped around the end of 2013, and then they began to communicate very
rarely, without any details. He (S.N. Loginov) is not a client of Qubey Finance LLC. Shpakov R.V. is not personally
known to him, in the course of his work activities, he became aware that he (Shpakov R.V.) is one of the managers of
Qubey Finance LLC;
(Vol. No. 286, pp. 24 - 27)
-D .V. Podoynikov's Testimony

given as a witness, according to which, since 2019, he has been the head of the 4th Department of the OEBiPK of the
Department of Internal Affairs for ZAO of the Main Department of the Ministry of Internal Affairs of Russia for Moscow.
His subordinate officers provide operational support for criminal case No. 12101007754000065, initiated by the SD of
the Ministry of Internal Affairs of Russia on the grounds of an offence under Part 4 of Article 159 of the Criminal Code
of the Russian Federation against unidentified persons. Earlier, the officers of the 4th Department of OEBiPK of the
Department of Internal Affairs for ZAO of the Main Department of the Ministry of Internal Affairs of Russia for Moscow
had the materials of verification on the applications of a number of citizens against unidentified persons from among
the employees of the Qubief group of companies. Thus, in the course of operational support, as well as on the basis of
an instruction from an investigator of the Investigative Department of the Ministry of Internal Affairs of Russia, which
he, by virtue of his official duties, wrote out to his subordinates, he became aware that the Qubief group of companies
included a large number of legal entities. The activity of these entities is connected with attracting personal funds of
citizens for the purpose of their further investment in stock markets. In the course of operational support it became
known that the actual beneficiaries of the QBIF group of companies are the following citizens: Roman Valeryevich
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Shpakov, Zelimkhan Visaitovich Munaev and Vladimir Sergeyevich Pakhomov. The main organiser is Shpakov R.V. To
implement his criminal intent aimed at embezzlement of citizens' money, Shpakov R.V. attracted a large staff to his
organisation, such as Munaev Zelimkhan Visaitovich, Pakhomov Vladimir Sergeevich, Rossieva Evgenia Anatolievna,
Matyukhin Stanislav Anatolievich, Athanasiadou Linda and others. R.V. Shpakov developed a criminal plan, according
to which they intended to systematically steal money belonging to citizens by means of deceit, consisting in the
deliberate reporting of knowingly false information that did not correspond to reality, in order to obtain criminal
income and distribute it among the members of the organised group, by concluding client agreements on behalf of
organisations under their control, acting under the guise of brokerage companies, for the provision of direct access to
international stock markets. The criminal plan developed by R.V. Shpakov together with Z.V. Munayev and V.S.
Pakhomov envisaged various stages of committing the crime, including: searching for the money necessary to ensure
the criminal activity of the criminal association (criminal organisation); searching for and attracting accomplices,
assigning them criminal roles in the organised group, as well as attracting persons unaware of the criminal intentions
of the criminal organisation. R.V. Shpakov was the organiser of the criminal group. Having determined the direction of
the activities of the organised group, R.V. Shpakov attracted Z.V. Munayev to participate in the organised criminal
group, who directed the participants of the organised group, determined the goals in the development of general
plans for the activities of the organised group, attracted co - conspirators to the organised group, sought legal entities
to carry out criminal activities, distributed the income obtained by criminal means among the participants of the
organised criminal group, based on the assigned role of each participant, as well as on his activities. The duties of E.A.
Rossieva, who is a co - conspirator of the organised criminal group, was responsible for legal support, which was
expressed in the search for legal entities registered both in the territory of the Russian Federation and in foreign
countries, necessary for the commission of the crime, change of nominal general directors in legal entities, including
QB Investment Company QBIF LLC, QB Investment Company QBIF LLC, QB Financial Group JSC, QB Finance LLC, QB
CAPITAL CY LTD. In addition, in the course of operational support the information on movable and immovable
property of the defendants, information on affiliated organisations, as well as information on open and closed
settlement accounts of the mentioned organisations was obtained. In addition, criminal case No. 12001450007000902
was under investigation by the Special Investigation Department of the Department of Internal Affairs of the ZAO
Department of the Ministry of Internal Affairs of Russia for the city of Moscow. As part of criminal case No.
12001450007000902, investigative actions were carried out in the course of which an IphoneX mobile phone was
seized from Z.V. Munayev. In the course of the examination with the participation of a specialist, correspondence in
the messenger "Whatsapp" was obtained, exposing the criminal intent of the defendants. The obtained information
was also attached to the materials of the criminal case;
(Vol. No. 260, pp. 1 - 5)
- D. A. Korshunov's testimony ,
given by him as a witness, according to which he has been registered with a narcological dispensary since 2021.
Approximately since 2001 he began to use strong narcotic substances, including heroin. On 02.07.2018 he entered a
rehabilitation centre for persons with drug addiction, in this centre he stayed for 11 months, until May 2019. About
two months before entering the rehabilitation centre, namely in May 2018, he (Korshunov D.A.) received an offer from
his acquaintance Dokuchaev Alexei (mail: [email protected]) about the possibility of additional income by providing
his (Korshunov D.A.) passport data as a guarantor. At that time he was not interested in the circumstances under
which he would act as a guarantor, as he was under the influence of narcotic substances. On 07 or 08 May 2018, he
together with Dokuchaev Alexey came to the address: Moscow, Nagatinskaya Street, 26 to the notary office, where
activities were carried out on behalf of the notary Natalia Nikolayevna Novikova, but the documents were certified by
a man temporarily acting as Novikova N.N. What documents were signed there by him (D.A. Korshunov), he does not
remember. Afer that Dokuchaev Alexei paid him 2,000 roubles and he (Korshunov D.A.) lef. About three weeks later,
he received an e - mail message from [email protected] about the completion of some procedure with
him to draw up documents for a fee of 22,000 roubles, as his acquaintance Alexei Dokuchaev was not in touch. He
(D.A. Korshunov) was able to read this message only afer leaving the rehabilitation centre, he did not reply to this
message. He has not heard the names of such organisations as LLC "VL - Consulting" (INN 7706463476), "WLM" (CR -
600
347210), "White Lake management" (SE - 330557), "Simtelligence", he has not heard of them, he has not worked in
them, he has not been a guarantor or trustee. He is not familiar with the QBF group of companies, he has not visited
the offices of these companies before, he has never conducted any negotiations on behalf of the above - mentioned
companies. In the copies of the documents "WLM" (CR - 347210), "White Lake management" (SE - 330557) presented
to him for review, the signature from his passport is shown in the signatory column on the side of the representative
of the companies, thus he believes that his passport data was used and the image of his signature was copied. He has
never received a foreign passport and has not applied to the migration authorities of the Ministry of Internal Affairs of
Russia. He has not visited the buildings of the Central Bank of Russia and has not communicated with a
representative;
(Vol. No. 260, pp. 6 - 8)
Christofi Michalakis' Testimony

as a witness, according to which he learnt and read about QBF - related incidents on the Internet, afer which he
immediately contacted the representative of the law enforcement authorities of the Russian Federation - operative
commissioner Renat Nagilevich Khalilullin, and expressed his desire to come for questioning and tell about the
circumstances known to him related to QBF. Thus, one of his accounting professionals introduced him to Apollon
Athanasiades in October 2016, who positioned himself as a broker for trade refinancing in the UK. On completion of
the funding project, Athanasiadou introduced him to his wife, Linda Athanasiadou/Kovalenko (Athanasiadou). During
the conversation they (the couple) claimed to be co - owners of Noa Circle LTD in Cyprus. The other partner was a
Russian organisation called QBF. The Athanasiadou couple stated that they had just completed a restructuring of the
QBF group of companies and were looking at expanding into Hong Kong SAR, China, and were primarily looking for
opportunities for trade between China and Russia and vice versa. The Athanasiadou family claimed that QBF Group
has been involved in several businesses in Russia and other CIS countries, with activities expanding from retail shops
and supermarkets to investment services, financial technology and natural resources trading. Athanasiadouis claimed
that the QBF Group controlled various supermarkets and retail chains (including Pyaterochka) with over 35,000 shops
in Russia, which was consistent with his (Christofi M.) company's strategic outlook and expansion plans. His main
business is the manufacturing and trading of electronics, home appliances, consumer goods and other consumer
products, and his business model is based on the idea of national retailing and distribution. Afer several meetings
and discussions, he realised that the beneficiaries of QBF were one Roman Shpakov and Zelimkhan Munayev. The
Athanasiadou couple, together with Dimitri Lepeshkin, as he (Christofi M.) understood at the time, had significant
power in the QBF group of companies and were responsible for all of QBF's operations outside of Russia.
Athanasiadou claimed that Noa Circle LTD and Aelius Circle LTD had many clients. He subsequently met accounting
and trust specialists in the UK and Hong Kong. During 2017, 2018, 2019 several meetings were held in Hong Kong,
Cyprus, UK, Cayman Islands and Armenia with Athanasiadou' spouses. In addition, he met several times with Dmitry
Lepeshkin in Hong Kong and Cyprus. He also met with Zelimkhan Munayev, several times during his two trips to Hong
Kong and once to Armenia. He never met with Roman Shpakov. Several projects were discussed, which included
import of electronics and household appliances from China to Russia, export of vodka and aluminium (ADC12) from
Russia to China and some other countries. For the said purposes, it acquired SIMTELLIGENCE COMPANY LIMITED,
registration number 1570903, on 02.05.2018, as a company licensed to export electronics, consumer goods from
China to Russia, with the possibility of tax refunds. In particular, the activities of the said company were initially
related to the purchase of electronics in China and selling them in Russia. He was the sole shareholder of the
company and its general director. The staff of the company consisted of two employees, him and the company
secretary, who was an acquaintance from Hong Kong. The company secretary did not perform any management
functions. SIMTELLIGENCE COMPANY LIMITED did not and could not carry out any brokerage activities as it did not
have the relevant licence. In addition, the company "WHITE LAKE MANAGEMENT LTD", registration number SE 330557,
was founded on 15.12.2017. The said company was initially registered in the Cayman Islands in the name of a local
lawyer, but subsequently on 10.01.2018 he (Christofi M.) became the sole proprietor. The purpose of this company
was to exchange and hold shares in various companies. At the same time, this exchange of shares was in no way
related to the acquisition of shares on various exchanges and stock markets. The need to exchange shares was due to
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the fact that he was working with factories in China with which an exchange of shares was required. At the same time,
there was the possibility of acquiring shares on the stock markets, but without reselling them. During the entire
period of activity of "SIMTELLIGENCE COMPANY LIMITED" and "WHITE LAKE MANAGEMENT LTD", they did not carry
out any brokerage, dealer activities, as well as any other activities related to the acquisition and sale of securities, as
there were no such purposes from the beginning. In this connection, SIMTELLIGENCE COMPANY LIMITED and WHITE
LAKE MANAGEMENT LTD did not obtain the relevant licences for investment, brokerage, depositary, dealer activities or
any other activities related to participation in the securities market for clients in accordance with the procedure
established by law. They have agreed to establish WHITE LAKE MANAGEMENT LTD in the Cayman Islands. Apollon
Athanasiades at the time insisted on using the Cayman Islands as his domicile jurisdiction on the grounds of being
away from home. Although he preferred to be in Hong Kong SAR or the UK as the jurisdiction in which he had worked
all his life. They also agreed that NOA Circle should do all the administrative, accounting and back office work for the
company as this was NOA Circle's speciality. The first real project was to supply consumer/lifestyle healthcare
products from their existing range to Apteki 36.6, which they (the couple) claim is QBF's business partner in Russia. In
February 2018, they (Christofi M.) Chinese company was authorised to import spirits and alcoholic beverages into
China and citizen Lepeshkin suggested several Russian vodka brands. In November 2018, afer sending an invitation
to QBF to attend the opening ceremony of its new joint venture in China, an aluminium hull and components plant,
Mr Shpakov offered to supply aluminium ingots directly from Rusal in Russia to their plant. In preparation for the
project, a special aluminium import permit and international import settlement quotes were obtained and approved
by the Guangdong provincial government, the provincial people's congress and the Chinese people's congress. In July
2019, the ingots arrived at their smelter afer four months of delays and disputes. However, despite competitive
pricing, it cancelled the project due to uncertainty. Operational and administrative complexities were secondary
concerns given the events described below. Several smaller projects were considered in 2018 and the first quarter of
2019. All of them failed as QBF was unable to fulfil the agreed terms and conditions. In October 2018, his (Christofi M.)
close friend was appointed to sell a financial/payment institution in Hong Kong. QBF expressed their interest. The
Athanasiadou couple travelled to Hong Kong for initial discussions, followed by Zelimkhan Munaev, he understood, to
finalise and conclude the transaction. Despite the agreements reached, QBF failed to fulfil any of the agreed
milestones and did not respond. In February 2019, his friend in charge of the sale advised him to stay away from all of
them. The friend also informed him (Christofi M.) of the existence of "VLM" and "SIM" restricted bank accounts of
which he was unaware. From March 2019 to June 2019, he had numerous lengthy arguments and disagreements with
the Athanasiadou spouses. In August 2019, while visiting the Cayman Islands for more information, he realised how
this would affect him, his family and his business. At that time he decided to draw the line and disassociate himself
from anything to do with QBF. He stepped down as a director and transferred all shares to the Athanasiadou couple.
Eventually giving up all his rights to future claims against the company and writing off all the money they owed him.
More than 750,000 euros were written off. Afer transferring the shares and writing off the debts, Athanasiadou' wife
tried to create many reputational, financial and personal problems for him. They wiped all his personal and business
data from his devices and servers. They tried to hold him hostage in his own home. They tried to demand more money
by claiming that third parties who lent to the company demanded their money. They tried to link him to fraudsters,
criminals and tried to damage his reputation not only to third parties but also to his friends and family. There were
several reports of fraud and other offences from him to the UK police. About the fact that the details of
"SIMTELLIGENCE COMPANY LIMITED" and EXEMPT COMPANY "WHITE LAKE MANAGEMENT LTD" were used to enter
into trust management agreements (contracts), agreements for the provision of services, the purpose of which was
the acquisition, storage of cash and securities, providing direct access to trading on stock and futures markets,
including but not limited to NYSE, NASDAO, AMEX, NYMEX, LSE, CME, CBOT, GLOBEX, CBOE, PSE, PHS and ISE, as well
as securities management with citizens of the Russian Federation, he does not know. He does not know Dmitry
Anatolievich Korshunov, he does not know any powers of attorney to represent the interests of SIMTELLIGENCE
COMPANY LIMITED and EXEMPT COMPANY WHITE LAKE MANAGEMENT LTD or to sign any documents on behalf of
these companies, including trust management agreements (contracts), agreements for the provision of services, he
has not issued. He believes that the data of the above companies were used by the above persons to carry out
fraudulent actions. During the interrogation he (Christofi M.) was presented with a response dated 09.09.2020,
received from the regulator of the Cayman Islands (CIMA), seized during the seizure in the Central Bank of Russia,
602
upon examination of this document he explained. According to this document, the company "WHITE LAKE
MANAGEMENT LTD" is a company within a group of companies that conducts the business of investing securities
exclusively for one or more companies, and, according to this response, the said company did not have licences to
carry out brokerage and other activities related to the purchase and sale of securities, the company could only
purchase securities for itself or for persons with whom he (Christofi M.) is personally acquainted. In the course of
interrogation he (Christofi M.) was presented for review agreements on provision of services between various citizens
of the Russian Federation and the company "SIMTELLIGENCE COMPANY LIMITED" represented by Korshunov D.A., as
well as agreements on provision of trust management services between various citizens of the Russian Federation
and the company "WHITE LAKE MANAGEMENT LTD" represented by Korshunov D.A., upon examination of these
documents he explained. He has seen these documents for the first time. How the money was raised on the basis of
these contracts (agreements), as well as how the raised money was spent, he does not know. He has nothing to do
with it. He opened 3 accounts for SIMTELLIGENCE COMPANY LIMITED, namely: 2 accounts in Hong Kong (DBS, Dahsing
banks), 1 account in Liechtenstein (Bendura bank). In addition, he applied in July 2019 to a small EQI bank (Bahamas
and Barbados) and an account was opened there around December 2019. He is also aware that other persons
(without his knowledge or involvement) have opened more accounts for SIMTELLIGENCE COMPANY LIMITED: 2
accounts in Vanuatu, accounts in Armenia (Ameria Bank), Kosovo, South Africa, Comoros, and possibly Turkey and
somewhere in the Balkans. Thus, some accounts were opened in blacklisted states. WHITE LAKE MANAGEMENT LTD
has, by him personally and with his involvement, opened accounts with the following organisations and countries:
Signature Bank, JP Morgan (USA), Global Fidelity Bank (Cayman Islands) - explained that this account was opened by
him, but he had access to it, Linda and Kirill Olezhko had access to it; (he knew that the company had funds in this
account), Deutsche Bank (Germany), EQI (Bahamas and Barbados), Santander Bank (Poland), Abanca (Portugal),
Clear Bank (UK), Bank of Lithuania, Igoria Bank - an electronic money bank; Ameria Bank (Armenia). When he
transferred the shares of "WHITE LAKE MANAGEMENT LTD", on his initiative the company's accounts in Germany, USA
(in JP Morgan Bank), in Poland, Portugal were closed. In addition, he knows that other persons (without his
knowledge and participation) opened accounts for "WHITE LAKE MANAGEMENT LTD" in Vanuatu in two banks - NBV
and ABB, in Clear Bank (at least 2 accounts, which he did not open); EQI (Bahamas and Barbados) - an account, which
he did not open; Valens Bank (assumes that in Germany). He is also aware of QB CAPITAL CY LTD, registered on 31
January 2008, registration number HE 221325, which Linda also told him about. However, Linda did not mention that
the above - mentioned organisation provides any brokerage services, saying that QB CAPITAL CY LTD provides
consulting services. He is also aware of the renaming of the said organisation to QCCI LTD. No funds were transferred
from the organisation QB CAPITAL CY LTD (QCCI LTD) to the accounts of WHITE LAKE MANAGEMENT LTD that he knew
of. At some period of time, Linda and Apollo requested him to open bank accounts for QCCI LTD. He contacted bankers
he knew about this issue and they explained to him that they would not open accounts for this organisation,
explaining that it was risky. In addition, he is aware that ARGENTO ACCESS SARL, registration number B 174.898,
including the issuance of bonds, is currently under investigation by the UK Financial Ombudsman in accordance with
one of his allegations against LPX and ARGENTO ACCESS SARL. He has learnt from the said Financial Ombudsman the
partial results of the interim interim judgement. In the course of the said investigation, a scheme to raise funds was
established which is structured under the issuance of corporate bonds on behalf of ARGENTO ACCESS SARL. The said
scheme consists of the following: ARGENTO ACCESS SARL issues corporate bonds and sells them subsequently at a set
price. These bonds are valid in accordance with the maturity date specified in the purchase and sale agreement
(memorandum of bond purchase). In the future, persons carrying out activities on behalf of ARGENTO ACCESS SARL,
as well as persons authorised by the management of ARGENTO ACCESS SARL to maintain bank accounts, do not
invest the received funds in the development of the company, but simply cash them out and appropriate them, at the
same time, these bonds are not secured by liquid assets and actually have no value. He is also aware that ARGENTO
ACCESS SARL uses this corporate bond scheme to launder money in Luxembourg, as Luxembourg banks accept funds
under lax rules, and uses the "grey areas" of Luxembourg law for its own benefit. In addition, under Luxembourg law,
there are no restrictions on the disposal by bond issuers of the cash received in the course of the realisation of these
bonds. At the same time, he is aware that ARGENTO ACCESS SARL has a corporate account with Societe Generale
where the proceeds from the sale of the bonds are received. ARGENTO ACCESS SARL was registered in 2013 and in
2014 the company was acquired by Phil Milo, Linda's friend and partner, who jointly organised the bond issue. In
603
addition, he learnt from his acquaintance that Linda had proposed to him (acquaintance Christofi M.) a criminal
scheme to embezzle investors' money, and, according to Linda, Apollo had successfully used it before. He also knows
Kirill Olezhko, who is Linda's confidant and who worked at NOA Circle and made fake contracts. Linda trusted him (K.
Olezhko) and provided him with access codes to the current accounts of the controlled organisations. Afer he sold
WHITE LAKE MANAGEMENT LTD in December 2019, Kirill Olezhko became its sole owner. The company
"SIMTELLIGENCE COMPANY LIMITED" was also sold free of charge (transferred) on 19.11.2019 to Apollo and Linda's
trustee Christophorou Andreas, who is a nominal manager. He is familiar with Andrei Berezka, with whom Linda was
in very frequent contact. It was he who arranged the aluminium deal he mentioned above. In her activities Linda has
always sought to attract rich and influential people to cover herself with their names and use them as advertising. All
of Linda's assets are in the UK and registered in the name of her mother, Ksenia Torres. The Falco and Purity funds
(which were actually managed by Linda) were positioned as developers of a cash investment algorithm. However,
afer he introduced Linda, who represented Purity (A.I. PURITY FUND AIF V.C.I.C. PLC, incorporated on 29 January
2020, registration number HE 4065230) to Deloitt, which is one of the developers of artificial intelligence, in order to
test the said algorithm for its effectiveness, no real working algorithms could be proposed by Linda, from which it can
be concluded that the scheme was also fraudulent initially. Assumes that the Falco fund (FALKO UMBREALL FUND AIF
V.C.I.C. - FALCO FUND, registration number 210N7940) was created to support A.I. PURITY FUND AIF V.C.I.C. PLC;
(Vol. No. 260, pp. 31 - 40)
- other documents - documents provided by Christofi M. during his examination as a witness, in support of his
testimony regarding the UK Financial Ombudsman's inspection of his (Christofi M.'s) application, which are
relevant to the criminal case; (Vol. No. 260, pp. 47 - 71, 77 - 101)
- - Protocol of seizure of 27 January 2022 from the witness Christofi Michalakis, during which files with scanned
documents in Google Drive cloud storage, relevant to the criminal case, were obtained; (Vol. No. 260, pp. 104
- 107)
- Protocol of examination of items dated 30 January 2022, namely a USB - Flash drive containing documents
provided by the witness Christofi Michalakis during the seizure on 27 January 2022, during which the
documents contained on the USB - Flash drive, which are relevant to the criminal case, were examined,
printed and attached to the materials of the criminal case; (Vol. No. 260, pp. 109 - 113)
- other documents documents provided by the witness Christofi Michalakis during the seizure on 27 January
2022, on the activities of "SIMTELLIGENCE COMPANY LIMITED", "WHITE LAKE MANAGEMENT LTD", including
registration, financial and economic activities, cash flow statements, as well as documents confirming the
testimony of Christofi Michalakis and relevant to the criminal case; (Vol. No. 260, l.d. 116 - 248, Vol. No. 261,
l.d. 1 - 250, Vol. No. 262, l.d. 1 - 248, vol. No. 263, pp. 1 - 245, vol. No. 264, pp. 1 - 249)
- - physical evidence - a USB - Flash drive in a green - coloured case, seized on 27.01.2022 during the seizure
from the witness Christofi Michalakis; (Vol. No. 260, pp. 114 - 115)
- A. V. Pshenichnikova's testimony
, given by her as a witness, according to which she has been employed by the Bank of Russia since December 2017, as
a chief expert of the ICI NFO for the Central Federal Financial Markets Centre of the SIDB, and has a certificate of the
Federal Financial Markets Service of the first series. During the interrogation, she was provided for review the interim
act of the audit of LLC Investment Company QBIF (INN 7733673955) No. A2N - I25 - 8 - 8 - 8/1275DSP (hereinafer
referred to as the interim act of the audit) and the final act of the audit of LLC Investment Company QBIF No. A1N - I25
- 8 - 6/1654DSP (hereinafer referred to as the final act of the audit). Afer familiarising herself with the said
documents, she explained that the interim act of inspection No. A2N - I25 - 8 - 8 - 8/1275DSP was drawn up based on
the results of the inspection of LLC "Investment Company "KyubeyEf", conducted in accordance with the order to
conduct an inspection dated 06.04.04.2021 No. PN - I25 - 8 - 4/717DSP, additions to the order to conduct an audit
dated 16.04.2021 No. DPN - I25 - 8 - 4/823DSP, dated 24.05.2021 No. DPN - I25 - 8 - 4/1135DSP, dated 31.05.2021 No.
DPN - I25 - 8 - 4/1227DSP. The final act of the inspection No. A1N - I25 - 8 - 6/1654DSP was drawn up on the basis of the
results of the inspection of LLC IC "Qubeef", conducted in accordance with the order to conduct the inspection dated
604
06.04.2021 No. PN - I25 - 8 - 4/717DSP, additions to the order to conduct the inspection dated 16.04.2021 № DPN - I25 -
8 - 4 - 4/823DSP, from 24.05.2021 № DPN - I25 - 8 - 4/1135DSP, from 31.05.2021 № DPN - I25 - 8 - 4/1227DSP, from
04.06.2021 № DPN - I25 - 8 - 4/1294DSP, from 08.06.2021 № DPN - I25 - 8 - 4/1339DSP, from 09.06.06.2021 № DPN - I25 -
8 - 4/1351DSP, from 15.06.2021 № DPN - I25 - 8 - 4/1405DSP, from 22.06.2021 № DPN - I25 - 8 - 4/1498DSP, from
28.06.2021 № DPN - I25 - 8 - 4/1566DSP, from 06.07.2021 № DPN - I25 - 8 - 4/1631DSP. The main persons responsible for
interaction with representatives of the Bank of Russia were the following persons: General Director of the Company -
Stanislav Anatolyevich Matyukhin, Deputy General Director - Controller Vladislava Georgievna Butkovskaya, these
persons were the main persons responsible for interaction with the working group. Also, the following persons
responsible for interaction on the part of the Company are reflected in the interim inspection report No. A2N - I25 - 8 -
8/1275DSP on the inspection of the activities of LLC Investment Company QBF: Anastasia Alekseevna Koval, holding
the position of Operations Director of LLC Investment Company QBiEf, Oleg Yuryevich Timokhin - Head of the
Department for Securities Market Professional Activity Support, Daria Yuryevna Filina, holding the position of Chief
Accountant of LLC Investment Company QBiEf, Aleksey Stanislavovich Stepanov, holding the position of System
Administrator, and Evgeny Sukhanov, holding the position of Specialist of the Information Technology Department.
The Bank of Russia employees involved in the preparation of interim audit No. A2N - I25 - 8 - 8/1275DSP were:
Asadullin Ayrat Rilevich, Mukhina Svetlana Anatolievna, Eremeyeva Nadezhda Aleksandrovna, Kharlamova Olga
Igorevna, Davydov Denis Romanovich, Rudakova Tatiana Vladimirovna. Denis Romanovich Davydov at the time of his
inclusion in the working group was the supervisor of LLC Investment Company QBF for supervision of the Company's
securities brokerage activities. Tatiana Vladimirovna Rudakova supervised the Company's depository activities, and
she (A.V. Pshenichnikova), as the head of the working group, before her the head of the audit was Natalia Alekseevna
Belova. Asadullin Airat Railievich Asadullin was the deputy head of the working group as of the date of signing of the
interim audit report No. A2N - I25 - 8 - 8/1275DSP. In accordance with the Bank of Russia Instruction No. 202 - I, the
working group sent registers of the working group's claims to LLC Investment Company QBIF during the audit, and
analysed the activities of LLC Investment Company QBIF on the basis of information from open sources and pre -
inspection preparation. The registers of requirements of the working group requested the internal regulatory
documents of QF Investment Company LLC, references and written explanations on the activities of QF Investment
Company LLC, internal accounting, bookkeeping data and other information necessary to achieve the objectives of
the audit. The full list of the registers of the working group's requirements, is placed in the passport of the inspection
of LLC Investment Company QBIF. The working group carried out the audit on the issues of the audit assignment. The
interim verification report No. A2H - I25 - 8 - 8/1275DSP and the final verification report No. A1H - I25 - 8 - 8 -
6/1654DSP contain references to the relevant information and explanations provided by the Company (Broker). The
deadlines for submission of information by QBIF Investment Company LLC were set in the registers of the working
group's claims. The Working Group requested a very large number of documents and information from QBIF LLC. The
working group, having studied the information provided on the registers of requirements of the working group, in
order to continue fulfilling the questions of the assignment, may request additional materials, information,
explanations from QBIF LLC, for the provision of which a new register (registers) of requirements of the working group
is prepared. In cases where the Company did not manage to provide the requested documents within the established
deadline for one reason or another, the Company sent a request to them to extend the deadline for providing the
documents. The working group examined OTC transactions in the interests of clients with option contracts - PFIs
(terms of conclusion, execution, settlement) for the period from 01.04.2019 to 30.06.2021. The mentioned issue was
considered, including by Eremeeva N.A. According to the interim audit act No. A2N - I25 - 8 - 8 - 8/1275DSP the
following was established. In the analysed period, LLC Investment Company QBF concluded transactions with
exchange - traded and OTC options. OTC option contracts were concluded in the interests of management founders,
as well as on behalf of clients under brokerage service. Information on the number of OTC option contracts and the
volume of invested funds broken down by underlying assets and time of contract conclusion is provided in Appendix
3.1 to the interim audit report No. A2N - I25 - 8 - 8/1275DSP. In accordance with the Company's internal accounting
data, OTC option contracts were concluded under the orders of the Company's clients (individuals and legal entities)
submitted on the basis of brokerage service agreements and counter - orders of QY.BROKER LLC, also sent by the
Company under the brokerage service agreement. The seller of OTC option contracts concluded in the analysed
period was QYU.BROKER LLC, the buyers were other clients of the Company. The Working Group analysed information
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on QYU.BROKER LLC, including information from open sources, constituent and other documents submitted to the
Company upon acceptance for servicing and further interaction, internal accounting. Based on the results of the
analysis, the following was established. Q-BROKER LLC was registered on 23.10.2019. The main type of activity
according to the Unified State Register of Legal Entities is provision of other financial services, except insurance and
pension services, not included in other groupings. Main type of activity in accordance with the Charter - making all
types of investments both in the Russian Federation and abroad, including by financing and managing commercial,
innovative and investment projects in various spheres of entrepreneurship and investments in securities, providing
consulting services in the field of investments, including by means of technical means and specialised sofware,
providing consulting services on financial intermediation. At registration the authorised capital of QB-BROKER LLC
amounted to 40 million rubles, the founder is JSC QB Financial Group, General Director Roman Valerievich Shpakov.
As of 01.04.2021 the authorised capital amounted to RUR 333 mln, manager Yuri Nikolayevich Orlov. According to the
information provided by QBIF Investment Company LLC, this company and QBU-BROKERLLC are related parties due
to the presence of a common founder and beneficiary. Also the representatives of QBIF LLC gave explanations during
the audit: 1) "QBIF LLC does not develop, offer and promote the product "IPO.XXX", therefore it does not notify the
clients regarding any issues related to the product "IPO.XXX", except for the notification of the general nature and
sources of conflict of interest, if such notification was not previously received by the client from the Company or from
other sources. The material terms and conditions developed by Q-BROKER LLC and contained in the Agreements on
General Terms and Conditions of Option Granting (Framework Agreements) concluded on the basis of clients'
instructions are unchangeable for all transactions concluded by clients on the basis of options granted in accordance
with the Agreements on General Terms and Conditions of Option Granting (Framework Agreement). The agreed terms
and conditions of these Specifications are specified by specifying the determinable terms and conditions of the
Specifications in Confirmations (the form of Confirmations is agreed in the Framework Agreements) when option
grant transactions are executed. The determinable conditions are determined by the clients without the Company's
participation and are contained in the clients' orders received by the Company. The Company has no information on
the procedure for the Company's clients to determine the terms and conditions of the specifications of the option
contracts of the Structured Product "IPO.XXX" in order to acquire them from Q-BROKER LLC; 2) "...QBF Investment
Company LLC does not have at its disposal any documents regulating the development of the product, offering the
product to clients, as well as other processes related to the creation, promotion and offering of the Structured
Product "IPO.XXX" to clients. The Company enters into transactions related to the product "IPO.XXX" in accordance
with the terms and conditions of the clients' orders". These explanations were provided in writing in response to the
working group's register of demands. The process of entering into OTC option contracts (hereinafer referred to as
OTC) and cash flows in accordance with these contracts entered into between the clients of QBIF Investment
Company LLC and QBU-BROKERLLC under which orders were submitted for execution of transactions with PFIs,
including options, are presented in Appendix 3.3 to the interim audit report No. A2H - I25 - 8 - 8/1275DSP. According to
the interim audit report No. A2N - I25 - 8 - 8 - 8/1275DSP, at the time of the audit the working group identified the
following two schemes. Under the first scheme, the interaction was as follows. 1) Receipt by the Broker of counter -
orders from QY.BROKER LLC and other clients to conclude an Agreement on General Terms and Conditions for
granting options to conclude contracts (framework agreement) with a view to conclude in the future OTC derivative
transactions, namely OTC option contracts (structural product "Product Name") on the terms and conditions attached
to the order. 2) Conclusion of an agreement on general terms and conditions of granting options contracts
(Framework Agreement) on behalf and at the expense of QYU.BROKER LLC (as a seller) and QBIF Investment Company
LLC on behalf and at the expense of the client (as a buyer). 3) Receipt by the Broker of counter orders from
QYU.BROKER LLC and other clients for execution of a futures transaction (structured product) on the terms and
conditions according to the annex to the orders (specifying the direction "for sale/purchase" and the Broker's role in
the transaction "acting on its own behalf and at the expense of the Client/acting on behalf and at the expense of the
Client"). 4) Conclusion of an OTC option agreement (irrevocable offer) on behalf and at the expense of QYU.BROKER
LLC (as a seller) and QBIF Investment Company LLC on behalf and at the expense of the Client (as a buyer), according
to which the seller undertakes to pay a lump sum of money stipulated in the agreement depending on the change in
the price of the underlying asset, and the buyer undertakes to pay an option premium upon the buyer's request. The
full terms and conditions of the contract and the calculation of the monies to be paid by the parties are set out in the
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specification of the structured product. 5) In accordance with the rights and obligations represented by the brokerage
service contracts and agreements, QBIF Investment Company LLC settles and accounts for the amounts of security
deposit balances under OTC option contracts. Under the second scheme, the interaction was carried out as follows. 1)
Receipt by the Broker of counter orders from QU.BROKER LLC and other clients for execution of a futures transaction
(structured product) on the terms and conditions according to the annex to the orders (specifying the direction "for
sale/purchase" and the Broker's role in the transaction "acting on its own behalf and at the expense of the
Client/acting on behalf and at the expense of the Client"). 2) Conclusion of an OTC option agreement on behalf and at
the expense of QYU.BROKER LLC (as a seller) and QBIF Investment Company LLC on its own behalf and at the expense
of the Client (as a buyer), according to which the seller undertakes to pay a lump sum of money stipulated in the
agreement depending on the change in the price of the underlying asset, and the buyer undertakes to pay an option
premium upon the buyer's request. The full terms and conditions of the contract and the calculation of the monies
payable by the parties are set out in the specification of the structured product. 3) In accordance with the rights and
obligations represented by the brokerage service agreements and the OTC option agreement, QBiEf Investment
Company LLC settles and accounts for the amounts of security balances under the OTC option agreements (including
determining the amount of cash to be transferred under the agreement, making and receiving claims, notices
provided for in the agreement, determining the value of rates, values, prices and other values, and performing any
actions necessary for the execution of the OTC option agreement). In addition, Interim Inspection Report No. A2N - I25
- 8 - 8/1275DSP contains the following explanatory information. In accordance with Federal Law No. 39 - FZ, the Broker
in its activities performs civil law transactions with securities on behalf and at the expense of clients or on its own
behalf and at the expense of the client. From the submitted primary documents, the working group found that when
concluding OTC option contracts, LLC Investment Company QBF acts as an "attorney" on behalf and at the expense of
LLC QBF (seller) and as a "commission agent" on behalf and at the expense of clients (buyers). Thus, on behalf of
QYU.BROKER LLC, QBIF Investment Company LLC executes the client's instructions to conclude the contract, and all
responsibility for further actions (payment of assets, ensuring delivery) is assigned to QYU.BROKER LLC. From the
second party of the transaction (other clients - buyers) LLC "QB.BROKER", acting as a commission agent, acquires the
rights and obligations for the execution of the transaction. The scheme of cash flows received from individuals -
clients of QBIF Investment Company LLC is presented in Appendix 4 to the final audit report No. A1N - I25 - 8 -
6/1654DSP. The scheme of cash flows of Q-BROKER LLC for the period from 01.11.2019 to 31.03.2021 is presented in
Appendix 3.3 of the interim act of audit No. A2H - II25 - 8 - 8 - 8/1275DSP. At the time of the audit, Denis Romanovich
Davydov was the supervisor supervising the brokerage activities of LLC Investment Company QBiEf on the part of the
Bank of Russia. The subject of the agreement No. UB - 288 dated 01.11.2019 concluded between QBiEf Investment
Company LLC and Q-BROKER LLC was as follows. In accordance with the interim act No. A2N - I25 - 8 - 8/1275DSP, Q-
BROKER LLC and QBiEf Investment Company LLC entered into a brokerage services agreement (adhesion agreement)
No. UB - 288 dated 01.11.2019. In accordance with the application for comprehensive services under the concluded
agreement, QBIF Investment Company LLC provides services on conclusion of transactions in the OTC market for
comprehensive services under the concluded agreement. Additional agreements of the said contract are disclosed in
the text of interim inspection act No. A2H - I25 - 8 - 8/1275DSP. According to the interim inspection act No. А2N - И25 -
8 - 8 - 8/1275DSP as of 31.03.2021 the following securities were in the assets of Q-BROKER LLC: - A.I. PURITY FUND AIF
V.C.I.C. PLC: Share; reg. No. CYF000001166; ISIN CYF000001166 in the amount of 49 593 590 rubles; - ARGENTO ACCESS
S.A R.L., COMPARTMENT 92; LU: Bond, documentary bearer; ISIN LU2181896106 in the amount of RUB 237,037,685; -
ARGENTO ACCESS S.A R.L. COMPARTMENT 92; LU: Bond, documentary bearer; ISIN LU218181897179 in the amount of
RUB 10,402,794; - PJSC "CEF": Ordinary share, book - entry; reg.No. 1 - 01 - 15103 - A; ISIN RU000A0JT3G8 in the
amount of RUB 35,420,000; - QBIF RFI "QBF Golden Section", QBF Asset Management LLC: Share; reg.N 3421; ISIN
RU000A0ZYLY8 in the amount of RUR 2,100,000; - OPIF RFI QBIF My Safe, MC QBIF Asset Management LLC: Share; reg.N
3420; ISIN RU000A0ZYLZ5 in the amount of RUR 5,766,734. According to the interim audit act No. A2N - I25 - 8 -
8/1275DSP the working group, at the time of signing of the interim act, analysed the information in respect of
ARGENTO ACCESS S.A R.L. and A.I. PURITY FUND AIF V.C.I.C. placed in public sources and provided by QBIF Investment
Company LLC on the registers of claims of the working group. Based on the results of the working group's analysis,
interim audit act No. A2N - I25 - 8 - 8/1275DSP recorded the absence of information on the financial indicators of
ARGENTO ACCESS S.A R.L. and units of A.I. PURITY FUND AIF V.C.I.C., which did not allow assessing the level of credit
607
risk on the above investments of Q.B.BROKER LLC and confirming the value of assets. The interim audit report No.
A2H - I25 - 8 - 8/1275DSP indicated the wording that in the period from 01.11.2019 to 31.03.2021 the source of refunds
to clients under OTC option contracts executed by QBU-BROKERLLC was funds received from new clients of QBIF
Investment Company LLC. This conclusion was made on the basis of the following. In accordance with the interim act
No. A2H - I25 - 8 - 8/1275DSP, the working group, based on the internal accounting data provided by QBIF Investment
Company LLC, conducted a cash flow analysis for the period from 01.11.2019 to 31.03.2021, within the framework of
which the difference between the amount of option premiums (security payments) received by QBIF Investment
Company LLC and the amount of funds returned to clients on the day in question was calculated on an accrual basis
on a daily basis. Information on the dynamics of the amount of liabilities of Q-BROKER LLC under OTC option
contracts for the period from 28.11.2019 to 31.03.2021, as well as information on the difference of cash funds of Q-
BROKER LLC from operations with cumulative total is provided in Appendix 3.3 of the interim act of audit No. A2N - I25
- 8 - 8 - 8/1275DSP. In addition, the final act of the audit No. A1N - I25 - 8 - 8 - 6/1654DSP reflects that the working
group analysed OTC option contracts in order to determine the financial result obtained by Q-BROKER LLC in the
period from 01.04.2019 to 31.03.2021. As a result, it was found that in the analysed period QYU.BROKER LLC paid
under the option contracts cash funds in the amount of 3 499 million rubles, under these contracts previously
received 2 560 million rubles as security payments. Thus, when executing option contracts, LLC Q-BROKER received a
loss of RUB 939 million or 36.68 per cent of the investment amounts received. The Working Group notes that a
significant part of this amount was re - invested in OTC option contracts. The funds withdrawn by investors from
brokerage accounts with LLC Investment Company QBF afer the execution of OTC option contracts totalled RUB 335
million. The above data demonstrate the lack of economic sense in the investment activity model adopted by QB-
BROKER LLC, caused by the disproportionality of investment income and liability expenses. Besides, having analysed
the circulation term of the instruments selected for investment, it has been established that it considerably exceeds
the expiry dates for the majority of the option contracts concluded. The working group's assessment of the financial
position of Q-BROKER LLC shows that it is impossible to fulfil its obligations to clients under OTC option contracts in
the amount of RUR 4,572 million as of 30.06.2021. Therefore, at the time of maturity of the contracts, the only source
of payments under the liabilities may be cash receipts from new contracts. Based on the results of the analysis of
internal and depository records of LLC QBIF Investment Company, as well as on the information available with the
Bank of Russia, the working group notes the absence of underlying assets under option contracts, under which LLC
QBIF was the counterparty, on the depo accounts, as well as the absence of hedging transactions with derivative
financial instruments and settlements on them in the audited period. Thus, the existing profitability of investments of
QBU-BROKERLLC does not allow to ensure cash flow covering its expenses on servicing of liabilities in full, the source
of settlements at execution of OTC option contracts of QBU-BROKERLLC are the funds received under the newly
concluded option contracts; (Vol. No. 259, pp. 6 - 15)
A.A. Litvinova's Testimony

as a witness, according to which she has been employed by the Bank of Russia since 2007. From 2007 to 2008 she
worked in the Currency Control Department of the Moscow State Technical University of the Bank of Russia, from 2008
she was employed in the Department for Organisation of Inspection Activities, further from 2012 she was employed in
the SIRB of the Bank of Russia, and from 2017 she was transferred to the position of Chief Expert of the SIRB of the
Bank of Russia, whose duties included inspection of NFEs. The unscheduled inspection in 2017 of the activities of
QBIF Investment Company LLC was initiated for the following reasons. In 2017, the requirements to the procedure for
calculating own funds of professional participants of the securities market were changed, in addition, in relation to
LLC Investment Company QBIF, a complaint was received earlier from an individual, this complaint was addressed to
the Head of the Bank of Russia. Dmitry Chertovich and General Director Stanislav Matyukhin were appointed to be
responsible for interaction with the working group. The following persons took part in the audit from the Bank of
Russia employees. She (A.A. Litvinova) was the head of the working group, Natalia Alekseevna Belova (participated in
the audit for no more than 10 working days), Inna Vladimirovna Volkova, Natalia Dmitrievna Larina, Anastasia
Borisovna Novozhilova, Vladimir Vladimirovich Volobuev; also at the time of the audit Maxim Viktorovich Shvedov,
Evgenia Olegovna Salatina came to check the working group for compliance with labour discipline and information
608
security. The analysis of the activities of QBIF Investment Company LLC was based on the documents provided by the
supervised organisation in the course of the audit, namely, reports of a professional securities market participant,
transcripts of reporting indicators, written explanations, FCD agreements, primary documents, and access to
accounting and operating systems. The working group checked the trust management agreements concluded on
behalf of QBIF Investment Company LLC for the period from 01.01.2017 to 25.01.2018. The essence of the trust
management agreements "MA", which were provided to clients on behalf of LLC "Investment Company QBIF" was as
follows. The agreement provided by QBIF Investment Company LLC to the clients with the title "Agreement on
Provision of Trust Management Services" was an assignment agreement, according to which individuals instructed,
and QBIF Investment Company LLC on behalf of individuals executed transactions of purchase and sale of securities,
PFIs within the framework of trading accounts opened in accordance with the "Agreement on Provision of Direct
Access Services to International Stock Markets" with individuals. At the same time, according to the explanations,
QBIF Investment Company LLC acts as an intermediary providing access to international stock markets. These
contracts were not contracts concluded within the framework of professional activities defined by the Law of the
Russian Federation No. 39 - FZ "On Securities Market". The working group also requested information on the
expediency of concluding "Trust Management" agreements while QBIF Investment Company LLC was issued a licence
by the Central Bank of the Russian Federation to carry out securities management activities. On what the
representative of LLC "QBIF Investment Company", namely General Director Matyukhin Stanislav Anatolyevich gave
explanations, based on which it follows that the purpose of conclusion of these agreements is a potential increase in
profit by offering clients who are interested in the international market of additional conclusion with LLC "QBIF
Investment Company" of contracts of trust management of securities on the basis of the licence of the Central Bank.
As the head of the working group, she is aware of about 40 facts of entering into trust management agreements with
clients on behalf of QBIF Investment Company LLC, where foreign companies participated in the related agreements.
She knows the company QB Capital CY LTD. At the time of the inspection, as part of the analysis of Stepanov S.V.'s
complaint, as well as the analysis of civil case No. 2 - 3771/2017 - m3727/2017, where Stepanov S.V. is the plaintiff, the
working group requested information from QB Investment Company QB CY LTD on what the lawsuit was filed in
connection with. To what LLC "QBIF Investment Company" represented by S.A. Matyukhin gave explanations, from
the contents of which it follows that the plaintiff (S.V. Stepanov) carried out cash settlements within the framework of
agreements with QB Capital CY LTD. In the course of the audit the working group requested the agreements (with all
additions, amendments, annexes) concluded between QB Investment Company CY LTD, the validity of which extends
to the dates of the audited period, with QBCapital CY LTD. This fact is reflected in the audit report No. A1H - I25 - 11 -
5/37DSP from pages 175 to 177 as follows: "...In addition, by the application dated 12.10.2017 No. 4 (item 9), the
working group requested all contracts (with all additions, amendments, annexes) concluded by the Company, the
validity of which extends to at least one date of the period from 01.01.2017 to 10.10.2017, with QBCapital CY LTD. The
Company provided information that "the Company has not entered into any contracts with QBCapital CY LTD, the
validity of which extends to at least one date of the period from 01.01.2017 to 10.10.2017". Taking into account the
Company's information that it is impossible to provide all contracts, the working group requested 50 contracts from
each "standard form" of "standard form No. 1", "standard form No. 2", "standard form No. 3", "standard form No. 4", as
well as copies of all documents executed as part of the conclusion of contracts, and also requested an explanatory
note on the process of concluding contracts, indicating: the process of attracting clients; the process of supporting
transactions; the process of internal accounting of such transactions; the existence of internal documents regulating
the conclusion of contracts; and the existence of internal documents regulating the conclusion of contracts As a result
of the execution of this request, the working group was provided with 32 originals "available on the date of execution
of the Request". In addition, the Company provided information from the content of which it follows that "The
remaining assignment contracts cannot be provided due to their transfer to the Limited Liability Company
"RentInvest" according to the concluded agreement dated 07.08.2017 on the transfer of assignment contracts.
Regarding the contracting process, the following information is provided by the Company: - Regarding the customer
acquisition process: 1. Potential clients are also attracted to the Company through recommendations of existing
clients. 2. Potential clients contact the Company by phone and e - mail indicated on the Company's website and
marketing materials to receive consultations on possible investment of assets in the securities market. Initial
consultations with clients include a general description of the potential and opportunities of the securities market,
609
both Russian and foreign, a description of the key issuers present in each market, including their weaknesses and
strengths. 3. Clients may also be attracted to the service through focus group telephone surveys describing
investment opportunities in the securities market. In case of a positive attitude of the client to receive additional
consultations, the client is either invited to the Company's office for a meeting or meets with the Company's manager
to provide consultations in another place convenient for the client. - On the process of transaction support: 1. The
client entered into an assignment agreement with the Company due to the client's agreement (contract) on access to
international securities markets concluded with a third party (the Company). Under the said agreement (contract) the
client transfers funds to the Company (subject to mandatory currency control and financial monitoring by the sending
bank). Due to the fact that direct servicing of the client was performed by the Company within the framework of the
agreement (contract) concluded with the client, the Company did not perform internal accounting of clients' funds (in
accordance with the official opinion of NAUFOR), the Company rendered only consulting services to clients". - On the
process of internal accounting of such transactions: "According to the Act No. 270117/VNKMT dated 27.01.2017
(attached) on the results of the audit of IC QBF LLC by the National Association of Stock Market Participants (NAUFOR),
it was found during the audit that the assignment agreements concluded by the Company are not agreements for
trust management of securities and cash intended for the execution of transactions with securities, and (or)
conclusion of agreements that are derivative financial instruments within the framework of the Company's operations
with securities and cash. In connection with the above, the Company has the right not to keep internal accounting of
cash and transactions made within the framework of rendering services on the basis of contracts concluded with
clients in accordance with the requirements of the Procedure for keeping internal accounting of transactions,
including futures transactions, and operations with securities of professional securities market participants engaged
in brokerage, dealer activities and securities management activities, approved by Resolution of the Federal Securities
Commission of Russia, the Ministry of Finance of Russia dated 11.12.2001 No. 32/108n (paragraph 5, page 2 of Act No.
270117/VNKMT). "According to the official opinion of NAUFOR set out in Act No. 270117/VNKMT dated 27.01.2017, the
conclusion of assignment agreements by the Company is not the performance of professional activities in the
securities market of the Russian Federation, the Company has not approved internal documents regulating the
conclusion of these agreements". In response to the working group's enquiry on the actual services provided by
QYUBIEF IC LLC under the trust management service agreements, the Company provided the following information:
"As noted in the Minutes of the meeting held on 15.05.2017 on the territory of the Central Federal District Main
Directorate of the Bank of Russia (p.6 of the Minutes) and the Minutes of the 12.09.2017 meeting at the Securities and
Commodity Market Department on the activities of QYUBIEF IC LLC, the Company was a party to the assignment
agreements (trust management services). Acts on rendering services with clients under the said agreements were not
drawn up. The purpose of the Company's conclusion of assignment agreements (provision of "trust management"
services) was to potentially increase the Company's profit by offering its clients additional trust management
agreements and brokerage services agreements within the framework of the Company's licence as a professional
participant of the securities market (core services of IC QUBIEF LLC). The working group was provided with a copy of
the Agreement on the Transfer of Contracts under Article 392.31 of the Civil Code of the Russian Federation dated
07.08.2017 (hereinafer - the Agreement), concluded between IK QiubiEF LLC and RENTINVEST LLC, in accordance
with which IK QiubiEF LLC assigns and RENTINVEST LLC accepts in full the rights (claims) and obligations under the
"Trust Management" contracts according to the list, which is an integral part of the Agreement. At the same time, the
working group notes that the list submitted was not available. The Working Group in response to the application No.
12 dated 24.10.2017 was provided with the act of acceptance - transfer of documents dated 07.08.2017, in accordance
with which LLC IC QUBIEF transferred and LLC RENTINVEST accepted 747 original documents. The acceptance act
contains "No. n/a, client's full name, agreement number". According to the results of the analysis of the agreement
between the Company and RENTINVEST LLC, it was established that there are no conditions in it on the
reimbursement of the transfer of the said agreements. By application No. 11 dated 23.10.2017, the working group
requested information on who is currently a party to the agreements. The Company provided information that "the
party to the contracts concluded between individuals and LLC IC QUBIEF transferred to LLC RENTINVEST is LLC
RENTINVEST". Also, the specified application (item 5) requested information on how LLC IK QUBIEF notified clients
about the transfer of contracts. The Company provided information that: "RENTINVEST LLC in accordance with clause
2.2 of the Agreement is obliged to notify third parties (Parties to the agreements on the provision of "Trust
610
Management" services. Information on the persons with whom such agreements were concluded and which were not
transferred to RENTINVEST LLC is given in Appendix No. 10 to this audit report".
All explanations from OOO Investment Company QBF indicated in the excerpt of the audit report were provided by
Director General S.A. Matyukhin. Due to changes in the requirements to the procedure for calculating equity of a
professional securities market participant, the working group was to verify the sources of equity, namely shares of
PJSC Gazprom. The working group found that the shares of PJSC Gazprom were received from the company's
participant LLC Kubi Group under the exchange agreement for ordinary shares of PJSC CEF. In order to analyse this
transaction, the working group analysed the issuer of PJSC CFP, during which it was found that the shares of PJSC CFP
in 2013 were made by the sole participant of LLC Investment Company QBF as a contribution to the authorised
capital. Thus, based on the results of the issuer's analysis, it was found that PJSC "CEF" was a related company with
LLC "Investment Company QBF" (the company's shares were previously also owned by LLC "Qubi Group", R.V.
Shpakov, LLC "CBF UA"). The General Director of CVF LLC was Nikolay Valeryevich Mikhailov, who worked at QBF LLC,
and the Auditor of CVF PJSC was Yury Vyacheslavovich Minaev, who worked at KBF UA LLC. PJSC "CBF" is registered at
the addresses of mass registration of legal entities, during the analysis of financial indicators of PJSC "CBF" it was
established that the main assets were accounts receivable in the amount of 99,5%, formed by the debt of LLC
"Avalon" (INN 7718970625) and LLC "MasterRealt" (INN 7706800442) for the total amount of 793 550 000 rubles.
Liabilities were represented by the authorised capital of 98.7%. The Working Group concluded that the value of PJSC
"CEF" shares indicated in the exchange agreement cannot be recognised as market value;
(Vol. No. 259, pp. 18 - 25)
- Testimony of E.S. Rogacheva, given to her as a witness,

according to which she has been working in the Central Bank of Russia for 6 years, has a higher education in
economics, her job duties include: supervising professional participants of the securities market, conducting
inspections in respect of professional participants of the securities market, drafing and sending requests,
instructions, as well as taking supervisory response measures. In 2017, the Consumer Protection Service received
about 8 complaints from individuals about the impossibility of withdrawing funds from the trust management
accounts of QBF LLC, QBIF LLC and other affiliated companies, the complaints were filed in respect of different
companies, but the TIN is the same everywhere, which allows us to conclude that the company is the same, the name
of the organisation has changed over time. Under the circumstances set out in the complaints of individuals, she
prepared and sent a request to LLC "IC QBF" (hereinafer - the Company) to provide the Central Bank with lists of
clients under trust management. Within the term established by law, the Central Bank received a response to the
request, the response contained a list of clients of LLC "IC QBF", the request was signed by the general director Frolov
V.G. According to the results of the analysis of this list of clients, it was found that the applicants - individuals are not
clients under trust management. In this regard, a supervisory meeting was scheduled, which implied a meeting of the
Company's participants and CB staff. The purpose of the meeting was to discuss the legality of the company's
activities. The representatives of the Society were notified in due time, minutes were drawn up and sent to the
Society. In 2017, some 4 - 5 supervisory meetings were held with representatives of the Society. At the first meeting,
on 17 April 2017, from the representatives of the Company arrived Munaev Zelimkhan - Managing Director, General
Director - Frolov Vladimir Georgievich, who, in her opinion, was a nominal director, as he did not take essentially any
part in the meeting and did not have information about the activities of the company. Rimma Viktorovna, a
representative of the owner of the Company, also came to the meeting; she was the leading representative at all
meetings and answered all questions of the CB staff. The following questions were put before the representatives of
the Company: the presence of a controller (responsible for compliance of the Company's actions with the
requirements of the legislation on the securities market), the reasons for the sharp increase in trust management
clients, comments of the Company's representatives regarding the replacement of shares of PJSC "Venture Finance
Centre" (the Company was audited for the replacement of shares of PJSC "Venture Finance Centre" with registered
ordinary shares of PJSC "Gazprom" in the amount of 59,600,000 rubles, which was also a scheme operation). They
611
were also questioned as to the reason for the systematic complaints of clients and the characterisation of the
Company's activities under assignment contracts. The assignment agreements were concluded with clients within the
framework of agency activity, which was confirmed by the conclusion of NAUFOR based on the results of an
unscheduled thematic audit conducted in the period from 12.12.2012 to 21.01.2017, within the framework of this
agency activity the Company received remuneration from foreign counterparties, which was recorded under the item
"Other income", the manager of the Company along with the trust management agreement offered clients to
conclude assignment agreements, in early 2017 the management of the Company made a decision on segregation of
the given funds For the purpose of segregation, the Company established a legal entity, the main activity of which was
to be agency activity, planned term end of 2017. The Company's representatives confirmed that clients who enter into
assignment contracts understand that these contracts are not trust management (licensing) activities. Accounting of
funds transferred to the foreign counterparty is performed directly by the counterparties. The Company acted as an
intermediary providing access to international stock markets, QB Capital (Cyprus company) was a company involved
in mutual settlements with clients, at the same time the Company acted as an agent for another company registered
in Cyprus, which transferred the agency fee to the Company. The Company did not guarantee the fulfilment of its
obligations by QB Capital (a Cyprus company). The Company does not accept clients' orders and does not transfer
them to the Cyprus company. According to the representatives of the Company, the complaints of individuals are
related to the duration of mutual settlements with clients, caused by changes in international legislation, including
the imposition of sanctions. Following the results of this supervisory meeting, a decision was made to take note of the
data received from the representatives of the Company, on the part of the Bank a decision was made to conduct
further inspection in relation to the Company. Later in 2017, it prepared and sent a request to the Company to provide
a list of clients under the assignment agreements, copies of contracts, copies of agreements on access to the
securities market. Later, within the established deadline, the Company received a response from the Company, signed
by CEO Frolov, with the requested copies of documents provided as an attachment to the response to the enquiry.
The Bank of Russia found that in the period from 2016 to 2017, the Company, using a licence of a professional
participant in the securities market, attracted funds from clients under the guise of securities trust management
activities, which, in fact, provided them with access to trading on international stock markets. As part of this activity,
instead of securities management or brokerage services, the Company offered clients services provided by companies
related to the Company, which are positioned as companies of the same group, under two interrelated agreements: 1)
Agreement on direct access to international stock markets with QCCI Ltd, under which the client transferred his funds
to a trading account opened by QCCI Ltd, which, in turn, transferred the said funds to foreign companies engaged in
brokerage activities. The Agreement provides for both the possibility of transferring the client's authority to an
authorised representative to act on his behalf by giving an order to execute relevant transactions, and transferring the
right to manage the trading account to a third party. At the same time, the legal relations of the parties, as well as all
disagreements and disputes arising from the Agreement, are governed by the laws of Cyprus and the European Union;
2) The Agreement on the provision of "Trust Management" services (hereinafer - the Agreement) with the Company,
which is concluded in accordance with the Agreement under the law of the Russian Federation, by its legal nature is
not a contract of trust management of securities, concluded within the framework of professional activities on the
securities market, as it does not involve the transfer of securities or funds for the provision of trust management
services. It is evident from the text of the Agreement that the client transfers to the Company the right to manage the
trading account opened by QCCI Ltd to the client on the basis of the Agreement with the client, and entrusts the
Company on its own behalf to give instructions to the financial intermediary, to execute transactions with securities
and to conclude contracts that are derivative financial instruments. In turn, the Company receives remuneration from
the profits made on the above trading account. During the period of time from the end of 2017 to the beginning of
2018, about 3 supervisory meetings were held with representatives of the Company. At these meetings, the
representatives of the Central Bank explained that this scheme of concluding contracts with individuals is an unfair
practice, in addition, the Central Bank sent a letter to the Company on the inadmissibility of offering services of
foreign organisations as part of the activities of a professional participant of the securities market of the Russian
Federation. As a result of supervisory measures taken by the Bank of Russia, the Company decided to change the
above scheme. The updated scheme did not involve direct participation of the Company; instead, clients entered into
a Trust Management Services Agreement with a Russian consulting company, OOO QBF Advisers (INN 7703426941),
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which does not have a licence as a professional securities market participant. QBF Adviszeri LLC acted as an
intermediary in establishing legal relations with the Cypriot company QCCI Ltd and as of 12.03.2018 continued to
bring clients to the international market under the above scheme. According to the results of the analysis of trust
management contracts and agreements, it was revealed that these documents were signed with the same person,
which allows to doubt the existence of the real brokerage activity of QB Capital (Cyprus company). It is also confirmed
by the fact that Munaev Z.V. is the founder of QB Capital (Cyprus Company), as well as an employee of IK QBEF LLC.
The reports were prepared by the employees of the Company, served as a means of misleading individuals, under the
guise of trust management of QB Capital (Cyprus Company) clients' accounts. Reports within the framework of trust
management are uploaded from the trading system, indicating the balance of securities, rate, portfolio dynamics. QB
Capital (Cyprus Company) reports do not contain the balance, company details, no stamp. The algorithm of
concluding a trust management agreement of an individual with a professional participant of the securities market
was as follows: the client applied to a professional participant of the securities market with a desire to conclude a
trust management agreement, which is posted on the website of the participant of the securities market, is usually an
agreement of accession to the rules of trust management, which is also posted on the website of the participant. To
conclude the agreement the client provides passport data, fills in the profiling questionnaire, depending on the risk -
appetite of the client he is offered strategies with different levels of risk and profitability, in the end the client chooses
a strategy suitable for him. Next, a trust management agreement is concluded, which specifies bank details for
transferring funds, and a payment order to the company is formed. Afer the client transfers funds, the participant
forms a portfolio in accordance with the chosen strategy. The manager's report on portfolio dynamics is sent to the
client in his personal cabinet on a monthly basis (unless otherwise stipulated by the contract), at the client's request,
no later than 3 working days, the client is given access to the state of his portfolio. R.V. Shpakov has never participated
in the meetings, although he has been repeatedly summoned to participate, however, other representatives have
informed that _ R.V. Shpakov is unable to participate in the meetings for various reasons. The Admission Department,
together with the Securities Market Department, conducted a pre - licensing inspection in 2019 for the Company to
obtain a depository licence. She in the summer of 2019, together with employees of the Admission Department,
carried out an on - site visit to the Company's office located at the address: Moscow, Presnenskaya Naberezhnaya, 8,
building, 1 in order to confirm compliance with the securities market legislation of the Company's activities,
availability of servers, company employees, special sofware. As a result of the visit, it was established that the
Company's activities comply with licence requirements. The contractual scheme of interaction between the
companies related to the Company and clients on the basis of civil law contracts concluded outside the framework of
special banking regulation of the relevant licensed activities deprives the latter of the mechanism of protection of
their property rights provided for by the current Russian legislation in case of losses incurred by the clients, and is
also aimed at avoiding civil law liability in case of non - performance of contractual obligations to clients, since
disputes on the failure to fulfil contractual obligations to the clients are not subject to civil law. All financial risks
related to non - return of the Company's clients' funds are fully transferred to the clients. The very name of the
Company's agreement with the clients - "Trust Management Agreement" - indicates that the clients were misled as to
the subject matter of the agreement and the services provided thereunder. The Company's clients believed that they
were provided with securities trust management services. According to information received from the Securities and
Exchange Commission of the Republic of Cyprus (the "Cyprus Regulator"), QCCI Ltd, prior to its liquidation in 2018, did
not have the licences required to carry out investment activities in the territory of the Republic of Cyprus. In the
period from 2017, their department, through an appeal to the NWPP of the Central Bank of Russia, initiated a control
purchase, which confirmed the fact that QCCI Ltd had entered into assignment agreements on behalf of QBIF Ltd and
an Agreement on the provision of services to international stock markets with a non - resident company QB Capital.
This procurement was conducted in the Moscow office of QBIF IK LLC. Afer the meeting and warning about
prevention of repetition of these facts from the clients of QBIF LLC continued to receive complaints, additionally a
repeated control purchase was carried out, according to the results of which the fact of conclusion of order
agreements on behalf of QBIF LLC and Agreement on provision of services to international stock markets with non -
resident QB Capital was confirmed. This purchase was conducted in the office of QBIF LLC in St. Petersburg. Based on
the results of these activities, the Department of the Central Federal District of the Central Bank of Russia sent a
proposal for cancellation of licences of LLC IC QBF, this proposal was sent to the DRSB of Russia. However, this
613
proposal was returned for revision and further supervisory activities. In addition, the department within the Central
Federal District Department of the Central Bank of Russia initiated an inspection of the Central Bank of Russia's SIRB.
Based on the results of the inspection by the Central Bank of Russia's SIRB, their department repeatedly proposed to
cancel the licences of QBIF LLC. This proposal was sent to the DRCB of the CBR, however it was not supported, due to
plans for further rehabilitation of the company. In 2017, materials were sent to law enforcement authorities for
verification under these assignment agreements. These materials were sent to law enforcement authorities for
verification;
(Vol. No. 259, pp. 26 - 30, Vol. No. 286, pp. 16 - 22)
- Testimony of Y.V. Dronov, given by him as a witness,

according to which, by Order No. 1969 - OD dated 21.09.2021 the Bank of Russia decided to appoint temporary
administration in Limited Liability Company "Investment Company QBF" (location address: 123112, Moscow,
Presnenskaya naberezhnaya, 8, building 1, floor/room/com 11/HP/11, TIN , OGRN , OGPN. Moscow, Presnenskaya
naberezhnaya, 8, building 1, floor/room/com 11/HP/11, TIN 7733673955, OGRN 5087746335551, hereinafer referred
to as the Company) for a period of three months with suspension of powers of executive bodies of Limited Liability
Company Investment Company QBIF. The basis for the decision was the repeated refusal within a month to satisfy
creditors' claims on monetary obligations and the failure to notify the Bank of Russia of the existence of the relevant
circumstances. The head of the temporary administration of LLC Investment Company QBF was approved. In the
course of the inspection of the activities of LLC Investment Company QBF,
he identified the related organisations, which are shown in the table below:
Also in the course of the audit it identified the following violations. As regards repurchase agreements, the following
violations were identified. According to the final act of the Bank of Russia's audit in relation to QBF Investment
Company LLC, the Company, acting as a trustee in the period from 01.04.2019 to 30.06.2021 concluded OTC repo
transactions, including transactions concluded with QBF.BROKER LLC, a member of the QBF informalised group. A full
list of persons belonging to the informalised QBF group is given in section 13 "Checking for participation of QBF
Investment Company LLC in illegal activities on the financial market by foreign organisations" of the audit report. In
addition, transactions were made under the security of units of ZPIF under the management of a related company -
KBF UA LLC (page 16 of the act). In the period from 01.04.2019 to 30.06.2021, 69 repo transactions were concluded, on
614
average for 90 days with the possibility of further prolongation. The average rate on these transactions was 8% p.a.,
discount - 10%. The following companies acted as counterparties under repurchase agreements: LLC Profi, LLC 702,
PJSC CMF and LLC QY.BROKER. As of 30.06.2021 in the investor's portfolio (under all trust management agreements)
investment units of Russian issuers received under Part 1 of the OTC repo were as follows:
Securities received under 1 part of repo Amount, rub. Quantity, pcs.
QBIF Real Estate - QBIF Asset Management LLC ISIN RU000A0JWBT7 140 499 2 872,00
096,29
QBIF Real Estate Development of Regions 2 ISIN RU000A100FL0 11 140 704,04 35,00
QBIF Real Estate Regional Real Estate - QBIF Asset Management LLC ISIN 24 564 846,00 2 305,00
RU000A0JWBS9
Tverskaya Usadba Rent ZPIF ISIN RU000A0JR0A9 187 302 5 622,00

128,81
Total 363 506 х

775,14
It revealed that under trust management agreements the clients' portfolios contain mutual funds under repurchase
(transferred under the first part of repurchase agreements with counterparties). The total number of units (UIFs) is
9244 for the amount of RUR 341.08 million. It is impossible to transfer the units in repo to clients to their new
brokerage accounts. In order to release the units of UIFs from REPO and transfer them to clients' trust accounts, it is
necessary to release them from obligations to counterparties (QYU.BROKER LLC, Profi LLC, 702 LLC, CVF PJSC) by
settling REPO transactions. On 13.12.2021 he as the head of the temporary administration of
LLC Investment Company QBF was provided with scanned images and became aware of the conclusion on 13.09.2021
by LLC Investment Company QBF of agreements on settlement and termination of obligations under repurchase
agreements concluded with PJSC CSF and LLC QBF.BROKER.
On 20.12.2021, in accordance with Article 102 - FZ "On Insolvency (Bankruptcy)" No. 127 - FZ, he, as head of the
temporary administration, declared his refusal to execute the above agreements dated 13.09.2021, on settlement and
termination of obligations under the following repurchase agreements concluded by LLC Investment Company QBIF
with PJSC CFP:
repurchase Date of repurchase

agreement number agreement
63р/0421 14.04.2021
64р/0421 14.04.2021
65р/0421 15.04.2021
66р/0421 16.04.2021
67р/0421 16.04.2021
68р/0421 16.04.2021
61р/1220 30.12.2020
69р/0421 28.04.2021
615
70р/0421 28.04.2021
71р/0421 29.04.2021
and agreement dated 13.09.2021 under repurchase agreement No. 62r/0321 dated 23.02.2021 concluded by QBIF
Investment Company LLC with QBROKER LLC. Repurchase agreements assume accrual of interest on the amount of
counterparties' outstanding obligations to QBIF Investment Company LLC. As of 13.09.2021, the amount of interest
(8% per annum) on the outstanding obligations is significantly lower (due to the total amount of the agreements -
RUB 340.08 million) than if the said agreements had been concluded on the current date. The grounds for refusal are
motivated by the fact that these agreements violate the rights of the clients of the DM. In addition, 2 statements of
claim were filed with the Arbitration Court to declare these transactions invalid due to violation of clients' rights in the
execution of these agreements. However, in order to terminate the fulfilment of obligations to clients (and transfer
these mutual funds to clients' brokerage accounts with another professional participant of the securities market) and
remove this REPO encumbrance from the mutual funds credited to the clients' MA accounts, it is necessary to release
that part of the mutual funds in the MA clients' accounts, which under these agreements dated 13.09.2021 are
recognised by the other party - counterparties to the REPO transactions. Authorisation has been requested from the
Bank of Russia to remove the REPO encumbrances from the trust clients' assets in respect of the units of mutual funds
uncontested by the REPO counterparties in order to transfer them to the clients. In addition, 4 statements of claim are
also at the stage of preparation for filing to the court to declare all repurchase agreements with counterparties invalid
in terms of performance under the second part of the repurchase (return of the part of units of mutual funds that were
provided as collateral for fulfilment of obligations). Possible violations are identified not only from the side of civil
legislation (related - party transactions, affiliated persons, non - market terms of repurchase agreements, etc.), but
also have a possible criminal context. A possible scheme of withdrawal of clients' funds under trust management
looked as follows. The accumulated funds of all clients were held in a trust management account with NSD, then LLC
QBIF Investment Company represented by its CEO S.A. Matyukhin entered into repurchase agreements with
companies belonging to the informalised QBIF group (LLC QBIF.Broker", PJSC "CVF", LLC "Profi" and LLC "702"), and
transferred knowingly unrecoverable clients' funds to LLC "QBIF Investment Company", having received 1 part of the
repo (as collateral for these clients' funds) PAI mutual funds, emitted by QBIF UA LLC (also an affiliated structure of
QBIF group), and for calculation of the collateral value under repurchase agreements it was actually not the market
value of the units, but the "estimated unit value" (UAV), which was quarterly published on the website of QBIF UA LLC.
Moreover, it is impossible to check the RSP, and the market value of units was absent as such and had no quotations
on any stock exchange, as repo transactions were made as if on the "over - the - counter market" - i.e. direct contracts.
Probably the centre of decision making on these transactions was R.A. Shpakov - the beneficiary of the group of
companies "Qubife", but the executors were the heads of the respective organisations. Besides, it is not known where
the clients' funds from the accounts of LLC "702", LLC "PROFI", LLC "QB.BROKER" and PJSC "CVF" were further
directed. The total amount of possible damage to clients of QBIF Investment Company LLC under trust management
is 340 million rubles. In terms of OTC financial instruments (options) of LLC Q-BROKER the following violations were
revealed. According to the final act of the Bank of Russia's audit in respect of LLC Q-BROKER Investment Company
(page 57), in the period from 01.04.2021 to 30.06.2021, 2,056 OTC option contracts were concluded for a total amount
of RUB 740,204 million. Information on the amounts of security payments by underlying assets is given in Appendix 4
to the audit report. The Working Group analysed the Company's compliance with the requirements of Article 51.4
"Specifics of concluding contracts that are derivative financial instruments" of Federal Law No. 39 - FZ with respect to
option contracts concluded in the interests of clients. Including fulfilment of clause 5.1 according to which the
contracts are concluded not on exchange trading only by a broker or a manager acting on his own behalf and at his
own expense or at the expense of his client. It was found that all option contracts concluded in the period from
01.04.2019 to 30.06.2021 were concluded by the Company as a trustee or commission agent. As of 31.03.2021, as part
of brokerage services, OTC option contracts were accounted for in the portfolios of 1,230 individual clients for a total
amount of RUB 3,499,300 thousand, of which the Company recognised 813 individual clients as qualified investors
(RUB 3,101,058 thousand) and 417 individual clients who are not qualified investors (RUB 398,242 thousand). In
addition, under framework agreements for the subsequent conclusion of OTC option contracts, Q-BROKER LLC
transferred funds in the amount of RUR 738,935 thousand, including RUR 4,868 thousand from non - qualified
616
investors. The Company also concluded OTC option contracts in the interests of management founders, as of
31.03.2021 the portfolios of individuals who transferred assets to the Company for trust management included OTC
option contracts concluded with QYU.BROKER LLC for the total amount of RUR 4,381 thousand, including RUR 1,417
thousand from non - qualified investors under trust management contracts of individuals. As of 04.06.2021, as part of
brokerage services, OTC option contracts were accounted for in the portfolios of 1,328 individual clients for the total
amount of RUB 3,748,365 thousand, of which the Company recognised 924 individual clients as qualified investors
(RUB 3,308,907 thousand) and 404 individual clients as non - qualified investors (RUB 439,458 thousand). In addition,
under framework agreements for the subsequent conclusion of OTC option contracts, Q-BROKER LLC transferred
funds in the amount of RUB 582,409 thousand, including RUB 40,898 thousand from non - qualified investors. The
Company also concluded OTC option contracts in the interests of management founders, as of 04.06.2021 the
portfolios of individuals who transferred assets to the Company for trust management included OTC option contracts
concluded with QYU.BROKER LLC for the total amount of RUR 86,327 thousand, including RUR 82,773 thousand from
non - qualified investors under trust management contracts of individuals. Information on the amount of option
liabilities to clients by investors and contracts is given in Appendix 4 to the audit report. The Working Group analysed
information from the Company's internal records on the conclusion of OTC option contracts with non - qualified
investors afer 30.07.2020. As a result of the analysis, it was found that the Company, on its own behalf and at the
expense of clients of non - qualified investors, concluded 399 OTC option contracts for a total amount of 365,372
thousand rubles, including 36 contracts for the amount of 13,464 thousand rubles in December 2020. The list of
contracts is provided in Appendix 4 to the audit report. Also, according to the final act of the Bank of Russia's audit of
LLC Investment Company QBIF (page 63), the working group analysed the cash flows of the Company and its
counterparties and found that in the audited period the special brokerage accounts of the Company received funds
from individuals, individual entrepreneurs and legal entities under merger agreements, the total amount of funds
received for the period from 01.04.2019 to 22.04.2021 was RUB 4,725,533,246.97, the funds were received mainly from
individuals, individual entrepreneurs and legal entities. Further, the monetary funds received under the accession
agreements were sent by QBIF Investment Company LLC to Q-BROKER LLC (INN 9703003668), QBIF FINANCIAL GROUP
JSC (INN 7703466327), CVF PJSC (INN 7734682254) and to non - residents ARGENTO ACCESS S.A R.L., Constance
Investment Ltd and T.C.R. INTERNATIONAL LTD. To the address of LLC "QYU.BROKER" (INN 9703003668) sent: - 1 365
441 522, 20 rubles as a withdrawal of funds under the agreement dated 01.11.2019 № YUB - 288; - 12 765 000,00 rubles
as payment under the contract of sale and purchase of units of ZPIF real estate "RIF Skladskoy Federal 1". Also from
the trust management account of QBIF Investment Company LLC to QB-BROKER LLC in the audited period was sent
93,670,000.00 rubles as withdrawal of funds under the agreement No. DU - YUL - 1957 dated 03.06.2020. The Company
received from QYU.BROKER LLC: - RUR 145,382,303.13 as a cash transfer under the Accession Agreement dated
01.11.2019 No. YUB - 288; - RUR 156,882,303.13 as a cash transfer/replenishment of the brokerage account under the
Agreement dated 01.11.2019 No. YUB - 288. RUB 1,408,023,475.50 as payment under the agreement on issuance of
promissory notes was sent to JSC Financial Group QBF. RUR 78,310,000.00 was sent to PJSC "CEF" as payment under
agreements on issuance of promissory notes. To non - residents: - RUB 260,068,726.50 (USD 3,393,000.00 and EUR
10,000.00) sent to ARGENTO ACCESS S.A R.L. 412F, route d'Esch, L - 2086, LUXEMBOURG for the purchase of ARGENTO
ACCESS S.A R.L.207 bonds; - some RUB 261,818,451.50 (USD 2,181,000.00) to CONSTANCE INVESTMENT LTD (Republic
of Cyprus) as settlement of OTC options; - some RUB 49,593,590.80 (USD 676,000.00) to T.C.R. INTERNATIONAL LTD.
INTERNATIONAL LTD (Republic of Cyprus) as payment for units of A.I. PURITY FUND AIF V.C.I.C. PLC (Republic of
Cyprus, date of company registration 29.01.2020). The scheme of cash flow received by QBIF Investment Company LLC
from individuals - clients under accession agreements with the subsequent conclusion of OTC option contracts with
Q-BROKER LLC is given in Appendix 4 to the act of audit. In the audited period, LLC Investment Company QBIF
withdrew funds from its special brokerage accounts (SBS) to LLC QYU.BROKER under the brokerage services
agreement No. UB - 288 dated 01.11.2019, the total amount of funds "withdrawn" under the said agreement
amounted to about RUB 1.4 billion. In addition, it follows from the act of the Bank of Russia's audit of LLC Investment
Company QBF (page 76) that according to internal accounting data and information available to the Bank of Russia, it
was established that LLC QB-BROKER carried out operations to acquire promissory notes, foreign financial
instruments, repay and issue loans. The working group determined a possible portfolio of assets of QBU-BROKERLLC
and analysed financial investments. The main volume of security payments under OTC option contracts was invested
617
in the following financial instruments: - promissory notes of JSC Financial Group QB-BROKER totalling RUB 1,422
million. From the copies of primary documents submitted to the working group, including promissory notes, client's
orders for transactions with securities, purchase and sale agreements, and acts of acceptance and transfer of
promissory notes, the working group found that the yield on purchased promissory notes varies within 8 - 11.5% per
annum depending on the maturity date; - securities issued by ARGENTO ACCESS S.A.R.L. totalling RUB 1,057 million.
According to the information provided, the yield is 5 - 9% per annum; - OTC options with CONSTANCE INVESTMENT
LTD totalling RUB 373 million. The working group analysed OTC option contracts in order to determine the financial
result obtained by Q-BROKER LLC in the period from 01.04.2019 to 31.03.2021. As a result, it was found that in the
analysed period QYU.BROKER LLC paid under the option contracts cash funds in the amount of 3 499 million rubles,
under these contracts previously received 2 560 million rubles as security payments. Thus, when executing option
contracts, LLC Q-BROKER received a loss of RUB 939 million or 36.68 per cent of the investment amounts received.
The Working Group notes that a significant part of this amount was re - invested in OTC option contracts. Cash
withdrawn by investors from brokerage accounts with the Company afer the execution of OTC option contracts
totalled RUB 335 million. The above data demonstrates the lack of economic sense in the investment activity model
adopted by Q-BROKER LLC, caused by the disproportionality of investment income and liability expenses. Besides,
having analysed the circulation term of the instruments selected for investment, it has been established that it
considerably exceeds the expiry dates for the majority of concluded option contracts. The working group's
assessment of the financial position of LLC "Q.BROKER" shows that it is impossible to fulfil its obligations to clients
under OTC option contracts in the amount of RUR 4,572 million as of 30.06.2021. Therefore, at the time of maturity of
the contracts, the only source of payments on liabilities may be cash receipts from new contracts. Based on the
results of the analysis of the Company's internal and depository records, as well as on the information available with
the Bank of Russia, the working group notes that there are no underlying assets under option contracts, under which
QBU-BROKERLLC was the counterparty, on the Company's depo accounts, as well as no hedging transactions with
derivative financial instruments and no settlements on them in the audited period. Thus, the existing profitability of
investments of QBU-BROKERLLC does not allow to ensure cash flow covering its expenses on servicing of liabilities in
full, the source of settlements at execution of OTC option contracts of QBU-BROKERLLC are the funds received under
the newly concluded option contracts. He (Ya.V. Dronov) as the head of the temporary administration filed a statement
of claim against QB-BROKER LLC for the total amount of obligations under options for the total amount of RUR 3.9
billion to clients in the interests and favour of clients on behalf of QBIF Investment Company LLC, case number A40 -
280258/2021. Thus, it becomes extremely difficult for the clients of QBIF Investment Company LLC to receive refunds
on the options of QBIF LLC. The data of the working group, indicated in the final act of the Bank of Russia audit, in
aggregate may indicate not only the presence of civil legal relations (contracts, agreements and other imitation of
economic activity, etc.), but also a criminal component, which is expressed in a possible scheme of withdrawal of
funds of clients of QBIF Investment Company LLC (former General Director Matyukhin S.A.). This is confirmed by the
fact that there was a withdrawal of clients' funds under "simulated economic activity" contracts and agreements with
legal entities fully controlled by the beneficiary Shpakov R.A., namely: LLC QB-BROKER (Shpakov R.A. - General
Director), PJSC CEF (Shpakov R.A. - General Director), JSC FG Kybief (Shpakov R.A. - General Director). In addition, the
incoming funds of the clients of QBIF Investment Company LLC for the purchase of options of QBIF LLC were further
withdrawn not only to the accounts of controlled Russian legal entities, but also to offshore jurisdictions (ARGENTO
ACCESS S.A R.L. 412F, route d'Esch, L - 2086, LUXEMBOURG, CONSTANCE INVESTMENT LTD (Republic of Cyprus), T.C.R.
INTERNATIONAL LTD (Republic of Cyprus), T.C.R. INTERNATIONAL LTD (Republic of Cyprus)). The total amount of
possible damage to the clients of QBIF Investment Company LLC on trust management and brokerage services on
options of QB-BROKER LLC is 3.9 billion rubles. In addition, the final act of the Bank of Russia's audit of QB Investment
Company QBIF LLC (p. 105) states that "According to the information available to the Bank of Russia, the applicants
concluded contracts with a legal entity - non - resident QB CAPITAL CY LTD, on behalf of which various documents
were signed by the following employees of the Company: Gorobets E.V., Z.V. Munayev, M.S. Yudin. In the opinion of the
working group, these facts may indicate coordination of actions by persons working in the Company and in QB
CAPITAL CY LTD in order to conclude contracts with individuals - clients of the Company. He (Dronov Y.V.) as the head
of the temporary administration believes that in the aggregate all these facts may indicate an unprecedented
deception of clients of QB Investment Company QB CY LTD, unprecedented withdrawal and plundering of monetary
618
clients of QB Investment Company QB CY LTD. With regard to causing real damage to QBIF Investment Company LLC
from the withdrawal of assets (cash) belonging to QBIF Investment Company LLC, he (Dronov Y.V.) explained the
following. According to the data of the financial statements and internal accounting of LLC "Investment Company
QBF" in April - May 2021 was concluded "imitating economic activity" loan agreement with the founder of LLC
"Investment Company QBF" (Matyukhin S. A. - former General Director) with the amount of money (cash) belonging to
LLC "Investment Company QBF".A. - former general director) with JSC Financial Group QBIF (R.A. Shpakov - general
director and founder), which according to the data entered in the accounting and internal records was to be repaid by
31.12.2021 together with interest - RUR 27,528,000. AO FG Qubief through S.A. Matyukhin made an offer to receive
securities to repay the loan, no written offer has been received to date. No money has been received from JSC FG
"Qybief". A pre - trial claim was sent to JSC FG Qybief. Due to the seizure of documents by law enforcement agencies,
the loan agreement itself is missing, but the statement of claim is being prepared on the basis of payment orders to
JSC FG Qybief. In this case, the funds transferred to JSC FG QBIF did not belong to the clients, but directly to LLC
Investment Company QBIF itself. Failure to fulfil this "simulated economic activity" loan agreement with JSC FG QBIF
may indicate the conclusion of the agreement "for the sake of appearances" without the purpose of returning the
funds to LLC Investment Company QBIF. Thus, in this case we can see not only civil - law basis (even if the agreement
was concluded "for the sake of appearances" only for withdrawal of assets), but also criminal violation of the law,
expressed in withdrawal of assets (funds) of LLC Investment Company QBIF. The total amount of possible damage
directly to LLC Investment Company QBF under the "imitated economic activity" loan agreement with JSC FG QBF is
27 million 528 thousand rubles. Regarding the obstruction of the activities of the temporary administration by a group
of persons (S.A. Matyukhin, R.A. Shpakov, Y.N. Orlova), he (Y.V. Dronov) explained. The internal accounting database
(clients' reports, internal postings, formation of clients' free account balances and formation of clients' portfolios) of
Fancy sofware at the computer (not user) level was and is remotely managed (via a server actually located in the
premises of QBIF Investment Company LLC) by IT - specialists of QBIF AG under the direction of Shpakov R.A.
Dronov.V. This internal accounting database was not transferred to him (Dronov Y.V.) as the head of the temporary
administration neither by Matyukhin S.A. nor by other persons. Backup of the database by his own efforts and by the
efforts of IT - specialists engaged by him as the head of the temporary administration could not be done. This
database of internal accounting (on Fancy sofware) is used to generate reports to clients, make wires, generate free
balances of clients and their portfolios, calculate taxes, etc. When the office moved to a new address (the move took
place on 27.12.2021), the server and the only computer of the Company were moved. At the same time, there was a
probability that JSC FG QBIF (IT specialists, R.V. Shpakov, S.A. Matyukhin) would oppose the temporary administration
of LLC Investment Company QBIF and LLC Investment Company QBIF would not have access to the internal
accounting database. As of 16.02.2022, as expected with a high degree of probability, S.A. Matyukhin, referring to R.V.
Shpakov and Yuri Nikolayevich Orlov (the Company's I.T. specialist), issued an ultimatum on immediate execution of
repurchase agreements dated 13.09.2021 and transfer of units of ZPIFs to QBIF LLC and to PJSC TSVF (affiliated
structures with R.A. Shpakov). In case of fulfilment of the above instructions, S.A. Matyukhin, also referring to the
words of R.V. Shpakov and Y.N. Orlov, said that access to the FANSI sofware and the client database would be
restored. In this regard, he engaged I.T. specialists from this area to unblock access to the data contained on the
servers. The involved I.T. specialists reported that it was impossible to bypass the server protection installed by the I.T.
specialists of Shpakov R.A. It was also separately reported that Matyukhin S.A. did not have the database and that "the
database belongs to the owner with all the I.T. infrastructure". Due to the destruction and non - transfer of the internal
accounting database of FANSI, the amount of possible damage directly to the clients of QBIF Investment Company
LLC may amount to a large damage. Since his arrival as head of the temporary administration and interaction with the
former CEO of QBIF Investment Company LLC S.A. Matyukhin, the latter almost always refers to R.V. Shpakov;
(Vol. No. 259, pp. 31 - 45)
- another document - a report of the temporary administration of QBIF Investment Company LLC containing
information relevant to the criminal case;
(Vol. No. 259, pp. 187 - 198)
619
- another document - the statement of the Central Bank of the Russian Federation dated 23 August 2021 No. 015 -
38/8243 on the revealed signs of unlawful acts, according to which in the activities of Q-BROKER LLC with the
mediation of a related professional participant of the securities market - QBIF Investment Company LLC - the signs of
organisation of a financial pyramid scheme under the guise of selling OTC options were revealed. It follows from the
above statement that according to the results of the analysis conducted by the Central Bank of the Russian
Federation, the model of OTC options realisation by Q-BROKER LLC bears significant risks for the clients of QBIF
Investment Company LLC and has the following features of a financial pyramid scheme: - the source of return of funds
to clients under OTC option contracts executed by Q-BROKER LLC were funds received under newly concluded option
contracts; - the obligations of Q-BROKER LLC to clients under OTC option contracts were not assessed by the Central
Bank of the Russian Federation. This does not allow to assess the level of credit risk on the mentioned investments of
Q-BROKER LLC and to confirm the value of assets, as well as to assess the repayment of the transferred funds); -
transcripts of the balance sheet items of Q-BROKER LLC as of 31.12. 2020 provided by QBIF Investment Company LLC
do not contain details regarding the assets of Q-BROKER LLC.2020 do not contain details regarding assets and
liabilities of the mentioned legal entity, which does not allow to assess the level of credit risk on investments of Q-
BROKER LLC (including those not accounted for within the framework of internal accounting), to confirm the value
and liquidity of assets on the balance sheet, and, as a consequence, the possibility of fulfilment by Q-BROKER LLC of
its obligations to clients of Q-BROKER LLC.Broker" LLC is unable to confirm its activities (direction of placement of
attracted funds, information on their placement); - transfer of large amounts from the account of "Q. Broker" LLC,
including in the course of internal accounting; - transfer of large sums from the account of "Q. Broker" LLC to the
account of "Q. Broker" LLC.Broker LLC also to the address of the beneficiary, founder or otherwise related companies;
- Q-BROKER LLC does not have a licence (permit) of the Central Bank of the Russian Federation to carry out activities
on the financial market. The identified facts and circumstances, as well as the information available to the Bank of
Russia on the cash flows of LLC Q.Broker, may indicate that the ultimate goal of the option contracts was the
implementation of LLC QBIF Investment Company and related legal entities and individuals (LLC Q.Broker, JSC
Financial Group QBIF, LLC KG, PI, PI, and other related companies). LLC "KG", PJSC "CEF", LLC "Indep Smart", LLC
"702", LLC "SeverSpetsStroy", LLC "Profi", LLC "Logopark Raevskaya", Shpakov Roman Valeryevich, Spinka Ruslan
Valeryevich, Fedorov Maxim Sergeyevich, Gramza Ekaterina Valeryevna, Maslennikov Vladimir Alexandrovich, Amerov
Rinat Feliksovich, Korzh Andrey Vasilyevich, Sokolov Ruslan Alexandrovich, Tallerov Artem Olegovich, Munaev
Zelimkhan Visaitovich, Danilenko Maxim Vyacheslavovich, Pliten Vladislav Olegovich, Meshkova Daria Yurievna,
Vartanov Avetis Stepanovich and others) of scheme operations, the ultimate purpose of which was to withdraw funds
outside the Russian Federation (in the total amount of 1,663,776,000 roubles), cash out (in the total amount of at least
332,338,000 roubles), purchase immovable property, finance construction and issue loans (in the total amount of at
least 622,702,000 roubles);
(Vol. No. 238, pp. 6 - 13)
- Protocol of inspection of items dated 04 October 2021, namely a DVD provided by the Central Bank of the Russian
Federation, which is an attachment to the application of the Central Bank of the Russian Federation dated 23 August
2021 No. 015 - 38/8243, in the course of which the documents contained on the disc and relevant to the criminal case
were printed out and attached to the materials of the criminal case;
(Vol. No. 238, pp. 15 - 31)
- other documents - documents submitted by the Central Bank of the Russian Federation together with the statement
on revealed signs of unlawful acts dated 23 August 2021 No. 015 - 38/8243, substantiating the conclusions that in the
activities of Q-BROKER LLC with the mediation of a related professional participant of the securities market - QBIF
Investment Company LLC - signs of organisation of a financial pyramid scheme under the guise of selling over - the -
counter options have been revealed, as well as other information establishing the circumstances of the criminal case;
620
(Vol. No. 238, pp. 32 - 250, Vol. No. 239, pp. 1 - 248, Vol. No. 240, pp. 1 - 56)
- another document - Rosfinmonitoring's information letter No. 12 - 00 - 20/17920 dated 18 August 2021, from which it
follows, among other things:
- R.V. Shpakov's account received about USD 63,000 from QB CAPITAL CY LTD in 2012; - in June 2018, R.V. Shpakov and
QB Group LLC entered into an indemnity agreement for the amount of about RUB 35.8 million, the client of Cubey
Group LLC submitted an order to write off 35,810 shares of common stock of PJSC CVCF to the account of R.V. Shpakov
in the depository of PJSC Bank Zenit, R.V. Shpakov is the beneficial owner of Cubey Group LLC, in 2012 and 2017. R.V.
Shpakov provided interest
- free loans to LLC "Kyubi Group", the balance of debt on which at the time of conclusion of the agreement on
derogation (29.06.2018) was about 35.8 million rubles, 29.06.2018 Shpakov R.V. and Qyubi Group LLC entered into an
agreement on derogation, according to which the parties agreed to terminate their obligations under the loan
agreements and Qyubi Group LLC provides Shpakov R.V. with a derogation - ordinary shares of PJSC CEF in the
amount of 35810 pieces, which on 29.06.2018 were credited to the account of LLC Kubi Group;
- in 2019, there were several transfers of funds between R.V. Shpakov and LLC 701, related to the granting and
repayment of loans, for a total amount of about 5.4 million rubles;
- according to the statement of JSC "Alfa Bank" on the operations of R.V. Shpakov, the largest financial transactions
were made on the ruble account, for the period from 10.01.2015 to 26.05.2020, the debit turnover was 768 982 423
rubles, the credit turnover was 768 625 705 rubles, the money was received on the account from the company LLC
"Kyubi Group", as well as transfers from individuals and legal entities in the form of loans, the largest outgoing flows
from the account of R.V. Shpakov. The largest outgoing flows from the account of R.V. Shpakov were sent to the
companies LLC "Kyubi Group", LLC "KF Estate SPB", LLC "VER - MONT", LLC "M1 Invest", as well as individuals -
Arsenchuk Valery Evgenyevich, Shevchenko Anton Yurievich, Yudin Maxim Stanislavovich;
- According to the information of foreign financial intelligence units Shpakov R. V. is the beneficial owner of the
account.V. is the beneficial owner of QB CAPITAL CY LTD (QCCI LTD) and "Constance Investment LTD (former name of
QBF INVESTMENT LTD); - according to the statement of JSC "Alfa Bank" on transactions of Munaev Z. V.V. it is
established that on the ruble account from 22.01.2015 to 26.05.2020 the credit turnover was 123 250 730 rubles, the
debit turnover was 122 858 435 rubles, the funds were received on the account of Munaev Z. V. from legal entities and
individuals as a loan repayment or transfer under the loan agreement, as well as were deposited by Munaev Z. V. in
cash.V. in cash;
- JSC Financial Group QBF carried out financial transactions, including, in December 2019, 2 financial transactions
related to the issuance of a loan to the company K - INVESTMENT LLC in the amount of about RUR 1.5 million and
receipt of about RUR 1 million from Q-BROKER LLC for a promissory note, in 2021. финансовые операции АО
Финансовая Группа «КьюБиЭф» были связаны с выдачей кредитов, а именно: в январе - марте 2021 г. АО
Финансовая группа «КьюБиЭф»» выдало займы на общую сумму 23,5 млн. рублей ООО «702», в период апрель -
май были выданы займы ООО «М1 Инвест» на общую сумму 45,6 млн. рублей, в апреле 2021 г. выданы займы
ООО «КФ ЭСТЕЙТ СПБ» на общую сумму 28,3 млн. financial transactions related to the transfer of funds from QB
CAPITAL CY LTD to individuals were qualified by credit organisations as suspicious, aimed at further cashing out, one
of the main recipients of funds is R.V. Shpakov, 14.08.2017 QB CAPITAL CY LTD changed its name to QCCI LTD,
Zelimkhan Munayev and Linda Athanasiadou had a power of attorney to open and manage accounts in CJSC Anelik
Bank on behalf of QB CAPITAL CY LTD, QB CAPITAL CY LTD accounts in CJSC Anelik Bank were opened by Zelimkhan
Munayev, afer which Linda Athanasiadou accompanied by Dmitry Lepeshkin visited the bank during the operation; -
funds from the accounts of QBIF LLC were mainly sent to foreign companies - Argento Access S. A R.L., Argento Access
S.A R.L., Constance Investment LTD, T.C.R. International LTD";
- for the period from 2014 to August 2020. Kubi Group LLC carried out financial transactions totalling over RUB
200,000,000,000, the bulk of the transactions were related to transfers to the accounts of individuals, including:
621
Roman Valeryevich Shpakov (RUB 35.8 million), Maxim Sergeyevich Fedorov (RUB 34.6 million), Ruslan Valeryevich
Spinka (RUB 32.7 million), Vladimir Alexandrovich Maslennikov (RUB 28.4 million), Andrey Vasilyevich Korzh (RUB 17.8
million), Maxim Vyacheslavovich Danilenko (RUB 6.8 million), Svetlana Belodeddlan (RUB 6.8 million), Vladimir V. RUB
6.8 million), Svetlana Vasilievna Beloded (RUB 3.9 million), Zelimkhan Visaitovich Munayev (RUB 3.9 million); - QBII
Asset Management LLC performed financial transactions for the period from May 2015 to June 2021 totalling
approximately RUB 7 billion, of which RUB 1.2 billion were related to deposit transactions. Among the main
counterparties of LLC QBIIF Asset Management are LLC KP Queue 3, LLC KP Queue 4, LLC KP Queue 2, which entered
into an agreement with LLC QBIIF Asset Management on assignment of claims under the agreement on participation
in shared construction, registered in the Office of the Federal Service for State Registration, Cadastre and Cartography
for the Arkhangelsk region and the Nenets Autonomous District, in addition, LLC QB Asset Management and LLC
Vysota concluded an agreement on assignment of rights of claim under the contract of participation in shared
construction, registered on 06.04.04.2018 by the Office of the Federal Service for State Registration, Cadastre and
Cartography in the Moscow Region;
- LLC F - Technologies performed financial transactions carried out in the period of October - November 2019 and
related to the receipt of a loan from LLC Profi in the amount of RUB 4.1 million on 10.10.2019 and its transfer as a loan.
and transferring it as a loan on the same day to the account of Ruslan Valeryevich Spinka, while there is no incoming
flow to the address of LLC Profit, however, outgoing transactions are related to the provision of an interest - bearing
loan to the non - resident Simtelligence Company Limited, in total LLC Profi transferred RUB 36.5 million to the non -
resident. RUB;
- LLC "M1 Invest" carried out financial transactions carried out in the period from October 2014 to May 2021 for a total
amount of over RUB 120 million related to the issue/payment of loans (counterparty JSC Financial Group "KybiEf"),
payment under securities purchase/sale agreements;
- LLC "Severspetsstroy" carried out financial transactions carried out in the period from February 2018. In the period
from February 2018 to April 2021 for a total amount of approximately RUB 19 million related to advance payments
under a construction contract, as well as the transfer of RUB 5.1 million under a contract for the purchase/sale of real
estate to V.F. Shpakov; (Vol. No. 240, pp. 66 - 87)
- Another document is Rosfinmonitoring's information letter No. 12 - 00 - 20/18766 dated 27.08.2021, which shows,
among other things, that between Argento Access S.A R.L. and QBIF Investment Company LLC, in the period from
August to November 2020, securities purchase/sale transactions totalling RUB 260 million were carried out through
NSD; (Vol. No. 240, pp. 89 - 92)
- Another document information letter of Rosfinmonitoring dated 11.02.2022 No. 12 - 00 - 19/2438, from which it
follows, among other things, that Rosfinmonitoring has received information from the Bank of Russia on questionable
transactions of clients of CB Alfa - Bank for the period 2020 - 2021, Among the identified customers of CB Alfa - Bank
who have made dubious transactions, there is KG LLC (Taxpayer Identification Number 7701876374, registration
address 123112, Moscow, Presnenskaya Naberezhnaya, 8, p. 1), KG LLC (Taxpayer Identification Number 7701876374,
registration address 123112, Moscow, Presnenskaya Naberezhnaya, 8, p. 1). 1), LLC "KG" for the period from October
2019 to July 2020 made transactions on issuance and repayment of interest - bearing loans totalling approximately
RUB 1 billion. The main counterparty - payer of KG LLC is JSC Financial Group QBF, KG LLC has a staff of one unit, the
activities of the said company have been identified as having confusing or unusual operations that do not have an
obvious economic sense or an obvious legitimate purpose, based on the results of the analysis of the current
accounts of counterparties - individuals opened with CB Alfa - Bank, in favour of which payments under loan
agreements were made, it was found that further funds were transferred mainly in favour of individuals (according to
the results of the analysis of the current accounts of the counterparties - individuals opened with CB Alfa - Bank). Vol.
No. 240, pp. 105 - 111)
622
- Protocol of seizure dated 17 September 2021, conducted at the Central Bank of the Russian Federation at 12
Neglinnaya Street, Moscow, during which items and documents relevant to the criminal case were seized; (Vol. No.
241, pp. 9 - 12)
- Protocol of examination of items dated 09 December 2021, namely a DVD disc seized during the seizure on 17
September 2021 at the Central Bank of the Russian Federation, during which the documents contained on the disc,
which are relevant to the criminal case, were examined, printed and attached to the materials of the criminal case;
(Vol. No. 241, pp. 13 - 22)
- other document - the final act of the audit of LLC Investment Company QBIF (date of the beginning of the audit
19.04.2021) with annexes, seized during the seizure on 17 September 2021 in the Central Bank of the Russian
Federation, which established, among other things:
- On the violation by QBIF Investment Company LLC of the requirements of cl. 9.3 of Regulation No. 577 - P and clause
7.1 of the internal accounting rules in terms of incorrect reflection of information on the date of the service agreement
in the reporting documents sent by QBIF Investment Company LLC to clients;
- violation by QBIF Investment Company LLC of the requirements of clause 9.7 of Regulation No. 577 - P and clause 7.1
of the internal accounting rules in terms of incorrect reflection of information on the date of the service agreement in
the reporting documents sent by QBIF Investment Company LLC to clients. 9.7 of Regulation No. 577 - P and p. 7.4 of
the internal accounting rules in terms of failure to send reports at the written request of the client within the
established time limit (up to ten working days from the date of receipt of the request, 33 cases);
- QBIF Investment Company LLC violated p. 6 of the procedure and terms of submission of reports. 6 of the procedure
and terms of reporting submission, which is Appendix 2 to Instruction No. 5117 - U in terms of failure to send to the
Bank of Russia corrected reports on the form 0420409 as of 30.09.2019, 29.02.2020 within 10 working days following
the day of occurrence of grounds for making changes;
- QBIF Investment Company LLC violated item. 6 of the procedure and terms for submission of reports, which are
Annex 2 to Instruction No. 5117 - U, in terms of failure to send to the Bank of Russia corrected reports on Form
0420417 as of 29.02.2020, 31.10.2020, 31.03.2021 within 10 working days following the day of occurrence of the
grounds for making changes; - QBIF Investment Company LLC violated the requirements of clause 1 of Article 15.8 of
Federal Law No. 39 - FZ in terms of providing the repository with incorrect information provided for by clause 1 of
Article 15.5 of Federal Law No. 39 - FZ. 1, Art. 15.5, para. 1 of Federal Law No. 39 - FZ, on a contract being a derivative
financial instrument; - QBIF Investment Company LLC violated the requirements of para. 8 of Instruction No. 4104 - U
in terms of sending incorrect information to the repository, namely: the date of conclusion of the agreement and the
registration number of the agreement concluded between QBIF Investment Company LLC and Constance Investment
LTD;
- QBIF Investment Company LLC violated the requirements of item 1 of article 15.8 of Federal Law No. 39 - FZ in terms
of providing the repository with the information stipulated by item 1 of article 15.5 of Federal Law No. 39 - FZ. 1 Art.
15.5 of Federal Law No. 39 - FZ, exceeding the deadlines established by the regulations of the Bank of Russia in respect
of 8 contracts; - QBIF Investment Company LLC violated the requirements of p. 3.4. 2 of the Regulations on the
Recognition of QBIF Investment Company LLC.2 of the Regulations on Recognition of Individuals and Legal Entities as
Qualified Investors by QBIF Investment Company LLC in terms of: failure of the controller to verify the documents
submitted by the interested party (27 cases), failure of the controller to mark on the application the resolution on
compliance/non - compliance with the requirements necessary for recognition of the person as a qualified investor
(27 cases), failure to fix the decision on recognition of the person as a qualified investor in the application (27 cases); -
QBIF Investment Company LLC violated the requirements of clause 3.4.2 of the Regulations No. 542 - .2 of the Bank of
Russia's regulations (27 cases); - QBIF Investment Company LLC violated the requirements of clause 3.4.2 of the
Regulations on Recognition of Individuals and Legal Entities as Qualified Investors. 4.2 of Regulation No. 542 - p in
623
terms of failure to include information on the name of the organisation from which the amount of income in
monetary form and (or) other monetary payments on securities was received; - despite offering complex structural
instruments to clients, QBIF Investment Company LLC used a formal approach to verifying information on compliance
with the requirements for qualified investors and subsequently concluded transactions with persons who do not
meet the requirements that a person must meet to be recognised as a qualified investor;
- despite the fact that QBIF Investment Company LLC offered its clients complex structural instruments, it used a
formal approach to verifying information on compliance with the requirements for qualified investors and
subsequently concluded transactions with persons who do not meet the requirements that a person must meet in
order to be recognised as a qualified investor. In the opinion of the working group, the numerous violations of legal
requirements, regulations of the Bank of Russia and internal documents of QBIF Investment Company LLC, including
those related to internal/depository accounting, trust management activities, as well as the failure to identify these
violations during internal audits, indicate the inefficiency of the internal control system developed at QBIF Investment
Company LLC, as well as the lack of control by the parties to the audit. 3 Art. 53 of the Civil Code of the Russian
Federation, para. 1 Art. 44 of Federal Law No. 14 - FZ). In addition, the violations of the requirements of the Russian
Federation legislation on securities identified during the audit on the basis of subpar. 7) п. 1, Article 39.1,
subparagraph 7) of Federal Law No. 39 - FZ are grounds for the Bank of Russia to revoke the licences of professional
securities market participants, and also indicate a threat to the rights and legitimate interests of consumers of
financial services; (Vol. No. 241, pp. 28 - 250, Vol. No. 242, pp. 1 - 62, Vol. No. 244, pp. 25 - 249, Vol. No. 245, pp. 1 - 177)
- another document - the act of inspection of LLC Investment Company QBIF (inspection start date 09.10.2017,
inspection completion date 26.01.2018) with annexes, seized during the seizure on 17 September 2021 at the Central
Bank of the Russian Federation, which established, among other things: - LLC "Investment Company QBF" violated:
the requirements of part 8 of article 10 of Law No. 402 - FZ in terms of the lack of information on the dates of
corrections made to the accounting registers, the requirements of part 1 of article 13 of Law No. 402 - FZ in terms of
the fact that the accounting (financial) statements do not give a true representation of the financial result as of the
reporting dates, the requirements of par. 3 of Instruction No. 3533 - U and clause 1 of the procedure for compiling and
submitting reports on Form 0420411 "Indicators of the Statement of Financial Results" of Appendix 1 to Instruction
No. 3533 - U in terms of submitting unreliable data on financial result indicators to the Bank of Russia, requirements
of clause 6, Section III of Order No. 43n. 6, Section III of Order No. 43n in terms of inaccurate presentation of
information on the financial position of LLC Investment Company QBIF, financial results of its activities and changes
in its financial position in the financial statements of LLC Investment Company QBIF; - LLC Investment Company QBIF
violated: the requirements of clause 1.2 of Regulation No. 548 - P in terms of reflecting in the calculation of own funds
as of 15.08.2017 the amount of NCD on OFZ not according to the accounting data, the requirements of clause 4.1.11 of
Regulation No. 548 - P in terms of reflecting in the calculation of own funds as of 15.08.2017 the amount of NCD on
OFZ not according to the accounting data, the requirements of clause 4.1.11 of Regulation No. 548 - P in terms of
reflecting in the calculation of own funds. 4.1.11 of Regulation No. 548 - P in terms of incorrect reflection in the
calculation of own funds as of 15.08.2017 of the amount of NCD on OFZ, requirements of clause 3 of Guideline No.
3533 - U and clause 1, clause 4 of the procedure for drawing up and submitting reports on OFZs. 4 of the procedure for
compiling and submitting reports in Form 0420413 "calculation of own funds" of Appendix 1 to Guideline No. 3533 - U
in terms of providing unreliable data on the indicators of asset value as of 15.08.2017, namely the amount of ICD on
OFZ; - LLC Investment Company QBF did not comply with the requirements of p. 34 of the accounting policy in terms
of revaluation of assets. 34 of the accounting policy in terms of securities revaluation; - QBIF Investment Company LLC
violated: clause 1.2 of Regulation No. 548 - P in terms of determining the amount of liabilities as part of long - term
liabilities in the amount of accrued interest not based on accounting data, clause 10.1.2 of Regulation No. 548 - P in
terms of accepting the incorrect amount of accrued interest calculated not based on accounting data as of all dates of
the audited period to the calculation of equity; - QBIF Investment Company LLC violated clause. 16 section 2 of the
procedure approved by the Resolution of the Federal Commission for Securities Market of Russia No. 32 and the
Ministry of Finance of Russia No. 108n, in terms of the absence of mandatory provisions in the rules of LLC Investment
Company QBF dated 20.05.2016, namely the procedure for internal accounting by the branch of the professional
participant, establishing the list of information to be submitted by the branch and the deadlines for submission of
624
information on transactions; - LLC Investment Company QBF violated the requirement of subpar. 2, p. 1, p. 1, Article
10.2 - 1 of Law No. 39 - FZ in terms of maintaining an individual investment account not on the basis of (without
concluding) trust management agreements; - repeated violations by QBIF Investment Company LLC of the
requirements of p. 5.2.4 of the rules of QBIF LLC. 5.2.4 of the rules of QBIF Investment Company LLC dated 20.05.2016,
item. 22 Section 3 of the procedure approved by the Resolution of the Federal Commission for Securities Market of
Russia No. 32 and the Ministry of Finance of Russia No. 108n in terms of: reflection in the Client Orders Registration
Journal of the time (with indication of hours and minutes) of receipt by QBIF Investment Company LLC of orders to
return the clients' property different from the time (hours and minutes) indicated in the provided orders to return the
clients' property (4 cases); reflection in the Client Orders Registration Journal of the registration numbers of orders to
return the clients' property, orders to transfer funds (4 cases); reflection in the Client Orders Registration Journal of
the registration numbers of orders to return the clients' property, orders to transfer funds (4 cases). According to
the data of the Unified State Register of Legal Entities, the owner of 88% in the authorised capital of LLC KG and 95%
in the authorised capital of LLC M4 Invest), it is not provided for by the business practice to conclude loan agreements
of identical dates with identical numbers, when executing payment documents for transfer of funds under loan
agreements LLC Investment Company QBIF and its counterparties allow incorrect filling in of data in the field
"Purpose of payment", In this connection, there is a possibility of ambiguous interpretation of the field, thus, in case
of identical details of loan agreements, arbitrary indication of the purpose of payment leads to non - transparency of
accounting of issuance and return of borrowed funds of counterparties; - with regard to PJSC "CEF" the following was
established: Absence of fixed assets, registration at the address indicated during state registration as the location by
several legal entities according to the data posted on the official website of the Federal Tax Service as of 30.06.2017,
31.03.2017, 31.12.2016 more than 99% of assets are accounts receivable, with more than 95% of the total amount of
accounts receivable accounted for 2 legal entities, as of 30.06.2017, 31.03.2017, 31.12.2016 PJSC "CEF" had no
financial investments, as of 2016, 6 months of 2017. The General Director of PJSC "CFV" is Nikolay Valeryevich
Mikhailov, who also held the position of the Director of Corporate Finance Department in LLC "Investment Company
QBF", one of the creditors of PJSC "CFV" is Roman Valeryevich Shpakov (the amount of accounts payable - 3,161.1
thousand roubles), shares of PJSC "CFV" are in the amount of 3,161.1 thousand roubles. The shares of PJSC "CEF" are
admitted to trading in the stock section of JSC SPCEX, at the same time, for the period from 19.06.2015 to 07.11.2017
no transactions were made with the above instrument, which, in the opinion of the working group, may indicate that
other participants of the organised securities market have no interest in investing in the above shares (conclusion -
highly liquid securities were acquired by QBIF Investment Company LLC by entering into a securities swap agreement
with KG LLC, under which QBIF Investment Company LLC transferred ordinary shares of CVF PJSC in exchange for
ordinary shares of GAZPROM PJSC. No cash settlements were made. Subsequently, by entering into an additional
agreement to the securities exchange agreement with KG LLC, the ordinary shares of PJSC GAZPROM were exchanged
for OFZ. Further, QBIF Investment Company LLC entered into a securities swap agreement under which OFZs were
transferred by QBIF Investment Company LLC to KG LLC in exchange for ordinary shares of GAZPROM PJSC. In the
period from 01.12.2017 to 25.12.2017, these shares were sold to KG LLC), in addition, the above act and its annexes
contain other information relevant to the criminal case; (Vol. No. 242, pp. 64 - 250, Vol. No. 243, pp. 1 - 250, Vol. No.
244, pp. 1 - 23)
Protocol of examination of items dated 17 December 2021, namely a DVD disc seized during the seizure on 17
September 2021 at the Central Bank of the Russian Federation, during which the documents contained on the disc
and relevant to the criminal case were examined, printed and attached to the materials of the criminal case; (Vol. No.
245, pp. 178 - 185)
- other documents - letters with attachments seized during the seizure on 17 September 2021 at the Central Bank of
the Russian Federation. in the Central Bank of the Russian Federation, sent to the Bank of Russia by the competent
authorities of the Cayman Islands, from which it follows, among other things, that: "Simtelligence Company Limited"
("Simtelligence Company Limited") has no data on residents of the Russian Federation acting as clients of the said
company; "Simtelligence Company Limited" ("Simtelligence Company Limited") has not received any funds from
625
clients; "Simtelligence Company Limited did not transfer clients' funds, did not use clients' funds and did not have in
its possession any documents containing the scheme of cash flow used by Simtelligence Company Limited in
transferring funds; "Simtelligence Company Limited ("Simtelligence Company Limited") was registered as a
"Securities - Exclusive Person" on 18 January 2018, following changes in legislation, Simtelligence Company Limited
("Simtelligence Company Limited") was reclassified as a "Securities - Registered Person" under Section 5(4) of the
Securities Investment Business Act on 01 January 2020, with "registered person" being defined as: 1) a company
within a group of companies carrying on securities investment business exclusively for one or more companies within
the companies, 2) a person carrying on securities investment business exclusively for one or more of the following
category of persons - a) a sophisticated person, b) a high net worth individual, c) a company, partnership or trust
(whether or not regulated as a mutual fund) whose shareholders, unit holders or limited partners are (Vol. No. 245,
pp. 187 - 197, Vol. No. 246, pp. 19 - 27)
- other documents account statements of "QB CAPITAL CY LTD" seized during the seizure on 17 September 2021 at the
Central Bank of the Russian Federation, according to which the main receipts of funds are at the expense of
individuals; (Vol. No. 245, pp. 198 - 246, Vol. No. 246, pp. 28 - 73)
- other documents - requests of the Central Bank of the Russian Federation, seized during the seizure on 17
September 2021 in the Central Bank of the Russian Federation, addressed to the Cayman Islands Monetary Authority
(CIMA), the Securities and Futures Commission (SFC) of Hong Kong, according to which the Bank of Russia, having
established signs of involvement of White Lake Management LTD."LTD) and Simtelligence Company Limited
(Simtelligence Company Limited) were involved in illegal activities on the financial market of the Russian Federation,
the Bank of Russia requested additional information on these organisations;
(Vol. No. 245, pp. 247 - 249, Vol. No. 246, pp. 1 - 16, 74 - 84)
- Protocol of examination of items dated 25 December 2021, namely a DVD disc seized during the seizure on 17
September 2021 at the Central Bank of the Russian Federation, during which the documents contained on the disc,
reflecting the claims activity of a large number of citizens (clients) to LLC Investment Company QBF and QBF Financial
Group as a whole, which are relevant to the criminal case, were examined, printed and attached to the materials of
the criminal case; (Vol. No. 246, pp. 85 - 120)
- other documents - claims for pre - trial dispute settlement (pre - trial claims), applications for termination of
contracts, claims for return of funds, as well as other related documents reflecting the claims activity of a large
number of citizens (clients) to QBF Investment Company LLC and QBF Financial Group as a whole, as well as various
documents in the form of notices to clients (including that all rights and obligations of QBF Financial Group LLC and
QBF Financial Group LLC are reserved), as well as various documents in the form of notices to clients (including that
all rights and obligations of QBF Financial Group LLC and QBF Financial Group LLC are reserved), as well as various
documents in the form of notices to clients (including that all rights and obligations of QBF Financial Group LLC and
QBF Financial Group LLC are reserved). (Vol. No. 246, pp. 122 - 222)
- physical evidence - optical discs seized on 17 September 2021 in the course of seizure at the Central Bank of the
Russian Federation located at 12 Neglinnaya Street, Moscow: DVD+R of "Verbatim" brand with a handwritten note "for
official use. ex 1 № 25 - 3 - 16/62 DSP dated 30.08.2021 LLC IC QBEEF INN 7733673955"; CD - R of "Verbatim" brand
with handwritten note "QBEEF UD 12101007754000065"; CD - R of "Verbatim" brand with handwritten note "For
official use ex 1 № 25 - 3 - 16/62 DSP dated 30.08.2021 LLC IC QBEEF INN 7733673955"; CD - R of "Verbatim" brand with
handwritten note "For official use ex. 1 No. 25 - 3 - 16/67 DSP dated 15.09.2021 QBF LLC INN 7733633955"; (Vol. No.
246, pp. 223 - 224)
- Protocol of seizure dated 22 April 2022, conducted at the Central Bank of the Russian Federation at 12 Neglinnaya
Street, Moscow, during which items and documents relevant to the criminal case were seized; (Vol. No. 309, pp. 1 - 12)
626
- Protocol of examination of items and documents dated 05 June 2022, seized during the seizure on 22 April 2022 at
the Central Bank of the Russian Federation, during which the documents establishing the circumstances of the
criminal case were examined and attached to the materials of the criminal case;
(Vol. No. 309, pp. 13 - 145)
- other documents seized during the seizure on 22 April 2021, including the inspection passports of QBIF Investment
Company LLC containing individual assignments (additions to the individual assignment) for conducting the
inspection, individual reports of members of working groups on the performance of individual assignments during
the inspection of QBIF Investment Company LLC, inspection reports of QBIF Investment Company LLC containing
information on identified violations of the requirements of the law, regulations of the Bank of Russia and internal
documents
(vol. No. 309, pp. 146 - 250, vol. 310, lit. 1 - 179, vol. 311, lit. 1 - 160, vol. 312, lit. 1 - 151, vol. 313, lit. 1 - 197, vol. 314,
lit.ll. 1 - 250, vol. 315, l.d. 1 - 212, vol. 316, l.d. 1 - 166, vol. 317, l.d. 1 - 170, vol. 318, l.d. 1 - 233, vol. 319, l.d. 1 - 194)
- Protocol of seizure dated 23 September 2021, conducted at the Central Bank of the Russian
Federation, 12 Neglinnaya Street, Moscow, during which documents relevant to the criminal
case were seized;
(Vol. No. 247, pp. 6 - 10)
- Other documents - various agreements, contracts with annexes and related documents seized during the seizure on
23 September 2021 at the Central Bank of the Russian Federation, which were imposed for conclusion with clients in
order to attract their funds for subsequent embezzlement, clients' appeals (statements, complaints) to various state
bodies of the Russian Federation (including the Ministry of Finance of the Russian Federation, the Bank of Russia and
others) about violations committed by QBEF Investment Company LLC and taking measures to respond to them.
(vol. No. 247, l.d. 11 - 249, vol. No. 248, l.d. 1 - 227, vol. No. 249, l.d. 1 - 210, vol. No. 250, l.d. 1 - 249, vol. No. 251, l.d. 1 -
245, vol. No. 252, l.d. 1 - 175, vol. 253, l.d. 1 - 240, vol. 254, l.d. 1 - 249, vol. 255, l.d. 1 - 238, vol. 256, l.d. 1 - 249, vol. 257,
l.d. 1 - 219, vol. 258, l.d. 1 - 117)
- Protocol of examination of documents dated 12 March 2022, seized during the seizure on 23
September 2021 at the Central Bank of the Russian Federation, which are of significance and
establish the circumstances of the criminal case;
(Vol. No. 258, pp. 118 - 242)
- Protocol of the search of 26 May 2021, conducted in the office premises of LLC Investment Company QBF, located at:
Moscow, Presnenskaya Naberezhnaya, 8 , p. 1, 5th floor, during which items and documents containing information
relevant to establishing the circumstances of the criminal case were seized. 1, 5th floor, during which items and
documents containing information relevant to establishing the circumstances of the criminal case were seized;
(Vol. No. 90, pp. 4 - 24)
627
- Protocol of examination of items and documents dated 30 June 2021, seized on 26 May 2021 in the office premises
of LLC Investment Company QBF, located at: Moscow, Presnenskaya Naberezhnaya, 8 , p. 1, 5th floor. 1, 5th floor,
during which items and documents relevant to the criminal case were examined, some of the documents were
attached to the materials of the criminal case;
(Vol. No. 90, pp. 30 - 61)
- other documents - documents seized on 26 May 2021 in the office premises of LLC QBIF Investment Company
located at: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, 5th floor, including: various agreements, annexes and
related documents concluded between controlled legal entities (including LLC QBIF). 1, 5th floor, including: various
agreements with annexes and related documents concluded between controlled legal entities (including LLC
Q.Broker, LLC Investment Company QBF, LLC Indep Smart); lists of persons with whom various agreements on raising
funds were concluded; documents on controlled foreign organisations (including Argento Access S.A R.L.), as well as
other documents containing information establishing the circumstances of the criminal case;
(Vol. No. 90, pp. 62 - 204)
Moscow, Presnenskaya Naberezhnaya, 8, p. 1, 9th floor, during which items and documents containing information
(Vol. No. 91, pp. 7 - 25)
- Protocol of examination of items and documents dated 24 October 2021, seized on 26 May 2021 in the office
premises of LLC Investment Company QBF, located at: Moscow, Presnenskaya Naberezhnaya, 8 , p. 1, 9th floor. 1,
9th floor, during which items and documents relevant to the criminal case were examined, some of the documents
were attached to the materials of the criminal case;
(Vol. No. 91, pp. 35 - 106)
- other documents - documents seized on 26 May 2021 in the office premises of LLC Investment Company QBF,
located at: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, 9th floor. 1, 9th floor, including: various agreements,
including agreements for placement of advertising and information materials on LED advertising structures,
agreements for advertising services, loan agreements, lease agreements, repurchase agreements, repurchase
agreements for immovable property, Investment unit sale and purchase agreements, securities loan agreements with
annexes and related documents concluded between controlled individuals and legal entities (including K -
Investment LLC, 776 LLC, QBF Advisor LLC, Q.Broker, K - Consulting LLC, 701 LLC, JSC QBIF Financial Group, QBIF
Investment Company LLC, F - Experts LLC, Rentinvest LLC, 702 LLC, Profi LLC, M1 Invest LLC, Simon jesso LLC, M4
Invest LLC, Format Development Ltd, LLC Vysota, LLC 168 Kvartal, LLC QBF Asset Management, LLC Severspetsstroy,
LLC KG, LLC KF Estate SPB, JSC QBF, LLC Ver - mont, LLC Indep Smart, JSC RIF, LLC F - Technologies, PJSC Venture
Finance Centre); documents on claim activity on the part of citizens to the address of the financial group "QBF"
(appeals of citizens, notifications and answers to citizens to their claims, statements of claim, responses to the court,
claims, court decisions and determinations); documents evidencing financial relations with controlled foreign
organisations (including "Argento Access S. A R.L.", "Argento Access S.A R.L., Constance Investment LTD;
correspondence of QBIF Investment Company LLC with the Central Bank of the Russian Federation, including:
628
requests (instructions) to provide the regulator with documents for inspections caused by citizens' appeals on non -
fulfilment of obligations to return funds, responses to these requests, as well as other documents containing
information establishing the circumstances of the criminal case;
(vol. 91, l.d. 107 - 249, vol. 92, l.d. 1 - 247, vol. 93, l.d. 1 - 248, vol. 94, l.d. 1 - 250, vol. 95, l.d. 1 - 248, vol. 96, l.d. 1 - 250,
vol. 97, l.d. 1 - 250, vol. 98, l.d. 1 - 219, vol. 99, l.d. 1 - 242, vol. 100, l.d. 1 - 248, vol. 101, l.d. 1 - 250, vol. 102, l.d. 1 - 247,
vol. No. 103, l.d. 1 - 247, vol. No. 104, l.d. 1 - 245, vol. No. 105, l.d. 1 - 247, vol. No. 106, l.d. 1 - 250, vol. No. 107, l.d. 1 -
245, vol. No. 108, l.d. 1 - 248, vol. No. 109, l.d. 1 - 233, vol. No. 110, l.d. 1 - 243, vol. No. 111, l.d. 1 - 249, vol. No. 112, l.d. 1
- 249, vol. No. 113, l.d. 1 - 249)
Moscow, Presnenskaya Naberezhnaya, 8, p. 1, 11th floor, during which items and documents containing information
(Vol. No. 114, pp. 4 - 16)
- Protocol of inspection of items and documents dated 19 October 2021, seized on 26 May 2021 in the office premises
of LLC Investment Company QBF, located at: Moscow, Presnenskaya Naberezhnaya, 8 , p. 1, 11th floor. 1, 11th floor,
during which items and documents relevant to the criminal case were examined, some of the documents were
(Vol. No. 114, pp. 21 - 33)
- other documents - documents seized on 26 May 2021 in the office premises of QBIF Investment Company LLC
located at the following address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, 11th floor, including: statutory and
foundation documents of QBIF Investment Company LLC, licences of a professional securities market participant
issued to QBIF Investment Company LLC. 1, 11th floor, including: charter and constituent documents of QBF
Investment Company LLC, licences of professional securities market participant issued to QBF Investment Company
LLC; documents on claim activity on the part of citizens to QBF Financial Group (appeals (claims) of citizens,
notifications and answers to citizens to their claims); correspondence of QBF Investment Company LLC with the
Central Bank of the Russian Federation, including: requests (prescriptions) to provide the regulator with documents
for inspections caused by citizens' appeals on non - fulfilment of obligations to return funds, responses to these
requests, as well as other documents containing information establishing the circumstances of the criminal case;
(Vol. No. 114, fol. 34 - 248, Vol. No. 115, fol. 1 - 243, Vol. No. 116, fol. 1 - 239, Vol. No. 117, fol. 1 - 248, Vol. No. 118, fol. 1 -
248, Vol. No. 119, fol. 1 - 192)
- Protocol of the search of 26 May 2021, conducted in the dwelling of A.S. Golubev, located at the address: St.
Petersburg, Nevsky Prospekt, b. 123, corp. 2, sq. 10, during which items and documents containing information
relevant to establishing the circumstances of the criminal case were seized. 123, bldg. 2, flat 10, during which items
and documents containing information relevant to establishing the circumstances of the criminal case were seized;
(Vol. No. 120, pp. 7 - 15)
629
- Protocol of examination of items and documents dated 28 September 2021, seized on 26 May 2021 in the dwelling of
A.S. Golubev, located at the address: St. Petersburg, Nevsky Prospekt, b. 123, corp. 2, sq. 10. 123, bldg. 2, sq. 10, in
the course of which items and documents relevant to the criminal case were examined, and some of the documents
(Vol. No. 120, pp. 18 - 56)
- other documents - documents seized on 26 May 2021 in A.S. Golubev's home located at the following address: St.
Petersburg, Nevsky Prospekt, bld. 123, bldg. 2, sq. 10, including: labour books of the accused Pakhomov V.S. and
Golubev A.S., testifying about the period of their work in the financial group "QBF" and their managerial positions;
numerous orders of citizens to withdraw funds, receipts of citizens in cash, which additionally confirms the
organisation of raising funds from clients on the signs of a financial pyramid scheme, where the source of repayment
of funds to old clients was the funds received from new clients; leasing agreements and related documents; leasing
contracts and other documents.
(vol. No. 120, l.d. 57 - 238, vol. No. 121, l.d. 1 - 249, vol. No. 122, l.d. 1 - 249, vol. No. 123, l.d. 1 - 246, vol. No. 124, l.d. 1 -
249, vol. No. 125, l.d. 1 - 231, volume No. 126, l.d. 1 - 247, volume No. 127, l.d. 1 - 244, volume No. 128, l.d. 1 - 250,
volume No. 129, l.d. 1 - 243, volume No. 130, l.d. 1 - 236, volume No. 131, l.d. 1 - 135)
- Protocol of the search of 26 May 2021, conducted in the office premises of LLC Investment Company QBF, located at
the address: St. Petersburg, Degtyarny per. 11, Lit B, during which items and documents containing information
relevant to establishing the circumstances of the criminal case were seized;
(Vol. No. 132, pp. 4 - 12)
- Protocol of examination of items and documents dated 21 October 2021, seized on 26 May 2021 in the office
premises of LLC Investment Company QBF, located at the address: St. Petersburg, Degtyarny per. 11, Lit B, during
which items and documents of significance for the criminal case were examined, some of the documents were
(Vol. No. 132, pp. 15 - 28)
- other documents - documents seized on 26 May 2021 in the office premises of LLC Investment Company QBF,
located at the address: St. Petersburg, Degtyarny per, 11, Lit B, including: contracts (draf contracts) for brokerage
services (adhesion contracts) with annexes, which were imposed on clients in order to attract their funds for
subsequent embezzlement; sheets with instructions (offer of co - operation) for newly recruited employees, according
to which the new employees were to attract as much money as possible within 10 months on an accrual basis, i.e. not
less than 40,000,000 roubles in the first month of work and not less than 250,000,000 roubles in the 10th month of
work, as a result of such contracts with individuals; numerous contracts with individuals; numerous contracts with
the following individuals; numerous contracts for the provision of brokerage services (adhesion contracts). with
individuals; numerous lease agreements for premises located in various cities (with additional agreements to the
agreements, acts of acceptance of premises) concluded between LLC KF Estate SPB, represented by the General
Director, including V.S. Pakhomov, and various Companies; lease agreements for premises located in various cities
(with additional agreements to the agreements, acts of acceptance of premises), and various companies; agreements
on the provision of advertising and information services by KF Estate SPB LLC, agreements on advertising campaigns,
agreements on the provision of services for the placement of advertising and information materials on the air of
various radio stations, concluded between KF Estate SPB LLC, represented by its CEO, including V.S. Pakhomov, and
various companies, as well as other documents containing information establishing the circumstances of the criminal
case;
630
(Vol. No. 132, fol. 29 - 242, Vol. No. 133, fol. 1 - 246, Vol. No. 134, fol. 1 - 247, Vol. No. 135, fol. 1 - 248, Vol. No. 136, fol. 1 -
240, Vol. No. 137, fol. 1 - 248, Vol. No. 138, fol. 1 - 250, Vol. No. 139, fol. 1 - 247, Vol. No. 140, fol. 1 - 119)
- Protocol of the search of 26 May 2021, conducted in the dwelling of Spinka R.V. at the address: Moscow, Vinokurova
Street, 10, bldg. 2, sq. 15, during which items and documents containing information relevant to the establishment of
the circumstances of the criminal case were seized;
(Vol. No. 141, pp. 9 - 20)
- Protocol of examination of items and documents dated 29 October 2021, seized on 26 May 2021 in the dwelling of
Spinka R.V. at the address: Moscow, Vinokurova Street, 10, bldg. 2, sq. 15, in the course of which items and documents
relevant to the criminal case were examined, some of the documents were attached to the materials of the criminal
case;
(Vol. No. 141, pp. 24 - 33)
- other documents - documents seized on 26 May 2021 in the home of Spinka R.V. at the address: Moscow, Vinokurova
St., 10, bldg. 2, sq. 15, including: instructions on how to attract and communicate with clients, containing various
psychological techniques on how to quickly and effectively position a person, as well as a list of questions to be asked
to the client in order to create confidence in the reliability of the company (these instructions contain sections,
subsections, including the following abbreviations: "meeting - profiling scheme", "preparation for the meeting"
(informational, emotional, technical), "establishing contact" (plan, approach for making contact at the first meeting),
"identifying needs" (why we ask questions, mitigating questions when identifying needs, creating agreements, verbal
fluff), "basic principles of working with objections", "stages of working with objections", "postponing deals",
"presentation of solutions"); methodological materials in several parts on working with clients, containing similar
instructions on how to work with clients. "QBF's mission", "the role of a financial advisor", "preparing for a meeting",
"establishing contact", "approaches to establishing contact", "identifying needs", "techniques for mitigating questions
when identifying needs", "SPIN technology", "directing questions for investment profiling", "dealing with popular
objections", "investing in other instruments", "postponing deals", "postponing a meeting by phone", "creating
agreements, closing"); step - by - step instructions for managers on how to introduce themselves and communicate
with the client during cold calls, containing 2 scripts of conversation with the client: 1st "calling on behalf of the
manager", 2nd "service call"; basic sales instruction, which includes the following stages: cold call, confirmation of the
meeting, first meeting - building interest and invitation to sign the contract, (sometimes) telephone conversation afer
the first meeting - invitation to the second meeting, second meeting - discussion and signing of the contract, the
actual winding up of the money; numerous reports on the meetings, containing the client's profile data, including
field of activity, solvency, his experience in investment and investment activities, and the client's ability to pay.
(Vol. No. 141, pp. 34 - 250, Vol. No. 142, pp. 1 - 243, Vol. No. 143, pp. 1 - 245, Vol. No. 144, pp. 1 - 126)
- Protocol of the search of 26 May 2021, conducted in the dwelling of R.F. Amerov at the address: 9 Ozernaya St., Q. 30,
Moscow, during which items and documents containing information relevant to the establishment of the
circumstances of the criminal case were seized;
(Vol. No. 144, pp. 203 - 209)
631
R.F. Amerov at the address: 9, Ozernaya Street, Q. 30, Moscow, during which items and documents of significance for
the criminal case were examined, some of the documents were attached to the materials of the criminal case;
(Vol. No. 144, pp. 217 - 222)
- other documents documents seized on 26 May 2021 in Amerov R.F.'s residence at 9, Ozernaya Street, Q. 30, Moscow,
including: loan agreements and additional agreements to them, concluded between KG LLC (the "Lender"),
controlled by the participants of the criminal association (criminal organisation), and Amerov R.F. (the "Borrower"),
evidencing the cashing of funds;
(Vol. No. 144, pp. 230 - 237)
- Protocol of the search of 26 May 2021, conducted in the dwelling of Korzh A.V. at the address: Moscow, Marshala
Zhukova Avenue, 43, bldg. 3, sq. 170, during which items and documents containing information relevant to
(Vol. No. 145, pp. 4 - 12)
- Protocol of examination of items and documents dated 24 September 2021, seized on 26 May 2021 in the dwelling of
Korzh A.V. at the address: Moscow, Marshala Zhukova Avenue, 43, bldg. 3, sq. 170, in the course of which items and
documents relevant to the criminal case were examined, some of the documents were attached to the materials of
the criminal case;
(Vol. No. 145, pp. 18 - 31)
- other documents - documents seized on 26 May 2021 at Korzh A.V.'s residence at the address: Moscow, Marshala
Zhukova Avenue, 43, bldg. 3, kv. 170, including: various contracts, agreements with annexes concluded with
individuals to attract their money under the guise of investment activities, which did not correspond to reality; a loan
agreement concluded between KG LLC (the "Lender"), controlled by the participants of the criminal association
(criminal organisation), and Korzh A. V. (the "Borrower").V. ("Borrower"), which testifies to the cashing of funds, as
well as other documents containing information establishing the circumstances of the criminal case;
(Vol. No. 145, pp. 32 - 212)
- Protocol of the search of 26 May 2021, conducted in the dwelling of Plitin A.A. at the address: Moscow, Beregovoy
proezd, b. 5A, building 6, square 137, during which items and documents containing information relevant to
(Vol. No. 146, pp. 96 - 103)
- Protocol of examination of items and documents dated 10 November 2021, seized on 26 May 2021 in the dwelling of
Plitin A.A. at the address: Moscow, Beregovoy proezd, b. 5A, building 6, sq. 137. 5A, building 6, square 137, in
the course of which items and documents relevant to the criminal case were examined, and some of the documents
(Vol. No. 146, pp. 107 - 114)
632
- other documents - documents seized on 26 May 2021 in Plitin A.A.'s dwelling at the address: Moscow, Beregovoy
proezd, b. 5A, building 6, square 137 , including: a memo "how to behave when detained", containing a 9 - point
algorithm of actions; a memo "how to behave when searched";
(Vol. No. 146, pp. 120 - 121)
- Protocol of the search of 26 May 2021, conducted in the dwelling of Timokhin O.Y. at the address: Moscow region,
Reutov, Oktyabrya street, 44, sq. 552, during which items and documents containing information relevant to the
establishment of the circumstances of the criminal case were seized;
(Vol. No. 146, pp. 129 - 139)
Timokhin O.Y. at the address: Moscow region, Reutov, Oktyabrya street, 44, sq. 552, in the course of which items and
the criminal case. During the examination of the seized phone of Timokhin O.Y., the correspondence in the application
"WhatsApp" was established. Thus, in the application "WhatsApp" it was established the presence of a group with the
name "Vekselnye trasnactionsQ.broker", the date of creation 18.02.2020. In the settings of the said group, at the time
of inspection, the presence of other participants in the number of 7 persons was established, namely: Contact "Alina
Voytenko" labelled "Group Admin" with the subscriber number +79168304119 (there are common groups in
"WhatsApp": "Bills of ExchangeQ.broker" and "Q.broker"); Contact "Madina" labelled "Group Admin" with the
subscriber number +79773316403 (there are common groups in "WhatsApp": "Bills of ExchangeQ.broker",
"QBFIIIRFK_working", "Cash, "VOD on units", "Qbrokerorders", "QBFNews"); Contact "Dasha Filina" with the
subscriber number +79263690779; Contact "Zhenya Rossieva" with the subscriber number +79851734321 (there are
common groups in "WhatsApp": "Bills of exchangeQ.broker", "QBFIIIRFK_work", "Call Paper for safekeeping", "VOD for
units", "Qbroker orders", "QBFNews", "Repo IR", "Repo 2", "Marginalka IR", "CHECK_CBR 2021", "IIIQBFIC work",
"CIIC"); Contact "Katya Kozlova" with subscriber number +79873063946; Contact "Olga Vasyukova" with subscriber
number +79263514595, +79851734321 (there are common groups in "WhatsApp": "Q.broker", "QBFNews", "Repo 2",
"Marginalka ik", "CHECK_CBR 2021", "CIIC"); Contact "Slava" with the subscriber number +79032084077,
+79851734321 (there are common groups in "WhatsApp": "Bill transactionsQ.broker", "QBFNews", "8 March"). In the
course of examination and analysis of correspondence in "WhatsApp" in the group "Bills of exchangeQ.broker" it was
established that the group consisted of accountants and employees of the BEC office, in this group the numbers of
contracts and amounts of money to be transferred within the framework of transfer of promissory notes between the
organisations controlled by the participants of the criminal community (criminal organisation), including JSC "FG
QBF", PJSC "Venture Finance Centre". In the course of examination and analysis of correspondence in the application
"WhatsApp" with the contact "PB" with the subscriber number +79057355588, belonging to Roman Valeryevich
Shpakov, it was established that in the correspondence dated 30.06.2020 Timokhin explains that taking into account
the shown profitability of clients of LLC Q.Broker, in the near future there will be no money lef in the portfolio of LLC
Q-BROKER for settlements with clients, in view of this, operations with promissory notes were suspended. In the
correspondence dated 20.10.2020 with the contact "PB" Timokhin explains that he receives instructions from Linda to
transfer funds to CI (Constance Investment) and to buy Argento bonds, Timokhin asks whether Shpakov is aware of
these transactions, to which Shpakov replies that these are his (Shpakov's) instructions and Linda simply broadcasts
them. In the correspondence dated 01.12.2020 with the contact "PB" Shpakov asks how much money is on the master
agreement on the account of Q-BROKER LLC, and then instructs Timokhin to purchase units. From the whole
conversation with the contact "PB" with the subscriber number +79057355588 it is established that it is impossible to
dispose of the funds on the accounts of the clients of LLC "Investment Company QBF" for investing in other sectors,
but it is possible to use the funds transferred under the General Agreement (framework agreement) to the accounts of
LLC "Q.Broker" at one's own discretion. It also follows from the correspondence with the contact "PB" that the
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distribution of funds received from clients under the IPO to LLC "Q.Broker" was handled directly by R.V. Shpakov.
During the inspection and analysis of correspondence in the application "WhatsApp" it was found that there was
correspondence with the contact "Stanislav Matyukhin" with the subscriber number +79262320192, it follows from
the correspondence that Stanislav Matyukhin notifies Timokhin that it is necessary to carry out a transaction to
transfer funds from the account of LLC "Q. Broker" to the account of Argento (Argento).Broker to Argento account (on
this basis, this information on Timokhin's phone refutes S.A. Matyukhin's testimony that he was unaware of the
activities of Q-BROKER Ltd. During the inspection and analysis in the application "WhatsApp" it was found the
presence of a group with the name "CI IR", which was created on 02.10.2020 by the user "Nastya Koval". At the time of
inspection, the presence of other participants in the number of 9 accounts was found: "Nastya Koval" with the
subscriber number +79266900607, who is the "Group Admin"; "Stanislav Matyukhin" with the subscriber number
+79262320192, who is the "Group Admin"; "Linda" with the subscriber number +735799920015, who is the "Group
Admin"; "Vlada" with subscriber number +79690879115; "Zhenya Rossieva" with subscriber number +79851734321;
"Katya Gramza" with subscriber number +79057377878; "Miroslav" with subscriber number +79237776976; "Olga
Vasyukova" with subscriber number +79263514595; Account "~DL" with subscriber number +79252767971. In the
course of inspection and analysis of the chat of the group with the name "CI IR", it was established that on 07.10.2020,
in agreement with Matyukhin, Linda requests to transfer funds from the brokerage account of Q-BROKER LLC to
Constance for the purchase of Argento bonds. In addition, there is coordination between the group members to make
a payment from Q-BROKER LLC to Constance for the purchase of Argento bonds, Matyukhin also coordinates the
transaction. In the course of analysis of the correspondence of the chat group with the name "CI IC" for 15.10.2020 it
was found that the participants of the group coordinate the payment from Q-BROKER LLC to Constance for the
purchase of Argento bonds, Matyukhin also coordinates the operation. In the course of analysing the chat
correspondence of the group named "CI IC" for 20.10.2020, it was established that in fact there is a discussion
between the group members, and in particular between Rossieva and Linda, about the interest rates of the currency
products within the framework of which Q-BROKER LLC transfers funds to CI (Constance). Linda explains that the
interest rate is 1% per year. To which Rossieva spells out that this is factually incorrect and this transaction cannot
carry an economic benefit to Q-BROKER LLC, as Q-BROKER LLC pays clients 4 - 6% per year. To which Linda replies
that it's all even, and let them leave in the contract the figure that was previously indicated in the amount of 5%. Thus,
this discussion further confirms that Rossieva was aware that there was no economic benefit in transferring money
abroad. In the course of the inspection, other correspondence was discovered, as listed in the inspection report,
which is of significance and establishes the circumstances of the criminal case;
(Vol. No. 146, pp. 142 - 232)
- other documents - documents seized on 26 May 2021 in Timokhin O.Y.'s home at the address: 44, Oktyabrya St.,
Reutov, Moscow Region, Q. 552, including: the job description of the Head of the Department for Support of
Professional Activities on the Securities Market - Timokhin O.Y., approved by the Director General of QBIF Investment
Company LLC S.A. Matyukhin;
(Vol. No. 146, pp. 233 - 239)
- Protocol of the search report of 26 May 2021, conducted in the dwelling of Lepeshkin D.S. at the address: 7, Mytnaya
St., Moscow, p. 1, sq. 316, during which items and documents containing information relevant to the establishment of
the circumstances of the criminal case were seized. 1, flat 316, in the course of which items and documents
containing information relevant to establishing the circumstances of the criminal case were seized;
(Vol. No. 147, pp. 7 - 14)
Lepeshkin D.S. at the address: Moscow, Mytnaya Street, 7, p. 1, sq. 316. 1, flat 316, in the course of which items and
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the criminal case. During the examination of the seized phone of Lepeshkin D.S., correspondence in the application
"WhatsApp" was established, including chat correspondence of subscriber "DL" with subscriber "Linda CY"
(subscriber number +357 - 96 - 09 - 22 - 15), during the analysis of which the following was established. The mentioned
subscribers discuss the possibility of sending a letter on behalf of "Argento", accounting of securities in the context of
the planned purchase on behalf of "Argento", exchange rates, purchase of a flat and a car (in confirmation of this,
subscriber "DL" sends a photo of a new car "BMW X6", subscriber "Linda CY" sends a photo of the screen with the
image of the programme "Calculator" with arithmetic operations: "2,031,350 - 70,001,736= - 67,970,386", with
comments from subscriber "Linda CY": "The sum is for the flat, the extra should be taken from the envelope and it is
for the car", afer which the above subscribers discuss how to explain the origin of the money to Sberbank
representatives, in the end, the subscriber "Linda CY" offers a version - "Family savings, my mother has been saving
for many years, she saved for a long time"), also in the correspondence the subscribers discuss Arsenchuk, the need
to collect 1.6 million in currency in an unnamed place. In the course of further correspondence subscriber "Linda CY"
informs: "...there is no money there, they all withdraw to bitcoin", they discuss Qbroker (qbroker), subscriber "DL" in
correspondence informs: "...that he wants to sell our product and work normally, legally". Further, in correspondence
for 05.04.2021, subscriber "Linda CY" sends a PDF file with the title "Central Bank Precept 01.04.2021 IPO" (in the
course of inspection and analysis it was found that this file contains the Bank of Russia's instruction to provide
information from QBIF LLC, including: a reference describing a detailed scheme to provide clients with a service to
participate in the initial public offering of companies' shares on foreign exchanges, including by providing an
opportunity to enter into OTC option contracts (IPO), with the provision of all supporting documents, including
information on companies that are counterparties to OTC option contracts and (or) financial instruments. Afer
sending this file, DL and Linda CY subscribers begin to actively discuss: "a scheme for the regulator, according to
which it is necessary to remove the loss by shifing it to other LLCs", also discussed is "a scheme with the resale of
bonds with a mark - up to the counterparty", also proposed is "a scheme with the production of an OTC contract for
something (the subject of the contract is proposed to be discussed later), under which the counterparty owes QBroker
an amount (underlying asset), with the subsequent transfer of bonds to the counterparty as collateral, and as a result
- the asset has grown, the rates set by QBroker have worked, the counterparty owes QBroker that will close the loss",
along with this subscriber "Linda CY" reports that it is necessary to somehow remove "Argento" from this whole story.
At the same time, subscribers "DL" and "Linda CY" discuss in their correspondence for 05.04.2021 that these options
should be discussed with Katya, Zhenya, and Stanislav. Thus, during the analysis of the correspondence for
05.04.2021 it is established that subscribers "DL" and "Linda CY" develop an algorithm of interaction with the Bank of
Russia, as well as a mechanism for providing the Bank of Russia employees with information and documents
necessary to give the appearance of legality of criminal activity and prevent the exposure of criminal activity of a
criminal association (criminal organisation). In this case, Katya, Zhenya and Stanislav referred to in the
correspondence are probably Gramza, Rossieva and Matyukhin. In the correspondence for 07.04.2021, the subscriber
"Linda CY" sends an xlsx file containing a tabular list of 79 clients with the clients' data and the amounts of money for
each client, totalling 9,918,627.53 USD. In the course of the inspection, other correspondence was found that is of
significance and establishes the circumstances of the criminal case;
(Vol. No. 147, pp. 17 - 86)
- other documents – documents seized on May 26, 2021 in the home of D.S. Lepeshkin at the address: Moscow,
Mytnaya Street, 7, bldg. 1, room 316, including: numerous loan agreements, share purchase and sale agreement,
agreement on investment activity rating analysis, assignment agreement (agreement on legal assistance), agreement
on purchase and sale of investment units, agreement on assignment of rights (claims) and set - off of counter
homogeneous claims, as well as related documents to the above contracts (agreements) concluded between
controlled individuals and legal entities (including: Kyubi Group LLC, Kyubi Finance LLC, M4 Invest LLC, M1 Invest LLC,
SeverSpecStroy LLC, Constance Investment LTD ("Constance Investment LTD"); various documents in relation to NOA
LLC; numerous statements by Lepeshkin D.S. for the transfer of large sums of money from a foreign currency account
635
to foreign banks; operational assistance agreements under which R.V. Shpakov transfers to Constance Investment LTD,
represented by Linda Athanasiadou, funds in the amount of EUR 160,000 and EUR 200,000 as financial assistance;
(Vol. No. 147, pp. 87 - 248)
- Protocol of the search of 26 May 2021, conducted in the Mercedes - Benz car used by Lepeshkin D.S., located at the
time of the search at the address: 7, Mytnaya Street, Moscow, p. 1. 1, during which items containing information
relevant to establishing the circumstances of the criminal case were seized;
(Vol. No. 148, pp. 29 - 34)
- Protocol of examination of items and documents dated 06 October 2021, seized on 26 May 2021 in the car used by
Lepeshkin D.S., located at the time of the search at the address: Moscow, Mytnaya Street, 7, p. 1. 1, during which the
seized items relevant to the criminal case were examined. During the examination of the seized phone of Lepeshkin
D.S., correspondence in the application "WhatsApp" was established.
A group chat correspondence named

was found between subscriber "DL", subscriber "Linda CY" having subscriber number "+357 - 96 - 092215", subscriber
"Evgeniya Rossieva" having subscriber number "+7 - 985 - 173 - 43 - 21", with whom the following correspondence was
carried out:
[10.03.2021, 20:45:23] Linda CY changed the subject to "QbrokerArgento"
[10.03.2021, 20:45:25] Linda CY added by.
[10.03.2021, 20:45:25] Evgeniya Rossieva added(s)
[10.03.2021, 20:45:33] Linda CY: Hi, Jen.
[10.03.2021, 20:46:09] Linda CY: We need to think about where to pass on the qbroker commitment
[10.03.2021, 20:46:15] Linda CY: Or rather aggento.
[10.03.2021, 20:46:32] Linda CY: Since the repayment of nothing is coming soon
[10.03.2021, 20:46:40] Linda CY: We have to give some promissory notes in return.
[10.03.2021, 20:47:28] Linda CY: What are your options?
[10.03.2021, 20:47:36] Eugenia Rossieva: Now - none
[10.03.2021, 20:47:39] Linda CY: Roman told you to write and decide.
[10.03.2021, 20:47:46] Eugenia Rossieva: Because I just heard about it now
[10.03.2021, 20:47:53] Linda CY: Oh yeah)
[10.03.2021, 20:47:57] Linda CY: That's what I wrote to you.)
[10.03.2021, 20:48:08] Linda CY: Since the banks will now start selling this product
[10.03.2021, 20:48:15] Linda CY: Roman is interested in him
[10.03.2021, 20:48:25] Linda CY: And said to close the commitment issue
[10.03.2021, 20:48:38] Linda CY: Should we give them Lameranotes?
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[10.03.2021, 20:48:42] Linda CY: Promissory Note.
[10.03.2021, 20:48:54] Eugenia Rossieva: Qbroker - y?
[10.03.2021, 20:49:12] Linda CY: What do you mean?
[10.03.2021, 20:49:44] Eugenia Rossieva: Sorry I do not understand the scheme to the end. It's just that you are in the
know you understand, I don't ((((
[10.03.2021, 20:50:38] Linda CY: So qbroker poked Argento
[10.03.2021, 20:50:46] Linda CY: Send in the time of cancellation.
[10.03.2021, 20:50:52] Linda CY: No money.
[10.03.2021, 20:52:09] Eugenia Rossieva: Do you have non - monetary options on the terms?
[10.03.2021, 20:52:21] Linda CY: I'll get you on the phone.
[10.03.2021, 20:52:24] Linda CY: Now?
[10.03.2021, 20:52:25] Eugenia Rossieva: This is not a good situation for qbrojer
[10.03.2021, 20:52:33] Eugenia Rossieva: I'm barely alive
[10.03.2021, 20:52:38] Eugenia Rossieva: I (foul language)
[10.03.2021, 20:53:01] Linda CY: If Argento does not pay the DC, the situation will be catastrophic for qbroker
[10.03.2021, 20:53:17] Linda CY: So instead of bonds, they will get promissory notes
[10.03.2021, 20:53:26] Linda CY: There are no other options.
[10.03.2021, 20:55:17] Eugenia Rossieva: Let's discuss tomorrow go it's straight urgent urgent urgency
[10.03.2021, 20:55:25] Eugenia Rossieva: We're calling tomorrow, right?
[10.03.2021, 20:58:50] Linda CY: Tomorrow. Yeah, it's not urgent, I'll give you that.
[10.03.2021, 21:11:15] Eugenia Rossieva: Thank you
Also during the examination of the phone a group chat with the name "NOA Circle<>ArgentoAcc" between subscribers
"DL" , subscriber "Linda" having subscriber number "+357 - 99 - 920015", subscriber "Kirill Oleshko" having subscriber
number "+357 - 97 - 754954", the subscriber "BD", having the subscriber number +44 - 7801 - 9332 - 88, the subscriber
"Amy Orivel", having the subscriber number +44 - 7895 - 80 - 7799, the subscriber "PM", having the subscriber number
+44 7903 - 5622 - 16. During the inspection and analysis of this correspondence, it was found that the group members
discuss the following, namely: the possibility of receiving money from individuals from the Russian Federation; details
of "White Lake Management LTD."; preparation of bonds and development of a bond programme, which is a lake in
England; presentation of "Argento". In the course of the inspection other correspondence, given in the protocol of the
inspection, which is of significance and establishes the circumstances of the criminal case, was found;
(Vol. No. 148, pp. 41 - 72)
- Protocol of the search of 26 May 2021, conducted in the premises occupied by NOA LLC at the address: Moscow,
Khilkov Lane, 1, sq. 19, during which documents were seized in relation to Simon Jesso LLC, M1 Invest LLC, 168
Kvartal LLC, KP Queue 2 LLC, KP Queue 3 LLC, KP Queue 4 LLC, controlled by the participants of the criminal
association (criminal organisation), as well as items containing information relevant to establishing the circumstances
of the criminal case;
637
(Vol. No. 148, pp. 76 - 92)
- Protocol of examination of items and documents dated 15 October 2021, seized on 26 May 2021 in the premises
occupied by NOA LLC at the address: Moscow, Khilkov per, 1, sq. 19, in the course of which the seized items relevant to
the criminal case were examined, including: the seal of Constance Investment LTD ("Constance Investment LTD",
registration number HE 333743); an iPhone8 Plus mobile phone, model number "MQ8Q2B\A", account ID "Alexander
Nepomnyashchiy", [email protected]. During the examination of the seized phone of A.V. Nepomnyashchiy,
correspondence in the application "WhatsApp" was established. The correspondence was found with the contact
"Linda Athanasiades", having the user name "Linda Athanasiades" and the subscriber number "+7 - 357 - 96 - 092215,
+7 - 903 - 287 - 92 - 98". During the examination and analysis of this correspondence it was established that the
subscribers discuss, among other things: payment in cash for rent in Moscow City without actual contractual
relations; the nominal position of director in "NOA" held by Zelimkhan, as well as the latter's answers to the
authorities (presumably the internal affairs authorities); the transfer of cash in currency, as well as the transfer of
funds to the accounts of Athanasiadoues Linda; the problem of non - payment for the service of opening an account
for a foreign company - "Lamera". In addition, during the examination of the seized phone of A.V. Nepomnyashchy, a
correspondence with the user name "Apollon Athanasiades" and the subscriber number "+35796218890, +7 - 985 -
303 - 06 - 70" was found. During the inspection and analysis of this correspondence it was found that the subscribers
discuss, among other things: a company in the British Virgin Islands; Cyprus, Israeli, Latvian Banks; the possibility of
cashing money in Crimea and the amount of interest for this service; the possibility of opening accounts for
organisations in foreign countries; the possibility of registering a fund in the Cayman Islands; the maintenance and
servicing of various (in priority cheap) offshore companies. In the course of the inspection, other correspondence was
found, as listed in the inspection report, which is of significance and establishes the circumstances of the criminal
case;
(Vol. No. 148, pp. 98 - 233, Vol. No. 149, pp. 1 - 242)
- Protocol of the search of 30 November 2021, conducted in the office premises of LLC Investment Company QBF at 12
Presnenskaya Naberezhnaya Street, 22nd floor, Moscow, during which items containing information relevant to
(Vol. No. 150, pp. 4 - 10)
- Protocol of examination of items and documents dated 06 February 2022, seized on 30 November 2021 in the office
premises of LLC "Investment Company QBF" at the address: Moscow, Presnenskaya Naberezhnaya, 12, 22nd floor, in
the course of which the seized items relevant to the criminal case were examined, including a mobile phone "iPhone
12 Pro Max", model number "MGDA3RU/A, ID: "Stanislav Matyukhin" "[email protected]".
During the examination of the seized phone of S.A. Matyukhin, a correspondence in the application "WhatsApp" dated
from 31 May 2021 was established. During the examination and analysis of the correspondence, it was established
that S.A. Matyukhin was in regular contact with R.V. Shpakov, S.A. Matyukhin and R.V. Shpakov discuss the algorithm
of alienation of assets, taking into account the crisis situation of QBF group of companies and the seizure of some
assets, in the correspondence R.V. Shpakov additionally refers to the fact of monetary value of QBF group of
companies. additionally refers to the fact of monetary remuneration as a result of execution by S.A. Matyukhin of
instructions of R.V. Shpakov. It also follows from the correspondence that S.A. Matyukhin informed R.V. Shpakov about
all financial and economic activities of QBF group of companies afer the searches conducted on 26 May 2021, as well
as about the working activity of the temporary manager of LLC "IC QBF" - Y.V. Dronov, discussed the actions of other
managers, Shpakov R.V. and Matyukhin S.A. in correspondence discuss ways of resolving issues with problematic
(media) applicants (in particular Anastasia Volochkova). In addition, during the inspection and analysis of the
638
correspondence it was established that S.A. Matyukhin communicated with the representative of the defendant Z.V.
Munayev in order to transfer the information received from the said representative to R.V. Shpakov and vice versa,
including on the issues of the remaining unarrested property and interaction with the defendant Z.V. Munayev, who is
in the remand centre. In addition, S.A. Matyukhin in his correspondence with the BL contact discusses clients and
their problems regarding the relationship with Q-BROKER LLC and the inability of the said company to fulfil its
obligations to clients. S.A. Matyukhin in correspondence with the contact "Yuri Orlov" discuss the need to sign
documents from Q-BROKER LLC for the transfer of assets of QBIF Investment Company LLC, and also discuss the
algorithm of selling units on behalf of Q-BROKER LLC to a natural person who should resell these units to another
natural person in Otkritie (during the preliminary investigation it was established that Q-BROKER LLC (INN ) is a
private individual who should resell these units to another natural person in Otkritie).Broker" (TIN 9703003668) had a
personal account B00004365 opened with NCO JSC "National Settlement Depository", which as of 31 May 2021. There
were 336385, 24 units (issuer - ZPIF of real estate "Rif Mixed Federal 2 qual"), which later with the purpose of
alienation of property in favour of third parties were re - registered in various depositories, including in the
depositories of LLC "Investment Company QBF" (INN 7733673955) and PJSC Bank "FC Otkrytie". Thus, on the basis of
the order for writing off the client (depositor) Tallerov Artem Olegovich (who is a controlled and trusted person of the
participants of the criminal association headed by the accused Shpakov R.V.) No. 1 dated 07 July 2021, securities of
the real estate ZPIF "Rif Mixed Federal 2 qual" in the amount of 336385, 24 pieces were written off in JSC Otkritie
Broker). During the examination and analysis of S.A. Matyukhin's phone, a correspondence with the subscriber
"Linda" with the number +357 - 96 - 09 - 22 - 15 was also found. In this correspondence, S.A. Matyukhin and the
subscriber "Linda" discuss the problems of LLC IC QBF, LLC Q.Broker, as well as the relationship of these companies
with Argento, Purity, Falco, Constance. Also during the examination and analysis of S.A. Matyukhin's phone a
correspondence with the subscriber "Vlada Butkovskaya" with the number +7 - 969 - 087 - 91 - 15 was found. In this
correspondence from the subscriber "Vlada Butkovskaya" Matyukhin S.A. received the following message: "This
appeal was made by QBF employees. I kept silent for a long time in the hope that maybe something will change. But it
is obvious that nothing will change. Dear partners and colleagues, We all know that on 25 May 2021 searches took
place in the Moscow office of QBF LLC, whose clients are many of us, both directly and indirectly through financial
advisors. As it became known afer the investigative measures, a criminal case under part 4 of article 159 of the
Criminal Code - "Fraud committed by an organised group on a particularly large scale" was initiated against the
company back in April 2021. Since 25 May, the company has stopped fulfilling its obligations related to the payment of
funds, except for the cases when clients' money is in the accounts of the National Settlement Depository (NSD), to
which the company fortunately does not have access. As you know, the proofs of non - fulfilment of obligations are
the mass replies of the company from the official e - mail address [email protected] with the refusal to execute our
orders for withdrawal of funds. The motivation of the refusal is as follows: "insufficiency of funds at the Counterparty -
Q-BROKER LLC". According to extracts from the Unified State Register of Legal Entities (USRYUL), which you can get
within 1 minute by TIN on the site of the Federal Tax Service of Russia: www.egrul.nalog.ru, LLC IC QBF (TIN
7733673955) and LLC Q-BROKER (TIN 9703003668) have 100% of the same founder: JSC Financial Group QBF (TIN
7703466327). In accordance with Article 105.1 of the Tax Code, interdependent persons are: organisations if one and
the same person directly and (or) indirectly participates in these organisations and the share of such participation in
each organisation is more than 25 per cent. Such companies are also called affiliated companies. In our case, QBF IK
LLC and Q-BROKER LLC are affiliated persons, and in fact they are the same company: one address, one founder. Thus,
the company, refusing to execute your orders with reference to non - fulfilment of obligations by the "counterparty",
deliberately and intentionally misleads everyone, pursuing its own goals. Speaking about the company's goals, we
should take into account the information received from the dismissed employees of QBIF LLC: the employees were
demanded to persuade clients to transfer funds from NSD to the company under any pretexts, since the company
cannot dispose of the money from NSD, but it can and very much wants to do so on its own accounts. For this reason,
in August 2020, the company came up with a rule that in order to participate in the IPO, the client must transfer their
cash from NSD to the company. And as we know, the IPO is the company's main "product". In 2021, already knowing
that it would be impossible to meet the demands of all its clients, the company deliberately continued to transfer
money from NSD to its accounts. These circumstances, as you understand, directly testify to the company's real
intentions - to receive maximum cash and be able to dispose of it. Now, the company offers us to supposedly
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"prolong" the term of fulfilment of its monetary obligations for 3 or 6 months. Let's think, why such terms? According
to Article 3 of the Federal Law "On Insolvency (Bankruptcy)" the signs of bankruptcy are: inability to satisfy the claims
of creditors on monetary obligations, if the corresponding obligations are not fulfilled within three months from the
date when they should have been fulfilled. Thus, there are good reasons to believe that the "prolongation" of
fulfilment of obligations is necessary for the company to withdraw assets (our money) and create conditions for
bankruptcy of the company and its "counterparty" - Q-BROKER LLC. Now it should be clearly understood and realised
that the return of our money depends on coordinated, joint and prompt actions. In case we allow the company to
withdraw assets and "go" into bankruptcy, the return of our money will be simply impossible. By acting now and
together, within the law, we have a real opportunity to prevent the withdrawal of assets and get our money back. If we
collectively apply to the court for protection of our interests, we have the right to demand the imposition of interim
measures - seizure of assets of the company and its "counterparty", blocking of accounts, as well as prove that LLC IC
QBF and LLC Q-BROKER are one person and are jointly and severally liable to us to return our money. There is no
sense to build illusions about "prolongation" of obligations with a company, if such a company, even when dismissing
its employees, does not pay their salaries for more than 2 months. Now it is absolutely obvious and very clear to
everyone what the real goals of the company are. Let's act!". In addition, in the correspondence between S.A.
Matyukhin and the subscriber "Vlada Butkovskaya" they discuss the problems of LLC "IC QBF", LLC "Q.Broker",
including the inability to fulfil obligations to their clients, they also discuss the appointment of a new general director
of the controlled PJSC "CEF", as well as the activities of other controlled and affiliated legal entities, including LLC
"Management Company "Moi Finansy", LLC "702", discuss the transfer of assets of LLC "Q.Broker". The inspection
revealed other correspondence cited in the inspection protocol that is of significance and establishes the
circumstances of the criminal case;
- Protocol of seizure dated 25 May 2022, conducted at the home of S.A. Matyukhin, during which a mobile phone
"iPhone 7" belonging to the latter was seized, containing information relevant to establishing the circumstances of
the criminal case;
(Vol. No. 302, pp. 63 - 66)
- Protocol of examination of items seized from S.A. Matyukhin dated 25 May 2022, during which the mobile phone
"iPhone 7", serial number DX3XGGV6HG6W, belonging to S.A. Matyukhin was examined. During the examination of the
seized phone of S.A. Matyukhin, a group "Smoke hookah" was found in the messenger "Telegram", consisting of 8
participants (Yuri Orlov, Andrey Korzh, Artem Tallerov, Kristina Bogdanova, Vladimir Maslennikov, Maxim Fedorov,
Ruslan Spinka, the period of receipt of text messages from 01.12.2021 to 25.05.2022). These group members discuss in
text messages, among other things: the activities of the Companies controlled by the participants of the criminal
association (criminal organisation) - LLC MC Granat, LLC Q.Broker, LLC IK QBF; ways of liquidating the company and
attracting a nominal general director and his subsequent actions. In the course of the inspection, other
correspondence was found that is given in the inspection protocol, which is of significance and establishes the
(Vol. No. 302, pp. 67 - 95)
- Material evidence - a mobile phone "iPhone 7", serial number DX3XGGV6HG6W, belonging to S.A. Matyukhin, seized
on 25.05.2021 during the seizure;
(Vol. No. 302, pp. 96 - 97)
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- Protocol of the search of 26 May 2021, conducted in the dwelling of E.A. Rossiyeva at the address: 4, Udaltsova
Street, Moscow, room 230, during which items and documents containing information relevant to establishing the
circumstances of the criminal case were seized;
(Vol. No. 154, pp. 7 - 14)
- Protocol of examination of items and documents dated 11 February 2022, seized on 26 May
2021 in the dwelling of E.A. Rossieva at the address:
Moscow, Udaltsova Street, 4, sq. 230, during which the seized documents and items relevant to the criminal case were
examined, including a laptop, S/N: FVFCT3FXM6KK, information about the AppleID account: "EugeniaRossieva"
"[email protected]". When examining the contents of the examined laptop, it was found that the application
"MicrosofOutlook", which is a mail client, was installed on the device. The subdirectory of the mail client contains
information about the user of the account: "[email protected]", and the user name column contains information:
"bsdm\evgeniya.rossieva". During the examination of the said mail client, mail messages of significance for the
criminal case under investigation were found.
In the course of examination and analysis of mail messages, correspondence with the respondent "Vlada
Butkovskaya" was established, from which it follows that employees of LLC Investment Company QBF, including
Evgeniya Rossieva, Stanislav Matyukhin, Vlada Butkovskaya, Oleg Timokhin discuss the mechanism of purchase and
sale of securities between legal entities controlled by the participants of the criminal association (criminal
organisation) (JSC Financial Group QBF, PJSC Venture Finance Centre) and natural persons (Spinka R.В., Maslenikov
V.A., Fedorov M.S.) in the absence of economic expediency (as the above persons themselves discuss in their
correspondence).
In the course of examination and analysis of mail messages a correspondence with the respondent "Artur Avanesyan"
was established, from which the following dialogue follows between the employees of "QBIF Investment Company"
LLC Artur Avanesyan and Evgenia Rossieva: "Zhen, on Dianov. It is necessary to make on 706 197 $. He needs to load
units at the Central Bank rate. It should be spelled out in this wording. Any unit price. ... There's no point in putting
him the units first and redeeming them right away. Just at the signing he will receive a part in money, a part in units
and for a part of units - a buyback" (during the preliminary investigation it was established that Dianov E.G. is a victim,
who actively conducted claim activity on return of his stolen money with employees of LLC "Investment Company
QBF", the analysis of the mentioned correspondence shows that Rossieva E.A. developed a mechanism of settlement
of situations with conflict clients, by means of only partial return of money, in order to prevent the appeal to law
enforcement agencies, in order to prevent the appeal to the law enforcement agencies.
In the course of examination and analysis of mail messages, correspondence with the respondent "Alex Tregubov"
was established. In the course of examination and analysis of mail messages with the said respondent,
correspondence between employees of QBIF Investment Company LLC, including Evgenia Rossieva, Georgy Dandov,
Anastasia Koval, Vladislav Pliteni was established as follows: "there are questions about Q.Broker's business model.
They want confirmation that we will use only our own funds (of course I will write it to them nicely))). + they are trying
to understand what Q-BROKER does and what its business model is. This issue is more complicated and we need to
provide a beautiful description. It is necessary to add the history with IC, but very carefully, otherwise they will have a
logical question - why not IC opens an account. We can say that the IC does not have free capital and resources for
normative trading in financial assets with a risk higher than the minimum (our Central Bank is evil and current
requirements force to reserve heavily, etc.). The shareholder's decision not to additional capitalise the IC, but to
create a legal entity K.Broker, which will invest on its own resources (including here can be attracted income from
third - party business enterprises to preserve and multiply capital) + as a business model can be specified that
K.Broker acts as a friendly enterprise for the IC in terms of providing liquidity. Repo, etc. The shareholder has already
contributed a substantial amount of assets and in case of success of the business model, investments in the
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company's funds will increase" (this correspondence shows only that the activity of QBroker LLC, by deceiving
investors in order to attract as much money as possible, tried to pass off as legitimate and profitable, which did not
correspond to reality). In addition, in correspondence with the respondent "Alex Tregubov" there are attached
documents, which were presented to clients for signing in order to subsequently receive money from them and make
them look like legitimate activities, including: draf agreements on the provision of services on behalf of
"Simtelligence Company Limited" ("Simtelligence Company Limited") represented by General Director Korshunov
D.A.; draf determination on cancellation of the agreement on provision of services of direct access to international
stock markets on behalf of QCCI LTD represented by Gorobets E.V.; draf agreements on the order of fulfilment of
obligations on behalf of "QBroker" Ltd.; draf agreements on the procedure of fulfilment of obligations under the
agreement on provision of services on behalf of QBIF LLC; draf agreements on assignment on behalf of Simtelligence
Company Limited represented by General Director Korshunov D.A. and on behalf of QBIF LLC. and on behalf of QBF
LLC; a draf statement by the client that he has no claims in relation to the appeal submitted to the Bank of Russia in
respect of QBF Investment Company LLC and that he withdraws his appeal to the Consumer Rights Protection and
Financial Services Availability Service of the Bank of Russia in respect of QBF Investment Company LLC. Also in the
correspondence with the respondent "Alex Tregubov" there is a letter of the following content: "1. Clause 6 of the
Assignment Agreement has been changed by us in your interests. In order for you to be able to "clear" the liabilities
and risks of Qubeef LLC, and transfer everything back to the company in Hong Kong. If you don't want it - delete it, we
don't want it even more. We don't need it. 2. Agreement on the order of fulfilment of obligations. We are prepared to
agree provided that the performance agreement should refer to or link to the Assignment Agreement. It is important
to understand exactly what obligations are being honoured. Suggest wording, simply referring to the Assignment
Agreement as it stands does not suit us. The contract assignment is made in respect of all obligations, it explicitly says
so. The subject matter of the dispute and your doubts are not clear. 3. The main misunderstanding that now arises on
your Side relates to the provisions that you present as assignments. We already have Russian jurisdiction, both
principals (Tregubov, Shestakov) have direct contracts with IC, both have more than comfortable withdrawal terms.
We have not signed anything that transfers the obligation with the IC. Thus, you are not giving us anything beyond
what we already have. On the contrary, our situation is getting worse. All we need is a mechanism that fully
guarantees actual deadlines. Since 04.06.2018, when the reorganisation of the IC in the form of a spin - off was
completed, all contracts have been transferred to QBF Ltd. Signature - consent of the client was not required for this
(Civil Code of the Russian Federation). DB and FTS were notified about the procedure, publications were made in the
Gazette and the Unified State Register of Legal Entities, the procedure was carried out in full compliance with the law.
Before the transfer of funds you receive the following: withdrawal of the Central Bank complaint + fully signed set of
documents + final withdrawal of the IC from the agreement. Fully signed set of documents is necessary for correct
registration of all relations - it is in the interests of all parties. Withdrawal of the complaint is a consequence of the
agreements reached, not a condition on our part. At the same time, there are no grounds for a complaint for all the
reasons mentioned above. Sending the complaint and using its withdrawal as a condition for reaching agreements is
an artificially created manipulation. What you are proposing now is simply to transfer the debt to an LLC with
authorised capital of 10 thousand roubles. No Russian jurisdiction will be of any use to us in case of failure to meet the
deadlines for withdrawal of funds by this LLC. Now we have a contract with IC (see authorised capital) and Russian
jurisdiction + CB. The only problematic point is the uncertainty of withdrawal terms, due to the failure on your side -
the delay is already more than 8 (!) months. The party to the assignment agreement is QBF Ltd (the result of
reorganisation). Payment was made by you to the foreign company under the contract concluded with it, there are no
grounds for making claims against EC. Under the proposed terms you receive an unambiguous unconditional
obligation to pay on the part of the Russian company, with jurisdiction in the Russian jurisdiction. 4. Given this, a
surety is not excessive, but essentially the only way for your Party to find a solution, especially since the negotiations
explicitly mentioned the possibility of involving group companies to create guarantees for us. If you have alternative
proposals that would give us such guarantees, we would be happy to consider them, suggest them. The impossibility
of involvement was explicitly stated. We will have a signed unambiguous unconditional obligation to pay (obliged
person, amount and terms). Guarantees are unnecessary. You on your part cannot give us any guarantees about non -
abuse. 5. Confidentiality - OK. The outcome of the negotiations is to reach a compromise, please note that. Early
agreement will allow for sooner implementation." (this correspondence indicates that the participants of the criminal
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association (criminal organisation) have developed conspiracy measures to conceal the criminal activity of the
criminal association (criminal organisation) from exposure by law enforcement officers, to develop a mechanism for
resolving problematic situations that arose in the course of inspections and supervision of the Bank of Russia, in
addition, analysis of this correspondence indicates that the participants of the criminal association (criminal
organisation) have created a legal mechanism for transferring the debt to the Bank of Russia.
In the course of examination and analysis of mail messages, correspondence with the respondent "[email protected]"
was established. In the course of inspection and analysis of mail messages with the said respondent, correspondence
between employees of QBIF Investment Company LLC, including Evgenia Rossieva, Zelimkhan Munayev, Maxim Yudin,
Ruslan Spinka was established as follows: "Dear Colleagues, At your request, I am sending Adv's assignment
agreement with an addition made - wording added to clause 9.4 (see below and attachment - highlighted in colour).
Please note the following: It is not necessary to make additions to the supplementary agreements as the contract
prescribes the general rule. A reservation is made that if "duplicate" expenses/payments/fees/commissions are not
stipulated byAdv, they do not reduce anything (e.g. according to certain MAs there is no management fee - there is
nothing to deduct from). Please evaluate the wording, including from the point of view of "understandability" for the
client - ready to answer all questions and, if necessary, to clarify / change. p.s. the company is WL. 9.4. The Principal
shall bear all expenses related to the execution of the order, execution of transactions, servicing of the trading
account, including various commissions and fees, including, but not limited to, commissions of such counterparties
as: stock exchanges, depositories, registrars, brokers, custodians and nominee holders. Expenses shall be deducted
from the Principal's funds in the trading account or, in case of insufficient funds in the trading account to reimburse
the expenses, shall be paid by the Principal. Commissions, special fees and remuneration paid directly by the
Principal to the Company (including by the Company withholding the relevant amounts from the Principal's funds) in
accordance with the Agreement concluded between the Principal and the Company, including management fees,
success fees, entry fees, early withdrawal fees for the provision of services by the Company, shall not be included in
the relevant amounts of expenses, commissions, special fees and remuneration to be reimbursed by the Principal to
the Attorney from the Principal. Sincerely, Evgenia Rossieva Director of QBF Legal Department". Also in the
correspondence with the respondent "[email protected]" there are the following letters: "Evgenia, good afernoon! There
is a "gap" in the WL / Advisory bundle: The same commissions appear in both documents, and it is not stated
anywhere that they are not duplicated. It is necessary to add wording to the Advisory contract that if there are
commissions in WL, they are paid there and are not added to the Advisory commissions. Eugenia, Is there anything
required from me to solve this issue?"; "Zelimkhan, on the first question - what is the minimum amount for accepting
a client without GC? Important point. Can we accept 10k or 30k on WL, without GC?"; "Zelimkhan, good afernoon!
Now we are preparing to accept a new client on WL. Questions: Can we accept him directly without HK on ETF,
amount 10k? Was a phrase added to the Contracts that the commission of Edweiseri and WL are not summarised?".
In the course of examination and analysis of mail messages, correspondence with the respondent "Alexander Salov"
between employees of QBIF Investment Company LLC, including Evgeniya Rossieva, Alexander Salov, Maxim Yudin,
Ruslan Spinka was established. In the correspondence with the respondent "Alexander Salov" there are attached
documents, which were submitted to the clients for signing in order to subsequently receive money from them and
make them look like legal activities, including: drafs of management consulting agreements on behalf of White Lake
Management LTD with draf annexes to the agreements; drafs of trust management agreements on behalf of White
Lake Management LTD with draf annexes to the agreements. Also in the correspondence with the respondent
"Alexander Salov" there is a letter of the following content: "To clarify question 9, paragraph 12 "The Company shall
not be liable for postal, facsimile, electronic and other communications that have not been duly received and
confirmed by it, as well as for the Company's actions on the basis of any signature that, in the opinion of the
Company, is genuine". Let's say that if the Company receives an email from a customer requesting an action along
with a signed form for that action, the Company will honour that request. If the client then says, "I didn't send it and
the signature is not mine," then this clause comes into effect. That is, if the Company believes the client's signature to
be genuine, then it is valid. If the client's email has fallen into the wrong hands, it is not the company's fault and it will
not be held liable".
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In the course of examination and analysis of mail messages, correspondence with the respondent "Back Office" was
established. In the course of inspection and analysis of mail messages with the said respondent, a correspondence
between employees of QBIF Investment Company LLC, including Nikolay Padalko, Zelimkhan Munayev, Ruslan
Spinka, Evgeniya Rossieva, Andrey Korzh was established with the following content: "Colleagues, good afernoon!
We have a number of questions and proposals on WL contracts and infrastructure. From the WLC and SIM contracts to
make one - page accession contracts and insert them into the WL contract. Set out in the contract a clear maximum
deadline for withdrawal of DCs of 90 days from the date of the notice. We promised to confirm the presence of Space X
position on the balance of WL to clients in the form of a statement + Certificate from WL itself - how many securities
belong to the client. Must be done for sure, now many do not believe that the company will actually issue such
documents. Many advisors are afraid that the attracted money either does not exist on the balance sheet at all or is
much less - if we can make a statement with the real balance sheet (volume of assets under management) of the
company for internal use and "accidentally" show it to everyone in a big secret - we will get another plus to
confidence. It is not clear at all how QBF shareholders are related to WL. This connection should be disclosed and
explained as simply as possible, so that advisers can easily work out such objections and be sure of it themselves.
There should be a package of documents to deal with this objection. It is necessary to promote easy conclusions with
WL, which will be in the near future, which went in correctly and also come out the same way. We'll be dripping on the
advisers' brains about it. To fix it in their subcortex. Due to changes in currency legislation from 01.01.20 clients are
obliged to report on the presence of trust accounts abroad. Now everything is going on the way of increasing
transparency and I think it is extremely important for us to work out the reporting of clients to the tax authorities on
our accounts that want to do this. Moreover, filing such reporting should become a basic option for most clients, and
the option not to advertise it should be an option. I am absolutely sure that even for SIM receipts banks will start
demanding clarification about the meaning of the contract and if the client even hints about transactions with
securities - be a letter to the tax authorities. This issue will become a problem in a month if advisors are not
thoroughly instructed on the meaning of the law, our actions and consequences. For large clients of 500k or more FG
to do a performance guarantee by WL. Including deadlines. This is a super argument in negotiations. Today a large
potential client had a question about "signatories" in WL Cons and WL, a question of the nature - can I see the person
signing the contract and make sure that he is not a nominee? Taking into account that this is not a single issue, I ask
you to consider the possibility of hiring a general director who will be able to meet with clients and sign documents in
their presence if necessary, if he is also able to sign documents on SIM and WL - an ideal option, thanks to which we
will avoid many uncomfortable questions and increase the confidence of employees" (the above correspondence
shows, among other things, that the participants of the criminal community (criminal organisation) took measures to
disguise illegal criminal activity with the purpose of signing documents in the presence of the client).
In the course of examination and analysis of mail messages, correspondence with the respondent "Egor Laipanov"
between employees of QBIF Investment Company LLC, including Egor Laipanov, Ruslan Spinka, Evgeniya Rossieva
was established with the following content: "Subject: new client WL+WLM+WLC. Good afernoon, colleagues!
Enclosed are documents for preparing contracts for the White lake structure in conjunction with WLM and WL
Consulting. I also attach the forms of contracts afer editing by Evgeniya Rossieva. Please prepare the documents by
10:00! Evgenia, please confirm the completeness and correctness of the data I have provided, Ruslan - the need to
prepare documents as soon as possible and the commission below! STRATEGY: Algorithmic $60,000, Weighted
average portfolio $40,000. Commissions 28.5% in both cases." In addition, correspondence with Respondent "Egor
Laipanov" contains attached documents that were submitted to clients for signature for the purpose of later receiving
funds from them and giving the appearance of legitimate activity, including: draf trust management agreement on
behalf of "White Lake Management LTD" ("White Lake") with draf annexes to the agreement; draf agreement for the
provision of services on behalf of "WLM LTD" ("WLM LTD"); draf services (standard form of adhesion agreement) on
behalf of "VL Consulting" LLC with draf annexes to the agreement.
In the course of examination and analysis of mail messages, correspondence with the respondent "Vladislav Pliteni"
between employees of QBIF Investment Company LLC, including Roman Shpakov, Vladislav Pliteni, Alexey Trigubov
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was established as follows: "Vladislav, we thank you for submitting the projects. We see them as a huge step forward,
especially in terms of creating a clear and transparent structure, taking into account our interest in the application of
Russian jurisdiction. On the whole, everything looks balanced, taking into account the difficulties that we realise
could be caused by the use of QBIF LLC as a party to such agreements. Your interest is absolutely clear to us and we
confirm our intention to take it into account. Edits to the agreements are minimal. However, in order to maintain a
proper balance between the parties and to make the agreements fully workable, we propose the conclusion of short -
term guarantee agreements from JSC Kubief Financial Group on behalf of Kubief Ltd.
In the course of examination and analysis of mail messages, correspondence with the respondent "Zelimkhan
Munayev" was established. In the course of inspection and analysis of mail messages with the said respondent,
correspondence between employees of QBIF Investment Company LLC, including Zelimkhan Munaev, Evgeniya
Rossieva, Alexander Salov, Kovalenko (Athanasiadou) Linda , was established as follows: "Subject: Calls to WL. From
an employee. Hi! The client 2 days calls during working hours white lake to check the reality of the company on the
phone from the site, they 2 days do not pick up the phone at all. Is there anyone alive there?? Colleagues, we even
made a separate tel. We are building up negativity among clients, take measures"; "We are not changing the requisites
this month, the content of contracts too. We are talking about footers, logos, emblems, etc. Moreover, we change the
QCCI logo directly to the attached WL picture, at the same time we simply delete the footers from QCCI forms - it
concerns legal documents. The enclosed WL form is used for marketing files and so on (because in legal documents
the requisites of one company, and the footer with the data of another company - not great), and in this case is not
critical"; "excellent, but I have a question: how on the basis of the logo and the form "to change QCCI to WL in the
areas of their direct responsibility". In order to fulfil your instruction, it is necessary to get the company details, also it
is necessary that the IT - department promptly makes changes in the program, and not as it makes changes to remove
the footer (nothing was done)"; "in continuation of this topic I send materials (logo and form) WL. I ask each of you to
replace QCCI with WL in your areas of direct responsibility. I also ask you to check the status of the task: Documents in
which the presence of the name QCCI is necessary (contracts, reports and other legal documents ...) should be placed
on the appropriate network discs".
In the course of inspection and analysis of mail messages, correspondence with the respondent "RV [email protected]" was
established. In the course of inspection and analysis of mail messages with the said respondent, correspondence
between employees of LLC Investment Company QBF, including Evgenia Rossieva, Zelimkhan Munayev, Kovalenko
(Athanasiadou) Linda was established with the following content: "Subject: The Bank of Russia considers
unacceptable the offer of financial services of foreign organisations on the territory of the Russian Federation. Your
suggestions?"; "Good afernoon! And again the Bank of Russia: the Bank of Russia considers unacceptable the offer of
financial services of foreign organisations on the territory of the Russian Federation. Information letter of the Bank of
Russia dated 05.07.2018 N IN - 01 - 59/42 "On the unacceptability of offering in the Russian Federation financial
services provided by foreign organisations". CONCLUSIONS are the same: DO NOT offer financial services of foreign
organisations in the offices of professional participants. NOT to place links, documents, offers of foreign organisations
and intermediaries on the website of professional participants (Qbfin / qbfam should not have links to qbfadvisory,
etc.). Informing clients that the contract is concluded with a foreign organisation and related risks (informing the
client about the risks associated with his choice of a foreign company, from White Lake - to discuss what to add to TC
+ think about whether something needs to be changed)".
In the course of examination and analysis of mail messages, correspondence with the respondent "Vladimir
Pakhomov" was established. In the course of inspection and analysis of mail messages with the said respondent,
correspondence was established between the employees of QBIF Investment Company LLC, including Vladimir
Pakhomov, Evgenia Rossieva, Vladislav Plitin, Nikolay Padalko, Zelimkhan Munayev, Alexey Golubev, Maxim Yudin, as
follows: "Vladimir Sergeyevich, in connection with the fact that the transfer of clients to the new structure has now
been completely transferred to SRM and M. Savvidi, it is necessary to remind all FSs once again that the forms of
documents should in no case be sent out to clients.Savvidi, it is necessary to remind once again all FS that the forms
of documents should in no case be sent to clients "for familiarisation" before signing. Such a complainant will happily
throw them to the Central Bank - and there you can see everything. I remind you that we do not give the main
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documents (consent to concessions) to the client, and from the signed ones, which remain in his hands, nothing can
be seen"; "Subject: Liquidation of Edv. This is a general familiarisation answer to clients interested in liquidation.
Comments, suggestions? Shall we make it more detailed or less detailed? QBF Advisery Ltd. provides services in the
interests of the Clients within the framework of the Agreements concluded by the Clients with the Company - resident
of the Republic of Cyprus. Meanwhile, due to stricter requirements to counterparties and non - resident clients
(foreign legal entities and individuals) in Cyprus, currently Clients have the opportunity to conclude an agreement
with a licensed financial company - resident of the Cayman Islands, which is the largest international financial centre
with an extremely developed financial services industry. The provision of advisory services in the interests of the
Clients under the Agreements concluded by the Clients with WL requires the creation of a separate business line and
appropriate restructuring within the financial group in order to optimise business processes, operating and capital
costs. As a result of the ongoing restructuring measures, the provision of services to Clients under the Agreements
concluded by Clients with WL Company, as well as to Clients under previously concluded agreements, will be
performed by companies that meet the necessary requirements and conditions, the rights of Clients under previously
concluded agreements will not be violated" (the above correspondence indicates methods and ways of deceiving and
misleading Clients about the legality of activities and the profitability of allegedly investing funds, as well as the
adoption of conspiracy measures to conceal the fact that the Client's rights under the Agreements with WL Company
have been violated).
In the course of examination and analysis of mail messages, correspondence with the respondent Kovalenko
(Athanasiadou) Linda, was established. In the course of inspection and analysis of mail messages with the said
respondent, a correspondence between employees of QBIF Investment Company LLC, including Kovalenko
(Athanasiadou) Linda , Evgenia Rossieva was established with the following content: "Sending documents (Korshunov
Dmitry Anatolievich): 1. Completed KYC. 2. Notarised copy of Russian passport. 3. Apostille of the foreign passport. 4.
Application form to Tinkoff Bank as a confirmation of basic data. 5. Certificate from the Bank on the state of the
account (with apostille). 6. Letter of recommendation from the Bank. With respect, Evgenia Rossieva" (during the
preliminary investigation it was established that the data of Korshunov Dmitry Anatolievich participants of the
criminal community (criminal organisation) used in contracts, annexes to contracts, as well as other documents as a
representative of "WLM LTD" ("WLM LTD") and "White Lake Management LTD" ("White Lake Management LTD"), but
questioned as a witness Korshunov D. A. explained that he is a drug addict.A. explained that he is a drug addict with
10 years of experience and has nothing to do with these organisations). Also in the correspondence with the
respondent Kovalenko (Athanasiadou) Linda, there are the following letters: "No one yet, the directors have not been
paid yet, I need to pay at least half of it, go to Roman tomorrow and tell him the situation, he will be allowed to pay";
"To whom of yours can I write on the execution of a power of attorney for White Holdings Limited for Nikolay
Padalko?"; "Linda, hi! White Holdings Limited is a participant (owner of a share in the capital) of LLC "VL Consulting".
VL Consulting LLC is a service company that "supports" sim and VL clients in Russia. Now the task is that it needs to
change its legal address and register it with the tax office. It needs a power of attorney for some person to vote on
behalf of White Holdings Limited (a member of VL Consulting Ltd) - on the decision to change the address. Also, such
issues arise from time to time (change of articles of association as new law, will change address), i.e. a power of
attorney is needed for the long term. I have executed it for Nikolay Padalko (he is still the director in VL Consulting
Ltd.), will you authorise it? Will you sign it? Thank you! Sincerely, Evgeniya Rossieva".
In the course of examination and analysis of mail messages, correspondence with the respondent "Nikolay Padalko"
was established. In the course of examination and analysis of mail messages with the above respondent,
correspondence between employees of LLC Investment Company QBF, including Nikolay Padalko, Evgeniya Rossieva,
Andrey Korzh, Alexey Golubev, Zelimkhan Munayev, Ruslan Spinka was established as follows: "Subject: signing of
contracts. Colleagues, the option with stitched seals is cleaner from a legal point of view, as we discussed yesterday.
However, the client's wishes sometimes have to be taken into account. I suggest: the main option - stitched seals, for
capricious clients - live seals. This will reduce the load on Kristina. Well then, to summarise: WhiteLakeManagement
contract, WLM and Sim - stitched seals, VL Cons. - physical seal. Is that correct? Shall we agree on such a variant?"; "if
we are a business representative just the sewn - in seal of the company we represent is completely in logic. On the
contrary - its live presence here is strange"; "do you mean that perhaps our foreign partners send us contracts with a
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seal, and we put it ourselves in the contract of the business representative in Russia? Is there a logic in this?"; "it can
be well played in all contracts except VL Cons, in VL Cons we can leave the personal one?"; "such contracts are usually
printed when you open some accounts or deposits remotely. When a person comes to sign it in person, it is usually
not accepted."; "the agreement is printed from CRM with a colour signature and seal from the company. This is an
analogue of a facsimile. It will be necessary to add a clause in the contract for the client that this way of signing on the
part of the company is OK"; "1) Based on the content of the letter, the claim was drawn up on 16.03, I receive
notification only on 30.03. If in the future notification from regional clients will take so long, WL's reputation may
suffer greatly, and I am now working very hard to clean it up. I ask my colleagues to inform me more promptly about
such cases. 2) Please send me all scans of contracts with this client and all documents signed by the client (notices,
orders, etc.). 3) Based on the text of the claim, I see that the client does not understand the role of VL Consulting in the
process of providing services to the client (the client confuses the terms "Company" and "Executor", but is sure that
the account is opened with the "Executor"). I conclude that the FSs are not communicating this role correctly enough,
or they simply do not have a correct understanding of this role. Once again, I ask that colleagues pay attention to the
memos I have developed this quarter. If additional training is needed, we will organise a webinar.
In the course of examination and analysis of mail messages, correspondence with the respondent "Ruslan Spinka"
was established. In the course of inspection and analysis of mail messages with the above respondent,
correspondence between employees of QBIF Investment Company LLC, including Ruslan Spinka, Maxim Yudin,
Nikolay Padalko, Evgenia Rossieva was established with the following content: "Be more attentive. Watch what you
discuss with the client. We do not discuss "B" over the phone at all. International markets preferably also at a
meeting, as we have for this purpose a separate company in the Caymans with its own licence, not QBF - well or in
extreme case Global Markets"; "1. Agency agreement can be provided (symtelligence - white - lake). 2. Simtelligence is
an agent of vl he has no contracts with trading floors. 3. The activity of Simtelligence is not licensable it is consulting
Services and agency".
In the course of examination and analysis of mail messages, correspondence with the respondent "Madina
Baderdinova" was established. In the course of examination and analysis of mail messages with the mentioned
respondent, correspondence between employees of LLC Investment Company QBIF, including Evgenia Rossieva,
Madina Baderdinova, Vladislav Butkovskaya, Stanislav Matyukhin was established as follows: "Subject: Demand
Advance LOD. Good day! Colleagues, in connection with the sales plan to place the product VOD On Demand on the IR
website, it became necessary to change the product passport of this VOD (VOD series) - QBIF LLC will be the developer
of the product instead of Q.Broker. Is it all right? It is necessary to decide from what date to start the product
registration with the new passport"; "Madina, I ask you to describe all types of orders, accounting and transactions
you conduct on Q-BROKER by the end of the day. From orders to sell - buy currencies, transfers to CI (it's not about CI,
it's about the principle - not one foreign broker so much) to accounting of unit buy - back agreements, execution of
option agreements with partners (RIF transfers), orders on personal accounts of funds, promissory notes, etc. etc. etc.
Hope - to help structure the information. IK should be fucked. We'll discuss the hours afer you describe everything.
A.Koval moved sharply when she saw that a real back Q-BROKER was being created - and not under the power of the
EC. They like power, but they don't like responsibility and work (when earlier I offered them to take back qb - they
sent them to the woods). Give it to them - there will be exactly the same mess and darkness and lack of documents as
we have in the WOD, especially once you let it go. And you will have to beg and bow down to them (on RIFs!! on
transactions on units and options not through IR!!!). And they'll start bending out even more and padding their false
price and snapping up trades."
During the examination of the laptop, other correspondence, letters with attachments in the form of various
documents (draf documents) were found, which are listed in the protocol of examination and printed out as annexes
to the protocol of examination, which are of significance and establish the circumstances of the criminal case;
(vol. No. 154, pp. 18 - 220, vol. No. 155, pp. 1 - 31, 105 - 216, vol. No. 156, pp. 1 - 235, vol. No. 157, pp. 1 - 185)
- other documents documents seized on 26 May 2021 in the home of E.A. Rossieva at the address: 4 Udaltsova St.,
Q230, Moscow, including: documents confirming her employment with the QBF group of companies; various
647
agreements, contracts with annexes, which were imposed for conclusion with clients in order to attract their funds for
subsequent embezzlement; various documents on clients' claim activities to the QBF group of companies;
(Vol. No. 155, pp. 33 - 104) - physical evidence - mobile phone "iPhone 11" model number MWLT2RU/A, serial number
C6KZK5N8N735, belonging to Lepeshkin D.S., owned by Timokhin O.Yu. mobile phone "ASUS" model number
ZB631KL, serial number JCAXB764225149P, belonging to Nepomnyashchy A.V. mobile phone "iPhone8Plus" model
number MQ8Q2B/A, serial number C39VC2UCJCLR, belonging to Rossieva E.A. laptop "MacBook Air S/N:
FVFCT3FXM6KK", belonging to S.A. Matyukhin mobile phone "iPhone 12 Pro Max", model number "MGDA3RU/A, serial
number "F2LFG91D0D52", belonging to D.S. Lepeshkin mobile phone "iPhone 12 Pro", model number "MGMK3GH\A,
serial number "F17DN5FG0D8X", IMEI:356692119859134, IMEI 356692119714008;
(vol. No. 157, pp. 186 - 188, vol. No. 287, pp. 167 - 168)
- expert opinion No. 243e - 17 dated 21 April 2022, according to which: 1) on the investigated external
information storage device "WD Elements" s/n WX21DA6JX05V, seized in the dwelling of Rossieva E.A. at the address:
Moscow, Udaltsova str. 4, text files and graphic files containing the keywords: "Kyybief", "TIN 7703399818", "Kyybief
Financial Group", "168 Kvartal", "7703769272", "701", "702", "776", "Ver - Mont", "7734371675", "Kyybief Investment
Company", "7733673955", "IR", "7704835400", "KG", "Qubey Group," "7701876374," "Q - Investment," "Investment,"
"9731017278," "KF Estate SPB," "Qubey Credit," "Qubeyef Advisors," "Qubeyef," "Qubeyef," "M1 Invest," "7701367560,"
"M4 Invest," "Finbutik," "7731610156 "Pro", "7703423933", "Severspetsstroy", "7703769579", "Simon Jesso",
"7703769586", "Synthesis", "7708270984", "S - Control", "5047245990", "7708243109", "F - Technologies", "F -
Technologies", "7725726949", "7703439757", "Venture Capital Finance Centre", "7734682254", "QBF", "QCCI", "Cap",
"Capital", "Sim", "WHITE", "VL", "VLC", "WL", "W", "Argento", "Constance", "Constance", "ESMA", "Shpakov", "Munaev",
"Zelimkhan", "ZVM", "Rossieva", "Evgenia", "Pakhomov", "Golubev", "Yudin", "Soboleva", "Athanasiadou", "Linda",
"Apollo", "Korzh", "Frolov", "Gorobets", "Lepeshkin", "Dima", "Korshunov", "Danchenko", "Kirill", "Berezka", "Andreas",
"Harris", "Charis", "Greg", "G", "Avetis", "Meshkova", "Maslennikov", "Stas", "Sorokin", "Spinka", "Isaev", "Matyukhin",
"Orlov", "Cyprus", "PIRAEUS", "Cdb", "Luxembourg", "CSSF", "Hong Kong", "HONG KONG", "CAP", "Caymans",
"Caymanian", "Cay", "Crand Cayman", "Cay", "CIMA", "Licence", "Licence", "Signatory", "Gd", "Daughter", "Trust",
"Trust", "Trust", "DS", "Advisory", "Victims", "Borzenkov", "Polezhaev", "Dianov", "Koptev", "Chernov", "Gusarov",
"Sloyeva", "Stepanov", "Vyatkina", "Regulator", "Central Bank", "Central Bank", "Central Bank", "Tsyb", "Verification",
"Complaints", "Fraud" and "Fraud"; 2) on the investigated USB - flash - drive "Kingston", seized in the dwelling of
Rossiyeva E. A. at the address: Moscow.A. seized in the home of Rossieva E. A. at the address: Moscow, Udaltsova str. 4,
there are text files containing the keywords: "Capital", "VL", "RV", "ZV", "Rossieva", "Evgenia", "Pakhomov", "Golubev",
"Yudin", "Soboleva", "Apo", "Frolov", "Dima", "Korshunov", "Kirill", "Berezka", "Greg", "Sorokin", "Isaev", "Orlov",
"Cyprus", "ATS", "licence", "signatory", "Gd", "Daughter", "Trust", "Victims", "Chernov", "Stepanov", "Regulator",
"Central Bank", "Central Bank", "Central Bank", "Check", "Complaints", "Fraud" and "Fraud"; 3) on the investigated
optical discs, seized in the dwelling of Rossieva E.A. at the address: Moscow, Udaltsova str. 4, there are text files
containing the keywords: "IK", "KG", "Synthesis", "Capital", "VL", "W", "Korshunov", "G", "Maslennikov", "Sorokin",
"Isaev", "Orlov", "Cyprus", "Hong Kong", "Caymans", "Licence", "Gd", "Daughter", "Trust", "DS", "Victims", "Chernov",
"Stepanov", "Central Bank", "Central Bank", "Verification", "Complaints" and "Fraud". The detected text and graphic
files contain information establishing the circumstances of a criminal case involving the embezzlement of citizens'
funds;
(Vol. No. 289, pp. 50 - 78)
- expert opinion No. 242e - 17 dated 04 April 2022, according to which: 1) on the investigated hard disc (ISN
number BTLA734102BM256CGN), seized during the search in the office of LLC "NOA", located at: Moscow, Khilkov per,
1, sq. 19, there are text files containing the keywords: "QBIF", "RIF", "7703466327", "168 Kvartal", "7703769272", "701",
"702", "7703474800", "776", "Ver - Mont", "Vysota", "7734371675", "Indep Smart", "7735159230", "QBIF Investment
Company", "7733673955", "IR", "KBF Asset Management", "7704835400", "KG", "Cubey Group", "7701876374", "K -
Investment", "Invest", "KP Phase 2", "7702459550", "KP Phase 3", "7704471087", "KP Phase 4", "9731017278", "KF
Estate SPB", "7840472851", "Cubey Credit", "M1 Invest", "7701367560", "M4 Invest", "Finbutik", "7731610156",
648
"Nortonstroy", "5047246489", "Profi", "7703423933", "Severspetsstroy", "7703769579", "Simon Jesso", "7703769586",
"Synthesis", "7708270984", "S - Control", "5047245990", "7708243109", "F - Technologies", "F - Technologies",
"7725726949", "Venture Capital Finance Centre", "7734682254", "QBF", "QCCI", "QB CAPITAL CY LTD", "QB CAPITAL
MANAGEMENT LTD", "QCM", "Kep", "Capital", "Sim", "WHITE", "VL", "WL", "W", "Durmitor investments limited",
"Constance", "Constance", "CI", "Cgs", "Shpakov", "RW", "Irina Shpakova", "Valery Shpakov", "Shpakov", "Munaev",
"Zelimkhan", "ZV", "Zelimkhan Munaev", "Rossieva", "Evgenia", "Vova", "Pakhomov", "PAkhomov", "Golubev", "Yudin",
"Soboleva", "Athanasiades", "Athanasiades", "Kovalenka", "Linda", "Apollo", "Apo", "Gramza", "Korzh", "Frolov",
"Gorobets", "Lepeshkin", "Dima", "Korshunov", "Danchenko", "Kirill", "Berezka", "Andreas", "Charis", "Greg", "G",
"Avetis", "Zoran", "Meshkova", "Maslennikov", "Stas", "Sorokin", "Spinka", "Isaev", "Matyukhin", "Orlov", "Cyprus",
"PIRAEUS", "Cdb", "Luxenburg", "Hong Kong", "SAR", "Licence", "License", "Signatory", "Gd", "Daughter", "Yubo",
"Trust", "Trust", "DS", "Advisory", "Victims", "Borzenkov", "Dianov", "Koptev", "Chernov", "Gusarov", "Sloyeva",
"Stepanov", "Vyatkina", "Regulator", "BN", "Central Bank", "Central Bank", "Verification", "Complaints" and "Fraud".
The detected text files contain information establishing the circumstances of a criminal case on embezzlement of
citizens' money;
(Vol. No. 289, pp. 135 - 160)
- exhibited evidence: hard disc (ISN number BTLA734102BM256CGN), seized on 26.05.2021 during the search
in the office of LLC "NOA", located at: Moscow, Khilkov Per, 1, sq. 19; external data storage device "WD Elements" (s/n
WX21DA6JX05V), USB flash drive "Kingston" (with marking C4300 - 339A00LF 5V 0S5072131 TAIWAN) and 6 optical
discs, seized on 26.05.2021 in the dwelling of E.A. Rossieva, located at the address: Moscow, Udaltsova St., 4, sq. 230;
(Vol. No. 289, pp. 192 - 193)
- another document - a certificate provided by the Bureau of Special Technical Measures of the Main Department of
the Ministry of Internal Affairs of Russia in Moscow, with background information on the domain "qbfin.ru", namely:
date of birth - 18.06.2010; organisation - LLC "Kyubi Finance"; address - Moscow, Presnenskaya Naberezhnaya, 8, p. 1;
taxpayer number ; legal address - Moscow, Presnenskaya Naberezhnaya, 8, p. 1; taxpayer number 7733673955; legal
address - Moscow, Presnenskaya Naberezhnaya, 8, bld. 1;
(Vol. No. 286, l.d. 3)
- another document - a letter provided by Regional Network Information Centre JSC (RNIC JSC), according to which
RNIC JSC is the registrar of the domain names qbfin.ru, qbcap.com, qbfworld.com. The domain name qbfin.ru was
registered on 18.06.2010. RSIC JSC is the registrar of the domain qbfin.ru since 29.01.2014. Roman Valeryevich
Shpakov was the administrator of the second - level domain qbfin.ru from 29.01.2014 to 01.03.2014. On 01.03.2014,
the rights to administer the qbfin.ru domain were transferred to Qubi Group LLC on the basis of a written request
(application for transfer of domain rights) from the domain administrator sent to RSIC JSC. The administrator of the
qbfin.ru domain from 01.03.2014 to 28.10.2015 was Qubey Group LLC. On 28.10.2015, the rights to administer the
qbfin.ru domain were transferred to QBF Investment Company LLC on the basis of a written request (application for
transfer of rights to the domain ) from the domain administrator sent to RSIC JSC. The administrator of the qbfin.ru
domain from 28.10.2015 to the present (the date of the request) is QBcap Investment Company LLC. The domain
name qbcap.com was registered on 26.07.2011. Roman Valeryevich Shpakov was the administrator of the second -
level domain qbcap.com from 26.07.2011 to 05.02.2014. On 05.02.2014, the rights to administer the qbcap.com
domain were transferred to Qubi Group LLC on the basis of a written request (application for transfer of rights to the
domain) from the domain administrator sent to RSIC JSC. The administrator of the qbcap.com domain from
05.02.2014 to the present (the date of the request) is Kyubi Group LLC. The domain name qbfworld.com was
registered on 21.06.2016. The administrator of the domain name qbfworld.som from 21.06.2016 and up to the present
time is Kyubey Group LLC. Other domain names registered to QBF Investment Company LLC in the RSIC: VIXGOLD.RU
(domain registration date: 18.07.2016), FREEFALL.MSK.RU (domain registration date: 06.09.2017), FREEFALL.MOSCOW
(domain registration date: 06.09.2017);
649
(Vol. No. 286, pp. 6 - 10)
- Protocol of the search of 19 November 2020, conducted in the dwelling of Munaev Z.V., located at the address: 1
Nikolayeva Street, sq. 96, Moscow, during which items and documents containing information relevant to establishing
the circumstances of the criminal case were seized;
(Vol. No. 286, pp. 55 - 65)
- Protocol of examination of items dated 20 December 2020, seized on 19 November 2020 in the dwelling of Z.V.
Munayev, located at the address: 1 Nikolayeva Street, sq. 96, Moscow, in the course of which the seized mobile phone
of the latter was examined. During the examination of the seized mobile phone of Z.V. Munayev, a correspondence in
the application "WhatsApp" was established.
Correspondence with the contact "Evgeniya Rossieva", subscriber number +7 - 985 - 173 - 43 - 21, with whom
correspondence was carried out, including the following content, was found and examined:
14.12.2017
[14.12.2017, 15:06:04] Evgeniya Rossieva: Zelimkhan Visaitovich, good afernoon! Is there any news from the lawyers,
any changes in our plans?
[14.12.2017, 15:07:26] .: I'll report back in 40 min.
[14.12.2017, 15:07:45] ... Good
[14.12.2017, 15:33:51] Evgeniya Rossieva: Zelimkhan Visaitovich, now I have received a question from the FS regarding
the signing of Q contracts by Gorobets facsimile. in all the writings of lawyers C and "expertise" Gorobets (who also
signed contracts from Q) is cited as evidence of "affiliation". And it turns out that we are again on the same rake)) it is
necessary to remove her from Q
[14.12.2017, 15:47:31] .: Signatures from the EC?
[14.12.2017, 15:47:38] .: That's impossible
[14.12.2017, 15:47:44] .: She doesn't have a power of attorney.
[14.12.2017, 15:48:15] Eugenia Rossieva: Q to not sign G
[14.12.2017, 15:53:09] .: From ik no longer doing it
[14.12.2017, 15:55:12] .: By Lawyers C - categorical denial
[14.12.2017, 15:55:20] .: From changing the decision
[14.12.2017, 15:55:39] .: Write a general letter, do an appeal, and they drop the lawsuit
12.03.2018
[12.03.2018, 09:19:34] .: Eugenia, good morning!
[12.03.2018, 09:20:18] .: Need to buy an empty company created before October 2017
650
[12.03.2018, 09:20:31] .: Activity finance, consulting, etc
[12.03.2018, 09:20:44] .: Empty, naked, no problem
[12.03.2018, 09:21:10] Eugenia Rossieva: And ours are not suitable?
[12.03.2018, 09:21:14] .: The name would also preferably reflect the activity explicitly, with the words finance,
consulting and similar abbreviations
[12.03.2018, 09:21:33] .: Current ones will not fit, this company will be needed by Cypriots
[12.03.2018, 09:21:45] .: You can't make a connection with ours
[12.03.2018, 09:22:01] Eugenia Rossieva: I see, I'll find out, I'll let you know
[12.03.2018, 09:22:12] Eugenia Rossieva: Price of the question?
[12.03.2018, 09:22:25] .: Look at the tentative options for now, come back in a couple of hours, we'll discuss the big
picture
[12.03.2018, 09:22:56] .: How much are empty companies worth now? Order of numbers?
[12.03.2018, 09:23:15] Eugenia Rossieva: I don't know yet either, I'll find out then I'll let you know
[12.03.2018, 09:23:30] .: Without a bank account, without permits and licences, etc
[12.03.2018, 09:23:34] .: Ok
[12.03.2018, 10:10:07] Evgeniya Rossieva: Zelimkhan Visaitovich, I remind you that you have to visit the notary today
and the ds. I ask to consider the possibility of allocating ds to the transaction on kg in excess of the monthly expenses
of the UD (at least in part), because with our number of corporate projects the amount of the balance will be enough
for 10 days and again we will have to ask(( I have already paid for 12 thousand at my expense expenses this month))
[12.03.2018, 10:22:55 pm] .: Not OK)
[12.03.2018, 10:23:16] .: Write now me, RV and Alena an email as much as you need today
[12.03.2018, 10:23:20] .: And how much did you overpay
[12.03.2018, 10:23:31] .: Plus how much ds until the end of mes
[12.03.2018, 12:20:26] .: Come in
[12.03.2018, 12:21:18] Eugenia Rossieva: Coming
[12.03.2018, 12:21:45 pm] .: When you're free.
[12.03.2018, 12:21:51 pm] .: Not lit.
[12.03.2018, 12:40:03] .: Notary at what time? If RW hasn't handed over the ds yet, better get in to see him
[12.03.2018, 13:41:32] Eugenia Rossieva: Does not give today. Need at least 15 thousand today, 5 thousand can
contribute their own)
[12.03.2018, 13:45:36] .: No, with RV then we will not over - negotiate)) let's go straight from it, specify exactly what day
and I will invite Anastasia
[12.03.2018, 13:56:01] Eugenia Rossieva: Ok, we will reschedule for the next day or two. I will inform in advance about
the time )
[12.03.2018, 13:56:46] .: OK
651
[12.03.2018, 15:42:38] Evgeniya Rossieva: Lawyers C reported that the statements all filed, but copies of Sergei
personally ready to give only to the Director (Matyukhin), offer to contact him.
[12.03.2018, 15:42:49] Eugenia Rossieva: Can you ?
[12.03.2018, 15:50:23] .: Why, let it be Matyukhin personally
[12.03.2018, 15:50:29] .: All the more reason for them to do so.
[12.03.2018, 15:50:36] .: Invite him to the office
[12.03.2018, 15:50:41] .: Me and Stanislav will come up.
[12.03.2018, 16:33:27] .: Is there an update on legal entities?
[12.03.2018, 16:34:03] Evgeniya Rossieva: Not yet, we are working. Still waiting for more from the lawyers.
[12.03.2018, 17:46:45] Eugenia Rossieva: Cheaper than 40 thousand + re - registration is not yet. Something it is quite
expensive. Can I request a birch?
[12.03.2018, 17:47:04] .: Let's request it
13.03.2018
[13.03.2018, 09:50:11] .: Good! Need to decide on a company today and drop Linda a name
[13.03.2018, 09:57:14] Eugenia Rossieva: Good morning! I will now check what we have
[13.03.2018, 11:44:22] Evgeniya Rossieva: Yesterday it was reported that you wanted to talk to me and Svetlana
Beloded. Mb convenient afer the meeting?
[13.03.2018, 13:21:45] Evgeniya Rossieva: Zelimkhan Visaitovich, came up S, the document on the cap will need to
sign (act of acceptance of the application in the police department), I will now prepare you can come in about 10 - 15
minutes?
[13.03.2018, 13:22:26] .: I was told I wasn't needed.
[13.03.2018, 13:22:31] .: I'll be there in an hour.
[13.03.2018, 13:22:47] Eugenia Rossieva: It is better that the EC does not accept documents on kep
[13.03.2018, 13:24:22] .: I'm in the Moscow Exchange building.
[13.03.2018, 13:24:27] .: I won't be until closer to 3:00.
[13.03.2018, 13:28:48] Evgeniya Rossieva: Will you be able to cross with C separately? I will give him the act separately
(they made a general one for everything and it does not fit). In what key with him it is better to agree?
[13.03.2018, 13:29:17] .: So that by 3 - 4 drive up again, I'll be there
[13.03.2018, 13:29:24] .: Downstairs maybe having a coffee
[13.03.2018, 13:29:29] .: Or at the resta eat.
[13.03.2018, 13:45:25] Evgeniya Rossieva: Zelimkhan Visaitovich, the documents on IK he handed over, only the
statement on kep, the act I prepared, he will contact you tentatively afer 16 hours.
652
[13.03.2018, 13:45:35] Eugenia Rossieva: Better get everything today)
[13.03.2018, 17:40:21] Evgeniya Rossieva: Zelimkhan Visaitovich, is it possible to meet with S? Do you need my help?
[13.03.2018, 19:31:58] .: No luck so far, if tomorrow, how critical is it?
[13.03.2018, 19:33:13] Eugenia Rossieva: Not critical, but you need to sign today's date because he came. I think it is
worth it to confirm that he did not worry. That we will sign on 13.03.
[13.03.2018, 19:57:31] .: Come on in
14.03.2018
[14.03.2018, 10:44:15] .: Good!
[14.03.2018, 10:44:36] .: 16:30 and later see if the notary will accept today on Anastasia's issue
[14.03.2018, 10:44:48] .: Yesterday Roman asked for a trade today
[14.03.2018, 10:45:02] .: You can take ds from him directly
[14.03.2018, 11:10:17] .: Vchershanyi Cypriot dock signed?
[14.03.2018, 11:22:23] Eugenia Rossieva: Eugenia, good afernoon!
On the availability of a clean company confirmed (waiting for the list).
Consulting activities
Price up to 120tr, but I think it will be cheaper
I'm waiting for a list of prices
[14.03.2018, 11:22:57] Eugenia Rossieva: Berezka soobshil. The price tag is tough( but let's see the list, I think it will
vary
[14.03.2018, 11:29:37] .: 120, wow
[14.03.2018, 11:29:46] .: You had a cheaper option yesterday
[14.03.2018, 11:30:06] .: Did you ask the new guy?
[14.03.2018, 11:30:35] Eugenia Rossieva: Exactly) but let's see in detail, maybe there will be cheaper. Yes, sent the task
to belodead yesterday
[14.03.2018, 11:32:59] .: by doc?
[14.03.2018, 11:34:31] Eugenia Rossieva: I will report back within half an hour (I am with Stanislav on the complaint in
BR)
[14.03.2018, 11:34:42] .: Ok
[14.03.2018, 11:34:58] .: And on the notary report, I Anastasia to tell Anastasia the time to tell the time need
[14.03.2018, 11:35:46] Eugenia Rossieva: We are trying to get to the notary without a queue. To the other is already
late there is a certificate of legal capacity
[14.03.2018, 13:56:09] .: Notary?
653
[14.03.2018, 13:56:15] ... : Cyprus dock?
[14.03.2018, 13:56:42] Eugenia Rossieva: On the notary we will clarify afer 14 hours, the last attempt
[14.03.2018, 14:26:37] Eugenia Rossieva: On the Cypriot letter - we were talking about a letter to the clients of Kep
from Kep. And here is a confirmation from the EC about unpaid invoices. We wrote everywhere that there are no
financial relations with Kep( or I don't know something?
[14.03.2018, 14:27:41] .: I honestly did not go into details, but I know for sure Frolov used to sign such letters before
[14.03.2018, 14:27:50] .: Call plz Linda, talk it through.
[14.03.2018, 14:27:59] .: They speak differently over there, don't they
[14.03.2018, 14:28:08] .: We have 2 paradigms in different jurisdictions
[14.03.2018, 15:14:47] Eugenia Rossieva: Notary on KG only tomorrow, at 16 o'clock but it is ironclad (certificates
received, all confirmed). I received the money, I gave it to Natalia. You will need the appearance of your buyer.
[14.03.2018, 15:15:16] .: Ok, we will.
[14.03.2018, 15:15:25] .: To Roman, write back that tomorrow at 16 go
[14.03.2018, 15:16:52] Evgeniya Rossieva: I told him verbally that there is no way today, only tomorrow. On Cyprus -
mentioned agency agreement with kep, I do not know what kind of agreement. For Stanislav to sign it maybe you
should explain it to him as well?
[14.03.2018, 15:19:09] Evgeniya Rossieva: Can you give me Ananyeva's contacts just in case? Natalia contacts and fully
explains everything + in case of any of those delays/lost etc
[14.03.2018, 15:37:31] .: I'll think about it, waiting for feedback from colleagues in Cyprus
[14.03.2018, 15:37:36] .: 8 (916) 311 - 36 - 36
[14.03.2018, 17:45:33] .: The Cyprus dock has been sorted out
[14.03.2018, 17:45:41] .: How's it going with yur l?
[14.03.2018, 17:45:49] .: Linda is demanding a title from me
[14.03.2018, 17:46:19] Eugenia Rossieva: I'll hurry up now
[14.03.2018, 21:01:44] .: Well? Has anything turned up in 3 days?
[14.03.2018, 21:03:02] Evgeniya Rossieva: Berezka swears that he found a lot and is about to send, I rub it constantly. I
want to see what he has, because the usual options are average
15.03.2018
[15.03.2018, 10:41:58] ... Good Morning
[15.03.2018, 10:42:06] .: So where are we on companies
[15.03.2018, 10:44:03] Eugenia Rossieva: Good morning) if within an hour birch will not give anything I will send our
option, what to do. We are still ringing through now
[15.03.2018, 11:11:02 pm] .: Candidate ask the candidate whether or not to expect him to do so
654
[15.03.2018, 19:55:22] .: So where are we with the companies?
[15.03.2018, 22:05:52] Evgeniya Rossieva: Sent you in the mail the company. It in principle can be taken, although the
prices now on it((((((((
[15.03.2018, 22:07:40] Eugenia Rossieva: I found it in the registry, it corresponds to what it says
[15.03.2018, 22:56:39] .: Got it, I'll look into it
[15.03.2018, 22:56:50] .: There was no information from Berezka?
[15.03.2018, 22:56:58] .: And from a noah candidate?
[15.03.2018, 23:54:32] Eugenia Rossieva: I wrote about birch, it is expensive there and the views are not suitable(
16.03.2018
[16.03.2018, 10:54:40] .: Here are more companies sent to me, take a look plz
[16.03.2018, 12:18:21] Evgeniya Rossieva: I looked, unimportant options - most companies do not meet the deadline
(too late created - Q4 2017, Q1 2018) there are few companies with a similar date of creation, and they generally have
other types of activities
[16.03.2018, 12:18:31] Eugenia Rossieva: You didn't like Big City at all?
[16.03.2018, 12:41:19] .: Norm
[16.03.2018, 12:41:27] .: Then we stop at the big city.
[16.03.2018, 12:42:00] .: Include these ds on payment, send to Alena (ask for a general wording), we make out on me at
once
[16.03.2018, 12:44:44] Eugenia Rossieva: And the directorship is on you too?
[16.03.2018, 13:00:24] .: Noo, need a nom.
[16.03.2018, 18:48:22] .: Tex, confirming to Cypriots Big City Ltd?
[16.03.2018, 18:49:00] Eugenia Rossieva: Yes, it has been booked for us already. Who will give the director?
[16.03.2018, 18:49:25] .: Need too legal service, outsourcing
[16.03.2018, 18:49:29] .: We don't have our own
[16.03.2018, 18:51:44] Eugenia Rossieva: Ask our lawyers for a nominal?
[16.03.2018, 18:52:27] .: Mm - hmm.
[16.03.2018, 19:00:23] Eugenia Rossieva: And I request also company maintenance (transaction accounting) or not?
[16.03.2018, 19:02:58] .: If there are no financial flows
[16.03.2018, 19:03:02] .: Need accounting?
[16.03.2018, 19:05:34] Eugenia Rossieva: Still monthly nulovka surrender, although it should not cost much.
[16.03.2018, 20:19:55] .: How many f/m will you get?
655
[16.03.2018, 20:21:33] Eugenia Rossieva: e/m is it?
[16.03.2018, 21:15:46] .: Monthly how much would the maintenance cost?
[16.03.2018, 21:16:28] Eugenia Rossieva: I will remember the abbreviation). I will clarify and report).
19.03.2018
[19.03.2018, 15:22:56] Evgeniya Rossieva: The cancellation of the claim is accepted, the proceedings are terminated.
We will receive the documents in the Ramenskoye court in about 7 - 10 days
[19.03.2018, 15:23:13] ... ...: Fr.
[19.03.2018, 15:23:16] .: Everything is not for nothing
22.03.2018
[22.03.2018, 12:23:25] Evgeniya Rossieva: Zelimkhan Visaitovich, good afernoon!
[22.03.2018, 12:40:03] Evgeniya Rossieva: We had a conversation in BR today. We strongly (!) hinted that according to
their information IK continues to recommend the international market. We are talking about the fact that in Kirosa Z
contracts signatories - workers of IK. This also applies to branches (branch managers) Within the framework of the
reorganisation of the structure it is necessary to remove this point, it is a very serious risk. And since the services for
the international market are offered in branches, it is probably worth opening branches of Edweiseri there and not on
the premises of IK, but to be different? Different premises?
[22.03.2018, 12:40:25] Eugenia Rossieva: Cyprus Treaties
[22.03.2018, 14:02:15] .: Hi
[22.03.2018, 14:02:26] .: I agree, adw branches and different premises
[22.03.2018, 14:03:44] Eugenia Rossieva: And very important people because we were practically poked with this
today, those are not jokes.
[22.03.2018, 14:06:09] .: Come in
[22.03.2018, 14:06:37] Eugenia Rossieva: We are just waiting for Linda or to run to you?
[22.03.2018, 14:06:57] .: Let's go to my place, let's go from me
26.03.2018
[26.03.2018, 14:44:09] Evgeniya Rossieva: Zelimkhan Visaitovich, good afernoon!
[26.03.2018, 14:44:51] Eugenia Rossieva: We have an urgent case - big city lawyers for service take but the director
does not give. Thought - seeking, in the end did not find. We urgently need a physicist.
[26.03.2018, 14:45:32] Eugenia Rossieva: Do you have the opportunity to find ?
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[26.03.2018, 14:59:33] .: Good!
[26.03.2018, 14:59:39] .: I don't have any such contacts
[26.03.2018, 14:59:41] .: birch?
[26.03.2018, 14:59:53] Eugenia Rossieva: I'll give it a try
[26.03.2018, 15:05:17] Eugenia Rossieva: Birch will be here tonight, agreed that we will discuss. Do you need to be
informed when he arrives?
[26.03.2018, 15:06:48] .: Here the point is clear, I think specifically my participation is not necessary
[26.03.2018, 15:07:01] .: Ask also Marianna Scherbakova
[26.03.2018, 15:07:08] .: She has contacts with law firms.
[26.03.2018, 15:07:24] .: I'll think about more options on who to contact
[26.03.2018, 15:07:22] Evgeniya Rossieva: Ok, will do)
[26.03.2018, 18:08:07] Evgeniya Rossieva: Zelimkhan Visaitovich, the company from which we buy big city, sent a
contract for services - they want it to be official. In principle it is possible to sign from you, as you buy officially this
company. Or some fl, like your attorney (do you have one?) I will send you the contract now, we can discuss the
options
[26.03.2018, 18:23:33] Eugenia Rossieva: And service lawyers of this firm are interested in how we will pay officially or
not? Since carrying out payments through the big city is not planned, the options: 1) pay you as the owner 2) pay
without a contract 3) pay through another person
[26.03.2018, 18:23:34] Eugenia Rossieva: Berezka on the director said that he has a face in mind, will confirm a little
later (tomorrow morning spishmesh).
[26.03.2018, 19:15:45] .: I am in the owners, so to do the contract not from me I think there is no point, what do you
think?
[26.03.2018, 19:15:56] .: 2
[26.03.2018, 19:16:16] .: Or 1 unofficially
[26.03.2018, 19:16:30] .: OK
[26.03.2018, 19:16:57] .: But ideally, for us to do it without a contract at all, convince them
[26.03.2018, 19:19:06] Eugenia Rossieva: I think it is also quite logical to do from you. Why unnecessary people. About
without a contract - we'll discuss, it would be a better option of course.
29.03.2018
[29.03.2018, 13:22:02] ... Good
[29.03.2018, 13:22:24] .: We need 2 physicist - subscribers for Cayman and for Gong Kong, not from the company
[29.03.2018, 13:22:32] Eugenia Rossieva: Good afernoon )
[29.03.2018, 13:22:36] .: Puzzle plz colleagues and Berezka
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[29.03.2018, 13:22:48] Eugenia Rossieva: Just signatories by proxy ?
[29.03.2018, 13:23:06] Eugenia Rossieva: They will just sign treaties ?
[29.03.2018, 13:23:12] .: They will only get a power of attorney, employment is not necessary, but if anything, they
should be ready to come to the office for a meeting just to show up.
[29.03.2018, 13:23:17] .: Yes
[29.03.2018, 16:03:29] Eugenia Rossieva: Berezka has found a director for big city (who generally agrees), how much
are we offering for this?
[29.03.2018, 16:03:39] Eugenia Rossieva: We need to voice him the amount of payment
[29.03.2018, 17:19:07] .: How much does Horobets et al similar friends get paid?
[29.03.2018, 17:25:26] Eugenia Rossieva: It depends on the volume. Fluctuates from 5 to 15 per month. We have a
slightly special situation: no volume, but a couple of deals. You need the loyalty of the person, those are estimated.
[29.03.2018, 17:25:57] Eugenia Rossieva: I can offer birch the range + maybe the person will want more (then we need
to understand our limits).
[29.03.2018, 18:31:26] .: Let's diapason.
[29.03.2018, 18:56:51] Eugenia Rossieva: I agree to 10tr per month
[29.03.2018, 18:56:55] Eugenia Rossieva: Ok?
[29.03.2018, 18:57:11] .: Ok
30.03.2018
[30.03.2018, 15:00:46] .: Good!
[30.03.2018, 15:00:59] .: Any progress on this issue?
[30.03.2018, 15:01:30] Evgeniya Rossieva: Berezka is looking for, said it is difficult to clarify now
[30.03.2018, 15:02:48] .: Plus need 1 limited company at 49% Rutiņš, 51% us or RV (but not affiliated), you can discuss
details with him directly
02.04.2018
[02.04.2018, 10:25:26] Evgeniya Rossieva: Zelimkhan Visaitovich, good morning! I'm sick, but on all our cases all lead.
Nominal GD on bigsity wants 15 per month, ok?
[02.04.2018, 10:27:11] Evgeniya Rossieva: On signatories to contracts for Hong Kong and Cayman - Berezka is still
looking for + I have outlined the task to Marianna (that foreign companies, due to the impossibility of ensuring the
presence of a representative in Russia, need persons who sign contracts by power of attorney. There are no risks for
the signatory in this case, as his powers are specified in the power of attorney, he is just a "pen"), she promised to
inform me of the result.
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[02.04.2018, 10:28:24] Eugenia Rossieva: On the scheme today I will send a variant to Alyona for registration - there is
an idea according to those tasks that outlined RV (will need to discuss possibly with the participation of M. Yudin - at
your discretion).
[02.04.2018, 10:29:10] Eugenia Rossieva: I hope that I will recover tomorrow - the day afer tomorrow. I'm on line and
work only from home, so inform what you need everything will do
[02.04.2018, 11:03:03] Evgeniya Rossieva: Documents on gd on big city I received (passport TIN), afer your
confirmation on payment, we can launch with the change of the founder and gd on big city.
[02.04.2018, 11:03:40] .: Good, get well! Looking forward to seeing you. 15k per month ok
[02.04.2018, 11:03:59] Eugenia Rossieva: On reorganisation from birch today waiting for the final decision - it will be
clear go through ooo separated from IK or plan B: through rent invest.
[02.04.2018, 11:04:19] Evgeniya Rossieva: Thank you, Zelimkhan Visaitovich)))
[02.04.2018, 11:04:20] .: Yudin should be avoided or minimised if possible
[02.04.2018, 11:04:38] .: Starting up
[02.04.2018, 11:04:43] Eugenia Rossieva: Not a problem) you can without it.
[02.04.2018, 11:05:24] .: Linda on this ned msk, keep in mind, it will be possible to discuss issues of assignment
contracts or to get together
[02.04.2018, 11:06:42] Eugenia Rossieva: That's very good! Just if we have to go with plan B with her we will discuss.
And contracts of course - how we sign them.
[02.04.2018, 11:06:51] Eugenia Rossieva: I will try very hard to come tomorrow ))))
[02.04.2018, 11:08:50] .: OK, get well, in touch then
23.04.2018
[23.04.2018, 13:03:14] Eugenia Rossieva: http://www.list - org.com/company/1221627
[23.04.2018, 13:03:33] Evgeniya Rossieva: Zelimkhan Visaitovich, the company from A.berezka.
[23.04.2018, 13:04:25] Eugenia Rossieva: Types of activity norms (a lot of financial), date of life too(since 2013). Give up
seem ready tomorrow.
[23.04.2018, 13:04:38] .: Seems OK.
[23.04.2018, 13:04:41] .: Taking
[23.04.2018, 13:04:49] .: No bank accounts?
[23.04.2018, 13:05:18] Eugenia Rossieva: If OK, how will we pay? I'm already without money - I was not given in peace
for expenses, I spent everything on corporate projects, there is a little lef - only for projects
[23.04.2018, 13:05:55] .: I will transfer separately on it, send the figure to Alena, let her fix it
[23.04.2018, 13:06:01] .: Only in general terms
[23.04.2018, 13:06:23] .: Other necessary payments send her too
[23.04.2018, 13:06:29] .: Also in general terms
659
[23.04.2018, 13:06:42] .: Cyril skimmed the passport? We ds sent to the man
[23.04.2018, 13:06:55] Eugenia Rossieva: Discounted)
[23.04.2018, 13:07:12] .: Send to Linda, ask for a power of attorney for wight leuk
[23.04.2018, 13:07:13] Eugenia Rossieva: Interesting denomination there - 60 for everything. It is profitable to hold
longer
[23.04.2018, 13:50:11] Evgeniya Rossieva: Okay. On the company from birch - there are no accounts, are ready
tomorrow to formalise everything, he should give them the money today.
[23.04.2018, 13:50:23] Eugenia Rossieva: Who will give it to him?
[23.04.2018, 13:51:24] .: Throw the figure to Alena, she will give it to you today, you can give it to him at once
[23.04.2018, 13:51:33] .: And we didn't prepay for big city?
[23.04.2018, 13:52:01] Eugenia Rossieva: No of course God forbid)
[23.04.2018, 13:52:49] Eugenia Rossieva: But I have our projects all eaten up - $300 and 15 thousand p(((( lef over
[23.04.2018, 13:53:13] Eugenia Rossieva: Not zvatit, it's only for me to reach afer May with our endless projects.
[23.04.2018, 13:56:04] .: Send Alena the upcoming expenses on a weekly basis
[23.04.2018, 13:56:11] .: 2 - 3 weeks in advance preferably
[23.04.2018, 13:56:34] .: With such planning, there will always be money to pay at the moment
[23.04.2018, 13:58:01] Eugenia Rossieva: Ok)
[23.04.2018, 13:58:21] Eugenia Rossieva: I was just given a lot last time, but our crazy life ate it all up)
[23.04.2018, 13:59:49] .: Ok)
[23.04.2018, 14:00:25] Eugenia Rossieva: sent to Alyona)
[23.04.2018, 14:30:38] Eugenia Rossieva: Zelimkhan Visaitovich need to pay nominal on the company that instead of
big city - 60tr to the card 5332 0580 6122 0790 this is from Kirill
[23.04.2018, 14:30:55] Eugenia Rossieva: This is a different nominee. You paid the nominee to a foreign company
[23.04.2018, 14:31:56] Eugenia Rossieva: He hasn't sent me the nominee for the foreign company docs yet, will send it
tonight
[23.04.2018, 14:32:49] Eugenia Rossieva: This nominal on ross.kompaniya need to pay urgently, birch negotiates a
deal for tomorrow (you also need as a participant). I will inform time - location separately
[23.04.2018, 15:34:21] Evgeniya Rossieva: Zelimkhan Visaitovich, on the nominal Russian Cyril hurries, as the deal
tomorrow already, need all his data and without payment does not give.
[23.04.2018, 15:34:54] Evgeniya Rossieva: Notary beryozki will conduct filing of documents to the ifns without director
but documents are needed))))
[23.04.2018, 15:35:23] Eugenia Rossieva: But you are likely to be needed because you are the contract of sale, I will
clarify it
[23.04.2018, 15:37:38] Evgeniya Rossieva: For the Federal Tax Service, what is your phone number and email? It makes
no difference, the main thing is that on it to answer or be able to say - now will do
660
[23.04.2018, 15:59:27] .: Скиньте платеж по Кириллу тоже Алене
[23.04.2018, 15:59:55] .: [email protected]
[23.04.2018, 16:00:26] .: But about the phone, you'd better work something out with Alena. Something not related to
ik
[23.04.2018, 18:26:10] Evgeniya Rossieva: Zelimkhan Visaitovich money for new big city company 110 thousand will be
allocated today? Berezka can pay their own to not delay the deal but the confirmation must be accurate
[23.04.2018, 18:26:58] .: Right
[23.04.2018, 18:30:00] Evgeniya Rossieva: You can give the money to Kristina she knows how to put on the card
beryozka
[23.04.2018, 19:28:13] Evgeniya Rossieva: All received, thank you, Zelimkhan Visaitovich!
[23.04.2018, 19:47:55] .: Contract don't forget the lease₽
[23.04.2018, 19:48:44] Eugenia Rossieva: Obligatory today) there the whole chip that the entrance is a ruble and the
exit - ten. Robbed at the termination of the contract)
[23.04.2018, 20:11:08] .: Okeh, but also see that it is not very different from other conditions in the city, if the others
have a similar practice, we will not push much, it is also important not to miss the room, so that we are already now
starting the move
[23.04.2018, 20:11:46] Eugenia Rossieva: Ok, I'll hold back)
24.04.2018
[24.04.2018, 11:01:51] Evgeniya Rossieva: Zelimkhan Visaitovich, good morning!
[24.04.2018, 11:02:48] Eugenia Rossieva: Kirill sent the passport of the signer from abroad, for which you have already
paid. I understand correctly that this is White lake? And Linda needs to discount it to make a power of attorney ?
[24.04.2018, 11:04:02] Eugenia Rossieva: And do we already have contracts that clients will sign with H and WL, can we
see them to understand the obligations of these companies? Are they already bilingual ?
[24.04.2018, 12:16:41 pm] .: Dobre
[24.04.2018, 12:16:43] .: Es
[24.04.2018, 12:17:03] .: Waiting for the latest version from Apollo
[24.04.2018, 12:57:55] Eugenia Rossieva: Kirill is ready to give a second signer (for Hong Kong if I understand
correctly), the price is the same.
[24.04.2018, 13:57:31] Evgeniya Rossieva: Zelimkhan Visaitovich, RW confirmed that it is necessary to instruct the HR
department to remove you from IK and UC (you are still listed there). I can inform them, but I need your confirmation
[24.04.2018, 14:01:20] .: In a week.
[24.04.2018, 14:01:36] .: Write with me in copy, I'll confirm it
[24.04.2018, 18:26:20] Evgeniya Rossieva: Zelimkhan Visaitovich, as soon as you are free we can discuss the issue of
presentations of IC MC where you are listed as a managing partner?
661
[24.04.2018, 20:35:40] Eugenia Rossieva: I sent a draf of the BR response by mail. Waiting for comments.
[24.04.2018, 20:38:50] .: Es, just let's do it tomorrow already
[24.04.2018, 20:39:10] .: We'll come up with a different wording or remove me altogether
[24.04.2018, 20:39:19] .: Are we shipping tomorrow?
[24.04.2018, 20:39:44] Eugenia Rossieva: Yes, the answer should be sent tomorrow, I was told the draf to discount
today
[24.04.2018, 20:39:54] .: Ok
[24.04.2018, 20:40:13] Eugenia Rossieva: Ready to discuss you tomorrow, RV said to remove you from the
presentations, but maybe come up with a different format?
[24.04.2018, 21:35:31] .: It's not fundamental, let's better remove it
[24.04.2018, 21:35:44] .: It's easier that way than racking your brains)
29.03.2018
[29.03.2018, 13:22:02] ... Good
[29.03.2018, 13:22:24] .: We need 2 physicist - subscribers for Cayman and for Gong Kong, not from the company
[29.03.2018, 13:22:32] Eugenia Rossieva: Good afernoon )
[29.03.2018, 13:22:36] .: Puzzle plz colleagues and Berezka
[29.03.2018, 13:22:48] Eugenia Rossieva: Just signatories by proxy ?
[29.03.2018, 13:23:06] Eugenia Rossieva: They will just sign treaties ?
[29.03.2018, 13:23:12] .: They will only get a power of attorney, employment is not necessary, but if anything, they
should be ready to come to the office for a meeting just to show up.
[29.03.2018, 13:23:17] .: Yes
[29.03.2018, 16:03:29] Eugenia Rossieva: Berezka has found a director for big city (who generally agrees), how much
are we offering for this?
[29.03.2018, 16:03:39] Eugenia Rossieva: We need to voice him the amount of payment
[29.03.2018, 17:19:07] .: How much does Horobets et al similar friends get paid?
[29.03.2018, 17:25:26] Eugenia Rossieva: It depends on the volume. Fluctuates from 5 to 15 per month. We have a
slightly special situation: no volume, but a couple of deals. You need the loyalty of the person, those are estimated.
[29.03.2018, 17:25:57] Eugenia Rossieva: I can offer birch the range + maybe the person will want more (then we need
to understand our limits).
[29.03.2018, 18:31:26] .: Let's diapason.
[29.03.2018, 18:56:51] Eugenia Rossieva: I agree to 10tr per month
[29.03.2018, 18:56:55] Eugenia Rossieva: Ok?
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06.04.2018
[06.04.2018, 15:20:19] Eugenia Rossieva: no image available
[06.04.2018, 15:45:56] .: Well great
[06.04.2018, 15:46:08] .: Moving on then.
[06.04.2018, 15:47:22] Eugenia Rossieva: All the same, only by agreement (otherwise long). Just having these
documents makes it easier and cheaper. Berezka is engaged, he was sent everything, will inform you
[06.04.2018, 15:47:52] .: Saw the letter on signatories
[06.04.2018, 15:47:56] .: Zarechnev is not an option
[06.04.2018, 15:48:00] .: We don't have any new ones?
[06.04.2018, 15:48:07] .: A man is needed very urgently
[06.04.2018, 15:48:21] Eugenia Rossieva: We only have those who are. Marianne did not give you anyone?
[06.04.2018, 15:48:27] Eugenia Rossieva: I'll check now
[06.04.2018, 15:58:52] .: It's time, not yet
[06.04.2018, 15:59:44] Evgeniya Rossieva: By the way, in our scheme we have what plans for Caymans: they can, in
principle, conclude a contract with Investment for agency services to find clients/contracts. If Investment is an agent
for a number of other companies, this does not create representation for Caymans here (the risk is only if Investment
works as an agent only for Caymans). The contract is signed by an employee of Investment under a power of attorney
from Investment. It will look like this: Caymans represented by Vasya Ivanov acting on the basis of a power of attorney
(from Investment) and an assignment agreement (between Investment and Caymans). But this is a rough idea. How
did you see the process of signing contracts by the Caymans or are we going to organise it now?
[06.04.2018, 16:02:13] .: Just now we need to organise, in fact it is Kep and IC in one person, with a license and more
capable. The question is, if the trust will be with an employee of investment, is this normal?
[06.04.2018, 16:14:26] Eugenia Rossieva: It is normal when an investor does nothing and nothing from the IR. At most -
looks for clients as an agent, but does not sign anything. Mb still corresponds with clients.
[06.04.2018, 16:34:03] .: Bottom line, can we temporarily elect an incumbent Investment officer?
[06.04.2018, 16:48:24] Eugenia Rossieva: Without a valid contract, it will be like before, one group. Would we be able to
sign the contract (cayman investment) retroactively later? And would get the approval of the RV.
[06.04.2018, 16:50:04] Evgeniya Rossieva: The employee will need a power of attorney from investment, where it
authorises him as an agent, and an agency contract between investment and caymanas to find clients and conclude
contracts.
[06.04.2018, 16:51:57] Eugenia Rossieva: And for attracting clients and zakuyucha contracts, so that it's not a sham,
caymans should ideally pay investiment. This is a foreign exchange contract
[06.04.2018, 17:43:23] .: I'll check on the currency agreement.
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[06.04.2018, 17:44:03] Eugenia Rossieva: If it is a foreign exchange contract, it should be shown to the bank, we should
look at the terms of the contract
12.11.2020
[12.11.2020, 12:41:35] .: Send full name please.
[12.11.2020, 12:47:42] Eugenia Rossieva: Vyatkina Anastasia Grigorievna
[12.11.2020, 12:50:20] Eugenia Rossieva: She mentions that she has two contracts - 2018 and 2019
[12.11.2020, 13:43:37] Eugenia Rossieva: I really need information on it segrdnya so that I verbally informed the
commissioner (he wants to give a refusal), and tomorrow - already written explanations.
But there's no Ufa analogy there?
[12.11.2020, 14:08:49] .: This is an old Moscow client there just index iMr , closed in ekb, re - signed or not I'll tell you in
30 minutes. Was ours, a long time ago at the conclusion.
26.08 sent her a balance
The application was written on 19.06. Withdrawal started in May.
[12.11.2020, 14:08:49] .: Took out profits at the beginning of the year.
[12.11.2020, 14:08:49] .: launched Clear All from 14 May.
[12.11.2020, 14:08:49] .: Not re - signed because when reading the documents vl, said she will sign when she gets the
money.
Two counts
3200$
31000$
Not on the b/n withdrawal list as the back doesn't accept those who are not oversubscribed.
[12.11.2020, 14:09:04] .: Not an analogy by the looks of it.
[12.11.2020, 14:13:25] Eugenia Rossieva: Yes to me also confirmed it. Requested the documents
[12.11.2020, 16:03:48] .: As there will be an understanding, write a letter to me, Golubev and Vsp on how to further
build communication with the client
[12.11.2020, 16:11:17] Eugenia Rossieva: There is a problem that you described. Since the client is stubborn, we need
to look for options to solve it.
According to her, she wrote to the Central Bank and it was there that they advised her to go to the place where she
applied (because the contracting party is not supervised, the Central Bank cannot do anything). It is not good that the
CBR receives this information, they do not throw it away, they save it. They will present it later.
How much she can be negotiated with now is best told by her fs. It better be.
My job is to unsubscribe.
[12.11.2020, 16:15:42] .: Yes, action for dp, a comment letter from you would be good
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[12.11.2020, 17:56:59] .: Ready for an op - ed?
[12.11.2020, 17:59:28] Eugenia Rossieva: Yes
[12.11.2020, 17:59:48] .: Come in black 5 min.
The correspondence of the participants of the group "Restructuring", which included "Linda"
(subscriber number +3 - 57 - 99 - 920 - 015), "Apollo" (subscriber number +3 - 57 - 96 - 218 -
890), "Munaev" (subscriber number +7 - 903 - 100 - 41 - 84), was found and examined; in
addition, a subscriber with the phone number +7 - 965 - 748 - 88 - 88, used by the accused
Pakhomov V. S., was a participant of the group.S. During the examination, correspondence was
established, including the following:
[15.01.2018, 14:27:38] +7 965 - 74888888888 - : And I have no confidence that it's not Stepanov
[15.01.2018, 14:32:53] Roman Shpakov: And we also have suspicions that this is not coming through the internal
system.
[15.01.2018, 14:37:39] Roman Shpakov: Well, and the cherry on the cake: no letters at all.
[15.01.2018, 14:40:41] Linda: Dear Roman, please advise what u mean there are no letters?
[15.01.2018, 14:41:00] Linda: Sorry have to communicate in English if Apollo is in
[15.01.2018, 14:41:11] Linda: Internal
[15.01.2018, 14:43:28] +7 965 - 74888888888 - : Well, as if I am the same here and all in English write for some reason ...
[15.01.2018, 14:47:41] Linda: I will ask a question and in Russian. Who said there are no letters?
[15.01.2018, 14:50:18] +7 965 - 74888888888 - : Do you believe in god ?
[15.01.2018, 14:51:33] Linda: And?
[15.01.2018, 14:53:26] +7 965 - 74888888888 - : Yes or no ?
[15.01.2018, 14:54:10] Linda: Naturally.
[15.01.2018, 14:54:46] +7 965 - 74888888888 - : This is not natural, by the way. - So, you are able to believe in those
things and events that you have not seen with your own eyes, but I do not.
[15.01.2018, 14:55:22] Linda: Vova, be more specific.
[15.01.2018, 14:55:38] +7 965 - 74888888888 - : Where to be more specific.
[15.01.2018, 14:55:59] Linda: You mean your people said there are no letters?)
[15.01.2018, 14:56:20] +7 965 - 74888888888 - : I'm saying you haven't seen them.
[15.01.2018, 14:56:22] +7 965 - 748888888 - : Me too
[15.01.2018, 14:57:24] Linda: Vova, there are letters. And if you haven't seen them with your own eyes it doesn't mean
they don't exist. I have a lot of evidence that there are letters.
665
[15.01.2018, 14:57:39] +7 965 - 74888888888 - : Well it's like with god.
[15.01.2018, 14:58:40] Linda: If there are no letters according to your version, then why our regulator has been writing
us letters and continues to do so.
[15.01.2018, 14:59:07] Linda: Next, you said yourself that your people got a letter from the regulator from us.
[15.01.2018, 14:59:30] Linda: Further with me people have repeatedly confirmed that your Central Bank writes letters
to Cyprus
[15.01.2018, 15:00:03] Linda: Further why would our regulator want to do that? And why would we want trouble with
our own regulator?
[15.01.2018, 15:00:29] +7 965 - 74888888888 - : Further I have not received confirmation from anyone, not even you,
no one has seen the emails.
[15.01.2018, 15:00:37] +7 965 - 748888888 - : I'm figuring - out the rest
[15.01.2018, 15:01:12] Linda: The letters are there and they have been seen by people who are from the regulator.
[15.01.2018, 15:01:50] +7 965 - 74888888888 - : And why did not send a picture ?
[15.01.2018, 15:03:11] Linda: We were given letters from our regulator. We have not been given any pics of the letters
from the Central Bank.
[15.01.2018, 15:28:04] Apollo: Guys i will be in Moscow on Thursday. On Wednesday we deliver our answer to latest
request. We can speak more in person there
[15.01.2018, 15:28:05] Linda: no image available
[15.01.2018, 18:27:22] +7 965 - 74888888888 - : What of the papers can we show our ?
[15.01.2018, 18:29:02] Linda: Show first this is an official letter from the regulator it is not confidential
[15.01.2018, 18:31:24] Linda: You can show the second one too but you have to have Apolo ask Haris because if he
showed those letters to anyone it's a coal case and it says so there.
[15.01.2018, 18:31:37] +7 965 - 74888888888 - : Then we will - not
[15.01.2018, 18:31:54] +7 965 - 74888888888 - : Yes and there in Greek
[15.01.2018, 18:32:07] Linda: But Apo and I liked the accusations you write about Cyprus))
[15.01.2018, 18:32:25] Linda: You can do a translation of the letter from Greek
[15.01.2018, 18:46:05] +7 965 - 74888888888 - : Where are the charges ?
[15.01.2018, 19:20:32] Linda: Vova enough. I think Apo is right and we will all talk in person. When you write what you
wrote above one should also understand what you are saying.
You're throwing around accusations that there were no letters.
Once again, there have been letters. And as long as we have fun here and don't find out who's writing them, they'll
continue to be written.
There are letters, it was confirmed by people in the regulator.
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Also, the questions now are.
1 you said your people got a response from our regulator.
2 trv said that he solved the issue and there will be no more letters
There are letters.
We can go the other way, Haris will answer everything about the company, then we will see what happens and if the
case goes to court we will find out exactly whether there were letters or not.
Instead of helping us, you write that nobody writes to us.
[15.01.2018, 19:24:24] +7 965 - 7488888 - : 1. - I do not accuse
2. I didn't say there were no letters, I said I didn't see them.
3. I didn't say I'd decide, I said I'd try to do it.
4. these letters are not in the CPD system, which means there is a possibility that they are fake and made on the
employee's own initiative, not the bank's.
[15.01.2018, 19:24:43] +7 965 - 74888888888 - : I need at least the number of the outgoing letter
[15.01.2018, 19:40:07] Linda: It is impossible. Such letters can not write such letters lef employees. This is a serious
accusation by the Central Bank to the individual and to the company , our regulator can not just write such letters to
Haris.
they can't just write from a torch.
Those letters are there. Let them look at other systems. They're there. Talk to your general manager, he told me he
found the person who wrote the letters, it was afer the first two letters.
There are letters.
[15.01.2018, 19:43:04] +7 965 - 74888888888 - : This could easily be Stepanov's person. I said how many people can
send these letters. About the level of corruption in Russia I think it is not worth telling. It could also be a competitor.
There are a - lot of options.
[15.01.2018, 19:43:54] +7 965 - 74888888888 - : And without an outgoing number, I have a hard time finding it
[15.01.2018, 19:45:14] Linda: Vova hear me. This can only be written by people with access to the internal system that
is between regulators. This is not Stepanov and not competitors these are official requests.
[15.01.2018, 19:45:28] +7 965 - 748888888 - : Fuck - yeah.
[15.01.2018, 19:45:31] +7 965 - 74888888888 - : Turn on your brain
[15.01.2018, 19:45:45] +7 965 - 74888888888 - : 5000 people - have this access
[15.01.2018, 19:45:55] +7 965 - 74888888888 - : Stepanov could have paid anyone
[15.01.2018, 19:46:01] +7 965 - 748888888 - : Or any competitor
[15.01.2018, 19:46:18] +7 965 - 74888888888 - : This is not fucking Cyprus where three disabled - people have access
[15.01.2018, 19:47:41] +7 965 - 748888888 - : Hear me out
[15.01.2018, 19:47:53] +7 965 - 74888888888 - : There is no - letter on the official list
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[15.01.2018, 19:48:08] Linda: What the fuck anyone! Do you realise what you're saying?
If the case isn't closed it goes to court, and fuck it, they're going to take her down from the position that they're
accepting letters from some fake people and launching an investigation into the company.
[15.01.2018, 19:48:39] +7 965 - 74888888888 - : How does she know who writes her letters ?
[15.01.2018, 19:49:09] Linda: What the fuck did your people say they got a response from the regulator then????
[15.01.2018, 19:50:22] +7 965 - 74888888888 - : This was confirmed not by my people.
[15.01.2018, 19:50:28] +7 965 - 74888888888 - : These can't see the emails
[15.01.2018, 19:50:37] +7 965 - 74888888888 - : Do you realise how confusing it is ?
[15.01.2018, 19:50:49] +7 965 - 74888888888 - : And how the fuck did you answer me - there
[15.01.2018, 19:50:52] +7 965 - 74888888888 - : Change - your tone of voice
[15.01.2018, 19:51:03] Linda: Whose?! You told me yourself! The letter received a reply norm.
[15.01.2018, 19:51:07] Linda: Tone!
[15.01.2018, 19:51:15] Linda: You haven't composed Apolo's tone yet!
[15.01.2018, 19:51:29] Linda: You wrote such a thing to us!
[15.01.2018, 19:52:22] +7 965 - 74888888888 - : I don't give a fuck about tone.
[15.01.2018, 19:54:18] +7 965 - 74888888888 - : Apo is definitely not hysterical and knows how to deal with issues
calmly
[15.01.2018, 20:00:26] Linda: I see. Now listen calmly. The letters are official and you have to find who's writing them.
Otherwise they will keep sending them.
Here, you tell me why you told me that your people said the regulator's response was OK and there would be no more
letters.
[15.01.2018, 20:03:50] +7 965 - 74888888888 - : Linda, I am not arguing about the presence of letters, I say that no one
has seen them, officially they are not written, they are not in the register, but it does not exclude that they can be
written illegally by employees of the Central Bank.
[15.01.2018, 20:04:03] +7 965 - 748888888 - : This is Russia
[15.01.2018, 20:04:42] +7 965 - 74888888888 - : Especially as you know we have already received letters from the fsb
from Zelim - 's people.
[15.01.2018, 20:08:42] Linda: Our regulator can't be sent letters by some lefist, just a Central Bank employee.
I know that in August, when the first letter was sent, they immediately replied that the Central Bank should go to the
woods. Then the letters started, with an interval of a month, the one who writes knows that it is necessary to reply to
the regulator within a month.
[15.01.2018, 20:08:56] Linda: I also know what the exchange control was involved in.
[15.01.2018, 20:08:58] Linda: Yours
[15.01.2018, 20:10:06] +7 965 - 74888888888 - : How ?
668
[15.01.2018, 20:14:48] Linda: How? This department and mentioned in the first letters, back in August. That's where
the 180kk amount came from
[15.01.2018, 20:15:10] +7 965 - 74888888888 - : And then what department ?
[15.01.2018, 20:20:52] Linda: On the internal communication system between regulators. They've always come by it.
It's just that the first letter mentioned exchange controls.
[15.01.2018, 20:22:20] +7 965 - 74888888888 - : There is no way to get the letter at all ?
[15.01.2018, 20:31:15] Linda: If I could I would get it. I've got it all out , dates, content, but what do I say now I don't
even know.
Like, we said that the Central Bank would write you an answer that the issue is closed, and now I. say, you know, they
tell me that the Central Bank did not write you an official letter.
I know, from what you and Zelimkhan told me.
1. My question was solved by Vova's men
2 The letters your people said they received
[15.01.2018, 20:31:30] Linda: I know for a fact the first request was 17 pages long
[15.01.2018, 20:32:18] Linda: Everything has been carried since August.
[15.01.2018, 20:32:24] Linda: It has begun
[15.01.2018, 20:34:12] +7 965 - 74888888888 - : And what is the difficulty in getting the letters ?
[15.01.2018, 20:36:18] Linda: They don't give them to me, and no one will take pictures of them either. I can get their
letters. But the kind of letters like official investigations from another regulator won't give them to me. I don't know
how else to explain it anymore.
[15.01.2018, 20:37:10] Linda: I know what we're going to get written.
[15.01.2018, 20:38:20] Linda: I know roughly what our regulator can and will do, we have been warned
[15.01.2018, 20:38:35] Linda: We have an election in January and this hype is unnecessary
[15.01.2018, 20:47:53] +7 965 - 74888888888 - : We have in March
[15.01.2018, 21:15:17] Linda: I see, we are going round in circles. I understand one thing that our issue has not even
been addressed .
1. I think this way, translate Haris' letter into Russian and give it to your people.
2. It says that it is confidential, such letters are written only during investigations.
3. I propose the following, Haris answers as a lawyer I want to know officially why the investigation. We will tell our
regulator that the letters from the Central Bank are not official, and then we will see how things develop.
4. You said this morning that there are no letters. Roman writes to me, based on your words that "the cherry on the
cake is no letters".
If you don't think they are, let's go on principle Then we'll see who was right and who was wrong.
We closed the issue, and instead of helping us, I got a claim. And I don't care what happens now. Quite the opposite.
I'll go on principle, but I'll prove to you that there are letters from the Central Bank, don't give me claims when I
closed the issue.
669
[15.01.2018, 21:17:10] +7 965 - 74888888888 - : Find where I wrote that there are no letters ? - Stop wishful thinking
and switch off the victim syndrome, you are a top manager, not an ordinary employee.
[15.01.2018, 21:18:54] Linda: And we also have suspicions that it's not coming through the internal system.
[15.01.2018, 21:18:54] Linda: Well, and the cherry on the cake: no letters at all.
[15.01.2018, 21:19:09] Linda: Roman wrote this.
[15.01.2018, 21:21:58] Linda: I am far from being a victim and never will be, not my style.
I know I'm right.
I know there are letters.
The correspondence of the members of the "Reorganisation" group, which included "Shpakov" (subscriber number
+7 - 905 - 735 - 55 - 88), "Rossieva" (subscriber number +7 - 985 - 173 - 43 - 21), and "Munaev" (subscriber number +7 -
903 - 100 - 41 - 84), was found and examined. During the inspection, correspondence was established, including the
following:
[10.04.2018, 13:56:34] Reorganisation: Messages and calls are protected by end - to - end encryption. Third parties,
including WhatsApp, cannot read or listen to them.
[10.04.2018, 13:56:34] Eugenia Rossieva created the group Reorganisation
[10.04.2018, 13:56:34] Evgeniya Rossieva added you
[10.04.2018, 14:01:29] Evgenia Rossieva: Info on reorganisation: the fns reported that the black mark on Gorobets (she
is there as gd kyubi group - 100% participant of the new company) and Frolov (gd baklan and baklan invest - old
stories) because of them will be rejected. It is proposed - instead of Frolov to put Munayev Z on the new stand - out
company gd, especially to him later it will be sold). In kyubi groups urgently replace gd Gorobets for someone. We will
submit on kyubi group, send them the documents and immediately submit for reorganisation. Let them do on this
basis otherwise what are the agreements for.
[10.04.2018, 14:02:20] Eugenia Rossieva: Somehow they dug closely so far neither on Frolov from Gorobets refusals
were not, there are no marks in the open registers on them. Shit!
[10.04.2018, 14:18:10] Roman Shpakov: Come on in
[10.04.2018, 17:01:17] .: I'm on my way, let's go in. As a gd I do not need to put me, it is necessary as the owner, look
for a new person for us on gd
[10.04.2018, 17:42:40] Evgeniya Rossieva: You can be put gd temporarily, when kg will give his share to you in this
company, will change to a lot of gd (just as an idea). There is time to think until Thursday - Friday as we are now
solving the issue with Gorobets )
[10.04.2018, 17:43:52] .: Let's go straight to the new gd, the time is just about right
[11.04.2018, 15:22:22] Evgenia Rossieva: on Gorobets all options will require time (5 working days) which we do not
have, it is faster to remove her from the CG and submit for reorganisation in 2 days (those if we change the gd in the kg
tomorrow, then on reorganisation will give the documents on Monday). Signatory in the bank for kg - RV, the change
670
of director does not affect the bank, for companies - just notify the Bank of Russia about the change of director of
kyubi groups.
[11.04.2018, 18:07:53] Evgeniya Rossieva: Roman Valeryevich, are we going to change Gorobets to kg?
[11.04.2018, 19:41:27] Eugenia Rossieva: On reorganisation - Berezka confirmed that the documents will take.nominal
in the daughter gives him (now will send) I all complete with the New nominal, send to check the curator, as soon as
he gives good, goes to the notary with matyukhin, we certify, transfer to registration. All by the end of the week.
[11.04.2018, 19:41:55] Eugenia Rossieva: Tomorrow on Avalon we will submit on the change of address still to clear
Gorobets.
[11.04.2018, 19:55:00] Roman Shpakov: Ok
[12.04.2018, 17:19:42] Evgenia Rossieva: Application for reorganisation of the EC signed, waiting for the supervisor
from the fns to give them the documents and the final OK on all other documents. On Gorobets also filed today.
[12.04.2018, 17:20:17] Roman Shpakov: Ok
[22.05.2018, 17:28:13] Eugenia Rossieva: called birch: reorganisation confirmed, tomorrow scans, the day afer
tomorrow the originals in hand.
[05.01.2019, 12:40:29] Roman Shpakov lef the group
The correspondence of the members of the group "Fin Potoki", which included "Linda" (subscriber number +3 - 57 - 99
- 920 - 015), "Munaev" (subscriber number +7 - 903 - 100 - 41 - 84), Tatyana Milekhina (subscriber number +7 - 916 - 981
- 81 - 80) was found and examined. During the inspection, correspondence was established, including the following:
[19.06.2020, 14:17:03] Fin Potoki: Messages and calls are protected by end - to - end encryption. Third parties,
[19.06.2020, 14:17:03] Linda created the group "Fin Potoki"
[19.06.2020, 14:17:03] Linda added you
[19.06.2020, 14:18:04] Linda: Tanya so de will be necessary according to the contract I will think which one to send
money from Q Broker but from the settlement account to the account of Constance Investment company.
[19.06.2020, 14:18:14] Linda: It's about 230k euros.
[19.06.2020, 14:19:20] Linda: Actually this money in the books q broker we can display as an investment , but this
money from constance will not return
[19.06.2020, 14:19:41] Linda: Tonight we'll discuss in threes at 17.00 all right?
[19.06.2020, 14:20:02] Linda: We can show it as a loan
[19.06.2020, 14:20:43] Linda: Then the loan repayment will be reissued to Aspard.
[19.06.2020, 14:20:47] Linda: I'll tell you today.
[19.06.2020, 14:21:20] .: I'm ok at 17.
[19.06.2020, 14:21:25] Linda: Ok.
[19.06.2020, 14:21:44] .: As an investment in a brokerage account at Constance for Q-BROKER I think it's ok
671
[19.06.2020, 14:22:17] Linda: No.
[19.06.2020, 14:22:19] Linda: Different.
[19.06.2020, 14:23:57] Tatiana Melekhina: Let's discuss)
[19.06.2020, 16:58:00] Tatiana Melekhina: Shall we meet?
[19.06.2020, 16:58:14] Linda: Yes.
[02.11.2020, 15:03:12] Tatiana Melekhina lef the group
The correspondence of the members of the group "WL", which included "Yuri Orlov" (subscriber
number +7 - 926 - 306 - 82 - 26), "Linda" (subscriber number +3 - 57 - 99 - 920 - 015), "Apollo"
(subscriber number +3 - 57 - 96 - 218 - 890), "Munaev" (subscriber number +7 - 903 - 100 - 41 -
84) was found and examined. During the inspection, correspondence was established, including
the following:
[15.11.2018, 16:05:31] Linda: Yura
[15.11.2018, 16:05:37] Linda: Who invented the phone
[15.11.2018, 16:05:41] Linda: For WL?
[15.11.2018, 16:06:01] Yuri Orlov: Which one is in the Caymans?
[15.11.2018, 16:07:36] Linda: Yes
[15.11.2018, 16:08:02] Yuri Orlov: There was an instruction to buy a number in the Caymans - they bought it
[15.11.2018, 16:08:28] Yuri Orlov: The redirection was made to a number in Cyprus
[15.11.2018, 16:08:33] Yuri Orlov: Mobile
[15.11.2018, 16:08:36] Linda: And there is a brain.
[15.11.2018, 16:08:36] Linda: Someone has to answer the phone.
[15.11.2018, 16:08:39] Yuri Orlov: Which pointed out
[15.11.2018, 16:08:48] Yuri Orlov: Yes
[15.11.2018, 16:08:54] Linda: Which one?
[15.11.2018, 16:32:05] Linda: Which one?
[15.11.2018, 16:32:12] Linda: Did you specify a phone number?
[15.11.2018, 16:32:30] Yuri Orlov: 35797754954
[15.11.2018, 16:42:56] .: Whose phone is this?
[15.11.2018, 16:54:44] Yuri Orlov: Letter from Andreas H dated 26 June 2018, at 16:56. In copy Linda and you,
Zelimkhan.
[15.11.2018, 16:55:17] .: Give me a screenshot here
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[15.11.2018, 16:57:27] Yuri Orlov: no image available
[15.11.2018, 16:58:04] .: Linda, so the tel was supposed to be answered by Andreas?
[15.11.2018, 17:22:02] Linda: I'll find out.
[15.11.2018, 17:23:00] Linda: And did you see the call times?
[15.11.2018, 19:24:25] .: Nope
In any case, we have to keep records, return phone calls, whoever calls us.
[15.11.2018, 19:24:32] .: What did Andreas say?
[15.11.2018, 20:49:40] Linda: That he got a call at night private's number and he picked up the phone and it was
dropped . The call forwarding doesn't work
[15.11.2018, 20:49:41] Linda: Normal people should have done the test
[15.11.2018, 20:59:56] .: Ask him to please call back on the missed number with the question that the client called and
here he is calling back, and say a few words that Vl is engaged in asset management, etc., has partners in Russia and
Asia, is ready to work with individuals and lawyers, and that the client can safely communicate with Russian
representatives.
[15.11.2018, 21:00:15] .: Just don't let him say that there are agents or intermediaries in Russia, etc., it will scare them
away.
[15.11.2018, 21:01:32] Yuri Orlov: The test was done - no one picked up the phone. The ringback tone was going, in
fact, the call passed. I will check tomorrow myself.
[15.11.2018, 21:07:03] Linda: I'm telling you again there was no number
[15.11.2018, 21:07:24] Linda: If the test was done then Andreas should have picked up the phone.
[15.11.2018, 21:07:32] Yuri Orlov: When was the call? At least tentatively?
[15.11.2018, 21:07:46] Linda: Write to him and he'll tell you everything.
[15.11.2018, 21:07:53] .: no image available
Correspondence with the contact "Smirnova Yaroslava", subscriber number +7 - 926 - 234 - 76 - 44, with whom
[18.11.2020, 19:38:49] Yaroslava Smirnova: Good afernoon!
Sent the first contract (for redemption of units through Broker) to IR today for assignment of number at 16:48.
The result is nil. No reply, no contract number, and no signed contract at all. No one is able to influence Stas, nor his
employees.
The risks are as follows: if we fail to extend the fund in time, the shareholders will have to buy back assets worth 300
million rubles from the Fund or lose their licence.
[18.11.2020, 19:39:37] Yaroslava Smirnova: I have done all - all the documents for them, and they can't assign a
number, print and sign the contract.
[18.11.2020, 22:02:18] .: Good, you should then call your colleagues if you are already so extreme
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[18.11.2020, 22:02:32] .: I've talked to Stanislav, he quickly gave approval, now we need implementation
[18.11.2020, 22:07:00] Yaroslava Smirnova: Yesterday I called Anastasia. And even with her is not so easy to call,
everyone is very busy.
The coordination is good, but the implementation is lame. Answering emails for 4 - 5 hours is overkill. Implementation
is very slow in IR, and I don't even know who to talk to about it(((
[18.11.2020, 22:21:30] Yaroslava Smirnova: I could be wrong, but it seems to me that the whole point is that Stas
himself does not "fluff" anyone. I write letters to nowhere, he doesn't react at all. And employees without his reaction
do not react either.
[18.11.2020, 22:22:30] Yaroslava Smirnova: Only Eugenia is "at the top", the contract was corrected, the orders were
signed, comments were given. Otherwise - silence!
[18.11.2020, 22:48:31] .: They've had a request from the nrd for 26 questions for 5 days since pon, there's tranches on
purity and argento, they're in a fuss
[18.11.2020, 22:48:51] .: And since the request came to them in a short time, that's why such a situation apparently
[18.11.2020, 22:49:06] .: I will tell both Stanislav and Anvstasia to hurry up once again
[18.11.2020, 22:49:20] .: You in turn tomorrow with them personally tighten to completion
[18.11.2020, 22:49:38] Yaroslava Smirnova: Thank you, I hope this will be enough to speed things up
[18.11.2020, 22:53:12] .: �
Correspondence with the contact "Alexey Golubev", subscriber number +7 - 921 - 858 - 16 - 24, with whom
12.01.2017
[12.01.2017, 13:13:15] Alexei Golubev: Zelimkhan, good afernoon.
Eugenia said you can be contacted, how to get reports on CHP ?
Yegudkin and Salnikov
[12.01.2017, 13:35:23] Alexey Golubev: Messages and calls are protected by end - to - end encryption. Third parties,
[12.01.2017, 13:39:34] ... Good
[12.01.2017, 13:39:38] ... ...: Drop your email
[12.01.2017, 13:57:59] Alexey Golubev: Send here please , I still have not made mail
[email protected]
[12.01.2017, 16:25:16] Alexey Golubev: Got it , thanks
And the fact that there is no change there for 2 months is normal ?)....
13.01.2017
674
[13.01.2017, 10:25:39] .: It is better to write on the back or ask colleagues, you can not chop from the shoulder
[13.02.2017, 18:30:36] Alexey Golubev: I put the date of receipt today ?
[13.02.2017, 18:31:25] .: Yes
[13.02.2017, 19:24:33] Alexey Golubev: Just in case I'll write here, on the post file
[13.02.2017, 19:29:53] .: Already have.
02.03.2017
[02.03.2017, 16:07:52] Alexey Golubev: Zelimkhan, good day . I can not get an answer to the questions, tax character
neither from Constance or legal, what other options are there ?:).
[02.03.2017, 21:38:15] ... Good
[02.03.2017, 21:38:34] .: Saw the correspondence
[02.03.2017, 21:38:56] .: Write here tomorrow by lunchtime, I'll see if there are still options available
[03.03.2017, 09:01:38] Alexey Golubev: Good morning
1. When working through Constance, what is the tax rate on dividends from foreign companies?
2. Is the tax rate on option income any different ?
(3) Taxation at the rate of 30 per cent shall be levied in respect of:
income on securities issued by Russian organisations, the rights to which are accounted for on a foreign nominee
holder's depo account, a foreign authorised holder's depo account and/or a depo account of depository programmes,
paid to persons whose information has not been provided to the tax agent.
Is this the case and what does it mean?
Source : http://ppt.ru/nalogi/ndfl
Please provide detailed answers
06.03.2017
[06.03.2017, 11:49:36] Alexey Golubev: Good afernoon , is there anything on this issue ?
[06.03.2017, 18:51:16] .: Good!
[06.03.2017, 18:51:36] .: Of the in - house or free options, no
[06.03.2017, 18:51:46] .: But NOA will be able to take over
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[06.03.2017, 18:52:00] .: It will be paid for, but very inexpensive
[06.03.2017, 18:52:20] .: I.e. The question will be considered in conjunction with specific solutions and not only on
constans
[06.03.2017, 18:52:43] .: For coordination on NOA - to Dmitry Lepeshkin
[06.03.2017, 18:57:11] Alexei Golubev: Zelimkhan, good evening. Maybe I do not understand something or do not ask
the question correctly.
We take money under management for investment activities, the client asks what tax he has to pay for investment
activities, working with us, and we will send him to a paid consultation? .....
[06.03.2017, 18:57:48] .: We are not a tax agent in terms of foreign companies
[06.03.2017, 18:58:13] .: This is actually the answer to the question
[06.03.2017, 18:59:08] Alexey Golubev: I understand this perfectly well, just a dubious service from our side turns out.
If the client wants to understand all the figures that will be when working with us, and I can not give them to him
[06.03.2017, 19:00:39] .: In terms of the lack of response from fellow constancers, that's really not okay
[06.03.2017, 19:01:20] .: But they certainly won't go into such strong details as taxation of specific individuals in a
specific country
[06.03.2017, 19:02:13] .: You can also ask Lepeshkin how to do it
[06.03.2017, 19:02:23] .: For Constance, he's the main person responsible.
[06.03.2017, 19:40:49] Alexey Golubev: Okay, thank you
02.04.2019
[02.04.2019, 17:55:11] Alexey Golubev: Zelimkhan, good afernoon. Could you please give me another hint?
There are two bundles
The "c" is the WLC+WLM+WL docks.
"bn" is the docks of WLC+Sim + WL
Is this correct? And is it possible to sign a document with WL without the other two (if it is more convenient for the
client and us)?
[02.04.2019, 20:59:57] .: Good!!!
[02.04.2019, 21:00:01] .: All correct
[02.04.2019, 21:00:26] .: If only with Vl, Andreas (who is back) has to coordinate with his own to take directly to Vl
[02.04.2019, 23:22:31] Alexey Golubev: And there is a link there in the app that sim agent
[03.04.2019, 10:36:00] .: Yes, but in the case of bn you need a contract with the host company, just like in the case of B
[03.04.2019, 10:36:27] Alexey Golubev: aha , it turns out the useless tail is only WLC
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[03.04.2019, 10:36:31] Alexey Golubev: right?
[03.04.2019, 10:36:49] .: Ess.
[03.04.2019, 10:36:54] Alexey Golubev: ok thank you very much
[03.04.2019, 10:36:55] .: It is so, for the communion of the rf
[03.04.2019, 10:37:00] Alexei Golubev: I got it
Correspondence with the contact "Nikolay Padalka", subscriber number +7 - 964 - 530 - 33 - 76, with whom
09.11.2020
[09.11.2020, 11:01:58] .: Salute
There was no call with Constance on Friday?
[09.11.2020, 11:02:16] Nikolay Padalko: Greetings
[09.11.2020, 11:02:29] Nikolay Padalko: They have not confirmed the meeting
[09.11.2020, 11:02:51] Nikolay Padalko: Although we have outlined the agenda.
[09.11.2020, 11:03:32] .: Can you cluster all the open questions to Linda and Dmitri on mr in the mail or jeer?
[09.11.2020, 11:05:07] Nikolay Padalko: I'll do it tomorrow, ok?
[09.11.2020, 11:06:39] .: Then it's not worth it, don't worry about it
[09.11.2020, 11:07:05] Nikolay Padalko: I just all weekend with reports. Finished yesterday at 11
[09.11.2020, 11:07:32] Nikolay Padalko: That is without days off)))
[09.11.2020, 11:07:49] Nikolay Padalko: I have recused myself for today...
[09.11.2020, 11:22:25] .: Got it)
[09.11.2020, 11:23:14] Nikolay Padalko: But for once we will give reports without delay. Because I have already
prepared everything: and ku and vl
[09.11.2020, 11:23:32] Nikolay Padalko: Nastia has her birthday today, if you write to her, I think it will be pleasant for
her
[09.11.2020, 13:05:30] Nikolay Padalko: I propose to move the OP by 3 tomorrow
[09.11.2020, 13:05:40] Nikolay Padalko: So how is the food committee there aferwards
[09.11.2020, 13:05:53] Nikolay Padalko: If you're ok, I'll write to Yulia
[09.11.2020, 13:23:55] .: Go ahead, send me her number
[09.11.2020, 13:24:10] .: On 14 is better then
[09.11.2020, 13:37:42] Nikolay Padalko: 89688037793
[09.11.2020, 15:15:54] .: Chernov and Balesny Sergei Petrovich are on the list for withdrawal
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[09.11.2020, 15:15:54] .: first prosecutor's office
[09.11.2020, 15:15:54] .: Second Admiral
[09.11.2020, 15:16:07] .: From Vsp to transaction trail priorities
[09.11.2020, 15:26:01] Nikolay Padalko: OK, noted
03.02.2020
[03.02.2020, 13:11:10] Nikolay Padalko: Greetings. Marketing has not yet received the budget for the Sim site, so that
we do not have delays with the launch - please allocate.
[03.02.2020, 13:29:57] .: Salute
Okay, I'll do the forcing.
[03.02.2020, 13:30:18] Nikolay Padalko: Thank you
07.02.2020
[07.02.2020, 14:06:22] .: Please make yourself promptly mail Vl
[07.02.2020, 14:06:27] .: Send it to me.
[07.02.2020, 14:24:16] Nikolay Padalko: I ordered it yesterday
[07.02.2020, 14:24:32] Nikolay Padalko: I would be grateful if you could help speed up the process
[07.02.2020, 14:24:37] Nikolay Padalko: I'll put you in the copy
[07.02.2020, 14:25:21] Nikolay Padalko: Just a question: VL or VL Consulting?
[07.02.2020, 14:25:48] Nikolay Padalko: I asked to make exactly wl - consulting.ru
[07.02.2020, 14:25:57] Nikolay Padalko: As a future site
[07.02.2020, 14:36:16] Nikolay Padalko: I'll make a w - lake, in short)
[07.02.2020, 14:37:10] .: Forget it, hit the general and don't sweat it)))
[07.02.2020, 14:40:31] Nikolay Padalko: Made an enquiry, you are in the copy
[07.02.2020, 14:43:18] Mykola Padalko: The mission of WL Consulting is to find the most favourable and safe financial
solution for each client, in accordance with the principles of uniqueness and efficiency.
[07.02.2020, 14:43:18] Nikolay Padalko: Here's what I came up with
[07.02.2020, 14:43:19] Nikolay Padalko: Will be on the site
[07.02.2020, 15:31:45] .: With VL make the same missions
[07.02.2020, 15:31:50] .: You can copy it.
[07.02.2020, 15:31:57] .: It's not like they're competing companies)
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[07.02.2020, 15:32:07] .: On the contrary content where possible should match
[07.02.2020, 15:34:15] Nikolay Padalko: You can't. WL is a controlling person
[07.02.2020, 15:34:30] Nikolay Padalko: VLC - consultant
[07.02.2020, 15:35:19] Nikolay Padalko: The missions are similar, but the logic is such that you can't pick on it: WL is
looking for a solution, and WL is implementing it
[07.02.2020, 15:38:09] Nikolay Padalko: We discussed with Eugenia, no strategies and money management, nothing
like that should be on the site. Because the risks
[07.02.2020, 16:01:05] .: You bet you can
[07.02.2020, 16:01:15] .: Same direction
[07.02.2020, 16:01:26] .: The mission is not divided by legal entities)
[07.02.2020, 16:01:32] .: It's not a legal element)
[07.02.2020, 16:01:46] .: words yes, I agree
[07.02.2020, 16:02:05] .: You can replace solutions, maintenance, support, etc. simply and that's it
[07.02.2020, 16:02:13] .: But get as close to the original as possible
[07.02.2020, 17:28:22] Nikolay Padalko: You have for a long time?
[07.02.2020, 18:34:34] .: rfc for conclusions how's it going?
[07.02.2020, 18:34:48] .: Ruslan has already scheduled two withdrawal meetings for me on Tuesday.
[07.02.2020, 19:04:29] Nikolay Padalko: Training conducted
[07.02.2020, 19:05:01] Nikolay Padalko: Eugenia promised to issue today
[07.02.2020, 19:08:21] Nikolai Padalko: I've already got her on hold
[07.02.2020, 19:08:44] Nikolay Padalko: It will be on Monday for sure, I think
[07.02.2020, 20:01:19] .: Okay.
13.02.2020
[13.02.2020, 17:46:16] Nikolay Padalko: If a client needs to make a confirmation of money, we can do it, right? I
remember with RV discussed that through the sale of aiti property and art objects.
[13.02.2020, 17:46:37] Nikolay Padalko: Who is doing this?
[13.02.2020, 18:52:01] .: Eugenia
[13.02.2020, 18:52:28] Nikolay Padalko: The Sim site will be ready for delivery tomorrow. Everyone worked in sweat
and made a really good product, considering the budget and deadlines. But we still don't have the budget allocated! I,
as soon as I get the final figure, will go personally to RV with this topic.
[13.02.2020, 18:53:01] .: Come on
[13.02.2020, 18:53:04] .: It can't get any worse.
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[13.02.2020, 18:53:17] .: The amount is about to be released.
[13.02.2020, 18:53:29] Nikolay Padalko: Speaking of her. She is swamped with tasks from IR and all my questions are
locked on her, and not moving
[13.02.2020, 18:54:22] Nikolay Padalko: This is despite the fact that I have distributed the tasks in time
[13.02.2020, 18:54:35] Nikolay Padalko: The question is not for Eugenia, but for prioritisation
[13.02.2020, 19:58:59] .: I have the same problem with it to be honest.
[13.02.2020, 19:59:53] .: I suggest you raise the question in a trivial format: who else to hire in Yud so that the issues of
the MR/RF nexus have time to close too
[13.02.2020, 20:00:02] .: Can you email me and her
[13.02.2020, 20:00:16] .: And I will further push through and alternative solutions to the issue
The correspondence of the members of the group "Fantastic 4",
which included "Roman Shpakov" (subscriber number +7 - 905 - 735 - 55 - 88), "Linda"
(subscriber number +3 - 57 - 99 - 920 - 015), "Munaev" (subscriber number +7 - 903 - 100 - 41 -
84) was found and examined; in addition, a subscriber with the phone number +7 - 965 - 748 - 88
- 88, used by the accused Pakhomov V. S., was a member of the group.S. During the examination,
correspondence was established, including the following:
13.11.2017
[13.11.2017, 21:51:44] Fantastic 4: Messages and calls are protected by end - to - end encryption. Third parties,
[13.11.2017, 21:51:44] Roman Shpakov created the group "Team A"
[13.11.2017, 21:51:44] Roman Shpakov added you
[13.11.2017, 21:55:01] Roman Shpakov: Colleagues, this group was created to coordinate actions.
[13.11.2017, 21:55:36] Roman Shpakov: Everyone has one main task:
Obtain those letters that were sent by CySEC.
[13.11.2017, 21:55:52] Roman Shpakov: This will allow us not to act blindly to begin with.
[13.11.2017, 21:56:35] Roman Shpakov: Zelim, Vladimir, your task this week is to provide a letter from the Central
Bank that the issue is exhausted, there is no issue.
[13.11.2017, 21:57:24] Roman Shpakov: Linda, your comment is needed: did the second letter come and specifically
fluffed it or was it the 3rd, 4th, 5th letter?
[13.11.2017, 22:20:50] Linda: 2 letters came in and specifically on it fluffed and fluffed.
[13.11.2017, 22:22:03] Roman Shpakov: Okay. Get the letter and what's in the dop letters. If possible.
680
[13.11.2017, 22:52:28] Roman Shpakov: Was there a push today?
[13.11.2017, 22:52:37] Roman Shpakov: How is your conversation at the regulator?
[13.11.2017, 23:40:23] Linda: I was today.
Sevak was sent to the regulator to give them the letters from you, as he still had to sign a form stating that Constance
did not make payments to capital clients.
I was at Harris's because they're gonna start the audit with him. I'm meeting with the auditors tomorrow because you
were in their jubo files.
We are now preparing for the capital and Constance verification.
14.11.2017
[14.11.2017, 00:19:07] .: Let me know tomorrow morning whether the answer from Sisek will be tomorrow or as you
said maybe in a couple of weeks, when everything will be checked.
[14.11.2017, 00:25:54] Linda: In the morning I will not know exactly, rather closer to 15.00, the result as will be the
information I will write off.
[14.11.2017, 00:26:09] .: okaysi
[14.11.2017, 00:28:00] Linda: Roman was once a QB fiancé director?
[14.11.2017, 00:32:39] Roman Shpakov: Commercial Director.
[14.11.2017, 10:48:44] Linda: Hi,
Zelimkhan, a letter has been sent to you. I need your help. Thank you.
[14.11.2017, 10:50:28] .: Hi, yep, already posted that they gave it to me.
[14.11.2017, 10:51:24] Linda: Thank you
[14.11.2017, 23:01:56] Linda: Do any of you remember people like Gusarov and Sloeva? They were involved in the
capital and valken scheme.
[14.11.2017, 23:06:36] Roman Shpakov: Apparently Murzy's
[14.11.2017, 23:06:39] Roman Shpakov: Looking for
[14.11.2017, 23:09:19] Roman Shpakov: Request from Gramza. It's Murzy's.
[14.11.2017, 23:10:28] Linda: Ok.
[14.11.2017, 23:24:32] Linda: If a wizard came right now and asked me what I wanted, I'd want the three of you to
come to me and just say everything will be fine, we're there for you)
[14.11.2017, 23:26:05] +7 965 - 74888888888 - : I'll tell you that everything will be fine.
[14.11.2017, 23:26:33] +7 965 - 74888888888 - : I can send an animated poop as proof ��
[14.11.2017, 23:29:08] Roman Shpakov: This is his new super ability
[14.11.2017, 23:30:30] +7 965 - 74888888888 - : audio file is missing
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[14.11.2017, 23:30:31] Linda: )))))
[14.11.2017, 23:34:00] Roman Shpakov: A brief history of Linda in Cyprus?
[14.11.2017, 23:35:31] Linda: Linda on the bottom most likely
[14.11.2017, 23:36:44] +7 965 - 74888888888 - : This was sent to my acquaintance ))))
15.11.2017
[15.11.2017, 13:37:38] +7 965 - 74888888888 - : Did the letters get to you ?
[15.11.2017, 13:42:50] Linda: I have the content of 2 letters, but the letters themselves are not there. I understand that
you must have received them from your sources
[15.11.2017, 13:49:00] +7 965 - 74888888888 - : Content can you solano forward ?
[15.11.2017, 13:50:05] +7 965 - 748888888 - : I need it - urgently
[15.11.2017, 13:50:21] Linda: It has already been forwarded to Roman and Zelimkhan, the translation is braid as the
first letter came in Russian
[15.11.2017, 13:50:39] Linda: Zelimkhan pass please
[15.11.2017, 13:51:28] Linda: I am preparing QBCM and QBFS company files and they will also be requested for review.
[15.11.2017, 15:26:38] Linda: Colleagues
[15.11.2017, 15:26:46] Linda: I just got a phone call from a man
[15.11.2017, 15:26:49] Linda: Fuck.
[15.11.2017, 15:27:55] Linda: CySEC replied to the CB that these companies are not related to persons activities . ( afer
they received the letter from Roman )
[15.11.2017, 15:28:35] Linda: An hour later came 2 letters from the Central Bank stating that they require CySEC to
conduct an investigation.
[15.11.2017, 15:28:53] Linda: That companies are invxt activities
[15.11.2017, 15:28:59] Roman Shpakov: Ok
[15.11.2017, 15:29:09] Linda: I don't understand what you're doing and how closes there questions
[11/15/2017, 15:29:13] Linda: There's more to it than that
[15.11.2017, 15:29:22] Linda: If the Central Bank doesn't calm down
[15.11.2017, 15:30:11] Linda: Saycek has requested a court order to bring up all accounts and will conduct a full
investigation.
[15.11.2017, 15:30:33] Linda: And the person said that the Central Bank is not calming down
[15.11.2017, 15:30:44] Roman Shpakov: We are aware of that.
[15.11.2017, 15:30:48] Roman Shpakov: Don't write anymore
[15.11.2017, 15:31:30] Linda: Well plus the next letters from our regulator will be for the CB to provide evidence .
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[15.11.2017, 15:31:50] Roman Shpakov: Let them not write yet. Give 2 days
[15.11.2017, 15:52:08] Linda: Zelimkhan,
I am writing as you asked because of what is happening now and the Central Bank is not calming down we will have to
show QB Finance and capital agreements.
[15.11.2017, 15:52:46] +7 965 - 748888888 - : Give it 2 - 3 days
[15.11.2017, 15:55:54] .: Got it, don't give access to the contracts yet, then it will be unrealistic to give the backside.
[15.11.2017, 16:00:48] +7 965 - 748888888 - : It will be realistic - to give in the rear
[15.11.2017, 16:01:19] .: In the back for sure.
[15.11.2017, 16:02:13] Linda: They are pushing for an investigation. Your DH. That means court order and opening all
books and bank accounts.
[15.11.2017, 16:03:37] +7 965 - 74888888888 - : And why should they even go for this one ?
[15.11.2017, 16:03:41] .: Ours will change his mind, don't doubt it. For now, lokirovat provide this information, I realise
it's difficult
[15.11.2017, 16:40:24] Linda: Because your Central Bank just blew the brains of our regulator. And our CySEC was
getting nervous, and they told our person that she would not risk her seat.
[15.11.2017, 16:40:47] Linda: There have not yet been such requests. And that even so quickly your Central Bank to
respond.
[15.11.2017, 16:41:12] Roman Shpakov: Because the bonuses are paid for.
[15.11.2017, 16:41:42] Linda: Roman, anything .
[15.11.2017, 16:41:55] Linda: She would rather shut us down than lose her position
[15.11.2017, 16:42:03] +7 965 - 748888888 - : Bear - with me
[15.11.2017, 16:42:04] +7 965 - 748888888 - : We are all busy with this issue
[15.11.2017, 16:50:16] +7 965 - 74888888888 - : Let her stall for time, she doesn't fucking need - this scandal either.
[15.11.2017, 16:54:06] Linda: Vova, she's not alone out there. We just set her up really badly. On the first enquiry they
responded to your CB to go far. The Central Bank has not calmed down.
Yesterday our man told her that we had resolved everything with our DH, new enquiries today.
I don't know how to explain the situation to you anymore.
[15.11.2017, 16:54:22] +7 965 - 74888888888 - : I don't know who said it
[15.11.2017, 16:54:24] +7 965 - 748888888 - : I understand - everything
[15.11.2017, 16:54:28] +7 965 - 748888888 - : Give a bit of time
[15.11.2017, 16:54:35] +7 965 - 74888888888 - : This is for me - personally
[15.11.2017, 18:05:02] Linda: I was told that the CB should write to CySEC the following.
683
Your reply is satisfactory the matter is closed.
It has to be done by Friday.
[15.11.2017, 18:11:51] .: Friday is almost an anrial. Until Tuesday plz
[15.11.2017, 18:12:11] .: I know it's hard.
[15.11.2017, 18:22:36] Linda: That's not my request.
We've been given enough time and enough help. Under other circumstances, we would have been there a long time
ago.
I'm passing on what was said to the person so there is no misunderstanding later.
Because then he'll be like, "I know it's hard."
Hear me, please.
[15.11.2017, 18:23:16] +7 965 - 74888888888 - : One day - lef until Friday
[15.11.2017, 18:23:19] +7 965 - 74888888888 - : It's not real.
16.11.2017
[16.11.2017, 08:45:29] Linda: Vova hi.
[16.11.2017, 08:46:06] Linda: What did the person tell you? Any chance of writing to CySEC before tomorrow?
[16.11.2017, 09:33:15] Roman Shpakov: Linda, Vladimir is in the process.
[16.11.2017, 09:35:19] Linda: I know, but I'm pressed for time. So is everyone else.
[16.11.2017, 09:36:15] Roman Shpakov: We are aware of that.
[16.11.2017, 10:12:18] +7 965 - 74888888888 - : Met in the morning. That's it for now. Today will be clear will be able to.
- Lee no.
[16.11.2017, 10:15:10] Linda: I see. So it's not even known yet if people can or not.
[16.11.2017, 10:15:38] Roman Shpakov: They can, it's a question of timing.
[16.11.2017, 10:42:48] Linda: I spoke to him, he said, if the process is started here (and it is already slowly starting), we
will not stop it aferwards.
We don't have much time lef, so I don't know what deadlines you're talking about.
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17.11.2017
[17.11.2017, 09:50:37] Linda: Yesterday another letter came from the Central Bank. I was just, just informed. No more
control over the process.
[17.11.2017, 09:52:05] Linda: "All i was told last night is that they have received another letter from central bank russia
This time saying they have many complaints from clients who have invested in these cyprus companies."
[17.11.2017, 09:53:47] Roman Shpakov: Okay.
[17.11.2017, 10:04:16] Roman Shpakov: Linda, someone should put the thought in your regulator that this action is
planned - bought and has nothing to do with our regulator. And there is no need to rush to react.
[17.11.2017, 10:09:22] Linda: Roman, they're putting us into a system where there are international investigations. It
can no longer contain the flow. In an hour or two a letter will come, to Haris or to us, with a copy to the Central Bank
and the Ministry of Finance.
[17.11.2017, 10:10:22] Roman Shpakov: Day submuti.
[17.11.2017, 10:10:29] Roman Shpakov: One last request.
[17.11.2017, 10:11:00] Roman Shpakov: You asked to do by the end of the week, so give me until the end of the week.
[17.11.2017, 10:11:57] Linda: Provided there are no more letters. And they keep coming
[17.11.2017, 10:12:42] +7 965 - 74888888888 - : In an hour ours will start booing
[17.11.2017, 10:54:42] Roman Shpakov: I don't know how relevant the information is, but all complaints have been
withdrawn by customers.
[17.11.2017, 10:56:03] Linda: Central Bank your writes the opposite
[17.11.2017, 10:59:18] Roman Shpakov: My sun, I give you food for thought, so that you compare facts to finally
understand the essence of the origin of these requests.
And blowing in the ears of the decision makers.
[17.11.2017, 11:02:20] Roman Shpakov: Especially such non - fucking passages that CI is just a cover)
[17.11.2017, 11:07:37] Roman Shpakov: Linda, once again, the full text of the message to be sent. Include all titles,
names and other things that should be specified.
[17.11.2017, 11:10:22] Linda: I'll transfer it to you.
[17.11.2017, 11:10:30] Linda: Give me 10 min.
[17.11.2017, 11:11:20] +7 965 - 74888888888 - : Write to whom and what
[17.11.2017, 11:11:32] +7 965 - 74888888888 - : Gus Zelim will go to decide ))))
[17.11.2017, 11:12:24] Roman Shpakov: Briefly summarise the essence point by point.
[17.11.2017, 11:14:08] Linda: I'm driving.
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[17.11.2017, 11:14:47] Roman Shpakov: We do not mind. I meant don't need to translate every word.
[17.11.2017, 11:18:05] Roman Shpakov: More specifically?
[17.11.2017, 11:19:49] Linda: I'm on my way to get a signature.
[17.11.2017, 11:22:54] Roman Shpakov changed the topic to "Fantastic 4"
[17.11.2017, 11:22:55] Linda: Questions
[17.11.2017, 11:23:00] Linda: Who yubo.
[17.11.2017, 11:23:07] Linda: Where is the company's activity
[17.11.2017, 11:23:21] Linda: Conducting unlicensed investment activities
[17.11.2017, 11:23:37] Linda: Who are noa, cgc
[17.11.2017, 11:24:14] Roman Shpakov: What does it say about 350k euros?
[17.11.2017, 11:24:51] Linda: Penalty to harisu
[17.11.2017, 11:24:57] Linda: If he tells anyone.
[17.11.2017, 11:25:03] Linda: They've launched an investigation
[17.11.2017, 11:25:06] Roman Shpakov: Ok
[17.11.2017, 11:26:12] Roman Shpakov: 1. And it's like, he has to prepare answers?
2. What is the deadline?
3. How loyal is Haris and how much does he need the help of tougher lawyers?
[17.11.2017, 11:26:31] Linda: Roman let me sign the papers.
[17.11.2017, 11:26:35] Linda: The auditor is coming in at 11
[17.11.2017, 11:26:42] Linda: I need to change you all over the place
[17.11.2017, 11:26:46] Linda: You're welcome
[17.11.2017, 11:26:50] Linda: Give me time
[17.11.2017, 11:27:17] Roman Shpakov: Ok
[17.11.2017, 11:33:05] Linda: I need to organise a way for Zelimkhan to meet me at Sheremetyevo.
[17.11.2017, 11:33:16] Linda: Sign the docks and I'll fly back to Cyprus
[17.11.2017, 11:33:23] Linda: Haris is signing everything now
[17.11.2017, 11:34:15] Roman Shpakov: Maybe Zelim will just fly in for the weekend?
[17.11.2017, 11:34:33] .: So sign it right away
[17.11.2017, 11:34:53 pm] .: At my place.
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[17.11.2017, 11:34:53] Roman Shpakov: I don't see a problem signing there either
[17.11.2017, 11:34:59] .: It's year 15 there
[17.11.2017, 11:35:30] .: You don't need to detail and meet in a balloon for that)
[17.11.2017, 11:43:18] Linda: Okay I'll sign on behalf of Zelimkhan.
[17.11.2017, 11:43:28] Linda: Zelimkhan can't fly here
[17.11.2017, 11:46:26] Linda: Signed it
[17.11.2017, 11:54:36] Linda: I'm flying to Moscow today.
[17.11.2017, 11:54:47] Linda: Transferring and flying to Armenia
[17.11.2017, 11:55:20] Linda: They told me to buy the ticket in Russia and then from there to Armenia so that it would
be impossible to trace where I was flying to.
[17.11.2017, 11:55:27] Roman Shpakov: Ok
[17.11.2017, 11:57:54] Linda: Zelimkhan, if anything you need to fly to Armenia
[17.11.2017, 11:58:05] Linda: You've got to get me off the signatory
[17.11.2017, 11:58:10] Roman Shpakov: Ok
[17.11.2017, 11:58:43] .: Whatever we need to do, we'll do.
[17.11.2017, 12:12:01] Linda: 1.yes, he should give an answer
2.We were given until 23/11 - that's the last we were given to help us.
3. Don't involve more people, the letter says if he says anything to anyone, he will be personally fined 350k and
prosecuted.
[17.11.2017, 12:26:20] Linda: Signed for Zelimkhan
[17.11.2017, 12:28:55] +7 965 - 74888888888 - : What about the text of the letter ?
[17.11.2017, 12:29:22] Linda: What letter?
[17.11.2017, 12:29:33] Linda: Sorry
[17.11.2017, 12:29:35] +7 965 - 74888888888 - : Which should leave - our central bank
[17.11.2017, 12:30:08] Linda: Thank you for clarification the matter is closed and we do not need any more
information.
[17.11.2017, 12:30:33] Linda: Version 2 - the matter is closed company do not provide any investment activity
[17.11.2017, 12:30:52] +7 965 - 748888888 - : Zelim))))
[17.11.2017, 12:31:15] Roman Shpakov: Linda, full letter.
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[17.11.2017, 12:31:24] Roman Shpakov: With the indication of names and surnames.
[17.11.2017, 12:31:35] Roman Shpakov: To be immediately clear.
[17.11.2017, 12:31:41] Linda: Roman
[17.11.2017, 12:31:55] Linda: I need to respond to Constance.
[17.11.2017, 12:32:04] Linda: Give me a little bit of time
[17.11.2017, 12:32:12] Linda: I'm being had here too
[17.11.2017, 12:43:52] +7 965 - 74888888888 - : But we all have sex.
[17.11.2017, 12:46:52] Linda: I wouldn't want to have that kind of sex.
[17.11.2017, 13:25:50] Linda: Zelimkhan, we need these documents for 2015, the date of early October 2015.
[17.11.2017, 14:06:04] Linda: Also, please do not discuss with anyone that we have a letter from CySEC. This is
confidential information
[17.11.2017, 14:08:01] Roman Shpakov: Ok
[17.11.2017, 15:14:10] Linda: Is it possible for your channel to send an email to the same email from which they
currently send emails ?
[17.11.2017, 15:15:23] Roman Shpakov: From the same post, you meant to say.
[17.11.2017, 15:17:19] Linda: The Central Bank sent letters from a certain plchta to our regulator.
Now we need the Central Bank to send a letter to our regulator from the same post.
Is that possible?
[17.11.2017, 15:20:06] Roman Shpakov: That's what we plan to do.
[17.11.2017, 15:49:57] Linda: Question
[17.11.2017, 15:50:28] Linda: In the letter they ask where and at what address the company does business
[17.11.2017, 15:51:43] Linda: What are your suggestions
[17.11.2017, 16:15:06] Linda: QNCM - in audit report for 2015, 2016 we write
The company didn't perform any activities and shareholder decided to liquidate it
Approve yes or no
[17.11.2017, 16:17:02] Linda: I need to do the audit of QBCM and QB Fs companies 2015,2016 to other auditors , as
2013 - 2104 I signed the report
[17.11.2017, 16:17:19] Roman Shpakov: Ok
[17.11.2017, 16:20:42] Linda: That needs an answer too
[17.11.2017, 16:21:08] Roman Shpakov: What are your suggestions?
[17.11.2017, 16:41:39] Linda: Ordered a full search in the register of companies
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[17.11.2017, 16:41:41] Linda: All Reports
[17.11.2017, 16:41:47] Linda: Who was who is who now
[17.11.2017, 16:42:15] Linda: Committee of Inquiry
[17.11.2017, 16:42:26] Linda: They're getting all the audit reports now.
21.11.2017
[21.11.2017, 19:27:15] Linda: Stop all dispatches
[21.11.2017, 19:27:48] Linda: The companies were listed in the ESMA system today
[21.11.2017, 19:28:06] Roman Shpakov: What is the system?
[21.11.2017, 19:31:24] Linda: When companies get caught up in an investigation
[21.11.2017, 19:31:29] Roman Shpakov: Ok
[21.11.2017, 19:31:32] Linda: The situation here is fucked up
[21.11.2017, 19:32:06] Linda: Your Tsyb sent another reminder
[21.11.2017, 19:32:13] Roman Shpakov: Today?
[21.11.2017, 19:32:22] Linda: Yes today.
[21.11.2017, 19:32:26] Roman Shpakov: Ok
[21.11.2017, 20:22:44] Roman Shpakov: Is there any confirmation on ESMA?
[21.11.2017, 20:26:47] +7 965 - 74888888888 - : I found 2kk here on ci
[21.11.2017, 20:35:58] Linda: From an internal regulator source . They follow a procedure.
[21.11.2017, 20:36:21] Roman Shpakov: Ok
[21.11.2017, 20:36:31] Roman Shpakov: A photo would be.
[21.11.2017, 20:36:35] Linda: Fine if we have another licence we'll get one.
[21.11.2017, 20:37:11] Roman Shpakov: Yes it is possible and without.
[21.11.2017, 20:37:46] Linda: Roman, who is going to send you pictures? I told you, you decide
[21.11.2017, 20:38:04] Roman Shpakov: Yes master.
[21.11.2017, 20:38:25] Roman Shpakov: At least pics of dimitra discount.
[21.11.2017, 20:39:03] Linda: Very funny.
[21.11.2017, 20:39:13] Linda: Should I go take her picture?
[21.11.2017, 20:39:53] Roman Shpakov: Let Dimon. Like seo has arrived. And like: dimitra dimon, the names are
similar.
[21.11.2017, 20:42:18] Linda: I sprained my arm.
[21.11.2017, 20:42:58] Roman Shpakov: Dima?
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[21.11.2017, 20:44:42] Linda: No, I was the one who wrote to Marina, I was beating the steering wheel of the car with
my hand.
[21.11.2017, 20:44:56] Roman Shpakov: Why?)
[21.11.2017, 20:45:01] Roman Shpakov: You have to bang your head.
[21.11.2017, 20:45:37] Linda: It didn't work, I was driving.
[21.11.2017, 20:46:25] Roman Shpakov: For the sake of this, you can stop.
[22.11.2017, 18:17:30] Roman Shpakov: Roman, , people are not ready to set themselves up and they are not ready to
bear criminal responsibility.
We said they'd write a letter to CySEC, but they haven't. Haris isn't willing to take that risk.
I have been told by Greg that he is not willing to work with us and help on those terms and represent the people he is
asking for help from for us.
Everything we said we'd do hasn't been done. No one is going to lose their position because of us.
I've been warning you for a month.
The commission will schedule an inspection tomorrow.
[22.11.2017, 18:33:42] +7 965 - 74888888888 - : If you're ready to talk quietly, I'll call you
[22.11.2017, 18:33:44] +7 965 - 748888888 - : Calmly
[22.11.2017, 18:42:53] Linda: Zelimkhan pick up the phone.
[22.11.2017, 18:45:24] +7 965 - 74888888888 - : Linda call me - back
[22.11.2017, 20:40:34] Linda: 180kk turnover on accounts
[22.11.2017, 20:41:55] Roman Shpakov: Quite)
[22.11.2017, 21:04:42] Linda: This amount is stated in the letter, today the person once again announced the figure
[22.11.2017, 21:04:53] Linda: Can you tell me what the situation is now?
[22.11.2017, 21:08:08] Roman Shpakov: And in fact which one?
[22.11.2017, 21:08:42] Linda: I'll have to look it up
[22.11.2017, 21:09:17] Roman Shpakov: Ahh.
[22.11.2017, 21:09:19] Roman Shpakov: Well OK
[22.11.2017, 21:09:38] Roman Shpakov: Someone did well and looked at the turnover of our accounts?
[22.11.2017, 21:09:59] Linda: This CB is yours
[22.11.2017, 21:10:08] Linda: They say you withdrew these amounts
[22.11.2017, 21:10:16] Linda: Or rather the turnovers on all accounts
[22.11.2017, 21:10:38] Roman Shpakov: My sun, I'm telling you, professionals tried.
[22.11.2017, 21:10:55] Linda: I can see that.
[22.11.2017, 21:11:35] Linda: And I see that there's nothing we can do.
690
[22.11.2017, 21:12:45] Roman Shpakov: Sorry of course, but have done almost everything.
[22.11.2017, 21:13:16] Linda: To dunk me up to my ears.
[22.11.2017, 21:13:17] Linda: Yes.
[22.11.2017, 21:13:21] Linda: I agree.
[22.11.2017, 21:13:41] Roman Shpakov: I don't mean the joints, but the solution)
[22.11.2017, 23:34:15] +7 965 - 74888888888 - : Written directly in the paper ?
[22.11.2017, 23:37:49] Roman Shpakov: Yes
[22.11.2017, 23:39:32] Linda: Yes.
[22.11.2017, 23:39:49] Linda: They want to figure out who's behind it all
[22.11.2017, 23:41:20] .: And then they discount me. Beautiful)
[22.11.2017, 23:41:53] Linda: Don't worry, we'll join you later.
23.11.2017
[23.11.2017, 00:09:50] Linda: Vov, what did your contact tell you?
It's not enough to just say nothing. It is necessary to say that the case is closed, otherwise they will not close the fial.
[23.11.2017, 00:17:07] Roman Shpakov: Linda, everything will be done.
[23.11.2017, 00:19:07] +7 965 - 74888888888 - : Probably :)
[23.11.2017, 00:32:39] Linda: I see.
[23.11.2017, 10:18:21] Linda: Hi. Is there any news?
[23.11.2017, 10:18:38] +7 965 - 74888888888 - : I have afer 16 will be
[23.11.2017, 10:19:35] Linda: Zelimkhan and you?
[23.11.2017, 10:19:46] Linda: Stas called me.
[23.11.2017, 10:19:49] Linda: Why?
[23.11.2017, 10:20:26] +7 965 - 74888888888 - : Don't take it from him
[23.11.2017, 10:20:41] Linda: I don't take it.
[23.11.2017, 10:20:43] +7 965 - 74888888888 - : And I'm saying you're not authorised to talk to - him.
[23.11.2017, 10:21:29] Linda: I don't pick up the phone at all anymore, I only communicate with you and a couple of
other people in Cyprus.
[23.11.2017, 10:22:31] +7 965 - 74888888888 - : Similarly ))))
[23.11.2017, 11:20:16] Linda: Zelimkhan, as someone I trust, please tell me what news do you have?
[23.11.2017, 11:20:53] .: No news, we were chatting last night.
[23.11.2017, 11:21:01] .: News only in the evening
691
[23.11.2017, 11:21:15] Linda: I thought if there is afer communication
[23.11.2017, 11:21:27 pm] .: Nothing has changed since last night
[23.11.2017, 11:21:27] Linda: I'll wait for tonight.
[23.11.2017, 11:22:21] .: Mm - hmm.
[23.11.2017, 11:23:04] .: In a nutshell - everything is on the right track, the case is in our favour and in the right
timeframe
[23.11.2017, 11:25:09] Linda: We need a result
1. The Central Bank does not write anything here
2. In response to the CySEC reply they write - thank you the case is closed.
Afer that, we move on.
[23.11.2017, 12:32:51] Linda: Roman, another reminder is here. Why are you telling me you're solving the issue?! Do
you realise I'm gonna get eaten alive here?! I cover your name everywhere and you leave me here alone! What are you
deciding?!
[23.11.2017, 12:34:54] +7 965 - 74888888888 - : Fuck.
[23.11.2017, 12:34:58] +7 965 - 74888888888 - : They said wait - for the evening
[23.11.2017, 12:35:14] +7 965 - 74888888888 - : I'm going - straight gassing out
[23.11.2017, 12:35:41] +7 965 - 74888888888 - : Reminder came only because today is the deadline for response and I
said, I'll arrange for yours to respond and ours will already put - the fuck down
[23.11.2017, 12:38:32] Linda: Zelimkhan said that everything is positive!!! And that we will not be written in they write
and write. It's a hell of a thing. I was always close to you, where you are now I have no idea!
[23.11.2017, 12:38:52] +7 965 - 748888888 - : Calm - down
[23.11.2017, 13:10:54] +7 965 - 748888888 - : Linda
[23.11.2017, 13:10:57] +7 965 - 748888888 - : Call back - immediately
[23.11.2017, 13:12:57] Linda: I'll be right out of the board room!
[23.11.2017, 16:42:28] Linda: Any news?
[23.11.2017, 16:57:24] +7 965 - 748888888 - : Yes
[23.11.2017, 16:59:45] Linda: And?
[23.11.2017, 17:15:56] Linda: Vova
[23.11.2017, 17:17:19] +7 965 - 748888888 - : Yes
[23.11.2017, 17:23:27] Linda: Haris is coming to the office today, he wants to talk about having us prepare files that will
show the truth of what happened so that we are prepared for an audit if there is a forensic audit.
[23.11.2017, 17:30:42] +7 965 - 74888888888 - : Let me fucking drive - to the office to drive
[23.11.2017, 17:35:01] Linda: I like that Roman is quiet.
[23.11.2017, 17:35:05] Linda: Like Zelimkhan.
692
[23.11.2017, 17:44:58] +7 965 - 748888888 - : Wait for me to call - you back
[23.11.2017, 18:15:30] Linda: Vova,
You can't change the name. The committee got Zelimkhan's name as UBO - who is currently behind the companies.
[23.11.2017, 18:16:10] Roman Shpakov: He is not asking to change. He's asking to remove from the response in RF.
[23.11.2017, 18:17:33] +7 965 - 74888888888 - : Exactly.
[23.11.2017, 18:17:54] +7 965 - 748888888 - : It will be - expensive for me to succeed him aferwards
[23.11.2017, 18:18:03] Linda: they will answer who yubo at the moment.
[23.11.2017, 18:18:04] Roman Shpakov: Yeah we know we're already fucked.
[23.11.2017, 18:18:20] Roman Shpakov: Can simply answer: not Shpakov.
[23.11.2017, 18:18:35] +7 965 - 74888888888 - : And not the ZVM
[23.11.2017, 18:18:45] Roman Shpakov: What right do they have to reveal a man who is kind of out of touch.
[23.11.2017, 18:19:01] Linda: On business
[23.11.2017, 18:19:10] Linda: This person is wanted by the Central Bank
[23.11.2017, 18:19:17] Linda: Fucked everyone's brains out
[23.11.2017, 18:19:47] Roman Shpakov: Linda, that's the way it is, don't have our mutual friend there.
[23.11.2017, 18:20:18] Linda: Roman, are you making a fool of me?
[23.11.2017, 18:20:29] Linda: I busted my arse to remove your name
[23.11.2017, 18:20:49] Linda: I told you to put Zelimkhan, you all said ok
[23.11.2017, 18:20:58] Roman Shpakov: Linda, you are asking to close the issue in RF. We are asking you to remove the
svm.
[23.11.2017, 18:21:06] Roman Shpakov: In response to your yes.
[23.11.2017, 18:21:13] Linda: Now on the 23rd when the answer was given you say take it away
[23.11.2017, 18:21:18] Linda: Not really.
[23.11.2017, 18:21:23] Linda: That's not what I'm asking.
[23.11.2017, 18:21:31] Roman Shpakov: Now take it out of cusek's response to the Central Bank
[23.11.2017, 18:21:32] Linda: Shut the crap you spewed on me.
[23.11.2017, 18:21:42] Roman Shpakov: OK)))
[23.11.2017, 18:21:44] Linda: And make sure we don't go to jail.
[23.11.2017, 18:23:44] Roman Shpakov: That's what I'm telling you, don't create problems on a flat spot. If yours can
change the answer, then fine.
[23.11.2017, 18:24:33] Roman Shpakov: Response from the regulator to the Central Bank.
693
[23.11.2017, 18:24:37] Linda: I don't create them, if your DH didn't write reminder the committee might not even
respond
[23.11.2017, 18:24:45] Roman Shpakov: Ok
[23.11.2017, 18:25:00] Roman Shpakov: So let them write a lightweight.
[23.11.2017, 18:25:26] Roman Shpakov: Like: not Shpakov, the activity is legal, with love...
[23.11.2017, 18:25:39] Linda: Especially afer we howl at them all the time
[23.11.2017, 18:26:03] Roman Shpakov: The question was: Shpakov?
The answer is: not Shpakov.
[23.11.2017, 18:26:37] Linda: No that was the first request.
[23.11.2017, 18:26:47] Linda: Second Shpakov or not
[23.11.2017, 18:27:15] Roman Shpakov: Not Shpakov.
[23.11.2017, 18:27:19] Linda: Then we want to investigate who is withdrawing the money and who owns these
companies
[23.11.2017, 18:27:29] Linda: I don't want to.
[23.11.2017, 18:27:40] Linda: Even in correspondence.
[23.11.2017, 18:27:41] Roman Shpakov: The company is conducting legitimate activities. Full stop.
[23.11.2017, 18:27:42] Linda: You.
[23.11.2017, 18:27:45] Linda: Linking up
[23.11.2017, 18:27:51] Linda: With this companies!!!
[23.11.2017, 18:28:03] Roman Shpakov: I do not mind. Zelim put it away. If possible.
[23.11.2017, 18:28:05] Linda: My whole life is breaking down.
[23.11.2017, 18:28:33] Linda: They have a committee tomorrow
[23.11.2017, 18:28:35] Linda: tsb
[23.11.2017, 18:28:39] Linda: Regulator
[23.11.2017, 18:28:41] Linda: Ministry of Finance
[23.11.2017, 18:28:48] Linda: And that's where they'll decide what to answer.
[23.11.2017, 18:29:28] Roman Shpakov: Great!)
[23.11.2017, 18:29:30] Linda: Once again G said Zelimkhan's name they will give, he was still saying that yesterday.
[23.11.2017, 18:30:03] Roman Shpakov: Well svm is QBF. And here I am again :)
[23.11.2017, 18:30:11] Roman Shpakov: Ai beauty how beautiful.
[23.11.2017, 18:30:24] Roman Shpakov: In short, if possible, do not.
[23.11.2017, 18:30:32] Linda: Not really.
[23.11.2017, 18:30:40] Linda: He did behind your back.
694
[23.11.2017, 18:30:50] Linda: You had nothing to do with it
[23.11.2017, 18:33:01] Roman Shpakov: Linda, Take it out of the regulator's response. The decision is made by specific
people. Everyone.
[23.11.2017, 18:33:08] Linda: One more time
[23.11.2017, 18:33:19] Linda: it's impossible on the 23rd at night
[23.11.2017, 18:33:28] Linda: You all knew everything
[23.11.2017, 18:33:48] Roman Shpakov: Linda, the response of your regulator to ours. Not the answer of charis.
[23.11.2017, 18:34:04] Linda: I got it.
[23.11.2017, 18:34:10] Roman Shpakov: So do it.
[23.11.2017, 18:34:18] Roman Shpakov: We do from our side.
[23.11.2017, 18:34:33] Roman Shpakov: That the most neutral response will be welcomed.
[23.11.2017, 18:34:46] Linda: Once again, from the fact that your Central Bank writes all these letters our regulator
already thinks we are laundering all the money of the Russian Federation.
[23.11.2017, 18:35:09] Roman Shpakov: Great.
[23.11.2017, 18:35:15] Linda: You are doing nothing on your part
[23.11.2017, 18:35:20] Linda: Or rather you do.
[23.11.2017, 18:35:21] Roman Shpakov: Don't waste our time, think how to solve.
[23.11.2017, 18:35:41] Linda: You tell me things you don't do.
[23.11.2017, 18:35:50] Linda: We're in a one - gate game.
[23.11.2017, 18:35:59] Linda: You Linda do it and we'll see.
[23.11.2017, 18:38:04] Roman Shpakov: We will remember this phrase.
[23.11.2017, 18:41:39] Linda: Remember. That's the impression given by the people who shut down our questions
here.
[23.11.2017, 18:41:52] Linda: One of them spoke to Zelimkhan yesterday.
[23.11.2017, 18:42:11] Roman Shpakov: Ok
[23.11.2017, 18:50:38] Linda: The agreement was.
1. By the end of last week, CySEC would get a letter - it was not there
2. By the end of Tuesday CySEC will get a letter too was not there
3. respond positively to the first letter and the CB will not write any more - 3 more letters and an investigation came in
4. I'm writing to you Roman, help me because I'm being pressurised from all sides and people are saying why should
we put ourselves in danger to cover for Roman?
5. I have covered you completely and in everything to the point where I would be criminally liable. And you take it all
for granted and don't care that people put their backs into it for you.
695
[23.11.2017, 18:52:04] Roman Shpakov: Ok
[23.11.2017, 18:53:56] Linda: Zelimkhan, if there is any chance of not writing your name, I will do everything I can to
make sure it didn't happen. But the chances are very small, as this is an investigation and not just an enquiry.
[23.11.2017, 18:56:04] Roman Shpakov: Ok
[23.11.2017, 18:56:32] Linda: Okay.
[23.11.2017, 19:10:24] .: Thank you very much, everything is clear) the main thing is that afer all this you have in these
three structures all stopped and no action on the companies and me, and then move to wight leuk
[23.11.2017, 19:13:35] Linda: It would be good if people learnt to respect the opinion of others and listen to it
otherwise nothing will change for us.
[23.11.2017, 20:31:30] .: That's for sure.
[23.11.2017, 20:33:27] +7 965 - 74888888888 - : Fuck off here at my place
[23.11.2017, 20:33:40] +7 965 - 74888888888 - : There will be a reminder tomorrow)))
[23.11.2017, 20:33:53] .: )))
[23.11.2017, 20:34:04] Linda: Very funny
[23.11.2017, 20:34:10] .: Dibs, dibs
[23.11.2017, 20:34:38] Roman Shpakov: Ka ka ka
24.11.2017
[24.11.2017, 11:16:38] Linda: What's in Russia?
[24.11.2017, 11:16:48] Linda: How is the closure of the issue moving?
[24.11.2017, 11:20:22] +7 965 - 748888888 - : Waiting for a call. - Before lunch should dial in.
[24.11.2017, 11:20:27] +7 965 - 74888888888 - : Are you all set ?
[24.11.2017, 11:22:47] Linda: I'm going to see G today , he'll ask me what you have.
Plus he'll tell us when we're shipping. 99% of them will ship on Monday.
[24.11.2017, 11:59:23] Linda: Zelimkhan, what do you have?
[24.11.2017, 12:04:59] ... : Yvning of May Time!!!
[24.11.2017, 12:05:49] Linda: So well we wait for tonight.
[24.11.2017, 12:06:39] .: Mine are in passive, now Vladimir's people are in active
[24.11.2017, 12:06:56] Linda: Yep
[24.11.2017, 12:07:04] Linda: So we didn't go with your method.
[24.11.2017, 12:07:13] Linda: Let's take the easier route.
[24.11.2017, 12:07:30] Linda: So what we agreed to in the bamba was not done.
696
[24.11.2017, 12:07:55] +7 965 - 74888888888 - : How fucked - up you are
[24.11.2017, 12:08:19] +7 965 - 74888888888 - : Don't look for the guilty , you are all to blame , figure out how to
prevent the following situation
[24.11.2017, 12:09:01] .: I am for Vladimir's people, they confirmed, everything is normal. We do not have a task to fuck
everyone up, there is a task to solve the issue in time and most effectively
[24.11.2017, 12:09:25] .: Mine are on back - up, everything is on, they're engaged
[24.11.2017, 12:10:53] Linda: I honestly don't care , I only care that you close the issue on Monday.
[24.11.2017, 12:14:09] Linda: There will be no next situation. It will just be the end of all situations.
[24.11.2017, 14:01:23] +7 965 - 748888888 - : no image available
[24.11.2017, 14:19:22] Linda: Okay. God willing, I'm saying prayers.
[24.11.2017, 14:19:40] Linda: If anything we'll go to vanuatu to live and start over.
[24.11.2017, 14:20:15] +7 965 - 74888888888 - : And you'll have to change your gender
[24.11.2017, 14:20:17] +7 965 - 74888888888 - : Dima will be glad ))
[24.11.2017, 14:20:42] Linda: He's not going.
[24.11.2017, 14:20:53] Linda: We're the ones who will go
[24.11.2017, 14:21:17] Roman Shpakov: Strange, I thought he was the one who started it all.
[24.11.2017, 14:23:02] Linda: Too many risks are falling on me, so it's not him
[24.11.2017, 14:23:57] Roman Shpakov: He seduced you.
[24.11.2017, 14:24:03] Roman Shpakov: And you believed him.
[24.11.2017, 14:25:57] Linda: Let's save our butts from this story for now and then find out who did it.
[24.11.2017, 14:26:09] Linda: At least it's warm in Vanuatu
[24.11.2017, 14:29:54] +7 965 - 74888888888 - : You accept 2kk for now plz
[24.11.2017, 14:30:29] Linda: That's how we'll get them there
[24.11.2017, 14:30:33] Linda: At ABB.
[24.11.2017, 14:52:01] Linda: Haris is here.
[24.11.2017, 15:00:12] +7 965 - 748888888 - : Say it' - s OK
[24.11.2017, 15:03:42] +7 965 - 74888888888 - : So everything is good
[24.11.2017, 15:03:46] +7 965 - 74888888888 - : Che green me
[24.11.2017, 15:11:07] Linda: He's explaining what's going to happen and the picture is very fucked up very fucked up
[24.11.2017, 15:14:12] Roman Shpakov: I wonder why repeat the same thing all the time.
[24.11.2017, 15:14:53] Linda: Because there are new delights every day.
[24.11.2017, 15:56:00] Linda: I'll write here. You can't sign client agreements with capital
697
[24.11.2017, 15:56:09] Linda: You can't bank them now
[24.11.2017, 15:56:25] Linda: It's like talking into a trumpet.
[24.11.2017, 23:26:33] Linda: So what's up with you guys?
[24.11.2017, 23:26:37] Linda: Any news?
[24.11.2017, 23:27:42] +7 965 - 74888888888 - : And you ?
[24.11.2017, 23:27:54] +7 965 - 74888888888 - : We're still waiting, they are consulting, they say everything will be - OK.
[24.11.2017, 23:28:15] Linda: We have gas in our flat.
[24.11.2017, 23:28:27] Linda: What are they conferring about?
[24.11.2017, 23:28:40] Linda: Zelimkhan and you?
[24.11.2017, 23:29:56] +7 965 - 748888888 - : How to do everything correctly so that everyone is satisfied
[24.11.2017, 23:31:50] Linda: We have a letter due on Monday.
[24.11.2017, 23:34:06] +7 965 - 74888888888 - : I told you how it's going to be
[24.11.2017, 23:34:37] Linda: How will it be? They will write thank you the case is closed? On Monday?
[24.11.2017, 23:35:37] .: According to my info the "infection" went in our favour today and will continue on Monday to
work up a response
[24.11.2017, 23:36:48] Linda: When is this all going to end?
[24.11.2017, 23:36:56] Linda: We just need an answer.
[24.11.2017, 23:36:58] Linda: Thank you
[24.11.2017, 23:37:02] Linda: Case closed.
[24.11.2017, 23:37:05] Linda: Everything
[24.11.2017, 23:45:56] Linda: Vova, please respond.
[24.11.2017, 23:55:31] +7 965 - 74888888888 - : At least there will be no new emails afer CySEC- 's reply
25.11.2017
[25.11.2017, 00:32:11] +7 965 - 748888888 - : I will make sure that all letters are - sent.
[25.11.2017, 00:32:15] +7 965 - 74888888888 - : There will be a - meeting tomorrow
[25.11.2017, 09:36:02] Linda: You tell me what you've been told.
[25.11.2017, 11:52:02] Linda: Ask your people to scrub the internet wherever Zelimkhan is present
[25.11.2017, 11:52:06] Linda: G said
[25.11.2017, 12:03:05] Roman Shpakov: I will make you sad, but it is physically impossible.
[25.11.2017, 12:09:35] Linda: can you take Vova off the site too for a while ?
698
[25.11.2017, 12:09:36] Linda: So he wouldn't be there.
[25.11.2017, 12:11:00] Roman Shpakov: We can.
[25.11.2017, 12:11:22] Roman Shpakov: Zelim, remove Vova, and put someone in his place.
[25.11.2017, 12:29:27] Linda: Apollo and I want you to find out who's really behind this.
[25.11.2017, 12:32:52] +7 965 - 74888888888 - : You cackers
[25.11.2017, 12:33:13] +7 965 - 74888888888 - : Zelim is G
[25.11.2017, 12:33:36] +7 965 - 74888888888 - : Easy as fuck
[25.11.2017, 12:40:00] Linda: We think it's not a competitor, whoever did it is around or was around.
It is profitable for this man to remove one of us (more likely Roman) this man did cleverly, as a puppeteer, his name is
probably nowhere to be found and he will not suffer but win.
Maybe he put Stepanov up to it, maybe she did, we don't know.
[25.11.2017, 12:41:12] +7 965 - 74888888888 - : This is svm
[25.11.2017, 12:46:01] Linda: No, it's not him.
[25.11.2017, 12:46:44] .: It's me, I set it up.
[25.11.2017, 12:47:00] .: Volodya has been removed from the corp site
[25.11.2017, 12:52:31] Linda: Thank you
[25.11.2017, 13:34:46] +7 965 - 74888888888 - : Straight anal - bleaching
[25.11.2017, 15:37:57] Roman Shpakov: Linda, we are doing well here. If possible, remove Zelim's name from the
cusek's response to the Central Bank.
[25.11.2017, 15:41:20] Linda: I told G yesterday, he said he would try but it's a very small percentage.
I already told you, they've got a figure of 180 and they want to find the man who withdrew the DS.
[25.11.2017, 15:43:18] Linda: What exactly is working out for you?
[25.11.2017, 15:43:42] Roman Shpakov: That's not what they want. They want to tie these companies to the Russian
Federation.
[25.11.2017, 15:43:59] Roman Shpakov: That's not your question right now.
[25.11.2017, 15:45:07] Linda: Of course it's mine. Everything that happens here depends on exactly what you're
getting at
[25.11.2017, 15:47:40] Roman Shpakov: We are getting what you asked for. But I tell you to remove the last name and
first name.
There was no 180, so it's a bluff. There's a goal to link RF and Cyprus. Through a shareholder you will do that. There's
no need for that. Just remove the name.
[25.11.2017, 15:51:03] Linda: Why didn't you say that before??? How am I going to remove the name now? The letter
went to the commission , meeting on Monday . There are a lot of people involved .
The Commission is now following procedure.
699
The name was not given out on the first enquiries, in now it is unrealistically hard.
[25.11.2017, 15:53:34] Roman Shpakov: Linda, we are not interested in your emotionality right now. You are told what
you need to do if possible.
[25.11.2017, 16:17:47] Linda: If possible, I'll get it done
[25.11.2017, 16:17:54] Linda: I don't have emotionalism
[25.11.2017, 16:18:09] Roman Shpakov: Excellent!
[25.11.2017, 16:18:12] Roman Shpakov: Thank you.
[25.11.2017, 16:18:20] Roman Shpakov: You are a big well done!
[25.11.2017, 16:18:41] Roman Shpakov: And if you do that, you'll be straight well done.
[25.11.2017, 16:18:58] Roman Shpakov: And then you get the head of the guilty)))
[25.11.2017, 16:21:11] Linda: The problem with all of this is that you're my weak spot.
[25.11.2017, 16:21:14] Linda: I got it.
[25.11.2017, 16:21:20] Linda: I'll try to make one
[25.11.2017, 16:21:25] Roman Shpakov: Ufff
[25.11.2017, 16:21:34] Roman Shpakov: How passionate that sounds
[25.11.2017, 16:21:45] Roman Shpakov: We thought Dima was your weak spot
[25.11.2017, 16:22:17] Linda: They are different things
[25.11.2017, 16:27:40] +7 965 - 74888888888 - : Personal grade heroin ��
[25.11.2017, 16:28:00] Roman Shpakov: That's what all the chicks say��
[25.11.2017, 16:28:49] Linda: I'm kind of your junior partner.
[25.11.2017, 16:29:05] Roman Shpakov: Submissive
[25.11.2017, 16:29:10] Roman Shpakov: �
[25.11.2017, 16:30:36] Roman Shpakov: Actually, if the cusec will answer for a couple more weeks, also an option�
[25.11.2017, 16:30:53] Roman Shpakov: So we know the source of the questions.
[25.11.2017, 16:31:58] Linda: They're not going to respond for a couple of weeks. They're already on the final frontier.
[25.11.2017, 16:41:28] Roman Shpakov: Everyone is tired)))
[25.11.2017, 16:43:58] Linda: When this story is over I'm going to go away for a week somewhere far away and switch
off my phone
[25.11.2017, 16:50:43] Roman Shpakov: Vanuatu?
[25.11.2017, 16:56:35] Linda: No, that's where we will all go together if the issue is not resolved.
[25.11.2017, 16:56:35] Linda: I want to go to Tibet
[25.11.2017, 17:00:44] Roman Shpakov: Let's go to Vanuatu. We will open a bank.
700
[25.11.2017, 17:05:48] Linda: Here we go
[25.11.2017, 17:06:03] Linda: Was just discussing this topic this morning
[25.11.2017, 17:07:10] Roman Shpakov: God himself commanded....
[25.11.2017, 18:24:49] Linda: ))
[25.11.2017, 18:39:46] Roman Shpakov: 4 seasons
[25.11.2017, 18:43:51] Linda: Bingo
[25.11.2017, 18:48:32] Roman Shpakov: Greg's place
[25.11.2017, 18:49:53] +7 965 - 74888888888 - : And where is that ?
[25.11.2017, 18:50:18] Linda: Bingo)
[25.11.2017, 18:52:16] Roman Shpakov: Metropolis?
[25.11.2017, 18:52:38] Roman Shpakov: Greg's abode, to be more precise.
[25.11.2017, 18:56:07] +7 965 - 748888888 - : Handsome man
[25.11.2017, 18:56:26] +7 965 - 74888888888 - : Although there are not so many shopping centres so mediocrely made
[25.11.2017, 18:56:40] Roman Shpakov: I have not been there for 3 years. Glass passages.
[25.11.2017, 18:57:03] Roman Shpakov: One of the most sensible shopping centre. Place cosmos as it turned out
[25.11.2017, 19:00:32] +7 965 - 74888888888 - : The place is cosmos , and yourself �
[25.11.2017, 20:22:21] Linda: Vov
[25.11.2017, 20:22:26] Linda: Any news?
26.11.2017
[26.11.2017, 00:43:30] Linda: Vova, confirm, I have the following for you
If on Monday the commission says Zelimkhan's name to your Central Bank, then the enquiries to Cyprus will continue.
The man who is helping us has been informed that you will close the matter by Monday and this is what he passed on
to her.
If the issue in RF is not closed, the situation will develop differently for all of us.
If we don't close the issue in Russia, it will mean for him that we have violated our agreements with him. Zelimkhan
also told him on the phone that he would close the issue by Monday.
701
[26.11.2017, 09:07:04] Linda: Vova?
[26.11.2017, 12:17:17] Linda: Vova, answer please I have to go to Limassol, we were all asked to come there afer the
information you gave me yesterday.
[26.11.2017, 15:09:16] +7 965 - 7488888 - : А?
[26.11.2017, 15:14:21] +7 965 - 74888888888 - : Linda, today is a day off. What are you waiting for? - I've coordinated
with people to take action.
[26.11.2017, 15:17:04] Linda: Confirm to me that on Monday if the Commission tells your Central Bank the name of
Zelimkhan, the questions to Cyprus will continue.
[26.11.2017, 15:17:16] Linda: I have no days off because of this story
[26.11.2017, 15:18:44] Linda: I need confirmation from you of the information you told me on the phone yesterday.
[26.11.2017, 15:19:25] Linda: The issue is not closed with the Central Bank
[26.11.2017, 15:45:32] Roman Shpakov: Linda, the only closure will be a letter, to close the issue. People are doing
that.
Second, remember, having information is better than the illusory world someone promised you.
One last thing: don't throw rocks on the water, they leave circles.
[26.11.2017, 15:45:54] +7 965 - 74888888888 - : You want me to do miracles, do you too.
[26.11.2017, 15:48:38] Linda: Vova, I am not asking for miracles.
You said yourself we'll close the matter by Monday.
Zelimkhan personally confirmed this to the man on the phone.
Asked him for a couple of days' grace.
[26.11.2017, 15:50:28] Roman Shpakov: Oooh! Now manipulating the regulator is no miracle. Phew.
Linda, close everything tomorrow in Cyprus, why are we wasting time?))
[26.11.2017, 15:50:45] Roman Shpakov: A bunch of correspondence created like a club of wankers.
[26.11.2017, 15:51:00] Roman Shpakov: I propose to conclude the discussion for today.
[26.11.2017, 15:51:46] Linda: Roman, I'm not throwing stones in the water.
At this point, we have not fulfilled our communications to the partners.
[26.11.2017, 15:52:12] Linda: I've closed the question
[26.11.2017, 15:52:17] Linda: And we made a miracle.
[26.11.2017, 15:52:36] Roman Shpakov: Well done. Now it's our turn�
[26.11.2017, 15:54:18] +7 965 - 7488888 - : +
[26.11.2017, 15:56:41] Linda: )))) understandable. We are doing well. Really what am I worried about.
[26.11.2017, 15:57:57] Roman Shpakov: Linda, we can shit ourselves with fear, realising the complexity of the
situation, but all we will get is dirty shitty trousers.
[26.11.2017, 15:58:39] Roman Shpakov: Everyone understands everything. Someone lamba I have already bought.
702
[26.11.2017, 16:08:25] Linda: I'll say the last ones and I won't say anything else. The time will come you will remember
my words.
It should have been handled through Zelimkhan's men two weeks ago.
What we will get now is shit our trousers, because afer the Central Bank responds again to Cyprus we can shit our
trousers or get fucked in the arse there will be no solution.
Have a good weekend.
[26.11.2017, 16:11:53] +7 965 - 74888888888 - : Zelimkhan's people also decide
[26.11.2017, 16:12:02] +7 965 - 74888888888 - : That's why rv said he gave lambos - already
[26.11.2017, 16:16:47] +7 965 - 74888888888 - : Too bad not me ))))
[26.11.2017, 16:16:52] Linda: Vov. Let's enjoy the weekend. We don't have many of them lef. It's a pity that none of
you listened to Istria guys with whom G worked.
[26.11.2017, 16:18:36] Roman Shpakov: It's a shame that you thought we decided to risk everything for the sake of
poking you.
[26.11.2017, 16:25:29] Linda: I get out of the car, I don't go to Limassol, I go for a walk in the park with Nicole.
Zeliman, if you are reading this correspondence, get your people involved to close the issue. Try to convince Roman,
in case he hears you.
[26.11.2017, 17:06:44] .: We have all agreed on actions, Vladimir keeps the situation under control, his people are
ready to act, if there is a need for assistance - let's give it, everyone is interested in the result. In any case today is a day
off, we'll move on tomorrow
[26.11.2017, 17:34:02] +7 965 - 748888888 - : Call - me back
[26.11.2017, 17:42:38] Linda: I'm with Nick, I'll dial in 15 mins.
[26.11.2017, 18:07:16] Linda: I'm calling can't reach you.
[26.11.2017, 22:52:45] Linda: No, that's not what we agreed in bamba. You're the one who's already overplayed it
without me.
We agreed that your men would go all out.
Then I was put to the fact that the matter would be dealt with in another way
I won't keep quiet anymore, we agreed to do through your people to the fullest, we have to follow what we agreed.
I don't enjoy writing the same thing to you 10 times a day.
[26.11.2017, 22:57:51] +7 965 - 74888888888 - : We agreed to wait.
[26.11.2017, 23:13:47] Linda: ))) well, well.
[26.11.2017, 23:27:38] Linda: Don't spit in the well, it will come in handy to drink water.
Let's keep this expression in mind when the request from the Central Bank comes again and how Cyprus will react to
it.
703
[26.11.2017, 23:28:26] Roman Shpakov: Ok
27.11.2017
[27.11.2017, 09:19:40] +7 965 - 74888888888 - : Will the letter go out today ?
[27.11.2017, 09:22:45] Roman Shpakov: According to Linda's guess, yes.
[27.11.2017, 09:23:02] +7 965 - 74888888888 - : The draf letter has arrived
[27.11.2017, 09:23:25] Roman Shpakov: Cyprus will first consult, then draf a letter, then send it.
[27.11.2017, 09:23:59] Roman Shpakov: Zelim, Krupsky finished.
[27.11.2017, 09:24:18] Linda: I'm tired.
[27.11.2017, 09:24:41] Roman Shpakov: What's in it for us.
[27.11.2017, 09:27:04] Linda: No need to throw stones in the water.
[27.11.2017, 09:27:17] Roman Shpakov: I see
[27.11.2017, 09:27:49] Roman Shpakov: Linda, as an adequate interlocutor we have lost.
[27.11.2017, 09:28:29] Roman Shpakov: Vov, write Apo
[27.11.2017, 09:28:53] Linda: I have no guesses, I say what I know. And because I don't agree with what's going on you
start attacking me.
[27.11.2017, 09:31:01] Roman Shpakov: Linda, there is a solution to the issue. You are required to assist. Gather your
strength and reach the path to the end. Vladimir requires from you information, give it to him.
[27.11.2017, 09:31:23] Linda: I'll give it my all
[27.11.2017, 09:31:27] Linda: We have 8.31.
[27.11.2017, 09:31:32] Linda: At 9 board.
[27.11.2017, 09:32:10] Roman Shpakov: Excellent. Immediately afer the info to Vladimir.
[27.11.2017, 09:32:26] Roman Shpakov: I wish everyone a good week.
[27.11.2017, 11:19:36] +7 965 - 74888888888 - : Any news ?
[27.11.2017, 11:20:05] Linda: No.
[27.11.2017, 11:21:10] Linda: Am I correct in confirming to Greg that we do not have 100% certainty that the Central
Bank will no longer respond with a request for Cyprus?
[27.11.2017, 11:29:49] Linda: ?
[27.11.2017, 11:31:22] Roman Shpakov: Look at the TV series Billions. There about 100% certainty.
[27.11.2017, 11:35:17] Linda: Roman, I need to give an answer to the person who asked me and Apollo a question
today.
[27.11.2017, 11:36:21] Linda: He wants to understand how to proceed with our case.
[27.11.2017, 11:36:44] +7 965 - 74888888888 - : Board is not over ?
704
[27.11.2017, 11:37:39] +7 965 - 74888888888 - : I d said, if the answer from Cyprus will come reasonable, not from the
series that the turnover was 180kk and lived pyramid, there will be no letters.
[27.11.2017, 11:38:17] Linda: I don't know. I have to give him the information. He said to give him answers to
questions from back on Sunday.
[27.11.2017, 11:38:31] Linda: �� Vova
[27.11.2017, 11:38:41] Linda: If the answer comes like this from Cyprus.
[27.11.2017, 11:38:52] Linda: I will no longer be in Cyprus at this point in time
[27.11.2017, 11:39:07] +7 965 - 74888888888 - : Well then we understand each other ?!
[27.11.2017, 11:40:09] Linda: No, you don't get it. Zelimkhan asked G, a couple of days of delay and that the issue with
the Central Bank would be closed. I don't know if you were at that conversation.
[27.11.2017, 11:41:14] Linda: That one agreed and said will help. We gave very superficial information to our board
and I was sending our response.
[27.11.2017, 11:42:22] Linda: If he doesn't have an understanding now that the issue with the Central Bank is closed I
don't know and I can't guarantee that our response will be accepted and they won't come to us with an investigation.
[27.11.2017, 11:42:55] Linda: That's one of the reasons why I'm so nervous.
[27.11.2017, 11:44:29] Roman Shpakov: Linda, our people are very eager to give a 100% guarantee, in fact they give it,
in principle, they are the only ones who can give it. But 100% guarantee is like a perpetual motion machine, it does
not exist.
[27.11.2017, 11:50:12] Linda: Roman, I understand everything. But you also understand me. I don't know how the
situation is going to unfold right now. We told him that we will close the issue and we guarantee it. On Saturday, we
got different information. So now he's asking, what's going on in Russia? Zelimkhan told him that we will close the
issue, he accepted these words and did not doubt them until we told him that if we give out Zelimkhan's name, the
enquiries may continue.
Because I'm more than sure if we say we don't know if we'll close the question or not, the situation is unpredictable
now.
And you certainly don't want to cheat him.
[27.11.2017, 11:50:45] +7 965 - 74888888888 - : I asked on Saturday to write in the letter sent things and afer that I
guarantee it
[27.11.2017, 11:52:17] Linda: (( Vov, come on, it's so hard. We are walking on thin ice here and one wrong step and
that's it.
We all passed on not to give Zelimkhan's name. The question is whether people can do it.
[27.11.2017, 11:52:30] Linda: This information came in on Saturday night
[27.11.2017, 11:52:42] Linda: It's not like she's alone on this board.
[27.11.2017, 11:53:07] Roman Shpakov: The sun is our favourite, we don't have an autobahn here either, you know.
[27.11.2017, 11:53:45] Linda: For the first time in my life, I don't know what to do.
[27.11.2017, 11:53:59] Roman Shpakov: Why all of a sudden?
[27.11.2017, 11:54:09] Linda: Definitely don't mess with him
705
[27.11.2017, 11:54:36] Linda: To tell him that you know we don't know here is also not clear what will happen
[27.11.2017, 11:55:42] Roman Shpakov: Of course. The answer should be:
Oh, they've taken on the issue. They guarantee to close the issue in full if the extra is not written from Cyprus. The
possibility that it could come from unexpected places is minimal.
[27.11.2017, 12:00:40] Linda: I already said that( to which I , let me finish and said, thank you for the tales of
Shehirizada .
Are you going to bury the question or not.
The agreement was that you would close him and your people confirmed it to me (my people are Zelimkhan) and that
no one had told him before not to give Zelimkhan's name.
I've been writing to you for two days about this. And I'm in a panic right now that I'm gonna say something to him that
he doesn't like and he's gonna say thank you, I get it.
[27.11.2017, 12:02:27] Roman Shpakov: Yes.
We know. We confirm. Please remove the name if possible.
You have to be careful, but honest with this man. Diplomacy is a thing.
[27.11.2017, 12:04:54] Linda: I'm glad you agree that you have to be honest with him, he doesn't forgive deception.
Now the question he asked, if they say Zelimaan's name, will the Central Bank respond as we asked? Thank you. Case
closed.
[27.11.2017, 12:07:18] Roman Shpakov: Our people know the installation. Ideally, if there is no name.
[27.11.2017, 12:10:37] Linda: If it will. The Central Bank will answer all the case is closed? Or a new enquiry will come. I
know why he's asking this, I hope you do too.
[27.11.2017, 12:40:22] Linda: Can I get an answer to his question?
[27.11.2017, 12:42:12] Roman Shpakov: They will answer correctly.
It's better not to have a name.
[27.11.2017, 12:42:19] Roman Shpakov: Final answer.
[27.11.2017, 13:02:30] +7 965 - 748888888 - : Linda
[27.11.2017, 13:02:31] +7 965 - 74888888888 - : I told you.
[27.11.2017, 13:02:36] +7 965 - 748888888 - : Everything will be fine
[27.11.2017, 13:06:38] Linda: Vov, thank you for your kind words.
But you told me so on Friday on Saturday you said there was a problem with the name.
You don't realise I answer to the man for this mess. And I know why he's asking me.
[27.11.2017, 13:07:04] +7 965 - 74888888888 - : I didn't say nat problem , I said it should be removed
[27.11.2017, 13:07:16] +7 965 - 74888888888 - : Don't compare history where there are 100 people and where there are
10000 - people
[27.11.2017, 13:07:23] +7 965 - 74888888888 - : Now I'm telling you everything will be fine
706
[27.11.2017, 13:13:40] Linda: The letter won't go out today.
[27.11.2017, 13:14:06] Linda: They're conferring.
[27.11.2017, 13:14:24] Linda: I'm just praying to God that the Central Bank doesn't send anything yet
[27.11.2017, 13:19:47] +7 965 - 74888888888 - : Dear, we have an agreement that your letter will go out today ....
[27.11.2017, 13:23:54] Linda: They're not sending yet, they're conferring. I didn't say it's going to leave today. I said
board, then conferring, then it's going to leave. That's while they're conferring. They'll tell us what's in there
[27.11.2017, 13:37:49] +7 965 - 74888888888 - : I did.
[27.11.2017, 13:40:05] +7 965 - 748888888 - : Okay
[27.11.2017, 13:40:14] +7 965 - 74888888888 - : I don't want to find out who's right
[27.11.2017, 13:40:41] +7 965 - 74888888888 - : You zorooo
[27.11.2017, 13:40:42] +7 965 - 748888888 - : OK
[27.11.2017, 13:41:28] Linda: Vova I pass on what I am told. Do I eat say no let it go today exactly?
[27.11.2017, 13:49:17] Linda: Vov ?
[27.11.2017, 13:49:21] Linda: So what's up ?
[27.11.2017, 13:51:04] +7 965 - 74888888888 - : And this process you can control ?
[27.11.2017, 14:09:50] Linda: I don't, she doesn't know. I'll ask him , I know there's a lot of people involved from
different departments right now.
[27.11.2017, 16:27:22] Linda: Vov
[27.11.2017, 16:27:28] Linda: Maybe we have a misunderstanding.
[27.11.2017, 16:28:52] Linda: Legal opinion of Krupskii, it is necessary in case a full investigation starts here. Now it will
not be attached to the response to your CB.
[27.11.2017, 16:29:53] +7 965 - 748888888 - : OK
28.11.2017
[28.11.2017, 00:21:24] +7 965 - 74888888888 - : Who has what news ?
[28.11.2017, 00:21:29] +7 965 - 74888888888 - : Zvm ? - Linda.
[28.11.2017, 00:21:31] +7 965 - 7488888 - : ?
[28.11.2017, 00:22:03] Linda: I have these.
[28.11.2017, 00:24:39] Linda: 1. QBCM - to liquidate urgently
2.Calculate actually how much money has gone into the accounts since the beginning of the story
3. The letter to your Central Bank has not been sent, they are still deciding.
4.QBFS - also liquidation
707
5. Clean the files, which is what we are doing now.
[28.11.2017, 00:27:53] +7 965 - 74888888888 - : Operation Clean Sheet
[28.11.2017, 00:30:15] Linda: I don't think it's a clean slate, it's more about saving drowning people
[28.11.2017, 00:30:20] Linda: What about you?
[28.11.2017, 00:35:54] +7 965 - 74888888888 - : I don't give a shit what you call it, I support - you
[28.11.2017, 00:36:13] +7 965 - 74888888888 - : I'm fine , the day is over , here at home, getting ready for bed.
[28.11.2017, 00:36:26] Linda: Vov
[28.11.2017, 00:36:32] Linda: I'm glad of course.
[28.11.2017, 00:36:40] Linda: But what's your deal with DH?
[28.11.2017, 00:36:57] Linda: Hi to you from Apo by the way
[28.11.2017, 00:37:10] +7 965 - 74888888888 - : Good.no.said even earlier not to fuss, everything will be fine. - (С)
[28.11.2017, 00:37:32] +7 965 - 74888888888 - : Him the same. - Say waiting in rf and personally invite to the korp new
year.
[28.11.2017, 00:37:51] Linda: Here we decided afer this story divorce, I will start a new life.
[28.11.2017, 00:37:58] Linda: Thank you I'll pass it on to him
[28.11.2017, 00:38:05] Linda: When is the corporate event?
[28.11.2017, 00:38:51] Linda: He really appreciates that you're the one who always invites him over, by the way.
[28.11.2017, 00:42:58] Linda: Zelimkhan dear man what have you got?
[28.11.2017, 00:43:34] +7 965 - 74888888888 - : Fuckers are you ?
[28.11.2017, 00:43:44] +7 965 - 74888888888 - : Afer 22 I think.
[28.11.2017, 00:46:15] Linda: Well, I've just got a lot of nerves and it's a mess.
.he doesn't say anything and he just says let's focus on solving the issue and then we'll talk. And I'm freaking out.
Okay, whatever.
[28.11.2017, 00:46:26] Linda: Ok tell me when.
[28.11.2017, 00:48:37] +7 965 - 74888888888 - : Well right now you really need to focus on solving all the issues
[28.11.2017, 00:53:16] +7 965 - 74888888888 - : I think in a couple of weeks we'll decide - everything already
[28.11.2017, 00:53:39] +7 965 - 74888888888 - : Afer the new year everyone will forget about everything and everyone
will remember it as jokes and jokes - about it
[28.11.2017, 00:55:40] Linda: Didn't even know that side of you.
[28.11.2017, 00:55:48] Linda: Thank you for your kind words
[28.11.2017, 00:55:54] Linda: God willing
708
[28.11.2017, 01:00:57] +7 965 - 74888888888 - : I'm not being kind, just stating the facts
[28.11.2017, 02:12:11] +7 965 - 74888888888 - : I hope you clean up the correspondence
[28.11.2017, 02:12:46] Linda: What correspondence?
[28.11.2017, 02:12:55] Linda: I'm the managing director of Constance
[28.11.2017, 02:13:03] Linda: I've known Roman for a long time
[28.11.2017, 02:13:14] Linda: He introduced me to Zelimkhan.
[28.11.2017, 02:13:23] Linda: I don't know anything.
[28.11.2017, 02:14:21] Linda: 2010 - 2015 the company was an agent for Walkena
[28.11.2017, 02:14:57] Linda: Here Zelimkhan decided to make caymans
[28.11.2017, 02:15:10] Linda: I don't know anything else.
[28.11.2017, 02:15:22] Linda: Yes signed the 2013.2014 audit.
[28.11.2017, 02:15:33] Linda: Yubo Zelimkhan
[28.11.2017, 02:15:43] Linda: Next up, other auditors
[28.11.2017, 02:16:57] +7 965 - 74888888888 - : That' - s not what I'm saying
[28.11.2017, 02:17:00] +7 965 - 7488888 - : )))
[28.11.2017, 02:17:05] +7 965 - 748888888 - : Just Correspondence
[28.11.2017, 02:17:06] Linda: I fronted Roman in the regulator everywhere because shareholder Vladimir Pakhomov
didn't know what to do with the company's faces)
[28.11.2017, 02:17:33] +7 965 - 74888888888 - : Well apparently I knew more than you:))))
[28.11.2017, 02:17:40] +7 965 - 748888888 - : Good night )))
[28.11.2017, 02:18:07] Linda: You too) went to clean the files further
[28.11.2017, 02:21:18] Linda: Our sore spot is two of them.
[28.11.2017, 02:21:24] Linda: Cdb
[28.11.2017, 02:21:29] Linda: Pireaus
[28.11.2017, 02:21:45] Linda: As we didn't try the documents in the cb there are
[28.11.2017, 02:21:59] Linda: There Roman
[28.11.2017, 02:22:42] Linda: Bank statements are bullshit too
[28.11.2017, 02:22:43] Linda: You are
[28.11.2017, 02:22:46] Linda: Roman
[28.11.2017, 02:22:49] Linda: Zelimkhan
[28.11.2017, 02:22:55] Linda: And aspard.
[28.11.2017, 02:25:47] Linda: Well the beautiful POA that Yudin dropped to Stepanov seems to be
[28.11.2017, 02:25:58] Linda: Where's Roman too
709
[28.11.2017, 02:30:56] Linda: That's how many times I ask Apo what happens if they get to the warrant, more and
more he keeps quiet and chews up the words and more and more I get nervous
[28.11.2017, 03:03:18] Linda: And we also found a trust on Roman from QB Capital, witnessed by Dima.
[28.11.2017, 03:04:35] Linda: Well, and a bunch more letters where I write that he lef the shareholders capital and
Roman sends me to three letters.
[28.11.2017, 03:13:19] Linda: In general, it was necessary to put Roman immediately on the sif and remove from the
capital. Why did you make a mess of this then , unclear to me who all this came up with as on purpose
[28.11.2017, 07:32:28] +7 965 - 74888888888 - : Apollo always chews up words ))))
[28.11.2017, 07:32:47] +7 965 - 74888888888 - : That's the most important thing to say right now.
[28.11.2017, 07:36:23] Linda: Take us to Thailand sometime, I will learn Thai boxing
[28.11.2017, 10:06:03] +7 965 - 74888888888 - : Of course
[28.11.2017, 11:00:25] +7 965 - 74888888888 - : Linda, what about the answer ? - You while pulling may reminder to
come
[28.11.2017, 11:08:32] Linda: So stop.
[28.11.2017, 11:08:41] Linda: You said it was closed.
[28.11.2017, 11:08:49] +7 965 - 748888888 - : Fuck - yeah.
[28.11.2017, 11:08:52] Linda: And they won't write anything else
[28.11.2017, 11:09:02] Linda: Here we go, I've got it all.
[28.11.2017, 11:09:04] +7 965 - 748888888 - : I'll call - you.
[28.11.2017, 17:43:31] Linda: You will also write well you slept with Dima.
[28.11.2017, 17:46:14] +7 965 - 7488888 - : �
[28.11.2017, 17:46:19] +7 965 - 748888888 - : Bouquet
[28.11.2017, 17:48:12] Linda: I responded to you about the baby bump, by the way.
[28.11.2017, 17:52:11] +7 965 - 74888888888 - : I saw - by the way
[28.11.2017, 17:55:10] Linda: Thank you Linda
[28.11.2017, 17:55:24] Linda: You're welcome Vova
[28.11.2017, 17:56:43] +7 965 - 748888888 - : I want to - pee
[28.11.2017, 17:57:17] Linda: Well, go ahead
[28.11.2017, 17:59:22] +7 965 - 74888888888 - : I'm in the car :(
[28.11.2017, 18:05:04] Linda: And I've got the arrival of brains.
[28.11.2017, 18:07:13] Linda: "Flushing.
[28.11.2017, 18:07:21] Linda: Didn't leave a reply
[28.11.2017, 18:07:35] Linda: Not everyone is happy with him
710
[28.11.2017, 18:07:59] Roman Shpakov: Are you correcting?
[28.11.2017, 18:08:17] Roman Shpakov: Or do they want to add a little bit of toughness?
[28.11.2017, 18:08:18] Linda: No!!!
[28.11.2017, 18:08:21] Linda: God forbid.
[28.11.2017, 18:08:33] Linda: While they're deliberating.
[28.11.2017, 18:08:37] Roman Shpakov: Ok
[28.11.2017, 18:08:51] Roman Shpakov: There should be an answer:
[28.11.2017, 18:08:57] Linda: He will.
[28.11.2017, 18:09:05] Linda: That's 100%.
[28.11.2017, 18:10:17] Roman Shpakov: no image available
[28.11.2017, 18:10:23] Roman Shpakov: Here it is
[28.11.2017, 18:10:40] Linda: Poor kid.
[28.11.2017, 18:43:10] Linda: In short.
[28.11.2017, 18:43:17] Linda: Clarification
[28.11.2017, 18:43:21] Linda: Right
[28.11.2017, 18:44:32] Linda: Your lovely DH sings the following
[28.11.2017, 18:45:08] Linda: That people who withdrew DS they did not pay tax as it is an investment business.
[28.11.2017, 18:45:48] Linda: They confirmed to me once again that this is currency control plus they are interested in
the tax component of this scheme
[28.11.2017, 18:48:32] +7 965 - 74888888888 - : Where is singing and to whom?
[28.11.2017, 19:08:45] Linda: In the first request.
[28.11.2017, 19:08:48] Linda: Then in the second one.
[28.11.2017, 19:09:35] Linda: And they say they're going to hook up the tax office and have their sights set on calling
for deofoshirisation
[28.11.2017, 19:11:34] Roman Shpakov: Here! I recognise Linda. And that all day positive, joyful.
[28.11.2017, 19:15:45] +7 965 - 748888888 - : Bullshit
[28.11.2017, 19:16:06] +7 965 - 7488888888888 - : Throw them this picture.
[28.11.2017, 19:22:08] Linda: The family is not without a freak. That's how negative you have me constantly pulling me
down to earth
[28.11.2017, 19:24:42] Roman Shpakov: Nah. That's not what I was getting at. It's just you've been cheerful all day, it
freaked me out.
[28.11.2017, 19:26:48] .: The topic of deoffshorisation with the disclosure of Russian yubos is like bread and butter for
everyone involved in the case, so the message with the absence of fios becomes even more relevant
711
[28.11.2017, 19:27:19] +7 965 - 7488888 - : +
[28.11.2017, 19:27:55] Roman Shpakov: +
[28.11.2017, 19:31:21] +7 965 - 7488888 - : +
[28.11.2017, 19:31:56] Roman Shpakov: =.
[28.11.2017, 21:13:59] Linda: It's hard not to give a yubo
[28.11.2017, 21:14:10] +7 965 - 74888888888 - : You should not give it
[28.11.2017, 21:14:31] Roman Shpakov: I don't get it(
[28.11.2017, 21:14:45] +7 965 - 74888888888 - : And you don't give - them one either
[28.11.2017, 21:14:49] Linda: There's more than one person sitting there.
[28.11.2017, 21:15:18] Linda: They need a yubo
[28.11.2017, 21:15:21] +7 965 - 748888888 - : I understand
[28.11.2017, 21:15:28] +7 965 - 74888888888 - : I'm meeting with ours - right now
[28.11.2017, 21:15:31] Linda: Maybe they want it that way because they think it's Roman
[28.11.2017, 21:15:49] Linda: This is where we give them that it's not Roman.
[28.11.2017, 21:16:57] Linda: You tell yours, regarding the law of delphshorisation and taxation. And those 180kk
figures of theirs
[28.11.2017, 21:17:09] Linda: I don't understand what your central bank has to do with the tax authorities.
[28.11.2017, 21:18:05] +7 965 - 74888888888 - : I'm not going to say that to - them
[28.11.2017, 21:18:17] Linda: You know best.
[28.11.2017, 21:18:24] Linda: But it figures.
[28.11.2017, 22:11:50] Linda: I met my ex - partner by chance, and realised that before meeting you I didn't know what
adrenaline was.
[28.11.2017, 22:27:00] +7 965 - 74888888888 - : Not excited ?:))))
[28.11.2017, 22:35:25] Linda: Offensive) I have the most excitable messages from Roman every morning.
For example, Roman's day off at the bank.
Answer, Linoyu, I said it all , open the bank and accept DS.
[28.11.2017, 23:25:38] +7 965 - 74888888888 - : But it's not boring ))))
[28.11.2017, 23:44:43] Linda: Vov
[28.11.2017, 23:44:45] Linda: So how was the meeting?
[28.11.2017, 23:57:25] +7 965 - 748888888 - : OK
[28.11.2017, 23:57:51] Linda: Well, what did they say?
29.11.2017
712
[29.11.2017, 00:00:21] +7 965 - 74888888888 - : They said everything is fine
[29.11.2017, 00:00:30] +7 965 - 74888888888 - : And that they were looking for a letter that doesn't exist
[29.11.2017, 00:01:03] Linda: Well, we kind of know he's gone.
[29.11.2017, 00:01:13] +7 965 - 74888888888 - : I didn't tell them ))))
[29.11.2017, 00:02:59] Linda: You didn't say about the IRS ?
[29.11.2017, 00:03:08] Linda: You didn't answer me.
[29.11.2017, 00:03:20] Linda: What does your Central Bank have to do with the tax office
[29.11.2017, 00:05:29] +7 965 - 748888888 - : No
[29.11.2017, 00:05:31] +7 965 - 74888888888 - : He didn' - t
[29.11.2017, 00:05:52] Linda: Zelimkhan, you have what?
[29.11.2017, 00:05:59] Linda: You've disappeared altogether.
[29.11.2017, 00:06:10] Linda: 4/12 needs to be in Montenegro
[29.11.2017, 00:06:15] Linda: Then on to Belgrade.
[29.11.2017, 00:06:45] Linda: Then we have to stop by Armenia
[29.11.2017, 00:07:02] Linda: I don't know when exactly to Armenia
[29.11.2017, 00:10:49] Roman Shpakov: Zelim, with Kirill stop all communication.
Also, charge him half of the amount paid, leave the rest to him for the work done.
[29.11.2017, 00:11:57] Linda: That's for what!
[29.11.2017, 00:12:05] Linda: For making my signature.
[29.11.2017, 00:12:17] Linda: Or for falsifying documents
[29.11.2017, 00:12:47] Linda: I'm suing him.
[29.11.2017, 00:12:54] Linda: Write to the komerz bank
[29.11.2017, 00:13:20] Linda: It remains to be seen what he signed on behalf of the company.
[29.11.2017, 00:14:57] Roman Shpakov: Linda, this is a separate case. Let's go without emotions. For now, just
separate peacefully.
[29.11.2017, 00:22:48] Linda: Roman, he did nothing. Other than doctored documents, forged my signature, used the
name vpard, and rubbished me with bullshit that we would open bank accounts without yubo information.
I need to get these forms fake.
They're crooks. Alice the fox and Basilio the cat.
I told you about that, by the way.
And you yelled at me for some parsley.
[29.11.2017, 00:28:24] +7 965 - 74888888888 - : Can we go without a showdown today ?
713
[29.11.2017, 00:28:27] +7 965 - 748888888 - : Not today
[29.11.2017, 00:28:30] +7 965 - 748888888 - : You're welcome
[29.11.2017, 00:47:04] Linda: Zelimkhan
[29.11.2017, 00:47:16] Linda: Where are you?
[29.11.2017, 00:59:58] +7 965 - 74888888888 - : He's been asleep for a long time
[29.11.2017, 01:06:00] Linda: He's hiding somewhere.
[29.11.2017, 01:21:38] +7 965 - 748888888 - : Sleeping
[29.11.2017, 01:21:57] Linda: All of you are asleep
[29.11.2017, 01:22:02] Linda: The old ones have become
[29.11.2017, 01:22:39] +7 965 - 7488888 - : �
[29.11.2017, 01:25:26] Linda: Okay, none of your business)
[29.11.2017, 01:26:13] Roman Shpakov: Linda, sleep.
[29.11.2017, 01:27:23] Linda: I'm sleeping, I'm sleeping.
[29.11.2017, 07:02:23] +7 965 - 74888888888 - : And so it is correct
[29.11.2017, 08:14:43] .: I'll cross paths with Kirill tomorrow, we'll discuss the dough and the run - up
[29.11.2017, 08:55:04] Linda: Hi.
[29.11.2017, 08:55:07] Linda: Podgorica
TGD, Golubovci Arpt
[29.11.2017, 08:55:16] Linda: You're going to this airport
[29.11.2017, 08:55:47] Linda: There are two in Montenegro, 4/12 you have to fly into this airport
[29.11.2017, 08:59:23] Linda: And get your hands on fake forms, if you can ask for copies. And please ask for the
specific branch where the account was supposedly opened, Ali will write there tomorrow
[29.11.2017, 09:47:35] .: Forms they will not give, it is if we accept the account, and here is not. About the branch I will
ask for sure
[29.11.2017, 09:48:21] Linda: Well, let them keep them as a souvenir. Ali is writing a formal letter to the bank's
compliance tomorrow
[29.11.2017, 09:58:54] Linda: And I have a question. When Apo told you that the person in question was a crook and
not to send him the docs, and you sent them anyway behind his back, did the documents sent include the capital and
yubo trust?
[29.11.2017, 10:16:11] .: Besides you, did anyone correspond with him on the documents?
[29.11.2017, 10:16:16] .: I don't)
[29.11.2017, 10:17:06] .: As you and he discussed on the docks what he had and what he didn't have, it's stayed that
way since then
[29.11.2017, 10:17:55] Linda: I didn't give him any documents. I wrote to him regarding the account requirements (I
was forced to).
714
[29.11.2017, 10:18:08] Linda: And he told me you gave him the capital docs.
[29.11.2017, 10:24:07] Roman Shpakov: Colleagues, we will discuss this with the three of us and later.
[29.11.2017, 10:26:19] Linda: Okay not the point who is right who is to blame.
We should learn to listen to each other's opinions. We trust them for some reason, but to our partners we say you are
fools and don't know anything.
Then we have problems because of strangers and we start blaming each other and again solve the problems we
created.
[29.11.2017, 10:27:49] Roman Shpakov: Ok
[29.11.2017, 13:22:56] +7 965 - 74888888888 - : Who has what news ?
[29.11.2017, 13:26:09] Linda: I don't have any, we're waiting.
[29.11.2017, 15:48:40] Linda: I'm going to G's
[29.11.2017, 15:48:43] Linda: A question for you.
[29.11.2017, 15:49:21] Linda: You resolve the issue this way on the CB not through QBF's staff
[29.11.2017, 15:49:28] Linda: And through other people.
[29.11.2017, 15:49:32] Linda: Right?
[29.11.2017, 15:50:21] Linda: He asked me that question and I'm asking you that question
[29.11.2017, 15:50:57] Linda: You've hooked up high profile people to shut down the issue
[29.11.2017, 15:51:05] +7 965 - 74888888888 - : Through which employees ?
[29.11.2017, 15:51:21] Linda: I don't know through which ones.
[29.11.2017, 15:51:28] Linda: I'm asking you.
[29.11.2017, 15:53:21] .: We decide through Avetis
[29.11.2017, 15:53:40] .: He has strong contacts all over the place
[29.11.2017, 15:54:00] Linda: Are you normal?
[29.11.2017, 15:54:15] Linda: Are you serious?
[29.11.2017, 15:54:24] .: Roman said via Avetis to decide
[29.11.2017, 15:54:42] Linda: Zelimkhan
[29.11.2017, 15:54:56] +7 965 - 74888888888 - : Well, if he knows - everyone.
[29.11.2017, 15:55:04] Linda: So I'm off for a drink.
[29.11.2017, 16:08:14] Linda: I will then go to solve our issue through the woman who cleans our office she has
connections in the regulator.
[29.11.2017, 16:10:39] +7 965 - 74888888888 - : Cleaning Director?
[29.11.2017, 16:12:23] Linda: No, photocopy director
[29.11.2017, 16:12:46] Linda: I understand that you are young and not serious, but not to such an extent.
715
[29.11.2017, 16:16:06] Linda: I don't even know what you can decide through a man who orders himself a shaving
machine, when his only way out is to burn all his hair with paraffin and that's not a fact
[29.11.2017, 16:19:35] +7 965 - 7488888 - : ��
[29.11.2017, 20:51:43] Linda: Here's the situation
[29.11.2017, 20:51:54] Linda: Letters will leave early tomorrow morning
[29.11.2017, 20:51:55] Linda: About who is yubo
[29.11.2017, 20:51:56] Linda: Company address in the RF
[29.11.2017, 20:51:56] Linda: And that according to the lawyer the company does not conduct investment activities
[29.11.2017, 20:51:57] Linda: Send proof on what basis you decided that yubo Roman and that the company is
conducting investment activities
[29.11.2017, 20:57:45] +7 965 - 74888888888 - : Fucking lite answer
[29.11.2017, 20:58:51] Linda: Well that's a lite answer for them
[29.11.2017, 21:01:18] +7 965 - 74888888888 - : Greg Resolved
[29.11.2017, 21:02:10] Linda: Vova
[29.11.2017, 21:02:32] Linda: Let's you not talk about him like that.
[29.11.2017, 21:02:52] Linda: There's more than one person on the board
[29.11.2017, 21:03:13] Linda: What they were able to achieve was not to come with an inspection before answering to
the CB
[29.11.2017, 21:07:07] Roman Shpakov: Can you send on the next week?
[29.11.2017, 21:20:04] Roman Shpakov: A power of attorney and a contract with my signature, and it will be
interesting)
[29.11.2017, 21:21:47] Roman Shpakov: Apparently Linda wants us all to get high afer all.
[29.11.2017, 21:23:03] Roman Shpakov: You know why they didn't send you reminders, because our people are
working. And you're proposing to shit on their work. Well, let's see)))
[29.11.2017, 21:24:34] +7 965 - 74888888888 - : Well, you said he'd solve - it all
[29.11.2017, 21:24:39] +7 965 - 74888888888 - : It doesn't look like it
[29.11.2017, 21:25:05] +7 965 - 74888888888 - : What happens if the cb sends a trust ? - How will yours react ?
[29.11.2017, 21:30:04] Linda: No, that's not true. The reason is because CySEC replied to them that we will reply by the
end of the month. This was confirmed today so there was no remender
[29.11.2017, 21:30:40] Linda: What they're trying to take away now is Roman's name.
[29.11.2017, 21:31:20] Linda: But send proof on the basis of what you have been touching us for almost 2 months -
they will write
[29.11.2017, 21:31:24] Linda: It can't be removed
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[29.11.2017, 21:33:19] Linda: We didn't have any inspection . We were just sent letters and told to give a response . We
didn't even respond to it in full .
[29.11.2017, 21:35:11] Linda: They had a board with a certain number of people. Somehow decided that helmet like
this. There was a question people then why we were fucked in the brain here with their messages and accusations
[29.11.2017, 21:50:05] Roman Shpakov: We have a check until pnd. Will send with this content, it will be Super!!!)) you
will resume the 3 - week cycle.
[29.11.2017, 21:55:33] Linda: Roman I told you the content a week ago.
[29.11.2017, 21:56:06] Linda: They added that on what grounds do you say that the company is conducting
investment activities
[29.11.2017, 21:56:19] Linda: Plus Your Name
[29.11.2017, 21:56:46] Linda: Regarding your name, I said it should be removed at will
[29.11.2017, 21:56:51] Linda: I'll be told tomorrow morning.
[29.11.2017, 21:57:15] Linda: Paragraph - regarding immnvest activities not to be removed
[29.11.2017, 21:57:24] Linda: It's a standard question
[29.11.2017, 21:57:30] Roman Shpakov: They will send you the contract too
[29.11.2017, 21:57:38] Roman Shpakov: Trustworthiness
[29.11.2017, 21:58:02] Linda: Once again, it's your name
[29.11.2017, 21:58:07] Roman Shpakov: With access to the securities market)))
[29.11.2017, 21:58:12] Linda: It should be removed
[29.11.2017, 21:58:25] Linda: I want to die here.
[29.11.2017, 21:58:39] Linda: But with investment activity.
[29.11.2017, 21:58:48] Linda: I don't fuckin' know what to do.
[29.11.2017, 21:59:19] Linda: This is what others are asking to add
[29.11.2017, 21:59:46] Roman Shpakov: And you don't need to ask for proof. It's like asking Vova to show his dick, he
will.
[29.11.2017, 22:01:39] Linda: Roman, how can you imagine when they are flooded with letters and accusations, they
are told we have carried out brining, go fuck yourself and on what basis do you fuck with us
[29.11.2017, 22:03:54] +7 965 - 74888888888 - : Well at least someone is fucking around - ))))
[29.11.2017, 22:04:19] Roman Shpakov: I have voiced the risks.
[29.11.2017, 22:05:22] Linda: Why the fuck do you keep the lights on!!!!
[29.11.2017, 22:09:50] +7 965 - 74888888888 - : When dick show ?))
[29.11.2017, 22:10:45] Linda: Jesus, it's not for you.
[29.11.2017, 22:12:31] Linda: That sentence is not going to be removed.
[29.11.2017, 22:25:38] +7 965 - 748888888 - : Fucking - awesome
717
[29.11.2017, 22:25:40] +7 965 - 74888888888 - : That's it
[29.11.2017, 22:25:46] +7 965 - 74888888888 - : Fucking hell:))))
[29.11.2017, 22:26:42] Linda: Right
[29.11.2017, 22:26:46] Linda: Here's what's going to happen
[29.11.2017, 22:26:52] Linda: A second to quote
[29.11.2017, 22:27:37] Linda: Please note if you want to clarify anything further please provide us with the proof
[29.11.2017, 22:27:46] Linda: Here's what it will say
[29.11.2017, 22:27:54] Linda: Without Roman.
[29.11.2017, 22:28:13] Linda: Without proving that investment activity
[29.11.2017, 22:29:36] Roman Shpakov: Provide us the proof... - prove
[29.11.2017, 22:33:03] Linda: No, if you still write us send us proof ,
[29.11.2017, 22:33:08] Linda: That's what it means
[29.11.2017, 22:33:31] .: Yep. The last couple of words negate the whole answer
[29.11.2017, 22:33:44] .: It turns out this is a request for a reply letter from the rf
[29.11.2017, 22:34:00] +7 965 - 748888888 - : Linda
[29.11.2017, 22:34:18] +7 965 - 74888888888 - : What happens if they get power of attorney for RV?
[29.11.2017, 22:34:59] Linda: Vova
[29.11.2017, 22:36:08] Roman Shpakov: They will send.
[29.11.2017, 22:37:12] Linda: It's a standard sentence in a letter between regulators. She confirmed
[29.11.2017, 22:38:27] Linda: Zoran said if you've sorted everything out nothing will be sent.
[29.11.2017, 22:39:57] Roman Shpakov: Let's flip a coin)
[29.11.2017, 22:41:09] Linda: If they send it means the issue has not been closed. That's what people have said
[29.11.2017, 22:41:24] Linda: How did you want it?
[29.11.2017, 22:41:30] Linda: Yes they send requests
[29.11.2017, 22:41:44] Linda: The response from us is a letter to the lawyer.
[29.11.2017, 22:41:52] Linda: And ALL.
[29.11.2017, 22:42:07] Linda: That's why they said close the issue in RF
[29.11.2017, 22:42:26] Linda: If they send it, it'll be fucked.
[29.11.2017, 22:43:09] Linda: 'Here.
[29.11.2017, 22:46:03] Linda: Quote - you will become famous throughout Europe and RF" scandal will be very big.
Dokverka on Roman people can not send if in the RF issue is closed.
[29.11.2017, 22:55:06] Roman Shpakov: Linda:
10,000 people
718
100 people
[29.11.2017, 22:55:26] Linda: Not 100 Roman.
[29.11.2017, 22:55:33] Linda: I spoke to Zoran.
[29.11.2017, 22:55:46] Linda: He was closing questions at the Central Bank
[29.11.2017, 22:55:58] Linda: And said if they contact him don't worry.
[29.11.2017, 22:56:07] Linda: Found it
[29.11.2017, 22:56:39] Roman Shpakov: What?
[29.11.2017, 22:56:50] Linda: Found a contact
[29.11.2017, 22:57:09] Linda: We had 3 departments
[29.11.2017, 22:57:20] Linda: To the borda
[29.11.2017, 22:57:54] Linda: 100% your name will not be in the answer
[29.11.2017, 23:04:11] Roman Shpakov: Cool))))
[29.11.2017, 23:06:49] +7 965 - 748888888 - : Zelim, call yours
[29.11.2017, 23:08:31] +7 965 - 74888888888 - : I mean Avetis.
[29.11.2017, 23:11:46] Linda: That's fucked up.
[29.11.2017, 23:11:53] Linda: That's it
[29.11.2017, 23:11:57] Linda: Just fucked up.
[29.11.2017, 23:12:38] +7 965 - 74888888888 - : Fucked up is this one
[29.11.2017, 23:25:58] Roman Shpakov: We discussed and made a decision: Cyprus does not respond until Tuesday.
[29.11.2017, 23:26:23] Linda: Not possible. There was a board
[29.11.2017, 23:26:28] Linda: I told Vova.
[29.11.2017, 23:26:39] Linda: The decision here has been made
[29.11.2017, 23:28:47] Roman Shpakov: From the heart
[29.11.2017, 23:57:18] +7 965 - 74888888888 - : Talked. Send this kind of shit, may respond because it's a challenge. -
Linda Tuesday...
[29.11.2017, 23:57:46] Linda: I have a 22.57.
[29.11.2017, 23:57:57] Linda: And all the residents here, too.
[29.11.2017, 23:58:19] Linda: You realise the decision has been made, reply tomorrow morning
[29.11.2017, 23:58:24] Linda: Approved
[29.11.2017, 23:59:04] Linda: Ettore challenge, it's about the treaty between the two countries
[29.11.2017, 23:59:23] Linda: One country has been blaming another for almost 2 months now
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01.12.2017
[01.12.2017, 00:07:27] Linda: I was told that these people were asking customers today if they were getting their
withdrawals on time
[01.12.2017, 00:07:31] Linda: Is that true?
[01.12.2017, 00:07:38] Roman Shpakov: No
[01.12.2017, 00:08:18] Roman Shpakov: And who told you such a thing?
[01.12.2017, 00:09:07] Linda: I can't say. I gave my word not to say
[01.12.2017, 00:09:26] .: That's bullshit, there was a passing phrase to a passing customer
[01.12.2017, 00:09:39] Roman Shpakov: Linda, now is probably not the moment when you should keep your word.
[01.12.2017, 00:09:42] .: Heard Sobolev, Avetis and a few other people
[01.12.2017, 00:09:48] Roman Shpakov: What is the phrase?
[01.12.2017, 00:09:52] .: The client's response was positive that everything is ok
[01.12.2017, 00:10:15] .: Do they pay you money?
[01.12.2017, 00:10:19] .: This is the one
[01.12.2017, 00:10:23] Linda: Yes
[01.12.2017, 00:10:29] Linda: That's what I was told.
[01.12.2017, 00:10:46] .: Then everyone around the office started bitching about it, like the client blew off the cop
[01.12.2017, 00:10:56] Linda: But not the people who were standing there.
[01.12.2017, 00:11:09] Linda: I was told the other day.
[01.12.2017, 00:11:16] Roman Shpakov: Ok
[01.12.2017, 00:14:17] +7 965 - 74888888888 - : Complete nonsense
[01.12.2017, 00:14:43] Linda: Zelimkhan confirmed this is true
[01.12.2017, 00:15:16] Linda: But in a less distorted version that was brought to me.
[01.12.2017, 00:15:22] .: The situation is bullshit
[01.12.2017, 00:15:33] .: It's to this).
[01.12.2017, 00:16:09] Linda: And when will Constance's seals be returned?
[01.12.2017, 00:16:14] Linda: And aspard?
[01.12.2017, 00:16:35] +7 965 - 748888888 - : Next week
[01.12.2017, 00:17:15] Linda: Roman, please take them home.
[01.12.2017, 00:17:27] Linda: Or give it to Dima.
[01.12.2017, 00:18:19] Roman Shpakov: We will do everything.
[01.12.2017, 00:18:48] Roman Shpakov: You better BO take tomorrow.
720
[01.12.2017, 00:22:51] Linda: Zelimkhan, I will stop any communication between your office and Constance
employees. No one will answer letters or calls. It will be better for everyone, and please give me all the brochures as
well.
[01.12.2017, 00:23:12] Linda: This client will be the death of me
[01.12.2017, 00:23:24] Linda: It's so hard to get him started
[01.12.2017, 00:25:37] +7 965 - 748888888 - : I understand
[01.12.2017, 00:25:44] +7 965 - 74888888888 - : But you will be asked for an invoice for 15 in the - morning
[01.12.2017, 00:25:46] +7 965 - 7488888 - : 150
[01.12.2017, 00:25:50] +7 965 - 74888888888 - : You're even in the know
[01.12.2017, 00:26:34] Linda: It will be easier later on
[01.12.2017, 00:26:37] Linda: I know.
[01.12.2017, 01:28:02] Linda: Happy 1st of December to you . Today is the first day of winter . We say kalo mina . So
have a good month
[01.12.2017, 01:29:14] +7 965 - 748888888 - : Dia
[01.12.2017, 01:31:35] Linda: We have a phrase written on the wall in our office
The darkest hour before dawn
[01.12.2017, 01:31:44] Linda: It was told to me by someone.
[01.12.2017, 01:31:52] Linda: It's very memorable
[01.12.2017, 01:32:16] Linda: And when I'm scared, I say it.
[01.12.2017, 01:32:33] Roman Shpakov: We're all waiting to see where the dawn is.
[01.12.2017, 01:37:53] Linda: When an important event in life comes, you have to pass some kind of test, sometimes
very hard, and everything depends on how you pass it.
If it passes and you've managed it, then wait for the dawn.
[01.12.2017, 01:38:04] Linda: That's a phrase you said to me.
[01.12.2017, 01:38:28] Linda: When I was really scared and worried.
[01.12.2017, 01:39:49] Roman Shpakov: We are waiting)
[01.12.2017, 01:41:06] +7 965 - 74888888888 - : Judging by events in 2018 I will be a millionaire
[01.12.2017, 01:41:33] Linda: ))))
[01.12.2017, 01:42:38] Linda: And I'm going to have a lot of clients at Constance and everything will be nice and quiet
[01.12.2017, 01:47:19] Linda: It's not funny anymore. We have every messenger of the year such that I am already
allergic to Christmas and New Year's Eve
[01.12.2017, 15:27:54] Linda: Please stop shouting at Cyril
[01.12.2017, 15:27:59] Linda: It's blocked.
721
[01.12.2017, 15:28:03] Linda: And there's no use.
[01.12.2017, 15:28:56] Linda: He's already afraid to come in and asks me to be on the phone when he goes to your
office
[01.12.2017, 16:20:03] Linda: What are we doing with B?
[01.12.2017, 16:20:13] Linda: He only wants it directly
[01.12.2017, 16:20:19] Linda: She's truer.
[01.12.2017, 16:22:18] Roman Shpakov: Vanuatu. Make this case, please.
[01.12.2017, 16:23:20] Roman Shpakov: Linda, it is very necessary. Agree with the bank. The money from the sale of
the TC. Clean.
[01.12.2017, 16:23:30] Linda: They don't want to, it's not profitable for them to lose their cor accounts
[01.12.2017, 16:23:37] Roman Shpakov: A couple more rounds of negotiations, and it will be - 6.
[01.12.2017, 16:23:45] Roman Shpakov: He's clean.
[01.12.2017, 16:24:01] Linda: No they're not.
[01.12.2017, 16:24:08] Linda: Remember Shishanov
[01.12.2017, 16:24:16] Linda: They kept the money for a month
[01.12.2017, 16:24:24] Linda: The investigation has begun again.
[01.12.2017, 16:24:35] Linda: And I flew to vanuatu.
[01.12.2017, 16:24:37] Roman Shpakov: Where?
[01.12.2017, 16:24:49] Roman Shpakov: I'll get you an aeroplane directly.
[01.12.2017, 16:25:20] Roman Shpakov: That one was a military man, this one is an ordinary comer.
[01.12.2017, 16:25:40] Linda: No he's a pep and that's a fact .
[01.12.2017, 16:25:44] Roman Shpakov: Either send a statement that borz pep, or put up an invoice.
[01.12.2017, 16:25:47] Linda: No matter how we spin it
[01.12.2017, 16:26:40] Linda: Roman I tell you again they will not accept it in their system they have it all. We had 2
accounts closed because of it, the security service in Armenia called it in
[01.12.2017, 16:28:08] Linda: We're about to get this account closed as well
[01.12.2017, 16:28:11] Roman Shpakov: Linda, close the question. Try 200 for a start
[01.12.2017, 16:28:18] Linda: And what are we going to do!
[01.12.2017, 16:28:41] Roman Shpakov: We are already launching a new scheme with Serbia. Without q.
[01.12.2017, 16:29:21] Linda: I understand, but it is a risk that the money will be blocked, then return it back and then
the scandal
[01.12.2017, 16:29:41] Roman Shpakov: This has already happened to him.
[01.12.2017, 19:23:15] Linda: Can you please tell me what's up with the DH?
[01.12.2017, 19:29:35] +7 965 - 748888888 - : Ždemojnovojeitz
722
[01.12.2017, 19:29:40] +7 965 - 748888888 - : Waiting for updates
[01.12.2017, 19:33:54] Linda: Any sense of when?
[01.12.2017, 19:34:10] Linda: I'm afraid to leave without knowing what's going to happen here.
[01.12.2017, 19:34:16] +7 965 - 748888888 - : Till Mon
[01.12.2017, 19:35:29] Linda: Well did they see the letter?
[01.12.2017, 19:35:52] +7 965 - 74888888888 - : What do you think ?
[01.12.2017, 19:37:03] Linda: A must see
[01.12.2017, 19:37:07] Linda: Is the answer ready?
[01.12.2017, 20:21:05] +7 965 - 74888888888 - : They may not respond
[01.12.2017, 20:21:09] +7 965 - 74888888888 - : I told you - already.
[01.12.2017, 20:21:37] +7 965 - 74888888888 - : They received the letter, just confirmed it
[01.12.2017, 20:22:39] Linda: They have to answer.
[01.12.2017, 20:22:51] Linda: Otherwise they'll start writing to them
[01.12.2017, 20:23:07] Roman Shpakov: And they won't answer again)
[01.12.2017, 20:23:23] Linda: There's no such thing.
[01.12.2017, 20:23:26] Roman Shpakov: They will send reminders to the Russian Federation.
[01.12.2017, 20:23:40] Linda: It's a violation of a bilateral treaty
[01.12.2017, 20:23:57] +7 965 - 748888888 - : Topic
[01.12.2017, 20:23:58] Linda: Until they get an answer the case is not closed
[01.12.2017, 20:24:19] Linda: It came was answered and said the case is closed
[01.12.2017, 20:24:30] Linda: So we fooled people here?
[01.12.2017, 20:24:44] +7 965 - 74888888888 - : Did I tell you there would be an answer?
[01.12.2017, 20:25:15] Linda: Yes, he did and Zelimkhan said so
[01.12.2017, 20:25:27] Linda: No it's not.
[01.12.2017, 20:25:37] Linda: You said I'd do anything to get an answer.
[01.12.2017, 20:25:45] Linda: Zelimkhan said will respond
[01.12.2017, 20:26:41] Linda: Here you go
[01.12.2017, 20:26:47] Roman Shpakov: And we can not start the weekend with a discussion)))
[01.12.2017, 20:26:54] Linda: You told me they'd answer.
[01.12.2017, 20:27:02] Linda: This is not a discussion
[01.12.2017, 20:27:20] Linda: This is my life.
723
[01.12.2017, 20:27:20] +7 965 - 74888888888 - : This is my correspondence with the person
[01.12.2017, 20:27:23] Roman Shpakov: Chet I don't see that it says they will answer)))
[01.12.2017, 20:27:28] +7 965 - 74888888888 - : No one has made - any promises yet
[01.12.2017, 20:27:41] Linda: Aaah wow.
[01.12.2017, 20:27:51] Linda: So here goes
[01.12.2017, 20:27:52] Roman Shpakov: Here we go)
[01.12.2017, 20:27:53] Linda: Ok.
[01.12.2017, 20:28:15] Linda: Zelimkhan
[01.12.2017, 20:28:21] Linda: You're the guarantor of the word
[01.12.2017, 20:28:29] Linda: Now here's a look at what I'm being told
[01.12.2017, 20:29:10] +7 965 - 748888888 - : Linda
[01.12.2017, 20:29:13] +7 965 - 748888888 - : Today is Friday
[01.12.2017, 20:29:52] +7 965 - 74888888888 - : I fought off - an office - search all night long
[01.12.2017, 20:30:01] +7 965 - 74888888888 - : And worked - all day long
[01.12.2017, 20:30:11] +7 965 - 74888888888 - : I honestly don't want to discuss this - today
[01.12.2017, 20:30:19] +7 965 - 74888888888 - : Better tell us about your plans for the weekend
[01.12.2017, 20:36:35] Roman Shpakov: Or tell us how you take borz.
[01.12.2017, 20:40:43] Linda: That's not how anyone does it
[01.12.2017, 20:40:50] Linda: We've been swindling people
[01.12.2017, 20:40:55] Linda: I have to tell them.
[01.12.2017, 20:41:04] Roman Shpakov: What was swathed with?)
[01.12.2017, 20:41:05] Linda: Cheating is bad.
[01.12.2017, 20:41:15] Roman Shpakov: �
[01.12.2017, 20:41:32] Roman Shpakov: You have been told, everything will be done in the best way. Stay out of it.
[01.12.2017, 20:41:39] Roman Shpakov: What's up with BO?
[01.12.2017, 20:42:17] Linda: What about the response to the regulator? This is a very important question
[01.12.2017, 20:42:31] Linda: With BO, I've already had my say.
[01.12.2017, 20:42:59] Linda: We promised there would be an answer that the issue is closed.
[01.12.2017, 20:43:12] Roman Shpakov: The question is closed.
[01.12.2017, 20:43:13] Linda: Based on that, a letter went out
[01.12.2017, 20:43:21] Linda: Letter
[01.12.2017, 20:43:47] Roman Shpakov: Letter
724
[01.12.2017, 20:43:52] Roman Shpakov: Gone
[01.12.2017, 20:44:10] Linda: When is it coming to us?
[01.12.2017, 20:44:34] Roman Shpakov: As you had on Friday lef.
[01.12.2017, 20:44:47] Linda: Roman
[01.12.2017, 20:44:50] Linda: I got it.
[01.12.2017, 20:45:00] Linda: We have swung the man around.
[01.12.2017, 20:45:04] Linda: Thank you
[01.12.2017, 20:49:08] Roman Shpakov: Linda Alexandrovna, behave like a lady, not like a market trader. We value our
word, and it is important for us to have good relations with our close people. As it turns out there are few of them.
[01.12.2017, 20:50:32] Linda: �
[01.12.2017, 20:51:02] Roman Shpakov: And stop smoking a hookah when you're talking to us.
[01.12.2017, 20:51:39] +7 965 - 74888888888 - : Hookah whether ...
[01.12.2017, 20:52:04] Roman Shpakov: And will not squeeze out so much coconut.
[01.12.2017, 21:06:36] Linda: God willing, that next to you in a difficult minute were those people who now stood
Radom.
I don't know if you'll hear or not and who you think is standing next to you.
[01.12.2017, 21:07:22] Roman Shpakov: You, my lovely,
[01.12.2017, 21:07:31] +7 965 - 74888888888 - : Surely not bong, crack?
[01.12.2017, 21:07:55] Linda: You'll drive me to my grave.
[01.12.2017, 21:08:28] +7 965 - 748888888 - : We'll - all be - there one day
[01.12.2017, 21:09:04] Linda: Will your DH respond as I asked or are you not sure?
[01.12.2017, 21:26:59] Linda: Vova?
[01.12.2017, 21:29:19] +7 965 - 748888888 - : Will reply
[01.12.2017, 21:29:28] +7 965 - 74888888888 - : Or will not answer at all
[01.12.2017, 21:29:56] Linda: It's all over.
[01.12.2017, 21:30:00] Linda: It's going to be a horror
[01.12.2017, 21:30:10] Linda: What do I do now?
[01.12.2017, 21:30:38] +7 965 - 748888888 - : I eat and drink wine
[01.12.2017, 21:30:42] +7 965 - 74888888888 - : I advise - you too
[01.12.2017, 21:31:00] Linda: Vova, when did I ever say that to you?
[01.12.2017, 21:31:10] Linda: When did you have to decide something?
[01.12.2017, 21:33:27] +7 965 - 74888888888 - : By the way, there is also an option to engage in the adoption of borza
725
[01.12.2017, 21:33:44] Linda: Roman
[01.12.2017, 21:34:04] Linda: That's not the right thing to do.
[01.12.2017, 21:34:26] Linda: Why is it that when I need something from your side I do not refuse and I am always
there for you
[01.12.2017, 21:34:33] Linda: Why when I have to.
[01.12.2017, 21:34:41] Linda: I am answered I drink and eat
[01.12.2017, 21:35:13] Linda: Why should I be nervous again right now
[01.12.2017, 21:36:30] Roman Shpakov: Linda, have a rest this weekend. We will do everything.
[01.12.2017, 22:43:53] Linda: And we were already thinking of making a suvla with Apo for your arrival.
21.12.2017
[21.12.2017, 15:22:25] .: Linda, hi.
[21.12.2017, 15:22:43] .: Need someone to fill in for Kirill when he's away to do invoices
[21.12.2017, 15:23:12] Linda: Hi.
[21.12.2017, 15:23:23] Linda: There is a man in Kirill's place
[21.12.2017, 15:32:05] ... ...: Fr
[21.12.2017, 16:26:30] .: Have you decided on the trusts?
[21.12.2017, 16:26:39] .: What I wrote in the post
[21.12.2017, 16:26:51] Linda: Apo Ask
[21.12.2017, 16:40:31] .: Says you didn't say anything.
[21.12.2017, 16:40:36] .: He'll look at it now
[21.12.2017, 16:40:43] .: I'm looking forward to it
[21.12.2017, 16:41:41] Linda: Yudin let him sign it
[21.12.2017, 16:53:11] .: He's in the rf's ics
[21.12.2017, 17:05:46] Linda: So Elena Gorobets.
[21.12.2017, 17:09:00] Roman Shpakov: Let's get a little more creative.
[21.12.2017, 17:09:55] Linda: Arseny Rukhov
[21.12.2017, 17:15:51] .: Got the trusts, there are all in the IR. If on Rukhov ok, let's release on him from noa, his trust I
do not have it
[21.12.2017, 17:16:14] Linda: We will.
[21.12.2017, 17:16:18] Roman Shpakov: No
[21.12.2017, 17:16:27] Roman Shpakov: There are no rouges.
726
[21.12.2017, 21:45:44] .: Iskhakov, Golubev, Rykov
[21.12.2017, 21:45:48] .: Actual trusts
[21.12.2017, 21:45:52] .: There is an apostille
[21.12.2017, 21:46:02] .: We have to pick one
[21.12.2017, 21:47:02] +7 965 - 74888888888 - : These are also no.
[21.12.2017, 21:58:46] .: There is no one else. Gorobets, Yudin and Sobolev are lef
[21.12.2017, 21:58:54] .: Total 6 people
[21.12.2017, 22:00:21] Linda: Sobolev forget it
[21.12.2017, 22:02:37] +7 965 - 748888888 - : Sobolev
[21.12.2017, 22:09:24] Linda: No.
[21.12.2017, 22:09:29] Linda: I said forget it.
[21.12.2017, 22:09:36] Roman Shpakov: Kirill?
[21.12.2017, 22:11:04] Linda: No.
[21.12.2017, 22:12:01] .: RW will offer to sign himself)
[21.12.2017, 22:12:18] +7 965 - 74888888888 - : Little did you say
[21.12.2017, 22:12:31] Roman Shpakov: I will sign it!
[21.12.2017, 22:12:49] Linda: No.
[21.12.2017, 22:12:55] Roman Shpakov: Me!
[21.12.2017, 22:13:01] Linda: I'm not asking you.
[21.12.2017, 22:13:11] Linda: Zelimkhan, I'll find someone.
[21.12.2017, 22:13:24] .: �
[21.12.2017, 22:20:22] +7 965 - 74888888888 - : Very much in vain
[21.12.2017, 22:20:56] +7 965 - 74888888888 - : I'll also hang - assets on Kirill
[21.12.2017, 22:21:03] +7 965 - 748888888 - : A couple of charags
[21.12.2017, 22:23:38] +7 965 - 74888888888 - : And I'll put it in the pep
[21.12.2017, 22:24:01] +7 965 - 74888888888 - : Then I will close Muskaluk's entry to the country
09.01.2018
[09.01.2018, 15:50:49] Linda: We have received a letter from the Central Bank. We'll find out the details.
[09.01.2018, 15:56:10] Roman Shpakov: Ok
[09.01.2018, 15:57:00] Roman Shpakov: It came - you wanted to say.
727
[09.01.2018, 16:01:10] Linda: Yes it did.
[09.01.2018, 16:01:30] Roman Shpakov: The essence will learn, report.
[09.01.2018, 18:05:21] Roman Shpakov: Linda, you have until tonight to prepare a document on Stepanov.
[09.01.2018, 18:15:56] Linda: Zelimkhan, send everything to Apollo, he should coordinate everything with Harris .
[09.01.2018, 18:16:05] .: Ok
[09.01.2018, 18:16:09] .: Doing Forward
[09.01.2018, 18:16:40] Linda: We need to translate into English , Haris does not speak Russian or Apolo
[09.01.2018, 18:18:54] .: Xenia, Ellie, Oleshko, another employee
[09.01.2018, 18:18:58] Roman Shpakov: Everything is in English there.
[09.01.2018, 18:19:13] Roman Shpakov: Preparing a document a month is a lot.
[09.01.2018, 18:20:01] Linda: What document? I had everything ready at the end of December, all the documents and
sent the Gospels.
[09.01.2018, 18:21:01] Roman Shpakov: A draf agreement is not an agreement.
[09.01.2018, 18:22:01] Linda: Once again, I sent everything to Eugenia at the end of December. I don't understand
where the one month deadline came from.
[09.01.2018, 18:23:17] .: The letter with the docks is already with Apo
[09.01.2018, 18:24:04] Roman Shpakov: 18.12 was a meeting at which the terms were agreed. Close the question
already.
[09.01.2018, 18:24:51] Linda: Stepanov has made certain demands , we need the names of his lawyers.
[09.01.2018, 18:25:24] Roman Shpakov: Finish the document.
[09.01.2018, 18:25:38] Roman Shpakov: Zelim, from you the name of his representative in Cyprus.
[09.01.2018, 18:27:03] .: Mm - hmm, as soon as the docks are agreed, we'll know right away
[09.01.2018, 18:28:18] Linda: Haris won't agree a document, and terms without lawyers named
[09.01.2018, 18:28:58] Linda: The agreement must be signed by authorised persons as required by law:
- notarisation of the signature of an authorised person of QCCI under the supervision of Stepanov Cyprus Lawyers.
Contacts of lawyers and notary will be given afer we agree the agreement for signature.
The requirement for an apostille (afer notarisation) was also verbally indicated
[09.01.2018, 18:29:50] Roman Shpakov: Logical.
[09.01.2018, 18:32:59] Linda: Defining in the agreement the nature of the money transferred from QCCI to Stepanov
S.V., namely:
- 2 500 000 (two million five hundred thousand) US dollars - refund of the amount of money actually paid by Sergey
Vitalievich Stepanov to QB Capital CY LTD;
- 300,892 (three hundred thousand eight hundred ninety - two) US dollars 39 (thirty - nine) cents and 118,298 (one
hundred eighteen thousand two hundred ninety - eight) euros - the amount of interest for the use of Stepanov's funds
and forfeit for late repayment of funds to Stepanov Sergey Vitalievich agreed by the Parties
728
[09.01.2018, 18:33:55] Linda: This no one will sign - it is to admit that the company was conducting a complete
inefficiency, plus violating laws
[09.01.2018, 18:34:40] Roman Shpakov: Colleagues, make up what you are ready to sign.
[09.01.2018, 18:34:54] .: Change the wording so that it fits. If we disagree, we need to offer our own version
[09.01.2018, 18:35:43] Linda: I sent it to her
[09.01.2018, 18:39:06] Linda: Zelimkhan, I told both you and Eugenia, the company do not sign that Stepanov had a
brokerage account or that Stepanov was returned to the DC from the investment, he is again planking on this and we
go round and round in circles
[09.01.2018, 18:39:21] .: He sent this comment in addition. Try to incorporate it in a suitable wording
[09.01.2018, 18:39:38] Linda: Plus he wants an apostille, which is out of line.
[09.01.2018, 18:39:40] .: What won't be clear, you have to change it so it's ok, don't just say no and that's it
[09.01.2018, 18:43:51] Linda: We still don't have a lawyers name.
No lawyer would negotiate important documents in a "let's make it quick" kind of way.
Give me the name of the lawyers again, no one will put the apostrel in the same way.
[09.01.2018, 18:47:26] Roman Shpakov: Zelim, go find out the name of the lawyer.
[09.01.2018, 18:55:13] .: I'll give him a challenge.
[09.01.2018, 18:56:01] Roman Shpakov: Ok
[09.01.2018, 19:06:58] .: Apostille no, but notarisation ok?
[09.01.2018, 19:10:32] Linda: Signature and company seal, we do not practice notarisation of signatures.
[09.01.2018, 19:11:46] .: Not practising this is understandable, but is it generally possible? Without an apostille if.
[09.01.2018, 19:14:18] Linda: Signature of the authorised person and the company seal.
How about a fingerprint and a blood signature?!
[09.01.2018, 19:15:44] .: It can be offered, if he is not satisfied, he will also raise a ruckus in Cyprus
[09.01.2018, 19:16:53] Linda: Don't bully me. It's not working well for me.
[09.01.2018, 19:18:37] .: That's what the letter says, I didn't make that up
[09.01.2018, 19:34:32] Linda: So he can burn in hell.
10.01.2018
[10.01.2018, 00:02:04] Linda: Were you able to get the name of the lawyers?
Also, who will sign on his end?
Signing the document he wants and specifying in the letter is tantamount to a headshot.
It didn't suit him because he can't do anything with this agreement aferwards.
729
And by signing the contract he wants means that the company itself admits that it conducts illegal activities,
withholds customers' money plus discloses all banks where it has accounts.
[10.01.2018, 00:02:36] Linda: Also if he wants the signatories to be you why would this contract be signed in Cyprus
and in front of lawyers?
[10.01.2018, 00:04:23] Linda: There is a law that says if any professional is aware that company is providing illegal or
unlicensed activities in the republic they need to inform authorities or they will bear a fine.
[10.01.2018, 00:04:59] Roman Shpakov: He is not against zelim signing by the way.
[10.01.2018, 00:05:18] Linda: That means his lawyers this agreement then send it to our regulator and at that point I
don't even know what happens
[10.01.2018, 00:05:23] Roman Shpakov: And it's not like he's against termination. Just taking into account his edits
[10.01.2018, 00:05:36] Linda: And he'll say I didn't know anything, they did.
[10.01.2018, 00:06:03] Linda: And they'll say it's our duty under the law.
[10.01.2018, 00:06:31] Linda: His edits and there is a very clever thing that will pull us down
[10.01.2018, 00:06:38] Linda: He knows what he's doing.
[10.01.2018, 00:06:51] Linda: I just read them again just now
[10.01.2018, 00:10:18] Linda: 5) To seek, with the help of Cyprus lawyers, the disclosure of more detailed information
about QCCI LTD (QB Capital CY LTD) relating to the money I have invested, including information about transactions,
beneficiaries, and other information.
Cyprus lawyers have now done only part of the legal actions against QCCI (QB Capital CY LTD): they have established
that it did not have a CySEC licence, that it did not file accounts, and that it was not at its registered office.
[10.01.2018, 00:10:33] Linda: This is where he's bluffing or his lawyers aren't very good.
[10.01.2018, 00:10:53] Linda: The company has filed reports and our regulator has them already
[10.01.2018, 00:12:36] Linda: The company has a registered address and by law it is not required to be located or have
an office at that address .
[10.01.2018, 00:13:14] Roman Shpakov: Linda, prepare a document. You don't need to prove us right. Do what you
think is right.
[10.01.2018, 00:13:47] Linda: I want to consult with you.
[10.01.2018, 00:13:56] Linda: This man is a nutcase
[10.01.2018, 00:14:34] Linda: If we make concessions to him he will then use it against us, there is no logic in his
actions
[10.01.2018, 00:15:03] Linda: He wants Zelimkhan to sign the document
[10.01.2018, 00:15:15] Linda: So we need to be brought to Cyprus by Zelimkhan then
[10.01.2018, 00:15:21] Linda: And get the name of the lawyers
[10.01.2018, 00:15:45] Linda: "To us
[10.01.2018, 00:16:17] +7 965 - 74888888888 - : I don't think lawyers don't autumn.
[10.01.2018, 00:16:44] Linda: If it's Stepanov's lawyers they're not great
730
[10.01.2018, 00:16:55] Linda: These are not Russian lawyers
[10.01.2018, 00:57:36] +7 965 - 74888888888 - : Want to check ?
[10.01.2018, 01:37:21] Linda: 1. Why didn't the Central Bank reply to our regulator that the case was closed, even
though that was our basic agreement
2. Why will the Central Bank make it more expensive to touch our regulator?
[10.01.2018, 01:40:34] Roman Shpakov: 1. Our main agreement is sitting in jail right now.
2. Because you haven't provided us with a single letter from our DH for us to charge people. They're saying it's
complete rubbish.
Good night.
[10.01.2018, 01:47:17] Linda: 1. I don't know who's in jail but I didn't make a deal with whoever is in jail that they
would write to our regulator
2 within two days we will receive a letter from the committee investigating this case and they don't need this story in
any way.
And how can these letters be a game if your people with me confirmed the existence of letters plus if your Central
Bank does not write us letters why should our regulator write us letters. They have better things to do.
[10.01.2018, 01:48:39] Roman Shpakov: Linda, wind up the last letter. We'll talk aferwards. Good night.
[10.01.2018, 21:06:52] Linda: The letter arrived on 22/12.
[10.01.2018, 21:07:14] Linda: This one was seen on Monday.
[10.01.2018, 21:07:22] Linda: CB sent a reply 22
[10.01.2018, 21:08:53] Linda: It was the last day when there was a deadline.instead of the cb's response that the case is
closed, they sent that the case is not closed, that the company is conducting investment activity.
[10.01.2018, 21:17:12] Roman Shpakov: Prepare the necessary answers and put it all on the Board.
[10.01.2018, 21:19:34] Roman Shpakov: And we need a letter from the Central Bank, because it all smacks of bullshit.
[10.01.2018, 21:19:41] Roman Shpakov: Our man confirmed.
[10.01.2018, 21:24:14] Linda: Let's wait for the fines, plus personally problems I have so it doesn't give away the cunt.
Let's do it this way.
I don't give a damn about this man, I know I was asked today where the letter from the Central Bank is that the case is
closed. That's what we promised. That's what Vova promised.
I will not get a letter from the Central Bank, let your people get it, they have connections in the Central Bank, not me. I
got our letters even though it is absolutely confidential information and Haris should not have disclosed it.
[10.01.2018, 21:25:00] Roman Shpakov: But our people say that they did not send letters.
[10.01.2018, 21:25:17] Linda: Roman
[10.01.2018, 21:25:19] Linda: 22
[10.01.2018, 21:25:20] Linda: The Letter
731
[10.01.2018, 21:25:23] Linda: Sent.
[10.01.2018, 21:25:29] Linda: Not the same as usual.
[10.01.2018, 21:25:33] Linda: Not 10 pages.
[10.01.2018, 21:25:39] Roman Shpakov: Which one?
[10.01.2018, 21:25:45] Linda: Notification
[10.01.2018, 21:25:57] Roman Shpakov: So and dopizda.
[10.01.2018, 21:26:02] Linda: That the information is not enough
[10.01.2018, 21:26:14] Linda: That the company is conducting investing activities
[10.01.2018, 21:26:14] Roman Shpakov: Ok
[10.01.2018, 21:26:17] Roman Shpakov: Ok
[10.01.2018, 21:26:25] Roman Shpakov: We heard you.
[10.01.2018, 21:28:21] Linda: I know I've been heard.
[10.01.2018, 21:28:36] Linda: The most important thing is that those people who need to be will not be hurt.
[10.01.2018, 21:28:50] Linda: And those who don't like Cyprus and all that is here I think are very happy with it
[10.01.2018, 21:29:34] Roman Shpakov: Ok
30.07.2018
[30.07.2018, 15:16:03] Roman Shpakov: Linda, what about the bills for Vladimir's client?
[30.07.2018, 15:17:47] +7 965 - 74888888888 - : I asked them on Friday to expedite them, I think she will try to do her -
best from her
[30.07.2018, 15:26:23] Linda: RV, anything I can do I will do, thank you.
[30.07.2018, 15:35:00] Linda: Who are the director and shareholder of Advisory ?
[30.07.2018, 15:50:48] Linda: Who is the ultimate shareholder, who is the director
[30.07.2018, 15:51:10] Linda: Zelimkhan?
[30.07.2018, 15:53:47] Roman Shpakov: Me
[30.07.2018, 15:53:56] Roman Shpakov: In six days it will not be me.
[30.07.2018, 15:54:19] Linda: What are you?
[30.07.2018, 15:54:23] Linda: On your own are you?
[30.07.2018, 15:54:46] Linda: Roman
[30.07.2018, 15:55:17] Roman Shpakov: Through AO.
[30.07.2018, 15:56:10] Linda: Who is the owner of the JSC?
732
[30.07.2018, 15:56:39] Roman Shpakov: Me
[30.07.2018, 15:57:09] Linda: This company is not on my list of your holdings.
[30.07.2018, 15:57:14] Linda: When was it created?
[30.07.2018, 15:57:54] Roman Shpakov: Add?)
[30.07.2018, 15:58:01] Roman Shpakov: Check with zhenya.
[30.07.2018, 15:58:25] Linda: And who gave you permission to put this company on you without approval?
[30.07.2018, 15:58:43] Roman Shpakov: Agreements with whom?
[30.07.2018, 15:59:19] Linda: With people who are looking at all of your structures and making sure that there are no
consequences.
[30.07.2018, 16:01:43] Roman Shpakov: For rf structures you do not look
[30.07.2018, 16:02:33] Linda: Roman
[30.07.2018, 16:04:21] Linda: Anything that involves you RF or timbahtu we're watching.
The RF should have specified
1. Can I put you
2. What is the company's activity
3. The real question is why they put you there.
[30.07.2018, 16:04:38] Linda: What's on this company ? Is it empty ?
[30.07.2018, 16:06:50] Roman Shpakov: Yep
[30.07.2018, 16:07:23] Linda: Ok.
[30.07.2018, 16:07:28] +7 965 - 7488888 - : �
[30.07.2018, 16:09:57] Linda: I'm glad you're having fun.
[30.07.2018, 16:25:24] Linda: 1. We signed a letter stating that you know nothing about companies K 1 and K 2.
2. A company is created which you own 100% and all K1 assignment contracts are assigned to it.
We shot ourselves in the head.
[30.07.2018, 16:27:51] Roman Shpakov: 2. No
[30.07.2018, 16:28:36] Roman Shpakov: Nothing was hung on her.
[30.07.2018, 16:33:19] Linda: It's got all the assignment contracts on it.
[30.07.2018, 16:33:55] Roman Shpakov: You are clearly mistaken. We do not have such information.
[30.07.2018, 16:35:19] Linda: Okay.
[30.07.2018, 16:35:41] Linda: The important thing is that you're not wrong.
[30.07.2018, 16:37:00] Roman Shpakov: That's the main thing for you.
[30.07.2018, 16:49:29] Linda: 1 on this company of assignment contracts.
2. Contracts of assignment that were concluded afer the official liquidation of K1.
733
3. Zelimkhan signed an order at the embassy to liquidate K1, and withdrew from the EC shareholders
4. the clients signed contracts with K1 and signed with K1, and sent DS to K1 ( which has already been liquidated)
5. Clients separately signed a power of attorney with Advisory. In this power of attorney the clients authorised
Advisory to act within the framework of the agreement with K1, it is a direct fact that everything that K1 swings has to
do with you.
We can thank people for such a beautiful scheme. It took a lot of effort to do this.
[30.07.2018, 16:50:02] Roman Shpakov: Ok
The correspondence of the participants of the "PND" group, which included "Roman Shpakov" (subscriber number +7
- 905 - 735 - 55 - 88), "Evgeniya Rossieva" (subscriber number +7 - 985 - 173 - 43 - 21), "Munayev" (subscriber number
+7 - 903 - 100 - 41 - 84), was found and examined; in addition, a subscriber with the phone number +7 - 965 - 748 - 88 -
88 used by the accused Pakhomov V. S. was a participant of the group.S. In the course of the examination,
correspondence was established, including the following:
[19.05.2018, 16:56:50] IPA: Messages and calls are protected by end - to - end encryption. Third parties, including
WhatsApp, cannot read or listen to them.
[19.05.2018, 16:56:50] Roman Shpakov created( - a) group "PND"
[19.05.2018, 16:56:50] Roman Shpakov added you
[19.05.2018, 16:58:12] Roman Shpakov: The most important question that can be:
1. What was the contractual relationship with S, since he decided to write 159?
2. What was the bottom line?
3. How many more such treaties are there?
4. What about Cyprus?
[19.05.2018, 17:01:19] Evgeniya Rossieva: 1. We describe contractual relations in the same logic as for the BR. The
main contractual relationship with the client was with a Cypriot company - he transferred there, received from it (he
himself brought payments and statements to the court), there is not a single payment to IK or from IK.
[19.05.2018, 17:02:10] Evgeniya Rossieva: Why 159 - it is convenient, everyone writes on it. It is expensive to sue
Cyprus, and we are at hand.
[19.05.2018, 17:02:23] Roman Shpakov: 1.1. Did you attract there?
1.2 Who is the contact person?
1.3. Is that the cap?
1.4 Licences?
[19.05.2018, 17:03:32] Evgenia Rossieva: Moreover, the Moscow Court of Appeal, removing interim measures (seizure
of ds on the account) recognised that Ik had nothing to do with it and the security cannot be imposed!!!! What a
lawsuit if in the middle of the process the court of second instance recognises that Ik is not actually a defendant.
[19.05.2018, 17:13:32] Roman Shpakov: 1.5. Why did he decide to sue you and not Cyprus?
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[19.05.2018, 17:15:00] Evgeniya Rossieva: 1. We did not attract, we offered investment counselling service when clients
placed funds with foreign brokers, etc. The client was free to place ds, chose himself, there are many such companies,
from us - counselling.
2. There was no permanent contact person, they communicated with the person who was currently performing the
functions, no records were kept, no correspondence was kept.
The foreign company where the client deposited the loan, in the absence of a licence to carry out operations,
delegated the execution of the relevant activities to a company with a licence, which was subject to a clause in the
agreement with the client. The foreign company where the client deposited the funds, in the absence of a licence to
carry out operations, delegated the execution of the relevant activities to a company with a licence, which was
specified in the agreement with the client.
[19.05.2018, 17:16:54] Eugenia Rossieva: Because we are close, you can use the scheme with the game with
jurisdiction (which the court itself in the decision made a reservation - that the preliminary contract of guarantee is
invalid and in fact initially the claim was considered in an improper court). Such tricks will not work abroad, there are
high penalties for deception in court.
[19.05.2018, 17:17:22] Roman Shpakov: 1.2. There was no contact person, and we were in contact with the client. We
do not care through whom he placed.
Companies without licences, without a top broker just wouldn't open a bank account. This is our purely personal
opinion
[19.05.2018, 17:17:23] .: Here we can say that there are such companies that conduct aml and compliance, then send
to the top brokers, where the client already has a trading account and trades. What exactly was the structure at kep
we can't confirm
[19.05.2018, 17:17:40] Roman Shpakov: Ok
[19.05.2018, 17:18:15] Roman Shpakov: We do not know whether it is a cap or not. We only said in court: go where you
sent.
[19.05.2018, 17:18:38] Evgeniya Rossieva: Yes. Different companies. The client placing 2 million dollars and having the
opportunity to hire an office of lawyers probably chose for himself not on nluposti
[19.05.2018, 17:19:28] Roman Shpakov: Exactly. It is unlikely that the person who wrote to all instances of professional
blots did not check everything at the very beginning.
[19.05.2018, 17:19:54] Eugenia Rossieva: Yes, on the old lady pensioner clearly )
[19.05.2018, 17:21:04] Roman Shpakov: Given the client's background: alpha group, he clearly knew what he was
doing. Also to a certain extent it looks like a competitive struggle, as we have better RF management results.
[19.05.2018, 17:21:49] Evgeniya Rossieva: We need to decide on the contracts (depends on birch): we are stumped by
cession or reorganisation. Cession is more reliable - they gave it to us and no, we don't have it. Reorganisation is
about to pop up.
[19.05.2018, 17:22:53] Eugenia Rossieva: Yes by the way, you can mention it.personal motive - competition for a
lawsuit - complaint to law enforcement is just understandable.
[19.05.2018, 17:23:03] Roman Shpakov: Cession. Transferred to a rent. Rent to somewhere else. In the process of
transfer, 95% dissolved.
[19.05.2018, 17:23:31] Evgeniya Rossieva: Ok. Yes, the cession is truer, justifies why we haven't had any documents for
a long time.
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[19.05.2018, 17:23:35] Roman Shpakov: I should say: we are not implying anything, but very similar.
[19.05.2018, 17:23:49] Eugenia Rossieva: Yes)))
[19.05.2018, 17:25:09] Roman Shpakov: We were asked by the Central Bank to remove this story, we immediately
fulfilled their request.
They carried out an inspection, and on this issue too, and found no violations, nor did they find anything strange with
the assignment agreements. They said: "Take it away, everyone comes to the RF market anyway.
[19.05.2018, 17:27:36] Roman Shpakov: Throughout the whole situation with Stepanov, the Central Bank was aware of
it and assisted us as best it could. Especially in the matter of lifing interim measures.
We know that something from the Central Bank sent information to the prosecutor's office, asking it to check whether
we are doing nonsense here. We proudly reply: the largest broker in the Central Bank of Russia is not engaged in
nonsense. We are only preparing a platform for attracting foreign investors.
[19.05.2018, 17:29:27] Eugenia Rossieva: The client wrote a complaint to the Central Bank, the Central Bank easily
obtained information from us, we passed everything that we tell you now and the Central Bank had no claims. No
administrative cases were not voshchazhdala orders to eliminate violations were not issued due to the lack of the
latter
[19.05.2018, 17:36:34] +7 965 - 74888888888 - : And who is the personnel officer ?
[19.05.2018, 17:36:34] +7 965 - 74888888888 - : If they request agency staffing etc
[19.05.2018, 17:37:11] Eugenia Rossieva: Requested from whom?
[19.05.2018, 17:38:21] Eugenia Rossieva: Cadres in Ik - libutina
[19.05.2018, 17:38:34] Evgeniya Rossieva: Ik physicists have no agents
[19.05.2018, 17:41:35] Eugenia Rossieva: There are 26 people on the staff in IK
[19.05.2018, 17:43:00] Eugenia Rossieva: By the way the corner offices in this wing - IK, yudin, padalko and others
should sit there, as was the case in the last weeks of the tsb
[19.05.2018, 17:45:39] Roman Shpakov: Can sit in the edweiserie.
[19.05.2018, 17:46:21] Roman Shpakov: If you ask the staff of the edwiseri, there are 100 people. How should we deal
with them?
[19.05.2018, 17:47:29] Eugenia Rossieva: According to the last state that I have if accurate: Investment 47, Edweiseri -
24
[19.05.2018, 17:47:42] Evgeniya Rossieva: Consulting 9
[19.05.2018, 17:48:00] Eugenia Rossieva: Those they kolkhoz on 100 approximately going)
[19.05.2018, 17:49:39] Roman Shpakov: I see.
[19.05.2018, 17:49:59] Eugenia Rossieva: Investment is advisors, agents to find clients. What prevents us from
communicating this? There is a staffing there are people with responsibilities, there is a business direction.
[19.05.2018, 17:51:22] Eugenia Rossieva: Most of them are not at their workplaces tk looking for clients.
Correspondence with the contact "Ruslan Spinka", subscriber number +7 - 967 - 186 - 60 - 39, with whom
736
14.05.2020
[14.05.2020, 12:06:31] Ruslan Spinka: Good afernoon!
Can we expect something this week, please?
[14.05.2020, 12:08:30 pm] .: Afernoon
[14.05.2020, 12:08:33 pm] .: Mm - hmm, clarified.
[14.05.2020, 13:28:54] .: Do I understand correctly that the final calculation was checked by you + Julia? And the rfc %
part is calculated by Madina
[14.05.2020, 13:52:44] Ruslan Spinka: All calculations are made by Angelina on the basis of data received from MIDL +
FS + RO + Korzh + me, Yulia checked. If there are doubts about specific operations - let me give comments
[14.05.2020, 14:15:55] Ruslan Spinka: On Kushnir (getting BP) - any update , when can we talk?
[14.05.2020, 14:49:13] Ruslan Spinka: Evgeny Gennadyevich Dianov
004696 , portfolio balance as of 31.03 - 858 243, with the initial investment of 1 000 000 $. I.e. the loss on the portfolio
is 140 000 $. However, we are talking about the second sub - account, where the primary invested 200 000 $ (REIT),
according to the report at the end of March the balance is 61 666, thus we could not hold the conditions of ID from our
side, where the drawdown of the sub - account more than 2 times, and in this instrument invested as the most
conservative with a possible drawdown of no more than 15%, we look at us as a pyramid scheme without qualified
professionals who could fix the loss, or at least earn on the drawdown.
[14.05.2020, 15:03:30] Ruslan Spinka: To keep the client, please allocate BP in the amount of 400k. Personally ready to
discuss in detail.
[14.05.2020, 16:53:37] Ruslan Spinka: It is extremely important for us to agree on further actions in one form or
another, such wording will not be enough to avoid conflict in the work
[14.05.2020, 16:54:34] Ruslan Spinka: please update if possible. Today we had an unforeseen dispatch of 3.5m to WOD
for 3 years, so the chief must definitely be in good spirits
[14.05.2020, 17:15:31] Ruslan Spinka: 1. Novoseltsev - ok
2. Evenko - ok
3. Porkhachev - I will send you additional information, the amount is quite small, but the risks are high.
4. Matsov's friend is already out. We can sit down at the negotiating table
[14.05.2020, 17:41:14] .: I'm on the phone.
[14.05.2020, 17:41:18] .: So
[14.05.2020, 17:44:52] .: Ok.
[14.05.2020, 17:45:43] .: I understand, so far so tight
[14.05.2020, 17:46:00] .: I'll try to bring it up again tomorrow.
[14.05.2020, 17:54:47] .: Talked, from next week there will be an issue
[14.05.2020, 18:26:38] Ruslan Spinka: Can we call from 19:30 to 20:00? Right now it's meeting afer meeting
737
[14.05.2020, 18:27:36] Ruslan Spinka: At least get 500 - 1000 tomorrow so that the most acute motivational things I
start to close. And the guys will calm down and the pace will pick up. Although it might be 15 - 25% of the whole
amount.
[14.05.2020, 19:03:41] Ruslan Spinka: ?
[14.05.2020, 19:22:02] .: At 20:00, yes.
[14.05.2020, 19:22:22] .: I'll skip Rv on pon then, I don't think I will tomorrow
[14.05.2020, 20:09:23] Ruslan Spinka: Calling in 10 minutes? Completing the file with Volodya
[14.05.2020, 20:23:24] .: I'll dial you in.
[14.05.2020, 20:23:30] .: I'm just finishing up a call.
[14.05.2020, 20:35:55] Ruslan Spinka: thanks, I'm waiting
[14.05.2020, 21:35:41] Ruslan Spinka: I have spoken to Andrei - the client will have to give it to him today.
[14.05.2020, 21:36:57] Ruslan Spinka: It's also important:
Next week the fixes will start - there's still 4m+ to go. If we don't do something this week, we'll get another August -
September 19.
[14.05.2020, 21:37:52] Ruslan Spinka: The current positive mood should be supported. We count on your participation
[14.05.2020, 21:46:31] .: Ok, tomorrow we will try to proforce the issue, remind me when the three of us will be there
[14.05.2020, 21:47:47] Ruslan Spinka: find an opportunity to do it please before this meeting, otherwise the argument
will be *"it's already evening, why did you say so late "* ☹
[14.05.2020, 21:48:04] .: So not tonight.
[14.05.2020, 21:48:07] .: It has to be daytime
[14.05.2020, 21:48:11] .: Before our meeting.
[14.05.2020, 21:48:24] .: By 15:30 somewhere.
[14.05.2020, 21:55:47] Ruslan Spinka: Questions with the chief:
1. Kushnir - BP 300k+300k
2. Dianov - BP 400k
3. Shishanova - exit roadmap
4. Matsov - a friend already out of prison
5. *comics* - need something on Friday
[14.08.2020, 09:10:45] Ruslan Spinka: Tuesday 14.00 ok?
[14.08.2020, 09:10:56] Ruslan Spinka: Good morning!
Is the interview with Anton okay?
[14.08.2020, 10:27:03] .: Salute
[14.08.2020, 10:27:04] .: Yes
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[14.08.2020, 11:30:47] Ruslan Spinka: We have a potentially very problematic client Dianov, you are aware of him. Can
we direct him a little over 3k dols on the dividend bank? He wrote an instruction a couple of weeks ago
[14.08.2020, 12:04:38] .: I think so, pon ask me for confirmation
[14.08.2020, 17:35:12] Ruslan Spinka: What time can we start?
[14.08.2020, 17:35:18] .: Now.
[14.08.2020, 17:36:06] Ruslan Spinka: cegth? 10 vbyen njulf b e dfc? [jhjij&
[14.08.2020, 17:36:06] Ruslan Spinka: super, 10 minutes and you have it, ok?
[14.08.2020, 17:36:15] .: Ess.
[14.08.2020, 17:40:45] Ruslan Spinka: confirm on post please
[14.08.2020, 17:43:15] .: What's the name?
[14.08.2020, 17:43:36] Ruslan Spinka: entrance on Sunday
[14.08.2020, 17:43:55] .: I think it already has
[14.08.2020, 17:43:58] .: Herziku
[14.08.2020, 17:44:18] Ruslan Spinka: yeah
17.08.2020
[17.08.2020, 12:57:25] .: Good
By the evening briefing, offer the Mikhailov option. Plus open up a job opening today
[17.08.2020, 12:58:10] .: And by what actions expected to discuss Linda on the prelims, we need options.
All right, I will.
[17.08.2020, 13:09:48] Ruslan Spinka: We discussed everything on Friday, do we need to agree with you separately?
[17.08.2020, 13:29:52] .: Well, it'll bring you up to speed.
[17.08.2020, 14:56:25] .: 78kk attracted as of Friday, according to Ik
[17.08.2020, 14:56:31] .: Does it add up for you?
[17.08.2020, 15:01:03] Ruslan Spinka: we have less on Thursday's statement
[17.08.2020, 16:05:29] Ruslan Spinka: You asked me to remind you about the withdrawal of 3.5k Dianov on the bank.
Will we be able to in a short time?
[17.08.2020, 17:59:12] Ruslan Spinka: Gathering at your place?
[17.08.2020, 18:15:44] .: Come on
[17.08.2020, 20:34:27] .: Could you please clarify the name of the person who helps with the custodian?
[17.08.2020, 20:34:56] .: Remember this bloke? Customer grandpa yoo who is insane
[17.08.2020, 21:25:12] Ruslan Spinka: we have several of these, please specify. Can't identify it that way
739
[17.08.2020, 21:25:42] .: In Naufor, he wrote
[17.08.2020, 21:25:47] .: I forwarded it to you.
[17.08.2020, 21:26:13] Ruslan Spinka: the most recent one that all - all partners wrote to?
[17.08.2020, 21:26:44] .: No, it's the penultimate one
[17.08.2020, 21:27:09] .: Was following. Noaoseltsev I think
[17.08.2020, 21:28:30] Ruslan Spinka: Of the grandfathers of crazy there are:
Novoseltsev
Kondratiev (question closed)
Muzharovsky (question closed)
[17.08.2020, 21:28:44] .: the first one
[17.08.2020, 21:29:23] Ruslan Spinka: do you need lawyer/assistant details on it?
[17.08.2020, 21:30:08] .: Yes
[17.08.2020, 21:30:14] .: From Custodian.
[17.08.2020, 21:30:18] .: He came with him
[17.08.2020, 21:30:28] .: And communicated with ours
[17.08.2020, 21:30:44] Ruslan Spinka: ok
[17.08.2020, 23:06:43] Ruslan Spinka: Couldn't find any data on him
18.08.2020
Please confirm the meeting for today at 14:00 with Anton Shkrut.
[18.08.2020, 11:07:06] .: Hi.
[18.08.2020, 11:07:09] .: 14 ok
[18.08.2020, 11:07:31] Ruslan Spinka: and a question on Dianov, sending him a small amount of money from SIM, can
we do it promptly!
[18.08.2020, 12:09:55] .: 100% Rv has not confirmed, but it is possible. Consolidate through Mxlennikov, let him
designate within the general lists to whom how much
[18.08.2020, 12:10:26] Ruslan Spinka: did you discuss that there the amount is about 5k total?
[18.08.2020, 12:10:46 pm] .: Mm - hmm.
[18.08.2020, 12:11:34] Ruslan Spinka: can the lists be sent now?
[18.08.2020, 12:11:43] .: Mm - hmm.
[18.08.2020, 12:12:09] .: In pp put this week 1kk r per client with my surname.
[18.08.2020, 12:15:24] Ruslan Spinka: Okay.
740
[18.08.2020, 12:36:15] .: ipo procedure - h discussed with Rv, there are edits and additions
[18.08.2020, 12:36:40] .: Did Javid do that file? How are we going to contribute?
[18.08.2020, 12:54:57] Ruslan Spinka: we are together with Javid.
[18.08.2020, 12:55:08] Ruslan Spinka: Will you give me the introductions personally?
[18.08.2020, 12:55:12] Ruslan Spinka: or in writing?
[18.08.2020, 12:59:25] .: Let's do it in person
[18.08.2020, 12:59:32] .: 15 minutes should be allotted today.
[18.08.2020, 13:33:35] Ruslan Spinka: you can at what time?
[18.08.2020, 13:54:04] .: В 15:40
[18.08.2020, 13:54:06] .: В 16:40
[18.08.2020, 14:04:13] Ruslan Spinka: Are you ready?
[18.08.2020, 14:05:26] .: Es
[18.08.2020, 14:05:35] Ruslan Spinka: Coming for you!
[18.08.2020, 15:41:28] .: Remind me about the conclusions, too.
[18.08.2020, 15:47:10] Ruslan Spinka: ok
[18.08.2020, 16:43:25] Ruslan Spinka: may I join you?
[18.08.2020, 16:45:24] .: In 5 min.
[18.08.2020, 16:52:17] .: Over
[18.08.2020, 18:18:10] .: Tural's mail is better on what domain?
[18.08.2020, 18:50:59] Ruslan Spinka: What do you think if on WL?
[18.08.2020, 20:09:21] .: You can.
[18.08.2020, 20:15:16] Ruslan Spinka: Have you sent the list on small outputs to RV yet?
[18.08.2020, 20:19:23] .: I'm not.
[18.08.2020, 20:19:31] .: You said Masdennikov will send
[18.08.2020, 20:32:38] Ruslan Spinka: Did you pick up the letter from him?
[18.08.2020, 20:37:14] .: I haven't watched it yet.
[18.08.2020, 20:37:37] .: Need me? If there's not much there and you're ok, send a rv
16.09.2020
[16.09.2020, 09:24:25] Ruslan Spinka: Good morning!
[16.09.2020, 09:24:34] Ruslan Spinka: You asked me to remind you in the morning:
1. Set of documents on transfer from SIM to RIF - current status
741
2. Status on BN transfers
3. Dianov - meeting with the client
[16.09.2020, 12:17:57] .: Good, tex
[16.09.2020, 12:19:07] .: 1 have already started to prepare, waiting for the deadlines for preparation and payment of
infrastructural builds, I will name them to you
2 there is a possibility on this ned, but not confirmed yet
3 so far only Mikhailov comes to mind
[16.09.2020, 13:13:42] Ruslan Spinka: 1. When do you have a status update ?
2. When do you have a status update ?
3. So you're definitely not?
[16.09.2020, 13:40:15] .: 3 definitely not
[16.09.2020, 13:40:22] .: 1 - 2 I'll try to give another segment an update
[16.09.2020, 14:16:43] .: Ephraim to Alexander
[16.09.2020, 14:16:52] .: Whose client? And what is the status on it now?
[16.09.2020, 15:19:15] Ruslan Spinka: I'll check now
[16.09.2020, 16:06:29] Ruslan Spinka: He won't re - sign the agreement, thinks we are frauds and has been out of sight
for a month now
Doesn't call or write
The re - signing could not be influenced even afer a joint meeting with Rossieva.
[16.09.2020, 16:06:37] Ruslan Spinka: ☝
[16.09.2020, 16:10:32] .: To lawyers outside turned, wants further to the authorities
[16.09.2020, 16:10:40] .: We'll have to discuss it separately
[16.09.2020, 17:08:13] Ruslan Spinka: ok. ready to discuss
[16.09.2020, 20:50:15] .: On this client ask you in the morning to write a detailed letter with the status, contract,
tranche amounts, etc., send it to Linda and a copy to me, add your comments.
[16.09.2020, 20:50:23] .: It would be nice to have everything before lunchtime
Correspondence with the contact "Roman Shpakov", subscriber number +7 - 905 - 735 - 55 - 88, with whom
07.11.2017
[07.11.2017, 22:12:15] Roman Shpakov: the Central Bank will send 3 - 4 more letters to Cyprus)?
[07.11.2017, 22:12:45] .: Yes, Stas said no more)))))
[07.11.2017, 22:13:11] .: 3 - 4 will send it, see that it's a dead end and drop out)
742
[07.11.2017, 22:13:22] .: They have no authority in Cyprus anyway
[07.11.2017, 22:14:28] Roman Shpakov: We already had 2 enough. Take the issue under control.
[07.11.2017, 22:21:23] .: When meeting with the new comrade I will discuss, the orientation for the weekend
immediately upon his return. If through him is not fast, then back to the new assistant P, if he is not fast either, I will
ask Paul if he can with Yudaeva to set up a meeting
[07.11.2017, 22:21:40] .: I'll ask more precisely tomorrow, and we'll see about the appointment
[07.11.2017, 22:22:23] Roman Shpakov: The issue should be closed this week
[07.11.2017, 22:25:45] .: On this force is directed at the main issue, on this non - Cyprus of the real only meetings and
agreements, people will not take action, we have already prioritised, now it will be necessary to correct them.
[07.11.2017, 22:25:56] .: So all in parallel then I will launch tomorrow
[07.11.2017, 22:29:26] Roman Shpakov: Cyprus is an important issue. We should not be disturbed there.
[07.11.2017, 23:55:00] Roman Shpakov: Close the Cyprus issue this week.
31.08.2020
[31.08.2020, 11:16:45] .: On Linda, the main thing is to retain her compliance powers as one of the directors
[31.08.2020, 11:16:56] .: Because she thinks you're going to fire her.)
[31.08.2020, 11:18:26] Roman Shpakov: What a good idea)
[31.08.2020, 11:31:14] Roman Shpakov: no audio file available
[31.08.2020, 11:43:18] .: shaban automation ok
[31.08.2020, 14:09:29] .: With Argento's tranche 20k to America? Masl, Burdygin, Dianov, Bondar - 4 small tranches
[31.08.2020, 14:09:47] .: L said will do. They won't write it off on G and kaartal maintenance
[31.08.2020, 14:13:48] Roman Shpakov: From this no. This week will be no kitty about the trenches, we'll do
everything.
[31.08.2020, 14:14:12] Roman Shpakov: And stop discussing in correspondence.
[31.08.2020, 16:54:12] Roman Shpakov: no audio file available
[31.08.2020, 16:59:42] .: Ok.
[31.08.2020, 19:01:41] .: shall we give the comms a dp today? L confirmed bts.
[31.08.2020, 19:03:26] Roman Shpakov: We'll give them 3. They can direct it to whatever they want. Want
commissions, want you
[31.08.2020, 19:04:15] .: Ok.
Correspondence with the contact "Yuri Orlov", subscriber number +7 - 926 - 308 - 82 - 26, with whom correspondence
was carried out, including the following content, was found and examined:
743
08.06.2018
[08.06.2018, 15:58:04] Yuri Orlov: Zelimkhan Visaitovich, do I generate reports from WL?
[08.06.2018, 16:23:51] .: Yes
[08.06.2018, 16:23:57] .: Show the template
[08.06.2018, 16:25:14] Yuri Orlov: The address would... new. The whole line
[08.06.2018, 16:31:24] .: What is the address?
[08.06.2018, 16:32:29] Yuri Orlov: The page poval has the company name and address, mail, phone number
[08.06.2018, 16:32:33] Yuri Orlov: *basement
[08.06.2018, 16:33:17] .: Not writing
[08.06.2018, 16:33:27] Yuri Orlov: Just the logo?
[08.06.2018, 16:33:33] .: Yes
[08.06.2018, 16:33:43] Yuri Orlov: A couple of minutes then - I'll send you an example
[08.06.2018, 18:59:50] Yuri Orlov: I would like a template confirmation... Or I can't start generating reports
[08.06.2018, 19:00:28] .: The letter W
[08.06.2018, 19:00:38] .: Unsigned by wightlake
[08.06.2018, 19:00:51] Yuri Orlov: Ok
[08.06.2018, 19:01:00] .: I'll talk to Rv about it.
[08.06.2018, 19:01:01] .: Sec.
12.09.2018
[12.09.2018, 13:23:33] ... : Reply to Linda on vl reports
[12.09.2018, 13:25:29] Yuri Orlov: According to reports - still being put together
[12.09.2018, 13:37:15] .: And also a list of four columns: first name, last name, number, date. All in Latin. It's by xyai
[12.09.2018, 13:38:06] Yuri Orlov: The list?
[12.09.2018, 13:38:31] .: What was discussed with Roman
[12.09.2018, 14:47:39] .: Ask you to send me by the end of the week all the clients entered this year in the SRM for
cssiai/vl. Also all clients in fensi ik and uk for all time
[12.09.2018, 14:47:43] .: Fio
Mail
[12.09.2018, 14:47:50] .: Everyone, 2 columns
[12.09.2018, 15:43:27] Yuri Orlov: Ok
[12.09.2018, 17:00:27] Yuri Orlov: Zelimkhan Visaitovich, please confirm the signature of the wiper
[12.09.2018, 17:00:33] Yuri Orlov: *dopnika
744
13.03.2019
[13.03.2019, 16:39:41] .: Turn off networking
[13.03.2019, 16:39:47] .: Put in the mail
[13.03.2019, 16:39:53] .: But don't delete it
[13.03.2019, 16:40:02] Yuri Orlov: Working
[13.03.2019, 16:40:05] Yuri Orlov: Already have
[13.03.2019, 16:40:07] .: Hard drives in the lock
[13.03.2019, 16:40:17] .: Hard drives of all comps
[13.03.2019, 16:40:20] Yuri Orlov: Ok
[13.03.2019, 16:40:26] .: first hp everything
[13.03.2019, 16:40:30] .: Then there are the monoblocks
[13.03.2019, 17:14:30] .: When you open my comp, the login with phio pops up
[13.03.2019, 17:14:52] .: Need to remove asap since I'm not in qbf
[13.03.2019, 17:25:39] Yuri Orlov: It's not fast
[13.03.2019, 17:25:43] Yuri Orlov: But I'll give it a shot
[13.03.2019, 17:34:58] .: On 12, the search began
[13.03.2019, 17:35:04] .: How is your process going?
[13.03.2019, 17:35:27] Yuri Orlov: Switch off the most basic thing
[13.03.2019, 17:35:57] .: no image available
[13.03.2019, 17:36:07] .: That's the bottom lef, there shouldn't be a phio on it
[13.03.2019, 17:36:14] Yuri Orlov: Yeaaaah
[13.03.2019, 17:36:22] .: Or lock the entire disc
[13.03.2019, 17:36:26] .: You can't give them the information
[13.03.2019, 17:36:36] Yuri Orlov: Give someone else's name
[13.03.2019, 17:36:41] Yuri Orlov: Whom you can
[13.03.2019, 17:36:44] Yuri Orlov: Matyukhin
[13.03.2019, 17:36:51] .: No
[13.03.2019, 17:36:54] .: Mmm.
[13.03.2019, 17:36:56] .
[13.03.2019, 17:37:04] .: Ryabokon.
[13.03.2019, 17:38:45] Yuri Orlov: Ok
745
[13.03.2019, 17:38:59] .: With skma info on the disc what to do?
[13.03.2019, 17:39:20] Yuri Orlov: I can start ciphering
[13.03.2019, 17:39:35] .: Take action
[13.03.2019, 17:43:14] .: If the hard ones are taken away, will the letters be seen aferwards?
[13.03.2019, 17:43:25] .: I'm talking about employees
[13.03.2019, 17:52:59] .: Any luck?
[13.03.2019, 17:53:14] Yuri Orlov: Working
[13.03.2019, 17:53:19] Yuri Orlov: Is the comp switched on?
[13.03.2019, 17:53:40] .: Yes
[13.03.2019, 17:58:56] Yuri Orlov: I don't see him online
[13.03.2019, 17:58:58] Yuri Orlov: RV I see it
[13.03.2019, 17:59:01] Yuri Orlov: Yours is not
[13.03.2019, 17:59:35] .: Momentum
[13.03.2019, 18:03:00] .: Check it out
[13.03.2019, 18:04:03] .: yes/no?
[13.03.2019, 18:04:49] Yuri Orlov: Yea
[13.03.2019, 18:05:47] Yuri Orlov: Gotcha
[13.03.2019, 18:05:51] Yuri Orlov: On your comp
[13.03.2019, 18:09:43] ... Cipher
[13.03.2019, 18:09:46] .: Or delete it
[13.03.2019, 18:09:49] .: But with backup
[13.03.2019, 18:09:53] Yuri Orlov: no image available
[13.03.2019, 18:10:04] .: Already gud)
[13.03.2019, 18:11:12] Yuri Orlov: And you are not in the building?
[13.03.2019, 18:12:38] .: Here
[13.03.2019, 18:13:06] .: rv same thing
[13.03.2019, 18:13:10] .: Put Zaitsev on him
[13.03.2019, 18:13:30] Yuri Orlov: Can you come up in TootoBen? Or are you upstairs?
[13.03.2019, 18:14:00] .: I'm on 9
[13.03.2019, 18:14:07] .: Vladimir's comp too
[13.03.2019, 18:14:41] .: Him Zaitsev Evgeniya
[13.03.2019, 18:15:06] Yuri Orlov: The opposite will happen
746
[13.03.2019, 18:15:41] .: Ok
[13.03.2019, 18:23:15] Yuri Orlov: On RV and VS a little bit to wait - guys work with CRM
[13.03.2019, 18:23:42] .: OK
[13.03.2019, 18:33:43] Yuri Orlov: Closing the main thing
[13.03.2019, 18:33:52] Yuri Orlov: The only things that remain are those on working machines
[13.03.2019, 18:37:36] .: What are working machines?
[13.03.2019, 18:37:45] Yuri Orlov: Employee computers
[13.03.2019, 18:37:59] .: Ok, got it
[13.03.2019, 18:38:06] .: In normal mode then.
[13.03.2019, 18:51:19] Yuri Orlov: Who is the priority?
[13.03.2019, 18:57:38] .: Savvidi, bogdanova, plitin, yudin, all managers
[13.03.2019, 18:58:27] .: Are you encrypting? Or are you scouring?
[13.03.2019, 18:58:38] Yuri Orlov: Cleaning it up
[13.03.2019, 18:58:44] .: With backups?
[13.03.2019, 18:58:44] Yuri Orlov: I'll pick up the profiles now
[13.03.2019, 19:01:24] Yuri Orlov: We're picking it up now
[13.03.2019, 19:02:14] .: ah, that's the backup, got it
[13.03.2019, 19:02:18] .: Terminology)
[13.03.2019, 19:02:37] Yuri Orlov: Documents, desktop, downloads
[13.03.2019, 19:02:42] Yuri Orlov: Next we'll smash profiles
[13.03.2019, 19:41:45] .: Passes are chopped off?
[13.03.2019, 19:41:54] Yuri Orlov: To the offices
[13.03.2019, 19:42:01] .: Hood
[13.03.2019, 19:42:03] Yuri Orlov: The offices are blocked
[13.03.2019, 20:02:39] Yuri Orlov: Done
[13.03.2019, 20:05:47] .: Ok, on to the rest of you.
[13.03.2019, 21:10:35] .: depo analytics uralsib
[13.03.2019, 21:10:54] .: eek whoop
[13.03.2019, 21:16:04] .: The network is up and running
[13.03.2019, 21:16:04] .: Lock discs too
[13.03.2019, 21:16:09] .: Written by Stanislav
[13.03.2019, 21:16:26] .: There are no discs on the grid
747
[13.03.2019, 21:17:52] .: Leave the desktop to him too
[13.03.2019, 21:18:04] .: They say they only want to sklp it.
[13.03.2019, 21:18:13] .: So we don't scare them off now
15.03.2019
[15.03.2019, 12:10:47] Yuri Orlov: Good, and you will be today?
[15.03.2019, 12:22:18] Yuri Orlov: Well we don't have HP
[15.03.2019, 12:46:45] .: Afernoon! I'll be off by the end of the day, I'm still in lockdown.
[15.03.2019, 12:47:13] .: Put him Hayaretdinov's comp then, and a monoblock in that place
[15.03.2019, 12:47:39] .: When hp is, give away a monoblock
[15.03.2019, 12:48:27] Yuri Orlov: He doesn't have an HP, it turns out
[15.03.2019, 13:18:44] .: From Venture were there systemics there?
[15.03.2019, 13:19:08] Yuri Orlov: Yes. These are self - collections
[15.03.2019, 13:19:15] Yuri Orlov: Maybe a monoblock afer all?
[15.03.2019, 13:19:53] .: Samosobors won't fit him temporarily?
[15.03.2019, 13:21:27] Yuri Orlov: Extremely undesirable
[15.03.2019, 13:48:35] .: Stanislav is not good at all
[15.03.2019, 13:48:49] .: Let's self - collect
[15.03.2019, 13:48:52] .: asap
[15.03.2019, 13:49:02] Yuri Orlov: Then by Monday - it must be prepared
[15.03.2019, 13:49:37] Yuri Orlov: We don't have time to prepare everything - we prepare as needed
[15.03.2019, 13:56:38] .: Got a list of who has hp standing?
[15.03.2019, 13:56:59] Yuri Orlov: Well we can prepare it
[15.03.2019, 13:57:08] Yuri Orlov: Within an hour
[15.03.2019, 14:01:52] .: Ok
[15.03.2019, 16:08:40] Yuri Orlov: On the three lists - by Wednesday morning will be ready.
[15.03.2019, 16:27:30] .: OK
[15.03.2019, 16:27:50] Yuri Orlov: The question on the ZP today... What should I say?
[15.03.2019, 16:28:12] Yuri Orlov: One more thing - WL reports I will be able to do only on the weekend. Write to Linda?
[15.03.2019, 18:23:03] Yuri Orlov: Zelimkhan Visaitovich?
[15.03.2019, 19:03:46] ... ...
[15.03.2019, 19:03:56] .: Mm - hmm.
748
[15.03.2019, 19:04:07] .: Send to the guys at once also for reconciliation in parallel
[15.03.2019, 19:04:22] Yuri Orlov: Ok
[15.03.2019, 19:04:42] Yuri Orlov: Yep
[15.03.2019, 19:04:50] Yuri Orlov: By WL
[15.03.2019, 19:07:12] .: ?)
[15.03.2019, 19:09:00] Yuri Orlov: I will write :)
16.07.2019
[16.07.2019, 08:35:17] Yuri Orlov: Zelimkhan Visaitovich, please take a charger for the Mac
[16.07.2019, 09:09:00] .: okeh
[16.07.2019, 09:36:46] Yuri Orlov: I don't see any interest at all
[16.07.2019, 09:37:06] .: Got it, thanks for writing back quickly
[16.07.2019, 09:37:27] Yuri Orlov: I will now answer Yudin in a more detailed way. There will be 3 points
[16.07.2019, 09:37:38] Yuri Orlov: And he will most likely pass on already
[16.07.2019, 09:37:44] .: okeh
[16.07.2019, 09:44:38] Yuri Orlov: I don't see the interest because:
No limits on transfers are specified anywhere. What about payer identification?
The presentation and teaser focus on Chinese buyers in Russia (WeChat, AliPay are essentially monopolistic in China)
If payment requires installing an app (e.g. WeChat) - hardly anyone will install it
The theme with QR codes works in Sberbank
Not in the next year anyway.
[16.07.2019, 10:47:57] .: Didn't get the adapter, didn't get home in time to stop by
[16.07.2019, 10:48:04] .: If it's urgent, then within a day
[16.07.2019, 10:51:32] Yuri Orlov: Let's do it tomorrow, then.
[16.07.2019, 10:51:53] Yuri Orlov: And you can go into IT on the 9th?
[16.07.2019, 10:52:00] Yuri Orlov: There is also a question here
[16.07.2019, 10:52:49] .: Mm - hmm.
[16.07.2019, 19:11:23] .: Polezhayev
[16.07.2019, 19:11:36] .: Send me his last 3 reports
[16.07.2019, 19:11:42] Yuri Orlov: To whom?
[16.07.2019, 19:11:47] .: Right this way
[16.07.2019, 19:11:56] Yuri Orlov: And can I have the code?
749
[16.07.2019, 19:14:02] Yuri Orlov: Are the risks normal?
[16.07.2019, 19:16:47] .: Es
[16.07.2019, 19:17:50] .: 592VR msq
[16.07.2019, 19:19:33] Yuri Orlov: Andrey Vyacheslavovich Polezhaev 000592, 30.04.2019.pdf - 6 pages document
missing
missing
missing
[16.07.2019, 19:19:44] .: Senk
[16.07.2019, 19:19:57] Yuri Orlov: Isn't that him?
[16.07.2019, 19:20:05] .: Mm - hmm.
04.09.2019
[04.09.2019, 09:40:23] Yuri Orlov: Good morning. Where to post it? To you on the desktop? There are 51 megabytes and
91 letters.
[04.09.2019, 09:44:41] .: Davazte
[04.09.2019, 09:44:44] ... Good Morning
[04.09.2019, 09:50:31] Yuri Orlov: On your desktop, Milyaev's folder is consent
[04.09.2019, 09:55:21] Yuri Orlov: The domains QBFCAPITAL.RU QBCAP.RU QBCAPITAL.RU QBCAPITAL.RU have been
cancelled.
The domains QBFCAPITAL.COM QBFCY.COM QBFCY.NET QBFCY.NET QBFCY.ORG will be deleted on 03.10.2019.
[04.09.2019, 10:22:49] .: Senk
[04.09.2019, 10:22:52] .: Ok
[04.09.2019, 13:06:39] .: By nabix.
[04.09.2019, 13:06:52] .: Now afer payment we have all the accesses, right?
[04.09.2019, 13:06:57] .: Remember h demo asked
[04.09.2019, 13:07:11] Yuri Orlov: Noooo... While we are preparing servers for deployment
[04.09.2019, 13:07:14] Yuri Orlov: By the end of the week
[04.09.2019, 13:07:29] .: So
[04.09.2019, 13:08:24] .: Look, while we are adjusting the box for the East, Vladimir asked to send everything to him in
parallel, so that we can think about adaptations to the dp and branches
[04.09.2019, 13:08:39] .: Including business processes, accesses, in short everything that is done
[04.09.2019, 13:08:55] .: Write him a letter and copy me in
750
[04.09.2019, 13:09:06] .: That as soon as the servers for deployment are up and running
[04.09.2019, 13:09:12] .: Then send it to him
[04.09.2019, 13:10:57] Yuri Orlov: During the day, can you?
[04.09.2019, 13:11:03] Yuri Orlov: And then we have a reshuffle...
[04.09.2019, 13:12:40] .: Es
[04.09.2019, 20:46:38] Yuri Orlov: Zelimkhan Visaitovich, will we be able to see you tomorrow on the IS presentation?
[04.09.2019, 20:49:41] .: Es
[04.09.2019, 20:49:56] Yuri Orlov: When will it be convenient for you?
[04.09.2019, 20:50:46] .: Let's get back together by 12
[04.09.2019, 20:50:51] .: And orientate ourselves
[04.09.2019, 20:51:12] Yuri Orlov: Ok
Correspondence with the subscriber number "+7 - 965 - 748 - 88 - 88" used by the defendant Pakhomov V.S. was found
and examined:
[16.07.2019, 10:42:33] +7 965 - 74888888888 - : What time were you called to spb ?
[16.07.2019, 10:44:03] .: Spb? In pon maybe? Time hasn't been fixed yet, we'll fix it on Friday
[16.07.2019, 10:47:21] +7 965 - 748888888 - : On Mon
[16.07.2019, 13:59:00] .: Some Ruslan dialled me from Veronica, a Chechen, he sounds like an adult. Cher hour in the
city will be in the city, wants to talk somewhere downstairs
[16.07.2019, 13:59:16] +7 965 - 748888888 - : Wow
[16.07.2019, 13:59:18] +7 965 - 74888888888 - : Come on - in
[16.07.2019, 13:59:26] +7 965 - 748888888 - : To me
[16.07.2019, 13:59:37] +7 965 - 748888888 - : Roma here
[16.07.2019, 13:59:49] .: Mm - hmm, on my way
[16.07.2019, 16:21:01] .: There was a meeting. About Kus there no one is aware of it and does not parody at all. About
what Veronica ds owes also says complete nonsense, etc
[16.07.2019, 16:21:59] +7 965 - 74888888888 - : He took it from me himself ))))
[16.07.2019, 16:22:08] +7 965 - 74888888888 - : I'll come and talk - to you.
[16.07.2019, 16:22:10] .: Veronica charged people to deal with us, you know about the closed case in Tsao, Zao is now
engaged and in Tsao they want to resume. Except for ds Veronica does not need anything says, close and that's it
[16.07.2019, 16:22:26] .: Ok
[16.07.2019, 16:25:31] +7 965 - 74888888888 - : He should put his - dogs away
751
[16.07.2019, 16:27:36] .: 100% there will be no such scenario that first remove the dogs, then ds. He didn't even want
to discuss it. First like decide with the client as you should, then he'll call it all off
[16.07.2019, 16:30:35] +7 965 - 74888888888 - : Who is the guarantor ?
[16.07.2019, 16:33:05] .: Let me ask you a question
[16.07.2019, 16:33:17] +7 965 - 74888888888 - : Wait - a minute
[16.07.2019, 16:33:21] +7 965 - 74888888888 - : I'll come back and talk - to you.
[16.07.2019, 16:33:25] .: Ok
[16.07.2019, 16:33:30] .: When are you going to be there?
[16.07.2019, 16:37:29] +7 965 - 74888888888 - : Coming Soon
[16.07.2019, 16:57:09] +7 965 - 748888888 - : I'll be there - in an hour.
[16.07.2019, 16:57:22] +7 965 - 74888888888 - : And who fluffed the topic, the Czech himself?
[16.07.2019, 17:03:41] .: Cheh said he knows Andrei and he said that I wrote to him that I saw who shines in k1, that
like what are you doing, etc., put out let's go and that the question in the ds at all was not there
[16.07.2019, 17:03:56] .: Yes it was all him saying it himself
[16.07.2019, 18:31:18] .: Are you at your place?
[16.07.2019, 18:31:25] .: And I see you.
[16.07.2019, 18:31:41] .: Come on in
During the examination of the phone, other correspondence, cited in the examination report, was found to be of
significance and establishing the circumstances of the criminal case;
(Vol. No. 286, pp. 80 - 169)
- Protocol of additional examination of items dated 11 March 2022, seized on 19 November 2020 in the dwelling of Z.V.
Munayev, located at the address: 1 Nikolayeva Street, sq. 96, Moscow, during which the seized mobile phone of the
latter was additionally examined. In the course of the additional examination of the phone, the correspondence given
in the protocol of the examination was discovered, which is of significance and establishes the circumstances of the
criminal case;
(Vol. No. 287, pp. 4 - 163)
- Material evidence - a mobile phone "iPhone XS max" belonging to Z.V. Munaev, IMEI: 35 728709
442062 9;
(Vol. No. 287, pp. 164 - 166)
752
- In 2012, Shpakov R.V. received about USD 63,000 from the account of QB CAPITAL CY LTD; in 2013, his
(Shpakov R.V.'s) account received about RUB 6,100,000 from QUBI FINANCE LLC as a loan repayment; in December
2017, Shpakov R.V. transferred about 130,000 Euros to the account of ASRARD BANK LATVIA RIGIA. In December
2017, R.V. Shpakov transferred about 130,000 Euros to the account of ASRARD BANK LATVIA RIGA under the loan
agreement; in June 2018, R.V. Shpakov and QB GROUP LLC entered into an agreement on compensation in the
amount of about 35.8 million rubles, according to the information provided by OJSC IK RUSS - INVEST, the client -
Qiubi GROUP LLC submitted an order to write off 35,810 shares of ordinary PJSC CVCF to the account of R.V. Shpakov
in the depository of PJSC Bank Zenit, and R. Shpakov is the beneficial owner of the shares.B is the beneficial owner of
QYUBI GROUP LLC, and in 2012 and 2017, Shpakov R.V. provided interest - free loans to QYUBI GROUP LLC; in 2019,
there were several transfers of funds between Shpakov R.V. and 701 LLC related to the granting and repayment of
loans totalling approximately RUB 5.4 million; in 2015, the account of Z.V. Munayev received approximately RUB 1.7
million. In 2015, about RUB 1.7 million was transferred to Munaev Z.V.'s account from the Moscow representative office
of QUBI CAPITAL MANAGEMENT LTD as a repayment of funds under the agreement, the representative of the foreign
company was Elena Vyacheslavovna Gorobets; the Federal Financial Database of Rosfinmonitoring contains
information on 20 financial operations/transactions for the period from May 2015 to March 2020 for a total amount of
about RUB 1.4 billion. RUB 1 billion, of which transactions worth RUB 1 billion are related to statutory activities.
Among the main counterparties of the company were LLC KP OCHEREDY 3, LLC KP OCHEREDY 4, these companies
entered into agreements with LLC CBF UA on assignment of claims under the contract of participation in shared
construction, registered with the Office of the Federal Service for State Registration, Cadastre and Cartography for the
Arkhangelsk region and the Nenets Autonomous District; CBF UA LLC and Vysota LLC concluded an agreement on
assignment of claim rights under the contract of participation in shared construction dated 10.05.05.2017 No. 9 - DDU;
the Federal Financial Database of Rosfinmonitoring contains 3 financial transactions with the participation of CBF
Venture LLC conducted in the period of October - November 2019 and related to the receipt on 10.10.2019 of a loan
from LLC Profi in the amount of 4.1 million rubles and its transfer as a transfer of funds to the Bank of Russia. RUB 4.1
million and its transfer as a loan on the same day to the account of Spinka Ruslan Valeryevich, there is no incoming
flow to the address of LLC Profi, however, outgoing transactions are related to the provision of an interest - bearing
loan to non - resident Simtelligence Company Limited, in total LLC Profi transferred RUB 36.5 million to the address of
the said non - resident. The Federal Financial Database of Rosfinmonitoring contains 13 financial transactions
involving M1Invest LLC conducted between November 2013 and August 2018 for a total amount of approximately RUB
25 million, of which RUB 21 million are financial transactions related to the repayment of the loan to Simtelligence
Company Limited. RUR 21 million are financial transactions related to loan repayment, increase of the authorised
capital, contributions under loan agreements, in addition, M1Invest LLC transferred to the company 701 LLC monetary
funds in the amount of RUR 1.5 million as payment for sublease, 701 LLC in turn transferred monetary funds received
to the account as sublease, including in the form of loan repayment to Shpakov R.V.'s accounts, LLC IK QBF, PJSC CVF;
the Federal Financial Database of Rosfinmonitoring contains 18 financial transactions involving LLC SeverSpetsStroy,
carried out between February 2018 and September 2019 for a total amount of approximately RUB 7.2 million, related
to advance payments to LLC PSK under construction contracts;
(Vol. No. 31, pp. 94 - 100)
- Another document is a certificate of Rosfinmonitoring, according to which: the company QB CAPITAL CY LTD
changed its name QCCI LTD on 14.08.2017, Roman Shpakov is stated to be the beneficial owner of the company, as
well as its account manager, the company was voluntarily liquidated on 07.08.2018; the company QB CAPITAL CY LTD
had a current account in the bank Direktna banka a.d. Kragujevac, to which funds were received in connection with
the provision of consulting, marketing and accounting services, subsequently, the received funds were transferred to
a large number of individuals located abroad. Kragujevac, which received funds in connection with the provision of
consulting, marketing and accounting services, subsequently, the received funds were transferred to a large number
of individuals located abroad on the basis of bilateral agreements; the directors of QB CAPITAL CY LTD on the day of
account opening in CJSC Anelik Bank were the Cypriot companies "CGC Nominess Limited" and "Noa Circle Ltd"; the
753
owner of QB CAPITAL CY LTD was Munaev Z. V.; for the opening and management of the account in CJSC Anelik Bank,
the directors of QB CAPITAL CY LTD were the Cypriot companies "CGC Nominess Limited" and "Noa Circle Ltd".V.;
Munaev Zelimkhan and Linda Athanasiadou had powers of attorney to open and manage accounts at Anelik Bank
CJSC on behalf of QB CAPITAL CY LTD; QB CAPITAL CY LTD accounts at Anelik Bank CJSC were opened by Munaev
Zelimkhan, afer which Linda Athanasiadou accompanied by Dmitry Lepeshkin visited the bank to conduct
transactions;
(Vol. No. 31, pp. 103 - 105)
- another document - certificate No. 33 - CIM on the study of documents in relation to QB CAPITAL CY LTD with an
appendix, according to which the total amount of money received on the accounts of QB CAPITAL CY LTD from legal
entities and individuals in the period of 2017 amounted to 562,597,743.68 rubles, and the total amount of money
transferred from the accounts of QB CAPITAL CY LTD to legal entities and individuals in the period of 2017 amounted
to 497,763,231.77 rubles;
(Vol. No. 31, pp. 106 - 133)
- another document - the conclusion of specialist Yakubova N.G. dated 25 February 2021, according to which, as a
result of the conducted research on the basis of the submitted documents and available information, it can be
concluded that the funds of Borzenkov M.I. cannot be considered as investments, both from the point of view of
Russian law and from the point of view of international investment law. Activity in relation to the funds of both
Borzenkov M.I. himself, QBIF LLC and QB CAPITAL CY LTD cannot be regarded as investment activity. The actual
circumstances testify to the unlawful and dishonest behaviour of the participants of the legal relations under
consideration, there is a scheme aimed at withdrawal of funds from the hands of their owner to unknown structures,
as evidenced, in particular, by the following circumstances: 1) Borzenkov M.I. transferred funds in the total amount of
$17,000,000 under contracts with interrelated companies that have one beneficial owner and the alleged one circle of
related persons. 2) For the entire duration of the contracts, M.I. Borzenkov did not receive any proper report on the
activities declared by the companies, which would allow establishing a legal connection between M.I. Borzenkov as a
subject of law and the securities comprising the investment portfolio as an object of law. M.I. Borzenkov had no
independent access to the accounts. There are no documents confirming M.I. Borzenkov's ownership of securities.
Possible placement of M.I. Borzenkov's funds on accounts possibly belonging to him is not an investment activity.
Investment activity is the actual placement of funds in securities, which must be confirmed by appropriate
documents. In this case, there are no such documents, nor is there any document that would confirm that this activity
was conducted. 3) M.I. Borzenkov as an individual was misled by QBIF LLC and QB CAPITAL CY LTD in connection with
the following. When concluding agreements on trust management services with QB CAPITAL CY LTD, M.I. Borzenkov
obviously believed that he was concluding a securities trust management agreement with a professional participant
of the securities market, whose activities are regulated and controlled by the Central Bank of the Russian Federation.
In reality, according to the content of the agreements, under the guise of trust management agreements, M.I.
Borzenkov entered into assignment agreements. Display in the title and subject of these contracts of contradictory
wording affecting the legal nature of the contract and misleading the counterparty - individual, is evidence of
misconduct and bad faith on the part of LLC IC QBF. The actual conclusion of assignment agreements with QB QF LLC
regarding the management of Borzenkov M.I.'s trading accounts opened with QB CAPITAL CY LTD in his name did not
comply with the requirement of the agreements concluded between Borzenkov M.I. and QB CAPITAL CY LTD that the
transfer of account management rights may be carried out only on the basis of a trust management agreement. 4) QB
IC QBIF LLC had no legal grounds to conclude with Borzenkov M.I. contracts, the subject of which is the execution of
purchase and sale transactions of securities, derivatives and other instruments within the framework of the trading
account opened in accordance with the agreements concluded by Borzenkov M.I. with QB CAPITAL CY LTD. Firstly, the
company QB Sartial CY LTD had the signs of an organisation that did not actually carry out financial and economic
activities, which was established by the Court Decision of 11 December 2017. Secondly, QB Sarital CY LTD had no legal
grounds to engage in the type of activity related to the performance of transactions with securities,
as this type of activity in accordance with the legislation of the Republic of Cyprus is subject to compulsory licensing,
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and QB Sarital CY LTD did not have a statutory licence from the Cyprus Securities and Exchange
Commission (CYSEC), as established by the Court Decision of 11 December 2017. Thirdly, QB Sarital CY LTD was not
actually located at its official place of business, as established by the Court Decision of 11 December 2017 The address
specified in the agreements with Borzenkov M.I. did not coincide with the legal address of QB Sarital CY LTD, which is
registered in the public database of the Republic of Cyprus. Fourthly, according to the information about the company
QB Sarital CY LTD, which is contained in the public database of the Republic of Cyprus, on 7 August 2018 in respect of
the company in the Register there is a record: "Dissolution following Voluntaru Liquidation" (dissolved due to
voluntary liquidation), about which no one officially notified Borzenkov MI. Fifhly, contracts and agreements with
Borzenkov M.I. were signed on behalf of IC QBF LLC and QB Capital CY LTD by the same persons (Sobolev K.S. and
Yudin M.S.) under powers of attorney. Sixthly, the signs of affiliation of QB IC QBiEf LLC and QB Sarital CY LTD,
established by the Court Decision of 11 December 2017, were expressed, in particular, in the following. Both
companies operate under the abbreviation (brand) "QB". On behalf of both companies (both QB IC CY LTD and QB
Capital CY LTD), the Contracts with the plaintiff were signed by the same person, who according to the data of the
Unified State Register of Legal Entities owns 6% in the authorised capital of QB GROUP LLC, which is the sole
participant (founder) of QB IC CY LTD. In addition, according to the response to the court request from the Joint Stock
Company "Regional Network Information Centre" both domain names qbfin.ru (the domain name of the Respondent
QB&EF LLC, which is reflected directly in the Agreements with the Complainant) and qbcap.som (domain name of QB
Capital CY LTD) are registered to the same individual, who according to the data of the Unified State Register of Legal
Entities owns 88% in the established capital of QB GROUP LLC, being the sole participant (founder) of the Respondent
QB IC QBF LLC. The conclusion of the forensic computer - technical expertise established that there are indications
that electronic messages from the mail addresses @qbcap.com and @qbfin.ru were actually sent using the same
infrastructure, mail servers and IP addresses. Seventh, QB IC QBiEF LLC could not have been unaware of the stated
violations of the law committed by QB Sarital CY LTD due to the clearly expressed signs of affiliation between QB IC
QBiEF LLC and QB Sarital CY LTD, as established by the Court Decision dated 11 December 2017. Eighthly, the
submitted financial documents on the cash flow on the account of QB Sarital CY LTD in Bank Direktna Vanka a.d.
Kgargujetvac (Serbia) allow us to assume that it was at the expense of the funds received by Borzenkov M.I. on this
account during a certain period that the company QB Sarital CY LTD made its payments;
(Vol. No. 31, pp. 151 - 202, Vol. No. 32, pp. 1 - 56)
- other documents - materials of civil case No. 2 - 5956/17 on the claim of Stepanov S.V. against
QBIF Investment Company LLC, containing
, inter alia, the following documents, namely: decision of the Ramenskiy City Court of the Moscow region, according to
which the court, having evaluated the totality of the evidence available in the case in accordance with the rules of
evaluation of evidence enshrined in Article 67 of the Russian Federation Code of Civil Procedure, came to the
conclusion that the defendant, LLC Investment Company QUBIEF, acted in bad faith and unlawfully within the
framework of legal relations with the plaintiff Stepanov S.V., which is confirmed by the totality of the following
circumstances. In accordance with clause 10.3 of Contract No. 2004, the Attorney undertakes to send monthly
responses to the Principal not later than the 15th day of the month following the reporting month (the reporting
period under the Contract is 1 calendar month). The Attorney shall guarantee to the Principal the full legality of the
reports provided and the validity of all data specified therein. In accordance with Clause 10.3. of the Agreement 2070,
the Attorney undertakes to send monthly responses to the Principal not later than the 15th day of the month
following the reporting month (reporting period under the Agreement - 1 calendar month). The Attorney shall
guarantee to the Principal the full legality of the reports provided and the validity of all data specified therein.
According to the annex to the forensic computer - technical examination report, the reports were sent on an irregular
basis and exclusively by e - mail from the e - mail addresses [email protected] and [email protected] to the
Claimant's e - mail address [email protected]. The content of all e - mailed reports is presented in the
case file as an annex to the forensic computer forensic examination report. The submitted reports contain
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information, according to which Stepanov S.V. owns shares of foreign organisations in the structure of his investment
portfolio. In part, the report submitted to Stepanov S.V. dated 10.05.2017 on portfolio No. 2004 - 15/IMR dated
03.02.2015 reflects information according to which the structure of the portfolio owned by Stepanov S.V. includes
shares of foreign companies: MeDonaldˈs. Snap Ine, TableauSotwarelne, ConstellationBrands, Inc. and
JPMorganChase&Co. Similar information is contained in other reports that were sent to the plaintiff, which contain
information about the plaintiff's ownership of shares in large international companies such as Deutsche Bank AG
(Germany) Ferrari NV (Netherlands), BBVA Vanco Frances S.A. (Argentina) and others. According to the terms and
definitions reflected in the Agreement No. 2004 and No. 2070 concluded between the plaintiff and the defendant
QUBIEF Investment Company LLC, the portfolio is a set of all instruments representing the property of the Principal,
including, but not limited to, cash and securities. It is also established in the terms and definitions that it is the
Principal (plaintiff Stepanov S.V.) who is the owner of the trading account. Thus, the Agreements No. 2004 and No.
2070 expressly determine that the property constituting the structure of the investment portfolio shall belong to the
Principal, i.e. the plaintiff Stepanov S.V. However, the reports submitted to Stepanov S.V. do not contain identification
data allowing to establish a legal connection between the plaintiff Stepanov S.V. as a subject of law and the securities
constituting the structure of the investment portfolio as an object of law. As it is rightfully noted in the conclusion of
the international law company "Dentons" provided by the plaintiff in the case materials, in order to establish a legal
connection between the Client as a subject of law and the object of law - shares of organisations specified in the
reports of the Counterparty, it is necessary to obtain, first of all, information on who is the nominal holder of the
shares acquired at the expense of the client, details of master accounts, statements from depo accounts of
counterparties, other documents confirming transactions with securities specified in the reports of the Counterparty.
The case file contains documents, according to which Stepanov S.V. on 29.03.2017 before filing a claim to the court
addressed the defendant LLC "Investment Company "QUBIEF" with a request to provide the manager's report, in
which he asked to provide identification data confirming the ownership of his rights to the assets that make up the
structure of his investment portfolio in accordance with the terms of Agreement No. 2004 and Agreement No. 2070,
namely: the name of the acquired and realised assets; the date, time and market of acquisition and realisation of the
price of the assets; the date, time and market of acquisition and realisation of the price of the assets. The requested
information was not provided to the plaintiff. This information was twice requested from the defendant LLC
Investment Company QUBIEF in the course of the court proceedings on the basis of the plaintiff's petition. By the
Ramensky City Court of the Moscow Region (court requests dated 07.07.2017 and 08.11.2017). Both court requests
were received by the defendant LLC "Investment Company QUBIEF", whose representative in the court session
repeatedly explained that he objected to the execution of these court requests and the organisation refused to
provide the court with the relevant information. No duly substantiated refusal to provide information has been
submitted to the court. The court notes that the requested information is directly related to the subject matter of the
dispute, as it is connected with the identification of the plaintiff's rights to shares and other assets, which constitute
the content of the plaintiff's investment portfolio in accordance with the terms and conditions of Agreement No. 2004
and Agreement No. 2070 concluded between the plaintiff and the defendant Investment Company QUBIEF LLC. The
evasion from providing this information, including on the basis of two court requests, is evidence of unlawful and bad
faith behaviour of the defendant Investment Company QYUBIEF LLC. The Court also notes that certain provisions of
Contract No. 2004 and Contract No. 2070 are formulated in such a way that they contain uncertainty and mislead the
plaintiff as an individual on the part of the defendant as a professional business entity licensed by the Central Bank of
the Russian Federation. The Court notes that the defendant LLC "Investment Company QUBIEF", concluded with the
plaintiff a contract of assignment under the guise of a contract of trust management of property. The agreement
offered to Stepanov S.V. misled him, as the title of the agreement contains the wording "agreement on the provision
of trust management services". In reality, the agreement is not a trust management agreement, since its subject
matter states that the agreement is a trust agreement. This contract does not meet the characteristics of a trust
management agreement as provided for in Chapter 53 of the Civil Code of the Russian Federation, which regulates the
issues of trust management of property, and, accordingly, in respect of securities subject to the regulation of the
Federal Law of 22.04.1996 No. 39 - FZ "On the Securities Market" and the control of the Central Bank of the Russian
Federation on the management of securities. The Court comes to the conclusion that Stepanov S.V., as a natural
person, due to the wording "agreement on provision of trust management services" in the title of Agreements No.
756
2004 and No. 2070, believed that he was entering into an agreement on trust management of securities with a
professional participant of the securities market, whose activities are regulated and controlled by the Central Bank of
Russia. Display in the title and subject of Agreements No. 2004 and No. 2070 of contradictory wording affecting the
legal nature of the contract and misleading the counterparty - a natural person, also testifies to illegal actions and bad
faith on the part of the defendant LLC Investment Company QUBIEF. The defendant "QBIEFF Investment Company"
LLC also had no legal grounds to conclude with the plaintiff agreements, the subject of which is the execution of
purchase and sale transactions of securities, derivatives and other instruments within the framework of the
Principal's trading account opened in accordance with the Agreements concluded by the Principal with QB Capital CY
LTD. Thus, at the time of conclusion of the agreement between the plaintiff and the defendant QB Capital CY LTD
Investment Company QB Capital CY LTD already had the signs of an organisation that does not really carry out
financial and economic activities. According to the answer from the Ministry of Energy, Trade, Industry and Tourism of
the Republic of "Cyprus", the company QB Capital CY LTD filed the last annual report for 2013, containing information
about its financial condition in 2012 and did not file annual reports for 2014 - 2017, containing information about its
financial condition in 2013 - 2016. However, despite this circumstance, the defendant QBIEFF Investment Company
LTD entered into a contract with the plaintiff in 2015, i.e. during the period when QB Capital CY LTD was no longer
filing statutory accounts. In addition, QB Capital CY LTD had no legal grounds to engage in the type of activity related
to the performance of transactions with securities, as this type of activity is subject to compulsory licensing under the
legislation of the Republic of Cyprus, and QB Capital CY LTD does not have a statutory licence from the Cyprus
Securities and Exchange Commission (CySEC). These circumstances are substantiated in detail and stated in the legal
opinion of the law firm ANTIS TRIANTAFYLLIDES & SONS LLC, the opinion of the international law firm "Dentons", as
well as directly notarised extract from a specialised website, confirming the absence of a statutory licence for QB
Capital CY LTD. Consequently, the defendant QBIEFF Investment Company Ltd. could not knowingly fulfil its
obligations under Agreements No. 2004 and No. 2070 with the plaintiff, as QB Capital CY LTD did not have the right to
engage in this type of activity due to the lack of a licence. Also QB Capital CY LTD is not located at its official place of
business, which is confirmed by the affidavit presented in the case materials (affidavit sworn in the Supreme Court of
Nicosia of the Republic of Cyprus, according to which, there are no signs indicating the physical presence of the
company QB Capital CY LTD at the address of location). The Court notes that the defendant QBIEFF Investment
Company Ltd. could not have been unaware of the alleged violations of the law committed by QB Capital CY LTD due
to the clear indications of affiliation of QBIEFF Investment Company Ltd. and QB Capital CY LTD, established in the
course of the proceedings. The signs of affiliation are expressed in the fact that both companies operate under the
abbreviation (brand) "QB". On behalf of both companies (both from "Investment Company "QBIEFF" LLC and from QB
Capital CY LTD) with the plaintiff Stepanov S.V., contracts were signed by the same person - Munaev Zelimkhan
Visaitovich, who according to the data of the Unified State Register of Legal Entities owns 6% in the authorised capital
of "QB GROUP" LLC (OGRN 1107746391532), which is the only participant (founder) of the defendant "Investment
Company "QBIEFF" LLC. In addition, according to the response to the court request received from the Joint Stock
Company "Regional Network Information Centre" both domain names qbfin.ru (the domain name of the Respondent
LLC "Investment Company "QBIEFF", which is reflected directly in Contracts No. 2004 and No. 2070 with the
Complainant) and qbcap.com (domain name QB Capital CY LTD) is registered to the same individual - Roman
Valerievich Shpakov, who according to the data of the Unified State Register of Legal Entities owns 88% in the
authorised capital of "QB GROUP" LLC (OGRN 1107746391532), which is the sole participant (founder) of the
Respondent "QBIEFF Investment Company" LLC. The conclusion of the forensic computer - technical expertise
established that there are indications that electronic messages from the mail addresses @ qbcap.com and @qbfin.ru
were actually sent using the same infrastructure, mail servers and IP addresses. The court also takes into account the
conclusion of the specialist Cherepanov V.Y., possessing special knowledge in the field of economy and finance, who
analysed the financial and economic side of the relations of the plaintiff Stepanov S.V. with the defendant Investment
Company QBIEF LLC. According to the submitted conclusion, in which the financial and economic substantiation is
given, the trust management of monetary funds, as well as the performance of duties under the contract with
Stepanov Sergey Vitalievich as an attorney on the part of the defendant, should be considered as unsatisfactory.
Under such circumstances, the court considers proved the arguments of the plaintiff that in the actions of the
defendant LLC "Investment Company "QUBIEF" there are signs of misconduct and bad faith, which is stipulated in
757
paragraph 10.7 of the Agreement № 2004 and the Agreement № 2070 grounds for recovery from the defendant of the
amount of losses and damage caused to the plaintiff. In accordance with paragraph 1 of Article 393 of the Civil Code of
the Russian Federation, the debtor is obliged to compensate the creditor for the losses caused by non - fulfilment or
improper fulfilment of the obligation. In accordance with Article 15 of the Civil Code of the Russian Federation, the
person whose right has been violated may demand full compensation for the losses caused to him, unless the law or
the contract does not provide for compensation for losses in a lesser amount. Losses are understood as expenses
which the person whose right is violated has made or will have to make to restore the violated right, loss or damage to
his property (real damage), as well as unreceived income, which this person would have received under normal
conditions of civil turnover, if his right had not been violated (lost profit). The plaintiff's claims for recovery of the
amount of real damage from the defendant Investment Company QUBIEF LLC are based on the law and are subject to
satisfaction;
expert opinion No. 1447 - E dated 27.11.2017,

from which it follows that in the course of the study of the submitted archive file containing the upload of electronic
mail messages from the account "Google", a list of electronic mail messages sent to the electronic mailbox
"[email protected]" from the following mail servers: - [email protected] - [email protected] -
[email protected] - [email protected] - [email protected] - [email protected] - [email protected] -
[email protected] - [email protected] - [email protected] - [email protected]" in the period from "01"
December 2014 to "08" November 2017 was established; in the course of the study of submitted - [email protected].
- [email protected], - [email protected] is contained in the service headings of the emails. Taking into account the
presence of information about DKIM records, DKIM filter and received SPF records in the service headers of some of
the studied e - mails, it can be concluded that these e - mails have correct signatures and were really sent from the
specified addresses; in the course of the analysis of service headers of e - mails it was established that e - mails from
the e - mail addresses "*qbcap.com" were sent from IP addresses: 94.243.131.92, 94.243.131.82, 94.243.131.86,
94.243.143.50, workstations with the names: "MSK1WS02BOF005", "MSK1WS02ITD001.lan.qbfin.ru", via mail servers:
"mx.qbfworld.com", "mx.mldevelop.ru", "mail.qbf.world". The following coincidental signs of sending using the same
infrastructure, mail servers and IP addresses from "@qbfin.ru" were also found: IP addresses: 94.243.131.82,
94.243.131.84, 94.243.143.50, 94.243.143.52, 94.243.143.55, 94.243.143.59, 94.243.131.82 - from the same subnet
94.243.131.131. * and 94.243.143.*, workstation names: MSK1WS02BOF005, as well as MSK1WS01WHR003,
MSK1WS02SAL019, MSK1WS02VIP008, via the mail server "mx.qbfworld.com"; The service headers of the emails
indicate either the IP addresses from which the email messages were sent (including from the subnet 94.243.131.*:
94.243.131.82, 94.243.131.84, 94.243.131.86, 94.243.131.92 and subnet 94.243.143.*: 94.243.143.50, 94.243.143.52,
94.243.143.55, 94.243.143.59), or the addresses of the servers used to send messages. Provision and accounting of the
use of external IP - addresses is made by authorised companies (Internet providers), which organise access to the
information - telecommunication network Internet. The affiliation (including territorial and geographical affiliation) of
each IP - address can be established by the Internet provider. In case of using e - mail services, the end sender can be
identified only by requesting the e - mail service provider;a legal opinion of the Lawyers and Legal Advisers of the
Republic of Cyprus, from which it follows that under the Law, in order for a Cyprus Investment Firm to provide
professional services in the field of investments in the Republic, it is required to have an authorisation under the Law.
Under the Law, this authorisation essentially entails the Company obtaining a licence from the Cyprus Securities and
Exchange Commission. In the present case, the Company is a Cyprus company which provides investment services in
accordance with the Basic Treaties and the Amendment Agreements, such a company is deemed to be a Cyprus
investment firm. Furthermore, it is evident from the Master Treaties and the Modification Agreements that the
Company provides the said services on a professional basis. Therefore, the Company must be licensed by the Cyprus
Securities and Exchange Commission in order to be able to provide the services contemplated by the Master Deeds
and the Amendment Agreements. The Law provides that in the event that a Cyprus Investment Firm providing
investment services on a professional basis fails to comply with the necessary provisions of the Law and fails to obtain
a licence from the Cyprus Securities and Exchange Commission, the Cyprus Investment Firm in question shall be
criminally and/or administratively and/or civilly liable. With regard to criminal liability, the Law provides that if an
758
offence is committed by a legal entity which is a Cyprus Investment Firm, not only the Cyprus Investment Firm itself
but also any director and member of its board of directors shall be criminally liable. The penalty provided for under
the Law is imprisonment of up to five years and/or a fine not exceeding €350,000. With respect to civil liability, under
the Act, a person who contravenes a provision of the Act is liable to pay compensation to any person who suffers
damage and/or loss of profit by reason of any act or omission on the part of the contravener as a result of the
contravention of the Act. It should be noted that any criminal liability imposed on a person does not relieve that
person of the corresponding civil liability. The Cyprus Securities and Exchange Commission is also authorised to
impose an administrative fine not exceeding €350,000 and, in the case of repeated or persistent violations, an
administrative fine not exceeding €700,000. A company which is a Cyprus Investment Firm and provides investment
services without a licence from the Cyprus Securities and Exchange Commission in contravention of the Law is
criminally, administratively and civilly liable. Afer careful examination of the Cyprus Securities and Exchange
Commission's online register, which records both all currently active Cyprus Investment Firms and all former Cyprus
Investment Firms that are no longer active, there is no entry or reference of any kind in respect of the Company (in
respect of its currently registered name or in respect of its previous names). Therefore, the Company has never
received or held any authorisation and/or licence from the Cyprus Securities and Exchange Commission to provide
investment services. In accordance with the letter dated 30.10.2017 from the Company's Registrar, addressed to Essex
Consulting Group Limited with the subject line "HE221325 - QCCI LTD", the Company has not filed any annual tax
return for the years 2014 - 2017, nor has it filed any relevant financial returns for the years 2013 - 2016. In accordance
with the Companies Act (Chapter 113), the Company is required to prepare an annual tax return and related financial
statements and file the same with the Registrar of Companies. Chapter 113 provides that a company and every
employee of the company who defaults commits a criminal offence and shall be punished accordingly upon
conviction; Legal opinion of the international law firm Dentons, from which it follows that in accordance with the list
of organisations specified in the Counterparties' reports for 2015 - 2017, various securities (including shares, ETFs,
bonds) were purchased at the expense of funds received by the Counterparties from their clients. At the same time,
according to the reports provided by the Counterparty - the Cyprus company "QB Capital LTD", most of the acquired
securities were shares of various international companies such as Deutsche Bank AG (Germany), McDONALDˈS
CORPORATION (Delaware USA), Ferrari NV (Netherlands), BBVA Banco Frances S.A. (Argentina), etc. Acquisition of title
to shares follows the law of the country where the relevant joint stock company is established (personal law of a legal
entity Art. 1202 of the Civil Code of the Russian Federation). At the same time, both in the Russian Federation and in
other countries, such as Germany, a model is currently in force which, with different legal consequences, requires
registration of the transfer of ownership of shares in the register of shareholders of the relevant joint stock company.
Similar rules exist in the legislation of other member states of the European Union. Accordingly, in order to determine
the composition of the shareholders of each individual joint stock company whose shares, according to the
Counterparties' reports, were acquired at the Client's expense, it was necessary to analyse the legislation of each
individual country in which the joint stock company concerned is located. However, in international practice and in
accordance with the rules governing the circulation of securities (including shares), a practice has developed that
facilitates the circulation of shares, given that it is practically impossible to register a large number of transactions
with shares, which take place on stock exchanges, in the register of shareholders of the relevant joint stock
companies. In accordance with such international practice, securities (including shares) are legally owned not by their
ultimate beneficiary (i.e. the person purchasing securities on the stock exchange), but by a depository organisation,
which from the legal point of view is the owner - nominal holder of shares, but at the same time owns the securities at
the expense of the beneficiary (the owner from the economic point of view). In this context, the reason why the
registrars keeping the shareholder registers of McDONALDˈS CORPORATION and Snap Inc. informed the Client in
response to the Client's respective requests that it was impossible to determine the Client's personal account, even if
the shares of these two companies had been acquired by one of the Counterparties at the Client's expense, it would
not be the Client but the nominee holder that would be registered as the legal owner in the shareholder registers of
these companies. Accordingly, in order to establish a legal connection between the Client as the subject of the right
and the object of the right - the shares of the organisations indicated in the Counterparties' reports, it is necessary to
obtain, first of all, information on who is the nominal holder of the shares acquired at the Client's expense. Clause 2.2
of agreements No. 2004 - 15/IMR dated 03.02.2015 and No. 2070 - 15/IMR dated 24.02.2016 on the provision of direct
759
access services to international stock markets, states that by signing the said agreements, "the Client agrees to the
accession of his trading account to the account opened with brokers (LEK Securities, R.J. OˈBrien & Associates and
other servicing brokers) master accounts of the Company (i.e. QB Capital CY LTD). The counterparty, QB Capital CY
LTD, a Cyprus company, may have opened a master "master account" with one of the brokerage firms mentioned in
Clause 2.2 of Agreements No. 2004 - 15/IMR and No. 2070 - 15/IMR or with some other firm. If these companies have
the licences required by the legislation applicable to them, they may, in theory, provide nominee services and be the
legal owner of the shares acquired with the funds that the Counterparties have received from the Client. R.J. OˈBrien &
Associates" in response to the Client's enquiry only stated that no personal account had been opened with the
company on behalf of the Client. According to the information received from the Client, LEK Securities has not
responded at all to the Client's enquiry as to whether a personal account has been opened on behalf of the Client
and/or whether there is any commercial relationship between the Counterparties and LEK Securities. However, even
if the mentioned brokerage companies were nominee holders of the shares of the Counterparty mentioned in the
reports - about which there is no confirmation in the Documents - then, in order to establish a connection between
the Client and the issuers of securities, it is necessary to obtain at least statements from the depo accounts of the
Counterparty - QB Capital CY LTD since 2015, so that it would be possible to confirm whether the securities mentioned
in the reports were on such depo accounts during the relevant periods of time. According to the information received
from the Client, the Counterparties refuse to provide the Client with specific information (details) about master
accounts, as well as statements from such master accounts or other documents confirming transactions with
securities specified in the Counterparty's reports, it is impossible to establish a legal connection between the Client,
as a subject of law, and the object of law - shares of the organisations specified in the Counterparties' reports. In
accordance with clause 1 of the Additional Agreement No. 1 to the Agreement on provision of direct access services to
international stock markets No. 2070 - 15/IMR dated 24.02.2015, as well as clause 1 of the Additional Agreement No. 1
to the Agreement on provision of direct access services to international stock markets No. 2070 - 15/IMR dated
24.02.2015. Additional Agreement No. 1 to the Agreement on rendering services of direct access to international stock
markets No. 2004 - 15/ IMR dated 03.02.2015, the Counterparty - the company "QB Capital CY LTD" performs "trust
management of the Client's account for placement of the Client's property on the following types: shares; bonds or
other debt securities; industrial securities, ADR and GDR on foreign shares, exchange - traded funds; options and
futures on all types of assets; currency pairs; cash, deposits and other objects. According to the legal opinion prepared
by lawyers admitted to practice law in the Republic of Cyprus, the legislation of the Republic of Cyprus considers the
services provided by the Counterparty, QB Capital CY LTD, as "investment services and investment activities", which
are subject to compulsory licensing in the Republic of Cyprus. Since the Cyprus Legal Opinion also confirms that the
company "QB Capital CY LTD" does not have the necessary licence, it can be concluded that the Counterparty - the
Cyprus company "QB Capital CY LTD" acted unlawfully by entering into agreements on the provision of direct access
services to international stock markets with the Client. The necessity to obtain a licence to provide investment
services is a requirement of the current legislation of the European Union (EC). In particular, Article 6 of Directive No.
2011/61/EC of the European Parliament and of the Council of 08 June 2011 on Alternative Investment Fund Managers
(as amended) requires EU Member States to ensure that managers of alternative investment funds conduct their
activities only with a licence (permit) issued to the manager by the relevant EU Member State in accordance with the
requirements of the AIFM Directive. The AIF Directive defines the terms "alternative investment fund" and alternative
investment fund manager in the following very broad terms: "Alternative investment fund" means "any pooled
investment vehicle, including its sub - funds (collects money from several investors in order to invest it with a specific
strategy in favour of the investors; is not required to obtain a permit (licence) in accordance with Article 5 of Directive
2009/65/EG". The agreements between the Client and the Counterparty - the Cypriot company "QB Capital CY LTD"
explicitly stipulate that the Counterparty is obliged to implement the trading strategy by placing the funds received
from the Client and from other clients on the "master accounts" of the Counterparty. The Counterparty - the Cyprus
company "QB Capital CY LTD" is an alternative investment fund manager and thus its activities are subject to
mandatory licensing also in accordance with the AIFM Directive, unless one of the exemptions provided for in the AIFM
Directive is applicable (there is no reason to believe that such exemptions are applicable in the provided information
and Documents). Such activities, if carried out by a legal entity established in the territory of the Russian Federation,
would also be subject to mandatory licensing in accordance with Article 39 of Federal Law No. 39 - FZ dated 22 April
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1996 "On the Securities Market". The use of a scheme of activities in which one Counterparty - the Russian company
QBIEF IK LLC acts only as an "attorney" in respect of the services of another Counterparty - the Cypriot company QB
Capital CY LTD, in general has signs of bad faith, as it can be assumed that such a scheme was developed to
circumvent the requirements for licensing of such activities in the Russian Federation. The activity of the
Counterparty - the Cypriot company "QB Capital CY LTD" is illegal, as it violates the requirements for compulsory
licensing in the Republic of Cyprus and the European Union. The Counterparty - Russian company QB Capital CY LTD is
also responsible for the illegality and bad faith of the actions described in the section above. This follows, inter alia,
from the fact that both Counterparties have the following indicia of affiliation: 1) Agreements on the provision of
services of direct access to international stock markets No. 2004 - 15/IMR dated 03.02.2015 and No. 2070 - 15/IMR
dated 24.02.2015 and related Agreements on the provision of "Trust Management" services (Counterparty: Russian
company LLC IK QUBIEF) were signed by one and the same individual - Munaev Zelimkhan Visaitovich. At the same
time, Munaev Zelimkhan Visaitovich is a member of the management (is the managing director) of the group of the
company "QBEEF" and, according to the data of the Unified State Register of Legal Entities as of 04.12.2017, is a
participant owning 6 % of the participation interest of the Limited Liability Company "QBEEF GROUP" (OGRN
1107746391532), which, according to the data of the Unified State Register of Legal Entities as of 04.12.2017, is the
only participant of the Counterparty - the Russian company IK QUBIEF LLC; 2)Additional Agreement No. 1 to the
Agreement on provision of services of direct access to international stock markets No. 2070 - 15/IMR dated 24.02.2015,
as well as Additional Agreement No. 1 to the Agreement on rendering services of direct access to international stock
markets No. 2004 - 15/IMR dated 03.02.2015 were signed on the part of the Counterparty - Cyprus company "QB
Capital CY LTD" by Ms Elena Vyacheslavovna Gorobets. Gorobets Elena Vyacheslavovna, in turn, according to the data
of the Unified State Register of Legal Entities as of 04.12.2017, is the General Director of Limited Liability Company "QB
GROUP" (OGRN 1107746391532), which according to the data of the Unified State Register of Legal Entities as of
04.12.3) As follows from the Documents, in part, from the agreements signed by the Client and the Counterparties, as
well as from the correspondence (cover letters/emails) when submitting reports of the Counterparty - the Cypriot
company "QB Capital CY LTD", members of the management bodies of the company "QB Capital CY LTD" never
contacted the Client. According to the information received from the Client, the whole negotiation process was
conducted exclusively through the representatives of QB Capital CY LTD; 4) The similarity of the names of the
companies - Counterparties testify to their affiliation, as the English abbreviation "QB" is pronounced (and in the
Russian language is read) as "QUBI", which is the main element of the names of both the Counterparty - the Russian
company LLC IC QUBIEF and its sole participant Limited Liability Company QUBI GROUP. Signs of bad faith of the
Counterparties are also present in their actions, in particular, in the refusal of IK QBIEF LLC to provide the Client with
reports and information on nominee holders of securities, which would have allowed to double - check the reliability
of the information indicated in the reports of the Counterparties about the securities declared by the company "QB
Capital CY LTD" as acquired at the expense of the Client. According to the affidavit of the private bailiff, Mr. Giannakiss
Ktorides, signed under oath on 3 November 2017, the Counterparty, the Cypriot company "QB Capital CY LTD" is not
present at its official address, i.e. the bailiff was unable to find any officers or other representatives of this company,
nor did he find any signs at all indicating the physical presence of this company at its official address. As a result, the
bailiff was unable to serve on the Counterparty, the Cypriot company QB Capital CY LTD, the court documents for civil
action No. 2242/2021, filed with the District Court of Nicosia. According to the letter of the Ministry of Energy, Trade,
Industry and Tourism of the Republic of Cyprus dated 30 October 2017, the Counterparty - the Cypriot company "QB
Capital CY LTD" did not file annual financial statements for the years 2014 - 2017, which is an indication that this
Cypriot company was no longer carrying out financial and economic activities in February and March 2015, i.e. at the
time when the representatives of LLC IC QBIEF signed the relevant agreements with the Client on behalf of the Cypriot
company "QB Capital CY LTD". Thus, the representatives of the Russian company QB - CYBIEF LLC misled the Client
about the fact that he concludes a contract with a Cypriot company carrying out financial and economic activities,
although there are indications (absence at the official address, failure to submit annual reports since 2014) that this
organisation does not actually carry out financial and economic activities. The contractual structure that was offered
to the Client by the representatives of IC QUBIEF LLC, the content of a number of provisions of the agreements and
violation of a number of circumstances by IC QUBIEF LLC indicate the presence of signs of bad faith on the part of IC
QUBIEF LLC. The Agreement on provision of "Trust Management" services in accordance with the Agreement on
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provision of direct access services to international stock markets No. 2014 - 15/IMR dated 03.02.2015 (Account
002014), as well as the Agreement on provision of "Trust Management" services in accordance with the Agreement on
provision of direct access services to international stock markets No. 2070 - 15/IMR dated 24.03.2015 (Account 002070)
offered to the Client for signing, misled the Client, as the title referred to "trust management" services. At the same
time, it does not follow from the content of the agreement that it meets the features of a trust management
agreement, as provided for in Chapter 53 of the Civil Code of the Russian Federation, which regulates the issues of
trust management of property, and, respectively, in relation to securities, falling under the regulation of the Federal
Law dated 22.04.1996 No. 39 - FZ (ed. 25.11.2017) "On the Securities Market" and the control of the Central Bank of
the Russian Federation in terms of securities management activities. Moreover, clause 3.2 of the Agreement directly
indicates a different legal relationship of the parties, in particular, that "this Agreement in accordance with clause 5.7
of the Agreement is an Assignment Agreement concluded in accordance with the requirements of Chapter 49 of the
Civil Code of the Russian Federation". At the same time, clause 5.5.7 of the Agreement on provision of direct access
services to international stock markets No. 2014 - 15/IMR dated 03.02.2015 (Account 002014), as well as the
Agreement on provision of direct access services to international stock markets No. 2070 - 15/IMR dated 24.03.2015
(Account 002070), provides for the Client's right to transfer its rights to manage the trading account (which, as will be
further described in the next paragraph, the Client does not actually own) to a third party, and such transfer was to be
made "in accordance with a trust management agreement executed in accordance with the requirements of the
legislation of the country of residence of such third party". Thus, LLC IC QUBIEF concluded an Agreement with the
Client, which by its nature does not comply with the terms of the Agreement and the intention of the Client, who
believed that he was concluding a securities trust management agreement with a professional participant of the
securities market, whose activities are regulated and supervised by the Central Bank of the Russian Federation.
According to the definition in clause 2 of the Agreements concluded by the Client with the Counterparty - the Russian
company LLC IC QUBIEF, the term "Trading Account" is defined as - an account, the owner of which (the Principal) has
entered into a written confirmation of the right of another person (the Attorney) to manage funds on the account
within the framework of a trading strategy for trading operations". However, as a result of this "granting" of an
account, the Client in turn "agrees to have his trading account joined to QB Capital CY LTD's master accounts opened
with brokers. Accordingly, even if the Counterparties had fulfilled all their obligations, the Client would not own his
own trading account, but the securities would still be in the master accounts of the Counterparty - the Cyprus
company QB Capital CY LTD. The Counterparty - the Russian company QB Capital CY LTD, using the above definition of
the term "Trading Account" in its sample contract for the provision of "Trust Management" services, misled the Client
as to the fact that he would be the owner of the trading account, that he will be the owner of trading accounts,
although, in fact, according to the agreements with the Counterparty - the Cyprus company "QB Capital CY LTD", not
the Client, but the Cyprus company "QB Capital CY LTD" is the owner of "master accounts", to which the Client's
trading accounts are only "joined". Apparently, the norm contained in clause 2.2 of the agreements that "each account
is insured by the Federal Investor Protection Corporation as part of the mandatory deposit insurance system based on
the Securities Investor Protection Act of 1970" was intended to create an appearance of additional "comfort" for the
Client. According to the information on the official website of the Federal Investor Protection Corporation
(SECURITIES INVESTOR PROTECTION CORPORATION - SIPC), only deposits made by clients of SIPC member
companies can be insured, and not deposits to the Client's account. At the same time, neither IK QBIEF LLC nor the
Cypriot company QB Capital CY LTD are specified in the list of SIPC participants posted on the official website of SIPC.
In addition, in accordance with the "Trustee Services Agreement" under the Direct Access to International Stock
Markets Agreement No. 2014 - 15/IMR dated 03.02.2015 (Account 002014), as well as in accordance with the
Agreement on Provision of "Trust Management" Services in accordance with the Agreement on Provision of Direct
Access to International Stock Markets No. 2070 - 15/IMR dated 24.03.2015 (Account 002070), the definition of "Trading
Account (Principal's Account)" expressly provides that the account owner is the Client "who has confirmed the rights
of another person (the Attorney) to manage the funds in the account...". According to the information received from
the Client, no actions were taken by the Counterparty to "grant", "join" or simply open any accounts, and no
additional documents related to these accounts were not provided or signed by the Client, which gives grounds to
believe that, in fact, no accounts were ultimately owned or managed by the Client. The Company LLC IC QUBIEF has
violated a number of obligations under the concluded agreements. In particular, the following obligations were
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violated: - obligations of cl. 10.3 of the Agreement on providing the Client with monthly reports. According to the
information received from the Client, the company "QUBIEF" LLC did not provide the Client with any reports; - the
obligation of clause 8.3 of the Agreement on transfer of funds by the company "QUBIEF" LLC to the Client on
condition of the Client's prior notification. The Client has repeatedly notified "QUBIEF" IK LLC about transfer of all its
funds, at the same time, according to the information received from the Client, "QUBIEF" LLC has not fully fulfilled its
obligations; - obligation of clause 12.1 of the Agreement on notification of the parties in case of change of any data of
the parties. IK "QUBIEF" LLC did not notify the Client about the change of the company name from "Qubey Finance"
LLC to IK "QUBIEF" LLC. All of the above examples clearly demonstrate that IK QUBIEF LLC acted in bad faith and
unlawfully. Based on the provided information and Documents (in terms of agreements between Stepanov S.V., on
the one hand, and the company IK QYUBIEF LLC and QB Capital CY LTD, on the other hand, as well as reports
submitted to Stepanov S.V., within the framework of these agreements) it is impossible to establish a legal connection
between Stepanov S.V. as a subject of law and the object of law - shares of the companies specified in the reports of
the companies IK QUBIEF LLC and QB Capital CY LTD. Taking into account the legislation of the Russian Federation
and the European Union in the field of securities and regulation of securities management services, in the legal
relations between Stepanov S.V., on the one hand, and the companies of IC QUBIEF LLC and QB Capital CY LTD, on the
other hand, there are signs that the companies of IC QUBIEF LLC and QB Capital CY LTD, when concluding agreements
or fulfilling obligations under such agreements, acted in bad faith and unlawfully. In part: a) in accordance with the
legislation of the Republic of Cyprus and the European Union, the company "QB Capital CY LTD" carries out its
activities without the necessary licences (permits); b) there are reasons to believe that the contractual scheme used
by the companies LLC IC "QBIEF" and "QB Capital CY LTD" was designed to circumvent the requirements for licensing
of such activities in the Russian Federation and that such unfair actions were aimed at misleading Stepanov S. V. in
the conclusion of the agreements.V. was designed to circumvent the licensing requirements for such activities in the
Russian Federation and that such unfair actions were aimed at misleading Stepanov S. V. when concluding
agreements with these structures; c) the contractual structure proposed to Stepanov S. V. by representatives of QY
LTD, d) there are signs of bad faith in the actions of QB Capital CY LTD in refusing to provide Stepanov S.V. with the
reports stipulated by the Agreements between QB Capital CY LTD and Stepanov S.V.; e) there are signs of bad faith in
the actions of QB Capital CY LTD, in part, information on nominal holders of securities, which would allow to double -
check the reliability of the information indicated in the reports of "QB Capital CY LTD" company about the securities
declared by "QB Capital CY LTD" company as acquired at the expense of Stepanov S.V.; e) the contractual structure
proposed to Stepanov S.V. by the representatives of IK "QBIEF" LLC, e) the contractual structure offered to Stepanov
S.V. by the representatives of "QBIIEF" LLC, as well as the content of a number of provisions of the agreements
testifies to the presence of signs of bad faith of the companies "QBIIEF" LLC and "QB Capital CY LTD"; f) "QBIIEF" LLC,
using the definition of the term "Trading Account" in its sample agreement on the provision of "Trust Management"
services, misled Stepanov S. V. with regard to the fact that the "QB Capital CY LTD" was not a trust management
company.V. misled Stepanov S.V. about the fact that he would be the owner of trading accounts, although, in fact,
according to the agreements of the Cyprus company "QB Capital CY LTD" is the owner of "master accounts", to which
trading accounts of the Client are only joined; g) representatives of the company LLC IC "QBIEF" misled Stepanov S.V.
misled Stepanov S.V. about the fact that he concludes an agreement with a Cypriot company carrying out financial
and economic activities, although there are indications (absence at the official address, failure to submit annual
reports since 2014) that this organisation, in fact, does not carry out financial and economic activities (and already at
the time of signing agreements with Stepanov S. V. did not); g) the representatives of the company IK "QUBIEF" Ltd.h)
according to the information on the official website of the Federal Corporation for the Protection of Rights of Interests
(SECURITIES INVESTOR PROTECTION CORPORATION - SIPC), only deposits made by clients of SIPC member
companies can be insured, and not deposits made by clients of foreign partners of SIPC member companies that are
not SIPC members themselves. At the same time, neither IC QUBIEF LLC nor the Cypriot company QB Capital CY LTD
are specified in the list of SIPC participants; and) no actions were taken by IC QUBIEF LLC and QB Capital CY LTD to
"provide", "join" or open any accounts and no additional documents related to these accounts were provided to
Stepanov S. V. or signed, which gives Stepanov S. V. the right to sign them.V. or signed, which gives grounds to believe
that, in fact, no accounts were ultimately owned or disposed of by Stepanov S.V.; conclusion of the specialist of AMS
Group LLC on determination of financial efficiency of trust management within the framework of Agreements on
763
provision of services of direct access to international stock markets concluded between QB Capital CY LTD and Sergey
Vitalievich Stepanov and Agreements on provision of "Trust Management" services, concluded between QB Capital CY
LTD and Sergey Vitalievich Stepanov, from which it follows that the trust management of funds, as well as the
performance of duties under the agreement with Sergey Vitalievich Stepanov as a trustee on the part of QB Capital CY
LTD should be considered as unsatisfactory. As a consequence, the violation of the provisions of the concluded
agreements on the provision of "Trust Management" services between LLC "Qubey Finance" and Stepanov S.V., in
terms of clause 1.2 of Annex No. 1 to the Agreement on the provision of "Trust Management" services in accordance
with the Agreement on the provision of direct access to international stock markets No. 2004 - 15/IMR dated
03.02.2015 (Account 002004) and No. 2070 - 15/ IMR dated 24.03.2015 (Account 002070) (Investment Declaration):
"Objectives of investment of funds: Achieving the greatest commercial efficiency in the utilisation of the Trustee's
property";
Specialist's opinion on the analysis of the conclusion of computer - technical expertise, responses to court requests
from Joint Stock Company "Regional Network Information Centre", Limited Liability Company "Capital Telecom"
dated 08.12.2017, from which it follows that the following IP addresses were used to send electronic mail messages:
94.243.131.82; 94.243.131.84; 94.243.131.86; 94.243.131.92; 94.243.143.50; 94.243.143.52; 94.243.143.55;
94.243.143.59. Using technical information, service headers of emails established in the Expert Conclusion, it is
concluded that the specified IP addresses were used to send emails from the email addresses: *@qbfin.ru - from "19"
December 2014 to "01" November 2017; *@ qbcap.com - from "10" June 2016 to "31" October 2017. It follows from
the court request to Capital Telecom LLC and the Response from Capital Telecom LLC that the above IP addresses are
used to access the information and telecommunications network Internet using equipment located at the address:
Moscow, Presnenskaya Naberezhnaya, 8, p.1, South Tower, 9th floor, MFC "Capital City". It was established that during
the above periods e - mail was sent from the computer network located on the 9th floor of the South Tower of the
Capital City MFC. In the expert's report it is noted that the electronic mail messages sent from the mail addresses
*@qbfin.ru, *@qbcap.com have DKIM - a method of authentication of electronic mail messages designed to prevent
forgery of messages sent by e - mail. DKIM allows you to verify that an email was actually sent from a specified sender
address. One of the components of DKIM is an electronic digital signature (hereinafer referred to as "EDS"). The
presence of an EDS eliminates the possibility of falsification of electronic mail messages. To specifically attach an EDS
to an electronic mail message, the appropriate configuration of the domains qbfin.ru, qbcap.com is required. It has
been established that the electronic mail messages incoming to [email protected] specified in the Expert
Conclusion were indeed sent by persons who at the time of sending had access to the infrastructure associated with
the domain names qbfin.ru, qbcap.com, and that the said domains were properly configured. The expert opinion
notes that the mail server mx.qbfworld.com was used to send electronic mail messages from the addresses
*@qbfin.ru, *@ qbcap.com. Using technical information, service headers of e - mails established in the Expert's
Conclusion, it is concluded that the mail server mx.qbfworld.com was used to send e - mails from the mail addresses:
*@qbfin.ru - from "10" January 2017 to "01" November 2017; *@ qbcap.com - from "10" August 2016 to "31" October
2017. In order to use the domain name qbfworld.com for the purposes of organising a mail server, it is necessary to
configure it accordingly, which is performed by the Administrator (owner) of the domain name. It follows from the
response from RSIC JSC that the domain name qbfworld.com was registered on 21 June 2016. The administrator of
the domain name qbfworld.com is the company QBF GROUP LLC. It has been established that there are indications of
the use of infrastructure for sending electronic mail messages from the addresses *@qbfin.ru, *@ qbcap.com. Taking
into account the information contained in the Response from JSC "RSIC", it was found that the administrator of the
domain name qbfworld.com used for sending e - mails is QBG GROUP LLC. The domain name is configured by the
Domain Name Administrator, a person who determines the procedure for the use of the domain. The right to manage
the domain shall be established by the domain name registration agreement. In order to manage the domain name,
the Administrator shall log in to the personal cabinet of the domain name registrar. It follows from the response from
RSIC JSC that RSIC JSC is indeed the registrar of the domain names qbfin.ru, qbcap.com. qbfworld.com. It follows
from the response from RSIC JSC that the Administrator of the domain name qbfin.ru is the company QUBI GROUP
LLC. It follows from the response from RSIC JSC that the domain names were managed, including IP addresses:
94.243.143.50; 94.243.131.82; 94.243.131.92. Information on domain name owners is placed in publicly available
764
databases, obtaining information is possible with the help of a number of WHOIS services. In order to hide the
registration data of the domain name administrator, the registrar may provide various additional services. RSIC JSC
provides WHOIS - PROXY service, which allows to change the domain registration data displayed in publicly available
sources. It follows from the response from JSC "RSIC" that the "WHOIS - PROXY" service to conceal registration data
was activated on "16" November 2017 from the IP address 94.243.143.50. It was established that the Administrator of
the domain names qbfin.ru., qbcap.com., qbfworld.com is one and the same legal entity QUBI GROUP LLC,
management of the domain names qbfin.ru., qbcap.com., qbfworld.com., as well as activation of the WHOIS - PROXY
registration data concealment service was performed from the computer network located on the 9th floor of the
South Tower of the Capital City MFC;
(Vol. No. 88, pp. 4 - 209)
- Protocol of examination of items dated 29 June 2021, namely, a CD - R disc provided by the Federal Tax Service No.
30 for Moscow containing information on legal entities used by members of a criminal association (criminal
organisation) to embezzle citizens' money, during which the documents contained on the disc, which are relevant to
the criminal case, were examined, printed and attached to the materials of the criminal case;
(Vol. No. 158, pp. 4 - 6)
- other documents - documents submitted by the Federal Tax Service No. 30 for Moscow in relation to 168 Kvartal LLC
(INN 7703769272), controlled and affiliated to the participants of the criminal association (criminal organisation),
according to which the Company is located at 8/1 Presnenskaya Naberezhnaya Street, Moscow, and was established
on 30 May 2012, Roman Valeryevich Shpakov, Irina Nikolayevna Shpakova, Valery Pavlovich Feoktistov are the
participants of the Company; Roman Valeryevich Shpakov, Irina Nikolayevna Shpakova, Valery Pavlovich Feoktistov
(the current General Director) were (are) the General Directors of the Company;
(Vol. No. 158, pp. 7 - 57)
- other documents - documents submitted by the Federal Tax Service No. 30 for the city of Moscow in respect of LLC
"701" (Taxpayer Identification Number 7703456375), controlled and affiliated to the participants of the criminal
association (criminal organisation), according to which the Company is located at the address: 8/1 Presnenskaya
Embankment, Moscow, and was established on 17 May 2018, the Company's participant is a foreign legal entity -
private limited liability company Bfinvestments registered on 21.11.2017, the General Director of the Company is (was)
Sergey Vladimirovich Agafonov (current General Director);
(Vol. No. 158, pp. 58 - 113)
- other documents - documents submitted by the Federal Tax Service No. 30 for the city of Moscow in relation to LLC
"702" (Taxpayer Identification Number 7703474800) controlled and affiliated to the participants of the criminal
association (criminal organisation), according to which the Company was located at the following addresses: 8/1
Presnenskaya Naberezhnaya Embankment, Moscow, and 16/10 Kirov St., Moscow Oblast, Khimki, 16/10 Kirov Street,
Khimki, was established on 19 April 2019, the participant of the Company is Victoria Viktorovna Smirnova, the General
Director of the Company is (was) Victoria Viktorovna Smirnova (current General Director);
(Vol. No. 158, pp. 114 - 185)
- other documents - documents submitted by the Federal Tax Service No. 30 for the city of Moscow in relation to the
LLC "776" (Taxpayer Identification Number 6658523875) controlled and affiliated to the participants of the criminal
association (criminal organisation), according to which the Company is located at the following address: Sverdlovsk
region, Ekaterinburg, Boris Yeltsin str. a, established on 15 March 2019, the Company's participant is Tatyana
Nikolayevna Kozhevnikova, the General Director of the Company was (is) Tatyana Nikolayevna Kozhevnikova (current
General Director);
765
(Vol. No. 158, pp. 186 - 242)
- other documents - documents submitted by the Federal Tax Service No. 30 for Moscow in relation to Ver - Mont LLC
according to which the Company is located at the address: Moscow, Podbelsky Proezd 4, 3/19, established on 24
October 2014, Nadezhda Sergeyevna Sloyeva and Ekaterina Sergeyevna Zherdeva are the participants of the
Company; Nadezhda Sergeyevna Sloyeva and Ekaterina Sergeyevna Zherdeva (current General Director) were (are)
the General Directors of the Company;
(Vol. No. 159, pp. 1 - 75)
- other documents - documents submitted by the Federal Tax Service No. 30 for Moscow in relation to K - Consulting
LLC (Taxpayer Identification Number 7703471373), controlled and affiliated to the participants of the criminal
association (criminal organisation), according to which the Company is located at the following address: 8/1
Presnenskaya Embankment, Moscow, formed on 18 February 2019, the Company's participant is Ivan Alexandrovich
Polibin, the General Director of the Company was (is) Ivan Alexandrovich Polibin (current General Director);
(Vol. No. 159, pp. 76 - 143)
controlled and affiliated to the participants of the criminal association (criminal organisation) LLC "KP Queue 2"
(Taxpayer Identification Number 7702459550), according to which the Company is located at the address: Moscow,
Prospekt Mira d. 19/1, was formed on 24 December 2018, the Company's participant is Irina Nikolaevna Shpakova, the
General Director of the Company was (is) Irina Nikolaevna Shpakova (current General Director);
(Vol. No. 159, pp. 144 - 213)
controlled and affiliated to the participants of the criminal association (criminal organisation) LLC "KP Queue 3"
(Taxpayer Identification Number 7704471087), according to which the Company was located at the following
addresses: 20 Efremova str. in Moscow and Moscow, Zelenograd, 1651, formed on 10 January 2019, the
participant of the Company is Irina Nikolaevna Shpakova, the General Director of the Company was (is) Irina
Nikolaevna Shpakova, (current General Director);
(Vol. No. 160, pp. 1 - 68)
controlled and affiliated to the participants of the criminal association (criminal organisation) LLC "KP Queue 4" (TIN
9731017278), according to which the Company is located at the address: 32 2/1 Krylatskie Holmy St., Moscow, formed
on 29 November 2018, the participant of the Company is Irina Nikolayevna Shpakova, the General Director of the
Company was (is) Irina Nikolayevna Shpakova (acting General Director);
(Vol. No. 160, pp. 69 - 137)
- other documents - documents submitted by the Federal Tax Service No. 30 for Moscow in relation to LLC KF Estate
SPB (Taxpayer Identification Number 7840472851), controlled by and affiliated with the participants of the criminal
association (criminal organisation), according to which the Company was located at the following addresses: St.
Petersburg, Marata Street, 60 letter a, St. Petersburg, Maloohtinsky Prospekt, ul. 64 letter b and St. Petersburg,
Degtyarny pereulok, d. 11b, established on 04 July 2012, the participants of the Company are Roman Valeryevich
Shpakov, Evgeny Nikolayevich Zvarin, the General Directors of the Company were (are) Vladimir Sergeevich
Pakhomov, Evgeny Nikolayevich Zvarin, Alexander Veniaminovich Diordits (current General Director);
(Vol. No. 160, pp. 138 - 205)
- other documents - documents submitted by the Federal Tax Service No. 30 for Moscow in relation to Finbutik LLC
(Taxpayer Identification Number 7731610156), controlled and affiliated to the participants of the criminal association
766
(criminal organisation), according to which the Company was located at the following addresses: 4/3 Gerasima Kurina
Street, Moscow, 18/1 Novinsky Boulevard, Moscow, and 12 Presnenskaya Embankment, Moscow, was
established on 12 December 2008, the participants of the Company are LLC Agrofirma Tsvetkovskoye, LLC Trading
House Rodnoye Pole, LLC M4 Invest, LLC Leshchev Maxim Vadimovich, the general directors of the Company are
(were) Suzdaltsev Gennady Viktorovich, Lazarenko Ekaterina Gennadyevna, Lobanov Konstantin Ivanovich, Melnikova
Maria Alexandrovna (acting general director);
(Vol. No. 161, pp. 1 - 54)
- other documents - documents submitted by the Federal Tax Service No. 30 for Moscow in relation to F -
Management LLC (INN 7703448776), controlled and affiliated to the participants of the criminal association (criminal
organisation), according to which the Company is located at the address: 8/1 Presnenskaya Naberezhnaya, Moscow,
and was established on 13 April 2018, the participants of the Company are QBEF JSC, QBEF Investment LLC, F -
Experts LLC, Roman Valeryevich Shpakov, the General Director of the Company is (was) Vladimir Georgievich Frolov
(current General Director);
(Vol. No. 161, pp. 55 - 114)
- other documents - documents submitted by the Federal Tax Service No. 30 for Moscow in relation to Format
Development LLC (Taxpayer Identification Number 7708243109), controlled by and affiliated with the participants of
the criminal association (criminal organisation), according to which the Company is located at the following
addresses: 1 Krasnoselsky Pereulok 1, 1 Krasnoselsky Pereulok 3, Moscow and 46 Parkovaya Street, Moscow, the
participants of the Company are M1 Invest LLC, Golovanova Dolores Vasilievna, Cholovanova, Cholores Vasilievna, and
M1 Invest LLC./46, Parkovaya Street 5, Moscow, was established on 24 December 2014, the participants of the
Company are M1 Invest LLC, Dolores Vasilievna Golovanova, Tatiana Nikolayevna Cherezova, Dmitry Sergeevich
Lepeshkin, and the General Director of the Company is (was) Dmitry Alexandrovich Golovanov (current General
Director);
(Vol. No. 161, pp. 115 - 170)
Technologies LLC (INN 7703448769), controlled and affiliated to the participants of the criminal association (criminal
organisation), according to which the Company is located at the address: 8/1 Presnenskaya Naberezhnaya Street,
Moscow, and was established on 13 April 2018, the participants of the Company are QBF JSC, QBF Asset Management
LLC, F - Management LLC, Roman Valeryevich Shpakov, the General Director of the Company is (was) Vladimir
Georgievich Frolov (current General Director);
(Vol. No. 161, pp. 171 - 239)
- other documents - documents submitted by the Federal Tax Service No. 30 for Moscow in relation to Q-BROKER LLC
(TIN 9703003668), controlled and affiliated to the participants of the criminal association (criminal organisation),
according to which the Company is located at the address: 8/1 Presnenskaya Naberezhnaya, Moscow, and was
established on 23 October 2019, the participants of the Company are JSC FG QBF, the General Directors of the
Company are (were) Roman Valeryevich Shpakov, Yuri Nikolayevich Orlov (acting General Director);
(Vol. No. 162, pp. 1 - 68)
Technologies LLC (Taxpayer Identification Number 7725726949), which is controlled by and affiliated with participants
of the criminal association (criminal organisation), according to which the Company is located at the following
addresses: 1/11 Partiyny Pereulok, Moscow, 8 Presnenskaya Naberezhnaya, Moscow and 12 Presnenskaya
Naberezhnaya, Moscow, formed on 20 June 2011./1 and 12 Presnenskaya Embankment, Moscow, was established on
20 June 2011, the participants of the Company are SRN LLC, QBEF Group LLC, Irina Sergeevna Nesterova, Vladimir
767
Georgievich Frolov, the general directors of the Company are (were) Irina Sergeevna Nesterova, Elena Vyacheslavovna
Gorobets, Vladimir Georgievich Frolov (acting general director);
(Vol. No. 162, pp. 69 - 135)
- other documents - documents submitted by the Federal Tax Service No. 30 for Moscow in relation to F - Experts LLC
(criminal organisation), according to which the Company is located at the following address: 8 Presnenskaya
Naberezhnaya, Moscow/1, formed on 22 December 2017, the participants of the Company are QBF JSC, QBF Asset
Management LLC, F - Management LLC, Frolov Vladimir Georgievich, the General Director of the Company is (was)
Frolov Vladimir Georgievich (current General Director);
(Vol. No. 162, pp. 136 - 199)
- other documents - documents submitted by the Federal Tax Service No. 30 for the city of Moscow in relation to LLC
"Venture Finance Centre" (INN 7734682254), controlled and affiliated to the participants of the criminal association
(criminal organisation), according to which the Company is located at the following addresses: 12 Presnenskaya
Naberezhnaya Naberezhnaya, Moscow and 2 Marshala Zhukova Ave. and 2, Marshala Zhukova Ave., Moscow, formed
on 18 June 2012, the participants of the Company are Investment Company Russian Financial Group LLC and
Management Company Center LLC, the general directors of the Company are (were) Irina Anatolievna Bolshakova and
Nikolay Valeryevich Mikhailov (acting general director);
(Vol. No. 163, pp. 1 - 60)
- other documents - documents submitted by the Federal Tax Service No. 30 for the city of Moscow in relation to
Rentinvest LLC (INN 7703423933), controlled and affiliated to the participants of the criminal association (criminal
organisation), according to which the Company is located at the following addresses: 8/1 Presnenskaya Embankment,
Moscow, 12 Presnenskaya Embankment, Moscow, and Moscow region, Khimki, Prospect Melnikova, 19, was
established on 03 March 2017, the participants of the Company are Irina Valeryevna Levina, Andrey Stepanovich
Berezka, Viktoria Viktorovna Smirnova, the General Directors of the Company are (were) Irina Valeryevna Levina,
Andrey Stepanovich Berezka, Viktoria Viktorovna Smirnova, (acting General Director);
(Vol. No. 163, pp. 61 - 132)
controlled and affiliated to the participants of the criminal community (criminal organisation) JSC "Rif" (INN
5047241522), according to which the Company is located at the address: 10/1 Kirov Street, Khimki, Moscow Region,
formed on 08 July 2020, the participant of the Company is Yuri Vasilyevich Shaban, the General Director of the
Company is (was) Yuri Vasilyevich Shaban (acting General Director);
(Vol. No. 163, pp. 133 - 196)
- other documents - documents submitted by the Federal Tax Service No. 30 for the city of Moscow in relation to OOO
Severspetsstroy (TIN 7703769579), controlled and affiliated to the participants of the criminal association (criminal
organisation), according to which the Company is located at the following addresses: 42 Gruzinskaya St., Moscow,
Moscow, 11 Vernadskogo Ave. /19 and Moscow, Presnenskaya Naberezhnaya, 12, was established on 04 June
2012, the participants of the Company are Roman Valeryevich Shpakov, Dmitry Evgenyevich Belov, the general
directors of the Company are (were) Roman Valeryevich Shpakov, Dmitry Evgenyevich Belov (acting general director);
(Vol. No. 164, pp. 1 - 66)
- other documents - documents submitted by the Federal Tax Service No. 30 for Moscow in relation to Simon Jesso
association (criminal organisation), according to which the Company is located at the following addresses: 42
Gruzinskaya Street, Moscow, Presnenskaya Embankment, 12, and 4b, Moscow, 5 Parkovaya Street, formed on 04 June
768
2012 and Moscow, 5 - ya Parkovaya str. 4b, was established on 04 June 2012, the participants of the Company are
Roman Valeryevich Shpakov, Valery Evgenyevich Arsenchuk, Denis Vitalyevich Sorokin, the general directors of the
Company are (were) Roman Valeryevich Shpakov, Valery Evgenyevich Arsenchuk (acting general director);
(Vol. No. 164, pp. 67 - 129)
- other documents - documents submitted by the Federal Tax Service No. 30 for Moscow in relation to Syntez LLC
(taxpayer identification number 7708270984), which is controlled and affiliated with the participants of the criminal
association (criminal organisation), according to which the Company is located at the following addresses: 3, 1st
Krasnoselsky Lane, Moscow, and 6/2, Lower Kislovsky Lane, Moscow, formed on 30 October 2015. 3, 1st
Krasnoselsky Lane, 3 and 6/2, Lower Kislovsky Lane, Moscow, was established on 30 October 2015, the participants of
the Company are a private limited liability company "Sintez", Elena Vyacheslavovna Gorobets, the general directors of
the Company are (were) Elena Vyacheslavovna Gorobets, Vladimir Alexandrovich Zarechnev, Gleb Sergeyevich Trishin
(acting general director);
(Vol. No. 164, pp. 130 - 187)
- other documents - documents submitted by the Federal Tax Service No. 30 for the city of Moscow in relation to S -
Control LLC (Taxpayer Identification Number 5047245990), controlled and affiliated to the participants of the
criminal association (criminal organisation), according to which the Company is located at the address: 31/2
Molodezhnaya St., Khimki, Moscow region, formed on 23 November 2020, the Company's participant is Roman
Valeryevich Shpakov, the Company's General Director is (was) Valery Borisovich Belov (acting General Director);
(Vol. No. 164, pp. 188 - 242)
- other documents - documents submitted by the Federal Tax Service No. 30 for Moscow in relation to JSC Financial
Group QBIF (Taxpayer Identification Number 7703466327), controlled and affiliated to the participants of the criminal
Presnenskaya Embankment, Moscow and Moscow, Presnenskaya Embankment, 8/1, was established on 17
October 2018, the Company's participant is Roman Valeryevich Shpakov, the Company's CEO is (was) Roman
Valeryevich Shpakov (current CEO);
(Vol. No. 165, pp. 1 - 50)
- other documents - documents submitted by the Federal Tax Service No. 30 for Moscow in relation to M4 Invest LLC
(criminal organisation), according to which the Company is located at the following addresses: 2 Semyonovskaya
Naberezhnaya, Moscow, and 12 Presnenskaya Naberezhnaya, Moscow, formed on 15 October 2012. /1 and 12
Presnenskaya Embankment, Moscow, formed on 15 October 2012, the participants of the Company are Roman
Valeryevich Shpakov, Dmitry Sergeevich Lepeshkin, Maxim Mikhailovich Khripunov, the General Director of the
Company is (was) Dmitry Sergeevich Lepeshkin (current General Director);
(Vol. No. 165, pp. 51 - 121)
- other documents - documents submitted by the Federal Tax Service No. 30 for the city of Moscow in relation to JSC
Marketplace Moi Finansy (INN 9703012630), a company controlled by and affiliated with participants of a criminal
association (criminal organisation), according to which the Company is located at the address: 8/1 Presnenskaya
Naberezhnaya, Moscow, was established on 03 June 2020, the Company's participant is Rinat Feliksovich Amerov, the
Company's General Director is (was) Rinat Feliksovich Amerov (current General Director);
(Vol. No. 165, pp. 122 - 191)
- other documents - documents submitted by the Federal Tax Service No. 30 for Moscow in relation to LLC Profi (INN
7703447860), which is controlled by and affiliated with participants of a criminal association (criminal organisation),
according to which the Company is located at 12 Presnenskaya Naberezhnaya Street, Moscow, and was established on
769
05 April 2018; the Company's participant is Nikolai Valeryevich Mikhailov; the Company's general director is (was)
Nikolai Valeryevich Mikhailov (acting general director);
(Vol. No. 165, pp. 192 - 250)
- other documents - documents submitted by the Federal Tax Service No. 30 for Moscow in relation to Millhouse
Invest LLC (Taxpayer Identification Number 5029252176), controlled and affiliated to the participants of the criminal
association (criminal organisation), according to which the Company is located at the following address: 3, Letnaya
Street, Mytishchi, Moscow Region, Russia /15, established on 19 November 2019, the participants of the Company
are Nargiz Nazimovna Kukhmazova, Anastasia Aleksandrovna Chirukhina, Tatyana Vladimirovna Sinyagina, the
general directors of the Company are (were) Sergey Vladimirovich Goltyaev, Irina Nikolaevna Ivanova (acting general
director);
(Vol. No. 166, pp. 68 - 136)
- other documents - documents submitted by the Federal Tax Service No. 30 for the city of Moscow in relation to KG
Arkhangelsky Lane, Moscow, and 8/1 Presnenskaya Embankment, Moscow, and was established on 12 May 2010,
Sergey Lvovich Kuzin, Roman Valeryevich Shpakov, Nikolay Vitalievich Modin, Zelimkhan Visaitovich Munaev, Vladimir
Sergeyevich Pakhomov, Anastasia Andreevna Ananyeva, Maxim Mikhailovich Khripunov are (were) the participants of
the Company; Sergey Lvovich Kuzin, Roman Valeryevich Shpakov, Elena Vyacheslavovna Gorobets (current General
Director) are (were) the General Directors of the Company;
(Vol. No. 166, pp. 138 - 202)
- other documents - documents submitted by the Federal Tax Service No. 30 for Moscow in relation to K - Investment
Presnenskaya Naberezhnaya Embankment, Moscow, and 8/1 Presnenskaya Embankment, Moscow, formed on 06
February 2019, the Company's participant is Ivan Alexandrovich Polybin, the General Director of the Company is (was)
Ivan Alexandrovich Polybin. and Moscow, Presnenskaya Naberezhnaya 8/1, was established on 06 February
2019, the participant of the Company is Ivan Alexandrovich Polibin, the General Director of the Company is (was) Ivan
Alexandrovich Polibin (current General Director);
(Vol. No. 167, pp. 1 - 69)
Qubey Credit LLC (Taxpayer Identification Number 7703740234), controlled and affiliated to the participants of the
criminal association (criminal organisation), according to which the Company is located at the following address: 8
Presnenskaya Naberezhnaya Street, Moscow/1, was established on 23 March 2011, the participants of the Company
are SRN LLC, Qubey Group LLC, Syuksyumov Maxim Mikhailovich, the general directors of the Company are (were)
Syuksyumov Maxim Mikhailovich, Gorobets Elena Vyacheslavovna (acting general director);
(Vol. No. 167, pp. 70 - 139)
- other documents - documents submitted by the Federal Tax Service No. 30 for Moscow in relation to QBF LLC
(Taxpayer Identification Number 7703458823), controlled by and affiliated with the participants of the criminal
Presnenskaya Naberezhnaya Naberezhnaya Street, Moscow, and 50/2 Aviamotornaya Street, Moscow, formed on 04
June 2018, the participants of the Company are QBF LLC, QBF LLC, KG LLC, Munaev Zeev Zeev. /1 and Moscow,
Aviamotornaya street 50/2, was formed on 04 June 2018, the participants of the Company are QBG LLC, KG LLC,
Munaev Zelimkhan Visaitovich, the general directors of the Company are (were) Buryakovsky Dmitry Henrikhovich,
Feoktistov Roman Valeryevich, (acting general director);
770
(Vol. No. 167, pp. 140 - 208)
- other documents - documents submitted by the Federal Tax Service No. 30 for Moscow in relation to QBF Advisery
LLC (Taxpayer Identification Number 7703426941), which is controlled and affiliated with the participants of the
criminal association (criminal organisation), according to which the Company is located at the following address: 8
Presnenskaya Naberezhnaya Naberezhnaya, Moscow/1, was formed on 02 May 2017, the participants of the Company
are, JSC QBF, Vladimir Georgievich Frolov, Natalia Vladimirovna Kochetkova, Victoria Viktorovna Smirnova, the
general directors of the Company are (were) Vladimir Georgievich Frolov, Marina Alexandrovna Tochilova, (acting
general director);
(Vol. No. 168, pp. 1 - 69)
- other documents - documents submitted by the Federal Tax Service No. 30 for Moscow in relation to QBF JSC
(criminal organisation), according to which the Company is located at the address: 8 Presnenskaya Naberezhnaya
Street, Moscow. /1, was established on 16 October 2015, the participant of the Company is Roman Valeryevich
Shpakov, the general directors of the Company are (were) Roman Valeryevich Shpakov, Maxim Mikhailovich
Khripunov (acting general director);
(Vol. No. 168, pp. 70 - 136)
controlled and affiliated to the participants of the criminal association (criminal organisation) LLC "Qusisiai"
(Taxpayer Identification Number 7708786218), according to which the Company is located at the following addresses:
3, 1st Krasnoselsky Pereulok, Moscow, and 24, Pyryeva St., Moscow, was established on 01 April 2013, the participants
of the Company are: Zotov Vladimir Alexandrovich, Munaev Zelimkhan Visaitovich, Panov Alexey Anatolievich, the
general directors of the Company are (were) Zotov Vladimir Alexandrovich, Zotova Irina Anatolievna, Marichev Alexey
Nikolaevich, Panov Alexey Anatolievich, (acting general director);
(Vol. No. 168, pp. 137 - 207)
LLC "VL - Consulting" (Taxpayer Identification Number 7706463476) controlled and affiliated to the participants of the
criminal association (criminal organisation), according to which the Company is located at the address: 28/3 Mytnaya
Street, Moscow, and was established on 17 December 2018, the participants of the Company are, limited liability
company "White Holdings Limited", Maricheva Olga Vladimirovna, general directors of the Company are (were)
Maricheva Olga Vladimirovna, Padalko Nikolay Sergeyevich, Taranukh Denis Viktorovich, (acting general director);
(Vol. No. 169, pp. 1 - 69)
Vysota LLC (Taxpayer Identification Number 7734371675), controlled and affiliated to the participants of the criminal
association (criminal organisation), according to which the Company is located at the following addresses: 35/2
Marshala Biryuzova St., Moscow, and 12 Presnenskaya Naberezhnaya St., Moscow, and was established on 04
December 2015, Sergey Aleksandrovich Kharitonov, Andrey Stepanovich Berezka, Maksim Mikhailovich Khripunov are
(were) the participants of the Company, Sergey Aleksandrovich Kharitonov, Svetlana Mikhailovna Fedorova, Andrey
Stepanovich Berezka, Maksim Mikhailovich Khripunov (current General Director) are (were) the General Directors of
the Company;
(Vol. No. 169, pp. 70 - 123)
- other documents - documents submitted by the Federal Tax Service No. 30 for the city of Moscow in relation to DV
Technologies LLC (Taxpayer Identification Number 7703442478), controlled and affiliated to the participants of the
criminal association (criminal organisation), according to which the Company is located at the following addresses: 12
Presnenskaya Naberezhnaya Naberezhnaya Street, Moscow, and 6/2 Kislovsky Lane, Moscow, 6/2, was established on
771
20 February 2018, the participants of the Company are Gleb Sergeevich Trishin, Elena Olegovna Mikheeva, the General
Directors of the Company are (were) Gleb Sergeevich Trishin, Elena Olegovna Mikheeva (acting General Director);
(Vol. No. 169, pp. 124 - 133, Vol. No. 170, pp. 1 - 44)
- other documents - documents submitted by the Federal Tax Service No. 30 for the city of Moscow in relation to M1
Invest LLC (Taxpayer Identification Number 7701367560), controlled and affiliated to the participants of the criminal
association (criminal organisation), according to which the Company is located at the following addresses: 3/3
Rubtsovskaya Embankment, Moscow, Rubtsovskaya Embankment, and 12 Presnenskaya Embankment, Moscow, and
was established on 13 August 2013, Roman Valeryevich Shpakov is a participant of the Company, Dmitry Sergeyevich
Lepeshkin and Olga Viktorovna Vasyukova (current General Director) are (were) General Directors of the Company;
(Vol. No. 169, pp. 134 - 192)
Investment Company QBF LLC (Taxpayer Identification Number 7733673955), controlled and affiliated with the
participants of the criminal association (criminal organisation), according to which the Company is located at the
following addresses: 7/6, Heroev - Panfilovtsev St., Moscow, 7/6, Slesarny per. Slesarny d. 4 a, 24 Krasnaya Presnya St.,
Moscow and 8/1 Presnenskaya Embankment St., Moscow, the Company was established on 01 November 2008, the
participants of the Company are: City Business Group LLC, Region - Invest OJSC, SRN LLC, QB Group LLC, QBF AG, the
general directors of the Company are (were) Natalia Sokolova, Sergey Smirnov, Pavel Shabunin, Vladimir Frolov,
Stanislav Matyukhin (acting general director);
(Vol. No. 170, pp. 45 - 115)
- other documents – documents submitted by the Federal Tax Service Inspectorate No. 30 for Moscow, in relation to
Indep Smart LLC (TIN 7735159230) controlled and affiliated with members of the criminal community (criminal
organization), according to which the Company is located at the following addresses: Moscow, Zelenograd, 1807 and
Moscow, Vasily Petushkova St. 3/3 p.1, was established on 28 December 2016, the participants of the Company are,
Pavel Leonidovich Maznichenko, Yuri Vasilyevich Shaban, the general directors of the Company are (were) Pavel
Leonidovich Maznichenko, Yuri Vasilyevich Shaban (acting general director);
(Vol. No. 170, pp. 116 - 173)
- other documents - documents submitted by the Federal Tax Service No. 30 for the city of Moscow in relation to QBG
Asset Management LLC (Taxpayer Identification Number 7704835400), controlled and affiliated to the participants of
the criminal association (criminal organisation), according to which the Company is located at the following
addresses: 16/1 Frunzenskaya Naberezhnaya, Moscow, 8/1 Presnenskaya Naberezhnaya, Moscow and 12
Presnenskaya Naberezhnaya, Moscow, and was established on 16 March 2013, the participants of the Company are:
LLC Investment Company Novoye Vremya, LLC QB Group, JSC FG QBF, Sergey Edikovich Rumak, the General Directors
of the Company are (were) Irina Anatolievna Bolshakova, Anna Petrovna Cherdyntseva, Vladimir Georgievich Frolov,
Stanislav Anatolievich Matyukhin, Yaroslava Gennadyevna Smirnova (current General Director);
(Vol. No. 170, pp. 174 - 225)
- Protocol of examination of items dated 12 February 2022, namely a CD - R disc provided by the Federal Tax Service
No. 3 for Moscow containing information on legal entities used by members of a criminal association (criminal
organisation) to embezzle citizens' money, in the course of which the documents contained on the disc that are
relevant to the criminal case were examined, printed and attached to the materials of the criminal case;
(Vol. No. 171, pp. 3 - 4)
- other documents - statutory and registration documents, as well as information on accounts in credit institutions,
submitted by the Federal Tax Service No. 3 for the city of Moscow, in respect of the Investment Company QBF LLC (INN
772
7733673955), controlled and affiliated to the participants of the criminal association (criminal organisation), whose
details and accounts were used by the participants of the criminal association (criminal organisation) to mislead
citizens as to their true intentions and the subsequent commission of serious crimes - embezzlement of funds;
- Other documents - statutory and registration documents, as well as information on accounts in credit organisations,
submitted by the Federal Tax Service No. 3 for the city of Moscow, in relation to Qubief Asset Management LLC (INN
7704835400), controlled and affiliated to the participants of the criminal association (criminal organisation), the
details and accounts of which were used to carry out schematic operations aimed at withdrawing funds from the
Russian Federation, cashing in funds, purchasing real estate, financing construction and issuance of loans to the
Russian Federation.
(Vol. No. 171, pp. 6 - 250, Vol. No. 172, pp. 1 - 156, Vol. No. 173, pp. 1 - 93)
- Protocol of examination of items dated 19 February 2022, namely, a DVD disc provided by the Federal Tax Service
(Vol. No. 177, pp. 4 - 6)
submitted by the Federal Tax Service No. 3 for Moscow, in relation to F - Expert LLC (INN 7703439757), controlled and
affiliated to the participants of the criminal association (criminal organisation), whose details and accounts were used
to carry out scheme operations aimed at withdrawing funds outside the Russian Federation, cashing in funds,
purchasing real estate, financing construction and issuing loans to affiliated companies.
(Vol. No. 177, pp. 8 - 74)
submitted by the Federal Tax Service No. 3 for Moscow, in relation to F - Management LLC (INN 7703448776),
controlled and affiliated to the participants of the criminal association (criminal organisation), the details and
accounts of which were used to carry out scheme operations aimed at withdrawing funds outside the Russian
Federation, cashing in funds, purchasing real estate, financing construction and issuing loans to affiliates.
(Vol. No. 177, pp. 75 - 142)
submitted by the Federal Tax Service No. 3 for Moscow, in relation to Syntez LLC (INN 7708270984), controlled and
affiliated to the participants of the criminal association (criminal organisation), the details and accounts of which
were used to carry out scheme operations aimed at withdrawing funds from the Russian Federation, cashing out
funds, purchasing real estate, financing construction and issuing loans to affiliated companies.
(Vol. No. 177, pp. 143 - 241)
- other documents - statutory and registration documents, as well as information on accounts in credit organisations,
submitted by the Federal Tax Service No. 3 for Moscow, in relation to OOO Severspetsstroy (INN 7703769579),
accounts of which were used to carry out scheme operations, the purpose of which was to withdraw funds outside the
Russian Federation, cash out, purchase real estate, finance construction and issue loans to Af.
(Vol. No. 178, pp. 1 - 103)
773
submitted by the Federal Tax Service No. 3 for Moscow, in relation to LLC Profi (INN 7703447860), controlled and
affiliated to participants of the criminal association (criminal organisation), the details and accounts of which were
used to carry out scheme operations aimed at withdrawing funds from the Russian Federation, cashing in funds,
(Vol. No. 178, pp. 104 - 160)
submitted by the Federal Tax Service No. 3 for Moscow, in relation to Finbutik LLC (INN 7731610156), controlled and
were used to carry out scheme operations aimed at withdrawing funds from the Russian Federation, cashing in funds,
(Vol. No. 178, pp. 161 - 244)
submitted by the Federal Tax Service No. 3 for Moscow, in relation to M4 Invest LLC (INN 7701973890), controlled and
were used to carry out scheme operations aimed at withdrawing funds outside the Russian Federation, cashing in
(Vol. No. 179, pp. 1 - 62)
- other documents statutory and registration documents, as well as information on accounts in credit organisations,
submitted by the Federal Tax Service No. 3 for the city of Moscow, in relation to Qubief Adviszeri LLC (INN
details and accounts of which were used to carry out scheme operations aimed at withdrawing funds from the
Russian Federation, cashing in funds, purchasing real estate, financing construction and issuing loans.
(Vol. No. 179, pp. 63 - 156)
submitted by the Federal Tax Service No. 3 for the city of Moscow, in relation to Qubi Credit LLC (INN 7703740234),
accounts of which were used to carry out scheme operations aimed at withdrawing funds from the Russian
Federation, cashing out funds, purchasing real estate, financing construction and issuing loans to affiliates.
(Vol. No. 179, pp. 157 - 208)
submitted by the Federal Tax Service No. 3 for Moscow, in relation to K - Consulting LLC (Taxpayer Identification
Number 7703471373), controlled and affiliated to the participants of the criminal association (criminal organisation),
the details and accounts of which were used to carry out scheme operations aimed at withdrawing funds from the
Russian Federation, cashing out funds, purchasing real estate, financing construction and issuing loans to affiliates.
(Vol. No. 179, pp. 209 - 244)
submitted by the Federal Tax Service No. 3 for Moscow, in relation to Q-BROKER LLC (TIN 9703003668), controlled and
funds, purchasing real estate, financing construction and issuing loans to affiliates of the criminal organisation.
(Vol. No. 180, pp. 1 - 46)
774
submitted by the Federal Tax Service No. 3 for Moscow, in relation to K - Investment LLC (INN 7703470098), controlled
and affiliated to the participants of the criminal association (criminal organisation), the details and accounts of which
funds, purchasing real estate, financing construction and issuing loans to affiliates.
(Vol. No. 180, pp. 47 - 132)
submitted by the Federal Tax Service No. 3 for Moscow, in relation to KG LLC (INN 7701876374), controlled and
(Vol. No. 180, pp. 133 - 250)
submitted by the Federal Tax Service No. 3 for Moscow, in relation to F - Technologies LLC (INN 7703448769),
Federation, cashing in funds, purchasing real estate, financing construction and issuing loans to affiliates.
(Vol. No. 181, pp. 1 - 104)
submitted by the Federal Tax Service No. 3 for Moscow, in relation to DV Technologies LLC (INN 7703442478),
accounts of which were used to carry out scheme operations aimed at withdrawing funds outside the Russian
Federation, cashing in funds, purchasing real estate, financing construction and issuing loans to affiants
(Vol. No. 181, pp. 105 - 155)
submitted by the Federal Tax Service No. 3 for Moscow, in relation to Vysota LLC (INN 7734371675), controlled and
affiliated to participants of the criminal association (criminal organisation), the details and accounts of which were
used to carry out scheme operations aimed at withdrawing funds from the Russian Federation, cashing out funds,
(Vol. No. 181, pp. 156 - 244)
submitted by the Federal Tax Service No. 3 for Moscow, in relation to LLC 701 (INN 7703456375), controlled and
(Vol. No. 182, pp. 1 - 49)
- Other documents - statutory and registration documents, as well as information on accounts in credit institutions,
submitted by the Federal Tax Service No. 3 for Moscow, in relation to 168 Kvartal LLC (TIN 7703769272), controlled and
(Vol. No. 182, pp. 50 - 142)
775
submitted by the Federal Tax Service No. 3 for the city of Moscow, in relation to Marketplace My Finance JSC (INN
details and accounts were used to carry out scheme operations, the purpose of which was to withdraw money outside
the Russian Federation, cash out, purchase real estate, finance construction and issue loans for the purchase of real
estate, purchase of real estate, construction financing, and issuance of loans.
(Vol. No. 182, pp. 143 - 183)
submitted by the Federal Tax Service No. 3 for Moscow, in relation to PJSC "Venture Finance Centre" (INN
7734682254), controlled and affiliated to the participants of the criminal community (criminal organisation), the
Russian Federation, cashing out funds, purchasing real estate, financing construction and construction of new
buildings in the Russian Federation, as well as to finance the construction of new buildings in the Russian Federation.
(Vol. No. 183, pp. 1 - 92)
submitted by the Federal Tax Service No. 3 for Moscow, in relation to QBF JSC (INN 7703399818), controlled and
(Vol. No. 183, pp. 93 - 141)
submitted by the Federal Tax Service No. 3 for the city of Moscow, in relation to JSC Financial Group QBF (INN
details and accounts were used to carry out scheme operations, the purpose of which was to withdraw funds outside
the Russian Federation, cash out, purchase immovable property, finance construction and issue
(Vol. No. 183, pp. 142 - 177)
- Protocol of examination of items dated 19 February 2022, namely, a CD - R disc provided by the Federal Tax Service
organization) to embezzle citizens' money, in the course of which the documents contained on the disc, which are
relevant to the criminal case, were examined, printed and attached to the materials of the criminal case;
(Vol. No. 184, pp. 3 - 4)
submitted by the Federal Tax Service No. 3 for Moscow, in relation to M1 Invest LLC (INN 7701367560), controlled and
affiliated to the participants of the criminal association (criminal organisation), whose details and accounts were used
to carry out scheme operations aimed at withdrawing funds from the Russian Federation, cashing out funds,
(vol. No. 184, pp. 5 - 134, 136, vol. No. 185, pp. 195 - 196, 200 - 201)
submitted by the Federal Tax Service No. 3 for Moscow, in relation to F - Technologies LLC (INN 7725726949),
776
Federation, cashing in funds, purchasing real estate, financing construction and issuing loans to affiliates of the
criminal organisation.
(vol. No. 184, pp. 133 - 135, 137 - 229, vol. No. 185, pp. 1 - 199)
submitted by the Federal Tax Service No. 19 for Moscow, in relation to Simon Jesso LLC (INN 7703769586), controlled
(vol. No. 186, pp. 1 - 200, vol. No. 187, pp. 1 - 195)
submitted by the Federal Tax Service No. 19 for Moscow, in relation to Format Development LLC (INN 7708243109),
controlled and affiliated to the participants of the criminal association (criminal organisation), whose details and
accounts were used to carry out scheme operations aimed at withdrawing funds from the Russian Federation, cashing
in funds, purchasing real estate, financing construction and issuing loans.
(Vol. No. 188, pp. 1 - 203, Vol. No. 189, pp. 1 - 220)
submitted by the Federal Tax Service No. 13 for Moscow, in relation to S - Control LLC (Taxpayer Identification Number
Russian Federation, cashing out funds, purchasing real estate, financing construction and issuing loans to affiliates.
(Vol. No. 190, pp. 1 - 34)
submitted by the Federal Tax Service No. 13 for Moscow, in relation to Nortonstroy LLC (INN 5047246489), controlled
(Vol. No. 190, pp. 35 - 81)
submitted by the Federal Tax Service No. 13 for Moscow, in relation to LLC 702 (INN 7703474800), controlled and
(Vol. No. 190, pp. 82 - 159)
submitted by the Federal Tax Service No. 13 for Moscow, in relation to Rif JSC (INN 5047241522), controlled and
were used to carry out schematic operations aimed at withdrawing funds from the Russian Federation, cashing out
funds, purchasing real estate, financing construction and issuing loans to affiliates
(Vol. No. 190, pp. 160 - 194)
submitted by the Federal Tax Service No. 13 for Moscow, in relation to LLC Rentinvest (INN 7703423933), controlled
777
(Vol. No. 191, pp. 1 - 174)
- Protocol of examination of items dated 15 January 2022, namely, a CD - R disc provided by the Federal Tax Service
organization) to embezzle citizens' money, during which the documents contained on the disc that are relevant to the
criminal case were examined, printed and attached to the materials of the criminal case;
(Vol. No. 192, pp. 3 - 4)
submitted by the Federal Tax Service No. 29 for Moscow, in relation to the controlled and affiliated to the participants
of the criminal community (criminal organisation) LLC Qusisiai (INN 7708786218), the details and accounts of which
(Vol. No. 192, pp. 6 - 250, Vol. No. 193, pp. 1 - 115)
No. 22 for the city of Moscow containing information on legal entities used by members of a criminal association
(criminal organization) to embezzle citizens' money, in the course of which the documents contained on the disc that
are relevant to the criminal case were examined, printed and attached to the materials of the criminal case;
(Vol. No. 193, pp. 123 - 124)
submitted by the Federal Tax Service No. 22 for Moscow, in relation to Qubief LLC (INN 7703458823), controlled and
(Vol. No. 193, pp. 120, 126 - 250)
- other documents - statutory and registration documents, as well as information on accounts in credit institutions,
submitted by the Federal Tax Service No. 2 for Moscow, in relation to the controlled and affiliated to the participants
of the criminal association (criminal organisation) LLC "KP Queue 2" (INN 7702459550), the details and accounts of
which were used to carry out schematic operations, the purpose of which was to withdraw funds outside the Russian
Federation, cash out, purchase real estate, finance construction and issue loans to affiliated companies.
(Vol. No. 194, pp. 1 - 40)
submitted by the Federal Tax Service No. 35 for the city of Moscow, in relation to the controlled and affiliated to the
participants of the criminal association (criminal organisation) LLC "KP Queue 3" (INN 7704471087), the details and
accounts of which were used to carry out schematic operations, the purpose of which was to withdraw funds outside
the Russian Federation, cash out, purchase real estate, finance construction and issue loans to affiliates.
(Vol. No. 194, pp. 41 - 123)
submitted by the Federal Tax Service No. 31 for the city of Moscow, in relation to the controlled and affiliated to the
778
participants of the criminal association (criminal organisation) LLC "KP Queue 4" (INN 9731017278), the details and
accounts of which were used to carry out schematic operations, the purpose of which was to withdraw funds outside
the Russian Federation, cash out, purchase real estate, finance construction and issue loans to affiliates.
(Vol. No. 194, pp. 124 - 185)
submitted by the Federal Tax Service of Russia for Verkh - Isetsky District of Yekaterinburg, in relation to LLC "776"
whose details and accounts were used to carry out scheme operations, the purpose of which was to withdraw money
outside the Russian Federation, cash out, purchase immovable property, finance construction projects
(Vol. No. 194, pp. 186 - 217)
organization) to embezzle citizens' money, in the course of which the documents contained on the disc that are
(Vol. No. 195, pp. 3 - 4)
submitted by the Federal Tax Service No. 33 for Moscow, in relation to Indep Smart LLC (INN 7735159230), controlled
(Vol. No. 195, pp. 6 - 250)
relevant to the criminal case were examined, printed out and attached to the materials of the criminal case;
(Vol. No. 196, pp. 3 - 4)
submitted by the Federal Tax Service No. 18 for Moscow, in relation to Ver - Mont LLC (INN 7718304946), controlled
were used to carry out schematic operations aimed at withdrawing funds from the Russian Federation, cashing out
(Vol. No. 196, pp. 6 - 165)
organization) to embezzle citizens' money, in the course of which the documents contained on the disc, which are
(Vol. No. 197, pp. 3 - 4)
779
submitted by the Federal Tax Service No. 6 for Moscow, in relation to VL Consulting LLC (INN 7706463476), controlled
(Vol. No. 197, pp. 6 - 171)
- Protocol of examination of items dated 10 April 2022, namely, CD - R discs provided by the Interdistrict Federal Tax
Service of Russia No. 11 for St. Petersburg and Interdistrict Federal Tax Service No. 15 for St. Petersburg containing
information on legal entities used by the participants of the criminal association (criminal organization) in embezzling
citizens' money, during which the documents contained on the discs that are relevant to the criminal case were
examined, printed and attached to the materials of the criminal case;
(Vol. No. 198, pp. 6 - 9)
submitted by the Interdistrict Federal Tax Service of Russia No. 11 for St. Petersburg and Interdistrict Federal Tax
Service of Russia No. 15 for St. Petersburg. Saint Petersburg, in relation to LLC KF Estate SPB (INN 7840472851),
controlled and affiliated to the participants of the criminal association (criminal organisation), whose details and
accounts were used to carry out scheme operations aimed at withdrawing funds from the Russian Federation, cashing
out funds, purchasing real estate, financing construction and issuing loans to affiliated legal entities and individuals;
(Vol. No. 198, pp. 10 - 94)
relevant to the criminal case were examined, printed out and attached to the materials of the criminal case;
(Vol. No. 199, pp. 3 - 4)
submitted by the Federal Tax Service No. 25 for the city of Moscow, in relation to LLC Managing Company Moi Finance
(INN 7725682730), controlled and affiliated to the participants of the criminal association (criminal organisation), the
details and accounts of which were used to carry out scheme operations aimed at withdrawing money outside the
Russian Federation, cashing in money, purchasing real estate, financing construction projects.
(Vol. No. 199, pp. 6 - 233)
provided by the Federal Tax Service of Russia for Mytishchi, in relation to Millhouse Invest LLC (INN 5029252176),
controlled and affiliated to the participants of the criminal community (criminal organisation), the details and
Federation, cashing in funds, purchasing real estate, financing construction and issuing loans.
(Vol. No. 200, pp. 1 - 179)
780
- Protocol of examination of items dated 21 February 2022, namely a CD - R disc provided by Alfa Bank JSC containing
account statements of QBIF Investment Company LLC, in the course of which the documents contained on the disc
and relevant to the criminal case were examined, printed and attached to the materials of the criminal case;
(Vol. No. 201, pp. 4 - 10)
- another document - a statement of account No. 40701810101400000783 of LLC "Investment Company QBF", the
details and accounts of which were used by participants of a criminal association (criminal organisation) to mislead
citizens about the true intentions and subsequent commission of grave crimes - embezzlement of funds, for the
period from 01. 01.2012 to 22.11.2021, the amount of transactions on the account on credit is 11,700,000 roubles, the
amount of transactions on the account on debit is 11,700,000 roubles, containing also information on the purpose of
payments. 01.01.2012 to 22.11.2021, the amount of transactions on the account on credit is 11 700 000 rubles,
the amount of transactions on the account on debit is 11 700 000 rubles, containing also information on the purpose
of payments, establishing the circumstances of the criminal case;
(Vol. No. 201, l.d. 12)
- another document - statement of account No. 40701810201400000052 of LLC "Investment Company QBF", the
details and accounts of which were used by the participants of the criminal association (criminal organisation) to
mislead citizens about the true intentions and subsequent commission of grave crimes - embezzlement of funds, for
the period from 01. 01.2012 to 22.11.2021. 01.01.2012 to 22.11.2021, the amount of transactions on the account on
credit is 2,686,655,788.89 rubles, the amount of transactions on the account on debit is 2,686,655,788.89 rubles,
containing also information on the purpose of payments, establishing the circumstances of the criminal case;
(Vol. No. 201, pp. 13 - 250; Vol. No. 202, pp. 1 - 45)
details and accounts of which were used by participants of the criminal association (criminal organisation) to mislead
period from 01. 01.2012 to 22.11.2021, the amount of transactions on the account on credit is 40,278,000 rubles.
01.01.2012 to 22.11.2021, the amount of transactions on the account on credit is 40 278 000 rubles, the
amount of transactions on the account on debit is 40 278 000 rubles, containing also information on the purpose of
payments, establishing the circumstances of the criminal case;
(Vol. No. 202, pp. 46 - 49)
the period from 01. 01.2012 to 22.11.2021, the amount of transactions on the account on credit is 23 000 306 rubles.
(Vol. No. 202, pp. 50 - 51)
details and accounts of which were used by participants of the criminal association (criminal organisation) to mislead
period from 01. 01.2012 to 22.11.2021, the amount of transactions on the account on credit is 18,567,000 rubles.
781
(Vol. No. 202, pp. 52 - 54)
details and accounts of which were used by participants of a criminal association (criminal organisation) to mislead
period from 01. 01.2012 to 22.11.2021, the amount of transactions on the account on credit is 172,590,039.01 rubles.
01.01.2012 to 22.11.2021, the sum of operations on the account on credit makes 172 590 039,01 rubles, the
sum of operations on the account on debit makes 170 373 510,17 rubles, containing also the information on the
purpose of payments, establishing the circumstances of the criminal case;
(vol. No. 202, pp. 56 - 250; vol. No. 203, pp. 1 - 250; vol. No. 204, pp. 1 - 43)
- Protocol of examination of items dated 04 March 2022, namely a CD - R disc provided by Sberbank of Russia PJSC
containing account statements of QBIF Investment Company LLC, in the course of which the documents contained on
the disc and relevant to the criminal case were examined, printed and attached to the materials of the criminal case;
(Vol. No. 204, pp. 83 - 89)
details and accounts of which were used by the participants of the criminal community (criminal organisation) to
the period from 20.04.04.2018 to 24.11.2021, the amount of transactions on the account on credit is 2 370 802 117,37
rubles, the amount of transactions on the account on debit is 2 370 802 117,37 rubles, containing also information on
the purpose of payments, establishing the circumstances of the criminal case;
(Vol. No. 204, pp. 92 - 235)
the period from 20.04.04.2018 to 24.11.2021, the amount of transactions on the account on credit is 162,083,045.18
rubles, the amount of transactions on the account on debit is 162,083,045.18 rubles, containing also information on
(Vol. No. 205, pp. 1 - 39)
the period from 07.02.02.2017 to 24.11.2021, the amount of transactions on the account on credit is 24,887,029.86
rubles, the amount of transactions on the account on debit is 24,880,336.83 rubles, containing also information on the
(Vol. No. 205, pp. 40 - 244)
- Protocol of examination of items dated 09 March 2022, namely, a CD - R disc containing account statements of QBIF
Investment Company LLC provided by the non - banking credit institution JSC National Settlement Depository, in the
course of which the documents contained on the disc and relevant to the criminal case were examined, printed and
(Vol. No. 206, pp. 83 - 110)
782
the period from 05.03.03.2018 to 22.11.2021, the amount of transactions on the account on credit is 373 502,41 rubles,
the amount of transactions on the account on debit is 373 502,41 rubles, containing also information on the purpose
(Vol. No. 206, pp. 132 - 147)
the period from 05.03.03.2018 to 22.11.2021, the amount of transactions on the account on credit is 9 175 009,12
rubles, the amount of transactions on the account on debit is 9 175 009,12 rubles, containing also information on the
(Vol. No. 206, pp. 178 - 179)
the period from 05.03.03.2018 to 22.11.2021, the amount of transactions on the account on credit is 8,537,542,895.47
rubles, the amount of transactions on the account on debit is 8,442,164,837.99 rubles, containing also information on
(Vol. No. 206, pp. 180 - 250; Vol. No. 207, pp. 1 - 250; Vol. No. 208, pp. 1 - 240)
(Vol. No. 208, pp. 243 - 250; Vol. No. 209, pp. 1 - 20)
rubles, the amount of transactions on the account on debit is 123 128 782,18 rubles, containing also information on
(Vol. No. 209, pp. 23 - 54)
the period from 05.03.03.2018 to 22.11.2021, the amount of transactions on the account on credit is 1 551 187 247,23
rubles, the amount of transactions on the account on debit is 1 551 187 247,23 rubles, containing also information on
(Vol. No. 209, pp. 57 - 102)
783
(Vol. No. 209, pp. 105 - 108)
(Vol. No. 209, pp. 109 - 250; Vol. No. 210, pp. 1 - 56)
(Vol. No. 210, pp. 57 - 87)
the period from 05.03.03.2018 to 22.11.2021, the amount of transactions on the account on credit is 9,716,953,117.52
rubles, the amount of transactions on the account on debit is 9,687,391,548.43 rubles, containing also information on
(Vol. No. 210, pp. 90 - 250; Vol. No. 211, pp. 1 - 250; Vol. No. 212, pp. 1 - 250; Vol. No. 213, pp. 1 - 250; Vol. No. 214, pp. 1 -
241)
(Vol. No. 214, pp. 246 - 249)
(Vol. No. 215, pp. 1 - 10)
784
the period from 05.03.03.2018 to 22.11.2021, the amount of operations on the account on credit is 212 548 643,25
rubles, the amount of operations on the account on debit is 212 548 643,25 rubles, containing also information on the
(Vol. No. 215, pp. 11 - 30)
the period from 05.03.03.2018 - 22.11.2021, the amount of transactions on the account on credit is 1 824 121.28 USD,
the amount of transactions on the account on debit is 1 769 498.58 USD, containing also information on the purpose
(Vol. No. 215, pp. 48 - 108)
USD, the amount of transactions on the account on debit is 23 767 958,26 USD, containing also information on the
(Vol. No. 215, pp. 111 - 202)
the period from 05.03.03.2018 to 22.11.2021, the amount of transactions on the account on credit is 14 443,75 USD,
the amount of transactions on the account on debit is 14 443,75 USD, containing also information on the purpose of
(Vol. No. 215, pp. 203 - 218)
the period from 05.03.03.2018 - 22.11.2021, the amount of transactions on the account on credit is 2 533 210,02 euros,
the amount of transactions on the account on debit is 2 533 210 210 euros, containing also information on the
(Vol. No. 215, pp. 223 - 229)
- Protocol of examination of items dated 10 March 2022, namely a CD - R disc provided by Alfa Bank JSC containing
account statements of QBIF Investment Company LLC, in the course of which the documents contained on the disc
(Vol. No. 216, pp. 26 - 32)
785
the period from 01. 01.2012 to 09.06.2021, the amount of transactions on the account on credit is 384,368,552.46
rubles. 01.01.2012 to 09.06.2021, the sum of operations on the account on credit makes 384 368 552,46 rubles, the
sum of operations on the account on debit makes 381 583 005,81 rubles, containing also data on the purpose of
the period from 01. 01.2012 to 09.06.2021, the amount of transactions on the account on credit is 273 000 USD, the
amount of transactions on the account on debit is 273 000 USD, containing also information on the purpose of the
account. 01.01.2012 to 09.06.2021, the amount of transactions on the account on credit is 273 000 USD, the
amount of transactions on the account on debit is 273 000 USD, containing also information on the purpose of
(Vol. No. 218, pp. 25 - 26)
- Protocol of examination of items dated 13 January 2022, namely a CD - R disc provided by Sberbank of Russia PJSC
containing account statements of QBF Asset Management LLC, in the course of which the documents contained on
the disc that are relevant to the criminal case were examined, printed and attached to the materials of the criminal
case;
(Vol. No. 218, pp. 75 - 88)
- another document - statement of account No. 42002810100020000818 of LLC QBF Asset Management, the details
and accounts of which were used by the participants of the criminal community (criminal organisation) to carry out
scheme operations, the purpose of which was the withdrawal of funds outside the Russian Federation, cashing of
funds, purchase of real estate, financing of construction and issuance of loans to affiliated legal entities and
individuals, for the period from 09.10.2015 to 30.10.2015, the amount of transactions on the account is 50,000,000
roubles, the amount of opex on the account is 50,000,000 roubles, the amount of the loan is 50,000,000 roubles.
(Vol. No. 218, pp. 89 - 90)
roubles, the amount of ope
(Vol. No. 218, pp. 91 - 92)
(Vol. No. 218, pp. 93 - 94)
786
roubles, the amount of opex on the loan account is 50,000,000 roubles, the amount of opex on the account is
50,000,000 roubles.
(Vol. No. 218, pp. 95 - 96)
(Vol. No. 218, pp. 97 - 98)
(Vol. No. 218, pp. 99 - 100)
(Vol. No. 218, pp. 101 - 102)
roubles, the amount of opex on the loan account is 69,550,500 roubles, the amount of opex on the account is
69,550,500 roubles.
(Vol. No. 218, pp. 103 - 108)
individuals, for the period from 01.01.2015 to 24.11.2021, the amount of transactions on the account is RUB
81,100,862.25, the amount of op
787
funds, purchase of immovable property, financing of construction and issuing loans to affiliated legal entities and
individuals, for the period from 04.03.03.2015 to 24.11.2021, the amount of operations on the account on credit is 936
931 576,23 rubles, the amount of operations on the account on debit is 936 931 067,37 rubles, containing also
information on the purpose of payments, establishing the circumstances of the criminal case;
(Vol. No. 220, pp. 184 - 210)
(Vol. No. 220, pp. 211 - 214)
- another document - a statement of account No. 40701810338000000518 of LLC QBF Asset Management, the details
individuals, for the period from 12.08.08.2015 - 24.11.2021, the amount of operations on the account on credit is 42
294 524,69 rubles, the amount of operations on the account on debit is 28 623 427,82 rubles, containing also
(Vol. No. 220, pp. 217 - 237)
individuals, for the period from 25.05.05.2016 - 24.11.2021, the amount of transactions on the account on credit is 192
809 505,71 rubles, the amount of transactions on the account on debit is 192 413 481,39 rubles, containing also
(Vol. No. 220, pp. 240 - 250; Vol. No. 221, pp. 1 - 66)
(Vol. No. 221, pp. 67 - 107)
scheme operations, the purpose of which was to withdraw funds outside the Russian Federation, cash out, purchase
real estate, finance construction and issue loans to affiliated legal entities and individuals, for the period from
08.12.12.2017 to 24.11.2021, the amount of transactions on the account on credit is 73,844,308.65 rubles, the amount
788
of transactions on the account on debit is 73,844,308.65 rubles, containing also information on the purpose of
(Vol. No. 221, pp. 108 - 124)
scheme operations, the purpose of which was to withdraw funds outside the Russian Federation, cashing out funds,
purchasing real estate, financing construction and issuing loans to affiliated legal entities and individuals, for the
period from 08.12.12.2017 to 24.11.2021, the amount of transactions on the account on credit is 26,743,606.11 rubles,
the amount of transactions on the account on debit is 26,743,606.11 rubles, containing also information on the
(Vol. No. 221, pp. 125 - 147)
period from 08.12.12.2017 - 24.11.2021, the amount of transactions on the credit account is 53,258,311.68 rubles, the
amount of transactions on the debit account is 52,930,383.07 rubles, containing also information on the purpose of
(Vol. No. 221, pp. 148 - 196)
period from 29. 04.2019 to 24. 11.2021, containing the following: the amount of transactions on the account on credit
is RUB 46,979,374.70, the amount of transactions on the account on debit is RUB 46,942,044.54. 04.04.2019 -
24.11.2021, the amount of operations on the account on credit is 46 979 374,70 rubles, the amount of operations on
the account on debit is 46 942 044,54 rubles, containing also information on the purpose of payments, establishing
the circumstances of the criminal case;
(Vol. No. 221, pp. 197 - 206)
44,013,000, the amount of ope
(Vol. No. 221, pp. 207 - 212)
(Vol. No. 221, pp. 213 - 250; Vol. No. 222, pp. 1 - 14)
789
period from 04.07.07.2018 - 24.11.2021, the amount of operations on the account on credit is 26 354 012,73 rubles, the
amount of operations on the account on debit is 26 341 435,66 rubles, containing also information on the purpose of
(Vol. No. 222, pp. 15 - 25)
rubles, the amount of ope
(Vol. No. 222, pp. 26 - 27)
scheme transactions, the purpose of which was to withdraw funds outside the Russian Federation, cashing out funds,
period from 08. 08.08.08.2018 - 24.11.2021, the amount of operations on the account on credit is 64 872 698,07 rubles,
the amount of operations on the account on debit is 64 761 073,49 rubles, containing also information on the purpose
(Vol. No. 222, pp. 28 - 91)
period from 08.08.08.2018 - 24.11.2021, the amount of operations on the account on credit is 80 694 662,63 rubles, the
(Vol. No. 222, pp. 92 - 101)
individuals, for the period from 08.08.2018 to 24.11.2021, the amount of transactions on the account is 28,537,172.59
rubles, the amount of op
(Vol. No. 222, pp. 102 - 118)
- other document - statement of account No. 40701810438000002597 of LLC QBF Asset Management, the details and
accounts of which were used by the participants of the criminal community (criminal organisation) to carry out
funds, purchase of real estate, financing of construction and issuing loans to affiliated legal entities and individuals,
for the period from 29.03.2019 to 18.07.2019, the amount of transactions on the account is 10,000,000 roubles, the
amount of opex on the loan is 10,000,000 roubles, the amount of opex on the account is 10,000,000 roubles.
790
(Vol. No. 222, pp. 119 - 120)
rubles, the amount of ope
(Vol. No. 222, pp. 121 - 125)
individuals, for the period from 29.03.2019 to 19.07.2019, the amount of transactions on the account is RUB 9,930,000,
the amount of opera
(Vol. No. 222, pp. 126 - 127)
for the period from 17.10.2019 to 17.09.2021, the amount of transactions on the account is RUB 8,000,000, the amount
of opera
(Vol. No. 222, pp. 130 - 131)
individuals, for the period 22.04.2020 to 24.11.2021, the amount of transactions on the account is 152,453,551.38
rubles, the amount of opex on the loan, the amount of the loan is 152,453,551.38 rubles.
(Vol. No. 222, pp. 138 - 181)
individuals, for the period from 22.04.2020 to 24.11.2021, the amount of operations on the account is 300,000 roubles,
the amount of operations on the loan account is 300,000 roubles, the amount of operations on the loan account is
300,000 roubles.
(Vol. No. 222, pp. 182 - 183)
for the period from 22. 04.2020 to 17.09.2021.04.04.2020 - 17.09.2021, the amount of operations on the account on
credit is 3,676,059,551.64 rubles, the amount of operations on the account on debit is 3,676,059,551.64 rubles,
791
(Vol. No. 222, pp. 184 - 203)
(Vol. No. 222, pp. 204 - 205)
roubles, the amount of the transaction is 5,000,000 roubles.
(Vol. No. 222, pp. 208 - 209)
funds, purchase of immovable property, financing of construction and granting loans to affiliated legal entities and
individuals, for the period from 29. 09.2020 to 24.11.2021, containing the amount of transactions on the account on
credit is RUB 5,069,428.33, the amount of transactions on the account on debit is RUB 5,013,849.62. 09.09.2020 -
24.11.2021, the amount of operations on the account on credit is 5 069 428,33 rubles, the amount of operations on the
account on debit is 5 013 849,62 rubles, containing also information on the purpose of payments, establishing the
(Vol. No. 222, pp. 210 - 213)
roubles, the amount of the transaction is 5,000,000 roubles.
(Vol. No. 222, pp. 214 - 215)
scheme operations aimed at withdrawing funds outside the Russian Federation, cashing out funds, purchasing real
estate, financing construction and issuing loans to affiliated legal entities and individuals, for the period from
30.11.2020 to 17.09.2021, the amount of transactions on the account is RUB 20,003,203.27, the amount of op
(Vol. No. 222, pp. 216 - 217)
individuals, for the period from 12.04.2017 to 24.11.2021, the amount of transactions on the account is 134,070.92
USD, the sum of the transactions is as follows
792
(Vol. No. 222, pp. 218 - 246)
individuals, for the period from 12.04.2017 to 24.11.2021, the amount of transactions on the account is 74,216.94 US
dollars, the sum of the transactions is as follows
(Vol. No. 222, pp. 247 - 250)
(Vol. No. 223, pp. 31 - 32)
individuals, for the period from 17.10.2018 to 06.12.2018, the amount of operations on the account is 500,000 rubles,
the amount of the operation
(Vol. No. 223, pp. 33 - 34)
30.11.2020 to 17.09.2021, the amount of transactions on the account is RUB 20,003,203.27, the amount of op
(Vol. No. 223, pp. 35 - 37)
roubles, the amount of opex on the loan is 227,647,000 roubles.
(Vol. No. 223, pp. 38 - 40)
- Protocol of examination of items dated 13 January 2022, namely a DVD - R disc containing account statements of
QBF Asset Management LLC provided by JSC Russian Agricultural Bank, in the course of which the documents
contained on the disc and relevant to the criminal case were examined, printed and attached to the materials of the
criminal case;
(Vol. No. 223, pp. 44 - 46)
793
(Vol. No. 223, l.d. 47)
- Protocol of inspection of items dated 13 January 2022, namely a DVD+R disc provided by PAO Sovcombank
containing account statements of LLC QBF Asset Management, during which the documents contained on the disc
that are relevant to the criminal case were examined, printed and attached to the materials of the criminal case;
(Vol. No. 223, pp. 51 - 53)
(Vol. No. 223, l.d. 54)
- Protocol of examination of items dated 13 January 2022, namely a CD - R disc provided by Alfa Bank JSC containing
account statements of QBF Asset Management LLC, during which the documents contained on the disc, which are
(Vol. No. 223, pp. 65 - 69)
01.01.2012 to 09.06.2021, the amount of transactions on the account is 60,649,186.32 rubles, the amount of op
(Vol. No. 223, pp. 70 - 143)
- Protocol of examination of items dated 14 January 2022, namely the CD - R disc provided by Alfa Bank JSC
containing account statements of F - Technologies LLC, in the course of which the documents contained on the disc
(Vol. No. 223, pp. 158 - 161)
- another document - statement of account No. 40702810901400002524 of LLC F - Technologies, the details and
funds, purchase of real estate, financing of construction and granting loans to affiliated legal entities and individuals,
for the period from 01.01.01.2012 to 16.01.2018, the amount of transactions on the account on credit is 8,306,068.87
794
rubles, the amount of transactions on the account on debit is 8,306,068.87 rubles, containing also information on the
(Vol. No. 223, pp. 162 - 196)
- Protocol of examination of items dated 11 October 2021, namely the CD - R disc provided by Alfa Bank JSC
containing account statements of Simon Jesso LLC, in the course of which the documents contained on the disc that
(Vol. No. 223, pp. 197 - 225)
- another document - statement of account No. 40702810701400002986 of Simon Jesso LLC, the details and accounts
of which were used by the participants of the criminal community (criminal organisation) to carry out scheme
operations aimed at withdrawing funds outside the Russian Federation, cashing out funds, purchasing real estate,
financing construction and issuing loans to affiliated legal entities and individuals, for the period from 01.01.2012 to
09.06.2021, the amount of operations on the account is 240,662,830.46 rubles, the amount of operations on the loan
account is 240,662,830.46 rubles.
(Vol. No. 223, pp. 226 - 250; Vol. No. 224, pp. 1 - 33)
containing account statements of Simon Jesso LLC, in the course of which the documents contained on the disc that
(Vol. No. 224, pp. 49 - 52)
- another document - statement of account No. 40702810240000053746 of LLC "Simon Jesso", the details and
schematic operations, the purpose of which was to withdraw funds outside the Russian Federation, cashing of funds,
purchase of real estate, financing of construction and issuing loans to affiliated legal entities and individuals, for the
period from 23.11.11.2018 to 29.10.2021, the amount of operations on the account on credit is 1 486 881 571,99
rubles, the amount of operations on the account on debit is 1 486 878 547,29 rubles, containing also information on
(Vol. No. 224, pp. 53 - 120)
- Protocol of examination of items dated 14 January 2022, namely, a CD - R disc provided by Sberbank of Russia PJSC
containing account statements of Rif JSC, in the course of which the documents contained on the disc and relevant to
the criminal case were examined, printed and attached to the materials of the criminal case;
(Vol. No. 224, pp. 135 - 139)
- another document - statement of account No. 40702810638000195724 of JSC Rif, the details and accounts of which
were used by the participants of the criminal community (criminal organisation) to carry out scheme operations, the
purpose of which was the withdrawal of funds outside the Russian Federation, cashing of funds, purchase of real
estate, financing of construction and granting loans to affiliated legal entities and individuals, for the period from
21.07.2020 to 20.10.2021, the amount of transactions on the account on credit is 14,161,513 roubles, the amount of
transactions on the account on debit with
(Vol. No. 224, pp. 140 - 163)
795
- Protocol of examination of items dated 14 January 2022, namely, a CD - R disc containing account statements of JSC
"Rif" provided by PJSC Bank Financial Corporation Otkrytie, during which the documents contained on the disc,
which are relevant to the criminal case, were examined, printed and attached to the materials of the criminal case;
(Vol. No. 224, pp. 167 - 170)
- another document - statement of account No. 40702810500490009571 of JSC Rif, the details and accounts of which
07.06.2021 to 16.11.2021, the amount of transactions on the account on credit is 505,000 rubles, the amount of
transactions on the account on debit is as follows
(Vol. No. 224, pp. 171 - 173)
- Protocol of examination of items dated 14 January 2022, namely a CD - R disc provided by Bank Uralsib PJSC
containing account statements of QBF Financial Group JSC, in the course of which the documents contained on the
disc and relevant to the criminal case were examined, printed and attached to the materials of the criminal case;
(Vol. No. 224, pp. 186 - 189)
- other document - statement of account No. 40702810100280001033 of JSC Financial Group QBF, the details and
individuals, for the period from 05.08.2020 to 09.06.2021, the amount of transactions on the account is 550,000
roubles, the amount of transactions on the account is 550,000 roubles, the amount of transactions on the account is
550,000 roubles, the amount of transactions on the account is 550,000 roubles, the amount of transactions on the
account is 550,000 roubles, the amount of transactions on the account is 550,000 roubles, the amount of transactions
on the account is 550,000 roubles.
(Vol. No. 224, pp. 190 - 193)
- Protocol of examination of items dated 14 January 2022, namely the CD - R disc provided by JSC "Alfa Bank"
containing account statements of JSC Financial Group QBF, during which the documents contained on the disc, which
are relevant to the criminal case, were examined, printed and attached to the materials of the criminal case;
(Vol. No. 224, pp. 196 - 201)
- another document - statement of account No. 40702810001400014959 of JSC Financial Group QBF, the details and
individuals, for the period from 01. 01.2012 to 09.06.2021. 01.01.2012 to 09.06.2021, the amount of transactions on
the account on credit is 2,867,994,169.73 rubles, the amount of transactions on the account on debit is
2,867,983,659.38 rubles, containing also information on the purpose of payments, establishing the circumstances of
the criminal case;
(Vol. No. 224, pp. 202 - 250; Vol. No. 225, pp. 1 - 40)
796
containing account statements of QBF Financial Group JSC, in the course of which the documents contained on the
disc that are relevant to the criminal case were examined, printed and attached to the materials of the criminal case;
(Vol. No. 225, pp. 59 - 63)
- another document - statement of account No. 40702810538000235140 of JSC Financial Group QBF, the details and
scheme operations, the purpose of which was to withdraw funds outside the Russian Federation, cash - in, purchase
08.11.11.2018 to 13.10.2021, the amount of operations on the account on credit is 507 974 421,14 rubles, the amount
of operations on the account on debit is 507 946 552,44 rubles, containing also information on the purpose of
(Vol. No. 225, pp. 64 - 137)
- Protocol of examination of items dated 15 January 2022, namely, a CD - R disc provided by VTB Bank (PJSC)
containing account statements of Sintez LLC, in the course of which the documents contained on the disc that are
(Vol. No. 225, pp. 138 - 141)
- another document - statement of account No. 40702810500000089275 of LLC "Sintez", the details and accounts of
which were used by the participants of the criminal community (criminal organisation) for the implementation of
scheme operations, the purpose of which was to withdraw funds outside the Russian Federation, cashing of funds,
period from 06.01.2017 to 24.08.2018, the amount of transactions on the account for credit is 6 122 027,26 rubles, the
amount of transactions on the account for debit
(Vol. No. 225, pp. 142 - 143)
- Protocol of examination of items dated 15 January 2022, namely, a CD - R disc containing account statements of
Sintez LLC provided by the branch of Tochka Bank Qiwi Bank (JSC), during which the documents contained on the
disc, which are relevant to the criminal case, were examined, printed and attached to the materials of the criminal
case;
(Vol. No. 225, pp. 149 - 152)
- other document - statement of account No. 40702810610050036222 of LLC "Sintez", the details and accounts of
which were used by the participants of the criminal community (criminal organisation) to carry out schematic
operations, the purpose of which was to withdraw funds outside the Russian Federation, cashing of funds, purchase
of real estate, financing of construction and granting loans to affiliated legal entities and individuals, for the period
from 21.08.2018 to 31.07.2018, the amount of transactions on the account for credit is 10 627 472.42 rubles, the
amount of transactions on the account for debit
(Vol. No. 225, pp. 153 - 158)
- another document - statement of account No. 40702978710050000278 of LLC "Sintez", the details and accounts of
797
of real estate, financing of construction and granting loans to affiliated legal entities and individuals, for the period
from 21.08.2018 to 31.07.2018, the amount of transactions on the account on credit is 54 970 euros, the amount of
transactions on the account on debit from
(Vol. No. 225, l.d. 160)
- Protocol of examination of items dated 15 January 2022, namely, a CD - R disc provided by VTB Bank (PJSC)
containing account statements of Q-BROKER LLC, in the course of which the documents contained on the disc that are
(Vol. No. 225, pp. 161 - 164)
- another document - a statement of account No. 40701810719150000044 of LLC Q.Broker, the details and accounts of
which were used by the participants of the criminal community (criminal organisation) to carry out scheme
operations, the purpose of which was the withdrawal of funds outside the Russian Federation, cashing of funds,
purchase of immovable property, financing of construction and granting loans to affiliated legal entities and
(Vol. No. 225, pp. 165 - 166)
- another document - statement of account No. 40701840025100000020 of Q-BROKER LLC, the details and accounts of
18.10.2021, the amount of transactions on the account is 253,208.33 US dollars, the amount of transactions on the
account is 253,208.33 US dollars, the amount of transactions on the account is 253,208.33 US dollars.
(Vol. No. 225, l.d. 169)
containing account statements of Q-BROKER LLC, in the course of which the documents contained on the disc that are
(Vol. No. 225, pp. 170 - 178)
operations, the purpose of which was to withdraw funds outside the Russian Federation, cash out, purchase real
estate, finance construction and issue loans to affiliated legal entities and individuals, for the period from
11.11.11.2019 to 13.10.2021, the amount of transactions on the account on credit is 941,766,700.68 rubles, the
amount of transactions on the account on debit is 941,755,124.22 rubles, containing also information on the purpose
(Vol. No. 225, pp. 179 - 240)
operations, the purpose of which was to withdraw funds outside the Russian Federation, cashing out funds, buying
real estate, financing construction and issuing loans to affiliated legal entities and individuals, for the period from
798
17.09.09.2019 - 13.10.2021, the amount of transactions on the account on credit is 5 398 341,10 USD, the amount of
transactions on the account on debit is 5 398 341,10 USD, containing also information on the purpose of payments,
establishing the circumstances of the criminal case;
(Vol. No. 225, pp. 241 - 248)
purchase of real estate, financing of construction and granting loans to affiliated legal entities and individuals, for the
period from 17.09.09.2020 - 13.10.2021, the amount of transactions on the account on credit is 5 282 842,29 USD, the
amount of transactions on the account on debit is 5 282 842,29 USD, containing also information on the purpose of
(Vol. No. 226, pp. 1 - 10)
which were used by the participants of the criminal association (criminal organisation) to carry out schematic
operations, the purpose of which was to withdraw funds outside the Russian Federation, cashing out funds,
period from 17.09.09.2020 - 13.10.2021, the amount of transactions on the account on credit is 759 493,28 euros, the
amount of transactions on the account on debit is 759 493,28 euros, containing also information on the purpose of
(Vol. No. 226, pp. 11 - 14)
- other document statement of account No. 40701978738000000267 of Q-BROKER LLC, the details and accounts of
operations aimed at withdrawal of funds outside the Russian Federation, cashing of funds, purchase of real estate,
financing of construction and granting loans to affiliated legal entities and individuals, for the period from 17.09.2020
to 13.10.2021, the amount of operations on the account for credit is 3,400,000 euros, the amount of operations on the
account for debit
(Vol. No. 226, pp. 15 - 20)
- another document - statement of account No. 42003810738000002375 of LLC Q.Broker, the details and accounts of
transactions aimed at withdrawing funds outside the Russian Federation, cashing out funds, purchasing real estate,
11.03.2021, the amount of transactions on the account is 2,000,000 roubles, the amount of transactions on the loan
account is 2,000,000 roubles, the amount of transactions on the loan account is 2,000,000 roubles, the amount of
transactions on the loan account is 2,000,000 roubles, the amount of transactions on the loan account is 2,000,000
roubles, the amount of transactions on the loan account is 2,000,000 roubles, and the amount of transactions on the
loan account is 2,000,000 roubles.
(Vol. No. 226, pp. 23 - 24)
17.03.2021, the amount of transactions on the account is 5,000,000 roubles, the amount of transactions on the loan
account is 5,000,000 roubles, the amount of transactions on the loan account is 5,000,000 roubles, the amount of
799
roubles, the amount of transactions on the loan account is 5,000,000 roubles, and the amount of transactions on the
loan account is 5,000,000 roubles.
(Vol. No. 226, pp. 25 - 26)
- иной документ – выписка по счету № 42004810238000000821 ООО «Кью.Брокер», реквизиты и счета

которого использовались участниками преступного сообщества (преступной организации) для
осуществления схемных операций, целью которых являлся вывод денежных средств за пределы Российской
Федерации, обналичивание денежных средств, покупка недвижимого имущества, финансирование
строительства и выдача займов аффилированным юридическим и физическим лицам, за период с 04.03.2021
по 17.03.2021, сумма операций по счету по кредиту составляет 4 000 000 рублей, сумма операций по счету по д
(Vol. No. 226, pp. 27 - 28)
account statements of Q-BROKER LLC, in the course of which the documents contained on the disc and relevant to the
(Vol. No. 226, pp. 38 - 44)
which were used by participants of the criminal community (criminal organisation) to carry out scheme operations,
the purpose of which was the withdrawal of funds outside the Russian Federation, cashing of funds, purchase of
immovable property, financing of construction and granting loans to affiliated legal entities and individuals, for the
period from 01.01.01.2012 to 09.06.2021, the amount of operations on the account on credit is 931 855 476,15 rubles,
the amount of operations on the account on debit is 931 849 761,10 rubles, containing also information on the
(Vol. No. 226, pp. 45 - 85)
- other document - statement of account No. 40702978901400004040 of Q-BROKER LLC, the details and accounts of
operations aimed at withdrawal of funds outside the Russian Federation, cashing of funds, purchase of real estate,
to 09.06.2021, the amount of transactions on the account for credit is 1 100 225 euros, the amount of transactions on
the account for debit is 1 100 225 euros, the amount of transactions on the account for credit is 1 100 225 euros, the
amount of transactions on the account for debit is 1 100 225 euros.
(Vol. No. 226, fol. 86)
which were used by the participants of the criminal association (criminal organisation) to carry out scheme
individuals, for the period from 01.01.01.2012 to 09.06.2021, the amount of operations on the account on credit is 2
277 077,50 USD, the amount of operations on the account on debit is 2 277 077,50 USD, containing also information
on the purpose of payments, establishing the circumstances of the criminal case;
(Vol. No. 226, pp. 87 - 91)
800
containing account statements of QBF JSC, during which the documents contained on the disc, which are relevant to
the criminal case, were examined, printed and attached to the materials of the criminal case;
(Vol. No. 226, pp. 114 - 117)
- another document - statement of account No. 40701810001400000210 of JSC QBF, the details and accounts of which
were used by the participants of the criminal association (criminal organisation) to carry out scheme operations, the
purpose of which was the withdrawal of funds outside the Russian Federation, cashing of funds, purchase of
period from 01. 01.2012 to 08.10.2021, containing the amount of transactions on the account on credit is RUB
6,395,963.19. 01.01.2012 to 08.10.2021, the amount of transactions on the account on credit is 6,395,963.19 rubles,
the amount of transactions on the account on debit is 6,395,963.19 rubles, containing also information on the
(Vol. No. 226, pp. 118 - 136)
- Protocol of examination of items dated January 16, 2022, namely the CD - R disc provided by the State Corporation
"Deposit Insurance Agency" containing account statements of "Ver - Mont" LLC, in the course of which the documents
contained on the disc and relevant to the criminal case were examined, printed and attached to the materials of the
criminal case;
(Vol. No. 226, pp. 144 - 147)
- other document - statement of account No. 40702810000050000110 of LLC "Ver - Mont", the details and accounts of
of real estate, financing of construction and issuing loans to affiliated legal entities and individuals, for the period
from 13.11.2014 to 17.04.2019, the amount of transactions on the account for credit is 10 570 000 rubles, the amount
of transactions on the account for debit
(Vol. No. 226, pp. 148 - 152)
containing account statements of Ver - Mont LLC, in the course of which the documents contained on the disc that are
(Vol. No. 226, pp. 153 - 157)
- another document - statement of account No. 40702810101400005350 of LLC "Ver - Mont", the details and accounts
period from 01.01.2012 to 08.10.2021, the amount of operations on the account for the loan is 150,674,674 roubles,
the amount of operations on the account for the deferred payment is 150,674,674 roubles.
(Vol. No. 226, pp. 158 - 188)
- another document - statement of account No. 40702810510000212436 of LLC Vysota, the details and accounts of
801
period from 08.11.2017 to 03.04.2018, the amount of operations on the account for credit is 4,965,088.06 rubles, the
amount of operations on the account for debit
(Vol. No. 226, pp. 217 - 219)
- Protocol of the examination of items dated 17 January 2022, namely the CD - R disc provided by JSC "Alfa Bank"
containing account statements of LLC "168 quarter", during which the documents contained on the disc, which are
(Vol. No. 226, pp. 220 - 225)
- another document - statement of account No. 40701810401400000768 of LLC "168 quarter", the details and accounts
purchase of real estate, financing of construction and issuance of loans to affiliated legal entities and individuals, for
the period from 01.01.2012 to 09.06.2021, the amount of operations on the loan account is 211,410,040.07 rubles, the
amount of operations on the credit account is 211,410,040.07 rubles, the amount of operations on the loan account is
211,410,040.07 rubles.
(Vol. No. 226, pp. 226 - 250; Vol. No. 227, pp. 1 - 51)
- another document - statement of account No. 40701810501400000066 of LLC "168 quarter", the details and accounts
the period from 01.01.2012 to 09.06.2021, the amount of operations on the account for the loan is 247,807,466.33
rubles, the amount of operations on the account for the purchase of real estate, financing of construction and
issuance of loans to affiliated legal entities and individuals, for the period from 01.01.2012 to 09.06.2021.
(Vol. No. 227, pp. 52 - 130)
- Protocol of the examination of items dated 17 January 2022, namely the CD - R disc provided by JSC "Alfa Bank"
containing account statements of LLC "701", in the course of which the documents contained on the disc, which are
(Vol. No. 227, pp. 138 - 142)
- another document - statement of account No. 40702810601400014087 of LLC "701", the details and accounts of
individuals, for the period from 01. 01.2012 to 09.06.2021, containing also the amount of transactions on the account
on credit is 61 437 700,25 rubles. 01.01.2012 to 09.06.2021, the amount of transactions on the account on credit is
61,437,700.25 rubles, the amount of transactions on the account on debit is 61,437,700.25 rubles, containing also
(Vol. No. 227, pp. 143 - 163)
802
containing account statements of 701 LLC, in the course of which the documents contained on the disc that are
(Vol. No. 227, pp. 164 - 167)
period from 24.05.2018 to 13.10.2021, the amount of transactions on the account on credit is 37,846,000 rubles, the
amount of transactions on the account on debit from
(Vol. No. 227, pp. 168 - 202)
- Protocol of examination of items dated 17 January 2022, namely a CD - R disc containing account statements of OOO
702 provided by Bank Uralsib PJSC, during which the documents contained on the disc that are relevant to the
(Vol. No. 227, pp. 203 - 206)
which were used by participants of the criminal community (criminal organisation) to carry out scheme operations,
the purpose of which was the withdrawal of funds outside the Russian Federation, cashing of funds, purchase of real
05.08.08.2020 to 09.06.2021, the amount of operations on the account on credit is 249,873,001.17 rubles, the amount
of operations on the account on debit is 249,845,416.19 rubles, containing also information on the purpose of
(Vol. No. 227, pp. 207 - 215)
containing account statements of LLC "702", in the course of which the documents contained on the disc and relevant
to the criminal case were examined, printed and attached to the materials of the criminal case;
(Vol. No. 227, pp. 216 - 219)
operations, the purpose of which was to withdraw funds outside the Russian Federation, cashing out funds, buying
real estate, financing construction and issuing loans to affiliated legal entities and individuals, for the period from
17.07.07.2019 - 20.10.2021, the amount of transactions on the account on credit is 682,780,663.75 rubles, the amount
of transactions on the account on debit is 682,698,623.88 rubles, containing also information on the purpose of
(Vol. No. 227, pp. 220 - 250; Vol. No. 228, pp. 1 - 37)
containing account statements of 776 LLC, in the course of which the documents contained on the disc that are
803
(Vol. No. 228, pp. 38 - 42)
period from 03.07.2019 to 13.10.2021, the amount of transactions on the account on credit is 36,425,300 rubles, the
amount of transactions on the account on debit with
(Vol. No. 228, pp. 43 - 114)
account statements of DV - Technologies LLC, during which the documents contained on the disc, which are relevant
to the criminal case, were examined, printed and attached to the materials of the criminal case;
(Vol. No. 228, pp. 115 - 119)
- another document - a statement of account No. 40702810202720003339 of DV - Technolodges LLC, the details and
accounts of which were used by participants of a criminal association (criminal organisation) to carry out schematic
operations, the purpose of which was to withdraw funds outside the Russian Federation, cashing out funds,
period from 01. 01.2012 to 09.06.2021, containing also information on the amount of transactions on the account on
credit is 5,135,199.12 rubles.01.01.2012 to 09.06.2021, the amount of transactions on the account on credit is
(Vol. No. 228, pp. 120 - 134)
- Protocol of the examination of items dated 17 January 2022, namely the CD - R disc provided by Sberbank of Russia
PJSC containing account statements of F - Experts LLC, in the course of which the documents contained on the disc
(Vol. No. 228, pp. 137 - 140)
- another document - statement of account No. 40702810038000167491 of LLC F - Experts, the details and accounts of
period from 31.01.2018 to 13.10.2021, the amount of operations on the account for the loan is 1,746,000 roubles, the
amount of operations on the account for the loan is 1,746,000 roubles, the amount of operations on the account for
the loan is 1,746,000 roubles, the amount of operations on the account for the loan is 1,746,000 roubles, and the
amount of operations on the account for the loan is 1,746,000 roubles.
(Vol. No. 228, pp. 141 - 149)
containing account statements of LLC "F - Experts", during which the documents contained on the disc, which are
(Vol. No. 228, pp. 150 - 153)
804
- another document - statement of account No. 40702810201400011419 of LLC F - Experts, the details and accounts of
08.10.2021, the amount of operations on the account for the loan is 2 290 000 roubles, the amount of operations on
the account for the loan is 2 290 000 roubles, and the amount of operations on the account for the loan is 2 290 000
roubles.
(Vol. No. 228, pp. 154 - 157)
containing account statements of Finbutik LLC, in the course of which the documents contained on the disc and
(Vol. No. 228, pp. 165 - 168)
- another document - statement of account No. 40702810238000037282 of Finbutik LLC, the details and accounts of
13.10.2021, the amount of operations on the account for the loan is 108,084,878.90 rubles, the amount of operations
on the account for
(Vol. No. 228, pp. 169 - 250; Vol. No. 229, pp. 1 - 6)
containing account statements of LLC "Format Development", in the course of which the documents contained on the
case;
(Vol. No. 229, pp. 7 - 11)
- another document - statement of account No. 40702810001400008402 of LLC "Format Development", the details
for the period from 01.01.2012 to 09.06.2021, the amount of operations on the account is 76,085,864.25 rubles, the
amount of operations on the loan account is 76,085,864.25 rubles, the amount of operations on the
(Vol. No. 229, pp. 12 - 45)
- Protocol of examination of items dated 18 January 2022, namely a DVD - R disc containing account statements of
Moi Finansy Management Company Ltd. provided by Moscow Industrial Bank JSC, during which the documents
contained on the disc, which are relevant to the criminal case, were examined, printed and attached to the materials
of the criminal case;
(Vol. No. 229, pp. 57 - 69)
- another document - statement of account No. 40701810000991149006 of LLC MC Moi Finance, the details and
805
funds, purchase of real estate, financing of construction and granting loans to affiliated legal entities and individuals,
for the period from 13.12.2010 to 24.04.2015, the amount of operations on the account is 2,936,913,794.90 roubles,
the amount of operations on the account is 2,936,913,794.90 roubles
(Vol. No. 229, pp. 70 - 77)
schematic operations aimed at withdrawing funds outside the Russian Federation, cashing out funds, purchasing real
08.12.2009 to 30.09.2021, the amount of operations on the account is 171,765,057.90 roubles, the amount of
operations on the account of
(Vol. No. 229, pp. 80 - 108)
- another document - a statement of account No. 40701810700990000006 of LLC MC "Moi Finansy", the details and
accounts of which were used by the participants of the criminal association (criminal organisation) to carry out
individuals, for the period from 08.12.12.2009 to 30.09.2021, the amount of transactions on the credit account is
8,381,985,213.99 rubles, the amount of transactions on the debit account is 8,381,985,213.99 rubles, containing also
(Vol. No. 229, pp. 110 - 170)
- another document - statement of account No. 40701810800990000016 of LLC MC Moi Finansy, the details and
schematic operations aimed at withdrawing funds outside the Russian Federation, cashing out funds, buying real
08.12.2009 to 30.09.2021, the amount of transactions on the account is 55,000,000 roubles, the amount of
roubles, the amount of transactions on the loan account is 55,000,000 roubles, the amount of transactions on the loan
account is 55,000,000 roubles, the amount of transactions on the loan account is 55,000,000 roubles.
(Vol. No. 229, l.d. 171)
(Vol. No. 229, l.d. 172)
806
(Vol. No. 229, l.d. 173)
08.12.2009 to 30.09.2021, the amount of operations on the account is 14,372,377.40 roubles, the amount of operations
on the loan account is 14,372,377.40 roubles, the amount of operations on the loan account is 14,372,377.40 roubles.
(Vol. No. 229, pp. 174 - 177)
schematic operations aimed at withdrawing money outside the Russian Federation, cashing in money, buying real
08.12.2009 to 30.09.2021, the amount of operations on the account is 108,033,300.15 roubles, the amount of
operations on the account is 108,033,300.15 roubles, the amount of operations on the account is 108,033,300.15
roubles, and the amount of operations on the account is 30.09.2021.
(Vol. No. 229, pp. 178 - 183)
schematic operations aimed at withdrawing money outside the Russian Federation, cashing in money, buying real
on the loan account is 27,120,613.16 roubles, the amount of operations on the loan account is 27,120,613.16 roubles,
the amount of operations on the loan account is 27,120,613.16 roubles, the amount of operations on the loan account
is 27,120,613.16 roubles.
(Vol. No. 229, pp. 184 - 190)
containing account statements of Moi Finance Management Company LLC, during which the documents contained on
the disc, which are relevant to the criminal case, were examined, printed and attached to the materials of the criminal
case;
(Vol. No. 229, pp. 191 - 197)
individuals, for the period from 19.02.2018 to 13.10.2021, the amount of operations on the account is 18,457,323.91
rubles, the amount of operations on the loan account is 18,457,323.91 rubles, the amount of operations on the
account of
(Vol. No. 229, pp. 198 - 250; Vol. No. 230, pp. 1 - 6)
accounts of which were used by participants of the criminal community (criminal organisation) to carry out scheme
807
operations aimed at withdrawal of funds outside the Russian Federation, cashing in of funds, purchase of real estate,
to 13.10.2021, the amount of operations on the account is 3,336,927.25 roubles, the amount of operations on the loan
account is 3,336,927.25 roubles, the amount of operations on the loan account is 3,336,927.25 roubles.
(Vol. No. 230, pp. 16 - 69)
containing account statements of F - Management LLC, in the course of which the documents contained on the disc
(Vol. No. 230, pp. 70 - 73)
- another document - statement of account No. 40701810838000004331 of LLC F - Management, the details and
on the loan account is 17,145,691.11 roubles, and the amount of operations on the loan account is 17,145,691.11
roubles.
(Vol. No. 230, pp. 74 - 114)
containing account statements of "Indep Smart" LLC, during which the documents contained on the disc and relevant
(Vol. No. 230, pp. 115 - 119)
- another document - statement of account No. 40701810402780001799 of "Indep Smart" LLC, the details and
schematic transactions aimed at withdrawing funds outside the Russian Federation, cashing out funds, purchasing
real estate, financing construction and issuing loans to affiliated legal entities and individuals, for the period from 01.
01.2012 to 09.06.2021. 01.01.2012 to 09.06.2021, the amount of transactions on the account on credit is
(Vol. No. 230, pp. 124 - 133)
- Protocol of examination of items dated 18 January 2022, namely the CD - R disc provided by JSC SC "Deposit
Insurance Agency" containing account statements of KG LLC, in the course of which the documents contained on the
case;
(Vol. No. 230, pp. 137 - 139)
- another document - statement of account No. 40702810802000022863 of KG LLC, the details and accounts of which
estate, financing of construction and issuing loans to affiliated legal entities and individuals, for the period from
808
09.06.2010 to 05.04.2019, the amount of transactions on the account on credit is 11,395,000 rubles, the amount of
transactions on the account on debit from
(Vol. No. 230, pp. 140 - 141)
containing account statements of KG LLC, in the course of which the documents contained on the disc, which are
(Vol. No. 230, pp. 142 - 147)
purpose of which was the withdrawal of funds outside the Russian Federation, cashing of funds, purchase of
period from 01. 01.2012 to 08.10.2021. 01.01.2012 to 08.10.2021, the amount of operations on the account on
credit is 1 539 546 730,01 rubles, the amount of operations on the account on debit is 1 539 546 730,01 rubles,
(Vol. No. 230, pp. 148 - 250; Vol. No. 231, pp. 1 - 14)
were used by the participants of the criminal community (criminal organisation) to carry out schematic operations
aimed at withdrawing funds outside the Russian Federation, cashing out funds, purchasing real estate, financing
construction and issuing loans to affiliated legal entities and individuals, for the period from 01.01.2012 to 08.10.2021,
the amount of transactions on the credit account is USD 411,154, the amount of transactions on the debit account is
USD 411,154.
(Vol. No. 231, pp. 16 - 19)
containing account statements of F - Technologies LLC, in the course of which the documents contained on the disc
(Vol. No. 231, pp. 20 - 24)
individuals, for the period from 01.01.2012 to 08.10.2021, the amount of transactions on the account is 44,244.32 US
dollars, the amount of transactions on the account is 44,244.32 US dollars, the amount of transactions on the account
is 44,244.32 US dollars.
(Vol. No. 231, pp. 26 - 28)
for the period from 01.01.2012 to 08.10.2021, the amount of operations on the account is RUB 8,024,125.27, the
809
amount of operations on the loan account is RUB 8,024,125.27, the amount of operations on the loan account is RUB
8,024,125.27.
(Vol. No. 231, pp. 31 - 35)
containing account statements of F - Technologies LLC, during which the documents contained on the disc that are
(Vol. No. 231, pp. 36 - 41)
accounts of which were used by participants of the criminal community (criminal organisation) to carry out scheme
period from 20.11.2019 to 13.10.2021, the amount of operations on the account is 22,700,039.02 rubles, the amount of
operations on the loan account is 22,700,039.02 rubles.
(Vol. No. 231, pp. 42 - 87)
schematic operations, the purpose of which was to withdraw funds outside the Russian Federation, cash - in,
purchase real estate, finance construction and issue loans to affiliated legal entities and individuals, for the period
from 22.11.2019 to 13.10.2021, the amount of transactions on the account is USD 111,778.01, the amount of
transactions on the loan account is USD 111,778.01, the amount of transactions on the loan account is USD
111,778.01, the amount of transactions on the
(Vol. No. 231, pp. 91 - 126)
containing account statements of K - Investment LLC, in the course of which the documents contained on the disc that
(Vol. No. 231, pp. 133 - 136)
- another document - statement of account No. 40701810038000002942 of K - Investment LLC, the details and
individuals, for the period from 04.07.2019 to 11.06.2020, the amount of operations on the account is 59,126,689.18
rubles, the amount of operations on the account is
(Vol. No. 231, pp. 137 - 148)
containing account statements of K - Consulting LLC, in the course of which the documents contained on the disc and
(Vol. No. 231, pp. 149 – 153
810
- other document - statement of account No. 40701810338000002943 of K - Consulting LLC, the details and accounts
of which were used by the participants of the criminal community (criminal organisation) to carry out schematic
13.10.2021, the amount of transactions on the account is 2,000,000 roubles, the amount of transactions on the
account of
(Vol. No. 231, pp. 154 - 157)
containing account statements of QBF Advisery LLC, in the course of which the documents contained on the disc and
(Vol. No. 231, pp. 164 - 167)
- another document - statement of account No. 40702810038000167514 of LLC QBF Advisery, the details and accounts
the period from 02.04.2018 to 13.10.2021, the amount of transactions on the account is 421,000 roubles, the amount
of transactions on the account is
(Vol. No. 231, pp. 168 - 173)
containing account statements of QBF Advisery LLC, in the course of which the documents contained on the disc that
(Vol. No. 231, pp. 174 - 178)
- another document - a statement of account No. 40702810001400009812 of LLC QBF Advisery, the details and
individuals, for the period from 01. 01.2012 to 08.10.2021, containing the amount of transactions on the account on
credit is RUB 1,588,548.58, the amount of transactions on the account on debit is RUB 1,588,548.58. 01.01.2012 to
08.10.2021, the amount of operations on the account on credit is 1 588 548,58 rubles, the amount of operations on the
account on debit is 1 588 548,58 rubles, containing also information on the purpose of payments, establishing the
(Vol. No. 231, pp. 179 - 187)
- Protocol of the examination of items dated 19 January 2022, namely the CD - R disc provided by Alfa Bank JSC
containing account statements of the My Finance Marketplace JSC, in the course of which the documents contained
on the disc that are relevant to the criminal case were examined, printed and attached to the materials of the criminal
case;
(Vol. No. 231, pp. 192 - 196)
811
- another document - statement of account No. 40702810202720004833 of JSC Marketplace My Finance, the details
and accounts of which were used by the participants of a criminal association (criminal organisation) to carry out
scheme operations aimed at withdrawing funds outside the Russian Federation, cashing in funds, purchasing real
transactions on the account is 13,379,371 roubles.
(Vol. No. 231, pp. 197 - 205)
- another document - statement of account No. 40702810200000229053 of Millhouse Invest LLC, the details and
for the period from 21.11.11.2019 to 25.10.2021, the amount of transactions on the account on credit is 190 753 183,33
(Vol. No. 231, l.d. 208)
containing account statements of Millhouse Invest LLC, in the course of which the documents contained on the disc
(Vol. No. 231, pp. 210 - 213)
- another document - statement of account No. 40702810438000209946 of Millhouse Invest LLC, the details and
scheme operations aimed at withdrawal of funds outside the Russian Federation, cashing of funds, purchase of real
22.10.2020 to 13.10.2021, the amount of transactions on the account is 460,010 roubles, the amount of transactions
on the loan account is 460,010 roubles, the amount of transactions on the loan account is 460,010 roubles.
(Vol. No. 231, pp. 214 - 220)
- Protocol of examination of items dated 11 November 2021, namely, a CD - R disc provided by Sberbank of Russia
PJSC containing account statements of KP Queue 4 LLC, KP Queue 3 LLC and KP Queue 2 LLC, during which the
documents contained on the disc that are relevant to the criminal case were examined, printed and attached to the
materials of the criminal case;
(Vol. No. 232, pp. 1 - 52)
- other document - statement of account No. 40702810238000107976 of LLC "KP Queue 4", the details and accounts of
operations, the purpose of which was to withdraw funds outside the Russian Federation, cashing in, buying real
21.02.2019 to 13.10.2021, the amount of transactions on the account is 108,267,339.57 rubles, the amount of
transactions on the loan account is 108,267,339.57 rubles.
(Vol. No. 232, pp. 54 - 121)
- another document - statement of account No. 40702810738000008944 of LLC "KP Queue 4", the details and accounts
812
from 20.12.2018 to 13.10.2021, the amount of operations on the loan account is 6 325 648,31 rubles, the amount of
operations on the account of the
(Vol. No. 232, pp. 124 - 147)
which were used by the participantts of the criminal community (criminal organisation) for the implementation of
scheme operations, the purpose of which was to withdraw funds outside the Russian Federation, cashing of funds,
the period from 28.03.2019 to 13.10.2021, the amount of operations on the account is 52,049,226 roubles, the amount
of operations on the account of
(Vol. No. 232, pp. 150 - 186)
operations, the purpose of which was to withdraw funds outside the Russian Federation, cash - in, purchase real
01.02.02.2019 to 13.10.2021, the amount of operations on the account on credit is 37 438 903,72 rubles, the amount of
operations on the account on debit is 37 437 673,09 rubles, containing also information on the purpose of payments,
(Vol. No. 232, pp. 187 - 230)
from 01.02.2019 to 13.10.2021, the amount of operations on the account is 22,299,000 roubles, the amount of
operations on the account is 22,299,000 roubles, the amount of operations on the account of
(Vol. No. 233, pp. 1 - 28)
operations, the purpose of which was to withdraw funds outside the Russian Federation, cash out, purchase real
28.03.03.2019 to 13.10.2021, the amount of operations on the account on credit is 53 426 810,72 rubles, the amount of
operations on the account on debit is 53 425 122,43 rubles, containing also information on the purpose of payments,
(Vol. No. 233, pp. 29 - 68)
containing account statements of LLC "SeverSpetsStroy", during which the documents contained on the disc, which
(Vol. No. 233, pp. 82 - 86)
- another document - statement of account No. 40702810001400002987 of LLC "SeverSpetsStroy", the details and
813
period from 01. 01.2012 to 09.06.2021. 01.01.2012 to 09.06.2021, the amount of transactions on the account on
credit is 539 915 008,49 rubles, the amount of transactions on the account on debit is 539 877 649,03 rubles,
(Vol. No. 233, pp. 87 - 198)
account statements of KF Estate SPB LLC, in the course of which the documents contained on the disc that are
(Vol. No. 234, pp. 1 - 4)
- another document - statement of account No. 40702810032200000295 of LLC "KF Estate SPB", the details and
accounts of which were used by participants of the criminal association (criminal organisation) to carry out scheme
period from 01. 01.2012 to 09.06.2021, the amount of transactions on the account on credit is RUB 323,002,535.8, the
amount of transactions on the account on debit is RUB 323,002,535.8. 01.01.2012 to 09.06.2021, the amount
of operations on the account on credit is 323 002 535,8 rubles, the amount of operations on the account on debit is
323 002 535,8 rubles, containing also information on the purpose of payments, establishing the circumstances of the
criminal case;
(Vol. No. 234, pp. 5 - 250)
containing account statements of M1 Invest LLC, in the course of which the documents contained on the disc and
(Vol. No. 235, pp. 1 - 5)
- another document - statement of account No. 40702810901400006478 of LLC M1 Invest, the details and accounts of
period from 01.01.01.2012 to 09.06.2021, the amount of operations on the account on credit is 321 620 765,33 rubles,
the amount of operations on the account on debit is 321 620 436,15 rubles, containing also information on the
(Vol. No. 235, pp. 6 - 100)
containing account statements of M1 Invest LLC, during which the documents contained on the disc that are relevant
(Vol. No. 235, pp. 106 - 109)
814
24.11.2021, the amount of operations on the loan account is 41,219,800 roubles, the amount of operations on the
debit account is 41,219,800 roubles, and the amount of operations on the credit account is 41,219,800 roubles.
(Vol. No. 235, pp. 116 - 148)
containing account statements of M4 Invest LLC, in the course of which the documents contained on the disc, which
(Vol. No. 235, pp. 149 - 153)
08.10.2021, the amount of operations on the account for the loan is RUB 98,136,411.98, the amount of operations on
the account for the loan is RUB 98,136,411.98, and the amount of operations on the account for the loan is RUB
1,960,411.98.
(Vol. No. 235, pp. 154 - 193)
- Protocol of the examination of items dated 20 January 2022, namely the CD - R disc provided by JSC Alfa Bank
containing account statements of LLC Profi, in the course of which the documents contained on the disc that are
(Vol. No. 235, pp. 198 - 202)
- another document - statement of account No. 40702810901400011890 of LLC "Profi", the details and accounts of
period from 01.01.2012 to 09.06.2021, the amount of operations on the account for credit is 145,973,589.8 rubles, the
amount of operations on the account for debit is 145,973,589.8 rubles, the amount of operations on the account for
credit is 145,973,589.8 rubles, the amount of operations on the account for debit is 145,973,589.8 rubles.
(Vol. No. 235, pp. 203 - 225)
containing account statements of Profi LLC, in the course of which the documents contained on the disc that are
(Vol. No. 235, pp. 228 - 231)
- other document - statement of account No. 40702810838000184823 of LLC "Profi", the details and accounts of which
were used by the participants of the criminal community (criminal organisation) to carry out schematic operations,
the purpose of which was to withdraw funds outside the Russian Federation, cash - in, purchase real estate, finance
construction and issue loans to affiliated legal entities and individuals, for the period from 18.04.2018 to 13.10.2021,
the amount of transactions on the account for credit is 745,606,113.58 rubles, the amount of transactions on the
815
account for debit is 745,606,113.58 rubles, the amount of transactions on the account for credit is 745,606,113.58
rubles, the amount of transactions on the account for debit is 745,606,113.58 rubles.
(Vol. No. 235, pp. 232 - 250; Vol. No. 236, pp. 1 - 48)
containing account statements of RentInvest LLC, in the course of which the documents contained on the disc and
(Vol. No. 236, pp. 49 - 53)
- another document - statement of account No. 40702810501400009765 of LLC RentInvest, the details and accounts of
period from 01.01.01.2012 to 09.06.2021, the amount of transactions on the account on credit is 254 891 952,42
(Vol. No. 236, pp. 54 - 129)
- Protocol of examination of items dated 20 January 2022, namely a CD - R disc containing account statements of
RentInvest LLC provided by Bank Uralsib PJSC, in the course of which the documents contained on the disc and
(Vol. No. 236, pp. 132 - 135)
- another document - statement of account No. 40702810700280001035 of RentInvest LLC, the details and accounts of
09.06.2021, the amount of operations on the account for the loan is RUB 1 330 000, the amount of operations on the
account for the loan is RUB 1 330 000, the amount of operations on the account for the loan is RUB 1 330 000, the
amount of operations on the account for the loan is RUB 1 330 000, the amount of operations on the loan is RUB 1 330
000, the amount of operations on the account for the loan is RUB 1 330 000.
(Vol. No. 236, pp. 136 - 140)
- Protocol of examination of items dated 20 January 2022, namely, a CD - R disc containing account statements of
PJSC "Venture Finance Centre" provided by JSC "Alfa Bank", in the course of which the documents contained on the
case;
(Vol. No. 236, pp. 141 - 145)
- another document - statement of account No. 40701810902200000166 of PJSC "Venture Finance Centre", the details
and accounts of which were used by participants of the criminal community (criminal organisation) to carry out
816
individuals, for the period from 01.01.2012 to 09.06.2021, the amount of transactions on the account is 375 211 695.31
rubles, the sum of the transactions on the loan account is 375 211 695.31 rubles.
(Vol. No. 236, pp. 146 - 209)
- Protocol of examination of items dated 20 January 2022, namely a CD - R disc provided by PJSC Bank FC Otkrytie
containing account statements of PJSC Venture Finance Centre, in the course of which the documents contained on
case;
(Vol. No. 236, pp. 212 - 217)
individuals, for the period from 19.03.2021 to 10.06.2021, the amount of transactions on the account is 11,265,127.19
rubles, the sum of the transactions on the loan account is 11,265,127.19 rubles.
(Vol. No. 236, pp. 218 - 222)
- other document - statement of account No. 40701810500000000684 of PJSC "Venture Finance Centre", the details
scheme operations, the purpose of which was to withdraw funds outside the Russian Federation, cash - in, purchase
10.06.2016 to 10.02.2019, the amount of transactions on the account is RUB 3,050,000, the amount of
(Vol. No. 236, pp. 224 - 230)
containing account statements of Venture Finance Centre PJSC, in the course of which the documents contained on
case;
(Vol. No. 237, pp. 1 - 4)
and accounts of which were used by participants of the criminal community (criminal organisation) to carry out
81,158,722.23, the sum of the transactions is as follows
(Vol. No. 237, pp. 5 - 65)
- Protocol of examination of items dated 13 February 2022, namely, a CD - R disc containing account statements of
PJSC "Venture Finance Centre" provided by the State Corporation "Deposit Insurance Agency", in the course of which
the documents contained on the disc, which are relevant to the criminal case, were examined, printed and attached
to the materials of the criminal case;
(Vol. No. 237, pp. 69 - 72)
817
for the period from 16.10.2012 to 24.11.2015, the amount of transactions on the account is 40,376,345 roubles, the
amount of
(Vol. No. 237, pp. 73 - 120)
- another document - statement of account No. 40817810300000004298 of Roman Valeryevich Shpakov for the period
from 07.06.2017 to 09.06.2021, the amount of transactions on the account on credit is 19 963 400 rubles, the amount
of transactions on the account on debit is 19 907 079, 20 rubles, containing also information on the purpose of
(Vol. No. 282, pp. 4 - 5)
- another document - statement of account No. 40817840600000004298 of Roman Valeryevich Shpakov, for the
period from 07.06.2017 to 09.06.2021, the amount of transactions on the account on credit is 12 000 USD, the amount
of transactions on the account on debit is 12 000 USD, containing also information on the purpose of payments,
(Vol. No. 282, l.d. 6)
- another document - statement of account No. 40817978200000004298 of Roman Valerievich Shpakov for the period
from 07.06.2017 to 09.06.2021, the amount of transactions on the account on credit is 128 536, 30 Euros, the amount
of transactions on the account on debit is 126 539, 16 Euros, containing also information on the purpose of payments,
(Vol. No. 282, pp. 7 - 8)
- another document - statement of account No. 40817810923000622214 of Pakhomov Vladimir Sergeevich, for the
period from 05.07.2019 to 08.06.2021, the amount of transactions on the account on credit is 28 997 334,50 rubles, the
amount of transactions on the account on debit is 28 991 031,50 rubles, containing also information on the purpose of
(Vol. No. 282, pp. 18 - 25)
- another document - statement of account No. 40817810650011017923 of Munaev Zelimkhan Visaitovich, for the
period from 24.09.2018 to 11.06.2021, the amount of operations on the account on credit is 9 242 225,07 rubles, the
(Vol. No. 282, pp. 30 - 41)
- Protocol of examination of items dated 20 June 2021, namely a CD - R disc provided by Sberbank of Russia PJSC
containing account statements of Zelimkhan Visaitovich Munaev, Evgenia Anatolievna Rossieva, and Roman
Valeryevich Shpakov, in the course of which the documents contained on the disc and relevant to the criminal case
were examined, printed and attached to the materials of the criminal case;
(Vol. No. 282, pp. 46 - 55)
period from 19.01.2018 to 02.06.2021 the sum of operations on the account on credit is 17 262 358, 45 rubles, the sum
818
of operations on the account on debit is 17 262 358, 45 rubles, containing also information on the purpose of
(Vol. No. 282, pp. 87 - 144)
period from 02.08.2019 to 02.06.2021, the amount of operations on the account on credit is 1 720 003, 16 rubles, the
amount of operations on the account on debit is 1 720 000 rubles, containing also information on the purpose of
(Vol. No. 282, pp. 145 - 147)
- Protocol of examination of items dated 27 June 2021, namely a CD - R disc provided by Alfa - Bank JSC containing
account statements of Zelimkhan Visaitovich Munaev, Vladimir Sergeevich Pakhomov, Evgenia Anatolievna Rossieva,
and Roman Valeryevich Shpakov, in the course of which the documents contained on the disc and relevant to the
(Vol. No. 283, pp. 6 - 28)
period from 01.01.2013 to 14.06.2021, the sum of operations on the account on credit is 1 523 246, 10 rubles, the sum
(Vol. No. 283, pp. 29 - 37)
(Vol. No. 283, pp. 38 - 49)
(Vol. No. 283, pp. 50 - 180)
period from 01.01.2013 to 14.06.2021, the amount of transactions on the account on credit is 561 159, 34 USD, the
amount of transactions on the account on debit is 600 897, 93 USD, containing also information on the purpose of
(Vol. No. 283, pp. 181 - 204)
period from 01.01.2013 to 14.06.2021, the amount of transactions on the account on credit is 384 133, 96 Euros, the
amount of transactions on the account on debit is 384 145, 15 Euros, containing also information on the purpose of
(Vol. No. 283, pp. 205 - 217)
819
(Vol. No. 283, pp. 218 - 221)
period from 01.01.2013 to 14.06.2021, the amount of operations on the account on credit is 15 891 761, 74 rubles, the
amount of operations on the account on debit is 15 891 761, 74 rubles, containing also information on the purpose of
(Vol. No. 284, pp. 1 - 66)
period from 01.01.2013 to 14.06.2021, the amount of transactions on the account on credit is 205 652, 84 USD, the
amount of transactions on the account on debit is 205 652, 84 USD, containing also information on the purpose of
(Vol. No. 284, pp. 67 - 74)
period from 01.01.2013 to 14.06.2021, the amount of transactions on the account on credit is 352 889, 80 Euros, the
amount of transactions on the account on debit is 352 889, 80 Euros, containing also information on the purpose of
(Vol. No. 284, pp. 75 - 79)
- another document - statement of account No. 40817810705600192943 of Evgeniya Anatolievna Rossieva for the
(Vol. No. 284, pp. 80 - 120)
- another document - statement of account No. 40817810905840316949 of Evgeniya Anatolievna Rossieva for the
period from 01.01.2013 to 14.06.2021, the sum of operations on the account on credit is 2,783,122, 10 rubles, the sum
of operations on the account on debit is 2,783,122, 10 rubles, containing also information on the purpose of
(Vol. No. 284, pp. 121 - 152)
from 01.01.2013 to 14.06.2021, the sum of operations on the account on credit is 932 347 622, 76 rubles, the sum of
operations on the account on debit is 931 542 306, 78 rubles, containing also information on the purpose of payments,
(Vol. No. 285, pp. 1 - 113)
- another document - statement of account No. 408178100064000008871 of Roman Valerievich Shpakov for the
(Vol. No. 285, pp. 114 - 144)
820
from 01.01.2013 to 14.06.2021, the amount of operations on the account on credit is 657 000 rubles, the amount of
operations on the account on debit is 657 000 rubles, containing also information on the purpose of payments,
(Vol. No. 285, fol. 145)
from 01.01.2013 to 14.06.2021, the sum of operations on the account on credit is 30 638 571, 28 rubles, the sum of
operations on the account on debit is 30 638 571, 28 rubles, containing also information on the purpose of payments,
(Vol. No. 285, pp. 146 - 198)
- another document - statement of account № 40817840604170004881 Shpakov Roman Valerievich, for the period
from 01.01.2013 to 14.06.2021, the amount of transactions on the account on credit is 2 478 015, 67 USD, the amount
of transactions on the account on debit is 2 478 015, 75 USD, containing also information on the purpose of payments,
(Vol. No. 285, pp. 199 - 210)
- another document - statement of account № 40817840704980005310 Shpakov Roman Valerievich, for the period
from 01.01.2013 to 14.06.2021, the amount of transactions on the account for credit is 130 300, 39 USD, the amount of
transactions on the account for debit is 130 300, 39 USD, containing also information on the purpose of payments,
(Vol. No. 285, l.d. 211)
- another document - statement of account No. 40817978504280010504 of Roman Valerievich Shpakov for the period
from 01.01.2013 to 14.06.2021, the amount of transactions on the account on credit is 2 296 583, 52 Euros, the amount
of transactions on the account on debit is 2 296 583, 52 Euros, containing also information on the purpose of
(Vol. No. 285, pp. 212 - 227)
- other documents - documents provided by the Federal State Budgetary Institution "Federal Cadastral Chamber of
the Federal Service for State Registration, Cadastre and Cartography" on ownership rights to immovable property
owned and previously owned by legal entities controlled by participants of the criminal association (criminal
organisation), some of which was obtained as a result of criminal actions, as well as on ownership rights to
immovable property owned by the accused S.A. Matyukhin, Z.V. Munaev, V.S. Pakhomov, the parents of the accused
R.V. Shpakov - V.F. Shpakov and I.N. Shpakova, Munaev Z.V., Pakhomov V.S., the parents of the accused Shpakov
R.V. - Shpakov V.F. and Shpakova I.N., part of which was obtained as a result of criminal actions;
(Vol. No. 277, pp. 3 - 52, 54 - 93, Vol. No. 278, pp. 129 - 138)
- other documents - documents provided by the administration of Severodvinsk Municipal Entity for construction
projects where the developers are: LLC "CP Queue 2" (object of capital construction - 4 - section 9 - storey residential
building, located on the land plot, located approximately 190 metres in the direction to the South - E from the
landmark - a building located outside the boundaries of the land plot at the address: Arkhangelsk region,
Severodvinsk, Pobedy Ave. 16); "KP Queue 3" Ltd (object of capital construction - 3 - section 9 - storey residential
building, located on the land plot, located approximately 190 metres in the direction to the South - E from the
landmark - a building located outside the boundaries of the land plot at the address: Arkhangelsk region,
Severodvinsk, Prospekt Pobedy, d. 16, Pobedy Avenue, Severodvinsk); "KP Queue 2" Ltd (the object of capital
construction - 4 - section 9 - storey residential building, located on the land plot located approximately 190 metres to
the South - E from the landmark - the building located outside the boundaries of the land plot at the address:
821
Arkhangelsk region, Severodvinsk, Pobedy Avenue, 16). 16 Pobedy Avenue, Severodvinsk, Arkhangelsk region), in
which the general director is the mother of the accused and the head of the criminal association Shpakov R.V. -
Shpakova I.N., and the general contractor at all three sites was OOO SeverSpetsStroy (whose general director is the
accused R.V. Shpakov himself). The materials of the criminal case have reliably established that part of the stolen
money of citizens was used by the participants of the criminal association (criminal organisation) for the
implementation of the above investment project;
(Vol. No. 277, pp. 95 - 204)
- other documents documents provided by the administration of Odintsovo City District of Moscow Region and
Srednerusskiy Bank of Sberbank PJSC on the construction project located at the address: Moscow Region, Odintsovo
District, v. Borodki, Parkovaya Street, 1, where the developer is Simon Jesso LLC. The materials of the criminal case
have reliably established that part of the stolen money of citizens was used by the participants of the criminal
association (criminal organisation) for the implementation of the above investment project. Thus, initially the
participant and beneficiary of LLC "Simon Jesso" was R.V. Shpakov, who in 2014 sold part of the share to V.K.
Arsenchuk, who is currently the general director of LLC "Simon Jesso" and the owner of 50% of the Company's share.
Currently, the remaining 50 % of the share of Simon Jesso LLC belongs to Denis Vitalievich Sorokin (who is the sibling
of Andrey Vitalievich Sorokin - the cohabitant of the accused Shpakov R.V.'s mother, I.N. Shpakova). Shpakov R.V.
(through his mother Shpakova I.N.) sold to Sorokin D.V. in March 2021 the specified 50 % of the Company's share, at
the same time, according to Sorokin D.V.'s version, in 2010 - 2011, he lent Shpakov R.V. money in the amount of
10,000,000, at the same time, Sorokin D.V. cannot document the fact of money transfer, afer which in 2021, allegedly
to repay the debt, Shpakov R.V. offered him to assign the specified share. At the same time, the general director of
"Simon Jesso" LLC - Arsenchuk Valery Evgenyevich, who is a business partner of Shpakov R.V. and a co - founder of
"Simon Jesso" LLC, does not know Sorokin D.V. and learnt about the transaction afer it was signed. These
circumstances, in conjunction with the documents obtained during the preliminary investigation, indicate the
invalidity of the version of Sorokin D.V. and point to the fictitious nature of the transaction between Sorokin and
Shpakov, who knew about the criminal prosecution against him under criminal case No. 12001450007000902,
initiated on 25 September 2020. In other words, R.V. Shpakov purposefully re - registered the property to the persons
under his control in order to avoid seizure of the property obtained as a result of criminal actions. The materials of the
criminal case also establish that money was transferred to the settlement accounts of "Simon Jesso" LLC from the
settlement accounts of various organisations controlled by the participants of the criminal association (criminal
organisation) and its leader - Shpakov R.V. and used for embezzlement of funds of numerous citizens, including from
the account of "M1 Invest" LLC (where the accused Shpakov R.V. is a participant), as well as from the account of the
accused Shpakov R.V. himself, where the basis of the transfer was "payment/transfer". Afer that, the said funds were
transferred to the address of the organisations involved in the construction of the housing estate located at the
following address: Moscow region, Odintsovsky district, v. Borodki, Parkovaya street, уч. 1;
(Vol. No. 277, pp. 207 - 223, Vol. No. 278, pp. 2 - 67)
- other documents - documents provided by LLC "Fonchenko Specialised Developer" containing information on the
acquisition by Torres Cristina (mother of the defendant Athanasiadou Linda) of a flat located at: Moscow, Fonchenko
Brothers St., Building 2, 5th floor, total area 126.83 sq.m., conditional number 2.21, at a cost of RUB 70,001,576.37;
(Vol. No. 278, pp. 70 - 116)
- other documents documents provided by JSC United Specialised Depository containing information in relation to
legal entities controlled by participants of the criminal association (criminal organisation) to which accounts in the
register of investment unit holders have been opened, namely: LLC 702, LLC Q.Broker, LLC Profi, PJSC Venture Finance
Centre, Lamera Holdings Limited (Lamera Holdings Limited), i.e. owners of property obtained as a result of criminal
actions;
(Vol. No. 278, pp. 147 - 160)
822
- other documents - documents provided by QBIF Investment Company LLC and Otkritie Broker JSC containing
information regarding individuals and legal entities controlled by the participants of the criminal association (criminal
organisation) to whom accounts were opened in the register of owners of investment units, i.e. owners of property
obtained as a result of criminal actions. Thus, in the course of the preliminary investigation it was established that Q-
BROKER LLC had a personal account B00004365 opened with the NCO JSC National Settlement Depository, which as
of 31 May 2021 contained 336385, 24,249,244. There were 336385, 24 units (issuer - ZPIF of real estate "Rif Mixed
Federal 2 qual"), which were further re - registered in various depositories, including the depositories of LLC
Investment Company QBF and PJSC Bank FC Otkrytie, for the purpose of alienation of property in favour of third
parties. It has been established that on the basis of the order for writing off the client (depositor) Tallerov Artem
Olegovich (who is a controlled and trusted person of the participants of the criminal association (criminal
organisation) headed by Shpakov R.V.) No. 1 dated 07 July 2021, securities of the real estate ZPIF "Rif Mixed Federal 2
qual" in the amount of 336385, 24 pieces were written off in JSC Otkritie Broker;
(Vol. No. 279, pp. 38 - 39, 48 - 62)
- other documents - documents provided by the Main Department of the Russian Ministry of Internal Affairs on
ownership of expensive vehicles belonging to individuals and legal entities controlled by participants of the criminal
association (criminal organisation), i.e. property obtained as a result of criminal actions;
(Vol. No. 279, pp. 84 - 98)
Evidence and their summary, confirming the guilt of Pakhomov V.S. in committing an offence under
part 4 of article 159 of the Criminal Code of the Russian Federation against Kozlovskaya N.S.:
- another document - a statement by N.S. Kozlovskaya, in which she asks to bring to criminal responsibility persons
from among the employees, managers of the financial group "QBF" (LLC "Investment Company QBF"), who stole her
money under the guise of carrying out brokerage activities;
(Vol. No. 3, l.d. 160)
- Kozlovskaya N.S.'s testimony , given to her as a witness and victim, according to which she at the end of
November 2013, in order to place free cash and receive profit, on the recommendation of her daughter's acquaintance
Kozlovskaya A.E., went to the office of the group of companies "QBF", located at: Moscow, Presnenskaya
Naberezhnaya, 8, p. 1, 9th floor, where she met Lepeshkin Dmitry (tel. 8 - 90 - 100 - 59 - 18), who became her financial
advisor. 1, 9th floor, where she met Dmitry Lepeshkin (tel. 8 - 903 - 100 - 59 - 18), who became her financial adviser.
Lepeshkin offered her to invest her money in various stock exchange products; he was very persuasive and persistent.
Dmitry offered her to deposit her money as an investment in the QBF group of companies, he guaranteed income
from these investments. On 28.11.2013 she together with her daughter, Kozlovskaya A.E., came to the office of the
group of companies "QBF", located at the address: Moscow, Presnenskaya naberezhnaya, 8, p. 1, where Lepeshkin
Dmitry came to the office of the group of companies "QBF", located at the following address: 8, bld. 1, where
Lepeshkin Dmitry voiced a number of proposals to invest money by investing in securities. So she agreed to
participate in investing in securities on international financial markets. Further all consultations on financial products
with her were carried out by Lepeshkin Dmitry. On 28.11.2013 she, being in the office of the company "QBF", located
at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, 9th floor, signed a contract with Dmitry Lepeshkin. 1, 9th
floor, signed the documents provided by Lepeshkin: Agreement on Direct Access to the US Securities Market No. 1344
- 13/VR dated 28.11.2013 between her and QB Capital CY LTD represented by R.V. Shpakov, as well as the agreement
on provision of "Trust Management" services in accordance with the agreement on direct access to the US securities
market No. 1344 - 13/BP dated 28.11.2013 (LEK Account 001344) between her and the company QB Finance LLC
represented by Shpakov R.V. When concluding and signing these documents, the representatives of the group of the
company "QB CAPITAL CY LTD" were the employees of "QBF", namely Lepeshkin Dmitry (personal manager). She has
not seen R.V. Shpakov personally. Also, on 28.11.2013, afer signing the above - mentioned documents, within the
framework of the previously concluded agreement and contract (agreement on direct access to the US securities
market No. 1344 - 13/VR dated 28.11.2013), she handed over to Lepeshkin Dmitry cash in the amount of USD 18,000,
823
which at the exchange rate of the Central Bank of the Russian Federation as of 28.11.2013 amounted to 594,000
rubles. Afer the transfer of funds she was given a receipt dated 28.11.2013 on receipt of USD 18,000 to be credited to
her account opened with the company "QB Capital CY LTD" (Nicosia, Cyprus) under the contract No. 1344 - 12/12BP
dated 28.11.2013. The signatory from the company "QB Capital CY LTD" in the receipt was the executive director
Modin N.V. Apart from this receipt, no cash reports or other documents on the acceptance of funds from her were not
given to her. Since December 2013 she received monthly reports on the state of her investment account to her e - mail,
until September 2019 from the e - mail address: [email protected], [email protected], since September 2019 from
the e - mail address: reports@wl - mnt.com. Thereafer, the funds were held in her investment account. She also
received monthly account statements. She had no need to withdraw or withdraw the funds. In 2018, the exact month
is difficult to name due to the age of the events, she was informed that her financial advisor instead of Dmitry
Lepeshkin was appointed Maslennikov Vladimir (tel. 8 - 964 - 530 - 32 - 16). Afer that her daughter A.E. Kozlovskaya on
her (N.S. Kozlovskaya) behalf and on her initiative started negotiations with Vladimir Maslennikov about withdrawal
of funds from her investment account from "QBF" group of companies. For this purpose she was issued a power of
attorney for her daughter Kozlovskaya A.E., and her daughter started to deal with all questions and correspondence
on withdrawal of her funds from the group of companies "QBF". She did not sign any documents on the transfer of
contracts and accounts to other companies, and her daughter did not sign new contracts on her behalf, except for the
order for withdrawal of funds dated 24.12.2018 with the company "White Lake Management". Till date, she has not
been able to withdraw the monies invested in QBF Group of Companies even partially. In June 2021, she learnt from
the media (official website of the Ministry of Internal Affairs of the Russian Federation) about the initiated criminal
case against the founders of the company "QBF" (LLC "Investment Company QBF"). Thus, on 28.11.2013 she invested
funds in the amount of USD 18,000, i.e. RUB 594,000, in the group of companies "QBF" (LLC "QBF Investment
Company") for the purpose of receiving income. To date, the funds have not been returned to her either in full or in
part. She considers that an offence has been committed against her, namely the thef of money by deception and
breach of trust. She considers the amount of damage caused as significant;
(Vol. No. 3, pp. 163 - 166, 175 - 178)
- other documents - documents provided by N.S. Kozlovskaya confirming her relationship with QBF Financial Group
(QBF Investment Company LLC) and testifying to the embezzlement of funds;
(Vol. No. 3, pp. 179 - 210)
part 4 of article 159 of the Criminal Code of the Russian Federation against Polezhaev A.V.:
- another document - statement of A.V. Polezhaev, in which he asks to bring to criminal responsibility
persons from among the employees, managers of the financial group "QBF" (LLC "Investment Company "QBF"), who
stole his money under the guise of carrying out brokerage activities;
(Vol. No. 1, l.d. 6)
- A.V. Polezhaev's testimony as a witness,

victim, according to which he has a close acquaintance Loginov Sergey (contract details 8 - 985 - 924 - 14 - 00), whom
he has known for more than 17 years, was on friendly terms with him, as far as he knows he has his own business,
which consisted in vehicle insurance. In 2012 he got acquainted with Vladimir Sergeevich Pakhomov, who works at QB
Finance LLC (mobile phone 8 - 965 - 748 - 88 - 88). He got acquainted under the following circumstances: in 2012, he,
Sergey Loginov and Vladimir Pakhomov met in a restaurant in Moscow. The meeting implied his acquaintance with
Pakhomov V.S., as earlier Loginov S. had told him that he had an acquaintance who accepted cash as an investment.
He was interested in this proposal, as he had free money at that time, Pakhomov V.S. promised about 2 - 3 per cent of
the deposited amount monthly in cash. Also an important fact of his trust in Pakhomov V.S. was that earlier Loginov
S., whom he had known for a long time, had also invested money. At the meeting Pakhomov V.S. seemed to him a
businessman who inspired confidence. Pakhomov V.S. told him how his activity was organised, which consisted in
824
attracting people with free cash to invest in his business, namely by buying and selling securities and building
apartment buildings. In April 2012, in the morning, he met with Pakhomov V.S. at the Hotel Ukraina, where he
transferred cash in the amount of 400,000 US dollars, with the aim of obtaining benefits from the investment. Afer the
cash transfer, he did not receive any documents from Pakhomov V.S. confirming the acceptance of the above amount
from him. The agreement with Pakhomov V.S. was conditional. About three months later he received a phone call
from Pakhomov V.S. asking him if he still had cash that he could invest. He replied that he had cash for such purposes.
At the beginning of June 2012, V.S. Pakhomov came to the address: Moscow, Berezovy Roschchi Proezd, No. 10,
(during this period he was renting accommodation at this address). At the meeting Pakhomov V.S. explained that it
was necessary to invest more money in investments and to reach USD 1,000,000, afer which his interest would
increase (at the moment of transferring the money for the first time and subsequently he believed that Pakhomov V.S.
was carrying out investment activities on his behalf and was really investing the money transferred by him in
investments). As a result of this meeting, he handed over to Pakhomov V.S. cash in the amount of USD 200,000 (he
could not specify the exact date of the cash transfer). It did not bother him that they did not draw up or sign any
documentation, as he trusted him and they had a common acquaintance. In the period from June 2012 to December
2015, with certain periodicity Pakhomov V.S. made interest payments from the amount previously paid by him (at
first, interest payments were made regularly, the amount of interest paid each time was different sometimes USD
10,000, sometimes USD 15,000, sometimes USD 50,000). Afer a year of interest payments, delays in interest payments
of up to seven months began to occur. Thus, Pakhomov V.S. used to hand him money in cash without documentary
proof. All his communication was with Pakhomov V.S., Sometimes the money was transferred by him personally, and
sometimes by persons unknown to him, who are employees of LLC Qubey Finance, they transferred the money to him
in different cities, namely St. Petersburg, Yekaterinburg, Moscow, where LLC Qubey Finance has opened additional
branches, also several times he received money on his bank card from persons unknown to him, representing
themselves as employees of LLC Qubey Finance, St. Petersburg branch (at the moment he cannot provide a
statement, as a lot of time has passed). The total amount of interest paid to him is not more than USD 300,000. On 05
June 2012, he personally came to the office of Qubey Finance LLC, which was located in the building of the Moscow
City complex at the following address: 8 Presnenskaya Naberezhnaya Street, Moscow, p. 1, 9th floor. 1, 9th floor. In
this office he met Roman Shpakov and Zelimkhan Munayev. Pakhomov Vladimir introduced Munaev Zelimkhan to him
as the commercial director of Qyubi Finance LLC, and Shpakov Roman as the deputy general director of Qyubi Finance
LLC. Pakhomov Vladimir explained to him that the Cyprus company was an affiliated company of Qubey Finance LLC.
While in this office, he signed the agreement on direct access to the US securities market No. 592 - 12/VR dated
05.06.2012 between him and the company QB Capital CY LTD, as well as the agreement on the provision of "Trust
management services under the agreement on direct access to the US securities market No. 592 - 12/VR dated
05.06.2012. At the signing of these documents Pakhomov Vladimir Sergeevich was present, it was he who convinced
him of the reliability of the transaction, he also guaranteed him the return of the full amount and the interest due to
him. He also explained to him that in fact he had no risk of losing his money, as the funds were insured by the Federal
Corporation for Protection of Rights of Interests under the mandatory deposit insurance system on the basis of clause
2.3 of the agreement. Afer the lapse of time he found out that there is no insurance. Roman Valeryevich Shpakov acts
as the representative of QB Capital CY LTD under this agreement. On 10 February 2014 Pakhomov V.S. called him and
offered to invest additional money in the business project in the amount of 1,050,000 Euros. He justified it by the fact
that it is a new project, in which it is necessary to contribute more than 1 million dollars, it guarantees him a stable
interest and profitability from the invested funds. Afer brief deliberation, he agreed with this proposal, Pakhomov V.S.
informed him that the funds should be transferred to the settlement account of the Cyprus company, he further
informed him of the number of the settlement account. So on 11.02.2014 he transferred funds in the amount of
1,050,000 Euros from his current account opened in a foreign bank in Germany, in Berlin, from account number
42100208900255970582 to the current account of the Cyprus company "QB Capital CY LTD". In 2016, he asked
Pakhomov V.S. to employ his common - law spouse at QB Capital CY LTD as a manager. He knew that there was a
branch in the city of Yekaterinburg, his wife at the time lived there, Pakhomov V.S. agreed and employed her. She
worked for about two months at Kubi Finance LLC, afer which she decided to resign because she was not satisfied
with a job where she had to deceive and mislead people. Later, he was informed by his German colleagues that "QB
Capital CY LTD" was liquidated, it does not conduct any financial and economic activity, also from the Republic of
825
Cyprus he was informed that "QB Capital CY LTD" on the territory of the Republic of Cyprus does not carry out its
activities, and is currently liquidated. Around 2017 he learnt that he was not officially registered as an investor in "QB
Capital CY LTD" and "QB Capital CY LTD". On 25 September 2015, according to V.S. Pakhomov, the terms of the
previously valid agreement expired and he had to sign an Additional Agreement to the Agreement on the provision of
"Trustee" services under the agreement on direct access to the US securities market No. 592 - 12/VR dated 25
September 2015. This agreement was signed between him and Qubey Finance LLC, the representative of Qubey
Finance LLC was Pakhomov V.S., the General Director of the branch of Qubey Finance LLC, however, this additional
agreement was valid until 2017. In total, he transferred to Pakhomov V.S. funds in the amount of EUR 1,050,000 and
USD 600,000 as investments, and he received the promised interest on the deposited amounts from Pakhomov V.S.
and unidentified persons who introduced themselves as employees of Qubey Finance LLC (approximately in the
amount of USD 300,000). In 2019 (he cannot specify the exact month) he had a meeting in the building of the Moscow
City complex, at the address: Moscow, Presnenskaya Naberezhnaya, 8, pp. 1 (on the ground floor in a coffee shop)
between him, Munaev Z.V., Shpakov R.V., Pakhomov V.S. at this meeting it was decided to return to him money in the
amount of 200 000 USD, for a period until 01 October 2019, until 01 November 2019 200 000 USD. Starting from 01
December 2019 at USD 15,000 each month for a total of USD 475,000, which was approximately 50 per cent of the total
amount of money he had invested. He wrote a statement that he would have no claim afer the above amount was
transferred to him. Around October 2019, he received USD 200,000 from Shpakov R.V. He wrote a receipt for the money
and gave it to Shpakov R.V. Later, he became aware of Aslambek, who was the brother of Munaev Zelimkhan, who said
that he was related to Qubey Finance LLC and was the curator of this company. Aslambek then put forward the
condition that he needed to transfer USD 200,000 to him as collateral for the project. He called Shpakov R.V. and asked
why Munaev Aslambek demanded money from him, to which Shpakov Roman replied that Munaev Aslambek had the
right to negotiate within the framework of the investment project, afer which Shpakov Roman stopped contacting
him. He repeatedly called the office of Qubey Finance LLC two times a day asking to be connected with Pakhomov
V.S., or with Shpakov R.V., with any of the company's managers. The girl secretary informed him that she would pass
on the information and he would definitely be contacted, but this did not happen. He repeatedly came to the office to
talk to the managers - Pakhomov, Shpakov, but the guard did not let him in, referring to the lack of a pass and the
absence of the management in the office. He asked Loginov to find Pakhomov V.S. to get in touch with him, Loginov
said that he was afraid of Pakhomov V.S. and he would also refuse to return the money. He said that V.S. Pakhomov
and R.V. Shpakov had acquaintances in law enforcement agencies and they would close all the issues. He would like
to note that Pakhomov threatened him with physical violence afer he went to the police. Thus, he believes that an
offence, namely fraud, has been committed against him. In total, he had made deposits totalling 1,050,000 euros and
600,000 United States dollars to the company QBF LLC, which were subsequently stolen from him. He considers that
he has suffered material damage in the above - mentioned amount, and considers the amount of damage caused to
be significant;
(Vol. No. 4, pp. 99 - 102, 103 - 111, 175 - 179)
- other documents - documents provided by A.V. Polezhaev confirming his relationship with QBF Financial
Group (QBF Investment Company LLC) and testifying to the embezzlement of funds;
• (Vol. No. 4, pp. 112 - 115, 118 - 127, 142 - 165, 183 - 214)
• Evidence and their summary, confirming the guilt of Pakhomov V.S. in committing an offence under
part 4 of article 159 of the Criminal Code of the Russian Federation against Bulina G.V.:
- another document - a statement by Bulin G.V., in which he asks to bring to criminal responsibility persons
from among the employees, managers of the financial group "QBF" (LLC "Investment Company QBF"), who
• (Vol. No. 5, pp. 7, 11)
826
- Testimony of Bulin G.V., given by him as a witness and victim,
according to which in 2013 his distant relative Yan Drachan got a job in the investment company LLC "QBF" (INN
7733673955) later renamed to LLC IC "QBF", part of the group of companies "QBF", in the sales department. In
January 2014, he was invited to a meeting at the company's office at 64 Maloohtinsky Ave. in St. Petersburg, lit. B, (BC
"St. Petersburg Plaza"), to which he and his friend and colleague Anna Severilova attended. At the meeting on the
company's side were Yan Drachan and Alexander (he does not remember his surname). Alexander, as a more senior
and experienced employee, told them about the prospects of co - operation, as well as about the company and the
options for investing money in order to receive income, told them that the company had existed since 2008, that
during this time it had proved itself in the investment market, that through their company "QB CAPITAL CY LTD" and
the company opened in Cyprus "QB CAPITAL CY LTD", it was possible to officially invest money in securities (shares)
traded on the New York Stock Exchange. They were provided with photocopies of licences dated 24.12.2009, which
were issued by the Federal Service for Financial Markets (FSFM of Russia). They checked the reviews about the
company on the Internet, as well as data on the website of the Central Bank of Russia, where the information was
confirmed - the licences were valid and the reviews were positive. All this was a decisive factor in choosing the
company and confirming its reliability. They were also told at the meeting that the entry threshold to the company
had been significantly reduced and was currently $20,000, which was done to attract new clients. They were promised
a profit of 20% per annum in dollars, with QBF's commission on Trust Management Agreements at 30% of the profit
(the commission was later reduced to 27%). They told that there are three strategies to choose from: aggressive,
weighted average, conservative. They recommended the weighted average strategy (with lower risks and average
profitability). Afer the meeting, having looked at reviews about the company on the Internet and not finding any
negative ones, we agreed to further co - operation. On 16.01.2014 on behalf of non - resident "QB Capital CY LTD" ("QB
Capital CY LTD") entered into the Agreement on Direct Access to the US Securities Market No. 1426 - 14/ISR dated
16.01.2014, as well as on behalf of "QB Finance LLC" entered into the Agreement on Provision of "Trust Management"
Services under the Agreement on Direct Access to the US Securities Market No. 1426 - 14/ISR dated 16.01.2014. The
Trust Management Agreement was signed by Vladimir Sergeevich Pakhomov, General Director of the branch of LLC
Qubey Finance SPB, acting on the basis of Power of Attorney No. 18 dated 01 October 2012, issued by Vladimir
Georgievich Frolov, General Director. The legal information of the company, indicating in it - General Director: Frolov
Vladimir Georgievich, Chief Accountant: Voronova Tatiana Petrovna and Commercial Director: Shpakov Roman
Valerievich confirms this information. He (Bulin G.V.) by receipt, in cash, directly in the office of LLC "Kyubi Finance" at
the address: St. Petersburg, Maloohtinsky Ave. 64, lit. B, (BC "Saint - Petersburg Plaza") transferred funds in rubles for
crediting to his dollar account (details of the dollar account are specified in the agreement) at the exchange rate of the
Central Bank under the agreement with "QB CAPITAL CY LTD" dated 16.01.2014, on 23 January 2014 in the amount of
515,000 rubles and on 29 April 2014 in the amount of 300,000 rubles. When converted into US dollars, the total
amount of cash transferred by him under the receipts is 23,533.40 (US dollars). The cash accepted from him is
confirmed by receipts. The cash was accepted by the financial (later executive) director of the company "QB CAPITAL
CY LTD" Modin Nikolay Vitalievich. Then monthly reports on his portfolio were sent to his e - mail address:
[email protected] from the company's e - mail addresses: [email protected]; [email protected], as well as, when the
reports for some reason did not come in time or were delayed, they were sent by financial advisors: Jan Drachan from
e - mail: [email protected], Gennady Vladimirovich Kisin from e - mail: [email protected], Anton Porfiriev
from e - mail: [email protected]. In August 2014, Gennady Kisin offered to purchase a closed unit of the real
estate investment fund "QBF REAL ESTATE". In 2015, in order to check the company for withdrawal of funds, he wrote
a withdrawal order in the amount of USD 3,000, which at the exchange rate of the Central Bank of the Russian
Federation as of 23.10.2015 is 188,366.4 rubles. The funds were transferred to his current account opened at the
additional office of Avangard Bank, located at the address: St. Petersburg, Nauki Ave. 17, k. 1 (account No.
40817840202600000261). Later, in August 2018, he requested and withdrew another sum of USD 3,300, which at the
maximum exchange rate of the Central Bank of the Russian Federation as of August 2018 is RUB 226,135.47, which he
received at the company's office from Alexei Golubev. In 2016, his financial advisor Gennady Kisin suggested opening
an Individual Investment Account (IIS), which he (Bulin G.V.) did through already QBF IK LLC (INN 7733673955) and
ZENIT Bank. In 2018, his financial advisor at the time, Artyom Efremtsov (email address: [email protected])
827
invited him to his new office located at 11 Degtyarny Pereulok, St. Petersburg, "B", (BC "Nevskaya Ratusha"), 6th floor,
where the St. Petersburg representative office of the financial group "QBF" had moved and insisted on re - registration
of contracts for new companies - "White Lake Management Ltd" registered in the Cayman Islands, "Simtelligence
Company Limited" registered in Hong Kong and LLC "VL Consulting". Saying that they would have problems
withdrawing their money if they did not do so. Justifying it by the fact that under the conditions set by the Cypriot
authorities to the companies from Russia, the rules on withdrawal of funds are tightened, which will violate the terms
of the contracts and that it is difficult to withdraw funds, but it is easy to transfer shares to another company.
Therefore, there will be no documents to withdraw funds from one company and transfer them to another. He was
also assured that it was a mere formality, and taking advantage of his position as a financial advisor, continued to
mislead him and involved him further in the implementation of the criminal scheme, as there were already courts
with Cypriot offshore companies, and the company lef Cyprus, which Artem could not have been unaware of. He said
that the new companies were their affiliated companies, and that the general director had just now gone to Hong
Kong to sort things out. Also, when signing agreements with VL Consulting Ltd and White Lake Management Ltd, he
was offered to contribute additional money and participate in a pre - IPO investment round with SpaceX shares. He
said he had no spare money and could take some of the money in his portfolio. In the end, he was forced to re -
register for new contracts in 2019, saying that the company "QB CAPITAL CY LTD" in Cyprus was closing down. Artyom
Efremtsov misled him as the company was already closed at that time. Reports started to come from the email
address: reports@w - lake.com; reports@wl - mnt.com, and when they were delayed and missing from the mail,
Artem Efremtsov [email protected]. In December 2020, Artem Efremtsov resigned. He and Anna Severilova
went to the company's office to meet with a new financial advisor, who turned out to be Dmitry Vladimirovich
Moskaluk, Vice President of QBF Financial Group. At the same time he and Anna informed Dmitry Moskalyuk that they
were withdrawing all cash from the main account, except for those in the pre - IPO "SpaceX" approximately 2/3 of the
total amount according to the latest reports. Dmytro Moskalyuk tried for a long time to persuade them not to
withdraw money and even to deposit more because, as he said, "now is the best period to deposit money". However,
his arguments seemed unconvincing, even suspicious. In the end, he and Anna Severilova insisted on signing a
withdrawal order. On 22.12.2020, Dmytro Moskaluk sent them a questionnaire and a list of documents to be collected
to submit the order and withdraw the funds. The algorithm of actions and the package of documents from Dmitry
Moskalyuk's letter is given below: 1. He submits a notice and requests a number for an order to sell off the assets in
the account. 2. Within 5 days the number is sent and he prepares an order for asset sale. 3. He comes to the office and
signs the sale order, he files it the same day. 4. The portfolio sale goes through (within 30 days - the time period is
regulated in the contract). 5. They prepare the document package, the document package includes: a. A notarised
English translation of the civil passport (spread with photo and all stamps) b. A colour, notarised copy (extract) of the
foreign passport (photo spread) c. The questionnaire (in the attachment of the letter) you fill in as a WORD document
and send it to him for checking, in fact the questionnaire is filled in with the data obtained from the whole package. d.
2NDFL certificates for the last year. e. A free - form recommendation from the bank about good relations with the bank
in English or with a notarised translation into English. f. Colour scan of TIN. g. Utility bill (proof of residential address)
receipt for payment of utility bills, and a recent payment of it in the bank from which the recommendation will be
made, i.e. your name must be on the payment slip. h. Dollar account details from the bank from which the
recommendation will be issued. 6. A liquidation balance sheet sent afer the sale. 7. They meet and sign an
application to send funds. 8. On the same day, he submits the signed application with the entire package of
documents 9. The order with the documents goes through an internal check.10. The payment is put for sending to the
bank, they submit the documents and the order. 11. The bank checks the documents - sends the money. On
21.01.2021, he and Anna Severilova once again came to the office at 11 Degtyarny Pereulok 11, "B", (BC "Nevskaya
Ratusha"), 6th floor, St. Petersburg, and signed the order for the sale of assets in the presence of Dmitry Moskalyuk.
On 28.01.2021, he sent Dmitry Moskalyuk the completed questionnaire and the entire package of requested
documents (electronically). On the same day Dzmitry Moskaluk sent a reply email from [email protected]
confirming that he had received the documents. Soon Dmytro Moskalyuk stopped answering emails and calls, both to
his mobile phone and on request to his landline (to the QBF office) with a request to call him back. However, he met
with him at the office and Dmytro Moskaluk said that his portfolio was being sold off. He did not receive monthly
statements for April and March 2021. He met again in the office with Dmytro Moskalyuk who said that the reports were
828
not coming because the portfolio was being sold off and the liquidation balance sheet had not yet been formed.
However, at the last meeting he and Anna Severilova had on 07.06.2021 (when she was able to catch Dmitry in the
office of the company) he avoided direct answers. When asked why all the assets have not been sold yet, the terms
expired on 21 March 2021, and the terms of the contract have been violated, Dmitry Moskalyuk began to say that
nobody wants to invest their money, that they have a position in the portfolio, which has sagged by 20% since the
purchase. Later it turned out that this position was bought into the portfolio afer they informed Dmytro Moskalyuk
about their intention to withdraw the money in December 2020. Because of which he assumes that this purchase was
a well - planned action, in order not to fulfil the terms of the contract and ignoring the order to sell off the assets,
Dmitry Moskaluk initially knew about the whole fraudulent scheme and that at the time of the cancellation of the
contract with QB CAP Ltd, The Cyprus company "QB CAPITAL CY LTD" had not existed for a year already, and that the
new contracts signed with "White Lake Management Ltd", "Simtelligence Company Limited" and "VL Consulting" Ltd
were contracts with shell companies, deliberately misleading them, realising that no money would be withdrawn. At
the same time he pretended to be active on the issue of withdrawal of their money. In June 2021, a report was sent to
reports@wl - mnt.com, which showed that Dmytro Moskaluk (and the QBF company) had not performed any of the
actions according to the algorithm sent to withdraw their funds. At the same time he actually made them pay for the
preparation of some of the requested documents, namely: notarised translation into English of a civil passport (photo
spread with all stamps); a colour notarised copy (extract) of a foreign passport (photo spread); a free - form
recommendation from the bank about good relations with the bank in English or with a notarised translation into
English. They also provided: 2NDFL certificates for the last year; colour scan of TIN. At the same last meeting Dmytro
Moskaluk said that they had to sign one more document in which he would assume all costs and losses during the
sale of assets. This document is not stipulated in the contract, but Dmytro Moskalyuk never provided him with the
document. At the meeting Dzmitry Moskaluk said that his printer was not working. He continued to confuse him and
Anna Severilova by using his position as a financial advisor to mislead them that the money would be returned. In
addition, at the meeting Dmitry Moskaluk changed his statements and proposals several times, and then he said that
his company (QBF) has nothing to do with them and our assets, because QBF is just an intermediary, a representative
of the fund in Russia, and the fund is not satisfied with their scandal, they will be contacted directly from "White Lake
Management Ltd", in a month they will receive reports without QBF participation, all communications will be
conducted directly, perhaps the fund, if it agrees with the financial advisors on certain conditions, advisors will still
manage their clients When he and Anna asked where he got this information, Dmitry Moskaluk said that this
information is transmitted through internal closed communication. When he and Anna asked for contacts, Dzmitry
Moskalyuk replied that there had been searches and all computers and documentation had been confiscated, and
that there was no communication now. He did not give them any contacts (e - mail, phone numbers, full names of
people to communicate with). Then Dzmitry Moskaluk said: "I have no time, he went to trade, maybe he will send in
the evening the form of a new order for the sale of assets "at market price" to the e - mail with his personal". When he
said that the money was handed over in your company's office, Dmytro Moskaluk replied, you should have looked at
what you re - signed, referring to the new contracts with "WLM" and "VK - Consulting". Besides, Dmitry Moskalyuk
never sent the forms and did not answer phone calls. At the same time, he and Anna learned about the initiation of
criminal proceedings against unidentified persons from among the representatives of LLC IC QBEF on the grounds of
an offence under Part 4, Article 159 of the Criminal Code of the Russian Federation. From what he made an
assumption that Dmitry Moskalyuk, having a high position, being on good account in the company (according to all
employees of "QBF" with whom he communicated) and possessing additional information, is a direct participant of
the criminal scheme under criminal case No. 12101007754000065, besides, in 2014 Dmitry Moskalyuk already worked
in "QBF" as a head of one of the sales departments, engaged in attracting new clients for "QB CAPITAL CY LTD".
01.07.2021, St. Petersburg representative office of QBF LLC moved out of the occupied office at the address: St.
Petersburg, Degtyarny pereulok 11, "B", (BC "Nevskaya Ratusha"), 6th floor, our phone calls were not answered.
Taking into account the fact that the deadline for returning the money to him had expired, there was no doubt that he
had become a victim of fraudsters. To date, he has not been refunded the money paid to the "QBF" group of
companies in the amount of 400,498.13 rubles. He considers that the persons acting on behalf of the group of
companies "QBF" initially did not intend to fulfil their obligations to him and acted solely with the purpose of stealing
his money by deceiving him. During the period of time from 16.01.2014 to 29.04.2014 the persons acting on behalf of
829
the group of companies "QBF" stole the money belonging to him in the total amount of 400 498,13 rubles. He assesses
the amount of damage caused to him as significant. He has been explained the right to file a civil action in the
criminal case. He wishes to exercise this right and file a lawsuit. He has been explained the right to familiarise himself
with the composition of the investigative teams, with the decisions on the appointment of forensic examinations,
with the conclusions of experts, with the records of interrogations of experts, and also to familiarise himself with the
materials of the criminal case in full or in part. He does not wish to exercise this right. He did not apply to the court
with applications for recovery of money from the "QBF" group of companies;
- (Vol. No. 5, pp. 12 - 17, 133 - 139)
- other documents - documents provided by Bulin G.V. confirming his relationship with QBF Financial Group
- (Vol. No. 5, pp. 20 - 127)
- Evidence and their summary, confirming the guilt of Pakhomov V.S. in committing an offence under
part 4 of article 159 of the Criminal Code of the Russian Federation against Petrov A.N.:
- another document - a statement by Petrov A.N., in which he asks to bring to criminal responsibility persons
- (Vol. No. 5, l.d. 151)
- Testimony of Petrov A.N., given by him as a witness and victim,

according to which in February 2014 he received a call on his mobile number (tel. 8 - 903 - 132 - 85 - 07) from a girl
who introduced herself as a financial advisor of the group of companies "QBF", he did not hear her name. The
aforementioned person voiced a number of offers to invest in various stock exchange products. She was very
persuasive and persistent, offered him to deposit funds as investments, guaranteed income from these investments.
On 07.02.2014, approximately at 13:00, he arrived at the office of the "QBF" group of companies at the address:
Moscow, 8 Presnenskaya Naberezhnaya St., p. 1, where he took part in a conversation with a representative of the
"QBF" group of companies. 1, where he took part in a conversation with Pavel Djimamuradov, financial advisor of QBF
Group. At this meeting, Pavel Jimamuradov, financial advisor, voiced a number of proposals on investing money by
investing in securities. At this meeting Pavel was persuasive and persistent. Thus, he agreed to participate in investing
in securities on international financial markets. At this meeting he was given printouts of advertising offers. On
07.02.2014, approximately at 13:30, afer a conversation with Pavel Jimamuradov, Financial Advisor of QBF Group of
Companies, in the office of QBF Group of Companies at 8 Presnenskaya Naberezhnaya St., bldg. 1, Moscow, he signed
an agreement on granting investment in securities on international financial markets. 1, he signed an agreement on
the provision of "Trust management" services, in accordance with the agreement on the provision of services of direct
access to international stock markets No. 1475 - 14/BP dated 07.02.2014. At the conclusion of the agreement the
representatives of the group of the company "QBF" were the employees of "QBF", namely - Pavel Jimamuradov
(financial advisor) and Shpakov R.V. - the signatory from the side of LLC "QBF". He did not see Shpakov R.V. personally
when signing the agreement. Afer signing the agreement, Pavel Dimimamuradov took the agreement to another
room and returned some time later with the already signed agreement. Afer signing the contract, on 07.02.2014,
approximately at 13:40, in the office of the QBF Group of Companies at the address: 8 Presnenskaya Naberezhnaya St.,
p. 1, Moscow, he handed the contract to Pavel Dmimamuradov. 1, he handed over to Pavel Jimamuradov cash in the
amount of RUB 2,000 and USD 139,949, which at the exchange rate of the Central Bank of the Russian Federation as of
07.02.2014 was RUB 4,860,428.77. The cash was transferred under the agreement on direct access to the US securities
market No. 1475 - 14/BP dated 07.02.2014. Afer the transfer of the funds, the financial advisor told him that he would
issue a receipt for the receipt of the funds later. On 20.02.2014, he received a receipt for receipt of funds in the amount
830
of RUB 2,000 and USD 139,949 to be credited to the account opened with the company "QBF" under the agreement
No. 1475 - 14/BP dated 07.02.2014. The signatory from the company "QBF" was the executive director Gorobets E.V.
Apart from this receipt, he was not given any cash reporting documents on the acceptance of funds from him. On
20.05.2014, approximately from 12 to 14 hours, he arrived at the office of the group of companies "QBF" at the
address: Moscow, Presnenskaya Naberezhnaya St., 8, p. 1. 1. In this office, he handed over to Pavel Djimamuradov
cash in the amount of USD 40,095, which at the exchange rate of the Central Bank of the Russian Federation as of
20.05.2014 amounted to RUB 1,392,900.3. The cash was transferred under the agreement on direct access to the US
securities market No. 1475 - 14/BP dated 07.02.2014. Afer the transfer of funds, he received a receipt on receipt of
funds in the amount of USD 40,095 to be credited to the account opened with "QBF" company under agreement No.
1475 - 14/BP dated 07.02.2014. The signatory from the company "QBF" was the executive director Gorobets E.V.,
except for this receipt, he was not given any cash reporting documents on the acceptance of funds from him. Since
28.02.2014 he received monthly reports on the state of his investment account to his e - mail, until September 2019
from the e - mail address: [email protected], [email protected], however, for the reports on the state of his
investment account, he tried to visit the office of the group of companies "QBF" at the address: Moscow,
Presnenskaya Naberezhnaya St., 8, p. 1 [email protected] , personally, having previously convened at the office of the
group of companies "QBF". 1 , in person, having previously telephoned a financial advisor. Based on the data
contained in the reports, he saw that the amount of the investment was growing. During the whole dialogue with
Pavel Djimamuradov, he (P. Djimamuradov) explained that his (A.N. Petrov) funds were in safe hands, all invested
funds were insured, risks were minimal, and he repeatedly offered him various products for investment. In the future,
the funds were on his investment account, and he had no need to withdraw or withdraw the funds. Approximately in
June 2016, it is difficult to name the exact date, he had a need to withdraw funds, in this regard, he informed his
financial advisor Jimamuradov Pavel about his desire to withdraw funds from the account in the company "QBF".
Afer that, his account № 40817840538254300139, opened in the branch of the additional office of "Sberbank", located
at the address: Moscow, Saikina Street, 2, received funds of approximately 45,000 US dollars, the exact amount is
difficult to name, (the bank statement can provide only for the last 5 years), which according to the official average
monthly exchange rate of the Central Bank of the Russian Federation for June 2016 was 2,939,055.75 rubles (65.31235
rubles - 1 US dollar). Later, it is difficult to name the exact dates, he repeatedly submitted orders for withdrawal of
funds invested in the group of companies "QBF", however, the employees of the group of companies "QBF" in all
possible ways delayed the withdrawal of funds, then were on holiday, then on sick leave, then on a business trip, and
then from 30.11.2019 stopped answering his calls. To date, he has not been able to withdraw the remaining funds
invested in the "QBF" group of companies. Around autumn 2020, he heard about a criminal case opened against the
founders of QBF. Afer that, in July 2021, he applied to the Lefortovsky District Court of Moscow with a petition for
recovery of funds from the company LLC "IC "QBF", 07.12.2021 his claim for recovery of funds was refused. Thus, in
the period from 07.02 to 20.05.2014, his money in the amount of RUB 6,257,329.07 was stolen from him;
- (Vol. No. 5, pp. 154 - 158, 191 - 194)

- other documents - documents provided by A.N. Petrov confirming his relationship with QBF Financial Group
- (Vol. No. 5, pp. 161 - 181, 195 - 201)
part 4 of article 159 of the Criminal Code of the Russian Federation against Sapozhkov N.G.:
- another document - a statement by N.G. Sapozhkov, in which he asks to bring to criminal responsibility
persons from among the employees, managers of the financial group "QBF" (LLC "Investment Company
QBF"), who stole his money under the guise of carrying out brokerage activities;
(Vol. No. 6, l.d. 6)
831
- The testimony of N.G. Sapozhkov, given by him as a witness and victim,
according to which he learned about the existence of the group of companies "QBF", which is engaged in successful
investments and pays citizens a favourable interest on investment activities, from his acquaintances, according to
which he learned about the middle of 2014. He had free savings and decided to make enquiries in the Internet about
the group of companies "QBF". In the network - Internet he found a large number of positive reviews, in connection
with which, he had even more interest in co - operation with the group of companies "QBF". One of his acquaintances,
who is difficult to name, gave him the phone number of the head of the investment services department of "QB
Finance" Kirill Sobolev (tel. 8 - 903 - 100 - 60 - 27). He contacted K. Sobolev and arranged a meeting with him at the
main office of the "QBF" group of companies to discuss their possible co - operation in more detail. Thus, on
23.07.2014, at approximately 14:00, he arrived at the office located at the address: Moscow, Presnenskaya
Naberezhnaya, 8, p.1, 9th floor. Upon arrival at the office, he was met by K. Sobolev and escorted to a meeting room,
where Sobolev K.'s supervisor - Deputy Director of QB Finance's Sales Department Yudin Maxim (tel. 8 - 903 - 100 - 24 -
68) - came later. During the meeting Sobolev K. and Yudin M. presented to him the investment products available in
the organisation, ways of investing, mechanism of profit formation, order of reporting and informing the client, as
well as in general the structure of the organisation, it was informed to him that the money will be invested in
investment sites of foreign countries and for this reason the money is required in currency. Everything was presented
in a colourful form, devoid of flaws, he was promised a high yield. He was also provided with the original licences of
the Central Bank of the Russian Federation. At the end of the meeting he was offered to conclude an agreement to
provide direct access to international stock markets. Yudin M. had already signed copies of documents with LLC
"Kyubi Finance" represented by Munaev Zelimkhan Visaitovich, namely the agreement on provision of "Trust
management" services No. 1721 - 14/IMR dated 23.07.2014, as well as the agreement on provision of services of direct
access to international stock markets with "QB Capital CY LTD" No. 1721 - 14/IMR dated 23.07.2014 in the person of the
representative by power of attorney Munaev Z.V. He gave his consent and signed the said documents, at the same
time he took a pause to deposit funds. On 30.07.2014, at approximately 14:00, he again arrived at the office located at:
Moscow, Presnenskaya Naberezhnaya, 8, bldg. 1, 9th floor. On arrival at the office, he was met by Mr K. Sobolev and
escorted to a meeting room. He came to this meeting with cash on hand to transfer it for investment activities to the
"QBF" group of companies within the framework of the agreements already concluded between them. Yudin M. was
also present at the meeting. He handed Yudin M. USD 100,000 in cash, which at the exchange rate of the Central Bank
of the Russian Federation as of 30.07.2014 was RUB 3,563,000. Yudin M. counted them on a money counting machine
and lef the meeting room. Some time later Yudin M. returned to the meeting room with a document in his hands, in
which it is written that the company "QB Capital CY LTD" confirms receipt of funds in the amount of USD 100,000 from
him. He (N.S. Sapozhkov) was not satisfied with this document and began to ask questions about the incorrect
registration of the receipt of funds from him. In response to his questions, Yudin M. invited Munayev Z. to their
meeting room, who confirmed the correctness of the actions of his employees. He was still not satisfied with this
order of things, so he made a receipt on the above document with his own hand about the fact of his money deposit,
but the above - mentioned citizens refused to sign it. Nevertheless, at the next meeting he was handed a receipt for
the deposit of funds No. 3007SN, signed by Munaev Z.V. Afer he had invested funds in the group of companies "QBF",
he started receiving reports to the e - mail address [email protected], which were received until May 2021. These
reports reflect the state of his investment portfolio. He was assigned a manager - Yudin M., then he was replaced by
Gurevich Igor (tel. 8 - 903 - 100 - 46 - 33), they periodically called and communicated about the state of his investment
portfolio. Also through communication by phone, he ordered to withdraw the "interest" received from investment
activities to his foreign currency account opened with Avangard Bank. Thus, between November 2016 and August
2018, he received 2,687,966 roubles from the QBF group of companies. He received the funds both in cash and non -
cash form. Twice during the entire time he received a call from Gurevich I. and invited him to the company's office for
a meeting to sign additional documents. Taking into account the high level of his trust, as well as the situation with
his investment portfolio reflected in the reports, he did not refuse Gurevich I. and arrived at the office of the company.
Thus, on 04.06.2018, he arrived at the company's office at the address: Moscow, Presnenskaya Naberezhnaya, 8, bldg.
1, 9th floor, he was met by Gurevich I. and escorted to the meeting room. In the meeting room Gurevich I. informed
him that in connection with the modification and development of the investment strategy of the QBF Group of
832
Companies he had to sign new documents of a technical nature. Thus, he signed a service agreement No. 1721 dated
04.06.2018 with "Simtelligence company Limited" represented by Korshunov D.A. Similarly, he signed a service
agreement with LLC "VL - Consulting" (INN 7706463476) represented by Maricheva O.V., as well as trust management
agreement No. D - 423227 - K with "White Lake Management Ltd" represented by Korshunov D.A. Payments were
suspended at the end of August 2018, later he started asking questions and periodically called his financial advisor on
this issue. Gurevich I. informed him about some reasons for which the payments were delayed. He was alarmed by all
this, but decided to allow some more time for the QBF. Later, at the end of May, the beginning of June 2021, he
learned from the media (the official website of the Ministry of Internal Affairs of the Russian Federation) that criminal
cases had been opened and an investigation was underway. Taking into account the specifics of communication with
managers, problems with attempts to withdraw funds, and also taking into account the fact that the money has not
been returned in full, he has no doubts that he has become a victim of fraudsters. He believes that an offence has
been committed against him, namely the thef of his funds in the amount of USD 100,000 through deceit and abuse of
trust. He estimates the amount of damage caused to him as significant, namely 875,034 roubles;
- (Vol. No. 6, pp. 9 - 13, 20 - 24)

- other documents - documents provided by N.G. Sapozhkov confirming his relationships with QBF Financial
- (Vol. No. 6, pp. 25 - 86)
- Evidence and their brief content, confirming the guilt of Pakhomov V.S. in committing an offence under
part 4 of article 159 of the Criminal Code of the Russian Federation against Shapran A.V.:
- another document - a statement of A.V. Shapran, in which she asks to bring to criminal responsibility persons
from among the employees, managers of the financial group "QBF" (LLC "Investment Company "QBF"), who
stole her money under the guise of carrying out brokerage activities;
- (Vol. No. 6, l.d. 98)
- The testimony of A.V. Shapran, given to her as a witness and victim

, according to which in September 2014, her mobile number (tel. 8 - 905 - 534 - 50 - 72) received a call from a girl
named Yulia, who introduced herself as a financial advisor of the group of companies "QBF", she finds it difficult to
specify more precise data. The above - mentioned person on the phone, and then at a personal meeting, voiced a
number of proposals to invest money by investing in securities. In October 2014, she met with a representative of the
company "QBF", who introduced himself as Zaitsev Evgeny, in a café, the exact name and address of which she finds it
difficult to give, and had a conversation with him about investing in securities. This conversation was an advertising
campaign of the group of companies "QBF". At this conversation Zaytsev Evgeny voiced a number of offers on
investment of money means by investing in securities. Zaitsev Evgeny was persuasive and persistent, so she agreed to
participate in investing in securities on the Russian and international financial market. Also earlier, for her personal
peace of mind, she checked the company on the Internet for the presence of a licence of a professional participant of
the securities market, which was confirmed by the available information. At this meeting she was given printouts of
advertising offers. Subsequently, all consultations on financial products were also conducted with her by Zaitsev
Evgeny. On 28.10.2014, being in a cafe, in the area of the Tretyakovskaya metro station of Moscow at an unspecified
place, in order to invest money in securities with high yield, she signed with the company "QB Capital CY LTD" ("QB
Capital CY LTD") Agreements on rendering services of direct access to international stock markets No. 1880 - 14/IMR
dated 28.10.10.2014 and also entered into an agreement for providing "Trustee" services under Direct Access to
International Stock Markets Services Agreement No. 1880 - 14/IMR dated 28.10.2014 on behalf of Qubey Finance Ltd.
On 31.10.2014, while at the office of Qubey Finance LLC, located at the following address: 8 Presnenskaya
Naberezhnaya Naberezhnaya, bld. 1, she made a cash transfer of 425,000 roubles. Subsequently, monthly investment
portfolio reports on the status of her investment portfolio were sent to her email address. Until July 2016, reports
from qbfin came from the email address [email protected], from August 2016 from [email protected], then from the
email address reports@wl - mnt.com. On 14.09.2018 she arrived at the office of QBF Group of Companies at the
833
address: Moscow, 8 Presnenskaya Naberezhnaya St., pg. 1, to withdraw some funds from her investment account,
where she received from Abbas Abdukadyrov cash in the amount of USD 3,000, which at the exchange rate of the
Central Bank of the Russian Federation as of 14.09.2018 amounted to RUB 205,911 (two hundred and five thousand
nine hundred and eleven rubles). Throughout her communication with the financial advisor Zaitsev Evgeny, and afer
his replacement in April 2018 Abbas Abdukadyrov, they explained that her funds were in safe hands, and repeatedly
offered her various products for investment, for example in construction in Severodvinsk, in the company's
construction projects in Odintsovo. On a monthly basis, she received reports on the investment portfolio on her e -
mail address about the trading on the account. Based on the data sent to her, the investment amount was increasing.
In June 2019, the financial advisor Abbas Abdukadyrov resigned and she asked for the contacts of a new financial
advisor, she was informed in an email that Ruslan Sokolov was appointed as her financial advisor. In June 2019 she
decided to completely withdraw all the funds from her investment account and in August 2019 Ruslan Sokolov sent
her an order, with which she got acquainted and on 21.08.2019 in the office of the company "QBF" at the address:
Moscow, Presnenskaya Naberezhnaya St., 8, p. 1, she signed this order. 1, she signed this order and handed it over to
Artyom Tallerov. In October 2019, she wrote to Ruslan Sokolov to find out how things were with the withdrawal of her
funds. On 30.10.2019 Ruslan Sokolov replied that he had made an enquiry about her portfolio. On 12.11.2019 she
received a report on the portfolio, from which it was clear that it was not sold out. Further, she received an email from
Ruslan Sokolov with an attached contract that needed to be re - signed. She did not re - sign this contract and further
dialogue with the financial advisors from QBF ceased. In July 2020 she started again correspondence on withdrawal of
funds from her account. She received a letter from Arthur Avanesyan on her mail that he is a financial advisor from
"QBF" company. He sent her a list of necessary documents for signing a new agreement for withdrawal of funds. Afer
familiarising herself with the documents and adjustments, she came to the office of the "QBF" company at the
address: Moscow, Presnenskaya Naberezhnaya St., 8, p. 1 and signed all the documents, the new one. 1 and signed all
the documents, new contracts and notices. The contracts were re - signed on 21.07.2020 with the company "White
Lake Management" trust agreement No. D - 065288 - G and the company LLC "VL Consulting" application for
accession No. 065288 - 01, as well as the definition of cancellation of the agreement on the provision of services of
"trust management" from 28.10.10.2014 between LLC "QBF", definition on cancellation of Agreement on provision of
services of direct access to international stock markets No. 1880 - 14/IMR dated 28.10.2014, signed agreement on
provision of services No. 1880 dated 04.06.2018 with Limited Liability Company "Simtelligence". Afer the re - signing,
she had no contact with the employees of the company, she was not interested in her investment account and the
status of funds in it. In May 2021, she heard from the mass media (official website of the Ministry of Internal Affairs of
the Russian Federation) about a criminal case initiated against the founders of QBEF and about searches conducted in
the office of QBEF. In June 2021, she tried to call the company, but to no avail, those who answered the phone could
not explain anything clearly. Also, on 15.07.2021 she was in the office at the address: Moscow, Presnenskaya
Naberezhnaya St., 8, p. 1, where the employee Evgeny (tel. 1, where the employee Evgeny (tel. 8 - 903 - 100 - 48 - 69),
more precise data is difficult to name, but at a meeting will be able to identify, offered her one of the options for
withdrawal of funds to buy ZPIF of real estate "RIF Warehouse Federal 1" in Novorossiysk. She asked him to send her
documents to the post office, which she would study and inform her decision, no documents were sent to the post
office. On 04.08.2021, notices on the realisation of assets were sent by courier mail to LLC IK QBF, LLC VL Consulting
and Simtelligence, as well as duplicated by e - mail. To date, the money has not been returned to her in full. She
estimates the amount of damage caused as significant;
- (Vol. No. 6, pp. 101 - 103, 123 - 127)

- other documents - documents provided by A.V. Shapran confirming her relationship with QBF Financial
- (Vol. No. 6, pp. 104 - 116, 128 - 186)
part 4 of article 159 of the Criminal Code of the Russian Federation against Polyakova I.E.:
- another document - a statement by I.E. Polyakova, in which she asks to bring to criminal responsibility
"QBF"), who stole her money under the guise of carrying out brokerage activities;
834
- (Vol. No. 7, pp. 6, 10)
- I. E. Polyakova's testimony , given to her as a witness, a victim,

according to which in 2014 Slobodov Alexander Arsenievich, who is her neighbour, told her about the group of
companies "OVF", namely about the possibility of additional income by investing money in IRO - initial placement of
securities on the stock exchange. She called the general telephone number of the "OVF" group of companies and was
answered by a secretary whose details she did not remember. She lef her contacts with the secretary. Afer that she
was contacted by the manager of the group of companies "OVF" Gennady Vladimirovich (tel: 8 - 921 - 858 - 16 - 35),
who immediately began to mislead her about allegedly financial products of the group of companies "OVF", about the
system of participation in IRO allegedly with increased allocation. By his stories Gennady Vladimirovich convinced her
that the group of companies "OVF" has a long and successful experience of work in Russia and abroad, has direct
access to IRO, all necessary licences are available. Gennady convinced her that the reliability of work with the group of
companies "OVF" is guaranteed by the legislation of the Russian Federation. Having trusted Gennady Vladimirovich,
she agreed to deposit her money in the group of companies "OVF". She provided her e - mail address:
iгеу[email protected], to which the documents for signing the agreement and participation in investment projects were
sent. On 13.10.2014 they entered into the Agreement on provision of services of direct access to international stock
markets No. 1850 - 14/ISR dated 09.10.2014, and on behalf of QB Finance LLC the Agreement on provision of "Trust
Management" services in accordance with the Agreement on provision of services of direct access to international
stock markets No. 1850 - 14/ISR dated 09.10.2014. In the period from 13.10.2014 to 11.12.2014, being in the office of
QBIF LLC located at the address: St. Petersburg, Maloohtinsky pr., 64, lit. "B" (BC "Plaza SPb"), she handed over
monetary funds to the employees of QBIF LLC, namely: 13.10.2014 in the amount of RUB 600,000, 27.10.2014 in the
amount of USD 6,000, which at the exchange rate of the Central Bank of Russia as of 27.10.2014 is RUB 250,860.60, and
EUR 6,000, which at the exchange rate of the Central Bank of Russia as of 27.10.2014 is RUB 317,439; 11.12.2014 in the
amount of RUB 600,000. The total amount of deposited funds totalled RUB 1,768,299.60. In order to give the
appearance of real investment of funds, Gennady Vladimirovich gave her 4 so - called "documents" in which the
amount of deposited funds was indicated. Afer that, she started receiving monthly reports from the e - mail address:
герогтѕ@w1 - mnt.соm. containing information about the alleged presence of her funds on the account of the
company "OVF". She believed her funds were invested. In October 2021, she decided to terminate all contracts with
the group of companies "OVF" and take back her money, for this purpose she came to the above - mentioned office of
IK QBF LLC. However, the office was closed and phones were not answered. At that time, she saw information in the
media that criminal cases had been opened and investigations were underway against employees and managers of
the OVF group of companies. This confirmed her thoughts that she had become a victim of fraudsters. To date, she has
not received a refund of the money paid to the "OVF" group of companies in the amount of 6,000 US dollars, which at
the exchange rate of the Central Bank of Russia as of 27.10.2014 amounts to 250,860.60 rubles, and 6,000 Euros, which
at the exchange rate of the Central Bank of Russia as of 27.10.2014 amounts to 317,439 rubles and 1,200,000 rubles.
She believes that the persons acting on behalf of the "OVF" group of companies initially did not intend to fulfil their
obligations to her and acted solely for the purpose of stealing her money by deceiving her. The persons acting on
behalf of the "OVF" group of companies stole her money in the total amount of 1,768,299.60 roubles. She considers
the amount of damage caused to her as significant. She has been explained the right to file a civil action in the
criminal case. She wishes to exercise this right and file a lawsuit. She has been explained the right to familiarise
herself with the composition of the investigative teams, with the decisions on the appointment of forensic
examinations, with the conclusions of experts, with the records of interrogations of experts, and also to familiarise
herself with the materials of the criminal case in full or in part. She does not wish to exercise this right. She has not
applied to the court with applications for recovery of money from the group of companies "IAB";
- (Vol. No. 7, pp. 11 - 14, 83 - 85)

- other documents - documents provided by I.E. Polyakova confirming her relationship with QBF Financial
- (Vol. No. 7, pp. 18 - 76)
835
part 4 of article 159 of the Criminal Code of the Russian Federation against Shut O.N.:
- another document - a statement by O.N. Shut, in which she asks to bring to criminal responsibility persons
(Vol. No. 7, pp. 99, 103)
- Testimony of O.N. Shut, given to her as a witness and victim,

according to which in early July 2013, she received a phone call from the manager of LLC "Kyubi Finance" Alexander
(she cannot remember his surname now). He invited her to a meeting to familiarise her with the company's activities
and its investment proposals. In the middle of July at the meeting Alexander told her about the trust management
service. Three strategies were offered: conservative, medium and high risk) with approximate returns of 20%, 30% -
35% and 60% - 85% respectively. The remuneration for managing the funds was 30% of the profit earned. The
following documents were provided as confirmation of the legitimacy and reliability of the company, additional
guarantees: Order No. 24/2012 "On the establishment of a separate structural subdivision" dated 01.10.2012, three
licences of a professional participant of the securities market of LLC "Kyubi Finance" (licences: series 01, No. 010595;
series 01, No. 010596; series 01, No. 010597 without limitation of validity), risk insurance for 500.000 USD. Special
emphasis was made on the fact that the company "Kubi Finance" is extremely reliable, has large partners, passes the
checks of the Central Bank of the Russian Federation and at the same time offers an extremely profitable and securely
insured trust management product with an affordable entry threshold (from 10,000 USD). 26.07.2013 in the office of
LLC "Qubey Finance" (195112, St. Petersburg, Maloohtinsky pr. 64, literature "B", BC "St. Petersburg Plaza"), they
signed a set of Documents on trust management: - Agreement on direct access to the U.S. securities market № 1131 -
13/VR of 26.07.07.2013 (Agreement on direct access to the U/S/equities market No. 1131 - 13/BP 26.07.2013); -
Agreement on provision of "Trust Management" services 10 111 (ten thousand one hundred and eleven) US dollars.
The funds were transferred in the office of LLC "Kubi Finance" to the manager Alexander, who brought a receipt on
receipt of funds on behalf of the financial director Modin Nikolay Vitalievich. The next replenishment of the account
took place on 21 September 2013 by bank transfer without concealment of the current account, through the cash
desk in the branch of PJSC "SberBank" located at the address: St. Petersburg, Novocherkasskiy prospect, 33, bldg. 3.
The amount of the transfer was 480 000 (four hundred and eighty thousand) rubles, which amounted to 15 126 (fifeen
thousand one hundred and twenty - six) US dollars at the exchange rate of the Central Bank as of 21.09.2013. In order
to make the transfer, the manager of Qubey Finance LLC personally accompanied her to the bank branch to assist her
in making the transfer. Approximately three months later, she received a phone call from another employee of Qubey
Finance LLC, Sergey Tetyuev, who informed her that he would now be her financial advisor because Alexander had
been fired for "leaking the client base to competitors". From 2014 until recently, she interacted only with Sergey
Tetyuev as a representative of OVF and as a financial advisor. In order to get acquainted and discuss various issues,
Sergey Tetyuev invited her to the office of Qubey Finance LLC. During the meeting Sergey actively promoted trust
management, offered to increase the amount of funds under management, spoke about the complete reliability and
high professionalism of the specialists of Qubey Finance LLC and guarantees of the result taking into account the
chosen strategy. Besides, in 2014 there were two more cash deposits with receipt of receipts dated 10.02.2014 in the
amount of 400 000 (four hundred thousand) rubles, signed by the Executive Director of QB Capital CY LTD Elena
Gorobets and 16.12.21014 in the amount of 740 000 (seven hundred forty thousand) rubles, signed by the Financial
Director Nikolay Vitalievich Modin - all employees of QB Capital CY LTD. At the official exchange rate on the date of
deposit, these amounts totalled USD 11,189 (eleven thousand one hundred and eighty - nine) and USD 12,683 (twelve
thousand six hundred and eighty - three) respectively. These deposits were made as a result of active campaigning by
the financial advisor Sergey Tetyuev, who convinced not only of the reliability but also of the profitability of
investments, taking into account the growth of the ruble - dollar exchange rate and the receipt of income in foreign
836
currency. Funds were transferred in the office of QB Finance LLC to the financial advisor Sergey Tetyuev, who in
exchange provided receipts for receipt of funds from the specified employees of QB Capital CY LTD. She did not receive
any documentary evidence that the money had been credited to her account at QB Capital CY LTD. The amount was
reflected only in the reports sent out. It is possible that the money deposited by her was misappropriated by the
persons indicated in the receipts, financial advisers or a group of persons. As it later turned out, no one could confirm
the amounts of her assets in trust. However, in 2015 there was one withdrawal of funds in the amount of USD 5,000
(Inbound Swif Transfer dated 17.03.2015), which amounted to RUB 310,748 (three hundred ten thousand seven
hundred and forty - eight) 50 kopecks (the official USD/RUB exchange rate as of 17 March 2015 was 62.1497). There
were no other transactions under these agreements. Periodically (usually once a month), sometimes afer a question
to the financial advisor, reports were received by her. In them practically every month some portfolio of shares,
financial result, for the period the size of commission was reflected. And the financial result was almost always
positive and at about the same level (1.5% - 3% per month). Unexpectedly, in 2018, the financial advisor Sergey
Tetyuev informed her about the need to reissue the contracts. As a justification, he said that this is due to tax
legislation and for further work and cash refunds, new contracts need to be signed. All this is also reliable and
profitable, the same analysts and traders are working, just the name is changed. At the same time trust management
on international markets is still the direction of "OVF" activity. As a result, there was signed the Service Agreement No.
1131 dated 04.06.2018 between it and Limited Liability Company Simtelligence, the Service Agreement with Limited
Liability Company "VL Consulting" dated 23.10.2019, Asset Management Agreement No. D - 191020 - J dated
23.10.2019, Trust Management Agreement No. D - 191020 - J dated 23.10.2019. When signing the agreements, the
amounts that were transferred under the new Agreements from the accounts opened under the agreements between
her, QB Capital and QB Finance LLC (QB Finance LLC was reorganised, legal successor of the rights and obligations of
QBIF LLC) did not appear anywhere, i.e. the actual transfer of funds to her account was not confirmed by anything. It
is possible that there was no such transfer and the money was withdrawn earlier or did not enter the trust
management account at all. She only received reports in the form of files, which are not signed or confirmed by
anyone. The re - signing of the contract and agreements look fictitious. The legal entities of the company, had the
purpose to steal her funds or to hide fraudulent schemes and as a result not to return the invested funds, to avoid
responsibility and to get out from under the control of the Central Bank of the Russian Federation. Sergey Tetyuev
assured that it would only be more profitable, but no less reliable and convenient. Moreover, financial advisor Sergey
Tetyuev claimed that it was OVF Group that had found the best way for the client to make a profit and minimise the
burden. Other investment and brokerage companies, namely "BKS", did not find such solutions. At the same time,
trust management has always been positioned by Sergey Tetyuev as a product of OVF and managed by OVF
employees. Financial Advisor Sergey Tetyuev has worked in the group "OVF" for more than 8 years, holding various
management positions. According to him, during his career, he was involved in training employees of all branches of
OBF, headed the OBF office in Belgorod, and then, according to him, headed the OBF office in Kaliningrad (since about
2018). Most likely, he was aware of what was happening, but continued to assure reliability and persuade to sign new
contracts and agreements. In August 2020, he claimed that the product was the best on the market and
recommended not to withdraw funds and earn income (income on paper). In addition, the financial advisor Sergey
Tetyuev regularly asked for contacts of acquaintances to also suggest that they invest in trust management from OVF.
In March 2020, she decided to withdraw some funds from the trust management, but due to the crisis from OVF, the
reports showed large minuses and Sergey Tetyuev persuaded her not to submit any withdrawal orders until the
situation improved. In August 2020, she sent a request to the financial advisor Sergey Tetyuev asking him to confirm
that she had assets in the amount indicated in the report. But in response she received a refusal with the reasoning
that it is impossible - there are no personal accounts, there are some segregated accounts (confirmed by email
correspondence). Moreover, the financial advisor Sergey Tetyuev continued to claim that the invested funds would
bring income, although at that time the funds were not returned to the clients. Then she submitted a request (order)
to withdraw USD 50,000 (fify thousand). In response, the financial advisor Sergey Tetyuev sent a list of documents to
prepare the withdrawal, and also sent a request for a "portfolio sale" (Notice of Asset Disposal dated 21.09.20 - signed
at the OVF office in St. Petersburg). As a result, they received confirmation of the portfolio sale for USD 50,000. All
documents for the withdrawal of funds were prepared, notarised, a 2NDFL certificate and her employment contract
were provided, which confirmed the origin of the funds. In addition, an application for withdrawal of funds was
837
prepared. However, it was not possible to receive the funds. In November 2020, she was confirmed to sell off her
assets. The financial advisor Sergey Tetyuev sent for filling and signing, the remaining documents. He also told her
about the legal complexities and that she needed to wait. By that time she had already learnt that there were a large
number of cases where people were not getting their money back for months or even years, there was no response to
complaints to the Central Bank of the Russian Federation, and court proceedings had already started. The financial
advisor argued that there are isolated cases related to incorrect documents, and so the funds are paid, perhaps with a
slight delay. As a result, in January 2021, the financial advisor Sergey Tetyuev offered "the only option to return the
funds" - through offsetting into units of the ZPIF "Skladskoy Federal" with the promise to further put in line for the
realisation of this sought - afer and profitable asset. Since she did not see any other ways to return the funds, and the
ZPIF was managed by a management company with a licence from the Central Bank of the Russian Federation, she
agreed to sign the documents and receive the units. At the same time, the value of the units at which they were to be
delivered to her was about 2 times higher than the estimated value indicated on the management company's website.
Financial advisor Sergey Tetyuev explained this as "tax optimisation" - the valuation of the fund's assets was
deliberately understated in order not to pay high taxes. The full set of documents to be signed was presented to her
only in the office of QBF LLC (address: St. Petersburg, Degtyarny per. 11 lit. B, pom.1 - H - "Nevskaya Ratusha"). The
financial advisor Sergey Tetyuev did not warn that it would be an obscure scheme with some strange operations and
counterparties. But since there were no other options, no possibilities to withdraw the funds, according to the
financial advisor Sergey Tetyuev, she signed the documents in the hope of receiving at least shares. The set of
documents included: 1. Set - off agreement between Olga Nikolaevna Shut and Lamera Holding Limited dated
17.04.2021 (it states that the company has debts to her, but such company is unknown to her); 2. Transfer Agreement
between Olga Nikolaevna Shut and Lamera Holding Limited; 3. Subscription Agreement for Aurum Access Sarl (in
English); 4. Subscription Agreement for Aurum Access Sarl (translation of the document from para. 3); 5. Netting
Agreement between Shut Olga Nikolaevna and Lamera Holding Limited on 5 sheets in 1 copy; 6. Unit Purchase and
Sale Agreement between Shut Olga Nikolaevna and Lamera Holding Limited; 7. Termination Agreement; 8. Service
Agreement between Shut Olga Nikolaevna and Limited Liability Company Simtelligence dated 27.04.2021. According
to the information of the financial advisor Sergey Tetyuev, the units have not been credited and all agreements,
contracts have not been executed. As the shares have not been delivered and all agreements are null and void. The
money is on the account. However, the money cannot be transferred due to legal nuances. From the moment of
searches in May 2021 in the offices of OVF and further revocation of licences of QBIF LLC (02.06.2021) it became
obvious that the funds will not be returned. From the moment of initiation of the refund process until the revocation
of the licence of IC QBF LLC, the financial advisor Sergey Tetyuev assured that "everything will be fine" and maybe a
little later, one way or another, but the funds will be returned to it. Since the revocation of the licence in June 2021,
the financial advisor Sergey Tetyuev has been communicating only via WhatsApp messenger, with the main message:
"No information yet; no options yet; Money is on the account, they can't transfer it". She believes the money has been
stolen and all trustee - related activity is fictitious and unsupported. No contacts for communication with those who
have her money in the account can be provided by the financial advisor Sergey Tetyuev. The only contact WLonsulting
has in the form of an e - mail address, which he provided for communication with his "partner" (regionsupport@/wl -
consulting.ru), is invalid, and e - mails to it do not go through. At the same time, she continues to receive fake monthly
statements for the cash balance, and the financial advisor suggested she apply for a sale of the portfolio balance. All
negotiations, signing of documents, operations on transfer of cash for crediting to her trust management account
took place only in the office of the group of companies "OVF" first at the address: 195112, St. Petersburg,
Maloohtinsky prospect 64, lit. "B", BC "St. Petersburg Plaza", then at the address: 191144, St. Petersburg, Degtyarny
per. 11, lit. "B", room 1 - H. Nevskaya Ratusha" BC) and only with the employees of "OVF" (mainly Sergey Tetyuev, the
financial advisor). All documents came from the email address of Sergey Tetyuev's financial advisor
([email protected], [email protected]), periodically reports also came directly from the email addresses
of Sergey Tetyuev's financial advisor. The initial contract was signed with QB Finance LLC and QB Capital CY LTD.
Reports came from the following email addresses: reports@qbfin. ru and [email protected]. Further (since October
2019), the reports came from the email (reports@wl - mnt.com) or from the email of the financial advisor Sergey
Tetyuev ( [email protected]). Believes that all agreements and contracts that were provided to her in order to
obtain more favourable terms (according to the financial advisor) were fraudulent schemes and were intended to
838
conceal the embezzlement of her funds received in cash by the financial advisor and employees of QB Finance LLC.
The financial advisor Sergey Tetyuev, who has (had) a certificate of a professional participant of the financial market,
deliberately misled her when reissuing documents from QB Finance LLC (QBF LLC) and QB Capital to dubious
companies, while pretending to be QBF group of companies with licences and reputation in the market. No funds
have been transferred anywhere, and there is not a single reliable document, neither about crediting of funds to her
trust management account, nor about further transfers within the framework of re - signed agreements. To date, she
has not been returned the funds deposited in the cash desk of the group of companies "OVF", as she then naively
believed for investment in the amount of 1 639 251,50 rubles. She believes that the persons acting on behalf of the
group of companies "QBF" initially did not intend to fulfil their obligations to her and acted solely for the purpose of
stealing money, having deceived her. During the period of time from 10.04.2014 to 16.12.2014, the persons acting on
behalf of the "QBF" group of companies stole money belonging to her in the total amount of RUB 1,639,251.50. She
considers the amount of damage caused to her as significant. She has been explained the right to file a civil action in
the criminal case. She wishes to exercise this right and file a lawsuit. She has been explained the right to familiarise
examinations, with the conclusions of experts, with the records of expert interrogations, and also to familiarise herself
with the materials of the criminal case in full or in part. She does not wish to exercise this right. In addition, she has
not applied to the court for recovery of money from the OVF group of companies;
- (Vol. No. 7, pp. 104 - 110, Vol. No. 8, pp. 44 - 49)

- other documents - documents provided by O.N. Shut, confirming her relationship with QBF Financial Group
- (Vol. No. 7, pp. 114 - 237, Vol. No. 8, pp. 1 - 39)
part 4 of article 159 of the Criminal Code of the Russian Federation against Ptitsyn A.A.:
- another document - a statement by A.A. Ptitsyn, in which he asks to bring to criminal responsibility persons
- (Vol. No. 8, pp. 62, 63)
A.A. Ptitsyn's Testimony

given as a witness and victim, according to which in December 2014, on the recommendation of an acquaintance, he
went to the office of the "QBF" group of companies at 8 Presnenskaya Naberezhnaya St., p. 1, Moscow, where he met
his financial advisor Adam Guchigov (tel. 8 - 926 - 430 - 12 - 90). 1, where he met his financial advisor Adam
Guchigov (tel. 8 - 926 - 430 - 12 - 90). Guchigov A. offered him to invest in various stock exchange products, he was very
persuasive and persistent, Adam offered him to deposit money as an investment and guaranteed a high return on
these investments. On 26.12.2014, at about 14 hours, he arrived at the office of the group of companies "QBF", at the
address of Moscow, Presnenskaya Naberezhnaya St., 8, p. 1, where he took part in a conversation with a
representative of the group of companies "QBF". 1, where he took part in a conversation with a QBF employee. This
conversation was an advertising campaign of the QBF group of companies. Guchigov A. was present at this
conversation. He was given a number of offers to invest money by investing in securities. Adam Guchigov was
persuasive and persistent, afer which he agreed to participate in investing in securities on the Russian and
international financial market. At this conversation he was given printouts of advertising offers. Further all
consultations on financial products were conducted with him by Guchigov A. On 26.12.2014, at about 15:00, in the
office of the "QBF" group of companies at the address: Moscow, Presnenskaya Naberezhnaya St., 8, p.1, he signed the
agreement on provision of services of direct access to international stock markets No. 1969 - 14/IMR dated 26.12.2014
with the company "QB Capital CY LTD" and the agreement on provision of "Trust management" services, in
accordance with the Agreement on provision of services of direct access to international stock markets No. 1969 -
14/IMR dated 26.12.2014 with the company "QBFinance" LLC. Both documents on behalf of the companies were
signed by Munaev Zelimkhan. He did not see Munaev 3. in person when signing the agreement. On the same day,
immediately afer signing the agreements, in the office of the company "QBF" he handed over to Guchigov A. cash in
839
the amount of 117,000 USD, which at the exchange rate of the Central Bank of the Russian Federation as of 26.12.2014
was 6,156,540 rubles. The cash was transferred under the agreement on direct access to the US securities market No.
1969 - 14/IMR dated 26.12.2014. Afer the transfer of funds, he was given a receipt dated 26.12.2014 on receipt of USD
117,000 to be credited to the account opened in the company "QB Capital CY LTD" (Nicosia, Cyprus), to the account
under the agreement №1969 - 14/IMR dated 26.12.2014. The signatory in the receipt from the company "QB Capital CY
LTD" was the executive director Gorobets E.V., except for this receipt no cash reporting documents on the acceptance
of funds from him were not given to him. Afer the transfer of funds to the employee of the company "QBF" and their
crediting to his investment account, he received monthly reports on trading on the account to his e - mail address,
based on the data sent to him, he saw that the amount of investments was growing. Throughout the time of
communication with A. Guchigov, he explained that his funds were in safe hands, all invested funds were insured, the
risks were minimal, and repeatedly offered him various additional products for investment. In January 2020, Vladimir
Maslennikov became his financial advisor and informed him that he needed to re - sign a number of documents. Afer
familiarising himself with them, at QBF's office at 8 Presnenskaya Naberezhnaya St., p. 1, Moscow, he signed all the
documents. 1, he signed all the documents, new contracts and notices. The contracts were re - signed on 28.01.2020
with the company with the company "White Lake Management" Trust Management Agreement No. D - 388562 - A and
the company LLC "VL Consulting" application for accession No. 388562 - 01, as well as the definition of cancellation of
the Agreement on trust management services of 26.12.12.2014 between QBF LLC, the definition on cancellation of the
Agreement on provision of services of direct access to international stock markets No. 1969 - 14/IMR dated 26.12.2014,
the agreement on provision of services No. 1969 dated 04.06.2018 was signed with Simtelligence Limited Liability
Company. From 2016 and 2017 he withdrew funds, namely on 25.12.2016 in the amount of USD 8,000, which at the
exchange rate of the Central Bank of the Russian Federation as of 25.12.2016 was 486,822.4 rubles, and on 25.12.2017
in the amount of USD 3,500, which at the exchange rate of the Central Bank of the Russian Federation as of 25.12.2017
was 204,103.2 rubles. From the words of Vladimir Maslennikov, he realised that the funds withdrawn by him were
profits from his investments. In December 2019, he realised from the report on the state of his investment account
that it had decreased. Afer consulting with Vladimir Maslennikov, the latter convinced him (A.A. Ptitsyn) that this
situation on the stock market is temporary, in the near future investments will start to grow. Afer that he monitored
his investment account by monthly reports sent to his mail. He did not plan to withdraw any funds. Afer the account
status report was not received in March 2021, he tried to contact Vladimir Maslennikov, but he did not answer calls
and messages in messengers. He tried to contact via contact phones in the office, but to no avail. In April 2021, he
heard from the media (the official website of the Ministry of Internal Affairs of the Russian Federation) about a
criminal case opened against the founders of QBF. To date, a significant part of the money he invested has not been
returned to him. He believes that an offence has been committed against him, namely thef of money by deceit and
abuse of trust. In total, he was robbed of money in the amount of 6,156,540 rubles, and the amount of damage
caused, taking into account the allegedly paid interest", is 5,465,614.4 rubles, which is significant for him;
(Vol. No. 8, pp. 66 - 70, 166 - 169)
- other documents - documents provided by A.A. Ptitsyn confirming his relationship with QBF Financial Group (QBF
Investment Company LLC) and testifying to the embezzlement of funds;
(Vol. No. 8, pp. 71 - 158)
part 4 of article 159 of the Criminal Code of the Russian Federation against V.V. Vedernikova:
- another document - a statement by V.V. Vedernikova, in which she asks to bring to criminal responsibility persons
from among the employees, managers of the financial group "QBF" (LLC "Investment Company "QBF"), who stole her
(Vol. No. 9, l.d. 4)
840
- Vedernikova V. V.'s testimony , given to her as a witness, a victim,
according to which in 2010 she met Andrey Polezhaev, the circumstances of her acquaintance she cannot remember
now, he is her common - law spouse, they are not officially married, they have two minor children. They live together
at the address: Moscow, Berezovaya Roshcha Proezd, 8, sq. 61. In March 2012, she met A.V. Polezhaev at the Novinsky
Passage restaurant, where they spent an evening together. Later, a man previously unknown to her arrived, A.V.
Polezhaev introduced him as a financial advisor of the company Qubey Finance LLC - Vladimir Sergeevich Pakhomov.
They got acquainted, sat and talked about their personal lives, Pakhomov V.S. told about his activities in LLC "Kyubey
Finance", where he was deputy general director. According to him, the company was engaged in attracting
investments from both individuals and legal entities. He spoke extensively about the successful transactions he had
concluded on behalf of the company. He offered her and A.V. Polezhaev to invest cash in Qubey Finance Ltd.
Pakhomov V.S. promised to pay monthly interest on the amount of the invested cash. At that time he did not tell her
what exactly the interest was. She and A.V. Polezhaev were interested in this investment idea and they decided to
contribute cash to Qubey Finance LLC. Around 25 March 2012, A.V. Polezhaev called Pakhomov V.S. and informed him
that she was ready to invest in the company, to which Pakhomov V.S. told A.V. Polezhaev that he was waiting for her in
the office. A.V. Polezhaev negotiated with V.S. Pakhomov the amount they should invest, as far as she remembered, it
was USD 17,000. On 27 March 2012, she arrived at the office of Qubey Finance LLC, located in BC "Moscow City" at 12
Presnenskaya Naberezhnaya Street, Moscow, on which floor the office was located, she does not remember. The office
seemed large to her, with many employees. The company secretary met her and invited her to the meeting room,
where Pakhomov V.S. came later. He had some documents in his hands, then he started to advertise the company and
said that they had made the right choice to invest money in this way. Then he asked her for her passport, she in turn
gave him her passport, he (V.S. Pakhomov.) went away for some time, about 20 minutes later he came to the meeting
room with the Agreement on provision of "Trust Management" services within the framework of the agreement on
direct access to the US securities market "539 - 12/VR dated 27 March 2012 and the agreement on direct access to the
US securities market "539 - 12/VR dated 27 March 2012, where "QB Capital CY LTD)" represented by R.V. Shpakov,
acting on the basis of the general power of attorney of QB Capital CY LTD and her. She was not interested in who
Shpakov R.V. was. This agreement implied the definition of conditions under which the company would interact with
the client on the US securities market. She familiarised herself with these documents and signed them on
Pakhomov's instructions. Further, she gave Pakhomov V.S. the money in the amount of USD 17,000, and he in turn
gave her a receipt stating that "QB Capital CY LTD" acknowledges receipt of the above amount of money to be
credited to her account opened with the Cyprus Company under the agreement No. 539 - 12/VR dated 27 March 2012.
Why the receipt states 28 March 2012 she cannot explain, she handed over the money on the day of signing the
contracts. V.S. Pakhomov convinced her that everything would be in the best way, saying that the larger the amount
on the account, the higher the interest would be. On 29 March 2012 V.S. Pakhomov called A.V. Polezhaev and offered
to deposit more money to her brokerage account. They collegially agreed, A.V. Polezhaev gave her USD 15,000 and she
went to the company's office, where she was met by V.S. Pakhomov and she gave him the above amount of money,
and he in turn gave her a receipt of receipt of the above amount of money to "QB Capital CY LTD" to be credited to her
account. Pakhomov V.S. persistently tried to gain their trust, constantly asked about their family income, about the
availability of real estate, constantly travelled to the working objects of A.V. Polezhaev, allegedly under the pretext of
buying some real estate. V.S. Pakhomov did not provide them with the number of their brokerage account, login and
password for their personal account. Every month they (V.V. Vedernikova, A.V. Polezhaev) received e - mail reports on
the state of her account and, accordingly, the funds on it. There were some credits, as far as she remembers about 500
US dollars per month. She did not withdraw any money from the account, she does not remember the total amount of
money on the account, as it was constantly changing and she did not keep track of it. In April 2012, she learned from
A.V. Polezhaev that he also decided to invest money in LLC "Kyubi Finance" in the amount of USD 600,000, as far as
she remembers he met with V.S. Pakhomov and gave him cash, but A.V. Polezhaev explained to her that he did not
sign any agreements, he did not give him any receipts from V.S. Pakhomov, but simply accepted the money and said
that he would deposit it into some investment account. On 05 June 2012 she became aware that A.V. Polezhaev
concluded a similar agreement and trust management agreement with "QB Capital CY LTD" represented by R.V.
Shpakov and deposited funds from his current account opened in a German bank, as far as she remembers the
841
amount was 1,000,050 Euros. He also received some reports on the status of funds by e - mail. A.V. Polezhaev
explained to her that he signed the documentation while in the office of Qubey Finance LLC, the contract and
agreement were provided to him by Pakhomov V.S. In the winter of 2012, A.V. Polezhaev gave her 100,000 US dollars,
which she decided to invest as well, and they went together with him (A.V. Polezhaev) to the office of Qubey Finance
LLC, where they were met by Pakhomov V.S. and received 100,000 US dollars from us. Further, she received an e - mail
message that USD 100,000 had been deposited into her account. On a monthly basis she received reports on the
interest credited for the use of the funds. In 2014 she decided to withdraw the funds from her account, she called
Pakhomov V.S. and said that she wanted her money back, for what reason she decided to return the money, she does
not remember. Pakhomov V.S. said that it was currently impossible, that the money was at auction. In 2014, her
mother Vedernikova S.F. gave her 1,000,000 roubles as a gif, and she decided to deposit the money into an account.
Following the same algorithm, she brought the money to the office and handed it over to Pakhomov V.S., afer which
she received a notification that the money had been credited to the account. In 2014, she had a desire to buy a flat in
Yekaterinburg, as she wanted to move to this city due to financial difficulties. For a long time they tried to withdraw
funds from her account in order to purchase the property. They had a conflict with V.S. Pakhomov about the return of
the money. They (Vedernikova V.V., Polezhaev A.V.) decided to go to the office and meet with Pakhomov V.S. and
resolve the issue. When they arrived at the office, Pakhomov V.S. came out, got into the car and handed over to
Polezhaev A.V. approximately 900,000 roubles. She resented this and demanded a larger amount, to which Pakhomov
V.S. told us to be happy with this amount, Pakhomov V.S. threatened them that if they demanded money from him,
they would lose all their money. In August 2015, she moved to live in Yekaterinburg, where she could not find a job for
a long time, further they learnt that there was a branch of Qubey Finance LLC in Yekaterinburg, afer which A.V.
Polezhaev offered her a job at Qubey Finance LLC as a financial advisor, he had previously discussed this issue with
V.S. Pakhomov, who promised to employ her. No labour contract was concluded, she had an internship. The company
office was quite large. Wages were not paid. There were always about 7 - 8 people in the office. She was interviewed
by Kirill Sobolev, the director of the office of Qubey Finance LLC. Sobolev provided her with a certain algorithm for
talking ("match") with a potential client and convincing him to invest money in the company. Her job description
included handling cold calls. She purchased a list of rich people's mobile phones on the Internet, whom she would
then call and attract to the company. If someone responded to an offer, they would come to the office and Sobolev
would already negotiate with them. During the time she worked there, she was unable to attract any clients. Afer
working there for about a month, she began to realise that this activity of attracting clients. When communicating
with the employees of the company, she realised that they did not understand the whole essence of the company's
activities, namely that the money was mainly attracted from individuals, some interest was paid, but in the future the
fate of the money remained unclear. She informed V.S. Pakhomov that she did not want to work here anymore, to
which he reacted aggressively. Munaev Zelimkhan Visaitovich and Roman Valeryevich Shpakov were acquainted to
her in absentia, she did not know them personally, she knew that they were managers of LLC "Kyubi Finance".
Pakhomov V.S. promised to return the money to her, as she needed to buy housing, but later he ignored her. She was
aware that Andrei also demanded that the money be returned to him, but he was also ignored. Around 2015, she
received an account statement on her email, where she found that there were no funds in the account. She reported
this to A.V. Polezhaev, to which he contacted V.S. Pakhomov, who in turn reported that her funds had been given to
A.V. Polezhaev in the amount of USD 170,000. She was surprised by this fact, as she had not given such consent and
had not signed any documents. Afer that she had a serious conflict with Pakhomov V.S., as she did not understand
where her money had gone, Pakhomov V.S. threatened her that she would never receive any money at all. She did not
fulfil any of the contracts and agreements she concluded with "QB Finance" and "QB Capital CY LTD", her obligations
were not fulfilled, her funds were not insured, she was not given the key to the accounts and the opportunity to
control transactions with her funds. No transactions were coordinated with her. Reports were sent to her on a
monthly basis, showing the amount of money that was charged as interest. She characterizes the actions of
Pakhomov V.S. as fraudulent, as he entered into their (Vedernikova V.V., Polezhaev A.V.) trust, then having taken
possession of the funds, began to conduct the dialogue differently. He refused to return the money on demand. Apart
from Pakhomov V.S., she did not negotiate with anyone from LLC "Kyubi Finance". Pakhomov V.S. worked in "Kyubi
Finance" LLC, therefore, I can state that the company also has signs of fraud. She admits such facts that some
individuals were officially registered by Qubey Finance LLC as investors, i.e. concluded contracts, agreements, entered
842
them into the client base, but there were also cases when they attracted investors, took money from them without
concluding a contract and without receiving the money in any way, as in the case of A.V. Polezhaev this was also the
case. She did not inquire whether she was a registered client of QB Capital CY LTD;
(Vol. No. 9, pp. 8 - 13, 59 - 63)
- other documents - documents provided by V.V. Vedernikova confirming her relationship with QBF Financial Group
(Vol. No. 9, pp. 16 - 53)
part 4 of article 159 of the Criminal Code of the Russian Federation against Tretiukhin A.N.:
- another document - a statement by Tretiukhin A.N., in which he asks to bring to criminal responsibility persons from
among the employees, managers of the financial group "QBF" (LLC "Investment Company QBF"), who stole his
(Vol. No. 9, l.d. 80)
- Testimony of Tretiukhin A.N., given by him as a witness and victim,

according to which he, 29.04.2015 arrived at the office of the group of companies "QBF" at the address: Moscow,
Presnenskaya Naberezhnaya St., 8, p. 1, where he took part in a conversation with an employee of "QBF". 1,
where he took part in a conversation with a QBF employee. This conversation was an advertising campaign of the
"QBF" group of companies. At this conversation Spinka Ruslan was present, who voiced a number of offers to invest
money by investing in securities. Ruslan Spinka was persuasive and persistent, so he agreed to participate in investing
in securities on the Russian and international financial markets. At this conversation he was given printouts of
advertising offers. Later on, Ruslan Spinka conducted all consultations on financial products with him. On 29.04.2015,
being in the office of Qubey Finance LLC, at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, he signed with
the company "Qubey Finance". 1, he signed an agreement with QB Capital CY LTD ("QB Capital CY LTD") on the
provision of services of direct access to international stock markets No. 2128 - 15/IMR dated 29.04.2015, he also signed
an agreement on the provision of "Trust management" services in accordance with the agreement on the provision of
services of direct access to international stock markets No. 2128 - 15/IMR dated 29.04.2015 with QB Finance. Within
the framework of the concluded contract and agreement, he, being in the office of Qubey Finance LLC, at the address:
Moscow, Presnenskaya Naberezhnaya 8, p. 1, realised the transfer of cash. 1, realised the transfer of cash as follows:
29.04.2015 in the amount of USD 14,000, which at the exchange rate of the Central Bank of Russia as of 29.04.2015 was
RUB 732,200; 23.06.2015 in the amount of RUB 673,000. Afer replenishing his investment account, monthly
statements came with the replenishment and increase of his investment portfolio. In October 2019, Ruslan Spinka, an
employee of QBF, informed him that it was necessary to re - sign a number of documents and sent him a list of
necessary documents for signing a new agreement. Afer familiarising himself with the documents, he came to QBF's
office at 8 Presnenskaya Naberezhnaya St., bld. 1 and signed all the documents, new contracts and notices. The
contracts were re - signed on 17.10.2019 with the company "White Lake Management" Trust Agreement No. D - 945933
- J, and the agreement with the company LLC "VL Consulting", application for accession No. 945933 - 01, as well as the
definition of cancellation of the agreement on the provision of services of "Trust Management" dated 29.04.04.2015
between LLC "QBF", definition on cancellation of agreement on provision of services of direct access to international
stock markets No. 2128 - 15/IMR dated 29.04.2015, signed agreement on provision of services No. 2128 dated
04.06.2018 with Limited Liability Company "Simtelligence". In June 2021, he heard from the media (official website of
the Ministry of Internal Affairs of the Russian Federation) about a criminal case initiated against the founders of the
company "QBEF" in relation to the embezzlement of funds of the company's clients, as well as the fact that the clients
843
could not withdraw the invested funds. The QBF employees could not clearly explain to him how he could withdraw
the money he had invested. On this basis, he concluded that the money he had deposited had been stolen by QBF
employees. Thus, in the period from 29.04. to 23.06.2015, he transferred funds in the amount of RUB 1,405,200 as an
investment to the QBF group of companies. No refunds of the funds were made to him. He believes that an offence
has been committed against him, namely thef of money by deceit and abuse of trust. He estimates the amount of
damage caused as significant, namely, 1,405,200 roubles;
(Vol. No. 9, pp. 83 - 87, 96 - 99)
- other documents - documents provided by A.N. Tretiukhin confirming his relationships with QBF Financial Group
(Vol. No. 9, pp. 100 - 203)
part 4 of article 159 of the Criminal Code of the Russian Federation against Sazonov E.O.:
- another document - a statement of E.O. Sazonov, in which he asks to bring to criminal responsibility persons from
(Vol. No. 10, l.d. 9)
- E.O. Sazonov's Testimony

as a witness and victim, according to which he received a telephone call in July 2015. The caller introduced himself as
a manager from the investment company "QBF" working on stock markets. The manager offered to visit their office
located at: Moscow, Presnenskaya Naberezhnaya 8, p. 1, 9th floor ("Moscow"). 1, 9th floor ("Moscow City") to discuss
the terms of a very favourable and reliable placement of funds. He had funds that he wanted to invest to receive
income. On 02.08.2015 he visited the company's office. In the reception room of QBF he was met by the manager of
the company Igor Gurevich (tel. 8 - 903 - 100 - 46 - 33) and escorted to one of the rooms of negotiations with clients.
During their conversation Igor Gurevich persuaded him to make a decision to place funds with them, promised high
profitability and high reliability of the placement. He was told that his funds would be in safe hands, the activity of
Qubey Finance Ltd. was licensed by the Central Bank of the Russian Federation. Having given in to persuasions and
promises of high and stable profitability, he visited the office of this company on 05.08.2015, in the first half of the day,
but not later than 13:00. There he was given the documents to sign. On 05.08.2015 he, being in the office of LLC
"Qubey Finance", located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, with the purpose of investing
funds. 1, for the purpose of investing funds in securities with high yield, he signed an agreement on the provision of
direct access to international stock markets No. 2267 - 15/IMR dated 05.08.2015 with QB Capital CY LTD ("QB Capital
CY LTD"), and also signed an agreement on the provision of "Trust Management" services in accordance with the
agreement on the provision of direct access to international stock markets No. 2267 - 15/IMR dated 05.08.2015 with
QB Finance LLC. Both agreements were signed by Zelimkhan Visaitovich Munayev, Director of Sales Department. Here
in the office Igor Gurevich introduced him to Munaev Zelimkhan Visaitovich. Munaev Z.V. assured him that their co -
operation would be "mutually beneficial". Then, being in the office of Qubey Finance LLC, located at 8 Presnenskaya
Naberezhnaya Naberezhnaya, bld. 1, Moscow, he made a transfer of cash to him. 1, made a cash transfer as follows:
on 06.08.2015 in the amount of USD 80,000, which at the exchange rate of the Central Bank of the Russian Federation
as of 06.08.2015 was RUB 5,017,600; on 06.08.2015 in the amount of EUR 11,220, which at the exchange rate of the
Central Bank of the Russian Federation as of 06.08.2015 was RUB 764,530.8; on 02.10.2015 in the amount of RUB
3,100,000, to carry out trust management of this money. In return, Igor Gurevich gave him receipts to the cash receipt
order (a total of 3 receipts were issued), but for some reason issued in the name of the Cypriot company "QB Capital
CY ltd". At that moment, unfortunately, he did not ask himself how a foreign company not registered on the territory of
the Russian Federation could issue cash receipts in accordance with the rules established exclusively for Russian legal
entities under Russian law. From the moment his financial assets were placed with QBF LLC, he received a financial
844
report on the trust management of his financial assets by email on a regular basis, once a month. In September 2020,
he decided to withdraw his invested funds from QBF Ltd. He repeatedly tried to call the company's office to organise
contact with his attached financial advisor Igor Gurevich, but the secretaries in the office each time informed him that
all managers were currently in negotiations and that he would definitely be contacted. A few weeks later he found Igor
Gurevich's phone number in his old records (tel. 8 - 903 - 100 - 46 - 33) and called him. It turned out, in his (Gurevich's)
words, that he had resigned from the company, and that his (Sazonov's) financial adviser was currently one Artur
Avanesyan. Afer some time he managed to call Artur Avanesyan and arrange a visit to the office of QBF LLC. On
23.11.2020, having visited the office of the company and having met with Arthur Avanesyan, he declared his desire to
initiate the withdrawal of his invested funds. Arthur informed him that they had reorganised their companies and
therefore it was necessary to observe certain formalities in the form of re - signing a number of papers and
agreements related to the trust management of the invested funds. In particular, on 23.11.2020 he re - signed the
"Trust Management" agreement with "White Lake Management Ltd" No. D - 635201 - K and the agreement on
provision of services of access to international stock markets. Artur Avanesyan tried to convince him of the
inexpediency of withdrawing the invested funds, as well as the fact that the reorganisation of the company should
result in a sharp increase in the efficiency of management and, as a consequence, the profitability of the portfolio.
Nevertheless, he insisted on his wish to withdraw the invested funds. Then Artur Avanesyan informed him that within
a few days he would send him an "asset realisation notice" to his e - mail, which he had to sign and send a scanned
copy of in return. Artur Avanesyan also informed him that the date of signing this document should be the starting
point for returning the funds to him. The company should return the funds within 30 working days. On 09.12.2020 he
signed the document and sent a scanned copy to the company. On 01.02.2021 the thirty - day period for the return of
funds expired, however, from the moment he placed his funds in the company QBF Ltd. until now he has never
withdrawn the invested funds and nothing has been returned to him. His repeated phone calls to his financial advisor
Arthur Avanesyan (tel. 8 - 964 - 530 - 33 - 27) did not answer and avoided talking and meeting with him. Only via
WhatsApp messenger he periodically received replies that there was no time to contact him, either a meeting or a
business trip. The office on each occasion promised to relay messages and information to him to contact him. In view
of the above, he believes that a group of persons consisting of the above - mentioned Igor Gurevich, Munaev
Zelimkhan, Artur Avanesyan and their unidentified accomplices from among the employees of the company "QBF"
unlawfully, through deceit, appropriated the money belonging to him by right of ownership. In total, they transferred
funds in the amount of 8,882,130.8 roubles as investments for income generation in the QBF group of companies. No
refunds were made to him. He estimates the material damage caused to him in the amount of 8,882,130.8 roubles as
significant;
(Vol. No. 10, pp. 12 - 15, 24 - 27)
- other documents - documents provided by E.O. Sazonov confirming his relationship with QBF Financial Group (QBF
(Vol. No. 10, pp. 28 - 195, Vol. No. 11, pp. 1 - 65)
part 4 of article 159 of the Criminal Code of the RF against Bubnov N.A.:
- another document - a statement by N.A. Bubnov, in which he asks to bring to criminal responsibility persons from
(Vol. No. 11, page 77)
845
- Testimony of N.A. Bubnov, given by him as a witness and victim,
according to which in the spring of 2015 he received an advertising call on his mobile phone number from the
representative of the group of companies "QBF" Rustam Akhmedov with a proposal for cooperation, in particular
investment in securities of stock markets of foreign countries. At first he did not give an unambiguous answer, but
started to make enquiries in the Internet about the group of companies "QBF". Having studied information from
various Internet resources, he decided to go to the company's office to confirm his interests. He contacted Rustam
Akhmedov and made an appointment at the office. In mid - June 2015, but no later than the 20th of June, he arrived
at the QBF office located at 8 Presnenskaya Naberezhnaya, 8, p.1, 9th floor, Moscow. During the meeting in the office
he was contacted by a manager named Rustam Akhmedov together with his supervisor named Padalko Nikolay.
During the meeting, the latter presented to him the investment products available in the organisation, the ways of
investment, the mechanism of profit formation, the procedure of reporting and informing the client, as well as the
structure of the organisation in general. He was informed that the money will be invested in investment platforms of
foreign countries, and for this reason the money is required in currency. Everything was presented in a colourful way,
devoid of flaws. He was promised a return of 10 to 30 per cent per annum. He was also provided with original licences
from the Central Bank of the Russian Federation. In addition, it was explained to him that among other financial
products, the group of companies "QBF" has ZPIF products related to the construction of residential real estate. As a
result of the meeting, he finally got the impression that these people could be trusted with his assets. They agreed
that within the next few days he would again come to the company's office to sign the relevant documents and also
carry the amount of money to be invested. On 24.06.2015, at approximately 13:00, he arrived at the address: Moscow,
Presnenskaya Naberezhnaya, 8, bldg. 1, 9th floor, where he was met by the same manager accompanied by his
supervisor Padalko Nikolay and escorted to the meeting room. They already had in their hands the documents signed
by the representatives of QBF. On 24.06.2015 he, being in the office of QBF company (QBF LLC), located at the address:
Moscow, Presnenskaya Naberezhnaya, 8, p. 1, with the purpose of investing money funds. 1, for the purpose of
investing monetary funds in securities with high yield, signed an agreement on provision of services of direct access
to international stock markets No. 2197 - 15/IMR dated 24.06.2015 with QB Capital CY LTD ("QB Capital CY LTD"), and
also signed an agreement on provision of "Trust Management" services in accordance with the agreement on
provision of services of direct access to international stock markets No. 2197 - 15/IMR dated 24.06.2015 with QB
Finance LLC. Both the agreement and the contract were signed on behalf of the representative Munaev Z.V. Padalko N.
also had Annex No. 2 to the agreement on provision of "Trust management" services to the agreement on provision of
direct access to international stock markets, within the framework of which in clause 4 he wrote about his intention to
allocate USD 6,000 from his invested funds for the purchase of units of ZPIF. Then, being in the office of Qubey Finance
LLC, located at the address: 8 Presnenskaya Naberezhnaya Naberezhnaya, bld. 1, Moscow, he made a cash transfer of
USD 6,000 of his invested funds to purchase units of the ZPIF. 1, realised the transfer of cash as follows: 24.06.2015 in
the amount of USD 18,500, which at the exchange rate of the Central Bank of the Russian Federation as of 24.06.2015
was RUB 1,002,885; 13.10.2015 in the amount of USD 9,500, which at the exchange rate of the Central Bank of the
Russian Federation as of 13.10.2015 was RUB 580,925. On 24.06.2015 he handed the money personally into the hands
of Padalko N., Padalko N. lef the meeting room with the money, then returned with a receipt in his hands, which he
handed to him. The receipt states that on 24.06.2015 the representative of "QB Capital CY LTD" Gorobets E.V. accepted
18 500 USD from him. Neither Gorobets E.V. nor Munaev Z.V. he has never personally seen or communicated with. Afer
he invested money in the group of companies "QBF", he started receiving reports to his e - mail address:
[email protected], which were received by him until 25.05.2021. These reports reflected the state of his investment
portfolio, both from the position of shares and ZPIF. From time to time he received calls from the manager Akhmedov
Rustam, who offered him to invest additional funds, as well as to consider purchasing additional financial products of
the group of companies "QBF". On 13.10.2015, at approximately 12:00, he arrived at the company's office at the
address: 8 Presnenskaya Naberezhnaya, 8, bldg. 1, 9th floor, Moscow, where he also handed over to Padalko N., who
met him, USD 9,500 within the framework of the previously concluded agreements, as indicated above. In exchange
for the transferred cash, Padalko N. handed him a receipt to the cash receipt order No. b/n dated 13.10.2015 in the
amount of USD 9,500. The signatory of the said receipt is Gorobets E.V. Subsequently, he never thought about
withdrawing the funds until 2021. During this whole period of time he communicated with financial advisors, afer
846
Padalko N., he was replaced by Zaitseva Yulia. The change of financial advisors occurred in early 2018. Around the
beginning of June 2018, he received a call on his mobile phone number from Zaitseva Y., who informed him that he
needed to come to the company's office in order to re - sign documents in the part concerning the investment
strategy. He was unable to come and asked to send a courier with the documents to his office for work. The courier
brought documents dated 04.06.2018, specifically service agreement No. 2197 dated 04.06.2018 with "Simtelligence
Company Limited". Under the said agreement, Yurmaster Ltd. acts as the agent. Also attached to the package of
documents are definitions on cancellation of the agreement on provision of services of direct access to international
stock markets No. 2197 - 15/IMR dated 24.06.2015 between him and QCCI (Formerly "QB Capital CY LTD"), as well as
the definition on cancellation of the agreement on provision of services of "Trust Management" dated 24.06.2015
between him and "QBifef" LLC. According to the words of Zaitseva Y., signing of these documents is a technical
necessity and is caused by some change of financial strategy of the group of companies "QBF", and it will not affect
the state of his invested funds in any way. He signed these documents. Later, about a year later, at the request of
Zaitseva Y., a courier again delivered documents to his office, in particular, the trust management agreement No. D -
392110 - J in his person and "White Lake management Ltd", as well as the service agreement with "VL Consulting" Ltd.
According to the words of Zaitseva Y. this set of documents similarly corresponds to the documents of the previous
year and it is connected exclusively with the investment strategy of the group of companies "QBF". In the future he
again changed his financial advisor from Zaitseva Y. to Danilenko Maxim. In February 2021, for personal reasons, he
had the need for a full withdrawal of funds. He contacted his financial advisor Danylenko Maxim and notified him that
he was going to withdraw the funds, to which he was informed that he needed to notify the company in writing. In
connection with the above, he visited the company and in person on 17.02.2021, approximately at 12:00 p.m., in the
office at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, 9th floor, he wrote a notice to the company. 1, 9th
floor, he wrote a notice of withdrawal. Afer submitting the notice of withdrawal, Danilenko M. informed him that the
withdrawal would take from several months to a year, and this was due to the closure of the international direction of
work in the group of companies "QBF". There is also a queue for payment of funds and he will have to wait. Also
Danilenko M. offered him to convert the debt to him in the face of the group of companies into the rouble equivalent
in the financial product ZPIF, which additionally alarmed him and he refused. Afer the above events he started to
make additional enquiries about the QBF group of companies and from information on the Internet he learnt that
they had problems with withdrawal of funds since 2018. His attempts to contact Danilenko M. already afer the
withdrawal application had been submitted were unsuccessful. In April 2021, Danilenko contacted him and provided
him with a long, absurd list of documents required to be submitted to withdraw his funds. Later, in late May or early
June 2021, he learned from the media, including official news from the Russian Ministry of Internal Affairs, that
criminal proceedings had been opened and an investigation was underway. Thus, he had no doubt that he was a
victim of fraudsters. So far his money has not been returned to him. In total, he transferred to the address of the group
of companies "QBF" in the period from 24.06. to 13.10.2015 monetary funds in the amount of 1 583 810 rubles. No
refunds were made to his address. He believes that an offence has been committed against him, namely the thef of
his money by deceit and abuse of trust. He estimates the amount of damage caused to him as significant, namely
1,583,810 roubles. Explains that no securities, in particular units of ZPIF and others, were purchased in his name. He
has not received any information or notifications from QBF employees about the existence of securities purchased in
his name;
(Vol. No. 11, pp. 83 - 87, 97 - 100)
- other documents - documents provided by N.A. Bubnov confirming his relationship with QBF Financial Group ( QBF
(Vol. No. 11, pp. 101 - 189)
part 4 of article 159 of the Criminal Code of the Russian Federation against Khlopiev V.N.:
847
- another document - a statement by Khlopiev V.N., in which he asks to bring to criminal responsibility persons from
(Vol. No. 12, l.d. 7)
- The testimony of Khlopiev V.N., given by him as a witness and victim,

according to which approximately at the end of April 2015 he was contacted by a representative of the group of
companies "QBF", Abdukadyrov Abbas, by mobile phone. During the telephone conversation Abdukadyrov Abbas told
him that the group of companies "QBF" is engaged in investing in shares of foreign companies and offered him to
invest in various exchange products. He (Abdukadyrov) was very persuasive and persistent, therefore he (Khlopiev)
was interested in his proposal, but decided to think about it. On 28.04.2015 he received another call on his mobile
phone from Abdukadyrov Abbas with a proposal to visit the office of the group of companies "QBF". On 28.04.2015, at
about 11:00 a.m. he arrived at the office of "QBF" companies, located at the address Moscow, Presnenskaya
Naberezhnaya St., 8, p. 1, where he personally met with his wife. 1, where he personally met his financial advisor
Abdukadyrov Abbas (tel. 8 - 985 - 700 - 07 - 42) who repeatedly offered him to invest in various stock exchange
products, he was very persuasive and persistent. Before he started investing through QBF Group of Companies, he
made enquiries about the company through the internet and through acquaintances. All reviews about the company
were positive, everyone said that they successfully invest and also successfully withdraw the invested money, there
were no doubts about the honesty of the company at the time of investment, therefore, he decided to agree to the
proposal of Abdukadyrov Abbas and 28.04.2015, approximately at 11:30 a.m., at this meeting he concluded the
between him and the company "QB CAPITAL CY LTD", as well as the agreement on provision of "Trust management"
services in accordance with the agreement on provision of services of direct access to international stock markets No.
2125 - 15/IMR dated 28.04.2015. At the conclusion of the agreement the representatives of the group of the company
"QB CAPITAL CY LTD" were the employees of "QBF", namely - Pavel Jimamuradov and Abdukadyrov Abbas (personal
manager), Zelimkhan Munayev - the signatory from the side of "QB CAPITAL CY LTD", I have not seen him personally,
he was not present at the meeting. Afer that on the next day 29.04.2015 at about 11:00 a.m. he again came to the
office of the group of companies "QBF" at the address Moscow, Presnenskaya Naberezhnaya St., 8, p. 1 and deposited
30 000 USD in cash. 1 and deposited USD 30,000 in cash, which at the exchange rate of the Central Bank of the Russian
Federation as of 29.04.2015 amounted to RUB 1,569,000, into his investment account in accordance with Agreement
No. 2125 - 15/IMR dated 28.04.2015. He deposited the funds through Pavel Djimamuradov, as he realised at the time
that he was Abdukadyrov Abbas's superior. Afer depositing the funds, he received a receipt confirming receipt of
funds in the amount of 30,000 USD to be credited to the account opened with the company "QB Capital CY LTD",
(Nicosia Cyprus) under the contract No. 2125 - 15/IMR dated 28.04.2015. The receipt had the signature of the chief
accountant Gorobets E.V. and the stamp of "QB Capital CY LTD", this receipt was dated 29.04.2015. On 11.08.2015, at
approximately 11:00 a.m. he arrived at the office of the "QBF" group of companies at 8 Presnenskaya Naberezhnaya
St., p. 1, Moscow and deposited USD 30,000 in cash. 1 and deposited USD 30,000 in cash, which at the exchange rate of
the Central Bank of the Russian Federation as of 11.08.2015 amounted to RUB 1,935,000, into his investment account
in accordance with Agreement No. 2125 - 15/IMR dated 28.04.2015. He deposited the funds through Pavel
Djimamuradov, afer depositing the funds he received a receipt to the cash receipt order on the deposit of funds. The
receipt was signed by the chief accountant Gorobets E.V. and stamped "QB Capital CY LTD", this receipt was dated
11.08.2015. On 24.09.2015 at approximately 11:00 a.m., he arrived at the office of the "QBF" group of companies at the
address: Moscow, 8 Presnenskaya Naberezhnaya St., p. 1 and deposited USD 40,000 in cash. 1 and made a cash
deposit of 40,000 US dollars, which at the exchange rate of the Central Bank of Russia as of 24.09.2015 was 2,641,600
rubles, to his investment account according to the agreement №2125 - 15/IMR dated 28.04.2015, he deposited the
funds through Pavel Jimamuradov, afer depositing the funds he (Jimamuradov) handed over a receipt to the cash
receipt order. The receipt was signed by the chief accountant Gorobets E.V. and stamped "QB Capital CY LTD", this
848
receipt was dated 24.09.2015. On 19.10.2015, at approximately 11:00 a.m., he arrived at the office of the "QBF" group
of companies at 8 Presnenskaya Naberezhnaya St., p. 1, Moscow and deposited USD 50,000 in cash. 1 and made a
cash deposit of USD 50,000, which at the exchange rate of the Central Bank of the Russian Federation as of 19.10.2015
amounted to 3,068,000 rubles, to his investment account according to the agreement №2125 - 15/IMR dated
28.04.2015, he deposited the funds through Pavel Djimamuradov, afer depositing the funds he handed him a receipt
to the cash receipt order. The receipt was signed by the chief accountant Gorobets E.V. and stamped "QB Capital CY
LTD", this receipt was dated 19.10.2015. Since May 2015, he started receiving monthly reports on the status of his
investment account to his email, from the email address: [email protected], [email protected], since September
2019 from reports@wl - mnt.com. Some time later, in December 2018, Bogdan Sirotiuk called him on his mobile
phone and informed him that Ruslan Sokolov would now be his financial advisor, explaining that Abdukadirov Abbas
was no longer in charge of financial matters and that Ruslan Sokolov would handle all matters. Subsequently, the
funds were in his (Khlopiev's) investment account, however, Ruslan Sokolov did not send monthly reports on the
status of the account, therefore, there was a need to withdraw or withdraw the funds. On 17.06.2019, at approximately
14:00 hours, he sent a notice to "KyBiEF Adviseri" LLC about the need to start the procedure of withdrawal of funds
from account No. 2125 - 15/IMR dated 28.04.2015. Afer that, Ruslan Sokolov delayed the withdrawal of funds until
December 2019 arguing that there were difficulties with the withdrawal through the Cayman Islands, later he said that
it was necessary to collect a package of documents. Afer he collected the necessary documents and on 07.07.2020,
approximately at 14:00, he (Sokolov) provided Ruslan Sokolov with the "Trust Management" agreement № D - 259031
- G dated 07.07.2020 "White Lake Managment Ltd", which was signed by Korshunov D.A. with the imprint of the seal
"WL", saying that he needed to sign it to be able to withdraw funds from the Cayman Islands. He signed the
agreement. During 2019 - 2021 he tried to withdraw funds from his account and initially all negotiations with him were
conducted by Sokolov Ruslan, afer which he (Sokolov) informed him (Khlopiev) that the withdrawal of funds was
handled by his Danelenko Maxim, who said that there were difficulties with the transfer, suggested him not to hurry
with the withdrawal of funds, but he refused and said that he intended to withdraw his funds. Danelenko then told
him that the funds could only be withdrawn through Meshkova Daria (tel. 8 - 903 - 153 - 17). He then met with
Meshkova Daria, the exact date and time is difficult to name, in the afernoon, talking to her about withdrawing the
funds. She offered him a withdrawal of USD 50,000 within 15 days and suggested that he sign "Appendix #1:
Investment Objectives and Fees and Related Terms and Conditions of WL". He signed this attachment. Thereafer, she
stopped contacting him. On 28.11.2018 he managed to withdraw USD 15,000, which at the exchange rate of the
Central Bank of the Russian Federation as of 28.11.2018 was 1,001,700 rubles. On 04.03.2019, he also withdrew USD
15,000, which at the exchange rate of the Central Bank of the Russian Federation as of 04.03.2019 was RUB 987,217.5.
Employees of the company "QBF", said that these were dividends. Approximately in May 2021, from the media (the
official website of the Ministry of Internal Affairs of the Russian Federation), he heard about a criminal case initiated
against the founders of the company "QBF". In total, they transferred 9,213,600 rubles to the "QBF" group of
companies between 29.04. and 19.10.2015. Till now the full amount of money invested by him in the group of
companies "QBF" has not been returned to him. Claims will be brought for the amount of damage caused to him. He
considers that a crime has been committed against him, namely thef of his money by deceit and abuse of trust. I
estimate the amount of damage caused to him as significant;
- (Vol. No. 12, pp. 10 - 14, 24 - 30)

- other documents - documents provided by V.N. Khlopiev confirming his relationships with QBF Financial
- (Vol. No. 12, pp. 31 - 134)
part 4 of article 159 of the Criminal Code of the Russian Federation against Khlobyshev A.A.:
- another document - a statement by A.A. Khlobyshev, in which he asks to bring to criminal responsibility
"QBF"), who stole his money under the guise of carrying out brokerage activities;
(Vol. No. 12, l.d. 147)
849
- Testimony of A.A. Khlobyshev, given by him as a witness and victim
, according to which approximately in October 2015 he started looking for additional income by investing the money
he had at that time. He found information on the Internet regarding the group of companies "QBF". LLC "IK
"QBF" had 4 licences of the Central Bank of Russia, namely: licence for brokerage activities No. 045 - 12805 - 100000
dated 24.12.2009, licence for dealer activities No. 045 - 17X16010000 dated 24.12.2009, licence for securities
management No. 045 - 12828 - 001000 dated 24.12.2009 and licence for depository activities No. 045 - 14078 - 000100
dated 08.08.2019. Having studied all the available information, on 29.10.2015 he called the group of companies "QBF"
and with the manager of the organisation Ruslan Spinka agreed to arrive at the office of the organisation the next day
to sign all the necessary documents. On 30.10.2015 he arrived at the office of QBF ("QBF") at the address: Moscow,
Presnenskaya Naberezhnaya 8, p. 1, where he was met by the manager of the organisation. 1, where he was met by
the manager of the organisation, who introduced himself by the name of Ruslan Spinka, with whom he further
interacted and contacted (tel.8 - 967 - 186 - 60 - 39). He (Spinka) told him about the products in which he (Khlobyshev)
was going to invest, was quite convincing, confidently told about the activities of the organisation. On 30.10.2015 he,
being in the office of LLC "Qubey Finance", located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, with
the purpose of investing funds. 1, for the purpose of investing cash in securities with high yield, he signed an
agreement with QB Capital CY LTD ("QB Capital CY LTD") for the provision of services of direct access to international
stock markets No. 2379 - 15/IMR, dated 29.10.2015 for some reason. He also signed an agreement on provision of
"Trustee" services under the agreement on provision of direct access services to international stock markets No. 2379
- 15/IMR dated 29.10.2015 with Qubey Finance Ltd. represented by Zelimkhan Visaitovich Munaev, Director of Sales
Department. Within the framework of the contract and agreement he made a cash deposit: being in the office of
Qubey Finance LLC located at the following address: Moscow, Presnenskaya Naberezhnaya 8, p. 1, he handed over
cash to the Director of Sales Department Munaev Zelimkhan Visaitovich. 1, he transferred cash to QBF employees as
follows: 30.10.2015 in the amount of RUB 1,160,000, 30.10.2015 in the amount of USD 5,265, which at the exchange
rate of the Central Bank of the Russian Federation as of 30.10.2015 was RUB 337,855.05, 30.10.2015 in the amount of
EUR 3,045, which at the exchange rate of the Central Bank of the Russian Federation as of 30.10.2015 was RUB
213,576.3, 19.01.2016 in the amount of RUB 300,000, 28.01.2016 in the amount of RUB 200,000. In total, he transferred
funds in the amount of RUB 2,211,431.35 to the QBF Group of Companies. When he had a need to withdraw funds, he
sent a corresponding withdrawal order in the amount of RUB 150,000 on 14.06.2016. Thereafer, on 21.07.2016, he was
paid the said amount of RUB 150,000 in cash at the office of QBF. On 25.07.2017, he sent a similar order for withdrawal
of funds in the amount of RUB 120,000, afer which he received the said amount of RUB 120,000 on 30.08.2017 at the
office of QBF. On 01.07.2019, on the initiative of the investment company QBF, a new service agreement No. 794941 -
01 was concluded with him, where the company named "VL Consulting LLC" was already listed as the second party, as
well as a "Trust Management" agreement No. B - 794941 - C, where the company named "White Lake Management
LTD" was listed as the second party, which was explained by the transfer of the international jurisdiction of the
company to the Cayman Islands. In November 2020, he expressed his wish to withdraw all his funds from the
investment company. On 07.12.2020 he sent a notice to the investment company to realise the assets. On 24.12.2020,
they were again sent a notice on the realisation of assets, but with copies of the requested documents (passport of the
Russian Federation, foreign passport, certificate of no criminal record, income certificates, etc.). However, these
notifications were not executed, and no more money was returned to him. To date, he has not received the funds from
the investment company in full. In May 2021, he learnt from the mass media and official publications of the Russian
Ministry of Internal Affairs that key employees of the OVF group of companies had been detained for alleged fraud,
and that the Central Bank of the Russian Federation had initiated an audit of QBIF LLC. They transferred a total of RUB
2,211,431.35 in cash to QBF Group. Employees of QBF returned the funds in the amount of RUB 270,000 to him. The
remaining withdrawal orders were not executed and the funds were not returned in full. Thus, he realised that he had
been cheated out of his money. He believes that an offence has been committed against him, namely the thef of his
850
money by deceit and breach of trust in the amount of 2,211,431.35 roubles. He considers the amount of damage
caused to him as significant;
(Vol. No. 12, pp. 150 - 153, 176 - 179)
- other documents - documents provided by A.A. Khlobyshev confirming his relationship with QBF Financial Group
(vol. No. 12, pp. 156 - 169, 180 - 248, vol. No. 13, pp. 1 - 32)
part 4 of article 159 of the Criminal Code of the Russian Federation against Eremin V.A.:
- another document - a statement of V.A. Eremin, in which he asks to bring to criminal responsibility persons from
among the employees, managers of the financial group "QBF" (LLC "Investment Company "QBF"), who stole his
(Vol. No. 13, l.d. 45)
- Testimony of V.A. Eremin, given by him as a witness and victim,

according to which approximately in the period from 2012 to 2013, being a client of "Stolichnye Finansovykh Gruppe",
he got acquainted with a manager named Andrey Korzh. He (Korzh) was his manager and financial advisor who
managed his investment account. In 2016, Andrey Korzh resigned from Stolichnye Finansovye Gruppe and was
employed by QBF Group. Afer the above events, Korzh Andrey got in touch with him and offered him to transfer his
assets already to "QBF" group of companies. Taking into account the trustful relations with Korzh Andrey he agreed.
Also for him a positive argument was the fact that the money will be invested in investment platforms of foreign
companies. Everything was presented in a colourful way, devoid of flaws. As a result, they agreed to meet at the main
office of "QBF". On 17.02.2016, at approximately 14:00, he arrived at the office located at: Moscow, Presnenskaya
Naberezhnaya, 8, p.1, 9th floor. Upon arrival, he was met by Korzh Andrey and escorted to a meeting room. Korzh
Andrey had already signed copies of the documents in his hands, namely: agreement on the provision of services of
direct access to international stock markets No. 2508 - 16/IMR dated 17.02.2016 between him (Eremin) and the
company "QB Capital CY LTD" represented by Munaev Zelimkhan Visaitovich and the agreement on provision of "Trust
Management" services, in accordance with the agreement on provision of services of direct access to international
stock markets No. 2508 - 16/IMR dated 17.02.2016 (Account 002508) between him and the company "QB Finance" LLC
represented by Munaev Zelimkhan Visaitovich. He reported that he had never seen Munaev Z.V. and had never
communicated with him. Later, by the beginning of March 2016, Korzh Andrei prepared all the necessary documents
for non - cash transfer of the funds belonging to him, which were on the foreign currency account opened in PJSC
"Rosbank". Thus, on 09.03.2016 in the morning, approximately at 15:00, he met with Korzh Andrey, and they
proceeded to the additional office № 9735 of the Moscow branch of JSCB "Rosbank" located at the following address:
Moscow, Bolshaya Polyanka Street, 28, b. 1. While at the bank branch, Korzh Andrey personally handed over the
documents prepared by him, as well as details for making the payment to the operating cash desk and thus made a
cashless transfer from his (Eremin's) foreign currency current account No. 40817840097350000292, opened at the
additional office No. 9735 of the Moscow branch of JSCB "Rosbank" located at: 28, Bolshaya Polyanka St., bldg. 1,
Moscow, to the account "QB Capital CYY". to "QB Capital CY LTD" account No. CY050140010101010101020011705019
opened with The Cyprus Development Bank Public Company Ltd - Nicosia, Cyprus. On that day he transferred a total
of USD 182,274, which at the exchange rate of the Central Bank of the Russian Federation as of 09.03.2016 amounted
to RUB 13,340,634.06. Afer he invested funds in the group of companies "QBF", he started receiving reports to his e -
mail address [email protected]. These reports reflected the state of his investment portfolio. Afer some time, he
was contacted by Korzh Andrey and informed him that the group of companies "QBF" was in a state of restructuring,
851
in connection with which it was necessary to sign a new agreement with their current partners. Taking into account
the trusting attitude, he agreed with Korzh Andrey and came on 04.06.2018, at about 14:00 hours to the office of the
company "QBF", located at the address: Moscow, Presnenskaya naberezhnaya, 8, p.1, 9th floor, where he was also met
by Korzh Andrey. He had in his hands an agreement for the provision of services No. 2508 dated 04.06.2018 between
him and the company "Simtelligence" represented by Korshunov D.A., whom he had never seen. He signed this
agreement. In the summer of 2019, for personal reasons, he had a need to withdraw some funds from the QBF group
of companies, in connection with which he drew up an order and sent it to Korzh Andrey Vladimirovich to his email
address, and also sent a copy to "Simtelligence company Limited". The process of withdrawal of funds took more than
half a year. During all this time he repeatedly reminded and demanded from the group of companies "QBF" the
withdrawal of funds, in particular, on these issues he communicated with Korzh Andrey. Afer some time, he was
contacted by Korzh Andrey and informed him that the group of companies "QBF" was again in a state of restructuring,
in connection with which it was necessary to sign a new agreement with their current partners. Taking into account
the information received from Korzh Andrey regarding the invalidity of the previous agreements, he agreed with Korzh
Andrey and arrived on 03.10.2019, at approximately 14:00 at the office of the company "QBF", located at the address:
Moscow, Presnenskaya Naberezhnaya, 8, page 1, 9th floor, where he was also met by Korzh Andrey. He had already
signed documents in his hands, namely: a service agreement (standard form of adhesion agreement) dated
03.10.2019 between him and the company VL - Consulting LLC (INN 7706463476) represented by. Maricheva O.V., as
well as the "Trust Management" agreement No. D - 693229 - J between him and the company "White Lake
Management Ltd" represented by Korshunov D.A. On the same day he signed these documents. Around mid -
December 2019 (he finds it difficult to give a more precise date), Korzh Andrey invited him to the office of QBF at 8
Presnenskaya Naberezhnaya, 8, p.1, 9th floor, Moscow, to disburse the funds. Korzh Andrey gave him USD 30,000 in
cash, which at the exchange rate of the Central Bank of the Russian Federation as of December 2019 was RUB
1,932,291. Immediately afer receiving the first amount, he submitted a new withdrawal order and sent it to Korzh
Andrey to his email address and sent a copy to Simtelligence company Limited. Afer almost a year of reminders and
promises from Korzh Andrey, he managed to withdraw another USD 30 000, in connection with which on 27.10.2020
he received the funds at the cash desk of the additional office "Zyablikovo" located at the address: 16 Voronezhskaya
St., Moscow. At the above address he received USD 30,000, which at the exchange rate of the Central Bank of the
Russian Federation as of 27.10.2020 was RUB 2,293,329. Immediately afer receiving the amount of money, as part of
the second withdrawal of his assets from the "QBF" group of companies, he submitted an order to withdraw all the
remaining money belonging to him. Afer a while, taking into account the fact that the money was never returned to
him, he filed a statement of claim in the civil court. In total, he transferred 13,340,634.06 rubles to the "QBF" group of
companies. Till now the full amount of money invested by him in the group of companies "QBF" has not been
returned to him. Claims will be brought for the amount of damage caused to him. Considers that a crime has been
committed against him, namely thef of his money by deceit and abuse of trust. He considers the amount of damage
(Vol. No. 13, pp. 48 - 52, 59 - 63)
- other documents - documents provided by V.A. Eremin confirming his relationship with QBF Financial Group (Q BF
(Vol. No. 13, pp. 64 - 148)
part 4 of article 159 of the Criminal Code of the Russian Federation against Lopatin M.I.:
- another document - a statement of M.I. Lopatin, in which he asks to bring to criminal responsibility persons
from among the employees, managers of the financial group "QBF" (LLC "Investment Company "QBF"), who stole his
(Vol. No. 13, l.d. 160)
852
- The testimony of Lopatin M.I., given by him as a witness and victim,
according to which in March 2016, he learned about the group of companies "QBF" from his work colleague named
Eugene, who said that through the group of companies "QBF", you can profitably invest money, and then
recommended to turn to the financial advisor of the group of companies "QBF" Julia Zaitseva (tel. 8 - 905 - 742 - 77 -
48). During a telephone conversation with the financial advisor Yulia Zaitseva, Yulia suggested investing in various
exchange - traded products. She was very persuasive and persistent, Yulia offered him to deposit funds, as an
investment she guaranteed a return on these investments. Yulia Zaitseva's proposal interested him, however, he had
to think about it. On 24.03.2016, approximately at 13:00, he arrived at the office of the group of companies "QBF"
located at the address: Moscow, Presnenskaya Naberezhnaya St., 8, p. 1, where he was met by Yulia Zaitseva. 1, where
he was met by Yulia Zaitseva. Yulia Zaitseva explained that QBF is an investment company that has a long and
successful experience in Russia and abroad, all the necessary licences are available, and she also informed him that
the reliability of working with QBF Group is guaranteed by the legislation of the Russian Federation. Moreover, in the
open sources of the Internet, he saw the information that QBF Advisery LLC has 4 licences of the Central Bank of
Russia, namely: the licence for brokerage activities No. 045 - 12805 - 100000 dated 24.12.12.2009, licence for dealer
activity No. 045 - 12816010000 dated 24.12.2009, licence for securities management No. 045 - 12828 - 001000 dated
24.12.2009 and licence for depository activity No. 045 - 14078 - 000100 dated 08.08.2019. During the conversation Yulia
Zaitseva offered to invest in various exchange products, she was very convincing and persistent. At the same meeting
on 24.03.2018, tentatively at 13.30 hours, in the office of the "QBF" group of companies, located at: Moscow,
Presnenskaya Naberezhnaya St., 8, p. 1, he agreed to participate in investing in securities on the international stock
market. At this conversation he was given printouts of advertising offers and signed an agreement with the company
"QB Finance investment" on provision of services of direct access to international stock markets No. 2553 - 16/IMR
dated 24.03.2016 in the person of Munaev Z.V., agreement on rendering services of direct access to international stock
markets No. 2553 - 16/IMR dated 24.03.2016 with the company "QB Capital CY LTD" represented by Munaev Z.V. At the
moment of signing the documents, signatures and stamps of the second party were already affixed, Munaev Z.V. was
not present at the meeting. Afer signing all the documents, he deposited cash in the amount of 500 000 (five hundred
thousand) rubles to his account under the agreement 2553 - 16/IMR dated 24.03.2016, transferring them to the cash
desk of the company "QB Capital CY LTD". Afer the cashier counted the funds through a counting machine, he and his
financial advisor Yulia Zaitseva returned back to the negotiation room of the "QBF" group of companies, located at 8
Presnenskaya Naberezhnaya St., bldg. 1, Moscow. 1, afer which, afer some time, a cashier entered the negotiation
room and provided him with a receipt for a cash receipt order b/n dated 24.03.2016 in the amount of 500,000 rubles,
according to the contract No. 2553 - 16/IMR dated 24.03.2016. On 20.04.2016, tentatively at 13:00, he arrived at the
office of the "QBF" group of companies, located at: Moscow, Presnenskaya Naberezhnaya St., 8, p. 1, where he met
with Yulia. 1, where he met with Yulia Zaitseva. During the meeting, in the office of the "QBF" group of companies, at
the above address, he deposited cash in the amount of 300,000 (three hundred thousand) rubles to his account under
the agreement 2553 - 16/IMR dated 24.03.2016, transferring them to the cash desk of the company "QB Capital CY
LTD". Afer the cashier counted the funds through a counting machine, he and his financial advisor Yulia Zaitseva
returned back to the negotiation room of the "QBF" group of companies, located at 8 Presnenskaya Naberezhnaya St.,
p. 1, Moscow. 1, afer which, afer some time, a cashier entered the negotiation room and provided him with a receipt
for a cash receipt order b/n dated 20.04.2016 in the amount of 300,000 rubles under the contract No. 2553 - 16/IMR
dated 24.03.2016. Around June 2018, Zaitseva Yulia explained during a telephone conversation that he would have a
new financial advisor, Maxim Yudin, and invited him to the office of the QBF Group of Companies located at 8
Presnenskaya Naberezhnaya St., p. 1, Moscow, in order to get acquainted with him. 1, in order to get to know him
personally. Upon arriving at the QBF Group office, Yulia introduced him to his new financial advisor, Maxim Yudin (tel.
8 - 903 - 100 - 24 - 68). Around December 2018, he received a call from Maxim Danilenko, his financial advisor, telling
him that he would now be his financial advisor, afer which he invited him to the office of the QBF Group of
Companies located at 8 Presnenskaya Naberezhnaya St., Moscow, p. 1. 1. When he arrived there, he met his new
financial advisor, Maxim Danelenko (tel. 8 - 903 - 289 - 76 - 41). Throughout his interactions with the financial advisors,
they explained to him that the money he had invested was in safe hands and repeatedly offered him various products
for investment. Reports were sent to him monthly to his email address: [email protected]. In June 2019, he had a need
853
to withdraw some of his invested funds in QBF Group of Companies, afer which he called his financial advisor Maxim
Danelenko and informed him that he wished to withdraw the funds, in connection with which Maxim Danelenko
offered to meet at the office of QBF Group of Companies located at 8 Presnenskaya Naberezhnaya St., page 1,
Moscow. 1. On 16.06.2019 at approximately 13:00, he arrived at the above address, in the office of the "QBF" group of
companies, he met with the financial advisor Maxim Danelenko, afer which in the meeting room, the financial advisor
Maxim Danelenko handed him cash in the amount of 300,000 rubles, he did not sign any documents on receipt of
funds. On 19.10.2020 he had a need to withdraw his invested funds in "QBF" group of companies. Afer that he called
his financial advisor Maxim Danelenko and informed him that he wished to withdraw the funds, in connection with
which Maxim Danelenko on the same day proposed to meet at the office of the "QBF" group of companies, located at:
Moscow, Presnenskaya Naberezhnaya St., 8, p. 1. 1. Having arrived at the above address, approximately at 13:00 at the
office of the "QBF" group of companies, he met with the financial advisor Maxim Danelenko, during the meeting he
informed Maxim of his intention to withdraw funds from the account of the "QBF" group of companies. Maxim
Danelenko said that the withdrawal would take place in approximately four months. However, four months later, at
the end of February, there were no actions and no cash receipts. Maxim Danelenko also said that at the moment all
the accounts of the "QBF" company were arrested, and therefore it would not be possible to withdraw the funds, and
then he stopped contacting him. Around January - February 2021, Maxim Danelenko contacted him and informed him
that criminal proceedings had been initiated against the "QBF" group of companies and recommended that he
contact law enforcement authorities. A little later he learnt from the mass media and official publications of the
Ministry of Internal Affairs of Russia that criminal proceedings had been initiated and key employees of the "QBF"
group of companies had been arrested for fraud. In total, 800,000 roubles were transferred by them to the QBF group
of companies. To date, the full amount of the money he invested has not been returned to him. He considers that an
offence has been committed against him, namely thef of money by deceit and breach of trust. He considers the
amount of damage caused as significant;
(Vol. No. 13, pp. 163 - 167, 172 - 175)
- other documents - documents provided by Lopatin M.I. confirming his relationship with QBF Financial Group (QBF
(Vol. No. 13, pp. 176 - 203)
part 4 of article 159 of the Criminal Code of the Russian Federation against Lomakina O.S.:
- another document - a statement by Lomakina O.S., in which she asks to bring to criminal responsibility persons
(Vol. No. 14, l.d. 6)
- The testimony of Lomakina O.S., given to her as a witness and victim,

according to which approximately at the end of 2015, she had free cash and was looking for additional income by
investing her money. Thus, at the end of 2015, she learnt about the group of companies "QBF". Having made enquiries
in the Internet, she saw information that LLC "IC QBF" (INN 7733673955) has licences of the Central Bank of Russia,
namely: licence for brokerage activities No. 045 - 12805 - 100000 dated 24.12.2009, licence for dealer activities No. 045
- 12816010000 dated 24.12.2009, licence for securities management No. 045 - 12828 - 001000 dated 24.12.2009. Having
studied all the information available on the Internet, around January 2016, she and her husband called the phone
number of the manager, which they learnt through mutual friends (tel. 8 - 967 - 186 - 60 - 39). The manager's name
was Ruslan Spinka. Having called this number, they spoke to the manager of the organisation, who voiced a number
of offers to invest money by investing in securities. During the conversation Ruslan Spinka was persuasive and
854
persistent, so she agreed to participate in investing in securities on international financial markets. On 11.05.2016, she
came to the office of QBF Group at 8 Presnenskaya Naberezhnaya St., bldg. 1, Moscow, where she met Ruslan Spinka
in person. 1, where she met Ruslan Spinka personally, who continued to convince her of the reliability of the
investment. On 11.05.2016 she, being in the office of LLC "IC QBF", located at the address: Moscow, Presnenskaya
Naberezhnaya, 8, bld. 1, for investing cash in securities with high yield, signed an agreement with QB Capital CY LTD
("QB Capital CY LTD") on providing services of direct access to international stock markets No. 2618 - 16/IMR dated
11.05.05.2016 and also signed a "Trustee Services Agreement" pursuant to the Direct Access to International Stock
Markets Services Agreement No. 2618 - 16/IMR dated 11.05.2016 on behalf of QCBIF Ltd. All the documents were
concluded between her and the signatory from the side of "QBF" Munaev Z.M.. Then she, being in the office of OOO IK
QBF, located at the address: Moscow, Presnenskaya Naberezhnaya 8, p. 1, realised the transfer of cash. 1, realised the
transfer of cash as follows: 11.05.2016 in the amount of USD 7,250, which at the exchange rate of the Central Bank of
the Russian Federation as of 11.05.2016 was RUB 480,892.5 and on the same day 11.05.2016 in the amount of RUB
185,000. She was given receipts to cash receipts for the indicated amounts. Since 11.05.2016, she received on a
monthly basis to her email [email protected], reports on the status of the client's accounts for securities
transactions. In 2019, she decided to withdraw the funds invested in QBF. Further, on 18.09.2019, at the request of
Ruslan Spinka, she came to the office of LLC "IC QBF", located at the address: Moscow, Presnenskaya naberezhnaya 8,
pp. 1, where she signed the "Trust Management" agreement No. D - 752682 - I dated 18.09.2019 between her and the
group of companies "White Lake Management", with Korshunov D.A. acting as a signatory. Ruslan Spinka explained
the necessity of signing the agreement by the relocation of the top broker organisation from the Cayman Islands to
Hong Kong and afer signing this agreement the money payments will start. So she also signed the "Trust Deed" No. D
- 763143 - I dated 18.09.2019 in English, and the service agreement. Despite repeated demands for disbursement of
funds, no disbursement was made. Around October 2020, she contacted Ruslan Spinka and told him that she wanted
to withdraw the funds from the company, to which he replied that it would take about a month. He sent a large list of
documents required for the refund. Around December 2020, she brought all the necessary documents to the
organisation's office. Her manager was no longer there, she was dealt with by a girl named Olga, who informed her
that it would take about 3 months to withdraw the funds. Afer that, she repeatedly called the organisation, but the
employees were evasive about the specific timeframe for withdrawal. In May 2021, she learnt from the media and
official publications of the Russian Ministry of Internal Affairs that key employees of the QBF group of companies had
been detained for fraud, and the Central Bank of the Russian Federation had launched an audit of IK QBF LLC. In total,
she transferred to the QBF Group of Companies on 11.05.2016 as an investment cash amounting to RUB 665,892.5. No
refunds were made to her. She was not able to withdraw her funds either in full or in part. No securities in her name
have been registered in depositaries, no documents confirming the purchase of securities have been issued. Her
demand to return the money belonging to her has not been fulfilled. The amount of damage caused to her is
665,892.5 roubles, the damage is significant for her;
(Vol. No. 14, pp. 9 - 12, 105 - 108)
- other documents - documents provided by Lomakina O.S. confirming his relationship with QBF Financial Group
(Vol. No. 14, pp. 13 - 98, 109 - 194)
part 4 of article 159 of the Criminal Code of the Russian Federation against Kozlovskaya A.E.:
- another document - a statement by Kozlovskaya A.E., in which she asks to bring to criminal responsibility persons
(Vol. No. 15, l.d. 6)
855
- A.E. Kozlovskaya's testimony, given to her as a witness and victim,
according to which in early July 2014, on the recommendation of her acquaintance, she went to the office of the group
of companies "QBF", located at 8 Presnenskaya Naberezhnaya St., page 1, Moscow, where she met her financial
advisor Dmitry Lepeshkin (tel. 8 - 90 - 100 - 59 - 18), who offered to invest in various exchange products. 1, where I
met my financial advisor Dmitry Lepeshkin (tel. 8 - 903 - 100 - 59 - 18), who suggested investing in various exchange -
traded products. Dmitry was very persuasive and persistent, offered her to deposit money as an investment and
guaranteed income from these investments. On 03.07.2014, at about 16:00 she arrived at the office of the group of
companies "QBF", at the address Moscow, Presnenskaya Naberezhnaya St., 8, p. 1, where Lepeshkin Dmitry arrived. 1,
where Lepeshkin Dmitry voiced a number of proposals to invest money by investing in securities. At this meeting
Dmitry was persuasive and persistent, so she agreed to participate in investing in securities on international financial
markets. Subsequently, all consultations on financial products were conducted with her by Dmitry Lepeshkin. On
03.07.2014 she, being in the office of LLC "Qubey Finance", located at the address: Moscow, Presnenskaya
Naberezhnaya, 8, p. 1, with the purpose of investing funds. 1, with the purpose of investing funds in securities with
high yield, she signed an agreement on direct access to the US securities market No. 1675 - 14/IMR dated 03.07.2014
with QB Capital CY LTD, and also signed an agreement on provision of "Trust Management" services in accordance
with the agreement on direct access to the US securities market No. 1675 - 14/IMR dated 03.07.2014 with QB Finance
LLC. Afer that, she, being in the office of LLC "Qubey Finance" (LLC "IK QBF"), located at the address: Moscow,
Presnenskaya Naberezhnaya 8, bld. 1, transferred cash as follows: on 03.07.2014 in the amount of USD 16,400, which
at the exchange rate of the Central Bank of the Russian Federation as of 03.07.2014 amounted to 561,700 roubles, in
May 2016, a more precise date is difficult to name, in the amount of USD 3,500, which at the maximum exchange rate
of the Central Bank of the Russian Federation as of May 2016 amounted to 231,280 roubles. From July 2014 she
received monthly reports on the status of her investment account by email, until September 2019 from the email
address: [email protected], [email protected], since September 2019 from the address, reports@wl - mnt.com.
Thereafer, the funds were in her investment account, she also received monthly account statements. In 2018, she was
informed that her financial advisor instead of Dmitry Lepeshkin was appointed Maslennikov Vladimir, who was
changed to Artur, his last name is not known to her. With him she started a dialogue about withdrawing funds under
the contract of her mother Kozlovskaya N.S., and at the same time she started thinking about withdrawing funds from
her account. In early 2019, she began correspondence and negotiations about withdrawing funds from her account.
She negotiated with this same Arthur, an employee of QBF. He initially offered to withdraw the funds from her
mother's contracts and aferwards to withdraw the funds from her account. In order to withdraw the money, she was
given a package of documents in the office to sign a new agreement, without which it was impossible to withdraw the
money. Afer reading the documents, she decided not to re - sign anything. At the beginning of 2021, she started to
withdraw her own funds and her financial advisor was Olga Bataeva (tel. 8 - 964 - 530 - 33 - 56), who offered her new
investments in ZPIF instead of withdrawing her funds. However, she did not agree. On 22.03.2021, a special order was
signed between her and LLC "VL Consulting" on the sale of assets, and Olga Bataeva promised that the funds would
be withdrawn within two to four weeks. To date, she has not been able to withdraw the funds invested in QBF Group
even partially. In July 2021, she heard from the media (the official website of the Ministry of Internal Affairs of the
Russian Federation) about a criminal case initiated against the founders of QBF. To date, no funds have been returned
to her, Anna Eduardovna Kozlovskaya. She believes that an offence has been committed against her, namely thef of
funds by deceit and breach of trust. In the period from 03.07.2014 to May 2016 she transferred to the group of
companies "QBF" the money belonging to her in the amount of 792 980 rubles. The money was not returned to her
either in full or in part. The amount of damage caused to her in the amount of 792,980 roubles is assessed as
significant;
(Vol. No. 15, pp. 9 - 11, 21 - 24)
- other documents - documents provided by A.E. Kozlovskaya confirming her relationship with QBF Financial Group
(Vol. No. 15, pp. 25 - 52)
856
Evidence and their brief content, confirming the guilt of Pakhomov V.S. in committing an offence under
part 4 of article 159 of the Criminal Code of the Russian Federation against Levchenko V.V.:
- another document - a statement by Levchenko V.V., in which he asks to bring to criminal responsibility persons from
(Vol. No. 15, l.d. 65)
- The testimony of Levchenko V.V., given by him as a witness and victim,

according to which in June 2014 he received a phone call on his mobile phone from a person unknown to him earlier,
who introduced himself as Ruslan Spinka (tel. 8 - 967 - 186 - 60 - 39). During the telephone conversation Ruslan Spinka
informed him that he was the financial manager of the company "QB Finance" and that there was a favourable offer
for him to invest his money in international shares for further earning of money. He replied that he did not want to
invest his cash anywhere. In December 2014, he again received a phone call from Ruslan Spinka from a phone number
(tel. 8 - 967 - 186 - 60 - 39). During the conversation, Spinka again offered him to invest money in international stocks,
to which he agreed. They agreed that he would come to the company's office at the end of December. The office of the
company QB Finance (QB Finance LLC) was located at the following address: Moscow, Presnenskaya Naberezhnaya, 8,
p. 1. 1. On 25.12.2014, he arrived at the office of QB Finance LLC at the above address, where he was met by Ruslan
Spinka and his (Spinka's) boss Nikolay Padalko, afer which they went to the meeting room. There, the above -
mentioned employees of QB Finance LLC informed him that QB Finance is an investment company that has a long
and successful experience in Russia and abroad. The company has all necessary licences, including licences from the
Central Bank of Russia. They also informed him that the reliability of work with the group of companies "QB Finance"
is guaranteed by the legislation of the Russian Federation, due to the fact that he will cooperate directly with the
Russian organisation LLC "QB Finance". In open sources of the Internet he saw the information that QB Finance LLC
has 4 licences of the Central Bank of Russia, namely: the licence for brokerage activities No. 045 - 12805 - 100000 dated
24.12.2009, the licence for dealer activities No. 045 - 12816010000 dated 24.12.2009, the licence for securities
management No. 045 - 12828 - 001000 dated 24.12.2009 and the licence for depository activities No. 045 - 14078 -
000100 dated 08.08.2019. During the conversation Ruslan Spinka offered him to invest money in various exchange
products, was very persuasive and persistent in connection with which, among other things, he agreed to participate
in investing in securities on the Russian and international financial market. During this conversation he was given
printouts of advertising offers. On the same day, 25.12.2014, he, being in the office of Qubey Finance LLC, located at
the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, with the purpose of investing funds in the Russian and
international financial market. 1, with the purpose of investing funds in securities with high yield, he signed an
agreement on provision of direct access to international stock markets No. 1962 - 14/IMR dated 25.12.2014 with QB
Capital CY LTD ("QB Capital CY LTD") and an agreement on provision of "Trust management" services in accordance
with the agreement on provision of direct access to international stock markets No. 1962 - 14/IMR dated 25.12.2014
with QB Finance LLC. Further, within the framework of the concluded contract and agreement, he at the office of LLC
Qubey Finance (LLC IK QBF), located at the address: Moscow, Presnenskaya Naberezhnaya 8, p. 1, transferred cash to
the office of LLC Qubey Finance (LLC IK QBF), located at the address: Moscow, Presnenskaya Naberezhnaya 8, p. 1. 1,
transferred cash: on 25.12.2014 in the amount of RUB 670,000, on 14.04.2016 in the amount of USD 3,500, which at the
exchange rate of the Central Bank of the Russian Federation as of 14.04.2016 was RUB 230,195, on 22.08.2016 in the
amount of USD 2,500, which at the exchange rate of the Central Bank of the Russian Federation as of 22.08.2016 was
RUB 159,850. He transferred all the funds to Ruslan Spinka. Regarding the withdrawal of funds, he explains the
following: in December 2015, during another call from Ruslan Spinka, he informed him that he wanted to withdraw
the profit of the year from his account, to which he (Spinka) informed him that he could come to the office of the
company "QB Finance", where he would be paid. On 29.12.2015 he arrived at the office of the company "QB Finance"
located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, where he met Ruslanka. 1, where he met Ruslan
Spinka, afer which they went to the meeting room, where he was provided with documents on the withdrawal of
857
funds from his account in the amount of 1,400 (one thousand four hundred) US dollars, which he signed. Ruslan
Spinka then informed him that he needed to come back in a few days to receive the funds. In January 2015, it is
difficult to name the exact date, he came to the office of the company "QB Finance", located at the address: Moscow,
Presnenskaya Naberezhnaya St., 8, p. 1, where he met with Ruslan Spinka. 1, where he met Ruslan Spinka, who gave
him cash in the amount of USD 1,400 (one thousand four hundred). In 2018, he received an email report stating that
there was a cash loss in his account in the amount of USD 1,100 (one thousand one hundred). He then received a
phone call from Elena Iosifova (8 - 495 - 120 - 22 - 28), who informed him that she was his new financial advisor, afer
which they agreed that he would come to the QB Finance office to sign documents and change strategies. In
December 2018, he arrived at QB Finance's office located at 8 Presnenskaya Naberezhnaya St., bldg. 1, Moscow, where
he met with Yelena. 1, where he met with Elena Iosifova, afer which he signed a number of documents, including a
change of strategy. He also signed Appendix No. 3 to the agreement on the provision of "Trust Management" services
for his account. Later he saw that he had signed this document not with QB Finance, but with the company QBF LLC,
which also had a changed TIN. Throughout his communication with the financial advisors, they explained to him that
the money he had invested was in safe hands and repeatedly offered him various products for investment. Reports
were sent to him monthly to his email address: [email protected]. In 2021, he received a phone call from a
phone number (8 - 964 - 530 - 33 - 56) from an unknown person who introduced herself as Olga Bataeva, his new
financial advisor, afer which Olga Bataeva informed him that QB Capital was liquidated and he needed to sign new
documents, for which she was ready to come to him to familiarise himself with them. At the end of February 2021,
Olga Bataeva came to his place of residence, where she familiarised him with the documents to be re - signed. He read
the documents and refused to sign them due to a number of material changes in the terms and conditions. He then
asked for payment of all the funds remaining in his account. Olga Bataeva informed him that due to the sanctions,
there are currently problems with the withdrawal of funds from abroad, and therefore the funds would be received by
him in 5 (five) years. Olga Bataeva offered him to buy units of an investment fund (UIF), for which he needed to collect
a list of documents, to which he subsequently refused the offer and said that he would wait 5 years. Around June
2021, he learnt from the media and official publications of the Russian Ministry of Internal Affairs that criminal
proceedings had been initiated and key employees of the QBF group of companies had been arrested for fraud. The
funds have not been returned to him in full. At present, his demand for the return of his funds has not been fulfilled.
He realised that his money had been stolen, he had become a victim of fraud. He transferred funds in the amount of
1,060,045 roubles to the QBF group of companies. The money was partially returned to him in the amount of USD
1,400. The rest of the money has not been returned to him. He believes that an offence has been committed against
him, namely the thef of his money by deceit and breach of trust in the amount of RUB 1,060,045. He considers the
amount of damage caused to him as significant;
(Vol. No. 15, pp. 68 - 73, 120 - 124)
- other documents - documents provided by V.V. Levchenko confirming his relationship with QBF Financial Group
(QBF Investment Company LLC) and testifying to the
embezzlement of funds;
(Vol. No. 15, pp. 76 - 109)
part 4 of article 159 of the Criminal Code of the Russian Federation against Golovach A.V.:
- another document - a statement by A.V. Golovach, in which he asks to bring to criminal responsibility persons from
(Vol. No. 15, pp. 137, 141)
858
- A.V. Golovach's testimony, given by him as a witness and victim
, according to which in September 2016 he was invited to QBF for an interview for the vacancy of financial advisor
(invited by Irina, +79218581604, +79211800268). At the interview he was told about the organisation and its projects,
and a meeting was held with the financial advisor Gennady (+79218581635). The meeting took place in the office at
64B Maloochtensky Ave. in St. Petersburg. Soon Gennady lef the company and another financial advisor Golubev
Alexey (+79218581624) communicated with me and persuaded him to bring and invest in QBF his savings in the
amount of 5 200 USD, which he did. On 19.10.2016 in the office of LLC "IK QBF", located at the address: St. Petersburg,
Maloohtinsky pr., 64, lit.B (BC "Plaza SPb"), according to the exchange rate of the Central Bank of Russia as of
19.10.2016 was 327 028 rubles. Subsequently, Alexey Golubev (from his words) headed the new Kaliningrad office of
QBF, and he passed it to the third financial advisor Artyom Efremtsov (+79990422832. +79218581623), with whom they
continued to communicate until 2020. Approximately, in February 2020, being in the above - mentioned office of QBF
group of companies, he asked to partially withdraw his invested funds. So from the company's cash desk he was given
700 US dollars, which at the maximum exchange rate of the Central Bank of the Russian Federation as of February
2020 was 46,893.63 rubles. In 2020 he was transferred to a new advisor Dmitry Moskaluk (+79218581623,
+79650288888). At his first meeting with Dmitry, he voiced that he planned to withdraw all the money. Dmitry
dissuaded him for a long time, but finally he realised that he could not change his mind and asked him to draw up
documents for withdrawal. It took a lot of time and money to prepare the full set of documents, as it was necessary to
make notarised documents, translations and bank certificates (the full list of documents is in the mail). When he had
prepared the package of documents, Dmitry told him in the mail that the procedure of withdrawal of funds had
changed and now it was necessary to prepare another package of documents (he sent it to him in the mail). He read
the documents and realised that they were clearly fraudulent. In June 2021, at the request of "QBF" in the Internet he
started to search for information and found information that it is a financial pyramid scheme and that a criminal case
has been opened against the organisers and there are many deceived depositors. To date, he has not been returned
his money deposited to the group of companies "QBF" in the amount of 280,134.37 rubles. He believes that an offence
has been committed against him, namely thef of his money by deceit and abuse of trust. The sum of the damage
caused to him estimates for himself as significant, namely 280 134,37 rubles (two hundred eighty thousand one
hundred thirty - four rubles thirty - seven kopecks). Also considers that the persons acting on behalf of the group of
companies "QBF" initially did not intend to fulfil their obligations to him and acted solely for the purpose of stealing
his money, having deceived him. The persons acting on behalf of the "QBF" group of companies stole money
belonging to him in the total amount of 280,134.37 roubles. He considers the amount of damage caused to him as
significant. He has been explained the right to file a civil action in the criminal case. He wishes to exercise this right
and file a lawsuit. He has been explained the right to familiarise himself with the composition of the investigative
teams, with the decisions on the appointment of forensic examinations, with the conclusions of experts, with the
records of interrogations of experts, and also to familiarise himself with the materials of the criminal case in full or in
part. He does not wish to exercise this right. He did not apply to the court with applications for recovery of money
from the "QBF" group of companies;
(Vol. No. 15, pp. 142 - 144, 237 - 239)
- other documents - documents provided by A.V. Golovach confirming his relationships with QBF Financial Group
(Vol. No. 15, pp. 145 - 230)
part 4 of article 159 of the Criminal Code of the Russian Federation against Bruskov A.N.:
- another document - a statement by Bruskov A.N., in which he asks to bring to criminal responsibility persons from
(Vol. No. 16, l.d. 7)
859
- A.N. Bruskov's testimony , given by him as a witness and victim,
according to which in May 2016 he learnt about the company LLC Investment Company QBF (LLC IK QBF, previous
name QBF LLC, INN 7733673955), at the address Moscow, Presnenskaya Naberezhnaya St., 8, p. 1, from an advertising
phone call received on his mobile phone. 1, from an advertising telephone call received on his mobile number. He
cannot explain how the representatives of the company got his number, but he was invited to the office for co -
operation, with a view to investing his money in securities for profit and income. Not being a professional investor, he
expected to place the funds in financial market instruments that would allow him to generate income. At the
beginning of May 2016, he first came to the office of IK QBF LLC (formerly QBF LLC) at the following address: 8
Presnenskaya Naberezhnaya, bld. 1, Moscow, where he met with representatives of the company. 1, where he met
with the company's representatives Aslan Daev, who introduced himself as the head of the department, and
Vyacheslav Morozov, his personal consultant. In the office of the company he was offered to invest in the international
stock market. On 30.05.2016, being in the office of LLC "IC QBF", located at the address: Moscow, Presnenskaya
Naberezhnaya, 8, p. 1, under the pretext of investing money on the international stock market. 1, under the pretext of
investing funds in securities with high yield, he signed an agreement with the company "QB Capital CY LTD" ("QB
Capital CY LTD") on the provision of services of direct access to international stock markets No. 2669 - 16/IMR dated
30.05.05.2016, as well as he signed an agreement on provision of "Trust Management" services in accordance with the
with "QBIF IK LLC". Further, being in the office of LLC IC QBF, located at the following address: Moscow, Presnenskaya
Naberezhnaya 8, p. 1. 1, realised the transfer of cash as follows: 30.05.2016 in the amount of RUB 670,000; 26.07.2016
in the amount of RUB 800,000; 27.07.2016 in the amount of RUB 830,000; 10.11.2016 in the amount of RUB 570,000;
10.11.2016 in the amount of RUB 1,030,000. He did not meet Z.V. Munayev himself, he received the contracts with his
signature and seals of the organisations. He was sure that his funds were used for investing in stock markets, as he
periodically received reports from the company to his email, indicating the ways of investing, securities and profits.
Subsequently, also in the office of the company at the invitation of V. Morozov, he renegotiated contracts with new
companies: service agreement No. 2669 dated 04.06.2018 with the company "Simtelligence", (Hong Kong, People's
Republic of China, under registration number 1570903, registered office at 148 - 156 Jeffy Road, Kam Fook Mansion,
Flat D 19/F, Wan Chai, Hong Kong, People's Republic of China), represented by Dmitry Anatolievich Korshunov, acting
on the basis of a power of attorney dated 01.04.2018. Trust management agreement No. D - 004876 - K dated
19.11.2019 with White Lake Management Ltd. registered in the Cayman Islands as an exempt company under the
Cayman Islands Companies Law SAR. 22 (the Cayman Islands Companies Law CAP. 22) under registration number SE -
330557 and with its registered office at Suite 2206, Cassia Court, 72 Market Street, Camana Bay, P.O. Box 30869, Grand
Cayman. Box 30869, Grand Cayman, KY1 - 1204, Cayman Islands, represented by Dmitry Anatolievich Korshunov.
These agreements, as V. Morozov explained to him, enabled the new companies to manage his money. All these
contracts and agreements were offered to him in the office of IK QBF LLC by employees of this company or companies
belonging to the same group of affiliates, citizens of the Russian Federation, and were signed by him for the purpose
of investing money and receiving income. All further interaction with the managers of this company was carried out
exclusively by e - mail or by phone of Vyacheslav Morozov (tel. 8 - 964 - 530 - 31 - 00), [email protected],
[email protected]. On a monthly basis, he received reports without EDS or other signatures to his email
from the company addresses [email protected], [email protected], reports@wl - mnt.com. In December 2017, he
partially withdrew funds from his investment accounts in the amount of USD 1,100, which at the average monthly
exchange rate of the Central Bank of Russia was RUB 65,224.28. He received the funds in hand at the company's office
also from Morozov V.. In February 2021, Morozov V. informed him of the need to transfer funds from abroad to Russian
accounts and suggested that he prepare the following documents: Notarised copy of a foreign passport, Notarised
copy of an internal passport (with English translation), TIN, letter of recommendation from a bank, proof of source of
income (KYC requiremets). On 22.03.2021 Vyacheslav Morozov informed him that his portfolio was closed. He was
waiting for the funds to be transferred to him, but no funds were transferred to him. He repeatedly contacted V.
Morozov by phone in May 2021, the last communication took place in early June 2021. He (Morozov) has not
contacted him further, he has no opportunity to contact the company, and the refund claim has not been fulfilled to
date. He has reasons to believe that the actions of the persons who concluded contracts with him in the city of
860
Moscow. Moscow: Vyacheslav Morozov, Munaev Zelimkhan Visaitovich, Elena Vyacheslavovna Gorobets, Dmitry
Anatolievich Korshunov, as well as the employees of the company and other persons forming one group with them,
acting in concert and by prior collusion, constitute an offence under Article 159 of the Criminal Code of the Russian
Federation, because the activities of this company and the group of persons acting on its behalf in attracting
investments on behalf of the Cypriot company, as well as the trust management of these investments, are fictitious,
do not contain real transactions and are aimed solely at taking money from investors. As it became known to him, by
the time of conclusion of the agreement on rendering services of direct access to international stock markets with him
in Moscow, the company "QB Capital CY LTD" (registration number HE221325, registered on 31.01.2008 at the address:
12 Kennedy Bisiness Centre, P. C. 1087 Nicosia, P. C. 1087 Nicosia, Nicosia.C. 1087 Nicosia, Cyprus - Cyprus), later
renamed to "QCCI LTD", did not carry out any real activity, was already in a pre - bankrupt state and was later
liquidated due to its bankruptcy, date of liquidation 07.08.2018. At the same time, no information about the
termination of the activities of the affiliated Cypriot structure was not provided to him by the employees of the
company IK QBF LTD (or companies belonging to the same group of affiliated entities with it). Thus, in the office of "IC
QB&EF" LLC he was offered to conclude knowingly invalid and unenforceable transactions with the companies "QB
Capital CY LTD" (later renamed into "QCCI LTD"), the alleged "Trust Management" agreement also had no legal
significance. All these papers were offered to him for signing solely for the purpose of illegal seizure of his money. The
reports sent to him in 2016 - 2021 were fictitious, there are no documents confirming the transactions with shares and
other investment instruments mentioned in the reports. In the period from 30.05. to 10.11.2016 he transferred to the
group of companies "QBF" the funds belonging to him in the amount of 3 900 000 rubles. In December 2017, a part of
the money in the amount of 65,224.28 rubles was returned to him. He assesses the amount of damage caused as
significant;
(Vol. No. 16, pp. 10 - 14, 19 - 22)
- other documents - documents provided by Bruskov A.N. confirming his relationship with QBF Financial Group (QBF
(Vol. No. 16, pp. 23 - 48)
part 4 of article 159 of the Criminal Code of the Russian Federation against Yegudkin B.A.:
- another document - a statement by Yegudkin B.A., in which he asks to bring to criminal responsibility persons from
(Vol. No. 16, pp. 62, 63)
- B.A. Yegudkin's testimony , given by him as a witness and victim,

according to which in August 2016 he was contacted by an employee of the company "QBF" Kisin Gennady
Vladimirovich. He does not know how Kisin G.V. got his phone number. During the telephone conversation G.V. Kisin
told about the possibility of additional income by investing the available funds, both in foreign currency and in rubles,
in the company "QBF" for further financial operations on the international market. Then he was interested in the
proposal and they agreed to meet. Having studied information about QBF in open sources, he found it attractive
enough to try to work with it. The presence of 4 licences from the Central Bank of the Russian Federation was one of
the most important points that determined the reliability of the company. The meeting took place in the company's
office located at 64 Maloohtinsky Ave., Lit. B (BC "Plaza SPb"), St. Petersburg. At the meeting G.V. Kisin told about the
prospects of co - operation, told about the company itself and the options of investing money in order to get income.
He showed colourful presentations, told that the company has been on the market for many years, that during this
time it has shown itself well in the investment market, that with the help of the company "QBF" you can officially
invest money in securities (shares) traded on the New York Stock Exchange. He was shown the licences issued by the
Federal Service for Financial Markets (FSFM of Russia). He was promised high yield and profit of at least 20% per
861
annum in dollars, with "QBF" commission on Trust Management Agreements of 30% of the profit. Different strategies
were shown. On a choice were offered: aggressive, average weighted and conservative. Everything sounded very
convincing, so the proposal then he was very interested, he took a pause to study everything carefully, think about it
and make an informed decision. At home he once again found, and carefully checked the reviews about the company
in the network - Internet, as well as data on the website of the Central Bank of Russia, where the information was
confirmed - the licences are valid, and the reviews about the company were extremely positive. All this was a decisive
factor in terms of choosing the company and confirming its reliability. Further, all interactions with the company
"QBF" took place through the financial advisor Golubev Alexey, who at that time was in the position of the head of the
department. Afer initial consultations and assurances in words that there will be no problems with the withdrawal of
funds, he decided to try to deposit the first amount and on 29 September 2016, on behalf of a non - resident "QB
Capital CY LTD" ("QB Capital CY LTD") with me signed an Agreement on the provision of services of direct access to
international stock markets № 2799 - 16/ISR dated 01.09.09.2016, as well as on behalf of LLC "IC QBF" Agreement on
the provision of "Trust Management" services in accordance with the Agreement on the provision of services of direct
access to international stock markets No. 2799 - 16/1SR dated 01.09.2016, at the same time in the office of the
company he made a cash deposit in the amount of 1,980,000 rubles. Afer Golubev A. told him that normal
profitability (in the amount of about USD 4,000 - 5,000 thousand per month) of annuity payments can be achieved
when investing at least USD 200,000 thousand in the account. On 14.11.2016, being in the office of the company
"QBF", he additionally transferred to Golubev A. cash funds, namely 8 400 000 rubles, and additionally concluded an
agreement with a non - resident "QB Capital CY LTD" ("QB Capital CY LTD"). Agreement on provision of services of
direct access to international stock markets No. 2918 - 16/ISR dated 14.11.2016, as well as on behalf of "QB Capital CY
LTD" Agreement on provision of "Advisory Management" services in accordance with the Agreement on provision of
services of direct access to international stock markets No. 2918 - 16/ISR dated 14.11.2016. Within the framework of
which, on the same day, he additionally transferred to Golubev A. cash funds in the amount of 38,000 Euros, which at
the exchange rate of the Central Bank of the Russian Federation as of 14.11.2016 is 2,702,761.40 rubles. All payment
documents (receipts to PKOs) for all three amounts accepted from him in rubles and Euros on behalf of "QB Capital CY
LTD" were signed by the Chief Accountant Gorobets E.V. Confirmation of acceptance of these amounts to the account
of the company "QB Capital CY LTD" were signed by Vladimir Pakhomov. All agreements on behalf of "QB Capital CY
LTD" and on behalf of "IC QBIF Ltd" were signed with him by the authorised person Tselenkova Evgeniya Yurievna,
who personally witnessed each page of each agreement with him. They transferred funds to the company's accounts
in the form of cash, in the company's office. A. Golubev personally accepted the money, and in exchange he was given
receipts stamped "QB Capital CY LTD". He would like to note that since October 2016 he started to receive electronic
reports on allegedly made transactions with securities to his e - mail. In addition, under the guise of payment of
interest from investment activities, in the period from 05.07.2017 to 26.12.2019, he made withdrawals of funds.
05.07.2017 in the amount of USD 5,000, which at the exchange rate of the Central Bank of the Russian Federation as of
05.07.2017 amounted to RUB 296,147.5, 08.12.2017 in the amount of USD 5,000, which at the exchange rate of the
Central Bank of the Russian Federation as of 08.12.2017 amounted to RUB 296,474, 22.06.06.2018 in the amount of
USD 5,000, which at the exchange rate of the Central Bank of the Russian Federation as of 22.06.2018 amounted to
RUB 318,936.5, 26.12.2019 in the amount of USD 15,000, which at the exchange rate of the Central Bank of the Russian
Federation as of 26.12.2019 amounted to RUB 925,746. In June 2021, he learnt from the media, as well as official
publications of the Ministry of Internal Affairs of Russia, that criminal proceedings had been initiated and key
employees of QBF Group had been arrested for fraud. Given the fact that the deadline for returning his money had
expired, there was no doubt that he had become a victim of fraud. To date, he has not been refunded his money
deposited with the QBF Group of Companies in the amount of 11,245,457.40 kopecks. He believes that the persons
acting on behalf of the group of companies "QBF" initially did not intend to fulfil their obligations to him and acted
solely for the purpose of stealing his money by deceiving him. In the period from 29.09.2016 to 14.11.2016 the persons
acting on behalf of the group of companies "QBF" stole his money in the total amount of 11 245 457,40 kopecks. He
considers the amount of damage caused to him as significant. He has been explained the right to file a civil action in
the criminal case. He wishes to exercise this right and file a lawsuit. He has been explained the right to familiarise
himself with the composition of the investigative teams, with the decisions on the appointment of forensic
examinations, with the conclusions of experts, with the records of expert interrogations, and also to familiarise
862
himself with the materials of the criminal case in full or in part. He does not wish to exercise this right. He did not
apply to the court with applications for recovery of money from the "QBF" group of companies;
(Vol. No. 16, pp. 66 - 69, Vol. No. 17, pp. 94 - 97)
- other documents - documents provided by B.A. Yegudkin confirming his relationship with QBF Financial Group (QBF
(Vol. No. 16, pp. 72 - 238, Vol. No. 17, pp. 1 - 85)
part 4 of article 159 of the Criminal Code of the RF against Sasovskaya O.B.:
- another document - a statement by O.B. Sasovskaya, in which she asks to bring to criminal responsibility persons
(Vol. No. 17, l.d. 110)
- The testimony of O.B. Sasovskaya, given to her as a witness and victim,

according to which in June 2015 she received a call on her mobile number 8 - 926 - 180 - 04 - 43 from a man who
introduced himself as Igor Gurevich, a representative of Qubey Finance LLC. He explained that he had an attractive
offer on the securities market and that in order to clarify more details she should come to the office of Qubey Finance
LLC located at 8 Presnenskaya Naberezhnaya Naberezhnaya, 8, p. 1, Moscow. 1. On 22.09.2015 at 12:14 p.m. she
arrived at the office of Qubey Finance LLC, located at 8 Presnenskaya Naberezhnaya St., page 1, Moscow, where Igor
Gurevich arrived. 1, where Igor Gurevich voiced a number of proposals to invest money by investing in securities. At
this meeting Igor Gurevich was persuasive and persistent, he also told her about the payment of increased interest,
guaranteed the legality and security of her subsequent investments, and psychologically pressurised her. Thus, she
agreed to participate in investing in securities. On 22.09.2015 she, being in the office of LLC "Qubey Finance", located
at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, with the purpose of investing money in securities. 1,
with the purpose of investing funds in securities with high yield, she signed an agreement with QB Capital CY LTD ("QB
Capital CY LTD") on the provision of services of direct access to international stock markets No. 2311 - 15/IMR, which
was dated 08.09.2015 (the agreement was drawn up in advance, but she signed it only before depositing the funds),
and she also signed an agreement on the provision of "Trustee" services under the agreement on the provision of
direct access services to international stock markets No. 2311 - 15/IMR dated 08.09.2015 with Qubey Finance Ltd.
Within the framework of the contract and agreement concluded by her, she, being in the office of LLC Qubey Finance
(LLC IC QBF), located at the address: Moscow, Presnenskaya Naberezhnaya 8, p. 1, transferred to the employees of
Qubey Finance. 1, handed over cash to QBF employees: on 22.09.2015 in the amount of RUB 500,000 and on
18.11.2016 in the amount of RUB 500,000. Both times she handed over the cash to Igor Gurevich. She was provided
with receipts for cash receipts. At the beginning of July 2018, she called Igor Gurevich and informed him that she
needed to withdraw funds in the amount of RUB 300,000. To which he responded positively and explained that she
needed to come to the office of Qubey Finance LLC to receive the funds. On 20.08.2018 at 12 hours 31 minutes she
arrived at the office of LLC "Kyubey Finance" at the address of Moscow, Presnenskaya Naberezhnaya St., 8, p. 1. 1. At
this address she was also met by Igor Gurevich, further she and he went to the meeting room. Afer that, on 20.08.2018
at 12:57 p.m. Igor Gurevich handed her money in the amount of 300,000 (three hundred thousand rubles). On
10.06.2020 in the morning she called Igor Gurevich and informed him that she needed to withdraw the remaining
amount. He replied that the assets had been transferred to other companies and that in order to withdraw the funds
she needed to come to the office again and sign new contracts. On 31.07.2020 at 14:30 she arrived at the office of LLC
"Kyubey Finance" at 8 Presnenskaya Naberezhnaya St., bldg. 1, Moscow. 1. At this address she was also met by Igor
Gurevich, then she and he went to the meeting room, afer which she signed the following documents: trust
863
management agreement No. B - 832460 - G with White Lake Management Ltd. and service agreement No. 2311 dated
04.06.2018 with Simtelligence. In July 2021, she heard from the media (official website of the Ministry of Internal
Affairs of the Russian Federation) about a criminal case initiated against the founders of QBEF. To date, the monetary
funds have not been returned to her in full in accordance with her requested withdrawal. In total, she has transferred
funds in the amount of 1,000,000 roubles to the QBEF group of companies under the contracts and agreements
concluded with them. QBF employees returned to her the funds in the amount of 300,000 roubles. RUB 700,000 has
not been returned to her. She believes that an offence has been committed against her, namely the thef of money by
deception and breach of trust in the amount of 1,000,000 roubles. She assesses the amount of damage caused as
significant;
(Vol. No. 17, pp. 113 - 117, 177 - 179)
- other documents - documents provided by O.B. Sasovskaya confirming her relationship with QBF Financial Group
(Vol. No. 17, pp. 120 - 172)
part 4 of article 159 of the Criminal Code of the Russian Federation against Sazonova I.O.:
- another document - a statement by I.O. Sazonova, in which she asks to bring to criminal responsibility persons from
among the employees, managers of the financial group "QBF" (LLC "Investment Company QBF"), who stole her
(Vol. No. 18, l.d. 8)
I.O. Sazonova's Testimony

as a witness and victim, according to which in January 2016 she learnt about the existence of the financial company
"QBF" (QBF) from her brother Sazonov Evgeny Olegovich. Her brother had by then invested a substantial amount of
money in QBF as an investment. In early May 2016, but no later than the 15th, from her mobile phone, she called the
"general" QBF reception phone and asked to be put through to one of the managers. She was connected to Yulia
Zaitseva. During repeated telephone conversations, Yulia Zaitseva insisted that she enter into a contract with QBF and
hand over her money to them to manage. Zaitseva told her about various investment options, strategies, returns, etc.
On 11.05.2016 in the morning, but no later than 13:00, she, having given in to persuasions and promises of high
returns, came to the office of QBF company, located at: Moscow, Presnenskaya Naberezhnaya 8, p. 1, 9th floor
("Moscow, Presnenskaya Naberezhnaya 8, p. 1, 9th floor"). 1, 9th floor ("Moscow City"). Zaitseva Y. gave her the
documents already signed by QBF representatives for signing. On 11.05.2016 she, being in the office of the company,
signed the documents handed over to her by Zaitseva Y., namely: agreement on provision of services of direct access
to international stock markets No. 2626 - 16/IMR dated 11.05.2016 between me and the company "QB Capital CY ltd"
represented by Munaev Z.V., agreement on provision of "Trust management" in accordance with the agreement on
provision of services of direct access to international stock markets No. 2626 - 16/IMR dated 11.05.2016 between me
and "QB Capital CY ltd" represented by Munaev Z.V. The agreement and the contract were already signed by Munaev
Zelimkhan Visaitovich. She has never seen Munaev Z.V. himself. On 11.05.2016, i.e. on the same day, being in the office
of LLC "IC QBF" at the address: Moscow, Presnenskaya Naberezhnaya 8, p. 1, she, within the framework of the
concluded agreement and contract, was in the office of LLC "IC QBF". 1, she, within the framework of the concluded
agreement and contract, handed over to Yulia Zaitseva for trust management of money belonging to her in the
amount of USD 20,000, which at the exchange rate of the Central Bank of the Russian Federation as of 11.05.2016
amounted to RUB 1,326,600. Having accepted the money from her, Yulia Zaitseva gave her a receipt for a cash receipt
for the amount of USD 20,000, and for some reason the receipt was dated 12 May 2016. Moreover, the receipt was for
some reason in the name of a Cypriot company "QB Capital CY ltd". At the time, she did not even ask herself how a
foreign company not registered in the territory of the Russian Federation could issue cash receipts in accordance with
the rules established exclusively for Russian legal entities under Russian law. All the more so because she had signed
864
the previously mentioned contract with OOO IK QBF. She believed that it was this company that would manage her
money on trust. Afer she deposited her funds, she started receiving reports on the state of her investment portfolio to
her email. Throughout 2016, Yulia Zaitseva constantly suggested that she transfer additional funds to QBF to invest
them, as she convinced her, in new financial "products". In November 2016, Julia Zaitseva persuaded her to invest an
additional €20,000 in QBF. She was very persuasive and persistent, so she agreed. On 25.11.2016, in order to receive
this amount, Yulia Zaitseva came to her personally. They met with her in the restaurant "The House" (now Larionov
Grill&Bar) in the shopping centre "Aventura", located not far from her (Sazonova) house, at the following address: 1
"A", Severnoe Chertanovo, Moscow. On 25.11.2016 approximately at lunchtime, but no later than 15 hours 00 minutes.
There she handed over to Yulia Zaitseva 20,000 euros under the concluded contract and agreement, which at the
exchange rate of the Central Bank of the Russian Federation as of 25.11.2016 was 1,361,800 roubles. Yulia Zaitseva
gave her a pre - prepared, signed receipt to the cash receipt order on behalf of the Cyprus company "QB Capital CY
ltd", dated 25 November 2016. Also, on 25.11.2016, Yulia Zaitseva handed her an additional agreement to the
previously signed contract, which she immediately signed. In June 2019, Yulia Zaitseva insisted that she cancelled the
trust management agreement with the Russian company QBF and entered into a new agreement with the foreign
company White Lake management Ltd. Yulia Zaitseva explained that this was a purely technical procedure, as White
Lake management Ltd was part of the QBF group of companies, and it was all necessary for the most efficient work on
international financial markets. As she did not understand anything in this, she, believing Yulia Zaitseva, signed a new
contract with "White Lake management Ltd" the "Trust management" agreement No. D - 912660 - F dated 27.06.2019
with "White Lake management Ltd". In addition, she signed twice some agreements in which she accepted the
obligation not to claim money from QBF during the next year. At the beginning of 2020, Yulia Zaitseva stopped
communicating with her. "QBF provided her with a new manager, Daria Meshkova. In March 2020, she wrote a letter to
Daria Meshkova in WhatsApp messenger in which she outlined her request to transfer money within QBF to other
financial products providing higher returns. There was no response to this letter. Since the managers of QBF actually
stopped contacting and communicating with her from about summer 2020, on 11.12.2020 she wrote an e - mail to
Daria Meshkova demanding the return of all the funds previously transferred to QBF. She did not receive any response
to this letter. On 17.12.2020 she wrote a second letter to Daria Meshkova demanding that she immediately return all
the money to me. She did not receive a reply to this letter either. Through her brother and his manager at QBF, she
told Daria Meshkova to get in touch immediately and to address her refund issue. Daria Meshkova, thereafer got in
touch, phoned her and agreed a meeting for 21.12.2020. However, on 21.12.2020 the meeting broke down. From
December 2020 to January 2021, she tried to call Daria Meshkova, but she did not contact her again and did not pick
up the phone. Between December and January 2021, she called the QBF reception desk on the "general" phone and
lef requests with the receptionists for someone from the QBF managers to contact her to resolve the refund issue. On
02.02.2021 Daria Meshkova got in touch with her. She asked Daria to send her a withdrawal application to her email,
afer which Daria Meshkova disappeared again. On 10.02.2021 Daria Meshkova sent her a notice on WhatsApp about
the realisation of assets, which she had to sign. This notification contained the following phrase: "The Client notifies
the Company and the Executor of the planned withdrawal order". She refused to sign this notice, as she did not plan,
but submitted an order for withdrawal of funds. Daria Meshkova refused to change this phrase or decipher it on the
part of the Company. Thus, she transferred funds to QBF Group of Companies as an investment in the amount of
2,688,400 roubles. The QBF group of companies did not return the money, even partially, to her. She believes that a
group of persons consisting of Yulia Zaitseva, Munaev Zelimkhan, Daria Meshkova and their unidentified accomplices
from among the so - called employees of QBF unlawfully, by deception, misappropriated the money belonging to her
in the amount of 20,000 (twenty thousand) US dollars and 20,000 (twenty thousand) euros, which at the exchange
rate of the Central Bank of the Russian Federation as of the date of transfer amounted to 2,688,400 roubles. The
amount of damage caused to her is 2,688,400 roubles, which is a significant loss for her;
(Vol. No. 18, pp. 11 - 14, 15 - 18, 28 - 32)
- other documents - documents provided by I.O. Sazonova confirming her relationship with QBF Financial Group (QBF
(Vol. No. 18, pp. 33 - 191)
865
part 4 of article 159 of the Criminal Code of the Russian Federation against Dyachenko E.V.:
- another document - a statement by E.V. Dyachenko, in which she asks to bring to criminal responsibility persons
(Vol. No. 19, pp. 7, 11)
- Dyachenko E.V.'s Testimony

given to her as a witness and victim, according to which in December 2016 her father Dyachenko Vladimir
Vladimirovich told her about the company "QBF". About the possibility to invest available funds in this company to
carry out financial operations on the international market. Then he gave her the contact of Bogdanov Kirill Yurievich
(tel. 89218581628, tel. 89046441254). They agreed to meet at the company's office located at the following address: St.
Petersburg, Maloohtinsky Ave. 64B, 9th floor, where they met on 20.12.2016. 26.01.2017 in the office of the company
"QBF" at the address: St. Petersburg, Maloohtinsky pr, d. 64B, 9th floor, she concluded the "Trust Management"
agreement No. 3025 - 17/18K. A few days later - on 31.01.2017, she deposited cash in the amount of 5000 000 (five
million) rubles in the presence of her financial advisor Bogdanov K.Y., in the negotiation room. The money was
accepted by an employee of the company "QBF". She received a receipt order. Subsequently, she regularly received
reports indicating foreign companies where her funds were placed. The returns were as per the reports convincing. On
26.04.2018, she prepared a set of documents for withdrawal of funds in the amount of 3,921,000 (three million nine
hundred and twenty - one thousand) rubles. In October 2018, the above amount was received on her current account
opened in "Sberbank". From the remaining funds in the amount of 1079,000 (one million seventy nine thousand)
rubles, the ZPIF "QVF" Regional Real Estate" was formed. At that time, according to Bogdanov K.Y., it was more
expedient to withdraw funds from the ZPIF afer the commissioning and revaluation of the Gribovsky les Residential
Complex located in Odintsovo, Moscow region. She obeyed.In July 2021 she learnt from the media that criminal
proceedings had been initiated against the employees and managers of the group of companies "OVR". Taking into
account the fact that the deadline for refunding her money had expired, there was no doubt that she had become a
victim of fraud. To date, she has not been refunded her money paid to the "OVF" group of companies in the amount of
1,079,000 (one million seventy - nine thousand) roubles. She believes that an offence has been committed against her,
namely thef of money by deceit and breach of trust. She estimates the amount of damage caused to her as
significant, namely 1,079,000 roubles (one million seventy - nine thousand roubles). She believes that the persons
acting on behalf of the "QBF" group of companies did not initially intend to fulfil their obligations to her and acted
solely for the purpose of stealing her money by deceiving her. Her right to file a civil action in the criminal case has
been explained to her. She wishes to exercise this right and file a lawsuit. She has been given the right to familiarise
herself with the composition of the investigation teams, the decisions to order forensic examinations, the expert
reports, the records of expert interrogations, and the materials of the criminal case in full or in part. She does not wish
to exercise this right. She has not applied to the court with applications for the recovery of money from the QBF group
of companies;
(Vol. No. 19, pp. 12 - 14, 29 - 31)
- other documents - documents provided by E.V. Dyachenko confirming her relationship with QBF Financial Group
(Vol. No. 19, pp. 17 - 24, 34 - 40)
part 4 of article 159 of the Criminal Code of the Russian Federation against Ermakov V.V.:
866
- another document - a statement by V.V. Ermakov, in which he asks to bring to criminal responsibility persons from
(Vol. No. 19, l.d. 53)
- Testimony of V.V. Ermakov, given by him as a witness and victim,

according to which in the winter of 2015, namely in early December, he received a call on his mobile phone number
from an employee - manager of the group of companies "QBF", who introduced himself as George Tsomaya.
George Tsomaya explained to him that he was a financial advisor of the QBF Group of Companies and offered him to
invest his assets in the QBF Group of Companies. They communicated on the phone, Tsomaya George very colourfully
and convincingly told him about the investment products available in the organisation "QBF", the ways of investment,
the mechanisms of profit formation, the order of reporting and informing the client, as well as in general about the
structure of the organisation. He was informed that the funds will be invested in investment platforms of foreign
countries. Everything was presented in a colourful form, devoid of flaws, Tsomaya George promised him a return of 7 -
9% per annum. As a result of all this presentation, he informed Tsomaya Georgiy in the course of a telephone
conversation that he was ready to invest in the group of companies "QBF". They agreed to meet at the main office of
"QBF". On 24.12.2015 at approximately 13:00 he arrived at the office located at: Moscow, Presnenskaya Naberezhnaya,
8, p. 1, 9th floor. 1, 9th floor. Upon arrival, he was met by George Tsomaya and escorted to a meeting room. Tsomaya
Georgiy had already prepared documents for him: the agreement on rendering services of direct access to
international stock markets with "QB Capital CY LTD" № 2452 - 15/IMR dated 23.12.2015 already signed by the
representative of the company Munaev Z.V., as well as the agreement on provision of "Trust Management" services in
accordance with the agreement on provision of direct access services to international stock markets No. 2452 - 15/IMR
dated 23.12.2015 (Account 002452) (INN/KPP 7733673955/770301001) with the company "QB Capital CY LTD"
represented by Munaev Z.V., also already signed by Munaev Z.V. He did not wonder why the documents were dated on
the 23rd, although he arrived on the 24th, nevertheless, he signed the above documents. Afer signing the above -
mentioned documents, as he and Tsomaya Georgiy had agreed beforehand, he gave him cash in the framework of the
agreements I had signed: USD 10,000, which at the exchange rate of the Central Bank of the Russian Federation as of
24.12.2015 was 709,300 roubles. Tsomaya Georgiy counted the money received from him and in return handed him a
receipt for a cash receipt order for the amount of USD 10,000. The receipt had the signature of the chief accountant
Gorobets E.V. and the stamp of "QB Capital CY LTD", this receipt was dated 24 December 2015, under the contract 2452
- 15/1MK dated 23.12.2015. Afer he invested the funds under the concluded contract and agreement for direct access
services to international stock markets in "QBF" group of companies, he started receiving monthly reports to his email
[email protected], which reflected the status of his investment portfolio. Afer some time his financial advisor
changed from Tsomaya Georgiy to a citizen named Zaytsev, the name is difficult to give. In the course of telephone
conversations with Zaitsev, the latter convinced him to invest additionally his funds. On 31.01.2017 at approximately
13:00, he arrived at the office located at the following address: Moscow, Presnenskaya Naberezhnaya, 8, p.1, 9th floor.
Upon arrival he was met by Zaitsev and escorted to a meeting room. In the meeting room, he handed him USD 5,500,
which at the exchange rate of the Central Bank of the Russian Federation as of 31.01.2017 was RUB 330,880. In return,
he received a receipt for a cash receipt order in the amount of USD 5,500. In the receipt was the signature of the chief
accountant Gorobets E.V. and the seal impression "QB Capital CY LTD", this receipt was dated 31 January 2017, under
the contract 2452 - 15/1МК from 23.12.2015. Zaytsev also asked him to sign a new agreement on the provision of trust
management services with "IK QB Capital CY LTD" (INN 77303673955), represented by no. I.A. Gusarenko. Zaytsev
explained to him that this was part of the new investment strategy of QBF Group and the reorganisation of the
companies. He signed the said agreement. Also later on 04.06.2018 he came to the head office at the request of
Zaitsev to sign a service agreement No. 2452 dated 04.06.2018 with "Simtelligence Company Limited", the above
agreement was also allegedly within the investment strategy of "QBF" group of companies. At the beginning of 2019,
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he again has a change of financial advisor from Zaitsev to Soloviev Igor. In order to withdraw the funds he had
invested in the "QBF" group of companies, on 03.04.2019 he applied for withdrawal and started the procedure of
collecting documents for withdrawal. There was a huge list of documents which he collected by early 2020. On
23.09.2019 his new financial advisor was Tallerov Artem, who invited him to the office under the same pretext - to sign
new documents related to the investment strategy of "QBF" group of companies. Thus, on 27.09.2019 at
approximately 13.00 hours he arrived at the office located at: Moscow, Presnenskaya Naberezhnaya, 8 pg. 1, 9th floor.
Upon arrival, he was met by Tallerov Artem and escorted to a meeting room. Tallerov A. had signed documents in his
hands: a "Trust Management" agreement and No. D - 025407 - I dated 27.09.2019 on the part of "White Lake
Management Ltd" represented by Korshunov D.A. and a service agreement dated 27.09.2019 represented by a certain
Maricheva O.V. He signed the above documents in the hope of a faster withdrawal of funds. In December 2019,
Danilenko Maxim (tel. 8 - 916 - 615 - 26 - 61) became his financial advisor. He had a lot of communication with
Danilenko M., and the maximum outcome was the withdrawal of funds to him on 12.02.2021 in the amount of USD
2,000, which at the exchange rate of the Central Bank of the Russian Federation as of 21.02.2021 was 147,500 rubles.
He failed to withdraw more money. Later, at the end of May, beginning of June 2021, he learned from the media,
including official news of the Ministry of Internal Affairs of Russia, that criminal proceedings had been initiated and
QBF was under investigation. Taking into account the specifics of communication with managers, the problems
encountered when withdrawing funds, and also taking into account the fact that the money has not been returned to
him in full, I have no doubt that he has become a victim of fraudsters. In total, he transferred 1,040,180 roubles to the
"QBF" group of companies from 24.12.2015 to 31.01.2021. Until now, the full amount of the money he invested in the
group of companies "QBF" has not been returned to him. Claims will be brought for the amount of damage caused to
him. Considers that an offence has been committed against him, namely thef of his money by deceit and abuse of
trust. He considers the amount of damage caused to him as significant;
(Vol. No. 19, pp. 56 - 59, 67 - 71)
- other documents - documents provided by V.V. Ermakov confirming his relationship with QBF Financial Group (QBF
(Vol. No. 19, pp. 72 - 181)
part 4 of article 159 of the Criminal Code of the Russian Federation against Cherkasov V.Y.:
- another document - a statement by Cherkasov V.Y., in which he asks to bring to criminal responsibility persons from
(Vol. No. 20, pp. 6, 7)
- The testimony of V.Y. Cherkasov, given by him as a witness and victim,

according to which approximately in 2009 he met, being a client of PJSC "Sberbank of Russia", with a manager named
Frolova Evgenia (t. 8 - 906 - 251 - 22 - 86). She was his manager who offered him investment products of the company
where she worked. She was then employed by VTB PJSC, where she also recruited him as a client of the bank. He had
personal savings by virtue of his managerial position in a group of companies involved in the supply of goods in the
field of mechanical engineering. He invested his personal savings in the activities of the banks of which he was a
client. Being in a trusting relationship with Frolova E., he listened to her advice and recommendations as a client
money manager. Some time later Frolova E. resigned from PJSC "VTB" and was employed by QBF group of companies.
Afer these events, Frolova E. contacted him and offered to transfer her assets to QBF group of companies. He agreed,
afer some time, because he had an opportunity to invest his personal funds and also because of his trust in Frolova
E.. When they talked on the phone, Frolova E. told him very colourfully and convincingly about investment products
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available in the organisation "QBF", ways of investment, mechanisms of profit formation, the order of reporting and
informing the client. He was informed that the funds would be invested in investment sites of foreign countries.
Everything was presented in a colourful way, devoid of flaws, Frolova E. promised him high profitability. As a result of
all this presentation, he informed Frolova E. in a telephone conversation that he was ready to invest in QBF group of
companies. They agreed to meet at the main office of "QBF" in St. Petersburg. So, on 21.07.2017 at approximately
13:00 he arrived at the office located at the address: St. Petersburg, Maloohtinsky prospectus, d. 64. Upon arrival, he
was met by Frolova E. and escorted to the meeting room. In the negotiation room they were waited for by her
supervisor, aka the signatory of the documents - Alexei Sergeyevich Golubev. A.S. Golubev had already signed copies
of documents with LLC IC "Qubeef" represented by the sales manager A.S. Golubev, namely the agreement on
provision of "Trust Management" services No. 3315 - 17/IMR dated 21.07.2017, as well as the agreement on provision
of services of direct Access to international stock markets with "QB Capital CY LTD" No. 3315 - 17/IMR 21.07.2017 in the
person of the representative by power of attorney Golubev A.S. They once again discussed the principle of work of the
group of companies and he signed. Having signed the said documents, Golubev A.S. invited a girl unknown to him,
who went into the meeting room with a machine to recalculate the money. On the phone with Frolova E. he indicated
that he would arrive with cash. Subsequently, he handed over the money to the girl in the amount of 70,000 US
dollars for recalculation, which at the exchange rate of the Central Bank of Russia as of 21.07.2017 is 4,135,600 rubles.
The girl counted the notes, took the entire amount and lef the meeting room. Afer some time she returned to their
meeting room and handed him a receipt to the cash receipt order, which contained the signature of the chief
accountant of "QB Capital CY LTD" Gorobets E.V., as well as an impression of the seal of "QB Capital CY LTD". Afer he
invested funds in "QBF" group of companies, he started receiving monthly reports on the status of his investment
portfolio to his email address [email protected]. At the beginning of June 2018, he received a call on his mobile phone
number from Frolova E., who explained that he needed to come to the office of the "QBF" group of companies to sign
an additional set of documents. She explained that this was necessary due to a change in the investment strategy of
the group of companies and that this action was inherently only formal in nature. He was satisfied with this
information received from the reports, and also due to the trust he had in Frolova E., he agreed to come to the office
to sign the documents without any unnecessary conversations. Thus, on 04.06.2018 at approximately 13:00 he arrived
at the office located at the address: St. Petersburg, Maloohtinsky Prospekt, d. 64, where he was also met by Frolova E.,
who took him to the meeting room, where he signed a service agreement No. 3315 dated 04.06.2018 with
"Simtelligence Company Limited" in the person of a certain Korshunov D.A., whom he had never personally seen or
communicated with in his life. Similarly, a year and a half later, in December 2019, he also received a call on my
mobile phone number from Frolova E., who explained that he again needed to come to the office of the "QBF" group
of companies to sign an additional set of documents. She similarly explained to him that it was necessary in
connection with the next change of the investment strategy of the group of companies and that this action had only a
formal meaning in its essence. He had no reason not to trust Frolova E. as far as the above information was
concerned, and he agreed to come. Thus, on 18.12.2019 at approximately 13:00 he arrived at the office located at: St.
Petersburg, Degtyarny pereulok, d. 11B, where he was also met by Frolova E., who took him to the meeting room,
where he signed a service agreement dated 18.12.2019 with LLC "VL Consulting" in the person of a certain Maricheva
O.V., which she already had in her hands, as well as a trust management agreement № D - 758514 - L with "White Lake
Management LTD" in the person of the same Korshunov D.A. Additionally, I inform you that he has never seen or
communicated with Korshunov D.A. and Maricheva O.V.. At the beginning of 2020 he had a need to withdraw his funds
in full from the group of companies "QBF". He contacted Frolova E. by phone, to which she began to dissuade him,
referring to the unfavourable situation on the financial markets, against the background of the pandemic and the
global crisis in general. He agreed with Frolova E.'s arguments and postponed this conversation until autumn 2020. In
the autumn of 2020, in October, he again addressed Frolova E., but in a more urgent form, saying that he was going to
withdraw all the funds he owned from the group of companies "QBF". Frolova promised to prepare the necessary
documents and call him back. She did not contact him for some time, and when he called her herself, she informed
him that she had resigned and no longer worked in the "QBF" group of companies. Afer the conversation with Frolova
E., he independently called the office on the general line and asked to be contacted by his current financial advisor.
Afer some time he received a call on his mobile phone number from Dmitry Vladimirovich Moskalyuk (tel. 8 - 965 - 028
- 88 - 88), they chatted and he invited him to a meeting at the office of the company. He agreed and in the first days of
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November 2020 he arrived at the office at the address: St. Petersburg, Degtyarny pereulok, d. 11Б. During the meeting
Moskalyuk D.V. informed him that the scheme described in the documents he had signed would not work, he
suggested that he open an account in a foreign jurisdiction, for which a large package of documents had to be
collected. This package of documents included the most incredible certificates, copies of documents with their
apostilisation. He collected these documents and at the end of December 2020 handed them over to the office,
sending them from his email address. In February 2021 Moskalyuk D.V. informs him that the previously described
scheme of withdrawal with opening an account abroad and collecting documents will not work. Therefore, D.V.
Moskalyuk started to offer him as a refund of his money participation in a ZPIF, which is an illiquid asset on the
balance sheet of the QBF group of companies. He, pursuing the purpose to return the money belonging to him, gave
his consent to Moskaluk D.V. (in correspondence) and they agreed that within 3 months the ZPIF would be sold out
and he would be reimbursed the money belonging to him. Later, at the end of May - beginning of June 2021, he learnt
from mass media, including official news of the Ministry of Internal Affairs of Russia, that criminal cases had been
opened and the investigation was underway. Taking into account the specifics of communication with managers,
problems with withdrawal of funds, and also taking into account the fact that the money was not returned to him in
full, he has no doubt that he became a victim of fraudsters. Until now, his money has not been returned to him, in
total, he transferred 4,135,600 rubles to the address of the group of companies "QBF". He believes that an offence has
been committed against him, namely the thef of his money by deceit and breach of trust. He considers the amount of
damage caused to him as significant. Additionally, within the framework of the present interrogation he asks to attach
to the materials of the criminal case the originals of the following documents: Agreement on provision of "Trust
Management" services in accordance with the Agreement on provision of direct access services to international stock
markets No. 3315 - 17/ISR dated 21.07.2017 (Account 003315) on 6 sheets; Annex No. 1 to the Agreement on provision
of "Trust Management" services in accordance with the Agreement on provision of direct access services to
international stock markets No. 3315 - 17/ISR dated 21.07.07.2017 (Account 003315) on 3 sheets; Annex No. 2 to the
Agreement on Provision of Trustee Services in accordance with the Agreement on Provision of Direct Access to
International Stock Markets No. 3315 - 17/ISR dated 21.07.07.2017 (Account 003315) on 3 sheets; Agreement on
Provision of Direct Access to International Stock Markets Services No. 3315 - 17/ISR dated 21.07.2017 on 13 sheets;
Client Questionnaire Agreement on Provision of Direct Access to International Stock Markets Services No. 3315 -
17/ISR dated 21.07.07.2017 on 1 sheet; copy of receipt to the cash receipt order dated 21.07.2017 in the amount of
USD 70,000 on 1 sheet; trust management agreement No. D - 758514 - L on 9 sheets; asset management agreement
no. D - 758514 - L on 8 sheets; service agreement (standard form of adhesion agreement) dated 18.12.2019 on 26
sheets; investment declaration to the agreement No. 758514 - 09 dated 18.12.2019 on 1 sheet; service agreement No.
3315 dated 04.06.2018 on 13 sheets;
(Vol. No. 20, pp. 10 - 14, 25 - 29)
- other documents - documents provided by V.Y. Cherkasov confirming his relationship with QBF Financial Group (QBF
(Vol. No. 20, pp. 15, 32 - 115)
part 4 of article 159 of the Criminal Code of the Russian Federation against Mullo T.I.:
- another document - a statement by Mullo T.I., in which he asks to bring to criminal responsibility persons from
(Vol. No. 20, pp. 129,130)
- Mullo T.I.'s testimony , given by him as a witness and victim,

according to which in May 2016 he received a call on his subscriber phone number from the manager of the group of
companies "QBF" Tetyuev Sergey Alexandrovich. In the course of the telephone conversation Tetyuev S.A. offered him
870
to invest money in the investment programmes of "QBF". He promised high returns and high interest on deposits. As a
result, S.A. Tetyuev invited him to the company's office located at the address: 64, Maloohtinsky Ave., Lit. B. The
meeting with S.A. Tetyuev took place on 26.05.2016, where in the meeting room S.A. Tetyuev offered to invest through
the provision of trust management services by "QBF". In the conversation Tetyuev S.A. repeatedly emphasised the
reliability of the group of companies "QBF" and the stable percentage of income from investment. He assured him
that the company has a long and successful experience of work in Russia and abroad, and also has all necessary
licences. Tetyuev S.A. informed him that the reliability of work with the company is guaranteed by the legislation of
the Russian Federation, due to the fact that he will cooperate directly with Russian organisations, namely: LLC IC
"QBF" (INN 7733673955). Afer this his consent to participate in the cooperation, and under the pretext of their
investment in securities with high yield on behalf of non - resident "QB Capital CY LTD" ("QB Capital CY LTD"), he
concluded the Agreement on the provision of services of direct access to international stock markets No. 2660 - 16/ISR
dated 26.05.05.2016, as well as on behalf of IC QBF LLC the Agreement on provision of "Trustee" services in
accordance with the Agreement on provision of services of direct access to international stock markets No. 2660 -
16/ISR dated 26.05.2016. S.A. Tetyuev explained the presence of names of foreign companies in the documents by the
fact that the optimal option of investing funds in currency, more precisely in US dollars. That the company IC QBF LLC
will be responsible for the whole process, because according to clause 10.3 of the Agreement "The Attorney (IC QBF
LLC) bears full financial responsibility to the Principal in the amount established in accordance with the Annexes of
the Investment Declaration to this Agreement". On 08.06.2016 in the office of "QBF", he transferred the sum (in cash)
in the amount of 670 000 (six hundred seventy thousand) rubles in the presence of Tetyuev S.A. to the cashier of the
group of companies, about what he received a receipt from the executive director Gorobets E.V. The specified sum of
money, according to the words of the employees of the company, was transferred into US dollars. Also, on 18.08.2016,
a sum of money in the amount of 700,000 (seven hundred thousand) rubles was deposited to the same account,
about which a receipt was received from the chief accountant Gorobets E.V. On 26.09.2016, a cash amount of 400,000
(four hundred thousand) rubles was deposited in the form of non - cash funds (cheque order dated 26.09.2016). On
10.08.2017 an agreement on provision of direct access services to international stock markets No. 3341 - 17/ISR and
an agreement on provision of "Advisory Management" services under the said agreement were concluded. On the
said day he made a cash deposit of 400,000 (four hundred thousand) rubles (cheque order dated 10.08.2017) in the
form of non - cash funds and 1,800,000 (one million eight hundred thousand) rubles in cash in the company's office
located in BC "Plaza SPb", about which he received a receipt from the chief accountant Gorobets E..V. Also on
14.08.2017 he paid RUB 1,800,000 (one million eight hundred thousand) in cash at the company's office located in BC
"Plaza SPb", of which he received a receipt from the chief accountant E.V. Gorobets. On 29.09.2017 a determination on
the cancellation of Agreement No. 1 was concluded. On 04.06.2018, a service agreement No. 2660 was concluded with
Simtelligence (Hong Kong). On 05.09.2019, the parties signed a determination to terminate Agreement No. 1. In
addition, on 05.09.2019 the Trust Management Agreement No. D - 699905 - I with "White Lake Management Ltd" and
the Service Provision Agreement with "VL Consulting Ltd" and its agreements No. 1 (Service Provision Regulations),
No. 2 (General Terms and Conditions of Investment Declarations), No. 3 (Standard Form), No. 4 (Standard Form) were
concluded, No. 5 (risk notification), No. 6 (consent for processing and dissemination of personal data), No. 7
(application for joining the service provision agreement No. 699905 - 09), Additional Agreement No. 1 (Investment
Declaration), Additional Agreement No. 2 (Investment Declaration). On 13.10.2021, Asset Disposition Notice 2110014
was signed. Monthly reports on the utilisation of his funds were sent to his email address. In October 2021 he learnt
from Tetyuev S.A. and mass media, as well as official publications of the Ministry of Internal Affairs of Russia that
criminal proceedings had been initiated and key employees of QBF Group of Companies had been arrested for fraud.
According to information known to him, criminal proceedings have already been instituted against certain
representatives of the QBF group of companies (QBF) for episodes of trust management (TM) and money transfer to
offshore companies. Due to the massive non - payment to many other clients since the end of May 2021, as well as the
criminal proceedings already underway, there is reason to believe that the withdrawal orders will not be honoured.
QBF Group's representatives and financial advisor are unable to provide any substantive explanation of the situation.
There is every reason to believe that instead of investing the money received from clients on the securities market,
these funds were misused, and the reports provided to clients were "fake". He made withdrawals from 30.11.2017 to
16.04.2020 for a total amount of RUB 2,422,669.18. Taking into account the fact that the deadlines for returning the
871
money from him have expired, there is no doubt that he became a victim of fraudsters. To date, he has not been
returned his money deposited to the "QBF" group of companies in the amount of 2,547,330.82 rubles. He believes
that the persons acting on behalf of the group of companies "QBF" initially did not intend to fulfil their obligations to
him and acted solely for the purpose of stealing his money by deceiving him. In the period from 08.06.2016 to
14.08.2017, the persons acting on behalf of the group of companies "QBF" stole money belonging to him in the total
amount of 2 547 330,82 rubles. He considers the amount of damage caused to him as significant. He has been
explained the right to file a civil suit in the criminal case. He wishes to exercise this right and file a lawsuit. He has
been explained the right to familiarise himself with the composition of the investigative teams, with the decisions on
the appointment of forensic examinations, with the conclusions of experts, with the protocols of interrogations of
experts, as well as to familiarise himself with the materials of the criminal case in full or in part. He does not wish to
exercise this right. In addition, he has not applied to the court with applications for the recovery of money from the
QBF group of companies;
(Vol. No. 20, pp. 133 - 136, Vol. No. 21, pp. 40 - 43)
- other documents - documents provided by Mullo T.I. confirming his relationship with QBF Financial Group (QBF
(Vol. No. 20, pp. 142 - 204, Vol. No. 21, pp. 1 - 35)
part 4 of article 159 of the Criminal Code of the Russian Federation against Maslov Y.V.:
- another document - a statement by Maslov Y.V., in which he asks to bring to criminal responsibility persons from
(Vol. No. 21, pp. 56, 65 - 69, 207)
- The testimony of Maslov Y.V., given by him as a witness and victim,

according to which in the summer of 2017 he received a call from the manager of the group of companies "QBF"
Frolova Evgenia (phone number +7 - 952 - 260 - 33 - 17, with whom he has known since 2000, previously she worked as
a manager of Sberbank and VTB Bank. During the conversation Frolova E. told him that she was a financial advisor of
the group of companies "QBF", and then began to mislead him about the allegedly high earnings from investments in
the group of companies "QBF". Frolova E. convinced him that his money should not lie on the bank account, but
should work in investments. With her stories Frolova E. convinced him to come to the office of the group of companies
"QBF", to get more information. On 17.08.2017 he came to the office of the group of companies "QBF" at the address:
St. Petersburg, Maloohtinsky pr., 64B, he was met by Frolova E., who continued to persuade him in every possible way,
persuade him to deposit money and mislead him about the legality of their activities, about the possibility of high
earnings from investments and so on. He believed the words of Frolova E. and trusted her. 17.08.2017 being in the
office of the group of companies "QBF" at the address: St. Petersburg, Maloohtinsky Ave, 64B with the purpose, as he
believed at that time, of investing money in securities, he concluded the Agreement on rendering services of direct
access to international stock markets No. 3354 - 17/ISR dated 17.08.2017 with "QB Capital CY LTD" ("QB Capital CY
LTD"), and also entered into a "Trustee Services Agreement" with "QBIF" LLC in accordance with the Direct Access to
International Stock Markets Services Agreement No. 3354 - 17/ISR dated 17.08.2017. Having trusted the manager of
the group of companies "QBF" Frolova E. and being in a state of delusion. 17.08.2017 being in the office of the group of
companies "QBF" at the address: St. Petersburg, Maloohtinsky prospect, 64B, in the presence of Frolova E., he
deposited in the cash desk of the "QBF" group of companies his own funds in the amount of 300,000 (three hundred
thousand) Euros, which at the exchange rate of the Central Bank of Russia as of 17.08.2017 was 20,998,740 rubles, as
well as 400,000 (four hundred thousand) US dollars, which at the exchange rate of the Central Bank of Russia as of
872
17.08.2017 was 23,860,840 rubles and 6,000,000 (six million) rubles. The cash was accepted by the cashier of the group
of companies "QBF" whose data he does not know. In order to mislead him and to make what was happening look
like a legal activity, the cashier of the group of companies "QBF" gave him receipts for receipt orders: No. b/n dated
17.08.2017 for the amount of 300 000 (three hundred thousand) Euros, No. b/n dated 17.08.2017 for the amount of 400
000 (four hundred thousand) US dollars and No. b/n dated 17.08.2017 for the amount of 6 000 000 (six million) rubles.
Later he became aware that Frolova E. received monetary remuneration in the amount of 1% to 3% of the money he
deposited, thus Frolova E. was interested in fraud against him and received criminal profit for it. He believes that
Frolova E. was aware of the criminal activities committed by the employees and managers of the QBF group of
companies against citizens. Frolova E. received a share of the stolen money for her actions in attracting and deceiving
citizens. In October 2018, he visited the office of the "QBF" group of companies 3 times at the address: St. Petersburg,
Maloohtinsky pr., 64B, where in the presence of Frolova E. the cashier of the "QBF" group of companies, whose data
he does not know, gave him cash in the total amount of 250,000 (two hundred and fify) thousand US dollars, which at
the maximum exchange rate of the Central Bank of the Russian Federation for October 2018 is 16,742,125 rubles.
Throughout the entire period of time Frolova E. constantly deceived him and supported the legend that his cash funds
were invested in various financial projects of the group of companies "QBF", as he did not have special knowledge and
skills in the field of investment he did not realise that Frolova E. was deceiving him and the investment was not carried
out. On 20.06.2019 Frolova E. told him that he should sign the Trust Management Agreement No. D - 301232 - F dated
20.06.2019 with "White Lake Management Ltd." and the service agreement with "VL Consulting" Ltd. dated
20.06.2019. According to Frolova E., these documents allegedly replaced the previously concluded contracts and
agreements (above). Since he trusted Frolova E. and did not know what was going on, he fulfilled her (Frolova E.)
instructions. At the end of 2020 Frolova E. informed him that she had resigned from the group of companies "QBF"
due to moving to another city. Naumova Tatiana Naumova, the financial manager of the "QBF" group of companies,
was assigned to him for further support of his "investments". At the beginning of February 2021, he approached
Naumova T. regarding the complete withdrawal of funds from the group of companies "QBF". Naumova T. began to
deceive him about the terms of return of money, began to delay the terms and invent different reasons not to return
the money. Since his money was not returned to him, he began to call Naumova T. on a regular basis and demand the
return of his money. Naumova T. was joined by another employee of the "QBF" group of companies - the head of the
investment department (as he introduced himself) Anton Porfiriev. Naumova T. together with Porfiriev A. continued to
deceive him and mislead him in every possible way about the return of his money. At that moment he realised that he
was a victim of fraudsters and was simply deceived in order to steal his money. At the end of April 2021 he was
contacted by the financial advisor of the group of companies "QBF" Moskalyuk Dmitry, who also began to deceive him
in every possible way about the return of his money, invented various reasons - falsehoods, for which he could not
return his money. He realised that D. Moskalyuk is the same fraudster, who just fools him and is not going to return his
money. He believes that Frolova E., Naumova T., Moskalyuk D. and Porfiriev A. deliberately deceived him, they did not
actually make any promised investments and had no real opportunity to do so. By virtue of their official position and
specialised knowledge Frolova E., Naumova T., Moskalyuk D. and Porfiriev A. could not have been unaware of the
aforementioned facts of fraud. To date, he has not been returned his money deposited in the cash desk of the QBF
group of companies, as he naively believed at the time for investment, in the amount of 34,117,455 roubles. He
believes that the persons acting on behalf of the group of companies "QBF" initially did not intend to fulfil their
obligations to him and acted solely for the purpose of stealing his money by deceiving him. On 17.08.2017, the
persons acting on behalf of the "QBF" group of companies stole the money belonging to him in the total amount of
34,117,455 rubles. He considers the amount of damage caused to him as significant. He has been explained the right
to file a civil action in the criminal case. He wishes to exercise that right and file a lawsuit. He has been explained the
right to familiarise himself with the composition of the investigative teams, with the decisions on the appointment of
forensic examinations, with the conclusions of experts, with the records of interrogations of experts, and also to
familiarise himself with the materials of the criminal case in full or in part. He does not wish to exercise this right. He
has not applied to the court with applications to recover money from the QBF Group of Companies;
(Vol. No. 21, pp. 208 - 213, Vol. No. 22, pp. 124 - 127)
873
- other documents - documents provided by Y.V. Maslov confirming his relationship with QBF Financial Group (QBF
(vol. No. 21, pp. 70 - 205, 215 - 240, vol. No. 22, pp. 1 - 117)
part 4 of article 159 of the Criminal Code of the Russian Federation against Velichko S.A.:
- another document - a statement by S.A. Velichko, in which he asks to bring to criminal responsibility persons from
(Vol. No. 22, l.d. 140)
- The testimony of S.A. Velichko, given by him as a witness and victim,

according to which approximately in February 2013 he learnt about the group of companies "QBF" from a phone call.
A representative of the group of companies "QBF" Padalko Nikolai Sergeevich (89645303376) called him on his phone.
Padalko N. told him that the group of companies "QBF" is engaged in investing in shares of foreign companies and
offered to invest in various stock exchange products. Padalko was very persuasive and persistent, therefore, he was
interested in his proposal, however, he decided to think about it. On 10.04.2013, at approximately 12:00, he arrived at
the address: Moscow, 8 Presnenskaya Naberezhnaya St., p. 1, where he was met by the financial advisor. 1, where he
was met by the financial advisor Nikolay Padalko, he repeatedly offered to invest in various stock exchange products,
he was very persuasive and persistent. Before starting to invest through the group of companies "QBF", he made
enquiries about the company through the Internet, all reviews about the company were positive, everyone said that
they successfully invested, as well as successfully withdraw the invested funds, there were no doubts about the
integrity of the company at the time of investment, therefore, he decided to agree to their proposal. On 10.04.2013 at
about 12:30 a.m. at the meeting at the address: Moscow, Presnenskaya Naberezhnaya St., 8, st. 1, he concluded an
agreement with "QB Finance" LLC (INN 7733673955) on provision of "Trust Management" services №964 - 13/VR dated
10.04.2013 and with "QB Capital CY LTD", direct access to the US securities market №964 - 13/VR dated 10.04.2013. At
the conclusion of the agreement the representatives of the group of companies "QB Capital CY LTD" were the
employees of the group of companies "QBF" financial advisor Padalko Nikolay and the signatory from the side of "QB
Capital CY LTD" Shpakov R.V., but he did not see him personally, he was not present at the meeting, the documents
were brought to him already signed. On 11.04.2013 at about 12:00 a.m. he arrived at the branch of the bank "OTP
Bank", located at the address Moscow, Zemlyanoy Val str. 46 and transferred funds in the amount of USD 11,000,
which at the exchange rate of the Central Bank of the Russian Federation as of 11.04.2013 amounted to 341,000
rubles, to his investment account according to the agreement No. 964 - 13/VR dated 10.04.2013, from his account No.
42306840400320000249 to account CY1700800170000000000000000000688040. His bank account was opened in OTP
Bank at the address: Moscow, Zemlyanoy Val str. 46. Afer the transfer of funds, he informed his financial adviser
Nikolai Padalko that he had made the transfer, afer which Nikolai Padalko confirmed the receipt of funds to his
(Velichko's) account. On 27.08.2013 at approximately 12:00 a.m. he arrived at the address 8 Presnenskaya
Naberezhnaya St., bldg. 1, Moscow, where he was met by the financial advisor. 1, where he was met by the financial
adviser Nikolai Padalko. He handed over cash in the amount of USD 10,000, which at the exchange rate of the Central
Bank of the Russian Federation as of 27.08.2013 was RUB 329,600. Afer the transfer of funds, the financial advisor
Nikolay Padalko handed over a receipt on receipt of funds by QBF Group dated 27.08.2013. On 22.11.2013 at
approximately 12:00 a.m. he arrived at the following address: Moscow, 8 Presnenskaya Naberezhnaya St., p. 1, where
he was met by the financial advisor. 1, where he was met by the financial adviser Nikolay Padalko. He said that he
wished to write an order to withdraw funds under the agreement No. 964 - 13/VR dated 10.04.2013, in the amount of
USD 9,000 at the exchange rate of the Central Bank of the Russian Federation in rubles, afer which on 25.11.2013 his
card received funds in the amount of 296,149.5 rubles. On 19.05.2014 at approximately 12:00 a.m. he arrived at the
874
following address: 8 Presnenskaya Naberezhnaya St., bldg. 1, Moscow, where he was met by the financial advisor. 1,
where he was met by the financial advisor Nikolay Padalko and handed over cash in the amount of USD 6,000, which
at the exchange rate of the Central Bank of the Russian Federation as of 19.05.2014 was 208,680 rubles, to be credited
to his investment account under the agreement No. 964 - 13/VR dated 10.04.2013. On 21.11.2014 at approximately
12:00 a.m. he arrived at the following address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, where he was met by
Padal. 1, where he was met by Padalko N. He informed him that he wished to write an order to withdraw funds under
the agreement No. 964 - 13/VR dated 10.04.2013, in the amount of USD 3,000, afer which on 21.11.2014 the funds in
the amount of RUB 140,114.1 were transferred to his card. On 28.08.2017 at approximately 12:00 a.m. he arrived at the
address Moscow, 8 Presnenskaya Naberezhnaya St., bld. 1, where he was met by the financial adviser Nikolai Padalko.
He (Velichko) gave him (Padalko) cash in the amount of USD 5,000, which at the exchange rate of the Central Bank of
the Russian Federation as of 28.08.2017 amounted to RUB 295,750, to be credited to his investment account under
Agreement No. 964 - 13/VR dated 10.04.2013. Afer the transfer of funds, the financial advisor gave Nikolay Padalko a
receipt to the cash receipt order dated 28.08.2017. Thereafer, the funds were on his investment account, the group of
companies "QBF", sent monthly reports on the status of the account. In July 2019, he received a call from his financial
advisor, Nikolay Padalko, informing him that due to "technical changes" in the group of companies "QBF", it was
necessary to re - sign the contract with "White Lake", in order to optimise the work with securities. On 19.08.2019 at
approximately 12:00 hours, he arrived at the address Moscow, Presnenskaya Naberezhnaya, 8, pp. 1, where he was
met by the financial advisor Nikolay Padalko. The latter provided a package of documents from White Lake
Management, a company registered in the Cayman Islands, afer which he re - signed the trust management
agreement with White Lake Management No. B - 379039 - N dated 19.08.2019, Asset Management agreement No. B -
379039 - N dated 19.08.2019, service agreement (standard form of accession agreement) with White Lake
Management dated 19.08.2019, service agreement No. 964 dated 04.06.2018. On 24.12.2020 Nikolay Padalko informed
him that he (Padalko) was being promoted and that his (Velichko) financial advisor would be Olga Bataeva (tel. 8 - 964
- 530 - 33 - 56). However, about a month later, his new financial adviser was Daria Meshkova (tel. 8 - 903 - 100 - 53 - 17).
Tentatively in May 2021, he heard from the media (official website of the Ministry of Internal Affairs of the Russian
Federation) about a criminal case against the founders of QBEF. In order to save his money in May 2021 he called
Padalko Nikolay to find out what to do in this situation, to which he sent him a letter, which contained a list of
documents, afer the provision of which the group of companies "QBF" would accept to implement the order to
withdraw funds. However, subsequently, the financial advisors of the group of companies "QBF" delayed the
withdrawal of funds in every possible way, arguing that there was a bank check, asked whether he could confirm the
ownership of the invested funds, said that there were difficulties with the withdrawal. On 02.03.2020 he repeatedly
sent an order for withdrawal of funds to the group of companies "QBF", but no withdrawal of funds was made. On
23.03.2020 he once again sent an order for withdrawal of his invested funds to "QBF" group of companies, attaching
documents according to the list provided by the employee of the group of companies necessary for withdrawal.
However, even in this case the withdrawal of funds was not realised. He believes that an offence has been committed
against him, namely thef of funds by deceit and abuse of trust, for a total amount of 1,175,030 rubles;
(Vol. No. 22, pp. 143 - 148, Vol. No. 23, pp. 6 - 10)
- other documents - documents provided by S.A. Velichko confirming his relationship with QBF Financial Group (QBF
(Vol. No. 22, pp. 151 - 231, Vol. No. 23, pp. 11 - 21)
part 4 of article 159 of the Criminal Code of the Russian Federation against Gumenyuk D.V.:
- another document - a statement by Gumenyuk D.V., in which he asks to bring to criminal responsibility persons from
(Vol. No. 23, pp. 35, 39)
875
- The testimony of Gumenyuk D.V., given by him as a witness and victim,
according to which in the autumn of 2017 his girlfriend Fadina Diana Vasilyevna (8 - 911 - 900 - 87 - 90) got a job at the
company QBF LLC. That's when she told him about the company's activities, that it had been on the market for
several years and had offices in a number of regions. That the company was successfully engaged in financial
management and had extensive experience in this area. Then she also arranged for him to meet with its head
Pakhomov Grigory (8 - 950 - 009 - 30 - 66). On 13.09.2017 he came to the office of the company LLC IC QBF, located at
the address: St. Petersburg, Maloohtinsky pr., 64, lit. A, BC "St. Petersburg Plaza", where he met with Pakhomov G.,
who told him about the company's products, how it functions, told him about the possibility of additional income by
investing money in IPO - initial public offering of securities on the stock exchange. Then he decided to invest his
money and entered into the "Trustee Services Agreement" No. 3408 - 17/ISR (hereinafer referred to as the
Agreement). The following documents were signed together with the Agreement: Appendix No. 1 to the Contract
(Investment Declaration) dated 13.09.2017; Agreement on Provision of Direct Access to International Stock Markets
Services No. 3408 - 17/ISR dated 13.09.2017. On 15.09.2017 he handed over money in the amount of USD 30,000
(thirty thousand) in the company's office located at the address : St. Petersburg, Maloohtinsky pr. , 64, lit. A, BC
"St. Petersburg Plaza". He handed over the money to the accountant in the presence of Pakhomov G., who gave him a
receipt No. b/n dated 15.09.2017. In addition, on 04.10.2017, he handed over money in the amount of 20,000 (twenty
thousand) US dollars in the company's office located at the address: St. Petersburg, Maloohtinsky prospect, 64, lit. A,
BC "St. Petersburg Plaza". He also handed the money to the accountant in the presence of Pakhomov G., who gave
him a receipt No. b/n dated 04.10.2017. Since October 2017, he began to receive reports on the purchase and sale of
shares of street companies to his mail. Around November 2017, he decided to withdraw the funds and wrote a
withdrawal application for USD 20,000 (twenty thousand). Sometime, in early 2018, he received the said amount in
cash. At the same time, more precisely in early 2018, Pakhomov G. began to ignore him and stopped answering his
calls. He called the company's office, explained the situation and demanded the appointment of a new financial
advisor. Some time later, he received a call from Artem Efremtsev (8 - 99 - 042 - 28 - 32) and, if he is not mistaken, set
up a meeting in the new office at 11, lit. A, Degtyarny Lane, St. Petersburg, BC "Nevskaya Ratusha", where they met. He
repeatedly tried to write an application for withdrawal of all the funds, to which Efremtsev A. each time found new
arguments why he should not do it. That the international stock exchange was not the best situation, that there was a
crisis, that there was a "drawdown". That it was not worth withdrawing funds, as he would suffer losses. According to
his predictions, the situation was to improve afer some time, thus he managed to dissuade him. In November 2019,
Efremtsev A. called and invited him to the office to renegotiate the contract and agreement. He explained this by the
fact that the company's system of work was changing. That the signing of a new contract is of a formal nature,
associated with the peculiarity of their activities in the territory of the Russian Federation. He travelled to the
company's office in the Nevskaya Ratusha BC, where they signed the new documents. Afer that, he received reports
from Efremtsev A. for several months. When the reports stopped coming to his mailbox, he contacted the office,
where it was explained to him that Efremtsev A. was no longer working. He again asked for a new financial adviser to
be assigned to him. Then he was assigned Dmitry Moskalyuk (8 - 921 - 858 - 16 - 13, 8 - 965 - 028 - 88 - 88). On
30.03.2021 he met with Moskalyuk D. and said that he wanted them to sell off his securities portfolio, that he wanted
to withdraw all his funds, to which Moskluk D. replied that it was problematic to withdraw the funds and that it was
necessary to wait for some time, as there was a queue for withdrawal of funds. He also said that if he had
acquaintances who wanted to invest in their products, they could be invited to the company and that this would help
speed up the process of withdrawing his funds. He also offered to renegotiate the contract with the legal entity under
their control, Logopark Raevskaya LLC (RIF Raevskaya), but he refused. Then Moskalyuk D. gave him a list of
documents necessary for withdrawal of funds. When he collected the above documents and dialled Moskalyuk D. to
make an appointment to hand them over to him, he stopped answering his calls. He was later contacted by a new
financial advisor, Kuznetsov Sergey (8 - 965 - 0794 - 11 - 11 - 11), who then helped him collect the remaining
documents and forwarded them to VL Consulting LLC for further withdrawal of funds. At that time the number of the
notice of asset realisation SPB2104016 was assigned, which they signed on 16.04.2021. I would like to mention that he
876
received confirmation from VL Consulting LLC that afer the sale of his portfolio, the final amount would be USD
30,371 (thirty thousand three hundred and seventy one). He requested that the said amount be sent to his foreign
currency account, however, the funds have not been received to date. Given the fact that the deadline for the return of
the money had expired, he had no doubt that he had fallen victim to fraudsters. To date, he has not been returned his
funds deposited to the address of the group of companies "QBF" in the amount of 30 000 (thirty thousand) US dollars,
which at the exchange rate of the Central Bank of Russia as of 15.09.2017 is 1 733 118 rubles. He believes that an
offence has been committed against him, namely the thef of his funds by deception and breach of trust. The amount
of damage caused to him estimates for himself as significant, namely 30 000 (thirty thousand) US dollars, which at the
exchange rate of the Central Bank of Russia as of 15.09.2017 is 1 733 118 rubles. He believes that the persons acting on
behalf of the group of companies "QBF" initially did not intend to fulfil their obligations to him and acted solely for the
purpose of stealing his money by deceiving him. In the period from 15.09.2017 to 04.10.2017, the persons acting on
behalf of the "QBF" group of companies stole money belonging to him in the total amount of 1,733,118 rubles. I
estimate the amount of damage caused to him as significant. He has been explained the right to file a civil action in
the criminal case. He wishes to exercise this right and file a lawsuit. He has been explained the right to familiarise
examinations, with the conclusions of experts, with the records of expert interrogations and with the materials of the
criminal case;
(Vol. No. 23, pp. 40 - 43, 138 - 141)
- other documents - documents provided by D.V. Gumenyuk confirming his relationship with QBF Financial Group
(Vol. No. 23, pp. 47 - 130)
part 4 of article 159 of the Criminal Code of the Russian Federation against Kholodkov S.V.:
- another document - a statement by Kholodkov S.V., in which he asks to bring to criminal responsibility persons from
(Vol. No. 23, l.d. 155)
- Testimony of Kholodkov S.V. given by him as a witness and victim,

according to which he was a client of JSC "Bank Rossiya" in 2017. At that time, he got acquainted with the manager of
this bank Ilya Shakhov (tel. 8 - 965 - 109 - 03 - 99). Later, Ilya Shakhov resigned from JSC "Bank Rossiya" and was
employed as a financial manager at QBF Group. In early September 2017, Ilya Shakhov contacted him with a proposal
for cooperation, in particular investment in securities of stock markets of foreign countries. He agreed to think about
it and took a pause for reflection. Later, Shakhov Ilya contacted him again and they agreed to meet. During the
meeting Ilya Shakhov very colourfully and convincingly told him about investment products available in the
organisation "QBF", ways of investment, mechanisms of profit formation, the order of reporting and informing the
client, as well as in general about the structure of the organisation. He was informed that the funds will be invested in
investment platforms of foreign countries. Everything was presented in a colourful form, devoid of flaws, Shakhov Ilya
promised him high returns. At the end of all this presentation he informed Shakhov Ilya that he was ready to invest in
"QBF" group of companies. They agreed to meet at the main office of the company. So, on 11.10.2017 he arrived at the
office located at: Moscow, Presnenskaya Naberezhnaya, 8, pp. 1, 9th floor. Upon arrival, he was met by Ilya Shakhov
and escorted to a meeting room. Ilya Shakhov had already signed copies of documents in his hands, namely:
877
between him and the company "QCCI LTD" represented by Yudin Maxim Stanislavovich dated 11.10.2017 and the
agreement on provision of "Trust Management" services in accordance with the agreement on provision of services,
direct access to international stock markets No. 3663 - 17/IMR dated 11.10.2017 (Account 003663) between him and
the company QCCI LTD represented by Yudin Maxim Stanislavovich Yudin. I signed the above documents. Afer signing
these documents in the presence of Ilya Shakhov, he handed over the cash available to him at that time in the amount
of 2,600,000 roubles. In return, he received a receipt for a cash receipt order b/n dated 11.10.2017 for the deposit of
cash in the amount of RUB 2,600,000 under contract No. 3663 - 17/IMR dated 11.10.2017. The receipt bore the
signature of the chief accountant Gorobets E.V. and the seal impression of "QB Capital CY LTD", this receipt was dated
11 October 2017. During the two years prior to signing the withdrawal application, he received monthly reports on the
status of his brokerage account. The last report was in the amount of $53,355.16. In early 2019, he received a call from
Ilya Shakhov informing him that he had resigned. When asked about withdrawing money, he explained that it was
unfavourable to withdraw money at the moment, that there would be a tangible loss, it should be done later, closer to
the end of the year. Having called in advance, on 11.10.2019 he came to the office of the company "QBF" ("QBF") at
the address: Moscow, Presnenskaya naberezhnaya, 8, p. 1, 9th floor and announced his desire to withdraw the money.
He was introduced to a new financial adviser, Elena Iosifova (tel. 8 - 963 - 055 - 59 - 32; 8 - 967 - 047 - 17 - 96). She
explained to him that in order to withdraw the money at the moment, a number of contracts and agreements had to
be signed, some of them back - dated. This raised questions for him. He called Ilya Shakhov and asked for
clarification. He (Shakhov) explained that there were a number of technical problems and convinced him that he
needed to sign documents to withdraw the money. So he signed an agreement with the Company "Simtelligence" Ltd
(Hong Kong) for the provision of services № 3663 which was dated 04 June 2018. The signatory of this agreement was
Dmitry Anatolievich Korshunov. At the same time, he signed the determination on cancellation of the agreement on
provision of services of direct access to international stock markets No. 3663 - 17/IMR dated 11.10.2017 with the
company "QCCI LTD" (Cyprus). The signatory of this agreement was Gorobets E.V. On the same day he signed the
definition on cancellation of the agreement on provision of "Trust Management" services between him and the
company "QBCI LTD" dated 11.10.2019, the signatory of which was Buryakovsky Dmitry Henrikhovich and the
definition on cancellation of the agreement on provision of services No. 3663 dated 04.06.2018 between him and the
limited liability company "Simtelligence" dated 11.10.2019. Iosifova Elena explained that in order to start the
withdrawal procedure, it is necessary to submit a notarised copy of his foreign passport, details of the account in
currency in sberbank, a bank loyalty certificate in English, and a certificate of no criminal record. Afer collecting all
these documents according to the sample application form sent to him, he emailed support@wl - mnt.com and sent
to [email protected] an executed application for withdrawal of funds in the amount of USD 53,355.16 (according
to the last report received). The application was accompanied by copies of all the documents he had collected. On
06.12.2019, Elena Iosifova confirmed receipt of the full set of documents required to withdraw his funds and transfer
them to his current account. However, afer the agreed time period (two and a half months) he did not receive the
promised funds. Regularly communicating on the phone, he heard various excuses that we are doing our best, but
now there is a pandemic crisis, etc. In May 2020 he received a call from Andrei Korzh (tel. 8 965 - 411 - 72 - 25), who
introduced himself as the head of the department where Elena Iosifova used to work. He informed him that she had
resigned and further communication should now be made with him. However, he did not hear any specific dates on
when he would receive the money. Regularly there were all sorts of excuses that they were doing everything possible
and impossible in the process of communication. Having called once again in January 2021, Andrey Korzh invited him
to his office located at: Moscow, Presnenskaya Naberezhnaya, 8, str. 1, 9th floor. At the meeting he introduced him to
another financial adviser, Olga Bataeva (tel. 8 - 964 - 530 - 33 - 56). She informed him that they would be able to return
his money to him only in 2022 if he signed the documents on transferring his cash assets to the warehouse - related
ZPIF. Realising that he had long been implicated in QBF's fraudulent schemes, he refused to do so, demanding that his
cash assets be returned to him. At the end of May 2021, he learned from the media and official publications of the
Russian Ministry of Internal Affairs that criminal proceedings had been initiated and key employees of the QBF group
of companies had been arrested for fraud. To date, his funds have not been returned to him. The actions of the
employees of QBF companies caused him damage in the amount of 2,600,000 roubles. Claims will be brought for the
amount of damage caused to him. He believes that an offence has been committed against him, namely the thef of
his money by deceit and abuse of trust. He considers the amount of damage caused to him to be significant;
878
(Vol. No. 23, pp. 158 - 162, 167 - 171)
- other documents - documents provided by Kholodkov S.V. confirming his relationship with QBF Financial Group
(Vol. No. 23, pp. 172 - 210)
part 4 of article 159 of the Criminal Code of the Russian Federation against Grigoriev A.B.:
- another document - a statement by Grigoriev A.B., in which he asks to bring to criminal responsibility persons from
(Vol. No. 24, l.d. 7)
- Testimony of Grigoriev A.B., given by him as a witness and victim

, according to which in August 2015 he received a call on his mobile number 8 - 916 - 608 - 73 - 50 from a man who
introduced himself as a financial advisor of QBF group of companies, he cannot explain more precise data. The
aforementioned man voiced a number of proposals to invest money by investing in securities. In September 2015, he
came to the office of QBF Group at 8 Presnenskaya Naberezhnaya St., bld. 1, Moscow, where he took part in a
conversation. 1, where he took part in a conversation with QBF employees. This conversation was an advertising
campaign of the QBF group of companies. At this conversation he was approached by a man who introduced himself
as Nikolay Padalko, he voiced a number of proposals to invest money by investing in securities. Nikolay Padalko was
persuasive and persistent, so he agreed to participate in investing in securities on the Russian and international
financial markets. At this conversation he was given printouts of advertising offers. Later on, Nikolay Padalko also
conducted all consultations on financial products with him. On 09.10.2015 he, being in the office of Qubey Finance
LLC, located at the following address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, with the purpose of investing
funds. 1, with the purpose of investing funds in securities with high yield, he signed an agreement on provision of
services of direct access to international stock markets No. 2348 - 15/IMR, dated 08.10.2015 with QB Capital CY LTD
(QB Capital CY LTD), and also signed an agreement on provision of "Trust management" services in accordance with
the agreement on provision of services of direct access to international stock markets No. 2348 - 15/IMR dated
08.10.2015 with QB Finance LLC. Afer that, being in the office of QBIF LLC located at the address: Moscow,
Presnenskaya Naberezhnaya, 8, bld. 1, he transferred cash as follows: on 09.10.2015 in the amount of RUB 1,640,000
and USD 20,000, which at the exchange rate of the Central Bank of the Russian Federation as of 09.10.2015 was RUB
1,245,800; on 22.03.2016 in the amount of USD 30,000, which at the exchange rate of the Central Bank of the Russian
Federation as of 22.03.2016 was RUB 2,064,300; on 26.09.2016 in the amount of USD 15,000, which at the exchange
rate of the Central Bank of the Russian Federation as of 26.09.2016 was RUB 957,900. Also on 08.07.2016 he, being in
the office of LLC IK QBF, located at the address: Moscow, Presnenskaya Naberezhnaya, 8, pg. 1, also with the purpose
of investing funds in securities with high yield, he signed an agreement with the company "QB Capital CY LTD" ("QB
Capital CY LTD") on rendering services of direct access to international stock markets No. 2709 - 16/IMR, dated
05.07.2016, as well as concluded an agreement on rendering services of "Consulting Management" within the
framework of the agreement on rendering services of direct access to international stock markets No. 2709 - 16/IMR
dated 05.07.2016. Afer that, being in the office of IK QBF LLC located at the following address: Moscow, Presnenskaya
Naberezhnaya, 8, bld. 1, he transferred cash as follows: 08.07.2016 in the amount of USD 17,000, which at the
exchange rate of the Central Bank of the Russian Federation as of 08.07.2016 was RUB 1,088,850; 16.10.2017 in the
RUB 1,498,120. Clarifies that during the interrogation as a witness he was informed that on 11.07.2016 he contributed
879
USD 30,000 to the QBF group of companies in accordance with the concluded contracts. In reality, he mixed up the
dates, and this amount he deposited not on 11.07.2016, but on 22.03.2016 under the agreement on provision of
services of direct access to international stock markets No. 2348 - 15/IMR dated 08.10.2015, which is confirmed by the
receipt to the cash receipt order. Throughout his communication with Nikolay Padalko explained that his funds were
in safe hands, and repeatedly offered him various products for investment. Every month he received monthly reports
on trading on his account to his e - mail address, and based on the data sent to him, the amount of his investment
grew. In addition, part of the money he invested under the above agreements, according to his order, was transferred
for the purchase of units of the Gribovsky les ZPIF. However, as he now realises, the reports sent to his email were
falsified and did not correspond to reality. QBF employees did not provide him with any information (evidence) that
any securities, including units of the ZPIF, had been purchased in his name, nor did they provide him with the
securities themselves and documents on their purchase. The existence of ZPIF units was only on paper, in reports,
and since they did not correspond to reality, he realised that he had been deceived. In March 2020 he heard from the
mass media (official website of the Ministry of Internal Affairs of the Russian Federation) that a criminal case had been
opened against the founders of QBEF and that QBEF clients had been unable to withdraw their invested funds for a
long time under similar contracts and agreements. Taking into account the abovementioned, as well as the fact that
up to now his money has not been returned to him, he considers that an offence has been committed against him,
namely thef of money by deceit and abuse of trust. In total, he transferred money to the address of the group of
companies "QBF" in the amount of 8 494 970 rubles in the period from 09.10.2015 to 16.10.2017. There were no
refunds to his address. He believes that the actions of the employees of "QBF" caused him material damage in the
amount of 8,494,970 rubles, the amount of damage caused is estimated as significant;
(Vol. No. 24, pp. 10 - 13, 26 - 29)
- other documents - documents provided by Grigoriev A.B. confirming his relationship with QBF Financial Group (QBF
(Vol. No. 24, pp. 30 - 220)
part 4 of article 159 of the Criminal Code of the Russian Federation against Nikitchenko N.V.:
- another document - a statement by Nikitchenko N.V., in which he asks to bring to criminal responsibility persons
from among the employees, managers of the financial group "QBF" (LLC "Investment Company QBF"), who stole his
(Vol. No. 25, l.d. 7)
- Testimony of Nikitchenko N.V., given by him as a witness and victim,

according to which, around the summer of 2017, he received information about the group of companies "QBF" from
his acquaintance named Alexander, his surname is difficult to give, the phone number is not saved. According to
Alexander, he himself was a client and had experience of successful co - operation with "QBF". He had personal
savings and an interest to multiply his capital. He was interested in the received information and started to make
enquiries for himself in the Internet. Afer he checked the available information, he decided to contact the employees
of "QBF" for clarification, for which he called the general number and arranged a meeting with the manager at the
main office of the company. Who exactly he spoke to he does not remember. On 18.09.2017, at about 12:00, he arrived
at the office of the company "QBF", located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p.1, 9th floor. He
was met at the entrance by a manager named Korzh Andrey, and it was with him that he communicated as his
financial advisor until the beginning of 2020. In the office Korzh Andrey took him to the meeting room, where he was
presented with the investment products available in the organisation, investment methods, profit generation
880
mechanism, the procedure of reporting and informing the client, as well as the structure of the organisation in
general. He was informed that the funds will be invested in the investment platforms of foreign countries, and for this
reason the funds are required in currency. Everything was presented in a colourful way, devoid of flaws. He was
promised a high return on invested funds. Also Korzh Andrey presented him various investment strategies available in
the group of companies "QBF", where for each of them special conditions were modelled, up to the minimum
threshold of the amount of entry into the investment portfolio. Following the results of the meeting he finally got the
impression that these people can be trusted with his assets, and he gave his consent to invest money in the group of
companies "QBF", with the purpose of receiving income. Korzh Andrey had already prepared and signed documents
on the part of "QBF" group of companies, namely: agreement on rendering services of direct access to international
stock markets No. 3412 - 17/IMR dated 18.09.2017 between him and the company "QCCI LTD" represented by the
representative by power of attorney Yudin M.S., as well as the agreement on the provision of "Trust Management"
services with LLC IC "Qubief" (INN 7733673955) represented by the Director of Sales and Customer Service
Department Yudin M.S. He has never seen or communicated with Yudin M.S.. As a result of the meeting, the above
documents were signed on his part and it was agreed that he would come again within a few days with cash for its
contribution to the company "QCCI Ltd". On 21.09.2017, at approximately 13:00 hours, he again arrived at the office of
"QCCI Ltd" located at the address: Moscow, Presnenskaya Naberezhnaya, 8, pp. 1, 9th floor. He was also met by
Andrey Korzh and escorted to a meeting room. In the meeting room there was a machine for recounting money. On
this day 21.09.2017, he handed over to Korzh Andrei within the framework of the previously concluded agreement
and contract the funds, namely: USD 10,000, which at the exchange rate of the Central Bank of the Russian Federation
as of 21.09.2017 was RUB 581,300, as well as EUR 8,500, which at the exchange rate of the Central Bank of the Russian
Federation as of 21.09.2017 was RUB 593,045. Korzh Andrey counted the money brought by him and lef the meeting
room with it. In return, he brought him two receipts to the cash receipt order for the amounts of: USD 10,000 and EUR
8,500. Everywhere in the receipts was the signature of the chief accountant Gorobets E.V. and the stamp of QCCI LTD,
these receipts were dated 21 September 2017, under the contract No. 3412 - 17/ IMR dated 18.09.2017. On 27.10.2017
at approximately 13.00 hours, he again arrived at the office of the company "QBF", located at the address: Moscow,
Presnenskaya Naberezhnaya, 8, pp. 1, 9th floor. He was also met by Andrey Korzh and escorted to a meeting room
with a money changer inside. In the negotiation room, he handed over to Korzh Andrey another sum of USD 5,000,
which at the exchange rate of the Central Bank of the Russian Federation as of 27.10.2017 was 288,850 rubles, as part
of the previously concluded agreement and contract. Korzh Andrey counted the money brought by him and lef the
meeting room with it. In return, he brought him a receipt for a cash receipt order in the amount of USD 5,000. The
receipt had the signature of the chief accountant Gorobets E.V. and the stamp of QCCI LTD, this receipt was dated 27
October 2017, under the contract No. 3412 - 17/ IMR dated 18.09.2017. He would like to inform that he has never seen
or communicated with E.V. Gorobets in his life. Afer he invested funds in the group of companies "QBF", he started
receiving reports to his e - mail address [email protected], which were received by him until May 2020. Said reports
reflected the state of his investment portfolio. Around the beginning of June 2018, he received a call on his mobile
phone number from Korzh Andrey, who informed him about the need to come to the office of the company "QBF" in
order to re - sign the documents regarding the investment strategy. He agreed and on 04.06.2018 arrived at the office
of the company "QBF" located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p.1, 9th floor. He was met by
Korzh Andrey, escorted to the meeting room and provided documents for signature, namely: service agreement No.
3412 dated 04.06.2018 between him and "Simtelligence Company Limited" represented by Korshunov D.A. He
immediately signed this agreement. According to the words of Korzh Andrey, signing of these documents is a
technical necessity and is caused by some change of financial strategy of "QBF" group of companies, which will not
affect the state of his invested money in any way. Later, about a year later, Korzh Andrey contacted him again and
asked him to come to the office of the company "QBF" for another re - signing of documents related to the change of
investment strategy. He agreed and on 05.09.2019 arrived at QBF's office located at: Moscow, Presnenskaya
Naberezhnaya, 8, str. 1, 9th floor. He was met by Korzh Andrey and escorted to a meeting room. Korzh Andrey
provided him with documents to sign, namely: the "Trust Management" agreement No. D - 499879 - I dated 05.09.2019
between him and the company "White Lake Management Ltd" represented by Korshunov D.A., as well as the service
agreement (standard form of accession agreement) between him and the company "VL Consulting" LLC dated
05.09.2019. According to Korzh Andrey, signing of these documents is a technical necessity and is conditioned by
881
some change of financial strategy of the group of companies "QBF", which will not affect the state of his invested
funds in any way. He agreed to sign the agreement with "White Lake Management Ltd" and signed it on the same day.
However, he did not sign the contract with VL Consulting Ltd. The reason for his reluctance to do so he does not
remember, but something made him very uncomfortable. In March 2020, for personal reasons he had a need for a full
withdrawal of funds, in connection with which he tried, contacted his financial advisor Korzh Andrey, but failed.
Through general telephone conversations he learnt that Korzh Andrei had allegedly transferred to another
department of the company and a new financial advisor would be introduced to him. Some time later he was
contacted by a certain Danilenko Maxim, his new financial advisor. He asked him to withdraw the funds and informed
him that he was going to withdraw the funds. Danilenko replied that according to the regulations he had to notify the
company in writing. In connection with the above, on 02.03.2020, approximately at 12:00 a.m., in the office of the
company "QBF" located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, 9th floor, he wrote to
Danilenko. 1, 9th floor, he wrote a notice of withdrawal, a copy of which he also has. Afer submitting the notice of
withdrawal, Danilenko Maxim informed him that the withdrawal would take from several months to a year, that it was
due to the closure of the international direction of work in the group of companies "QBF", there was a queue for the
payment of funds and he would have to wait. Also Danilenko Maxim offered him to convert the debt to him in the face
of the group of companies into the rouble equivalent in the financial product ZPIF. However, this offer further alarmed
him and he refused. Maksim Danilenko also informed him that he had to collect a large list of documents for
withdrawal of funds, which included very strange items, such as translation of passport into English, certificate of no
criminal record, etc. As a result of the documents submitted by him for withdrawal of funds, the following funds were
returned to him: 13.10.2020 in the amount of USD 4,000, which at the rate of the Central Bank of the Russian
Federation was 308,095.6 rubles, 23.12.2020 in the amount of USD 3,000, which at the rate of the Central Bank of the
Russian Federation was 226,049.4 rubles, 08.04.2021 in the amount of USD 2,000, which at the rate of the Central Bank
of the Russian Federation as of 08.04.2021 was 155,546 rubles. Total amount of USD 9,000, which amounted to RUB
689,691. Later, at the end of May - beginning of June 2021, he learned from the media, including official news of the
Ministry of Internal Affairs of Russia, that criminal cases had been opened and investigations were underway
regarding the fraudulent actions of QBF with respect to the clients who had invested their money. Thus he had no
doubts that he had become a victim of fraudsters. Until now his money has not been returned to him in full. In total,
he transferred funds in the amount of 1,463,195 rubles to the "QBF" group of companies in the period from 21.09. to
27.10.2017. Until now, the full amount of the money he invested in the group of companies "QBF" has not been
returned to him. Claims will be brought for the amount of damage caused to him. Considers that an offence has been
committed against him, namely thef of his money by deceit and abuse of trust. He considers the amount of damage
(Vol. No. 25, pp. 10 - 14, 25 - 30)
- other documents - documents provided by Nikitchenko N.V. confirming his relationship with QBF Financial Group
(Vol. No. 25, pp. 31 - 115)
part 4 of article 159 of the Criminal Code of the Russian Federation against Zinovv S.D.:
- another document - a statement by S.D. Zinoviev, in which he asks to bring to criminal responsibility persons from
(Vol. No. 25, l.d. 127)
882
- Testimony of S.D. Zinoviev, given by him as a witness and victim
, according to which in October 2017, he had free cash, and he was looking for additional income by investing his
money. Thus, in October 2017, his acquaintance Galina Baranova advised him to invest his money in the group of
companies "QBF". Making enquiries on the Internet, he saw information that LLC IC "QBF" (INN 7733673955) has 4
licences of the Central Bank of Russia, namely: licence for brokerage activities № 045 - 12805 - 100000 dated
24.12.2009, licence for dealer activity No. 045 - 12816010000 dated 24.12.2009, licence for securities management No.
045 - 12828 - 001000 dated 24.12.2009 and licence for depository activity No. 045 - 14078 - 000100 dated 08.08.2019.
Having studied all the information available on the Internet, around the beginning of June 2017, he called the
manager's phone number, which was given to him by his acquaintance Galina Baranova (tel. 8 - 985 - 250 - 21 - 04).
Having called this number, he spoke to the manager of the organisation, who introduced himself as Anton Shkrut,
who voiced a number of offers to invest money by investing in securities. In the conversation Anton Shkrut was
persuasive and persistent, so he agreed to take part in investing in securities on international financial markets. On
04.06.2017, from the email [email protected] he sent him a set of documents for review and information about
available products to his email [email protected]. Having familiarised himself with the provided documents,
he came to the office of the company. He arrived at the office of QBF Group at 8 Presnenskaya Naberezhnaya St., bldg.
1, Moscow, around August 2017. 1, approximately in August 2017, where he met personally with Anton Shkrut, who
continued to convince him of the reliability of investing. He visited the organisation again at the end of September
2017, where they discussed the details of the contract and agreed on the amount of money to be deposited. On
21.11.2017 he, being in the office of LLC "IC QBF", located at the address: Moscow, Presnenskaya Naberezhnaya, 8,
bld. 1, in order to invest cash in securities with high yield, I signed agreements with "QCCI LTD" company on providing
services of direct access to international stock markets No. 4198 - 18/IMR dated 21.11.2017, and I also signed an
assignment agreement No. 4198, dated 23 January 2018, with "QCBIF Advisor" LLC. On 21.11.2017, he handed over
cash in the amount of USD 30,000, which at the exchange rate of the Central Bank of the Russian Federation as of
21.11.2017 amounted to RUB 1,778,100. In fact, he concluded all documents and transferred cash on 21.11.2017,
however, the manager Anton Shkrut, asked him to sign a number of documents dated 23 January 2018, due to the
specifics of the end of the year, a specific explanation as to why he (Shkrut) asked to do this, he currently does not
remember. All documents were concluded between him and the signatory from the side of "QBF" Frolov Vladimirov
Georgievich. From 21.11.2017, he received monthly reports on the status of the client's accounts on securities
transactions and transactions related to them, as well as on futures transactions and transactions related to them, to
his email. Around January 2020, Anton Shkrut, the manager of QBF, informed him that he was planning to resign from
the organisation and in February 2020, he resigned permanently. Further, he was unable to reach the organisation for
some time and in approximately February 2020 he contacted Vladimir Maslennikov (tel. 8 - 964 - 530 - 32 - 16), who
introduced himself as the head of the department, to whom he informed that he wanted to issue an order to
withdraw the full amount of funds. Afer that he (Maslennikov) informed him that further his manager would be Artur
Hovhannisyan, whom he contacted by phone (8 - 964 - 530 - 33 - 27). On 28.02.2020 he sent a notarised notice of
termination of the contract by post, but it was not until around May that he was able to get Artur Hovhannisyan to
stamp the copy of the notice with a notarised receipt of my notice, but the contract was never terminated. During the
period from May 2020 to September 2020 they repeatedly called Artur Hovhannisyan and he persistently convinced
him that there was no need to withdraw the funds and the interest on the deposits would be paid later. On 14.09.2020,
at Artur Hovhannisyan's request, he came to the office of the organisation and concluded the Trust Management
Agreement No. D - 763143 - I dated 14.09.2020 between him and the group of companies "White Lake Management
LTD" with D.A. Korshunov as a signatory. Artur Hovhannisyan explained the necessity of signing the agreement by
moving the organisation of the top broker from the Cayman Islands to Hong Kong and afer signing this agreement
the payment of funds will start. He took these documents and came again on 03.12.2020 to the office of the
organisation where he signed the "Trust Management" agreement No. D - 763143 - I dated 03.12.2020, the
authorisation notice dated 03.12.2020, the application on joining and the investment declaration dated 03.12.2020.
Despite repeated demands for payment of funds, no payment was made. On 29.01.2020 he was contacted by Trutnev
Alexander and sent him a number of necessary documents that were needed to sign an agreement with "White Lake
Management LTD" for the strategy "Golden Express". In May 2021, he learnt from the media, as well as official
883
publications of the Ministry of Internal Affairs of Russia, that key employees of the QBF group of companies had been
detained for alleged fraud, and the Central Bank of the Russian Federation had initiated an audit of QBF LLC. He also
wants to draw attention to the fact that in June 2021 on the company's website, on behalf of the General Director of
LLC IC QBF Matyukhin S.A. was posted information that there is no connection between the detention of the
company's employees and the current brokerage activities, that all the activities carried out by law enforcement
officers are related to another division of the company and that this issue will not affect us in any way. According to his
assumptions, the funds invested by him were not used for their intended purpose, but were used for withdrawal to
offshore companies, as well as used to buy shares in construction funds. The reports sent did not correspond to reality
in any way, it can be said that the reports were drawn. In September 2021 on the website of LLC "IK Qubief" appeared
information about the temporary administration, their task was supposedly to sort out the situation and help clients
to return their invested funds. In fact, there are no actions on the part of the temporary administration, on the
contrary, they discourage people to apply to law enforcement authorities with applications. Out of all the money he
deposited in the address of LLC "IC "Qubief" in the amount of 1,778,100 rubles nothing has been returned to him. No
securities in his name have been registered in depositaries, and no documents confirming the purchase of securities
have been issued. His demand to return the funds belonging to him has not been fulfilled. On 21.11.2017, he
transferred to the QBF Group of Companies the funds belonging to him in the amount of RUB 1,778,100. He assesses
the amount of damage caused as significant.
Thus, he believes that an offence, namely fraud, has been committed against him. The amount of damage caused to
him as of the current date is 1,778,100 roubles;
(Vol. No. 25, pp. 130 - 134, 217 - 220)
- other documents - documents provided by S.D. Zinoviev confirming his relationship with QBF Financial Group (QBF
(Vol. No. 25, pp. 135 - 208, 221)
part 4 of article 159 of the Criminal Code of the Russian Federation against Lomov S.N.:
- another document - a statement by Lomov S.N., in which he asks to bring to criminal responsibility persons from
(Vol. No. 26, l.d. 8)
- S.N. Lomov's Testimony

as a witness and victim, according to which he knows Daria Meshkova, who previously worked as a manager for
servicing privileged clients, including him, at Raiffeisenbank. In November 2016, D. Meshkova invited him with an
investment opportunity to an introductory meeting with Ruslan Spinka at the following address: 8 Presnenskaya
Naberezhnaya Street, Moscow, bldg. 1, 9th floor. He arrived at the meeting on 12.12.2016 at approximately 12:00. At
the meeting Ruslan Spinka described in detail the advantages of co - operation with IK QBF LLC and guaranteed full
reliability. He claimed that QBIF LLC complied with all the laws of the Russian Federation, had all the necessary
licences, and that his (Lomov's) money would be returned at his first request. Since it was about investing in US
dollars, he recommended signing a contract with a foreign legal entity that would be able to buy and sell securities of
foreign companies. He also promised that he (Lomov) would receive monthly reports and his money would be
invested in reliable securities with high ratings. Having trusted Ruslan Spinka, he signed on 12.12.2016: an agreement
for the provision of direct access services to international stock markets No. 2965 - 16/IMR dated 12.12.16 between
him and the Cyprus company "QB Capital CY LTD". The signatory was Yudin Maxim Stanislavovich, the agreement on
provision of "Trust Management" services in accordance with the agreement on provision of services of direct access
to international stock markets No. 2965 - 16/IMR dated 12.12.2016 (Account 002965) between him and the company
884
QB Capital CY LTD. The signatory was Yudin Maxim Stanislavovich. The essence of the contract and agreement, as
Ruslan Spinka explained to him, is as follows: he transfers funds to the Cyprus company, which, on behalf of IK QBF
LLC, performs transactions with securities. Afer signing the contracts, he was to deposit the cash. As a result, he
visited the office of the QBF Group of Companies at 8 Presnenskaya Naberezhnaya Embankment, bld. 1, Capital City
Tower, 9th floor, seven times, each time handing over cash to employees of QBF IK LLC within the framework of
concluded agreements and contracts. Thus, on 13.12.2016, he handed over USD 10,000, which at the exchange rate of
the Central Bank of the Russian Federation as of 13.12.2016 amounted to RUB 615,800. Meshkova Daria and Spinka
Ruslan were present at the meeting. In return, they handed him a receipt for a cash receipt order in the amount of:
USD 10,000.00. In the receipt was the signature of the chief accountant Gorobets E.V. and the stamp of "QB Capital CY
LTD", this receipt was dated 13 December 2016, under the contract № 2965 - 16/ IMR from 12.12.2016. On 27.12.2016
he handed over USD 10,000, which at the exchange rate of the Central Bank of the Russian Federation as of 27.12.2016
amounted to 609,100 rubles. Only Meshkova Daria was present at the meeting. In return, he was given a receipt to the
cash receipt order for the amount of USD 10,000.00. In the receipt was the signature of the chief accountant Gorobets
E.V. and the seal impression "QB Capital CY LTD", this receipt was dated 27 December 2016, under the contract № 2965
- 16/ IMR from 12.12.2016,. 03.02.2017 transferred 10,000 USD, which at the exchange rate of the Central Bank of the
Russian Federation on 03.02.2017 was 599,900 rubles. Meshkova Daria and Spinka Ruslan were present at the
meeting. In return, they handed him a receipt for a cash receipt order in the amount of USD 10,000.00. The receipt had
the signature of the chief accountant Gorobets E.V. and the stamp of "QB Capital CY LTD", this receipt was dated 03
February 2017, under the contract No. 2965 - 16/ IMR dated 12.12.2016. On 10.03.2017 he handed over USD 10,000,
which at the exchange rate of the Central Bank of the Russian Federation as of 10.03.2017 amounted to RUB 588,318.
Meshkova Daria and Spinka Ruslan were present at the meeting. In return, they handed him a receipt for a cash
receipt order in the amount of USD 10,000.00, the receipt had the signature of the chief accountant Gorobets E.V. and
the stamp of "QB Capital CY LTD", this receipt was dated 10 March 2017, under the contract No. 2965 - 16 IMR dated
12.12.2016. On 11.04.2017 he handed over USD 10,000, which at the exchange rate of the Central Bank of the Russian
Federation as of 11.04.2017 was 573,900 rubles. Meshkova Daria was present at the meeting. In return, he was given a
receipt to the cash receipt order for the amount of: USD 10,000.00. In the receipt was the signature of the chief
accountant Gorobets E.V. and the seal impression "QB Capital CY LTD", this receipt was dated 11 April 2017, under the
contract № 2965 - 16/ IMR from 12.12.2016. On 29.05.2017 he handed over USD 9,000, which at the exchange rate of
the Central Bank of the Russian Federation as of 29.05.2017 amounted to 510,840 rubles. Vladimir Maslennikov was
present at the meeting. In return, he was given a receipt to the cash receipt order for the amount of: USD 9,000.00. In
the receipt was the signature of the chief accountant Gorobets E.V. and the seal impression "QB Capital CY LTD", this
receipt was dated 29 May 2017, under the contract № 2965 - 16/ IMR from 12.12.2016. On 20.06.2017 he handed over
USD 1,900, which at the exchange rate of the Central Bank of the Russian Federation was 110,124 rubles. Meshkova
Daria was present at the meeting. In return, he was given a receipt to the cash receipt order in the amount of: USD
1,900, 00. The receipt had the signature of the chief accountant Gorobets E.V. and the stamp of "QB Capital CY LTD",
this receipt was dated 20 June 2017, under the contract No. 2965 - 16/ IMR dated 12.12.2016. On 2.12.2017, he
transferred non - cash funds in the amount of USD 95,000 from his foreign currency settlement account No.
40817840040000131156 opened with PJSC Promsvyazbank, branch located at 21 Dolgorukovskaya Street, page 1,
Moscow, to "QB Capital CY LTD" account No. 0127031002 opened with Alpen Baruch Bank Ltd, which amounted to
RUB 5,626,850 at the exchange rate of the Central Bank of the Russian Federation as of 12.12.2017. The requisites for
the above non - cash transfer were given to him by Ruslan Spinka. He and Spinka met every 3 months and Ruslan
Spinka showed him reports on the "Trust Management" of his funds and convinced him that the assets were
increasing in value and it was a great time to add funds. Afer 6 months Ruslan Spinka told him that it was urgent to
sign a new contract as the Cyprus Company might have problems and might not be able to carry out operations. To
his reluctance to sign a new contract, Ruslan Spinka claimed that there could be problems with the return of the
funds. For this reason, on 04.06.2018, being in the office of the company LLC "IC QBF" at the address: Moscow,
Presnenskaya naberezhnaya, 8, building 1, he was forced to sign a service agreement № 2965 dated 04.06.2018 with
the company "Simtelligence", the essence of this agreement is the transfer of rights and obligations under the
contract on access to the stock market and operations to the Hong Kong company "Simtelligence". The agreement
had already been signed by a representative of Simtelligence, D.A. Korshunov, whom he had never seen. At the same
885
time, he asked to return some of his money, as he began to suspect that he had become a victim of fraud. However,
Ruslan Spinka continued to stall, did not respond to calls and letters, but afer 8 months Vladimir Maslennikov gave
out part of the money: 07.03.2019 in the office of LLC IC QBF, located at the address Moscow, Presnenskaya
Naberezhnaya 8, bldg. 1, 9th floor, Maslennikov handed him USD 10,000 (ten thousand), which at the exchange rate of
the Central Bank of the Russian Federation as of 07.03.2019 amounted to RUB 658,430, in cash from dividends and
coupons on assets in which his money was invested. Nevertheless, he asked Ruslan Spinka to return all his money, to
which he replied that in order to return the funds, a new contract had to be signed, otherwise the money would not be
returned. Thus, he was forced to sign new documents. On 05.12.2019 he, being in the office of the company LLC "IC
QBF" at the address: Moscow, Presnenskaya naberezhnaya, 8, building 1, he signed the "Trust Management"
agreement with "White Lake Management Ltd" №D - 872742 - L dated 5.12.2019. The company is registered in the
Cayman Islands, but has a representative office at 8 Presnenskaya Embankment, building 1, Capital City Tower,
Moscow. Dmitry Anatolievich Korshunov is again a signatory. He also signed a service agreement (standard form of
accession) dated 05.12.2019 with VL Consulting LLC. In 2020, he tried to persuade the company LLC IK QBF
represented by Ruslan Spink to return his money, but heard only excuses and references to the Coronavirus. In the
autumn of 2020 Ruslan Spinka again assured him that as soon as he confirmed the origin of the money and provided
notarised documents, the money would be returned to him. It took him 2 months to prepare the required set of
documents and in November 2020 he provided them to Ruslan Spinka. In addition, in December 2020, he sent
another application for the sale of all securities that Ruslan Spinka had assured him were included in his assets and
asked for his money to be returned to him. Afer that, it became clear to him that the company QBIF LLC represented
by Ruslan Spink was just stalling using various pretexts and was not going to give him his money. To date, the QBIF
company represented by its employees refuses to return his money, does not answer letters, does not answer calls
and does not do anything to return his money. He is sure that R.V. Spinka, D.A. Korshunov, S.A. Matyukhin and the
shareholders of the company from the very beginning pursued the goal of embezzling his money. By deceit and
threats they forced him to hand over the funds and then refused to give them back. They did nothing to give him the
money and simply delayed the time. He was not provided with any information and supporting documents that
securities, shares, bonds, units had been purchased in his name. There were no other refunds to him. Later, in the
middle of 2021, I learnt from the media, including official news of the Russian Ministry of Internal Affairs, that criminal
proceedings had been initiated and an investigation was underway. Taking into account the specifics of
communication with managers, problems in withdrawing funds, and also taking into account the fact that the money
was not returned to him in full, he had no doubts that he was a victim of fraudsters. To date, his money has not been
returned to him in full. In total, he transferred 9,234,832 roubles to the QBF group of companies. The company has
returned to him 658,430 roubles. Claims will be brought for the amount of damage caused to him. He believes that an
offence has been committed against him, namely the thef of his money by deceit and breach of trust. He considers
the amount of damage caused to him as significant;
(Vol. No. 26, pp. 11 - 15, 30 - 35)
- other documents - documents provided by Lomov S.N. confirming his relationship with QBF Financial Group (QBF
(Vol. No. 26, pp. 36 - 86)
part 4 of article 159 of the Criminal Code of the Russian Federation against Nemtsev V.V.:
- another document - a statement by Nemtsev V.V., in which he asks to bring to criminal responsibility persons from
(Vol. No. 26, pp. 99, 105, 106 - 107, 207 - 208, 209 - 210)
886
- Testimony of V.V. Nemtsev, given by him as a witness and victim,
according to which in 2017 he learnt the company "QBF" from the Internet. At the same time he was contacted by the
employee of the company Frolova Evgenia. During the telephone conversation, Frolova E. told about the possibility of
additional income by investing available funds, both in foreign currency and in rubles, in the company "QBF" for
further financial transactions in the international market. Then he was interested in the proposal and they agreed to
meet in person. Having studied information about QBF in open sources, he found it attractive enough to try to work
with it. The availability of licences from the Central Bank of the Russian Federation was one of the key points that
determined for me the reliability of the company. The first meeting between Nemtsov V.V. and Frolova E. took place
outside the company's office in some café, where exactly he does not remember. At the meeting Frolova E. told about
the prospects of co - operation, told about the company itself and the options for investing money in order to receive
income. She showed colourful presentations, told him that the company had been on the market for many years, that
during this time it had shown itself well on the investment market, that with the help of the company "QBF" it was
possible to officially invest money in securities (shares) traded on the New York Stock Exchange. He was shown the
licences issued by the Federal Financial Markets Service. He was shown different strategies. Everything sounded very
convincing, so the offer then interested him, he took a pause to study everything carefully, think it over and make an
informed decision. At home he found and carefully checked the reviews about the company, as well as the data on the
website of the Central Bank of Russia, where the information was confirmed - the licences were valid, and the reviews
about the company were extremely positive. All this was a decisive factor in choosing the company and confirming its
reliability. The next meeting took place in the company's office. So, no later than 17.08.2017, being at the address: St.
Petersburg, Maloohtinsky pr., 64, Lit. B, in accordance with his chosen strategies, under the pretext of investing his
funds in securities with high yield, on behalf of a non - resident QB Capital CY LTD ("QB Capital CY LTD") concluded
with him the Agreement on rendering services of direct access to international stock markets No. 3356 - 17/ISR dated
17.08.08.2017, and on behalf of QBF IC Ltd. entered into the Trustee Services Agreement in accordance with the Direct
Access to International Stock Markets Services Agreement No. 3356 - 17/ISR dated 17.08.2017. During the period from
17.08.2017 to 14.12.2017, while being present at the office of QBF located at the above address, he handed over cash
to the employees of the company viz: 17.08.2017 in the amount of USD 100,000, which at the exchange rate of the
Central Bank of Russia as of 17.08.2017 amounted to RUB 5,965,210; 14.12.2017 in the amount of USD 10,000, which at
the exchange rate of the Central Bank of Russia as of 14.12.2017 amounted to RUB 591,446. Since September 2017, he
began to receive electronic reports on allegedly completed transactions with securities to his email address. He would
like to note that he managed to partially return the money he had invested. So on 15.03.2018 in the cash desk of the
office of the company "QBF", located at the address: St. Petersburg, Maloohtinsky pr., 64, lit. B, he received funds in
the amount of 2,200 US dollars, which at the rate of the Central Bank of the Russian Federation on 15.03.2018
amounted to 125,261.84 rubles, and on 04.12.2019 in the cash desk of the office of the company "QBF", located at the
new address: St. Petersburg, Degtyarny per, 11, Lit. "B", he received cash in the amount of USD 11,600, which at the
exchange rate of the Central Bank of the Russian Federation as of 04.12.2019 amounted to RUB 744,025.16. In
September 2019, QBF notified him about the change of broker in another jurisdiction and offered to re - sign all the
contracts for the change of broker and jurisdiction, without the possibility of choosing to stay with the previous
contracts. He was re - signed the new contracts: 1) Trust Management Agreement No. D - 021509 - J with White Lake
Management Ltd. registered in the Cayman Islands; 2) Service Agreement No. 3356 dated 04.06.2018 with
Simtelligence registered in Hong Kong; 3). Service Agreement with VL Consulting LLC, being a representative office in
Moscow No. 021509 - 09 dated 04.10.2019; 4) Determination on termination of the Agreement on provision of direct
access services to international stock markets No. 3356 - 17/ISR dated 17.08.2017. 5) Determination on termination of
the Agreement on provision of trust management services dated 17.08.2017 between QBF LLC and Vladimir
Vladimirovich Nemtsev. In the summer of 2021 he had a change of financial advisor, it became Moskalyuk Dmitry
Vladimirovich. He was the last person he had contact with. In response to his request to draw up documents for the
return of funds Moskalyuk D.V. refused, referring to the fact that the police officers in May took away all the servers of
the company and therefore it is impossible to withdraw funds. Since 06.07.2021 Dmitry Moskalyuk stopped answering
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phone calls and e - mail appeals regarding the return of his funds. On 23.06.2021 and again on 12.07.2021, in
accordance with the contract, he sent a message to the centralised e - mail of QBF company, with a request to sell the
portfolio and withdraw all his funds: according to the company's report for the month of May 2021 the amount was
112.859,15 $ (one hundred twelve thousand eight hundred and fify nine US dollars and 15 cents), also in the message
he asked to give him contacts of the company's employee in St. Petersburg, with whom he could interact on this issue.
To date, no one has contacted him. He has still not received any written response to his request for a refund. All the
contracts he signed stipulate that the money is refundable, i.e. the company undertakes to return the money within a
specified period of time. According to the trust management agreement with White Lake Management Ltd No. D -
021509 - J clause. 9 "Cancellation", the withdrawal of funds is carried out within 30 days afer receiving the notice. But
at the present moment, he knows from numerous reviews on the Internet on the website banki.ru. that QBF company
does not observe the terms and does not return the funds. In addition, in May 2021, in many business media (RBC,
Kommersant, etc.), and on various channels, including federal, there was information that QBF used fraudulent
schemes and worked as a pyramid scheme, and the shareholder of the company QBF Shpakov Roman Valeryevich
fled abroad. Taking into account the fact that the terms of returning his money expired, there was no doubt that he
became a victim of fraudsters. Up to the present time his money deposited to the address of the group of companies
"QBF" in the amount of 5 687 369 roubles has not been returned to him. He believes that the persons acting on behalf
of the group of companies "QBF" initially did not intend to fulfil their obligations to him and acted solely for the
purpose of stealing his money by deceiving him. In the period from 17.08.2017 to 14.12.2017, the persons acting on
behalf of the "QBF" group of companies stole his money in the total amount of 5,687,369 rubles. He considers the
amount of damage caused to him as significant. He has been explained the right to file a civil action in the criminal
case. He wishes to exercise this right and file a lawsuit.
He has been given the right to familiarise himself with the composition of the investigative teams, with the decisions
to order forensic examinations, with the conclusions of experts, with the transcripts of expert interrogations, and also
to familiarise himself with the materials of the criminal case in full or in part. He does not wish to exercise this right.
He did not apply to the court with applications for recovery of money from the "QBF" group of companies;
(Vol. No. 26, pp. 111 - 114, 218 - 222)
- other documents - documents provided by V.V. Nemtsev confirming his relationship with QBF Financial Group (QBF
(Vol. No. 26, pp. 125 - 206)
part 4 of article 159 of the Criminal Code of the Russian Federation against Novitsky A.G.:
- another document - a statement by A.G. Novitsky, in which he asks to bring to criminal responsibility persons from
(Vol. No. 27, pp. 8, 9)
- Testimony of A.G. Novitsky, given by him as a witness and victim,

according to which in November 2017, his mobile phone number received a call from an employee of the group of
companies "QBF" Bogdanov Kirill (tel. 8 - 921 - 858 - 16 - 28) with an offer of additional income by allegedly investing
in financial products of the group of companies "QBF". Bogdanov K. persuaded him to come to the office of "QBF"
group of companies to get additional information. When he arrived at the office of the group of companies "QBF" at
the address: St. Petersburg, Degtyarny per. 11 lit. B, room. 1 - H, BC "Nevskaya Ratusha", he was met by Bogdanov K.,
888
who began to persuade him in every possible way, persuade him to deposit money and mislead him about the legality
of their activities, about the possibility of high earnings from investments and so on. He believed the words of
Bogdanov K. and trusted him. 08.11.2017 being in the office of the group of companies "QBF" at the address: St.
Petersburg, Degtyarny per. 11 lit. B, pom.1 - .H with the purpose, as he believed at that time, of investing funds in
securities he concluded the Agreement on rendering services of direct access to international stock markets No. 4130 -
17/ISR dated 08.11.2017 with "QCCI LTD" ("QCCI LTD") and also entered into a Trustee Services Agreement with "QBIF
IK LLC" pursuant to the Direct Access to International Stock Markets Services Agreement No. 4130 - 17/ISR dated
08.11.2017. Trusting the employee of the group of companies "QBF" Bogdanov K. and being in a state of delusion
07.12.2017 being in the office of the group of companies "QBF" at the address: St. Petersburg, Degtyarny per. 11 lit. B,
room 1 - H, in the presence of Bogdanov K., he deposited in the cash desk of the group of companies "QBF" his own
funds in the amount of 30 000 USD, which at the exchange rate of the Central Bank of Russia as of 07.12.2017 was 1
767 843 rubles. Some employee of "QBF" group of companies took the money from him (he does not remember the
data of this employee). In order to mislead him and to make what was happening look like a legitimate activity, this
employee of the group of companies "QBF" gave him a receipt to the receipt order No. b/n dated 07 December 2017.
Trusting the employee of the group of companies "QBF" Bogdanov K. and being in a state of delusion on 14.12.2017 in
the office of the group of companies "QBF" at the address: St. Petersburg, Degtyarny per. 11 lit. B, room 1 - H, in the
presence of Bogdanov K., he deposited in the cash desk of the group of companies "QBF" his own money in the
amount of 20 000 USD, which at the exchange rate of the Central Bank of Russia on 14.12.2017 was 1 182 892 rubles.
Some employee of "QBF" group of companies took the money from him (he does not remember the data of this
employee). In order to mislead him and make what was happening look like a legitimate activity, the said employee of
the "QBF" group of companies gave him a receipt to the receipt order No. b/n dated 14 December 2017. Starting from
December 2017, he started receiving reports on the alleged purchase of securities to his email. In January 2019, he
approached Bogdanov K. about receiving his profits from the invested funds. Bogdanov K. told him that QBF Group
could pay him $2,700, which was allegedly the profit on the monies he had contributed. In order to convince him of
the legality and profitability, thereby misleading him Bogdanov K. gave him USD 2,700 in hand, which at the
maximum exchange rate of the Central Bank of the Russian Federation as of January 2019 was RUB 181,418.40. The
transfer of funds was in the office of the QBF Group of Companies at the address: St. Petersburg, Degtyarny per. 11 lit.
B, pom.1 - H. Around the end of 2020, he approached Bogdanov K. about a full refund of his money. Bogdanov K.
began to deceive him about the terms of return of the money, began to delay the terms and come up with various
reasons not to return the money. Afer that he began to demand from Bogdanov K. the return of his money on a
regular basis, but he (Bogdanov K.) continued to deceive him and mislead him in every possible way about the return
of his money. At that moment he realised that he had become a victim of fraudsters and was simply deceived to steal
his money. At that time, he saw information in the media that criminal cases had been opened and investigations
were underway against the employees and managers of the QBF group of companies. This confirmed his thoughts
that he was a victim of fraudsters. To date, he has not been returned his money deposited in the cash desk of the
"QBF" group of companies, as he then naively believed for investment, in the amount of 2,769,316.60 rubles. He
believes that the persons acting on behalf of the group of companies "QBF" initially did not intend to fulfil their
obligations to him and acted solely for the purpose of stealing his money by deceiving him. In the period from
07.12.2017 to 14.12.2017, the persons acting on behalf of the "QBF" group of companies stole his money in the total
amount of 2,769,316.60 rubles. He considers the amount of damage caused to him as significant. He has been
explained the right to file a civil action in the criminal case. He wishes to exercise this right and file a lawsuit. He has
the appointment of forensic examinations, with the conclusions of experts, with the records of expert interrogations,
and also to familiarise himself with the materials of the criminal case in full or in part. He does not wish to exercise
this right. He has not applied to the court with applications for the recovery of funds from the "QBF" group of
companies;
(Vol. No. 27, pp. 12 - 14, 64 - 67)
- other documents - documents provided by A.G. Novitsky confirming his relationship with QBF Financial Group (QBF
889
(Vol. No. 27, pp. 17 - 56)
part 4 of article 159 of the Criminal Code of the Russian Federation against Vavilova L.A.:
- another document - a statement by Vavilova L.A., in which she asks to bring to criminal responsibility persons from
(Vol. No. 27, l.d. 82)
- Vavilova L.A.'s testimony, given to her as a witness and victim,

according to which, around the summer of 2017, her daughter Vavilova Elena Borisovna, afer a sports training camp,
afer returning home, informed her that she met Padalko Nikol, and told her that he was a high - class specialist in
investments and an employee of the group of companies "QBF". Also her daughter informed her that she had checked
the information about the company "QBF". This company (QBF IK LLC) has licences from the Central Bank of Russia
necessary for brokerage and other activities with securities, the company has a good reputation. She had personal
savings and a desire to invest them for profit, but she herself had little understanding of brokerage activities. She
decided to invest her money in QBF Group. Her daughter called Padalko N. and arranged a meeting, explaining in
advance that they would come with the money. On 22.09.2017 at approximately 11:00 a.m., she and her daughter
arrived at the office of LLC "IK "QBF", located at the following address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1,
9th floor. 1, 9th floor. At the entrance they were met by Padalko N. and were taken to a meeting room where he
presented them with the investment products available in the organisation, investment methods, profit generation
mechanism, the procedure for reporting and informing the client, as well as the structure of the organisation in
general. They were informed that the money will be invested in investment sites of foreign countries, and for this
reason the money is required in currency. Everything was presented in a colourful way, devoid of flaws. They were
promised high returns. Also Padalko N. presented them different investment strategies available in the group of
companies "QBF", where for each of them special conditions were modelled, up to the minimum threshold of the
amount of entry into the investment portfolio. At the end of the meeting they finally got the impression that these
people can be trusted with their assets. She gave her consent to invest her money in the QBF group of companies.
Padalko N. had documents already prepared and signed by the "QBF" group of companies. On 22.09.2017, being in
the office of "QBF" LLC, she signed these documents, namely: agreement on provision of services of direct access to
international stock markets № 3421 - 17/IMR from 21.09.2017, between her and the company "QCCI LTD" represented
by the representative by power of attorney Yudin M.S. Agreement on provision of "Trust management" services in
accordance with the agreement on provision of direct access to international stock markets No. 3421 - 17/IMR, dated
21.09.2017, between her and QCCI LTD represented by Yudin M.S. Yudin has never seen or communicated with Yudin
M.S.. The existence of licences from the Central Bank gave her confidence in the safety of her investments and in the
reliability of the company. She did not wonder why the agreement was executed on behalf of a foreign company. Afer
the above events, on the same day, she brought the funds to be transferred to QBF Group of Companies. On
22.09.2017 she, being in the office of LLC "IK QBF", located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p.
1, handed over to Nikolay Padalko the funds under the concluded contract and agreement in the amount of USD
20,000, which at the exchange rate of the Central Bank of Russia as of 22.09.2017 amounted to RUB 1,164,400. Padalko
N. counted the brought money and lef the meeting room with it. In return, he brought a receipt to the cash receipt
order b/n dated 22.09.2017 stating that 20,000 US dollars were accepted from Vavilova L.A., the reason - crediting in
US dollars to the account under the contract No. 3421 - 17/IMR dated 21.09.2017. The receipt was issued on behalf of
the company "QCCI Ltd", signed by the chief accountant Gorobets E.V., and the receipt has an imprint of the QCCI seal.
Gorobets E.V. she has never seen. Afer they invested money in the "QBF" group of companies, she started receiving
reports to her daughter's e - mail address [email protected], which she received until the beginning of summer
2021 and later. These reports reflected the status of her investment portfolio. Seeing the positive trend in the reports,
she decided to add an additional $12,000. In this regard, she and Padalko N. agreed to meet. On 26.01.2018, at
approximately 11:00, she and her daughter arrived at the office of LLC "IC QBF", located at the address: Moscow,
890
Presnenskaya Naberezhnaya, 8, p. 1, 9th floor. They were also met at the entrance by Mr N. Padalko. During the
meeting in the office, Padalko N. led them to a meeting room, where she handed over to Padalko N. cash in the
RUB 671,160. Padalko N. counted the money brought to her and lef the meeting room with it. In return, he brought
her a receipt to the cash receipt order b/n dated 26.01.2018 stating that USD 12,000 was accepted from Vavilova L.A.,
the reason - crediting in USD to the account under the agreement No. 3421 - 17/IMR dated 21.09.2017. The receipt was
issued on behalf of the company "QCCI Ltd", signed by the chief accountant Gorobets E.V., and also the receipt had an
imprint of the QCCI seal. Afer the above events, her email continued to receive investment reports on the status of the
portfolio. Around the beginning of June 2018, she received a call on her daughter's mobile phone number from
Padalko N., who informed her about the need to come to the company's office in order to re - sign documents in the
part concerning the investment strategy. On 04.06.2018 she and her daughter arrived at the office of IK QBF LLC at the
address: Moscow, Presnenskaya Naberezhnaya, 8, p.1, 9th floor. N. Padalko met us, escorted us to the meeting room
and provided us with documents to sign. On 04.06.2018, being in the office of IK QBF LLC, she signed the following
documents provided by Padalko N.: service agreement No. 3421 dated 04.06.2018 between her and Simtelligence
Company Limited. Within the framework of the said agreement, Yurmaster LLC acts as an agent. According to Padalko
N., signing of these documents is a technical necessity and is conditioned by some change of financial strategy of the
group of companies "QBF", which will not affect in any way the state of the money invested by her. Later, afer about a
little over a year, Padalko N. contacted them again and asked us to come to the office for another re - signing of
documents related to the change of investment strategy. On 07.10.2019 she arrived at the office of IK QBF LLC at the
address: 8 Presnenskaya Naberezhnaya Naberezhnaya, 8, p.1, 9th floor, Moscow. She was met by N. Padalko, escorted
to the meeting room and provided documents for signing. On 07.10.2019 she, being in the office of IK QBF LLC, signed
the documents presented to me, namely: trust management agreement No. D - 450603 - J dated 07.10.2019 between
me and White Lake management Ltd, service agreement with VL Consulting LLC, other documents provided to her by
Padalko N., these documents she attached to the protocol of interrogation. According to Padalko N. signing of these
documents is a technical necessity and is conditioned by some change of financial strategy of the group of companies
"QBF", which will not affect the state of her invested money. She signed these documents trusting Padalko Nikolay. At
the end of May - beginning of June 2021, I learned from the media, including official news from the Russian Ministry of
Internal Affairs, that criminal cases had been opened and investigations were underway regarding fraudulent actions
against clients. Her daughter received a call from Padalko N. and informed her that all this was a provocation and
external pressure on the company, in this connection she should persuade her to buy units of ZPIF also from the
group of companies "QBF". Afer that they started to study information about the company QBF IK LLC and clients of
QBF group of companies. Based on information from various sources, she realised that she had become a victim of
fraudsters and Padalko N. together with other employees of "QBF" was deceiving them. In this regard, she submitted
an application for withdrawal of funds dated 16.06.2021, as well as a notice of realisation of assets dated 16.06.2021,
which were accepted by a QBF employee on 06.07.2021, but this application and notice were not executed, the funds
were not returned to her even partially. Also later she became aware that the Central Bank of Russia revoked all
available licences from the "QBF" group of companies. In total, she had transferred to the address of the "QBF" group
of companies money in the amount of 1,835,560 roubles. No refunds have been made to her from the QBF Group of
Companies. She believes that an offence has been committed against her, namely the thef of money belonging to her
by deceit and breach of trust. The material damage caused to her in the amount of 1,835,560 roubles is significant for
her. She specifies that in her earlier testimony as a witness, she had calculated some of the amounts incorrectly when
converting from dollars to roubles;
(Vol. No. 27, pp. 85 - 89, 90 - 94, 102 - 107)
- other documents - documents provided by Vavilova L.A. confirming her relationship with QBF Financial Group (QBF
(Vol. No. 27, pp. 108 - 196)
891
part 4 of article 159 of the Criminal Code of the Russian Federation against Vetrova N.S.:
- another document - a statement by Vetrova N.S., in which she asks to bring to criminal responsibility persons from
(Vol. No. 28, pp. 6,10)
- Testimony of N.S. Vetrova, given to her as a witness and victim,

according to which in 2017 she became aware of the existence of the investment financial group QBF, which offered
clients asset management, brokerage and custody services, investment counselling, as well as structured products,
investments in derivative financial instruments, both in foreign and domestic markets. QBF's branch office in St.
Petersburg was located at 64, Malookhtensky Ave. in St. Petersburg, and its head office in Moscow at 8, Presnenskaya
Pub. 1. The QBF representative with whom she had contact was Salimova Zarina, who held the position of sales
manager. She had known Salimova Zarina previously when she worked at VTB Bank PJSC as a personal manager of
the Privileges department. In the course of communication with Salimova 3arina the latter described to her the
profitability she could get in currency, levelling currency risks, told her that they cooperate with well - known foreign
brokerage houses such as Interactive Brokers, LEK Securities, R.J, O'Brien & Associates and others. Having been
persuaded, she decided to start co - operation with the company in the direction of stock trading on foreign stock
markets. She was provided with the Agreement for Direct Access Global Stock Market (Access Global Stock Market) No.
4236 - 17/ISR dated 15.11.2017 (Account 004236) with QCCI based in Cyprus. The subject matter of the Agreement is
opening of trading account No. 004236 for her to make purchase and sale transactions of Securities, derivatives and
other instruments; trust management agreement to the above Agreement dated 15.11.2017 with QCCI LLC
represented by Golubev A.S. under which she entrusted the company to manage the assets on her account. On
15.02.2017, being in the QBF office located at the address: St. Petersburg, Maloochtensky Ave. 64, as an investment
amount she gave Salimova Zarina 10 000 Euro, which at the exchange rate of the Central Bank of Russia as of
15.02.2018 was 712 329 rubles, in cash, and she gave her a signed receipt signed by the chief accountant Gorobets E.V.
and stamped by QCCI LTD. Later, as instructed by the manager, she signed Service Agreement No. 4236 with
Simtelligence Company Limited dated 04.06.2018. The subject matter of the agreement was as follows: consultancy
assistance in providing information and details of trading activities. In 2019, its manager informed that there was a
change of jurisdiction of domicile in Spain providing access to foreign markets and instead of QCCI it was necessary to
enter into an agreement with WhiteLakeManagement, registered in the Cayman Islands. Considering that the change
of company was a non - alternative option, she was forced to sign a Termination Agreement with QCCI Ltd., transfer of
rights to YurMaster Ltd. and sign the Trust Deed No. D - 901087 - K dated 11.11.2019 with WLM Ltd. submitted to her,
together with Annexes No. 1 and No. 2, which defined the investment strategy - Weighted Average and Asset
Protection. The subject matter of the agreement was the same as the earlier agreement with QCCI Ltd. She also
signed a Service Agreement (standard form of adhesion agreement) with VL - Consulting LLC dated 11.11.2019 with all
annexes and additional agreements, under which she allegedly opened an account with the Company to store cash
and securities, and VL - Consulting LLC advises her and provides services for delivery of her orders, documents to the
Company. On behalf of LLC "VL - Consulting" the documents were signed by Maricheva O.V. She does not know
anything about this company, she has never communicated with any of its representatives, she did not need any co -
operation. Communication with this company was supposed to take place by means of telephone communication by
number +13457691389, which she never called, e - mail info@w - lake.com.Через. Some time ago she learnt about
initiation of criminal proceedings and tried to withdraw funds from her brokerage accounts both foreign and Russian.
However, her instruction was not executed and the company did not respond to her requests. Thus, she believes that
a group of people, including Salimova Zarina, under the pretext of brokerage services, received money from her in the
892
amount of 712,329 rubles, but did not intend to fulfil their obligations and return the funds to her. She believes that by
means of deceit and abuse of trust she was robbed of her money in the amount of 712,329 roubles. The damage
caused to her is significant. To date, she has not received the return of her money deposited to the "QBF" group of
companies in the amount of 712,329 roubles. She also considers that the persons acting on behalf of the "QBF" group
of companies initially did not intend to fulfil their obligations to her and acted solely for the purpose of stealing her
money, having deceived her. The persons acting on behalf of the "QBF" group of companies stole her money in the
total amount of 712,329 roubles. She estimates the amount of damage caused to her as significant. She has been
explained the right to file a civil action in the criminal case. She wishes to exercise this right and file a lawsuit.She has
been explained the right to familiarise herself with the composition of the investigative teams, with the decisions on
the appointment of forensic examinations, with the conclusions of experts, with the records of expert interrogations,
and also to familiarise herself with the materials of the criminal case in full or in part. She does not wish to exercise
this right. She has not applied to the court with applications to recover money from the "QBF" group of companies;
(Vol. No. 28, pp. 11 - 14, 114 - 117)
- other documents - documents provided by N.S. Vetrova confirming her relationship with QBF Financial Group ( QBF
(Vol. No. 28, pp. 16 - 107)
part 4 of article 159 of the Criminal Code of the Russian Federation against Bozhko O.B.:
- another document - a statement by O.B. Bozhko, in which she asks to bring to criminal responsibility persons from
(Vol. No. 28, pp. 131, 132)
- O.B. Bozhko's testimony, given to her as a witness and victim

, according to which approximately in March 2018 from her acquaintance Spiridonov Oleg Gennadyevich she learnt
about the activities of the group of companies "QBF". At that time Spiridonov O.G. was a client of the group of
companies "QBF". Spiridonov O.G. introduced her to Alexey Sergeyevich Golubev (tel.8 - 921 - 858 - 16 - 24), the
financial advisor of the group of companies "QBF", who later became the head of the St. Petersburg branch of the
group of companies "QBF". A.S. Golubev told her about all investment products of the group of companies "QBF",
assured her of its financial stability and integrity, and also described all financial benefits that she would get by
investing money in the group of companies "QBF". She believed A.S. Golubev's words and concluded the trust
management agreement No. 4285 - 18/ISR dated 13.03.2008 with the company "QCCI LTD", which is a part of the
group of companies "QBF". Besides, on 13.03.2018 being in the office of the group of companies "QBF" at the address:
68, Maloohtinsky Ave., St. Petersburg, under the direction of the manager of the group of companies "QBF", whose
data she does not know, she deposited her funds in the amount of 20 000 US dollars and 6 000 Euros in the cash desk
of the group of companies "QBF", at the same time she was given 2 receipts to the natural cash order b/n. The funds
were accepted by the cashier, whose data she does not know. On 04.06.2018 the agreement between her and "QCCI
LTD" was cancelled and an agreement was concluded with the Limited Liability Company "Simitelligence"
represented by Dmitry Anatolievich Korshunov. The signing of the agreement took place under the direction of
Golubev A.S. In 2019, Golubev A.A. introduced her to Salimova Zarina Salimova (her tel. 8 - 953 - 148 - 18 - 59), the
financial advisor of the QBF group of companies, telling her that she (Salimova 3.) would be her personal manager. In
May 2020, Salimova 3. informed her that it was necessary to reissue the contract she had previously concluded with
"QCCI LTD" to a new legal entity - the legal successor, which was the company "White Lake Management Ltd". Under
the guidance of Salimova 3. she concluded with "White Lake Management Ltd" the trust management agreement No.
D - 397016 - E dated 07.05.2020. Interaction with "White Lake Management Ltd" was carried out through Limited
Liability Company "VL Consulting" OGRN 5187746009468. Since depositing money in the group of companies "QBF",
893
the Company "White Lake Management" sends her monthly reports on alleged investment activities. She received the
last report for August on 20 September 2021. During the time that her money was held in "Trust" in the "QBF" group of
companies, she managed to recover 1,500 Euros. In May 2021, she learned from Salimova 3. that QBF Group had some
difficulties and their licence was being revoked. Afer that she decided to return her money, previously contributed to
the group of companies "QBF", so on 29.07.2021 she sent Salimova 3. a notice to realise the assets under the
international contract. Salimova S. and forwarded the notice to: regionsupport@wl - consulting.ru. According to the
words of Salimova 3. to the specified e - mail address were sent applications of depositors, to return their money. She
has not received a reply to her notice to date. To date, she has not been returned her money deposited to the address
of the group of companies "QBF" in the amount of 20,000 US dollars and 4,500 Euros, which at the exchange rate of
the Central Bank of Russia at the time of deposit is 1,432,309.55 rubles. She believes that an offence has been
committed against her, namely the thef of her money by deceit and breach of trust. I estimate the amount of damage
caused to her as significant, namely 1,432,309.55 (one million four hundred and thirty - two thousand three hundred
and nine roubles and fify - five kopecks) roubles. Considers that the persons acting on behalf of the group of
companies "QBF" initially did not intend to fulfil their obligations to her and acted solely for the purpose of stealing
her money, having deceived her. The persons acting on behalf of the "QBF" group of companies stole money
belonging to her in the total amount of 1,432,309.55 roubles. She considers the amount of damage caused to her as
significant. She has been explained the right to file a civil action in the criminal case. She wishes to exercise this right
and file a lawsuit. She has been explained the right to familiarise herself with the composition of the investigative
records of expert interrogations, and also to familiarise herself with the materials of the criminal case in full or in part.
She does not wish to exercise this right. She has not applied to the court with applications to recover money from the
"QBF" group of companies;
(Vol. No. 28, pp. 135 - 138, 194 - 197)
- other documents - documents provided by O.B. Bozhko confirming her relationship with QBF Financial Group (QBF
(Vol. No. 28, pp. 139 - 187)
part 4 of article 159 of the Criminal Code of the Russian Federation against Batalova M.R.:
- another document - a statement by M.R. Batalova, in which she asks to bring to criminal responsibility persons from
among the employees, managers of the financial group "QBF" (LLC "Investment Company "QBF"), who stole her
(Vol. No. 29, l.d. 6)
- The testimony of M.R. Batalova, given to her as a witness and victim,

according to which approximately from January 2017 on her subscriber phone number began to receive phone calls
from employees of the group of companies "QBF". The calls were of an introductory and advertising nature, with the
aim of attracting her as a client. Having made enquiries in the Internet, namely on the website of the group of
companies "QBF", she paid attention to the fact that some employees of the group of companies "QBF" are former
employees of the Central Bank of the Russian Federation, which inspired confidence in this organisation. Later,
around July 2017, she was contacted by a manager of the "QBF" group of companies named Sirotiuk Bogdan (8 - 967 -
185 - 51 - 70), email address [email protected]), with whom she had an introductory conversation. The
financial advisor assured her that the company had a long and successful track record in Russia and abroad. Also in
open sources of the Internet she saw information that LLC "IK QBIF" (INN 7733673955) has 4 licences of the Central
Bank of Russia, namely: licence for brokerage activities No. 045 - 12805 - 100000 dated 24.12.12.2009, licence for
894
dealer activity #045 - 12816010000 dated 24.12.2009, licence for securities management #045 - 12828 - 001000 dated
24.12.2009 and licence for depository activity #045 - 14078 - 000100 dated 08.08.2019. Later she met with him at my
workplace, discussed various products that Bogdan offered her and agreed on the decision to open an IIS. She did not
have any problems while maintaining the IIS with QBF, she does not have any complaints regarding the maintenance
of the IIS. Then she decided to deposit funds in the QBF group of companies in another product, and QBF employees
Sirotiuk Bogdan and Ruslan Spinka persuaded her to invest in international products. On 28.12.2017 she, being in the
office of LLC "IC QBF", located at the address: Moscow, Presnenskaya naberezhnaya, 8, p.1, in order to invest funds in
securities with high yield, signed an agreement on provision of services of direct access to international stock markets
No. 4182 - 17/IIMR dated 11.11.2017 with QCCI LTD, and also signed an assignment agreement No. 4182 dated
28.12.2017 with QBIF Advisery LLC. Further, being in the office of LLC QB&EF Investment Company, located at the
address: 8 Presnenskaya Naberezhnaya Embankment, bldg. 1, Moscow, she made a cash transfer as follows:
28.12.2017 in the amount of USD 20,000, which at the exchange rate of the Central Bank of the Russian Federation as
of 28.12.2017 was RUB 1,149,000, 22.03.2018 in the amount of EUR 10,000, which at the exchange rate of the Central
Bank of the Russian Federation as of 22.03.2018 was RUB 705,700. Afer depositing the funds into the account, she
periodically, very rarely received reports on transactions and deals. During the entire period of co - operation she
received only 4 reports. Around September 2021, she learnt that criminal proceedings had been initiated against the
employees of QBF Group of Companies, in connection with which she called Ruslan Spinka, Senior Financial Advisor,
to enquire about the situation. Spinka assured her that there was no reason to worry about the matter. However, she
did not receive any clear explanations from QBF employees on how to withdraw the invested funds. In connection
with the above, she believes that a crime has been committed against her by "QBF" employees, namely thef of her
money by deceit and abuse of trust. In total, 1 854 700 roubles were transferred to her to the address of the group of
companies "QBF". She did not manage to withdraw the invested money even partially. She considers the amount of
damage caused to her by the offence of 1,854,700 roubles as significant;
(Vol. No. 29, pp. 9 - 12, 68 - 70)
- other documents - documents provided by M.R. Batalova confirming her relationship with QBF Financial Group (Q
BF Investment Company LLC) and testifying to the embezzlement of funds;
(Vol. No. 29, pp. 13 - 58, 72)
part 4 of article 159 of the Criminal Code of the Russian Federation against Romanovsky A.A.:
- another document - a statement by A.A. Romanovsky, in which he asks to bring to criminal responsibility persons
(Vol. No. 29, pp. 84, 88, 89)
A.A. Romanovsky's testimony, given by him as a witness and victim,

according to which at the beginning of March 2018 someone from his acquaintances, he does not remember exactly
who, advised him the group of companies "QBF" as a reliable financial structure, with the help of which it is possible
to earn additional income from investing money. As he needed money for the operation he was interested in it. By
phone he made an appointment at the office of "QBF", located at that time at the address: 64, Maloohtinsky Prospekt,
64, Business Centre "Plaza", St. Petersburg. When he came to the office he was met by Grigory Gennadievich
Pakhomov, a consultant of the "QBF" group of companies, who immediately started to persuade him to deposit
money in the cash desk of the "QBF" group of companies. Pakhomov G.G. began to mislead him, told him about the
financial products of "QBF", about the alleged reliability of the group of companies, about the presence of a licence of
the Central Bank of the Russian Federation, etc., in general, convinced him in good faith, legality and reliability of the
group of companies "QBF", as he is not well versed in investing he believed Pakhomov G.G. On 20 March 2018, being in
the office of the group of companies "QBF" at the address: St. Petersburg, Maloohtinsky Prospekt, 64, he was deceived
895
by the representative Pakhomov G.G. and under his accompaniment signed the following documents: Agreement
with "QCCI LTD" ("QCCI LTD") on provision of services of direct access to international stock markets No. 4298 - 18/ISR
dated 20.03.2018 for allegedly investing in securities with high yield and Agreement Order No. 4298 dated 20.03.2018
of "QBCI Advisery" LLC. On 20 March 2018, being in the office of the "QBF" group of companies at the address: 64,
Maloohtinsky Prospekt, St. Petersburg, he deposited USD 20,000 in cash, which at the exchange rate of the Central
Bank of Russia as of 20.03.2018 amounts to RUB 1,151,042, in the cash desk of the "QBF" group of companies. The
money was accepted by an employee of the "QBF" group of companies (he does not remember the data of this
employee) in the presence of Pakhomov G.G. In order to mislead him and to give the appearance of legitimate activity,
the said employee of the "QBF" group of companies gave him a receipt to the receipt order No. b/n dated 20 March
2018. On 24 March 2018, being in the office of the group of companies "QBF" at the address: St. Petersburg,
Maloohtinsky Prospekt, 64, he deposited USD 23,000 in cash, which at the exchange rate of the Central Bank of Russia
as of 24.03.2018 is 1,313,465.60 rubles, in the cash desk of the group of companies "QBF". The money was accepted by
an employee of the "QBF" group of companies (he does not remember the data of this employee) in the presence of
Pakhomov G.G. In order to mislead him and to give the appearance of legal activity, the said employee of the "QBF"
group of companies gave him a receipt to the receipt order No. b/n dated 24 March 2018. On 04 June 2018, being in
the office of the group of companies "QBF" at the address: St. Petersburg, Maloohtinsky Prospekt, 64, according to the
conviction of Pakhomov G.G., he concluded a contract with QBF Advisery LLC, it was necessary according to the words
of Pakhomov G.G., as QCCI LTD changed its location from Cyprus to Hong Kong. On 25 October 2019, being in the
office of the group of companies "QBF" at the address: St. Petersburg, Degtyarny per. 11 lit. B, pom.1 - H, BC
"Nevskaya Nevskaya".H, BC "Nevskaya Ratusha" according to the belief of Pakhomov G.G. he concluded the contract
No. 387803 - 09 of rendering services with LLC "QBF Advisery". The contract contained the name of VL Consulting LLC
TIN 7706463476. He did not go into the documents and circumstances, because he was deluded and did not realise
that he was being deceived, he was under the control of Pakhomov G.G. In addition, an agreement to the Trust
Management Agreement No. D - 387803 - J with "White Lake Management Ltd" was also signed. On or about 20
September 2020, he sent a notice to the QBF Group of Companies that he wanted to withdraw his funds in full.
However, he received no response to his request. At the end of December 2020, Dmitry Vladimirovich Maskalyuk, the
manager of the QBF Group of Companies, appointed him a meeting for 14 January 2021. On 14 January 2021 at the
meeting D.V. Moskalyuk misled him and fraudulently persuaded him to postpone the withdrawal of funds for some
time, motivated by the fall of the securities market. He believed D.V. Moskalyuk and did not demand the return of his
money. In April and May 2021, he repeatedly tried to call Moskalyuk D.V. by phone in order to return to him the money
deposited to the cash desk of the "QBF" group of companies. When he got through to Moskalyuk D.V. he (Moskalyuk
D.V.) again began to deceive him and mislead him in every possible way about the return of money to him, invented
different circumstances and reasons. At that moment he realised that he had become a victim of fraud and was simply
deceived in order to steal his money. At that time, he saw information in the media that criminal cases had been
opened and investigations were being conducted against the employees and managers of the "QBF" group of
companies. This confirmed his thoughts that he was a victim of fraud. To date, he has not been returned his money
deposited to the address of the group of companies "QBF" in the amount of 43 000 US dollars, which at the exchange
rate of the Central Bank of Russia on the dates of deposit of funds on 20.03.2018 and 24.03.2018 is 2 464 507,60
Rubles. He believes that the persons acting on behalf of the "QBF" group of companies initially did not intend to fulfil
their obligations to him and acted solely for the purpose of stealing his money by deceiving him. In the period from
20.03.2018 to 24.03.2018, the persons acting on behalf of the "QBF" group of companies stole his money in the total
amount of 2,464,507.60 rubles. He considers the amount of damage caused to him as significant. He has been
explained the right to file a civil action in the criminal case. He wishes to exercise this right and file a lawsuit. He has
the appointment of forensic examinations, with the conclusions of experts, with the protocols of interrogations of
exercise this right. He did not apply to the court with applications for recovery of money from the "QBF" group of
companies;
(Vol. No. 29, pp. 90 - 93, Vol. No. 30, pp. 18 - 21)
896
- other documents - documents provided by A.A. Romanovsky confirming his relationship with QBF Financial Group
(Vol. No. 29, pp. 95 - 147, 159 - 167, 182 - 228, Vol. No. 30, pp. 1 - 10)
part 4 of article 159 of the Criminal Code of the Russian Federation against Erofeev D.V.:
- another document - a statement by D.V. Erofeev, in which he asks to bring to criminal responsibility persons from
(Vol. No. 30, pp. 34, 35)
- Testimony of D.V. Erofeev, given by him as a witness and victim,

according to which approximately in early 2018 from his brother - in - law Bogdanov Kirill Yuryevich, he learnt about
the financial company QBF. At that time Bogdanov K.Y. worked in this company as a financial advisor. At that time his
money savings were on a deposit account in "Baltinvestbank". Bogdanov K.Y. told him about the activity of QBF
company and a higher rate of return on the invested money than on the deposit in the bank. Therefore, he decided to
invest his money in QBF company. 19.04.2018 in the office of QBF company at the address: St. Petersburg, Degtyarny
per. 11, lit. B, pom.1 - H, BC "Nevskaya Ratusha" he signed the "Trust Management Agreement No. 4341 - 18/ISR dated
19.04.2018" between the company "QCCI LTD", and the company "QBF Advisory", and he (D.V. Erofeev) transferred
funds in the amount of 2 500 000 rubles to Alexey Sergeyevich Golubev (tel. 8 - 921 - 858 - 16 - 24), who acted on the
basis of a power of attorney from the company "QCCI LTD" and represented himself as the head of the branch network
QBF and the head of the back - office Marzenyuk Ekaterina (8 - 913 - 988 - 88 - 05), who in return handed him a cash
receipt from the company "LTD QCCT". I would like to note that he was told that the management of the invested
money will be carried out by the specialists of QBF company. A.S. Golubev informed him that the deposited funds
would be used for transactions on purchase and sale of various financial instruments (shares, etc.) on international
exchanges. He was directly assigned a financial advisor Bogdanov K.Y. Interaction with "QCCI LTD" was carried out
within the framework of the assignment agreement No. 4341 dated 19.04.2018 concluded between him and QCCI LTD
represented by Pakhomov Grigory Gennadyevich acting on the basis of a power of attorney. He has never personally
communicated with G.G. Pakhomov. Also, when signing these documents, he was informed that in three months he
could withdraw the profit received from the transactions on the purchase and sale of shares on the basis of his
application, he could withdraw the entire amount of money deposited by him without commission in 12 months.
Starting from May 2018, he started receiving reports on the purchase of securities on his account to his email
[email protected]. I cannot confirm or deny the accuracy of these reports. According to these reports, he was
making profit and there was a positive trend in his account. On 26.06.2020 he (D.V. Erofeev) sent a notification letter to
the QBF company to the mailbox regionsupport@wl - consulting.ru about the start of the process of withdrawal of all
deposited funds. On 17.09.2020 he was provided with a withdrawal order number. During September 2020, through
their financial advisor Bogdanov K.Y., they prepared the requested set of documents for the refund, which included:
Russian passport, foreign passport, notarised English translation of the Russian passport, notarised foreign passport,
TIN, bank statement in English with confirmation of my registration, KYC - questionnaire in English. I note that when
they started working, Golubev A.S. assured him that no documents would be taken from him when withdrawing
funds, and that withdrawal of funds could also be done through the company's office at the above address. On
08.10.2020 a letter was sent with all requested documents and repeated withdrawal orders. In response to this letter,
the company insisted on the need to sign the documents on the transfer of assets from Cyprus to "White Lake
Management" (Cayman Islands) and Hong Kong "Simtelligence". And if such re - signing was not done, it would be
impossible to realise a refund. These requirements were explained by QBF's policy. On 25.12.2020, an agreement for
the transfer of assets from Cyprus to White Lake Management (Cayman Islands) and Hong Kong Simtelligence was
897
prepared for him, but he did not sign it. On 22.01.2021, a meeting was held in the office of QBF company with the
representative of the company - Dmitry Moskaluk (8 - 965 - 028 - 88 - 88), who represented himself as a vice - president
of QBF company. At this meeting the terms of withdrawal of funds till the end of April 2021 were outlined. On
25.01.2021, there was a second meeting at QBF with A.S. Golubev, where he also confirmed the withdrawal of funds
by the end of April, with the signing of documents on the transfer of assets from Cyprus to "White Lake Management"
(Cayman Islands) and Hong Kong "Simtelligence" and the availability of all other documents. Also, Golubev A. To
speed up the process of withdrawal of funds he proposed to sign a document for the sale of assets at market value.
According to him, it will speed up the process of selling off the securities. On 01.02.2021, he (D.V. Erofeev) signed the
documents for the transfer of assets and was assigned a new contract number No. D - 461156 - L dated 25.12.2020. On
behalf of the company "White Lake Management" the contract was signed by Korshunov D.A. He has not seen this
person personally and has not communicated with him. Further, the whole set of documents required from him was
sent to the company. On 08.02.2021, he sent an application to sell the portfolio at the market price, at which he was
promised to sell it within 5 working days. On 09.03.2021, from the post office regionsupport@wl - consulting.ru came
a notification about the sale of his portfolio with the final balance of 43 961,4 USD or 3 340 156 rubles at the Central
Bank exchange rate of 75,98 rubles. At the same time he was told that he needed to update the documents that were
prepared in autumn. On 15.04.2021 all requested documents were sent to QBF. However, a request for another
certificate confirming his income came. Without this certificate they refused to accept the whole set of documents. On
30.04.2021, this certificate was sent. Thereafer there was no feedback from the company. He also did not receive any
money. Around the same time, he learnt from the media about the criminal case opened against QBF employees and
investigative actions being carried out, including in the St. Petersburg office. To date, he has not been returned his
money deposited with the QBF group of companies in the amount of 2,500,000 roubles. He believes that the persons
acting on behalf of the "QBF" group of companies initially did not intend to fulfil their obligations to him and acted
solely for the purpose of stealing his money by deceiving him. The persons acting on behalf of the "QBF" group of
companies stole his money totalling 2,500,000 roubles. He considers the amount of damage caused to him to be
significant. He has been explained the right to file a civil action in the criminal case. He wishes to exercise that right
transcripts of expert interrogations, and with the materials of the criminal case in full or in part. He does not wish to
companies;
(Vol. No. 30, pp. 38 - 41, 126 - 129)
- other documents - documents provided by D.V. Erofeev confirming his relationship with QBF Financial Group (QBF
(Vol. No. 30, pp. 43 - 121)
part 4 of article 159 of the Criminal Code of the Russian Federation against Borzenkov M.I.:
- another document - a statement by M.I. Borzenkov, in which he asks to bring to criminal responsibility persons from
(Vol. No. 31, pp. 10 - 12)
- M.I. Borzenkov's testimony as a victim,

according to which he is currently an individual entrepreneur, his line of business is wholesale and retail trade in
household appliances and renting out real estate. Since 2008 and up to the present time his father I.A. Borzenkov has
also been an individual entrepreneur. His line of business - renting out real estate, wholesale and retail sale of
household appliances. He specified that he himself and his father, I.A. Borzenkov, had money savings, which they
898
placed in business projects, in real estate and on accounts of various banks. As the funds were released, they were
channelled to his account opened with the Ekaterinburg branch of PJSC Gazprombank. In 2016, Khvostenko S.R. was
a trustee of his father, Borzenkov I.A. As far as he remembers, at that time she was employed by Vash Accountant LLC.
This company carried out accounting for a number of his father's organisations. S.R. Khvostenko's job duties included
liaising with banks, financial analyses and so on. His father, I.A. Borzenkov, instructed S.R. Khvostenko to find an
investment organisation in which to place (invest) funds in order to gain profit through trust management (he
specified that neither he nor his father had previously cooperated with such organisations). As far as he knows S.R.
Khvostenko considered several investment organisations and decided on QBF LLC. According to Khvostenko S.R., she
had a preliminary meeting with K.S. Sobolev (neither he nor his father had previously met him), who was a
representative of the Ekaterinburg branch of QBIF LLC, received from him draf agreements on the provision of direct
access to international stock markets and agreements on the provision of trust management services, and checked
whether QBIF LLC had a licence and other necessary documents. In early 2016, S.R. Khvostenko informed them that
she had found QBF LLC, which would be engaged in trust management. His father instructed S.R. Khvostenko to
organise a meeting with the managers of QBF LLC. In April 2016, his father I.A. Borzenkov met with K.S. Sobolev, a
representative of the Ekaterinburg branch of LLC IC QBF. The meeting took place in the office of this company in the
President BC at 1A Boris Yeltsin St., Ekaterinburg, office #1204. K.S. Sobolev told his father during the meeting that
they co - operated with American brokers and the money invested by them would be insured. The conditions were
slightly better than those of other investment companies. The documents submitted for examination, in the opinion
of his father and Khvostenko S.R., were in order, and the presentation of their company did not resemble a company
of swindlers at all. According to the words of K.S. Sobolev, their company makes its profit by investing money in
foreign bonds, shares, etc., which they trade on the American securities market. Given that they trade on the foreign
market, Sobolev said that the cash should be invested in US dollars and transferred to the Cyprus company QB
CAPITAL CY LTD (later renamed "QCCI"), part of the holding company QB IC LLC. They travelled together with his
father, I.A. Borzenkov, to the second meeting, also in April 2016, at the address: 1A Boris Yeltsin St., Ekaterinburg,
office No. 1204, where they also discussed the terms of the "Agreement on the provision of direct access services to
international stock markets", as well as the terms of the agreement on the provision of "Trust management" services
concluded in accordance with the above Agreement. Prior to the conclusion of the agreements in the course of
negotiations it was agreed that the payment for the trust management services of QBIF LLC shall be made only from
the Principal's profit (success fee) and the procedure of tariff reduction was agreed upon in case the Principal
increases the funds under the management of QBIF LLC and increases the terms of trust management. In addition,
the terms of investment and the procedure for return of funds were agreed upon. The terms and conditions of the
contracts and agreements generally corresponded to the oral agreements. They agreed to the scheme of work
proposed by QBIF LLC, in particular by K.S. Sobolev, whereby their funds are transferred to the "master account" of
the Cyprus company QB CAPITAL CY LTD (QCCI), afer which their money, together with the funds of other Trustees, is
placed in securities and managed by the Russian licensed company QBIF LLC. According to the words of the
employees of LLC IC QBF (K.S. Sobolev), this scheme is related to the convenience of working on the New York Stock
Exchange and reducing costs. He and his father, prior to the withdrawal problems (July 2019), had treated QBF IK LLC
with full confidence and planned long - term investments. On 28 April 2016, he himself and his father, I.A. Borzenkov,
again came to the above - mentioned office of IC QBF LLC, where he himself, as an individual, signed the "Agreement
on provision of direct access services to international stock markets No. 2611 - 16/1EC 28.04.2016", as well as signed
the Agreement on provision of "Trust Management" services, concluded in accordance with the above - mentioned
Agreement. Subsequently, it signed several more Agreements and contracts on provision of trust management
services. In total, under all contracts and agreements, he transferred to the accounts of the Cyprus company QB
CAPITAL CY LTD (QCCI), USD 14,000,000. All contracts and agreements were signed in the office of QB CAPITAL CY LTD
in Ekaterinburg in BC "President". All funds were transferred from his personal account opened with the Ekaterinburg
branch of PJSC Gazprombank. All payments passed currency control, payment orders are available. All documents
were submitted to the bank's employees, and the bank's employees did not have any questions. Control over trust
management was carried out until May 2018 by S.R. Khvostenko, by receiving monthly reports to her email, later
monthly reports from the side of LLC IC QBF began to come to his father, I.A. Borzenkov. Reports from the side of LLC
IC QBF until September 2019 came from the email address: [email protected], afer that from the email address
899
адреса:reports@wl - mnt.com. All reports came to his email address: [email protected]. Neither he, his father, nor
their proxies had independent access to the trading account (the account where the funds were placed). All
operations on the accounts were carried out exclusively by employees of QBIF Ltd. No information on specific
securities transactions, other than that contained in the reports, was provided to them. Since summer 2018, instead
of K.S. Sobolev, communication with them began to be conducted by Alexey Golubev, who was in St. Petersburg and
said that he was the head of the client network and explained that further communication would take place with him.
From September 2018, his father made attempts to obtain interest on the concluded contracts. For this purpose, he
negotiated with A. Golubev, and further in December 2018, his father submitted formal demands for interest
payments totalling USD 1,805,000 to the office of QBIF LLC in Ekaterinburg. However, no money was received until
March 2019. All negotiations were conducted by his father, as he himself entrusted his father to conduct all
negotiations. In March - April 2019, his father, on his (Borzenkov M.I.) behalf, held meetings with the beneficiary of
QBIF LLC Shlakov Roman Valeryevich in the office of QBIF LLC, in Moscow at the following address: Moscow,
Presnenskaya Naberezhnaya, 8, p. 1. 1. At the meeting it was agreed that by 01 July 2019 the entire interest amount of
USD 1,805,000 will be transferred to his account, afer which the parties will discuss further actions (reissuance of
contracts, registration of the CIC by the Principal, terms of early termination of contracts). Shpakov R.V. assured his
father that the agreements reached by him will be fulfilled. By 01 July 2019, $250,000, in several transfers, instead of
$1,805,000, was deposited into his account. Golubev A. and Shpakov R.V. explained the reason for the delay by the
difficulties of passing bank control and the holiday season. In June 2019, his father learnt through his acquaintances
that it is possible to check the data on Cypriot legal entities in open sources. Afer that, his father independently found
out through internet sites that the company QB CAPITAL CY LTD (QCCI), where the funds were transferred from his
account, was liquidated. In order to establish the reasons of liquidation of the Cypriot company QB CAPITAL CY LTD
(QCCI), his father turned to Golubev A., who answered him (Borzenkov M.I.) that "they had to leave Cyprus quickly"
and QB CAPITAL CY LTD (QCCI) transferred all the obligations under its contracts to the Hong Kong company
"Simtelligence", all the funds invested by him under the above contracts are fully preserved. Afer that Golubev A.
suggested them to agree on this transfer first to the Russian company, under the contract of assignment of the right of
claim, and then to the Hong Kong company. His father then realised that they were being tried to deceive them and
take possession of the funds belonging to them by deception. In September 2019, R.V. Shpakov suggested to his father
that he (M.I. Borzenkov) should enter into an interest - free foreign currency loan agreement and promised to transfer
the remaining US$1,413,000 within 2 weeks of signing. Afer payment of all monies, a set - off of counterclaims was
planned. The loan agreement was signed by him (M.I. Borzenkov) at the end of September 2019 at the office of IK QBF
LLC in Moscow. In October 2019, his father again held a meeting with R.V. Shpakov in an attempt to recover the
invested funds. However, R.V. Shpakov did not return the money. At the moment, QBF IK LLC has sent on behalf of the
Hong Kong company Simtelligence a total of US$ 587,000,000 to him for "services". However, these amounts are not
properly formalised and therefore cannot be considered a return of investment at this time, as there was and is no
relationship properly formalised between himself and Hong Kong Simtelligence. In November 2019, on his behalf, his
father prepared and sent to QBIF LLC at the address: 1A Boris Yeltsin St., Ekaterinburg, office #1204, letters of
termination of the agreements on the provision of trust management services, the said letters were handed to the
secretary of QBIF LLC on 14 November 2019. A little later, Orders for withdrawal of funds under all the contracts
totalling $17,700,572 were sent. The said Orders were also received by the employees of QBIF IC LLC. However, to date
the funds have not been credited to his account. The employees of QBF LLC avoid communicating with him and his
father, their letters and calls are not answered. On the part of QBF LLC, the communication with his father, I.A.
Borzenkov, and their representatives was also conducted by lawyer Evgenia Rossieva and assistant to R.V. Shpakov. -
Vlasov Pavel, who for many months assured him and his father that the funds would be returned to them, citing
various problems. His father has a saved correspondence in messengers with R.V. Shpakov and P. Vlasov (printout
attached). Approximately in February 2020, he entered into an assignment agreement with the Foreign Investors'
Rights Protection Fund, according to which the right to claim the debt from LLC "IK QBF" in connection with the need
to perform actions outside the Russian Federation. He added that since the documents on assignment of the right of
claim with the Cyprus company QB CAPITAL CY LTD (QCCI) neither he nor his father, Borzenkov I.A., signed, the
liquidation of the Cyprus company could only be done illegally with forged signatures, as it is impossible to legally
liquidate a company with a debt to a client under Cyprus law. In addition, the e - mail of his father, Borzenkov I.A.,
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until January 2021 came financial reports, which, according to financial experts, contain completely unreliable -
invented information. Due to the failure of the company IK QBF LLC to return the money to him, the Russian
Federation has not received due taxes in the amount of approximately 37,000,000 roubles. He is currently unable to
repatriate the funds that he has withdrawn from the Russian Federation. He said that due to his studies in Canada, it
was not possible for him to come to Russia frequently to participate in investigative activities. In this regard, he
entrusts and fully trusts his father, I.A. Borzenkov, to represent his interests in law enforcement and other bodies
during the investigation of this criminal case, or the lawyers and legal experts he will engage for this purpose. His
father, I.A. Borzenkov, is fully aware of the circumstances of his relationship with representatives of QBF. He also
issued a power of attorney to his father to represent him;
(Vol. No. 33, pp. 8 - 14, 25 - 31)
- other documents - documents provided by M.I. Borzenkov in the form of correspondence from Whats App
messenger, testifying to the implementation with employees of QBF Financial Group (QBF Investment Company LLC)
of claiming stolen funds of M.I. Borzenkov;
(Vol. No. 33, pp. 32 - 40)
- other documents - documents provided by M.I. Borzenkov confirming his relationship with QBF Financial Group
(vol. No. 31, pp. 13 - 68, vol. No. 32, pp. 58 - 112, 122 - 151, 156 - 187, 193 - 200,
vol. No. 323, pp. 10 - 12)
- The testimony of the witness Borzenkov I.A.

, according to which he is registered at the address: Sverdlovsk region, city of Yekaterinburg, Tveritina Street, house
No. 38, building No. 2, flat No. 10, actually resides at the address: Krasnodar region, city of Anapa, Lenina Street,
house No. 146, flat No. 186. At this address he resides jointly with his common - law wife, Olga Ivanovna Vilisova. He
has a son, Maxim Ilyich Borzenkov, born in 1993. He specified that since December 2020, his son had been studying in
Canada and was currently unable to come to the territory of the Russian Federation because the borders were closed
due to the pandemic. His son is also an individual entrepreneur, his line of business is wholesale and retail trade of
household appliances, renting out real estate. He has been self - employed from 2008 to date. His line of business is
property rental, wholesale and retail sale of household appliances. He specified that he and his son, M.I. Borzenkov,
had cash savings, which they had placed in business projects, in real estate and in accounts at various banks. As funds
were released, they were channelled to his son M.I. Borzenkov's account opened at the Ekaterinburg branch of PJSC
Gazprombank. In the period of 2016, Khvostenko S.R. was his authorised person. As far as he remembers, at that time
she was employed by Vash Accountant LLC. This company carried out bookkeeping for a number of his organisations.
S.R. Khvostenko's job duties included liaising with banks, financial analyses, etc. He instructed S.R. Khvostenko to find
an investment organisation in which to place (invest) funds in order to gain profit through trust management (he
specified that neither he nor his son had previously cooperated with such organisations). As far as he knows, S.R.
Khvostenko considered several investment organisations and settled on LLC IC QBF. According to Khvostenko S.R.,
she had a preliminary meeting with Sobolev K.S. (he was a representative of the Ekaterinburg branch of IK QBF LLC),
received from him draf agreements on the provision of direct access to international stock markets and agreements
on the provision of trust management services, and checked whether IK QBF LLC had a licence and other necessary
documents. In early 2016, Khvostenko S.R. informed him that she had found IC QBF LLC, which would be engaged in
trust management. He instructed S.R. Khvostenko to organise a meeting with the managers of IK QBF LLC. In April
2016, he met with a representative of the Ekaterinburg branch of QBIF LLC Sobolev K.S. The meeting took place in the
office of this company in BC "President" at the following address: Ekaterinburg, Boris Yeltsin Street, house No. 1a,
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office No. 1204. During their meeting K.S. Sobolev informed him that they co - operated with American brokers, the
money invested by them would be insured. The conditions were slightly better than those of other investment
companies. The documents submitted for examination, in their opinion (his and Khvostenko S.R.'s) were in order, and
the presentation of their company did not resemble a company of fraudsters at all. According to the words of K.S.
Sobolev, their company earns profit by placing money in foreign bonds, shares, etc., which they trade on the
American securities market. Taking into account that they trade on the foreign market, the funds should be invested
in US dollars and transferred to the Cyprus company "QCCI", which is part of the holding company of LLC "IC QBIF". He
and his son, M.I. Borzenkov, also went to the second meeting in April 2016 at the office of QBIF LLC in Ekaterinburg at
the following address: Boris Yeltsin Street, No. 1a, office No. 1204, Ekaterinburg, together with his son, M.I. Borzenkov,
during which they also discussed the terms and conditions of the "Agreement on the Provision of Direct Access to
International Stock Markets Services", as well as the terms and conditions of the agreement on the provision of "Trust
Management" services concluded in accordance with the aforementioned Agreement. Prior to the conclusion of the
agreements in the course of negotiations, it was agreed that the payment for the trust management services of QBIF
LLC shall be made only from the Principal's profit (success fee) and the procedure of tariff reduction was agreed upon
in case the Principal increases the funds under the management of QBIF LLC and increases the trust management
terms. In addition, the terms of investment and the procedure for return of funds were agreed upon. The terms and
conditions of the contracts and agreements generally corresponded to the oral agreements. The Trustor agreed to the
scheme of work proposed by QBIF LLC, whereby the Trustor's funds are transferred to the master account of the
Cyprus company QCCI, afer which the Trustor's money, together with the funds of other Trustors, are placed in
securities and managed by QBIF LLC, a Russian licensed company. According to the employees of QBIF LLC, this
amount is related to the convenience of working on the New York Stock Exchange and reducing costs. The Trustee
had, prior to the withdrawal problems (July 2019), treated QBeeF LLC with complete confidence and planned a long -
term investment. On 28 April 2016, he himself and his son, M.I. Borzenkov, again came to the above - mentioned office
of QBF LLC, where M.I. Borzenkov, as an individual, concluded the "Agreements on the provision of services of direct
access to international stock markets No. 2611 - 16/1EC 28.04.2016", as well as the Agreements on the provision of
services of "Trust Management" concluded in accordance with the above - mentioned Agreement. Subsequently, his
son, M.I. Borzenkov, signed several more Agreements and contracts on the provision of trust management services. A
total of USD 14,000,000 was transferred by M.I. Borzenkov to the accounts of the Cyprus Company under all the
Agreements and Contracts. All contracts and agreements were signed in the office of QBF LLC in Ekaterinburg, in BC
"President". All funds were transferred from the account of M.I. Borzenkov opened in the Ekaterinburg branch of PJSC
Gazprombank. All payments passed currency control, payment orders are available. All documents were submitted to
the bank staff, the bank staff had no questions. Control over trust management was carried out until May 2018 by S.R.
Khvostenko, later by him on monthly reports, which until September 2019 came from the electronic address:
[email protected], afer from the electronic address: reports@wl - mnt.com. All reports were received by him at the
email address: [email protected]. Neither his son nor their proxies had independent access to the trading account (the
account where the funds were placed). All operations on the accounts were to be carried out exclusively by the
employees of QBIF Ltd. No information on specific securities transactions, other than that contained in the reports,
was provided to them. From summer 2018, instead of K.S. Sobolev, communication with him started to be conducted
by Alexey Golubev, who was in St. Petersburg and said that he was the head of the client network and explained that
further communication would take place with him. From September 2018, he made attempts to receive interest on
the concluded contracts. For this purpose, he negotiated with A. Golubev, and further, in December 2018, he
submitted formal demands for interest payments totalling USD 1,805,000 to the office of QBIF LLC in Ekaterinburg.
However, no money was received until March 2019. All negotiations were conducted by himself, as his son entrusted
him to conduct all negotiations, while he himself was immersed in his studies. In March - April 2019, on behalf of his
son, he held meetings with Roman Valeryevich Shpakov, the beneficiary of QBIF LLC, in the office of QBIF LLC, in
Moscow, at the following address: Moscow, Presnenskaya Embankment, house No. 8, building 1. They reached an
agreement that by 01 July 2019, the entire amount of interest in the amount of USD 1,805,000 would be transferred to
the account of M.I. Borzenkov, afer which the parties will discuss further actions (reissuance of contracts, registration
of CIC by the Principal, terms of early termination of contracts). R.V. Shpakov assured him that the agreements they
had reached would be fulfilled. By 01 July 2019, Borzenkov M.I. received $250,000, in several transfers, instead of
902
$1,805,000. Golubev A. and Shpakov R.V. attributed the reason for the delay to difficulties in passing bank control and
the holiday season. In June 2019, he learnt through his acquaintances that it is possible to check the data on Cyprus
legal entities in the public domain. Afer that, he independently found out through Internet sites that the company
"QCCI", where the funds were transferred from the account of Borzenkov M.I., was liquidated. In order to establish the
reasons for the liquidation of the Cyprus company "QCCI", he turned to Golubev A., who told him that "they had to
leave Cyprus quickly" and "QCCI" transferred all the obligations under its contracts to the Hong Kong company
"Simtelligence", all the funds invested by Borzenkov M.I. under the above contracts are fully preserved. Afer that
Golubev A. proposed to him to agree this transfer first to the Russian company under the contract of assignment of
the right of claim, and then to the Hong Kong company. Then he realised that Borzenkov M.I. and himself were trying
to deceive and take possession of the funds belonging to them by deception. In September 2019, Shpakov R.V.
suggested to him that Borzenkov M.I. should conclude an interest - free foreign currency loan agreement and
promised to transfer the remaining USD 1,413,000 within 2 weeks afer signing. Afer payment of all monies, a set - off
of counterclaims was planned. The loan agreement was signed by Borzenkov M.I. at the end of September 2019 in the
office of IK QBF LLC in Moscow. In October, he again held a meeting with R.V. Shpakov in an attempt to receive the
funds. At the moment "IC QBF" has sent on behalf of the Hong Kong company "Simtelligence" to Borzenkov M.I. a
total of 587,000 USD, for "services". However, these amounts are not duly formalised and therefore cannot be
considered as a return of the invested funds at this time, as there was and is no duly formalised relationship between
Borzenkov M.I. and Hong Kong Simtelligence. In November 2019, on behalf of M.I. Borzenkov, letters of termination of
the three agreements on the provision of trust management services were prepared and sent to QBIF LLC at the
address: Ekaterinburg, Boris Yeltsin Street, house No. 1a, office No. 1204. The said letters were handed to the secretary
of QBIF LLC on 14 November 2019. A little later, the Orders for withdrawal of funds under all three contracts totalling
$17,700,572 were sent. The said Orders were also received by the employees of IK QBF LLC. However, to date the
funds have not been transferred to Borzenkov M.I.'s account. Employees of the company LLC "IC QBF" evade
communication with him and M.I. Borzenkov, their letters and calls are not answered. Around February 2020, M.I.
Borzenkov concluded an assignment agreement with the Foreign Investors' Rights Protection Fund, according to
which the right to claim the debt from LLC "IC QBF" in connection with the need for action outside the Russian
Federation. He added that since neither he nor Borzenkov M.I. signed the documents on the assignment of the right of
claim with the Cypriot company "QCCI", the liquidation of the Cypriot company could only be carried out illegally with
forged signatures, as it is impossible to legally liquidate a company with a debt to a client under Cypriot law. In
addition, until January 2021 he received financial reports by e - mail, which, in the opinion of all financial experts to
whom he showed them, contain completely false, invented information. Due to the failure of the company IK QBF LLC
to return the funds to Borzenkov M.I., the State of the Russian Federation did not receive due taxes in the amount of
approximately 37,000,000 roubles. At present, M.I. Borzenkov has no possibility of repatriating the funds withdrawn
from the Russian Federation. He (M.I. Borzenkov) also added that during meetings, transactions and other
interactions between his son M.I. Borzenkov and employees of QBIF LLC, due to his (his son's) young age, he was
almost always personally present. In rare cases, these interactions took place without his personal participation, but
he (M.I. Borzenkov), nevertheless, was aware of them from M.I. Borzenkov's stories, knew their content and
circumstances. From the moment of initiation of criminal proceedings on his son's statement, they periodically
analysed the documents available and subsequently discovered in their possession, which they had not previously
taken into account when testifying. He specified that on 28.04.2016 M.I. Borzenkov was invited to the office of LLC
"Investment Company QBF", which was located at the following address: 1a Boris Yeltsin Street, Ekaterinburg. There,
an employee of QBIF Investment Company LLC handed over to my son the Agreement on rendering services of direct
access to international stock markets No. 2611 - 16/IER dated 28.04.2016, which he (my son) signed on the same day
afer familiarising himself with it. The agreement was on behalf of QB Capital CY LTD, a company registered in the
Republic of Cyprus. On the same day on 28.04.2016, at the same office of "QB Investment Company CY LTD",
immediately afer signing the agreement, the son signed the Agreement for the provision of "Trust Management"
services, concluded in accordance with the above mentioned Agreement No. 2611 - 16/IER dated 28.04.2016. In
addition, between 28.04.2016 and 01.02.2017, at the insistence of one of the employees of QBIF Investment Company
LLC, Borzenkov M.I. came to the office of QBIF Investment Company LLC located at: Ekaterinburg, ul. Ekaterinburg,
Boris Yeltsin St., 1a, where he signed with "QB Capital CY LTD" the Agreement on provision of services of direct access
903
to international stock markets No. 2611 - 16/IЕR dated 01.02.2017. The agreement number was the same as that of the
first agreement, except for the changed date. Executing the terms and conditions of the above agreements and the
contract, M.I. Borzenkov from his account No. 40817840848010178524 opened in the Uralsky branch of JSC
Gazprombank located at the address: Sverdlovsk region, Ekaterinburg, Lunacharskogo str. 134 - v, transferred funds to
the accounts of "QB Capital CY LTD" in the following sequence, based on the dates and amounts of transfers:
06.05.2016 in the amount of USD 500,000; 23.05.2016 in the amount of USD 400,000; 10.06.2016 in the amount of USD
100,000; 26.08.2016 in the amount of USD 500,000; 08.09.2016 in the amount of USD 1,000,000. Also, fulfilling these
agreements and contracts Borzenkov M.I. made subsequent transfers of funds: On 26.01.2017 he transferred funds
from his account No. 40817840848010178524, opened in the Uralsky branch of JSC Gazprombank, located at the
address: Sverdlovsk region, Ekaterinburg, Lunacharskogo str. 134 - v, to QB Capital CY LTD account No.
11800083622101 opened with Anelik Bank in the amount of USD 1,500,000; on 03.02.2017 he transferred funds from
his account No. 40817840848010178524 opened with the Uralsky branch of JSC Gazprombank located at: Sverdlovsk
region, Ekaterinburg, Lunacharskogo str. Ekaterinburg, Lunacharskogo St., 134 - v, to QB Capital CY LTD account No.
RS35105051012100012316 opened with AIK Banka in the amount of USD 1,500,000; 21.02.2017 he transferred funds
from his account No. 40817840848010178524 opened with the Uralsky branch of JSC Gazprombank located at 134 - v
Lunacharskogo St., Ekaterinburg, Sverdlovsk region, to QB Capital CY LTD account No. RS35150007020000052652
opened with Direktna Banka in the amount of USD 1,500,000. Subsequently, on 30.03.2017, in the office of QB
Investment Company LLC, located at 1a Boris Yeltsin St., Ekaterinburg, M.I. Borzenkov signed with QB Capital CY LTD
the Agreement No. 3117 - 17/IЕR dated 30.03.2017, as well as an agreement on the provision of "Trust Management"
services in accordance with Agreement No. 3117 - 17/IER dated 30.03.2017 with "QB Investment Company" LLC
(hereinafer referred to as the Contract and Agreement No. 3117 - 17/IER dated 30.03.2017). Executing the Contract
and Agreement No. 3117 - 17/IER dated 30.03.2017 Borzenkov M.I., made transfers of funds from his account No.
40817840848010178524 opened with the Uralsky branch of JSC Gazprombank located at the address: Sverdlovsk
region, Ekaterinburg, Lunacharskogo str. 134 - v, to the account "QB Capital CY LTD" No. RS35150007020000052652
opened with "Direktna Banka" in the following sequence, based on the dates and amounts of transfers: 20.04.2017 in
the amount of USD 800,000; 24.04.2017 in the amount of USD 200,000; 14.06.2017 in the amount of USD 1,000,000.
Further, on 06.12.2017, in the office of "QBIF Investment Company" LLC, located at the address: 1a Boris Yeltsin St.,
Ekaterinburg, M.I. Borzenkov signed Agreement No. 4148 - 17/IER with "QCCI LTD", a company registered in the
Republic of Cyprus, and an agreement on the provision of "Trustee" services under the agreement (Account 004148)
with "QBIF Investment Company" LLC. Executing Agreement No. 4148 - 17/IER and Agreement (Account 004148)
Borzenkov M.I., Borzenkov M.I., from his account No. 40817840848010178524 opened with the Uralsky Branch of
Gazprombank JSC located at the address: Sverdlovsk region, Ekaterinburg, Lunacharskogo str. 134 - v, made transfers
of funds to QCCI LTD account No. 1570025497880101 opened with Ameriabank in the following sequence, based on
the dates and amounts of the transfers: 07.12.2017 in the amount of USD 2,000,000; 26.01.2018 in the amount of USD
2,000,000; 15.03.2018 in the amount of USD 2,000,000; 23.04.2018 in the amount of USD 2,000,000. The total amount
of money transferred by Borzenkov M.I. was USD 17,000,000. Based on the exchange rate of the US dollar against the
Russian rouble on the dates of the transfer of funds, in total for the above period of time, the employees of LLC
"Investment Company QBF" stole funds in the amount of 1,007,926,000 roubles from Borzenkov M.I.;
(Vol. No. 32, pp. 222 - 228, Vol. No. 323, pp. 5 - 9)
part 4 of article 159 of the Criminal Code of the Russian Federation against Baiguzina S.A.:
- another document - a statement by Baiguzina S.A., in which she asks to bring to criminal responsibility persons from
(Vol. No. 33, pp. 70,74)
904
- Testimony of Baiguzina S.A., given to her as a witness and victim, according to which in November 2017, her mobile
phone received a call from Oleg Vladimirovich Golovnenko, who was previously known to her as a manager of such
banks as "SBERBANK First" and "VTB Private banking". Golovnenko O.V. informed her that he was now the vice -
president of QBF Management Company and offered to come to the company's office, which was located in BC "SPB
PLAZA" (64 B Maloohtinsky Ave., St. Petersburg), to discuss investment opportunities. As Golovnenko O.V. proved to
be a competent and responsible employee of the above - mentioned banks, she came to talk to him at the company's
office, where he suggested investing through trust management services provided by QBF. During the conversation
O.V. Golovnenko repeatedly emphasised the reliability of the "QBF" group of companies and the stable percentage of
income from investment. He assured her that the company has a long and successful experience of work in Russia and
abroad, and also has all necessary licences. Golovnenko O.V. informed her that the reliability of work with the
company is guaranteed by the legislation of the Russian Federation, due to the fact that she will cooperate directly
with Russian organisations, namely: LLC IC "QBF" (INN 7733673955). Afer giving her consent to participate in the
cooperation, the documents were prepared, which she signed on 27.11.2017 in the office of the company "QBF" in the
presence of Vice - President Golovnenko O.V. The documents included: Agreement on the provision of services of
direct access to international stock markets No. 4126 - 17/ISR dated 08.11.2017 - with the Cypriot company "QCCI
LTD", Client Questionnaire, Agreement on provision of "Trust Management" services dated 08.11.2017 - with IC QBIF
LLC (hereinafer referred to as Agreement 1), Appendix No. 1 to Agreement 1 (investment declaration for weighted
average investment strategy), Appendix No. 2 to Agreement 1 (investment declaration for conservative investment
strategy). When asked why a foreign company was present in the documents, she was assured that it was the best
option for investing in US dollars and that QBIF Ltd. would be responsible for the whole process, as according to
clause 10.6 of the Agreement "The Attorney (QBIF Ltd.) shall bear full financial responsibility to the Principal (i.e. her)
in the amount of the sum determined in accordance with the Annexes of the Investment Declaration to this
Agreement". On the same day on 27.11.2017 in the office of "QBF" at the meeting on signing documents she handed
over the sum (in cash) in the amount of 30,000 (thirty thousand) US dollars, which at the exchange rate of the Central
Bank of Russia as of 27.11.2017 is 1,755,954 rubles, for which she received a Cash Receipt Order dated 27.11.2017. In
April 2018, the mobile phone of her husband Baiguzin Evgeny Yakovlevich began to receive calls from Golovnenko O.V.
with urgent recommendations to increase the amount of money invested in view of the collapse in the international
financial market of shares/bonds in order to profitably acquire monetary securities (shares/bonds). On 24.04.2018 in
the office of QBF company in the presence of Golovnenko O.V. was transferred another sum of money (cash) in the
amount of 50 000 (fify thousand) US dollars, which at the exchange rate of the Central Bank of Russia as of 24.04.2018
is 3 088 275 rubles, for which she received a Cash Receipt Order dated 24.04.2018. At the beginning of 2020, she
decided to gradually withdraw the funds, about which she informed the financial advisor (hereinafer referred to as
FS). Due to the departure of Golovnenko O.V. from the company, at that time she had another FS - Efremtsov Artyom.
For several months he persuaded her to delay the withdrawal of funds. As a result, only on 05.06.2020 an order for
withdrawal of funds in the amount of 12 000 (twelve thousand) US dollars was sent to the e - mail of the company's
FS, which at the maximum exchange rate of the Central Bank of Russia for July 2020 is 880 359,60 rubles. In July 2020,
the above amount was received by her in cash in the presence of Artyom Efremtsov in the new office of the company
(BC "Nevskaya Ratusha", Degtyarny per. 11 lit. B, St. Petersburg). She wrote a receipt as a document confirming
receipt of the said amount. Artem Efremtsov further informed her that she had to urgently "re - sign" all contracts due
to the impossibility of further work with the Cypriot company "QCCI LTD", otherwise the QBF company would not
guarantee the withdrawal of funds. At the same time he pointed out that almost all clients under such contracts have
already passed the procedure of signing new documents. The signing of new contracts and new agreements was,
according to the financial advisor, a prerequisite for further work with my securities portfolio. On 03.08.2020 she
signed the following agreements: - Trust management agreement No. D - 963729 - H dated 03.08.2020 (in Russian and
English) - with "White Lake Management Ltd.", Cayman Islands, notification of authorisation and statement of
accession to the Service Agreement of LLC "VL Consulting" No. 963729 - 09 dated 03.08.2020 (hereinafer referred to as
Contract 2), additional agreement No. 1 to Contract 2 (investment declaration for balanced investment strategy),
additional agreement No. 2 to Contract 2 (investment declaration for conservative investment strategy), service
905
agreement No. 4126 dated 04/06/2018 - with "Simtelligence Company Limited. At the same time, it was asked why the
latter agreement has an earlier date that does not correspond to the date of signing the document. To which she did
not receive any specific reply. On 09.04.2021 she sent another notification for withdrawal of funds in the amount of 25
000 (twenty five thousand) US dollars to the email of the financial advisor. I should note that her new financial advisor
was Tetyuev Sergey Alexandrovich. Further for two and a half months she could not get any information about the
withdrawal of the above amount. During this time she provided all the documents according to the list, received by
Tetyuev S.A. to her e - mail, namely: extract from the foreign passport certified by a notary; copy of the passport of the
Russian Federation, translated into English and notarised; dollar details of the bank; reference (characteristic) from
the bank in English; document confirming the origin of funds, translated into English. And only on 24 June Tetyuev
S.A. reported the amount afer the sale of all her assets - 73 (59.1 (Seventy three thousand five hundred and fify nine)
US dollars and 10 cents. Since the portfolio of assets according to Tetyuev S.A. was completely sold out, she filled in
all the necessary documents for withdrawal of this very amount, and not the amount stated earlier. Further, S.A.
Tetyuev sent her the documents to be signed: the control questionnaire "Know Your Client" for "White Lake
Management", application for transfer of funds No. SPB2104008 dated 30.06.2021. On 02.07.2021 these documents
with her signature were sent to the e - mail of Tetyuev S.A. During July and August she repeatedly sent requests (to the
e - mail of Tetyuev S.A. - sergey.tetuev@,gbf.worid and to the mail regionsupport@wl - consulting.ru) with the
question about the date of transfer of funds to her account in the bank. At the same time the representatives of "QBF"
redirected her to my financial advisor, claiming that he had all the information. As a result, S.A. Tetyuev informed her
that the money could not be transferred due to legal difficulties. The total amount of funds she invested for
investment is 80,000 (eighty thousand) US dollars. The total amount of her withdrawn funds is 12,000 (twelve
thousand) US dollars. Her remaining funds of USD 68,000 (sixty - eight thousand), in terms of RUB 3,964,319.40 as of
the date of deposit, are on the side of QBIF IK LLC and/or QCCI LTD and/or VL Consulting LLC and/or White Lake
Management Ltd. and/or Simtelligence Company Limited and/or their counterparties unknown to her. It is not
possible to trace the movement of her funds, as she received information about her investment portfolio only from
the reports sent to her e - mail. The last two reports on her investment portfolio are dated 10.03.2021 and 16.04.2021.
In June 2021, she learnt from the media, as well as official publications of the Ministry of Internal Affairs of Russia, that
criminal proceedings had been initiated and key employees of QBF Group had been arrested for fraud. According to
her knowledge, criminal cases have already been opened against some representatives of QBF Group of Companies
(QBF) for episodes of Trust Management (TM) and money diversion to offshore. Due to massive non - payments to
many other clients since the end of May 2021, as well as the failure to recover monies following the sale of its portfolio
of assets, as well as the criminal cases already pending, there is reason to believe that the withdrawal orders will not
be honoured. The representatives of QBF Group and the financial adviser are unable to explain the situation in
substance. There is every reason to believe that instead of investing the money received from clients on the securities
market, these funds were misused, and the reports provided to clients were "fake". The reports showed a clear
tendency to reduce the amount of the investment portfolio afer the withdrawal orders were given. At the same time,
the withdrawal of funds was delayed. Her financial advisors were/are: Oleg Vladimirovich Golovnenko, tel.
+79112328954, Artyom Efremtsov, tel. +79218581623, Sergey Alexandrovich Tetyuev, tel. +79119683368. Till now her
money, deposited in the cash desk of the group of companies "QBF", as she naively believed at that time for
investment, in the amount of 3 964 319,40 has not been returned to her. She believes that the persons acting on
behalf of the "QBF" group of companies initially did not intend to fulfil their obligations to her and acted solely for the
purpose of stealing her money by deceiving her. In the period from 08.11.2017 to 31.07.2020, the persons acting on
behalf of the "QBF" group of companies stole her money in the total amount of 3,964,319.40 rubles. She considers the
amount of damage caused to her as significant. She has been explained the right to file a civil action in the criminal
case. She wishes to exercise this right and file a lawsuit. She has been explained the right to familiarise herself with
the composition of the investigative teams, with the decisions on the appointment of forensic examinations, with the
conclusions of experts, with the records of expert interrogations, and also to familiarise herself with the materials of
the criminal case in full or in part. She does not wish to exercise this right. She has not applied to the court with
applications for the recovery of funds from the "QBF" group of companies.
(Vol. No. 33, pp. 75 - 80, 187 - 191)
906
- other documents - documents provided by Baiguzina S.A. confirming her relationship with QBF Financial Group
(Vol. No. 33, pp. 81 - 179)
part 4 of article 159 of the Criminal Code of the Russian Federation against Levina G.V.:
- another document - a statement by Levina G.V., in which she asks to bring to criminal responsibility persons from
(Vol. No. 34, l.d. 6)
- The testimony of G.V. Levina, given to her as a witness and victim,

according to which from 2015 to spring 2018 she was a client of the financial group "BKS", she had personal savings
invested and her financial adviser was Alexander Gaponov (8 - 926 - 171 - 86 - 96). In the spring of 2018, A. Gaponov
resigned from BKS and took a job as a financial manager at QBF Group. In turn, he approached her as his old client
and offered to transfer her assets from "BCS" to "QBF" on more interesting terms. She agreed to think about it and
took a pause for reflection. From 16.05.2018 to 18.05.2018 she came for a consultation with A. Gaponov at the
following address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, 9th floor. 1, 9th floor. During the meeting at the
office, A. Gaponov presented the investment products available in the organisation, investment methods, profit
generation mechanism, reporting and client information procedures, as well as the structure of the organisation in
general. She was informed that the funds will be invested in investment platforms of foreign countries. As a result of
the meeting, she finally got the impression that A. Gaponov offers a really reasonable and profitable way of investing
her money and they agreed to meet on Tuesday of the next week, namely on 22.05.2018. On 22.05.2018 she, being in
the office of LLC "IC QBF", located at the address: Moscow, Presnenskaya Naberezhnaya, 8, pp. 1, in order to invest
cash in securities with high yield, she signed an agreement on providing services of direct access to international
stock markets No. 4374 - 18/IMR dated 22.05.2018 with QCCI LTD, and also signed an assignment agreement No. 4374
dated 22.05.2018 with QBCI Advisery LLC. On 22.05.2018, being in the office of QB&EF Investment Company LLC,
located at the following address: Moscow, Presnenskaya Naberezhnaya 8, p. 1, she made a cash transfer to the
company. 1, she made a cash transfer in the amount of USD 20,000, which at the exchange rate of the Central Bank of
the Russian Federation as of 22.05.2018 was RUB 1,250,600. Afer she invested cash in the "QBF" group of companies,
she started receiving reports to her email address [email protected]. The said reports reflected the state of my
investment portfolio. A few days afer signing the documents and transferring the money, she received a call from
Gaponov A. and invited her to the office of the company to sign an additional set of documents. On 04.06.2018 she
came to the company's office at the address: 8 Presnenskaya Naberezhnaya Embankment, 8, bldg. 1, 9th floor,
Moscow, where she signed a service agreement No. 4374 with "Simtelligence Company Limited" represented by
Korshunov D.A. Gaponov A. informed her that this was a certain "technical" moment related to the change of the
financial strategy of the "QBF" group of companies. Being in friendly, even trusting relations with Gaponov A., she
agreed and signed the above mentioned document, without really looking into the essence. Some time later, A.
Gaponov resigned from the "QBF" group of companies, which came as a surprise to her, and she was appointed a new
financial advisor Balayan Ara (8 - 903 - 289 - 69 - 57). Ara would occasionally call her and offer her various financial
products, but she would not agree to anything else. One day, in September 2019, Balayan A. invited her to the
company's office for another re - signing of documents, all for the same reasons. So, on 18.09.2019 she arrived at the
address: Moscow, Presnenskaya Naberezhnaya, 8, bldg. 1, 9th floor, she was met by Balayan A. and provided her with
the following documents to sign: service agreement with VL Consulting LLC and trust management agreement No. D -
719710 - I with White Lake Management Ltd. A. Balyan informed her that this was also necessary in the interests of
QBF's investment strategy. She agreed and signed the said documents. On 09.04.2021, she applied to QBF Group for
907
withdrawal of funds. Balayan A. informed her that she had to prepare a huge list of documents that were allegedly
needed by the foreign partners of "QBF" for withdrawal of funds. On 21.05.2021 she brought these documents and
gave them to Balayan A. to work on. At the end of May 2021 she learned from mass media that a criminal case was
opened, investigative actions were carried out, that the group of companies "QBF" is a pyramid scheme. Till now her
money has not been returned to her, in total 1 250 600 roubles have been transferred to the address of the group of
companies "QBF". She considers the amount of damage caused to her as significant.
(Vol. No. 34, pp. 9 - 12, 19 - 21)
- other documents - documents provided by Levina G.V. confirming her relationship with QBF Financial Group (QBF
(Vol. No. 34, pp. 22 - 121)
part 4 of article 159 of the Criminal Code of the Russian Federation against Naumova E.G.:
- another document - a statement by Naumova E.G., in which she asks to bring to criminal responsibility persons from
(Vol. No. 34, l.d. 136)
- Testimony of Naumova E.G., given to her as a witness and victim, according to which in the middle of 2018 she had
an interest to invest personal funds in the group of companies "QBF" at the example of her husband. Her spouse's
financial advisor was Zorin Artem. It was to Zorin A. that she turned for counselling. They talked about the
forthcoming transaction in general details over the phone in advance and agreed to meet at the head office of the
company. On 20.06.2018, at about 13:00, she arrived at the office of the company "QBF" at the address: Moscow,
Presnenskaya Naberezhnaya, 8, p.1, 9th floor, where they were met by Zorin A. together with his manager Spinka
Ruslan and led them to a meeting room with a cash desk. During the meeting Zorin A. together with Spinka R.
presented to her the investment products available in the organisation, the ways of investment, the mechanism of
profit formation, the procedure of reporting and informing the client, as well as the structure of the organisation in
general. It was explained to her that the money will be invested in the investment platforms of foreign countries and
for this reason the money is required in currency. Everything was presented in a colourful way, devoid of flaws. She
was promised returns of 15% to 20% per annum. It was also explained to her that the company IK QBF LLC had
licences from the Central Bank of the Russian Federation to carry out activities with securities, which gave her
confidence that this company could be entrusted with her money to receive income from brokerage activities .
Zorin A. and Spinka R. had documents already signed by QBF Group of Companies. On 20.06.2018 she, being in the
office of "QBF", signed these documents given to her by Zorin and Spinka, namely: - Direct Access to International
Stock Markets Service Agreement No. 4411 - 18/IMR between her and "QCCI LTD". The agreement was already dated
19.06.2018. At present this agreement is lost, it is not possible to provide a copy of it, as well as the assignment
agreement No. 4411, dated 19.06.2018, between her and "QCCI LTD" represented by General Director Vladimir
Georgievich Frolov, with annexes, service agreement No. 4411 dated 20.06.2018 with "Simtelligence Company
Limited" represented by Korshunov D.A. She believed that she concluded a trust management agreement with "IC
QBF LLC", as she was in the office of this company, communicated with its representatives, and did not pay attention
to the fact that the agreements were signed on behalf of other companies. Afer signing the above documents, on the
same day, 20.06.2018, she, being in the office of the company "QBF", within the framework of the concluded
agreements and contracts, personally handed over to Spinka R. the money in the amount of 1,900,000 rubles. Spinka
R. counted the money on a counting machine and then lef the meeting room with the money. He then returned with
a receipt for the cash receipt order in hand, which he handed to her. The receipt states that on 20.06.2018 the
908
representative of the company "QCCI LTD" Gorobets E.V. accepted 1,900,000 rubles from her. Neither Gorobets E.V.,
nor Korshunov D.A., nor Frolov V.G. she has never personally seen or communicated with. She would like to add that
she did not really look into the documents she signed, as her family had previously cooperated with "QBF" and they
trusted the financial advisors. Afer she invested in the QBF Group of Companies, she started receiving reports to her e
- mail address [email protected], which she received until January 2021. These reports reflected the state of her
investment portfolio. During the whole time she repeatedly changed her financial advisors, afer Zorin A. appeared
Laipanov Egor, followed by Danilenko Maxim. All this time these persons were subordinates of Spinka R. It should also
be noted that she twice applied for withdrawal of funds and she was indeed withdrawn small amounts: 04.04.2019
she was paid USD 1,500, which at the exchange rate of the Central Bank of the Russian Federation on the date of issue
was 97,740 rubles (USD exchange rate as of 04.04.2019 was 65.16 rubles); 21.10.2019 she was paid USD 1,200, which at
the exchange rate of the Central Bank of the Russian Federation on the date of issue was 76,740 rubles (USD exchange
rate as of 21.10.2019 was 63.95 rubles). In total, she was refunded cash in the total amount of 174,480 rubles. On
24.12.2019, at the personal request of Spinka R., she came to the office of the company "QBF" at the address: Moscow,
Presnenskaya Naberezhnaya, 8, p.1, 9th floor, in order to re - sign the documents, as Spinka informed her. On
24.12.2019, she signed the following documents handed over to her by Spinka R.: "Trust Management" agreement No.
D - 004031 - L between her and the company "White Lake Management Ltd" represented by the same Korshunov D.A.,
the agreement is dated 23.12.2019, service agreement between her and LLC "VL Consulting" (standard form of
accession agreement) represented by Maricheva O.V., dated 23.12.2019, as well as some other documents handed
over to her by Spinka R. (these documents are attached to the present interrogation protocol).The said documents she
signed as she trusted Spinka R. and due to the fact that Spinka R. said that infrastructural changes were taking place
in the group of companies and it was just necessary to re - sign the documents as a formality. According to Spinka R.,
the quality of work and safety of her invested money will not be affected. At the beginning of July 2020, for personal
reasons, she had the need to withdraw her funds from the "QBF" group of companies in full. In this connection, on
13.07.2020 she came to the main office of the company "QBF" at the address: Moscow, Presnenskaya naberezhnaya,
8, page 1, 9th floor, where she submitted an application for withdrawal of funds. To date, the funds under this
application have not been returned to her, not even partial amounts for withdrawal have not been provided. On all
questions regarding such a long delay in withdrawal of funds, Spinka R. referred to the most conceivable and
unthinkable reasons, asked to collect an insane list of documents and other excuses. They even filed available claims,
but to no avail. Later, in late May - early June 2021, she learned from the media, including the official news of the
Russian Ministry of Internal Affairs, that criminal cases had been opened and an investigation was underway. Taking
into account the specifics of communication with managers, problems in withdrawing funds, and the fact that the
money was not returned to her in full, she had no doubt that she had been a victim of fraudsters. To date, her money
has not been fully returned to her. A total of 1,900,000 roubles was transferred to the QBF group of companies. The
money in the amount of 174,480 roubles has been returned to her. The QBF Group of Companies has not returned to
her money in the amount of 1,725,520 roubles. She believes that an offence has been committed against her, namely
the thef of her money by deception and breach of trust in the amount of 1,900,000 roubles. She considers the amount
of damage caused to her as significant;
(Vol. No. 34, pp. 139 - 142, 150 - 154)
- other documents - documents provided by Naumova E.G. confirming her relationship with QBF Financial Group
(Vol. No. 34, pp. 155 - 249, Vol. No. 35, pp. 1 - 9)
part 4 of article 159 of the Criminal Code of the Russian Federation against Danilov A.V.:
- another document - a statement by Danilov A.V., in which he asks to bring to criminal responsibility persons from
909
(Vol. No. 35, pp. 22, 26)
Danilov A.V.'s Testimony

as a witness and victim, according to which in April 2016, his mobile phone number received a call from Bogdanov
Kirill Bogdanov (tel. 8 - 921 - 858 - 16 - 28), an employee of the company "QBF", with an offer of cooperation by
investing in their products. He was interested and on 11 May 2016 he came to their office located at the address: St.
Petersburg, Maloohtinsky pr, 64B, 9th floor. There he listened to the proposal of Bogdanov K., afer which he
concluded with non - resident "QB Capital CY LTD" ("QB Capital CY LTD") the Agreement on provision of services of
direct access to international stock markets No. 2623 - 16/ISR dated 11.05.2016, as well as on behalf of "IC QB&Ef" LLC
the Agreement on provision of "Trust management" services in accordance with the Agreement on provision of
services of direct access to international stock markets No. 2623 - 16/ISR dated 11.05.2016. At that time, he did not
have extra cash, so he started co - operating with "QBF" only in June 2017. In the period from 07.06.2017 to
26.06.2018, being in the office of LLC "IK "QBF", located at the address: St. Petersburg, Maloohtinsky pr, 64, lit. B (BC
Plaza SPb), he handed over cash to an employee of LLC IC QBF, namely: 07.06.2017 in the amount of RUB 600,000;
28.08.2017 in the amount of RUB 2,100,000; 21.12.2017 in the amount of RUB 1,655,000; 26.06.2018 in the amount of
RUB 630,000. Starting from July 2017, he began to receive reports on the purchase of securities on his account. The
reliability of this data he cannot confirm or deny. At the end of 2018, through his financial advisor Bogdanov K., he
applied for a withdrawal of funds in the amount of 11,479 (eleven thousand four hundred and seventy - nine) US
dollars. In early 2019, he received the above amount from the hands of Martsenyuk E. at the company's office. In June
2020, Bogdanov K. called him and asked him to re - sign the contract concluded between me and the company "QBF".
He gave the reason for the re - signing as "change of jurisdiction and legislation". Thus, on 25 June 2020 in the already
new office of the company, located at the address: Degtyarny pereulok. 11 lit.B, pom.1 - H, BC "Nevskaya Ratusha"
was re - signed the contract with the company "LLC QCCI" to "White Lake Management" (Cayman Islands) Hong Kong
"Simtelligence". On 24 November 2020, he was sent a notification letter to the mailbox of "QBF" regionsupport@wl -
consulting.ru requesting a withdrawal of US$20,000 (twenty thousand). On 30 December 2020, he received a
notification from regionsupport@wl - consulting.ru that there was a sale of a block of shares for the above amount,
i.e. for the USD 20,000 (twenty thousand) he requested. On 07 April 2021 in the office of the company Moskaluk
Dmitriy handed him 5 000 (five thousand) US dollars, i.e. a quarter of the previously requested amount. In return, he
signed a receipt for this money. He was promised to pay the rest of the sum within two months, i.e. by the end of May.
On 11 March 2021 he sent a notification letter to the mailbox of the company "QBF" regionsupport@wl - consulting.ru
with a request to withdraw funds from "White Lake Management" (Cayman Islands) to the Russian jurisdiction to the
warehouse real estate funds "RIF" in the amount of 6 327 012 (six million three hundred twenty seven thousand
twelve) rubles. On 28 April 2021, the sale of this package was completed, but neither the transfer to the Russian
jurisdiction nor the transfer of funds took place. At that time, he saw information in the media that criminal cases had
been opened and investigations were underway against employees and managers of the QBF Group. This confirmed
his thoughts that he had become a victim of fraudsters. To date, he has not been returned his money deposited in the
cash desk of the "QBF" group of companies, as he naively believed at the time for investment, in the amount of
3,831,802.03 rubles. He believes that the persons acting on behalf of the group of companies "QBF" initially did not
intend to fulfil their obligations to him and acted solely for the purpose of stealing his money by deceiving him. In the
period from 07.06.2017 to 26.06.2018, the persons acting on behalf of the "QBF" group of companies stole money
belonging to him in the total amount of 3,831,802.03 rubles. He considers the amount of damage caused to him as
significant. He has been explained the right to file a civil action within the framework of the criminal case. He wishes
to exercise this right and file a lawsuit. He has been explained the right to familiarise himself with the composition of
the investigation teams, with the decisions on the appointment of forensic examinations, with the conclusions of
experts, with the protocols of interrogations of experts, as well as to familiarise himself with the materials of the
criminal case in full or in part. He does not wish to exercise this right. He has not applied to the court for the recovery
of money from the group of companies;
(Vol. No. 35, pp. 27 - 30, 99 - 102)
910
- other documents - documents provided by A.V. Danilov confirming his relationship with QBF Financial Group (QBF
(Vol. No. 35, pp. 33 - 94)
part 4 of article 159 of the Criminal Code of the Russian Federation against Krechetova T.O.:
- another document - a statement by T.O. Krechetova, in which she asks to bring to criminal responsibility persons
(Vol. No. 35, pp. 119,121)
- Testimony of T.O. Krechetova, given to her as a witness and victim,

according to which in January 2018, her mobile phone number received a call from an employee of the group of
companies "QBF" Bogdanov Kirill (tel. 8 - 921 - 858 - 16 - 28) with an offer of additional income by allegedly investing
in financial products of the group of companies "QBF". Bogdanov K. persuaded her to come to the office of the group
of companies "QBF" to receive additional information. When she arrived at the office of the group of companies "QBF"
at the address: St. Petersburg, Maloohtinsky prospect, 64B, she was met by Bogdanov K., who began to convince her
in every possible way, persuade her to deposit money and mislead her about the legality of their activity, about the
possibility of high earnings from investments and so on. She believed the words of Bogdanov K. and trusted him. On
31.01.2018 in the office of the group of companies "QBF" at the address: St. Petersburg, Maloohtinsky Ave, 64B, with
the purpose, as she believed at that time, of investing money in securities, she concluded the Agreement on rendering
services of direct access to international stock markets No. 4213 - 17/ISR dated 13.11.2017 with "QCCI LTD" ("QCCI
LTD") and also entered into a "Trustee Services Agreement" with "QBIF IK LLC" pursuant to the Direct Access to
International Stock Markets Services Agreement No. 4213 - 17HSR dated 13.11.2017. Having trusted Bogdanov K., an
employee of QBF Group of Companies, and being in a state of delusion, on 31.01.2018 being in the office of QBF Group
of Companies at the address: St. Petersburg, Maloohtinsky prospect, 64B, in the presence of Bogdanov K., she
deposited her own funds in the amount of 1,400,000 (one million four hundred thousand) rubles into the cash desk of
QBF Group of Companies. The head of the client office of the group of companies "QBF" Golubev Alexey Sergeevich
took the money from her. In order to mislead him and give the appearance of legal activity Golubev A.S. gave him a
receipt to the receipt order № b/n dated 31 January 2018. Trusting the employee of the group of companies "QBF"
Bogdanov K. and being in a state of delusion 29.06.2018 being in the office of the group of companies "QBF" at the
address: St. Petersburg, Maloohtinsky prospect, 64B, in the presence of Bogdanov K., she deposited in the cash desk
of the group of companies "QBF" - own money in the amount of 550 000 (five hundred fify thousand) rubles. In order
to mislead her and give the appearance of legitimate activity Golubev A.S. gave her a receipt to the receipt order No.
b/n dated 29 June 2018. Starting from January 2018, she received reports allegedly on the purchase of securities with
her invested funds. In April 2019, she approached Bogdanov K. about receiving her profits from her invested monies.
Bogdanov K. said that QBF Group could pay her USD 1,250 (one thousand two hundred and fify), which was allegedly
received as profit from the monies she had contributed. On 21.04.2019 in order to convince her of the legality and
profitability, thus misleading her, Bogdanov K. gave her 250 (one thousand two hundred and fify) US dollars in hand,
which at the exchange rate of the Central Bank of Russia as of 21.04.2019 is 79 950,25 rubles. The transfer of funds was
in the office of the group of companies "QBF" at the address: St. Petersburg, Degtyarny per. 11 lit. B, pom.1 - H. In
December 2019, she approached Bogdanov K. about receiving her profit from the invested money. Bogdanov K. said
that the group of companies "QBF" could pay her 1 250 (one thousand two hundred and fify) US dollars, which were
allegedly received as profit from the money she had contributed. On 10.12.2019, in order to convince her of the
legality and profitability, thus misleading her, Bogdanov K. gave him 1,250 (one thousand two hundred and two
911
hundred and fify) US dollars, which at the exchange rate of the Central Bank of the Russian Federation as of
10.12.2019 amounted to 79,655.50 rubles. The transfer of funds was in the office of the group of companies "QBF" at
the address: St. Petersburg, Degtyarny per. 11 lit. B, pom.1 - H. In approximately May 2021, she approached Bogdanov
K. about the full return of her funds. Bogdanov K. began to deceive her about the terms of returning the money, began
to delay the terms and invent various reasons for not returning the money. Afer that she began to demand from
Bogdanov K. the return of her money on a regular basis, but he (Bogdanov K.) continued to deceive her and mislead
her in every possible way about the return of her money. At that moment she realised that she had become a victim of
fraudsters and was simply deceived to steal her money. At that time, she saw information in the media that criminal
cases had been opened and investigations were underway against employees and managers of the QBF group of
companies. This confirmed her thoughts that she was a victim of fraudsters. To date, she has not been returned her
money deposited in the cash desk of the "QBF" group of companies, as she naively believed at the time for
investment, in the amount of 1,790,394.25 rubles. She believes that the persons acting on behalf of the "QBF" group
of companies initially did not intend to fulfil their obligations to her and acted solely for the purpose of stealing her
money by deceiving her. In the period from 31.01.2018 to 29.06.2018, the persons acting on behalf of the "QBF" group
of companies stole her money in the total amount of 1,790,394.25 rubles. I estimate the amount of damage caused to
her as significant. She has been explained the right to file a civil action within the framework of the criminal case. She
wishes to exercise this right and file a lawsuit. She has been explained the right to familiarise herself with the
composition of the investigative teams, with the decisions on the appointment of forensic examinations, with the
applications for the recovery of funds from the "QBF" group of companies;
(Vol. No. 35, pp. 122 - 124, 161 - 164)
- other documents - documents provided by T.O. Krechetova confirming her relationship with QBF Financial Group
(Vol. No. 35, pp. 127 - 156)
part 4 of article 159 of the Criminal Code of the Russian Federation against Ostovich E.N.:
- another document - a statement by E.N. Ostovich, in which she asks to bring to criminal responsibility persons from
among the employees and managers of the financial group "QBF" (LLC "Investment Company QBF"), who stole her
(Vol. No. 35, pp. 176,180)
- The testimony of Ostovich E.N., given to her as a witness and victim,

according to which approximately in November - December 2017, her mobile phone number received a call from the
financial advisor of the group of companies "QBF" Chernyshova Natalia Anatolievna (tel. 8 - 921 - 858 - 16 - 18) with an
offer of additional income by allegedly investing in financial products of the group of companies "QBF". By telling her
about the possibility of earning money Chernyshova N.A. persuaded her to come to the office of the group of
companies "QBF" to get additional information. When she arrived at the office of the group of companies "QBF" at the
address: St. Petersburg, Maloohtinsky prospect, 64B, business centre "Plaza" she was met by Chernyshova N.A., who
began to persuade her in every possible way, persuade her to deposit money and mislead her about the legality of
their activities, about the possibility of high earnings from investments and so on. She believed the words of
Chernyshova N.A. and trusted her. 28.12.2017 in the office of the group of companies "QBF" at the address: Saint -
Petersburg, Maloohtinsky pr, 64B, with the purpose, as she believed at that time, of investing money in securities, she
concluded the Agreement on rendering services of direct access to international stock markets No. 4186 - 17/ISR
912
dated 11.11.2017 with "QCCI LTD" ("QCCI LTD") and also entered into a Trustee Services Agreement with "QBIF IK LLC"
pursuant to the Direct Access to International Stock Markets Services Agreement No. 4186 - 17/ISR dated 11.11.2017.
Having trusted the employee of the group of companies "QBF" Chernyshova N.A. and being in a state of delusion, on
28.12.2017 being in the office of the group of companies "QBF" at the address: St. Petersburg, Maloohtinsky prospect,
64B, in the presence of Chernyshova N.A., she deposited in the cash desk of the group of companies "QBF" her own
funds in the amount of 600 000 rubles. The money was taken from her by an employee of the "QBF" group of
companies, whose details she does not know. In order to do so, the said employee of the group of companies "QBF"
gave her a receipt to the receipt order No. b/n dated 28 December 2017 for 600,000 rubles. Having trusted the
employee of the group of companies "QBF" Chernyshova N.A. and being in a state of delusion. 04.07.2018 being in the
office of the group of companies "QBF" at the address: St. Petersburg, Maloohtinsky pr., 64B, in the presence of N.A.
Chernyshova, she deposited her own money in the amount of 630 000 rubles in the cash desk of the group of
companies "QBF". The money was taken from her by an employee of the "QBF" group of companies, whose details
she does not know. In order to mislead her and make what was happening look like a legitimate activity, the said
employee of the "QBF" group of companies gave her a receipt to the receipt order No. b/n dated 04 July 2018 for
630,000 rubles. In May 2021, she approached Chernyshova N.A. regarding the full return of her funds to her.
Chernyshova N.A. began to deceive her about the terms of returning the money, began to delay the terms and come
up with various reasons not to return the money. Since nothing happened afer her demand for the return of the
money - she did not get the money back, she0 started to demand from Chernyshova N.A. the return of her money on a
regular basis, but she (Chernyshova N.A.) stopped answering her calls and sms messages. At the end of June 2021, she
went to the office of the "QBF" group of companies at the address: St. Petersburg, Degtyarny pereulok, ul. 11, lit. B, in
order to investigate what was going on. She found that the office of the group of companies "QBF" was missing, at the
entrance of the business centre she was told that the group of companies "QBF" had moved out in an unknown
direction. At that moment she realised that she had become a victim of fraudsters and was simply deceived in order to
steal her money. She began to look for information in the media, where she read that criminal cases had been opened
and investigations were underway against the employees and managers of the "QBF" group of companies. This
confirmed her thoughts that she was a victim of fraudsters. To date, her money deposited in the cash desk of the
"QBF" group of companies, as she naively believed at the time for investment, in the amount of 1,230,000 roubles has
not been returned to her. She believes that the persons acting on behalf of the group of companies "QBF" initially did
not intend to fulfil their obligations to her and acted with the sole purpose of stealing her money by deceiving her. In
the period from 28.12.2017 to 04.07.2018, the persons acting on behalf of the "QBF" group of companies stole her
money in the total amount of 1,230,000 rubles. She assesses the amount of damage caused to her as significant. She
has been explained the right to file a civil action in the criminal case. She wishes to exercise that right and file a
lawsuit. She has been explained the right to familiarise herself with the composition of the investigative teams, with
the decisions to order forensic examinations, with the conclusions of experts, with the transcripts of expert
interrogations, and also to familiarise herself with the materials of the criminal case in full or in part. She does not
wish to exercise this right;
(Vol. No. 35, pp. 181 - 184, 237 - 240)
- other documents - documents provided by E.N. Ostovich, confirming her relationship with QBF Financial Group
(Vol. No. 35, pp. 186 - 232)
part 4 of article 159 of the Criminal Code of the Russian Federation against Drobin V.M.:
- another document - a statement by V.M. Drobin, in which he asks to bring to criminal responsibility persons from
(Vol. No. 36, l.d. 6)
913
- The testimony of V.M. Drobin, given by him a ss, the s a witne victim
, according to which approximately in 2017 he found information on the Internet regarding the group of companies
"QBF". He was interested in the published materials, in particular investments in securities of stock markets of foreign
countries. He called the general telephone number and lef his contacts there. Later he was contacted by a manager of
the "QBF" group of companies named Sirotuk Bogdan with a proposal for co - operation, in particular investments in
securities of stock markets of the Russian Federation and foreign countries. At first he did not give an unambiguous
answer, but began to make enquiries in the Internet about the group of companies "QBF". Having studied the
information from various Internet resources he decided to go to the meeting to confirm his interests. He contacted the
manager named Sirotyuk B. and they agreed on a meeting. Thus, from 15 to 20.10.2017 he came twice to the office
located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p.1, 9th floor. Upon arrival, he was met by Sirotiuk B.
and escorted to a meeting room. B. Sirotyuk presented to him the investment products available in the organisation,
the methods of investment, the mechanism of profit formation, the procedure of reporting and informing the client,
as well as the structure of the organisation in general. He was informed that the funds would be invested in
investment platforms of foreign countries. As a result of the above meetings, as well as relying on the entreaties and
stories of Sirotiuk B., he informed that he was ready to invest in the group of companies "QBF". On 24.10.2017 he,
being in the office of LLC "IK "QBF", located at the address: Moscow, Presnenskaya naberezhnaya, 8, bld. 1, for the
purpose of investing funds in securities, he signed an agreement with QCCI LTD ("QCCI LTD") on the provision of
services of direct access to international stock markets No. 3994 - 17/IMR dated 24.10.2017, and also signed an
agreement on the provision of "Trust management" services in accordance with the agreement on the provision of
services of direct access to international stock markets No. 3994 - 17/IMR dated 24.10.2017 with IC QBiEf LLC. Afer
that, he, being in the office of IK QBF LLC, located at the address: Moscow, Presnenskaya Naberezhnaya 8, p. 1,
realised the transfer of cash as follows: 30.10.2017 in the amount of RUB 500,000; 31.10.2017 in the amount of RUB
300,000; 25.07.2018 in the amount of RUB 1,000,000. Afer he invested funds in the "QBF" group of companies, he
started receiving reports to his email address volodimir.drobinyandex.ru, which are still being received. These reports
reflect the state of his investment portfolio. Periodically, he received calls from Sirotiuk B., who offered him to invest
additional funds, as well as to think about purchasing additional financial products of the group of companies "QBF".
At the beginning of June 2018, he was contacted by Sirotiuk B. and asked to come to the office of the company to sign
technical documents. So, on 04.06.2018 at about 14:00 he arrived at the company's office at the address: Moscow,
Presnenskaya Naberezhnaya, 8, p.1, 9th floor, where he was also met by Sirotyuk B. and escorted to the meeting
room. Later, Spinka R. came as usual and informed him that due to the modification and development of the
investment strategy of the QBF Group of Companies he had to sign new documents of technical nature. So he signed
service agreement No. 3994 dated 04.06.2018 with "Simtelligence company Limited". At the end of 2020 he had a
change of financial advisor, he became Danilenko Maxim. At the beginning of April 2021, he was again contacted by
Danilenko M. and asked to come to the company's office to sign technical documents. Thus, on 16.04.2021, at
approximately 15:00, he arrived at the company's office at 8 Presnenskaya Naberezhnaya Street, bldg. 1, 9th floor,
Moscow, where he was met by Danilenko M. and escorted to a meeting room. Danilenko M. informed him that the
return of funds from trading account No. 3994 - 17/IMR was possible only afer signing a new "Trust Management"
agreement with White Lake Management Ltd. So he signed the "Trust Management" agreement No. D - 946255 - D
with "White Lake Management Ltd." represented by D.A. Korshunov, an application on joining the service agreement
No. 946255 - 01 dated 16.04.2021. Later, in late May, early June 2021, he learned from the media, including official
news of the Russian Ministry of Internal Affairs, that criminal proceedings had been initiated and an investigation was
underway. In addition, he contacted M. Danilenko and he confirmed the above information to him. Taking into
account the specifics of communication with managers, problems with withdrawal of funds, as well as the fact that
the money was not returned to him, he had no doubts that he had become a victim of fraudsters. In the period from
30.10.2017 to 25.07.2018 he transferred to the group of companies "QBF" the money belonging to him in the amount
of 1 800 000 rubles. There were no returns of the funds to him. He estimates the amount of damage caused in the
amount of RUB 1,800,000 as significant;
914
(Vol. No. 36, pp. 9 - 13, 18 - 21)
- other documents - documents provided by V.M. Drobin confirming his relationship with QBF Financial Group (QBF
(Vol. No. 36, pp. 22 - 86)
part 4 of article 159 of the Criminal Code of the Russian Federation against Kilo V.A.:
- another document - a statement by Kilo V.A., in which he asks to bring to criminal responsibility persons from
(Vol. No. 36, l.d.99)
- The testimony of Kilo V.A., given by him as a witness and victim

, according to which in July 2017 he received an advertising call on his mobile phone number from a representative of
the group of companies "QBF" named Leonid Sukharev with a proposal for cooperation, in particular investments in
securities of stock markets of foreign countries. At first he did not give an unambiguous answer, but began to make
enquiries for himself on the Internet about the QBF group of companies. In April 2016, his mobile phone received a
call from a manager of the "QBF" group of companies, who introduced himself as Andrei Yeshkeev. The conversation
was of an advertising and introductory nature, during which Andrei explained that QBF was an investment company
that had a long and successful track record in Russia and abroad. All necessary licences are available, and he also
informed him that the reliability of work with QBF Group is guaranteed by the legislation of the Russian Federation,
due to the fact that he will cooperate directly with a Russian organisation, namely, with QBF IK LLC. Moreover, in open
sources of the Internet he saw information that LLC "IK QBF" has 4 licences of the Central Bank of Russia, namely: the
licence for brokerage activities №045 - 12805 - 100000 from 24.12.12.2009, licence for dealer activity #045 -
12816010000 dated 24.12.2009, licence for securities management #045 - 12828 - 001000 dated 24.12.2009 and licence
for depository activity #045 - 14078 - 000100 dated 08.08.2019. During the conversation, Andrey Yeshkeev offered to
invest in various exchange products, was very convincing and persistent. At the end of the conversation, Andrey
invited him to the office of 2IC QBF LLC, located at: Moscow, 8 Presnenskaya Naberezhnaya St., p. 1. 1. At the
beginning of May 2016, he arrived at the office of QBF Group, located at 8 Presnenskaya Naberezhnaya St., p. 1,
Moscow, where he took part in a conversation. 1, where he took part in a conversation with QBF employees (Andrey
Eshkeev and another employee, whose details he found difficult to give). The conversation was mostly conducted by
Andrey Yeshkeev, who voiced a number of proposals on investing money by investing in securities, derivatives and
other instruments. The employees of the group of companies "QBF" were persuasive and persistent, in connection
with which, among other things, he agreed to participate in investing in securities. At this conversation he was given
printouts of advertising offers. On 24.05.2016 he, being in the office of LLC "IC QBF", located at the address: Moscow,
Presnenskaya naberezhnaya, 8, p. 1, with the purpose of investing funds in securities. 1, for the purpose of investing
funds in securities with high yield, signed with QB Capital CY LTD ("QB Capital CY LTD") an agreement on providing
services of direct access to international stock markets No. 2650 - 16/IMR dated 23.05.05.2016 and also signed an
agreement for providing "Trustee" services under Direct Access to International Stock Markets Services Agreement
No. 2650 - 16/IMR dated 23.05.2016 with QCB Capital CYF Ltd. Aferwards, on different dates, being in the office of "IC
QBF" LLC, located at the address: Moscow, Presnenskaya Naberezhnaya 8, p. 1. 1, within the framework of the
concluded contract and agreement, he transferred cash and made transfers as follows: On 24.05.2016 he made a bank
transfer of funds from his current account No. 40817810201000936854 opened with JSC Raiffeisenbank at the
address: Moscow, Kutuzovsky pr. 34, page 14, to the settlement account "QB Capital CY LTD" ("QB Capital CY LTD") No.
CY240140010101010101150011705010 opened with "The Cyprus Development Bank" (Cypress Development Bank,
Republic of Cyprus) in the amount of RUB 1,000,000; At the office of QBF he handed over the cash to the employees of
915
QBF: 28.10.10.2016 in the amount of RUB 1,000,000 and USD 4,000, which at the exchange rate of the Central Bank of
the Russian Federation as of 28.10.2016 was RUB 252,160, 23.01.2017 in the amount of EUR 10,000, which at the
exchange rate of the Central Bank of the Russian Federation as of 23.01.2017 was RUB 637,300, 28.03.2017 in the
RUB 1,083,380, 28.07.2017 in the amount of EUR 32,000, which at the exchange rate of the Central Bank of the Russian
Federation as of 28.03.2017 was RUB 2,228,480, 28.06.2018 in the amount of USD 8,000, which at the exchange rate of
the Central Bank of the Russian Federation as of 28.06.2018 was RUB 505,120 and EUR 13,450, which at the exchange
rate of the Central Bank of the Russian Federation as of 28.06.2018 was RUB 989,920, 31.07.2018 in the amount of RUB
80,000 and EUR 4,500, which at the exchange rate of the Central Bank of the Russian Federation as of 31.07.2018 was
RUB 329,400. Afer depositing the funds, he was given receipts for cash receipts signed by Gorobets, but he has not
seen the person by the name of Gorobets, he is not familiar with him. Around the end of 2018 he changed his financial
advisor to Ara Balayan, due to the fact that Abdukadyrov Abas transferred to work in JSC "BCS Bank". On 24.07.2020
he was invited to the office of the organisation by Ara Balayan and Artur Aganisyan, who introduced himself as a
lawyer of "QBF" group of companies. Upon arrival, the above mentioned persons explained to him that it was
necessary to sign a new package of documents, namely: Trust Management Agreement No. D - 657758 - G dated
24.07.2020 with "White Lake Management Ltd." represented by D.A. Korshunov, its annexes, additional agreement,
authorisation notice, application for accession, investment declarations. He signed the said documents. Throughout
his communication with the financial advisors, they explained to him that the money he had invested was in safe
hands, and repeatedly offered him various products for investment. Reports were sent to him monthly to his email
address: [email protected]. Around the end of 2021, he learnt from the media and official publications of the
Russian Ministry of Internal Affairs that criminal proceedings had been initiated and key employees of QBF Group had
been arrested for fraud. The QBF employees did not explain anything clearly to him about this fact, as well as about
the ways and possibilities of withdrawal of funds. Taking into account the above - mentioned, as well as the fact that
to date the funds have not been returned to him, he believes that the money he invested has been stolen. An offence
has been committed against him, namely embezzlement of funds through deceit and breach of trust. According to the
reports submitted to him, the money in the amount of 8,105,760 roubles was spent on the purchase of structural
products. However, these funds were not returned to him. In total, between 24.05.2016 and 31.07.2018, he transferred
to the "QBF" group of companies as an investment in the amount of RUB 8,105,760. There were no returns of the
funds to him. He assesses the damage caused to him by the offence in the amount of RUB 8,105,760 as significant;
(Vol. No. 36, pp. 102 - 107, 204 - 207)
- other documents - documents provided by Kilo V.A. confirming his relationship with QBF Financial Group (QBF
(Vol. No. 36, pp. 108 - 185, 208 - 218)
part 4 of article 159 of the Criminal Code of the Russian Federation against Emirgamzaev V.E.:
- another document - a statement by Emirgamzaev V.E., in which he asks to bring to criminal responsibility persons
(Vol. No. 37, l.d. 6)
- V. E. Emirgamzaev's testimony, given by him as a witness and victim,

according to which in 2014, on the recommendation of his acquaintance, he went to the office of the "QBF" group of
companies at 8 Presnenskaya Naberezhnaya St., page 1, Moscow, where he met his financial advisor Pavel
Dzhimamuradov (8 - 967 - 047 - 34 - 26, 8 - 915 - 245 - 27 - 22 - 22), who offered to invest in various stock exchanges and
products. 1, where he met his financial advisor Pavel Jimamuradov (8 - 967 - 047 - 34 - 26, 8 - 915 - 245 - 27 -
22), who offered to invest in various stock exchange products, he was very persuasive and persistent. Due to the fact
916
that his acquaintance, who recommended the company "QBF", had successfully invested since 2013, and also
successfully withdrew the invested funds, there were no doubts about the honesty of the company at the time of
investment. Pavel offered him to visit the office of the group of companies "QBF" in order to sign contracts and
deposit money as investments, and he also guaranteed the income from these investments. Afer that, he arrived at
the office of the group of companies "QBF" at the address of Moscow, Presnenskaya Naberezhnaya St., 8, p. 1, where
Pavel Jimamura arrived at the office of the group of companies "QBF". 1, where Pavel Dzhimamuradov made a
number of offers to invest money by investing in securities. At this meeting Pavel was persuasive and persistent, so he
agreed to participate in investing in securities on international financial markets. Later on, all consultations on
financial products were conducted with him by Vladimir Maslenikov. On 07.08.2014 he, being in the office of LLC
"Qubey Finance", located at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, with the purpose of further
investment of money. 1, with the purpose of further investing monetary funds in securities with high yield, he signed
an agreement on provision of services of direct access to international stock markets No. 1753 - 14/IMR dated
07.08.2014 with QB Capital CY LTD ("QB Capital CY LTD"), and also signed an agreement on provision of "Trust
management" services in accordance with the agreement on provision of services of direct access to international
stock markets No. 1753 - 14/IMR dated 07.08.2014 with QB Finance LLC. He decided to deposit funds under the
concluded contract and agreement only in 2017. Further, he, being in the office of QBIF LLC, located at the address:
Moscow, Presnenskaya Naberezhnaya 8, pg. 1, made a cash transfer as follows: 03.04.2017 in the amount of 100,000
rubles, 03.04.2017 in the amount of 8,200 US dollars, which at the exchange rate of the Central Bank of the Russian
Federation as of 03.04.2017 was 458,872 rubles. 07.04.2017 in the amount of RUB 500,000, 11.07.2017 in the amount
of USD 600, which at the exchange rate of the Central Bank of the Russian Federation as of 11.07.2017 was RUB 36,180,
11.07.2017 in the amount of RUB 390,000, 25.12.2017 in the amount of RUB 400,000, 13.04.2018 in the amount of RUB
100,000, 13.04.2018 in the amount of RUB 1,000,000, 13.04.2018 in the amount of USD 6,500, which at the exchange
rate of the Central Bank of the Russian Federation as of 13.04.2018 was RUB 403,455, 30.05.2018 in the amount of USD
600, which at the exchange rate of the Central Bank of the Russian Federation as of 30.05.2018 was RUB 37,584,
30.05.2018 in the amount of RUB 1,775,000, 18.07.2018 in the amount of RUB 1,700,000, 02.08.2018 in the amount of
RUB 600,000. Afer each cash deposit, he was given receipts to cash receipts for the respective amounts. I would like to
clarify that in the receipt dated 02.08.2018, when he deposited 600,000 rubles, the basis is "crediting in rubles under
the contract No. 3121 - 17/IMR dated 03.04.2017", which does not correspond to reality and is apparently a technical
error of the QBF employee who issued this receipt. The money was deposited on 02.08.2018 under contract No. 1753 -
14/IMR dated 07.08.2014. Afer he invested the funds in QBF Group of Companies, he started receiving reports on his
email address. The said reports reflected the status of his investment portfolio. Thereafer, the funds were in his
investment account, he had no need to withdraw or withdraw the funds until 2019. In early 2019 until January 2021,
he began correspondence and negotiations to withdraw funds from his account. He negotiated with Vladimir
Maslennikov who initially suggested not to withdraw the funds, arguing that now the markets will grow and he
(Emirgamzaev) will get additional benefit, later he said that it is better not to withdraw the funds because now there
are delays in withdrawal from the Hong Kong stock exchange, but he (Emirgamzaev) insisted on withdrawing his
funds. In order to withdraw his funds, he was given a list of necessary documents to submit to the QBF office at 8
Presnenskaya Naberezhnaya St., p. 1, Moscow. 1 to withdraw funds from the foreign exchange. From 2019 to 2021 he
tried to withdraw funds from his account and initially all negotiations with him were conducted by Vladimir
Maslenikov, afer which he informed him (Emirgamzaev) that his assistant Olga Bataeva (8 - 964 - 530 - 33 - 56) was in
charge of withdrawing funds and offered him to transfer his investments to ZPIF instead of withdrawing them, but he
refused and informed Olga Bataeva that he intended to withdraw his funds. Olga Bataeva repeatedly offered him to
think about it and informed him that the funds would probably be withdrawn within a year or more. To date, he has
not been able to withdraw the funds invested in the QBF group of companies, even partially. Approximately in May
2021, he heard from the media (the official website of the Ministry of Internal Affairs of the Russian Federation) about
a criminal case initiated against the founders of QBF. To date, the money has not been returned to him, Vilen
Eduardovich Emirgamzaev. He estimates the amount of damage caused as significant, namely 7,501,091 roubles;
(Vol. No. 37, pp. 9 - 13, 25 - 28)
917
- other documents - documents provided by Emirgamzaev V.E. confirming his relationship with QBF Financial Group
(Vol. No. 37, pp. 29 - 75)
part 4 of article 159 of the Criminal Code of the Russian Federation against Kosorukov O.A.:
- another document - a statement by O.A. Kosorukov, in which he asks to bring to criminal responsibility persons from
(Vol. No. 37, l.d. 88)
O.A. Kosorukov's testimony , given by him as a witness and victim,

according to which in August 2017, a representative of the group of companies "QBF" (personal data is difficult to
name) called him on his mobile phone with a proposal to start investing through the group of companies "QBF". He
was interested in the information regarding investment in the Gribovsky Les housing estate under construction. Afer
the telephone conversation on 20.08.2017, approximately at 11:00 a.m., he arrived at the office of the "QBF" group of
companies, at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, where the first meeting with him took place.
1, where the first meeting with his financial advisor Ahat Gibatov (8 - 915 - 395 - 80 - 48, 8 - 903 - 100 - 47 - 60) took
place. This meeting was of an introductory nature, he made a questionnaire where he indicated his contact details,
including his e - mail address: [email protected], as well as his investment goals and financial capabilities. On the
same day he got acquainted with financial advisor Yulia Zaitseva (8 - 905 - 742 - 77 - 48. 8 - 925 - 285 - 04 - 16), the
direction of her activity was not investments in real estate, but directly conducting trust management of invested
funds. During the conversation Yulia was very convincing. Zaitseva Yulia assured him that the company has a long and
successful experience of work in Russia and abroad, all necessary licences are available, informed him that the
reliability of work with the group of companies "QBF" is guaranteed by the legislation of the Russian Federation in
view of the fact that he will cooperate directly with the Russian organisation, namely: LLC IC "QBF" (INN 7733673955).
Moreover, in open sources of the Internet he saw information that LLC "IK QBF" (INN 7733673955) has 4 licences of the
Central Bank of Russia, namely: licence for brokerage activities №045 - 12805 - 100000 from 24.12.12.2009, dealer
activity licence #045 - 12816010000 dated 24.12.2009, securities management licence #045 - 12828 - 001000 dated
24.12.2009 and depository activity licence #045 - 14078 - 000100 dated 08.08.2019. On 29.08.2017, he, being in the
office of LLC IK QBF, located at the address: Moscow, Presnenskaya Naberezhnaya, 8, pp. 1, in order to invest cash in
securities with high yield, signed an agreement with QB Capital CY LTD ("QB Capital CY LTD") on the provision of direct
access services to international stock markets No. 3384 - 17/IMR dated 29.08.08.2017 and also signed an agreement
for the provision of "Trustee" services pursuant to the agreement on provision of direct access services to
international stock markets No. 3384 - 17/IMR dated 29.08.2017 with QBiF IC Ltd. Afer concluding the agreement,
during another conversation, the financial advisor Ahat Gibatov offered to invest according to the strategy prepared
by QBIF IK. He also explained that his funds would be invested within the framework of the concluded "Trust
Management" agreement in international stock market products. Further, he, being in the office of IK QBF LLC,
located at 8 Presnenskaya Naberezhnaya Naberezhnaya Street, bld. 1, Moscow, carried out the transfer of cash. 1,
realised the transfer of cash as follows: 29.08.2017 in the amount of RUB 1,200,000, 17.08.2018 in the amount of RUB
620,000. Afer investing the cash, he started receiving monthly reports on the status of his investment account to his
email, from the email address: [email protected]. Afer each deposit of funds, he received receipts for cash receipts for
the respective amounts from the employees of QBF Group. On 26.03.2018, in order to check the reliability of the QBF
group of companies, he decided to withdraw part of his invested funds in the amount of USD 500, in this connection,
on 26.03.2018, being in the office of the "QBF" group of companies, at the address: Moscow, Presnenskaya
naberezhnaya, 8, p. 1, he informed Ahat Gibat. 1, informed Ahat Gibatov about his intention to withdraw funds from
his account in the amount of USD 500, afer which Ahat Gibatov took him to the meeting room of the office of the
"QBF" group of companies, at the address: 8, page 1, Presnenskaya Embankment, Presnenskaya Embankment,
918
Moscow, where Yulia Zaytsev took her to the office of the "QBF" group of companies, at the address: 8, page 1,
Presnenskaya Embankment, Moscow. 1 , where Yulia Zaitseva handed him cash in the amount of USD 500, equivalent
to 28,553.6 roubles. In the same way, he withdrew part of the invested funds in the group of companies "QBF",
namely: 24.09.2018 in the amount of USD 237, which is equivalent to 15,701.18 rubles at the official exchange rate of
the Central Bank of Russia, 19.04.2019 in the amount of USD 500, which is equivalent to 32,034.4 rubles at the official
exchange rate of the Central Bank of Russia, 24.07.2019 in the amount of USD 5,000, which is equivalent to 315,645
rubles at the official exchange rate of the Central Bank of Russia. Approximately in December 2019, in the course of
another telephone conversation Zaitseva Yulia informed him that now there is a great opportunity to invest money, so
favourable offer that Yulia Zaitseva herself was ready to come to a convenient place for him to invest money in the
group of companies "QBF". However, he refused Yulia's offer. In October 2019 he decided to withdraw all the invested
funds, afer which he informed Zaitseva Yulia and Ahat Gibatov about his intention. They told him that in order to
withdraw funds from the account, he had to re - sign a number of documents, in this regard, he arrived at the office of
the group of companies "QBF", at the address: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, where he was met by
Zaytseva Yulia and Ahat Gibatov. 1, where he was met by Yulia Zaitseva and Ahat Gibatov. During the meeting, Yulia
Zaitseva explained that in order to withdraw the invested funds, he had to sign a service agreement with
Simtelligence LLC retroactively. If he refuses to sign this agreement, the fate of his invested funds will be unknown,
therefore, either he will sign and the withdrawal will be made, or he will not sign and the funds will not be credited to
his account. For this reason, he was forced to sign the service agreement with Simtelligence Ltd No. 3384 dated
04.06.2018 retrospectively. Afer that, on 27.12.2019 on his bank currency account opened in the branch of PJSC
"SberBank of Russia" at the address: Moscow, Preobrazhenskaya Ploshchad, 7 A, str. 1, account No.
40817840238290005099, received funds in the amount of USD 16,028.84, which is equivalent to RUB 990,062.98 at the
official exchange rate of the Central Bank of Russia. In September 2021, through the media, he learnt that criminal
proceedings had been initiated against employees of the QBF Group of Companies. To date, the remaining funds in
the account, invested in the "QBF" group of companies, in the amount of about 438,000 rubles, have not been
returned to him. The employees of the "QBF" group of companies are unable to explain the current situation in
essence. In total, they were transferred to him for investment through QBF between 29.08.2017 and 17.08.2018 in the
amount of RUB 1,820,000, which is equivalent to approximately USD 29,764 on the dates of transfer. He managed to
withdraw funds between 26.03.2018 and 27.12.2019 in the amount of USD 22,265.84, equivalent to RUB 1,381,997.16.
The remaining monies invested by him have not been returned to him. He considers that an offence has been
committed against him, namely the thef of his funds in the amount of 1,820,000 rubles by deceit and breach of trust.
He considers the amount of damage caused to him as significant;
(Vol. No. 37, pp. 91 - 96, 141 - 145)
- other documents - documents provided by O.A. Kosorukov confirming his relationship with QBF Financial Group
(Vol. No. 37, pp. 97 - 136)
part 4 of article 159 of the Criminal Code of the Russian Federation against Lyutov A.V.:
- another document - a statement by A.V. Lyutov, in which he asks to bring to criminal responsibility persons from
(Vol. No. 37, pp. 158, 159)
919
- Testimony of A.V. Lyutov, given by him as a witness and victim,
according to which approximately in early June 2018, his mobile phone number received a call from the manager of
the group of companies "QBF" Fedotova Lidia with an offer of additional income by allegedly investing in financial
products of the group of companies "QBF". Fedotova L. (tel. 8 - 911 - 832 - 68 - 26) persuaded him to come to the office
of "QBF" group of companies to get additional information. In August 2018, he came to the office of the "QBF" group
of companies at the address: St. Petersburg, Degtyarny per., 11 lit. B, room 1 - H, where he was met by Fedotova L.,
who continued to persuade and persuade him in every possible way to deposit money, to mislead him about the
legality of their activities, about the possibility of high earnings from investments and the like. He believed the words
of Fedotova L. and trusted her. 21.08.2018 being in the office of the group of companies "QBF" at the address: St.
Petersburg, Degtyarny per., 11 lit. B, pom.1 - .H with the purpose, as he believed at that time, of investing funds in
securities he concluded the Agreement on rendering services of direct access to international stock markets No. 4506 -
18HSR dated 20.08.2018 with "QCCI LTD" ("QCCI LTD") and also entered into an agreement with "QBIF IK LLC" for the
provision of "Trust Management" services in accordance with the Agreement on Provision of Direct Access to
International Stock Markets Services No. 4506 - 18/ISR dated 20.08.2018. Having trusted Fedotova L. and being in a
state of delusion on 21.08.2018 being in the office of the group of companies "QBF" at the address: St. Petersburg,
Degtyarny per., 11 lit. B, pom.1 - H, in the presence of Fedotova L., he deposited in the cash desk of the group of
companies "QBF" his own funds in the amount of 10 000 USD, which at the exchange rate of the Central Bank of
Russia as of 21.08.2018 was 671 807 rubles. The cash was taken from him by the cashier of the group of companies
"QBF" whose data he does not know. In order to mislead him and give the appearance of legitimate activity, the
cashier of the group of companies "QBF" gave him a receipt to the receipt order No. b/n dated 21.08.2018 in the
amount of USD 10,000. Around October 2019, he contacted Fedotova L. regarding the full return of his money from the
"QBF" group of companies to him. Fedotova L. referred him to another manager of the QBF Group of Companies, Meri
Baghdasaryan, who in turn demanded that he provide a large number of documents allegedly needed to return the
money. He collected these documents for about one month, afer which he provided them to M. Baghdasaryan, but
the money was not returned to him, M. Baghdasaryan continued to deceive him in every possible way on the issue of
returning the money, delayed the terms of return, constantly found new reasons not to return the money to him. In
May 2021, he saw information in the media that criminal cases had been opened and investigations were being
conducted against the employees and managers of the "QBF" group of companies. Afer that he realised that he had
become a victim of fraudsters. To date, he has not been returned his money deposited in the cash desk of the "QBF"
group of companies, as he then naively believed for investment, in the amount of 671,807 roubles. He believes that
the persons acting on behalf of the group of companies "QBF" initially did not intend to fulfil their obligations to him
and acted solely for the purpose of stealing his money by deceiving him. On 21.08.2018, the persons acting on behalf
of the "QBF" group of companies stole his money in the total amount of RUB 671,807. He estimates the amount of
damage caused to him as significant. He has been explained the right to file a civil action in the criminal case. He
wishes to exercise this right and file a lawsuit. He has been explained the right to familiarise himself with the
conclusions of experts, with the records of expert interrogations, and also to familiarise himself with the materials of
the criminal case in full or in part. He does not wish to exercise this right. He did not apply to the court with
applications for recovery of funds from the QBF Group of Companies";
(Vol. No. 37, pp. 162 - 165, 231 - 233)
- other documents - documents provided by A.V. Lyutov confirming his relationship with QBF Financial Group (QBF
(Vol. No. 37, pp. 167 - 224)
part 4 of article 159 of the Criminal Code of the Russian Federation against Bokov O.M.:
920
- another document - a statement by O.M. Bokov, in which he asks to bring to criminal responsibility persons from
(Vol. No. 38, pp. 6,10)
- The testimony of Bokov O.M., given by him as a witness and victim,

according to which approximately in September 2018 he received a call from Salimova Zarina, who introduced herself
as the manager of the group of the company "QBF". Salimova 3. told him about the possibility of earning money by
depositing money in trust management of the group of the company "QBF". During the conversation Salimova 3.
convinced and assured him of the reliability of the "QBF" group of companies, motivated, among other things, by the
fact that "QBF" has a licence from the Central Bank of the Russian Federation, so the depositors' funds are reliably
protected. Before concluding the contract, he met Salimova 3. once at the office of the QBF Group of Companies at 68
Maloohtinsky Prospekt, 68, Plaza Business Centre, St. Petersburg. During the meeting Salimova 3. once again told him
about the investment products of the "QBF" group of companies and persuaded him to conclude a contract. He
trusted Salimova 3. and decided to deposit his money in "QBF", for which purpose he visited the above mentioned
office of "QBF" group of companies on 12.09.2018. In the office he was met by Salimova 3., under the guidance of
whom he concluded an assignment agreement No. 4542 dated 12.09.2018. So on 12.09.2018 being in the office of
"QBF" group of companies at the address: St. Petersburg, Maloohtinsky Prospekt, 68, under the direction of Salimova
3. he deposited his personal funds in the amount of 1 500 000 rubles in the cash desk of "QBF" group of companies, at
the same time he was given a receipt to the natural cash order b/n. The funds were accepted by the cashier, whose
data he does not know. Afer that, throughout the whole period he received monthly reports from "QBF" from the
electronic box: [email protected] to the box [email protected]. The reports contained information about the
status of investment products of "QBF" group of companies, in which he had invested his money. He did not receive
any funds from QBF Group of Companies, under the said agreement. In May 2019, Salimova 3. called him and offered
to deposit additional funds in a new investment product of the "QBF" group of companies - Depository". Salimova 3.
explained that "Depositary" was a set of shares of the Russian securities market located within the Russian
Federation, which QBF Group would purchase with his money. He believed Salimova 3. and agreed to additionally
deposit his money. So on 08.05.2019 in the office of the group of companies "QBF" at the address: St. Petersburg,
Degtyarny per. 11, lit. B, 6th floor, office 601, under the supervision of Salimova 3. he concluded an agreement with
LLC IC "QBF" of trust management of securities and means of investment in securities № DU - F - 1357, by submitting
an application for joining this agreement. Under the agreement No. DU - F - 1357, on 21.05.2019, he transferred RUB
2,000,000 from his account opened at the Severnaya Stolitsa branch of JSC Raiffeisenbank at the address: 36, Moika
River Nab., St. Petersburg, to the settlement account of QBIF LLC opened at NSD, Moscow. In October 2019 he received
a call from Salimova 3. informing him that QBF Group of Companies was undergoing restructuring, so he should come
to their office and conclude a trust management agreement with "White Lake Management Ltd.", within the
framework of which his funds, which he had previously deposited under the order agreement No. 4542 dated
12.09.2018, would be used for further investment. So on 18.10.2019 in the office of the group of companies "QBF" at
the address: St. Petersburg, Degtyarny per. 11, lit. B, 6th floor, office 601, under the supervision of Salimova 3. he
concluded the trust management agreement №D - 009378 - J with "White Lake Management Ltd". In October 2020,
Salimova 3. called him and informed him that "White Lake Management Ltd" had transferred the right to invest the
funds to "Lamera Holding Limited", therefore he should come to the office of "QBF" group of companies to sign the
relevant documents. At the office of QBF Group of Companies at 11 Degtyarny per. 11, Lit. B, 6th floor, office 601, St.
Petersburg. On 29.10.2020, under the supervision of Salimova 3. he concluded assignment agreement No. 009378
with Lamera Holding Limited. In March 2021, he received a call from Salimova 3. and offered to transfer his assets to
the group of companies "QBF" to the closed unit investment real estate fund "RIF Warehouse Federal 1". The cost of
the 3 units was 1,815,000 roubles, of which he received a notice from Salimova 3. He agreed to Salimova 3.'s proposal,
but to date he has not received the said units. In June 2021 he learnt from mass media, including official news of the
921
Ministry of Internal Affairs of Russia, that criminal cases have been initiated and investigations are being conducted
against employees and managers of the QBF group of companies. Taking into account the fact that he had expired
deadlines for repayment of his money, he realised that he had become a victim of fraudsters. He believes that the
above - mentioned reports sent to his e - mail from "QBF" group of companies are fictitious, his money was not
managed by anyone, and it was simply stolen. The reports were made to mislead him. Up to now his money deposited
to the address of the group of companies "QBF" in the amount of 3 500 000 roubles has not been returned to him. He
also considers that the persons acting on behalf of the group of companies "QBF" initially did not intend to fulfil their
obligations to him and acted solely for the purpose of stealing his money by deceiving him. The persons acting on
behalf of the "QBF" group of companies stole the money belonging to him in the total amount of 3,500,000 roubles.
He assesses the amount of damage caused to him as significant. He has been explained the right to file a civil action in
the criminal case. He wishes to exercise that right and file a lawsuit. He has been given the right to familiarise himself
with the composition of the investigation teams, the decisions to order forensic examinations, the expert reports, the
records of expert interrogations, and the materials of the criminal case in full or in part. He does not wish to exercise
this right. He did not apply to the court with applications for recovery of money from the "QBF" group of companies;
(Vol. No. 38, pp. 11 - 14, 176 - 179)
- other documents - documents provided by O.M. Bokov confirming his relationship with QBF Financial Group (QBF
(Vol. No. 38, pp. 16 - 171)
part 4 of article 159 of the Criminal Code of the Russian Federation against Kostovskaya E.N.:
- another document - a statement by Kostovskaya E.N., in which she asks to bring to criminal responsibility persons
(Vol. No. 38, pp. 192,196)
- The testimony of Kostovskaya E.N., given to her as a witness and victim,

according to which, on 07.09.2015 up to the present time, she is employed at Polychim - Akrokor LLC, in the position
of general director. In autumn 2016, she received a call on her mobile phone number from an employee of the QBF
group of companies, whom she does not remember, with an offer to finance Polychim - Akrokor LLC with funds from
the QBF group of companies. By telling her about the possibility of earning money, the said employee of the QBF
group of companies convinced her to come to the office of the QBF group of companies to receive additional
information. She together with the co - founders of LLC "Polyhim - Akrokor" Proskuryakov S.V. and Esenovsky A.G.
came to the office of the group of companies "QBF" at the address: St. Petersburg, Maloohtinsky prospect, 64B. They
were met in the office by an employee of the QBF group of companies, who she does not remember, who began to
persuade them to use the funds of the QBF group of companies to develop the production of Polychim - Akrokor LLC.
She immediately declined the offer of financing and they lef. At the beginning of June 2017, her mobile phone
number received a call from an employee of the QBF Group of Companies, whom she does not remember, with an
offer of additional work by allegedly investing in financial products of the QBF Group of Companies. The mentioned
employee persuaded her to come to the office of the group of companies "QBF" to receive additional information.
When she came to the office of the group of companies "QBF" at the address: St. Petersburg, Maloohtinsky prospect,
64B, she was met by Bogdanov Kirill Yurievich, who began to persuade her in every possible way, persuade her to
deposit money and mislead her about the legality of their activity, about the possibility of additional earnings from
investments and so on. She believed the words of Bogdanov K.Y. and trusted him. 20.06.2017 in the office of the group
922
of companies at the address: Saint - Petersburg, Maloohtinsky pr, 64B, with the purpose, as she believed at that time,
of investing money in securities, she concluded the Agreement on rendering services of direct access to international
stock markets No. 3256 - 17/ISR dated 20.06.2017 with "QB Capital CY LTD" ("QB Capital CY LTD") and also entered into
an agreement with "IK QBiEf" LLC for the provision of "Trustee" services in accordance with the Direct Access to
International Stock Markets Services Agreement No. 3256 - 17/ISR dated 20.06.2017. Having trusted the employee of
the group of companies "QBF" Bogdanov K.Y. and being in a state of delusion on 20.06.2017 in the office of the group
of companies "QBF" at the address: Saint - Petersburg, Maloohtinsky prospect, 64B, in the presence of Bogdanov K.Y.,
she deposited in the cash desk of the group of companies "QBF" her own funds in the amount of 1 100 000 rubles and
2 000 USD, which at the exchange rate of the Central Bank of Russia as of 20.06.2017 is 115 917 rubles. The money was
taken from her by an employee of the "QBF" group of companies, who exactly she does not remember. In order to
mislead her and to make what was happening look like a legitimate activity, the employee who took money from her
gave her a receipt to the receipt order No. b/n dated 20 June 2017 in the amount of 1 100 000 rubles, as well as a
receipt to the receipt order No. b/n dated 20 June 2017 in the amount of 2 000 USD. Trusting the employee of the
group of companies "QBF" Bogdanov K.Y. and being in a state of delusion on 26.07.2017 in the office of the group of
companies "QBF" at the address: St. Petersburg, Maloohtinsky prospect, 64B, in the presence of Bogdanov K.Y., she
deposited in the cash desk of the group of companies "QBF" her own money in the amount of 250 000 rubles. The
money was taken from her by an employee of the group of companies "QBF", who she does not remember. In order to
mislead her and make what was happening look like a legal activity, the employee who accepted money from her
gave her a receipt to the receipt order No. b/n dated 26 July 2017. Having trusted the employee of the group of
companies "QBF" Bogdanov K. and being in a state of delusion on 03.11.2017 in the office of the group of companies
"QBF" at the address: St. Petersburg, Maloohtinsky prospect, 64B, in the presence of Bogdanov K.Y., she deposited in
the cash desk of the group of companies "QBF" her own money in the amount of 300 000 rubles. The money was
taken from her by an employee of the group of companies "QBF", who she does not remember. In order to mislead her
and make what was happening look like a legitimate activity, the employee who accepted money from her gave her a
receipt to the receipt order No. b/n dated 03 November 2017. Trusting the employee of the group of companies "QBF"
Bogdanov K.Y., and being in a state of delusion, on 30.01.2018 in the office of the group of companies "QBF" at the
address: St. Petersburg, Maloohtinsky prospect, 64B, in the presence of Bogdanov K.Y., she deposited in the cash desk
of the group of companies "QBF" her own money in the amount of 280 000 rubles. The money was taken from her by
an employee of the group of companies "QBF", who she does not remember. In order to mislead her and make what
was happening look like a legal activity, the employee who took money from her gave her a receipt to the receipt
order No. b/n dated 30 January 2018. Trusting the employee of the group of companies "QBF" Bogdanov K.Y., and
being in a state of delusion, on 03.10.2018 in the office of the group of companies "QBF" at the address: St.
Petersburg, Maloohtinsky prospect, 64B, in the presence of Bogdanov K.Y., she deposited in the cash desk of the group
of companies "QBF" her own money in the amount of 700 000 rubles. The money was taken from her by an employee
of the group of companies "QBF", who she does not remember. In order to mislead him and make what was
happening look like a legitimate activity, the employee who accepted the money from her gave her a receipt for the
receipt order No. b/n dated 03 October 2018. Starting from June 2017, she received reports allegedly on transactions
for the purchase of securities with her money. In May 2018, she approached Bogdanov K.Y. about receiving her profits
from the invested funds. Bogdanov K.Y., said that the group of companies "QBF" could pay her USD 3,000, which was
allegedly received as profit from her deposited money. On 21.05.2018, in order to convince her of the legality and
profitability, thereby misleading her Bogdanov K.Y., made an appointment for her to give her the money. In the office
of the group of companies "QBF" at the address: St. Petersburg, Maloohtinsky pr., 64B, an employee of the group of
companies "QBF", whose data she does not remember, gave her 3,000 US dollars, which at the exchange rate of the
Central Bank of Russia as of 21.05.2018 was 185,822.40 rubles. In May 2019, she approached Bogdanov K.Y., on the
issue of receiving her profit from the invested funds. Bogdanov K.Y., said that the group of companies "QBF" could pay
her USD 3,500, which was allegedly received as profit from the money she had contributed. On 26.06.2019 in order to
convince her of the legality and profitability, thus misleading her Bogdanov K.Y., made an appointment for her to give
her the money. In the office of the group of companies "QBF" at the address: St. Petersburg, Degtyarny per. 11 lit. B,
room 1 - H, an employee of the group of companies "QBF", whose data she does not remember, gave her 3,500 US
dollars, which at the exchange rate of the Central Bank of the Russian Federation on 26.06.2019 amounted to
923
218,830.15 rubles. In January 2020, she approached Bogdanov K.Y., on the issue of receiving her profit from the
invested money. Bogdanov K.Y., said that the group of companies "QBF" could pay her USD 3 500, which allegedly
were received as profit from the money she had contributed. On 21.01.2020, in order to convince her of the legality
and profitability, thereby misleading her, Bogdanov K.Y., appointed a meeting with her to give her the money. In the
office of the group of companies "QBF" at the address: St. Petersburg, Degtyarny per. 11 lit. B, room 1 - H employee of
the group of companies "QBF" Efremtsov Artyom gave her 3 500 US dollars, which at the exchange rate of the Central
Bank of the Russian Federation on 21.01.2020 amounted to 215 128,90 rubles. In May 2021, she saw information in the
the "QBF" group of companies. She realised that she had become a victim of fraudsters. In June 2021 she tried to
return her money, for what she addressed to Bogdanov K.Y., on the question of full return of her money. Bogdanov K.Y.
told her that the money of the group of companies "QBF" had been seized, therefore it was impossible to return the
money and suggested to apply to the police. Bogdanov K.Y. did not inform her who and for what reasons had put the
money of "QBF" group of companies under arrest. Up to the present time his money deposited in the cash desk of the
group of companies "QBF", as she naively believed at that time for investment in the amount of 2 126 135,55 roubles,
has not been returned to him. She believes that the persons acting on behalf of the group of companies "QBF" initially
did not intend to fulfil their obligations to her and acted solely for the purpose of stealing her money by deceiving her.
In the period from 20.06.2017 to 03.10.2018, the persons acting on behalf of the QBF Group of Companies stole her
money in the total amount of 2,126,135.55 rubles. She estimates the amount of damage caused to her as significant.
She has been explained the right to file a civil action in the criminal case. She wishes to exercise that right and file a
lawsuit. She has been explained the right to familiarise herself with the composition of the investigative teams, with
the decisions on the appointment of forensic examinations, with the conclusions of experts, with the protocols of
interrogations of experts, and also to familiarise herself with the materials of the criminal case in full or in part. She
does not wish to exercise this right. She has not applied to the court with applications for recovery of funds from the
QBF Group of Companies";
(vol. No. 38, pp. 197 - 200, vol. No. 39, pp. 91 - 95)
- other documents - documents provided by E.N. Kostovskaya confirming her relationship with QBF Financial Group
(vol. No. 38, pp. 203 - 218, vol. No. 39, pp. 1 - 71, 79 - 82, 84)
part 4 of article 159 of the Criminal Code of the Russian Federation against Morozov V.V.:
- another document - a statement by V.V. Morozov, in which he asks to bring to criminal responsibility persons from
(Vol. No. 39, pp. 107,111)
- Testimony of V.V. Morozov, given by him as a witness and victim,

according to which, in June 2017, his mobile phone number received a call from an employee of the group of
companies "QBF", whose details she does not remember, with an offer to invest money in allegedly investment
products of the group of companies "QBF". This employee persuaded him to come to the office of "QBF" group of
companies by telling him about the possibility of earning money. When he arrived at the office of the group of
companies "QBF" at the address: St. Petersburg, Maloohtinsky prospect, 64B, he was met by Grigory Pakhomov, who
introduced himself as the head of the department of investment services of the group of companies "QBF". Pakhomov
G. began to persuade him in every possible way, to persuade him to deposit money and to mislead him about the
924
legality of their activities, about the possibility of high earnings from investments and so on. I believed the words of
Pakhomov G. and on 14.06.2017 being in the office of the group of companies "QBF" at the address: St. Petersburg,
Maloohtinsky Ave, 64B concluded the Agreement on rendering services of direct access to international stock markets
№ 3245 - 17/ISR dated 13.06.2017 with "QB Capital CY LTD" (QB Capital CY LTD), as well as on behalf of "QBF" LLC the
Agreement on rendering services of "Trust management" in accordance with the Agreement on rendering services of
direct access to international stock markets № 3245 - 17/ISR dated 13.06.2017. Having trusted the employees of the
group of companies "QBF" and being in a state of delusion, on 14.06.2017 being in the office of the group of
companies "QBF" at the address: St. Petersburg, Maloohtinsky prospect, 64B, in the presence of the manager of the
group of companies "QBF" Igor Bagniuk, he deposited his own funds in the amount of 580 000 (five hundred eighty
thousand) rubles in the cash desk of the group of companies "QBF". Some employee of the group of companies "QBF"
took the money from him (he does not remember the data of this employee). In order to mislead him and make what
was happening look like a legitimate activity, the said employee of the "QBF" group of companies gave him a receipt
to the receipt order No. b/n dated 14 June 2017. Starting from June 2017, he started to receive reports about alleged
purchase of securities on his account. Trusting the employees of the group of companies "QBF" and being in a state of
delusion 10.10. 2018 being in the office of the group of companies "QBF" at the address: St. Petersburg, Maloohtinsky
prospect, 64B in the presence of the manager of the group of companies "QBF" Efremtsov Artem, he deposited in the
cash desk of the group of companies "QBF" his own money in the amount of 1 400 000 (million four hundred
thousand) rubles. The money was taken from him by some employee of the group of companies "QBF" he doesn't
remember the data of this employee. In order to mislead him and make what was happening look like a legitimate
activity, the said employee of the "QBF" group of companies issued a receipt to the receipt order No. b/n dated 10
October 2018. In June 2020, Efremtsov A. contacted him and convinced him to conclude a new contract with the
group of companies "QBF", according to Efremtsov A. it was necessary to do so because the group of companies
"QBF" changed the form of activity. He did not understand what this meant, but as he trusted (Efremtsov A. he
fulfilled his instruction. Thus, on 13 December 2019, being in the office of the group company "QBF" at the address:
Degtyarny per. 11 lit. B, pom.1 - H, BC "Nevskaya Ratusha", under the guidance and accompaniment of Efremtsov A.,
he concluded a contract with "White Lake Management" (Cayman Islands) and Simtelligence". In November 2020, he
wanted to withdraw his funds from the group by QBF. In the office of the group by "QBF" at 11 Lit. B, Degtyarny per.
11, pom.1 - H, he submitted a written application with a demand for the return of his funds. Mr Efremtsov A. accepted
his application, but demanded that he provide a large number of documents that were allegedly necessary for the
withdrawal of funds. He collected all the documents indicated by Efremtsov A. and came again to the office of the
group by the company "QBF", where he was met by Efremtsov A., who informed him that he was being dismissed from
the group by the company "QBF" and further the vice - president of the group by the company "QBF" Moskalyuk
Dmitry Vladimirovich would work with him. He gave the collected documents to D.V. Moskalyuk, who also began to
deceive him about the terms and possibility of withdrawal of money, invented various excuses and delayed the time
of return of money to him. D.V. Moskalyuk assured him that the money would be transferred to his foreign currency
account within a month. Afer a month the money was not received. Afer that he began to demand the return of his
money on a regular basis, but D.V. Moskalyuk continued to deceive him and mislead him in every possible way about
the return of his money, inventing different circumstances and reasons. At that moment he realised that he had
become a victim of "fraudsters and I was simply deceived to steal his money. At that time, he saw information in the
the QBF group of companies. This confirmed his thoughts that he was a victim of fraudsters. To date, his money
deposited in the cash desk of the "QBF" group of companies, as he naively believed at the time for investment, in the
amount of 1,980,000 roubles has not been returned to him. He believes that the persons acting on behalf of the group
of companies "QBF" initially did not intend to fulfil their obligations to him and acted solely for the purpose of
stealing his money by deceiving him. In the period from 14.06.2017 to 10.10.2018, the persons acting on behalf of the
QBF Group of Companies stole his money in the total amount of RUB 1,980,000. He estimates the amount of damage
caused to him as significant. He has been explained the right to file a civil action in the criminal case. He wishes to
exercise that right and file a lawsuit. He has been given the right to familiarise himself with the composition of the
investigative teams, with the decisions to order forensic examinations, with the conclusions of experts, with the
transcripts of expert interrogations and with the materials of the criminal case in full or in part. He does not wish to
925
exercise this right. In the summer of 2021, the exact date he does not remember, he applied to the Presnensky District
Court of Moscow with a claim for recovery of funds from the QBF group of companies;
(Vol. No. 39, pp. 112 - 114, 156 - 159)
- other documents - documents provided by V.V. Morozov confirming his relationship with QBF Financial Group (QBF
(Vol. No. 39, pp. 117 - 151)
part 4 of article 159 of the Criminal Code of the Russian Federation against Voropaev A.V.:
- another document - a statement by A.V. Voropaev, in which he asks to bring to criminal responsibility persons from
(Vol. No. 39, pp. 172, 173)
- Testimony of Voropaev A.V., given by him as a witness and victim,

according to which, at the end of 2017, his acquaintance Salimova Zarina offered him the possibility of imaginary
earnings, which consisted in the fact that he would transfer a certain amount of money in trust management to the
organisation QBF, licensed by the Central Bank, on the terms of monthly payment of fixed interest. Since he had
known Salimova Zarina for a long time, he knew that she worked in a financial institution and was engaged in
financial management, he did not have any suspicions about her proposal. However, fearing possible risks, having
received information from Salimova Z. about possible conditions of investment, the name of the organisation and the
identity of its managers, he spent several months checking the reliability of the organisation, searching for and
reading customer reviews. During this whole period of time Salimova Z. continued to constantly tell me about the
benefits of offers, invited me to seminars, where representatives of the organisation continued to persuade me to
transfer funds to the trust management of the company. In October 2018, as he now understands, having succumbed
to beautiful stories about rapid and obligatory earnings, he decided to transfer a certain amount of his personal funds
to the organisation LLC "IK QBF". Thus, on 22.10.2018, being in the office of the branch of LLC IC QBF at the address:
Maloohtinsky prospect, d. 64B in St. Petersburg, he concluded an agreement with LLC "QBIF Adviszeri", as he was told,
a subsidiary of LLC "IC QBIF" and an agreement with "QCCI LTD" registration number NOT 221325, on the basis of
which he transferred his funds into trust management, with the possibility of selling the portfolio within 30 working
days and transfer to my account within 5 working days. At the moment of signing the contract and agreement, the
documents were already signed and stamped by QBF company. He was not suspicious of this fact, as he understood
that the management of the company was not in St. Petersburg, and believed that this was a developed procedure for
concluding and signing such documents. Afer he signed the contract and agreement, on the same day, 22.10.2018,
also being in the office premises at the address: St. Petersburg, Maloohtinsky pr. 64, lit. B (BC SPb"), he handed over to
the cashier money in the amount of 1 950 000 rubles belonging to him personally, Salimova Zarina accompanied him
at all stages. In turn, she handed him a receipt for the receipt order for the said amount as proof of payment under the
contract. He noted that he communicated with Salimova Zarina, who positioned herself as a senior financial advisor,
later she got the position of Vice - President of the company and Gevorg Shakespearevich Gevorgyan, Head of
Investment Services Department. Throughout the entire co - operation, he regularly received information from
Salimova and Gevorgyan about the successful investment of his funds in certain shares, however, the monthly reports
sent to him contained information about the lack of efficiency in the use of his funds and negative financial results. At
the same time Salimova and Gevorgyan explained this fact to him by saying that the securities market had collapsed,
and this drop in the performance of her "portfolio" was temporary and it would become more efficient in the future.
926
He could not verify Salimova's and Gevorgyan's words in any way, as well as the data indicated in the reports and the
validity of the investment of his funds in certain shares, and therefore, fearing the loss of his funds, he decided to
withdraw his funds from the trust management of the company. On 24.09.2019, he requested for documents to
withdraw his funds, but afer talks with Zarina in early May 2019, she persuaded him to wait and give them a chance to
rehabilitate. He agreed. On 18.02.2020, he wrote an application for withdrawal, which he sent via email to Salimova Z.,
who acknowledged receipt of his application and acceptance of it. On 19.03.2020 he received a notification from
Salimova Z. that the stock market has corrected by 30% and he will suffer even greater financial losses when
withdrawing funds. In the course of communication Salimova Z. continued to convince him in the unfavourable
withdrawal of funds, in the need to continue cooperation, promising in the future, when the market recovers,
accelerated withdrawal of funds or introduction of a new strategy of earning. Salimova Z.'s explanations sounded
plausible and tempting to him, promising the least loss of his invested funds, and therefore he agreed. On 19.11.2020
he again wrote an application for withdrawal, which he also sent by e - mail to Salimova Z. However, on far - fetched
pretexts, the accelerated withdrawal of his funds was not carried out. He never received the funds. At the beginning of
April 2021, during a personal meeting with Gevorg Gevorgyan and Zarina Salimova, the latter informed him that the
withdrawal of funds was suspended because the licence of the foreign company was being checked. At the end of May
2021 Zarina Salimova informed him that the money would arrive in the second week of June, however, at the
beginning of June he learnt from Salimova that the Moscow office of the company was searched and all activities
were suspended. At the beginning of July he was offered other ways to withdraw his invested funds, such as: purchase
of RIF ZPIFs, at a price 2 times higher than the one stated in the report of this ZPIF, purchase of some securities with
additional payment from his side. Thus, he believes that a group of people, including Salimova and Gevorgyan, under
the pretext of brokerage services, received money from him in the amount of 1,950,000 rubles, but they did not intend
to fulfil their obligations and return the money to him. He believes that by means of deceit and abuse of trust he was
robbed of his money in the amount of 1,950,000 roubles. The damage caused to him is significant. To date, he has not
been returned his monetary funds deposited to the "QBF" group of companies in the amount of 1,950,000 roubles. I
also believe that the persons acting on behalf of the group of companies "QBF" initially did not intend to fulfil their
obligations to him and acted solely for the purpose of stealing his money by deceiving him. The persons acting on
behalf of the "QBF" group of companies stole money belonging to him in the total amount of 1,950,000 roubles. He
considers the amount of damage caused to him to be significant. He has been explained the right to file a civil action
in the criminal case. He wishes to exercise that right and file a lawsuit. He has been explained the right to familiarise
examinations, with the conclusions of experts, with the transcripts of expert interrogations and with the materials of
the criminal case in full or in part. He does not wish to exercise this right. He did not apply to the court with
applications for recovery of money from the "QBF" group of companies;
(Vol. No. 39, pp. 176 - 179, Vol. No. 40, pp. 52 - 55)
- other documents - documents provided by A.V. Voropaev confirming his relationship with QBF Financial Group (Q
BF Investment Company LLC) and testifying to the embezzlement of funds;
(Vol. No. 39, pp. 180 - 244, Vol. No. 40, pp. 1 - 47)
part 4 of article 159 of the Criminal Code of the Russian Federation against Kishilov S.M.:
- another document - a statement of S.M. Kishilov, in which he asks to bring to criminal responsibility persons from
(Vol. No. 40, l.d. 68)
927
- Testimony of S.M. Kishilov, given by him as a witness and victim,
according to which in July 2017 he received an advertising call on my mobile phone number from a representative of
the group of companies "QBF" named Leonid Sukharev with a proposal for cooperation, in particular investments in
securities of stock markets of foreign countries. At first he did not give an unambiguous answer, but began to make
enquiries for himself on the Internet about the group of companies "QBF". Later, in December 2017, he contacted the
manager Sukharev L. and we agreed to meet. Also in December 2017, he met with Sukharev L. in the cafe "Ruccola"
located at the following address: Moscow, Klimentovsky pereulok str. 10, page 2. Sukharev L. presented to him the
investment products available in the organisation, the ways of investment, the mechanism of profit formation, the
order of reporting and informing the client, as well as in general the structure of the organisation. He was informed
that the funds will be invested in investment sites of foreign countries. Everything was presented in a colourful form,
devoid of flaws, he was promised a yield of 10 to 30% per annum. At first he did not give an unambiguous answer, but
began to make enquiries in the Internet about the group of companies "QBF". Having studied the information from
various Internet resources, he again contacted the manager named Sukharev L. and they agreed to meet in the office
of the company. So on 21.02.2018 he, being in the office of LLC "IK "QBF", located at the address: Moscow,
Presnenskaya naberezhnaya, 8, pg. 1, with the purpose of investing funds in securities with high yield, signed with the
company "QCCI LTD" agreements on rendering services of direct access to international stock markets No. 4251 -
18/IMR, dated 16.11.2017, as well as concluded an assignment agreement No. 4251 dated 21.02.2018 on behalf of
QCBIF Advisery LLC. Also being in the office of LLC QB&EF Investment Company, located at the address: Moscow,
Presnenskaya Naberezhnaya 8, pg. 1, he handed over cash as follows: 21.02.2018 in the amount of USD 22,000, which
at the exchange rate of the Central Bank of the Russian Federation as of 21.02.2018 was RUB 1,243,440; 21.06.2018 in
the amount of RUB 700,000; 21.06.2018 in the amount of USD 18,000, which at the exchange rate of the Central Bank
of the Russian Federation as of 21.06.2018 was RUB 1,145,160; 28.10.2018 in the amount of USD 22,000, which at the
exchange rate of the Central Bank of the Russian Federation as of 28.10.2018 was RUB 1,443,860. For all deposits, he
was given receipts for cash receipts No. b/n for the respective amount. The signatory of all receipts was Gorobets E.V.
Afer he invested funds in the group of companies "QBF", he started receiving reports to his e - mail address
[email protected]. These reports reflected the state of his investment portfolio. Periodically he received calls from
Sukharev L., who offered him to invest additional funds, as well as to think about purchasing additional financial
products of the group of companies "QBF". Later in 2019, he had a change of financial advisor, and Padalko Nikolai (8 -
964 - 530 - 33 - 76) became his financial advisor. In May 2019, he was contacted by Padalko N. and informed him that
due to the modification and development of the investment strategy of the "QBF" group of companies he needed to
sign new documents of technical nature. So, on 26.09.2019 Padalko N. came to his house at the address: Reutov,
Nosovikhinskoye shosse, 27, where in the underground car park he signed the following documents: "Trust
management" agreement No. D - 212164 - N with "White Lake Management LTD" represented by D.A. Korshunov,
service agreement with "VL Consulting" LLC, service agreement No. 4251 dated 04.06.2018 with "Simtelligence
company Limited" represented by Korshunov D.A. Some time later, his financial advisor changed again and he was
assigned Danilenko Maxim (8 - 903 - 289 - 76 - 41) as his financial advisor. In September 2020, he had a need to
withdraw the funds in full, which he notified Danilenko M., whereupon he wrote an official letter and collected the
entire requested package of documents to withdraw the funds previously provided to him by Danilenko M. Later, in
late May, early June 2021, he learned from the media, including official news of the Russian Ministry of Internal Affairs,
that criminal proceedings had been initiated and an investigation was underway. Taking into account the specifics of
communication with managers, problems with withdrawal of funds, as well as the fact that the money was not
returned to him in full, he had no doubts that he had become a victim of fraudsters. To date, his money has not been
returned to him. He considers that an offence has been committed against him, namely the thef of his money by
deceit and abuse of trust. In the period from 21.02.2018 to 28.10.2018 he transferred to the group of companies "QBF"
the money belonging to him in the amount of 4 532 460 rubles. He assesses the amount of damage caused as
significant;
(Vol. No. 40, pp. 71 - 75, 84 - 87)
928
- other documents - documents provided by S.M. Kishilov confirming his relationship with QBF Financial Group (QBF
(Vol. No. 40, pp. 89 - 225, Vol. No. 41, pp. 1 - 28)
part 4 of article 159 of the Criminal Code of the Russian Federation against Bogomolov I.L.:
- another document - a statement by Bogomolov I.L., in which he asks to bring to criminal responsibility persons from
(Vol. No. 41, l.d. 40)
- I.L. Bogomolov's testimony as a witness and victim,

according to which he was a client of PJSC Promsvyazbank from 2013 to 2017. He had personal savings invested in
this organisation, and his financial advisor was Igor Soloviev. In 2017, Igor Soloviev resigned from PJSC
Promsvyazbank and was employed as a financial manager at QBF Group. In March 2018, he (Soloviev) approached
him (Bogomolov) as his old client and offered to transfer his assets from PJSC Promsvyazbank to QBF on more
interesting terms. He agreed to think about it and took a pause for reflection. Later, Solovyov contacted him again. In
the course of communication Soloviev Igor very colourfully and convincingly told him about investment products
available in the organisation "QBF", ways of investment, mechanisms of profit formation, the order of reporting and
informing the client, as well as in general about the structure of the organisation. He was informed that the funds will
be invested in investment platforms of foreign countries. Everything was presented in a colourful way, devoid of
flaws, and he was promised high returns. Based on the results of their communication, as well as relying on entreaties
and stories Solovyev Igor informed during a telephone conversation that he was ready to invest in the group of
companies "QBF". On 01.06.2018 he arrived at the office of the "QBF" group of companies at the address: Moscow,
Presnenskaya naberezhnaya, 8, bldg. 1, 9th floor, where he was met by Solovyev Igor and escorted to the meeting
room. He had in his hands the documents already signed by the representative: agreement on the provision of
services of direct access to international stock markets No. 4388 - 18/IMR dated 30.05.2018 between him and the
company "QCCI LTD" represented by Gorobets Elena Vyacheslavovna (in the agreement the date of signature of
Gorobets E.V. was dated 30.05.2018), as well as the assignment agreement No. 4388 dated 30.05.2018 between him
and the company QCCI LLC (INN 7703426941) represented by the general director Frolov V.G., the agreement was
already signed by Frolov V.G. on 01.06.2018. Thus, on 01.06.2018, he signed the above agreement and the assignment
agreement. Afer signing the above documents, Solovyev Igor escorted him to an additional room, where there was,
according to Solovyev Igor's words, his manager - Anna Sidorova. In the said room, he handed over to Anna Sidorova
the money belonging to him in cash, namely 2,840,000 roubles, as well as 4,590 US dollars, which at the exchange rate
of the Central Bank of Russia as of 01.06.2018 is 284,671.8 roubles. In return, he was given two receipts for a cash
receipt order for the amounts of: RUB 2,840,000 and USD 4,590. Everywhere in the receipts was the signature of the
chief accountant Gorobets E.V. and the seal impression "QB Capital CY LTD", these receipts were dated 01.06.2018,
under the contract No. 4388 - 18/ IMR dated 30.05.2018. Afer he invested the funds in "QBF" group of companies, he
started receiving reports on his email address [email protected]. The said reports reflect the status of his investment
portfolio. On 30.10.2018 on the recommendation of Soloviev Igor he came to the office of the group of companies
"QBF" located at the address: Moscow, Presnenskaya naberezhnaya, 8, page 1, 9th floor and made an additional
deposit of 1 970 000 rubles, which he handed over to an employee of "QBF". In return, he was given one receipt for a
cash receipt order in the amount of 1,970,000 roubles. The receipt bore the signature of the chief accountant Gorobets
E.V. and the stamp of "QB Capital CY LTD", this receipt was dated 30.10.2018, under the contract No. 4388 - 18/IMR
dated 30.05.2018. On 30.10.2019 he came to the office of the company "QBF" located at the address: Moscow,
Presnenskaya Naberezhnaya, 8, p.1, 9th floor and wrote an application for a refund of all funds from all strategies
under his contract. His portfolio was sold out and sent the last report on 11.01.2020 with the amount to be refunded
78,566.85 USD. Also on 30.10.2019 Soloviev Igor convinced him that to accelerate the withdrawal of funds it is
929
required to sign a service agreement No. 4388 dated 04.06.2018 between him and "Simtelligence Company Limited".
He signed this agreement on 30.10.2019. However, the monies were neither fully nor partially returned to him. At the
end of May 2021, he became aware from the media that a criminal case has been opened, investigative actions have
been carried out, that the group of companies "QBF" is a pyramid scheme. Till now his money has not been returned
to him, in total he transferred 5 094 671,8 roubles to the address of the group of companies "QBF". Claims will be
brought for the amount of damage caused to him. He believes that an offence has been committed against him,
namely the thef of his money by deceit and breach of trust. He considers the amount of damage caused to him as
significant;
(Vol. No. 41, pp. 43 - 46, 53 - 57)
- other documents - documents provided by I.L. Bogomolov confirming his relationship with QBF Financial Group
(Vol. No. 41, pp. 58 - 110)
part 4 of article 159 of the Criminal Code of the Russian Federation against Kosovsky B.G.:
- another document - a statement of B.G. Kosovskiy, in which he asks to bring to criminal responsibility persons from
(Vol. No. 41, l.d. 122)
- Testimony of Kosovsky B.G., given by him as a witness and victim,

according to which, on 30.10.2018 from his acquaintance Igor Gurevich (89031004633) he learnt about the existence
of the group of companies "QBF". During a telephone conversation with Igor Gurevich, he (Igor Gurevich) proposed to
meet in the office of the group of companies "QBF" at the address Moscow, Presnenskaya Naberezhnaya St., 8, p. 1 at
about 15:00. 1 at approximately 15:00. At the meeting, Igor Gurevich told him again that the QBF group of companies
was engaged in investing in shares of foreign companies, offered to invest in various stock exchange products, he was
very persuasive and persistent, therefore he was interested in Igor Gurevich's proposal. Before starting to invest
through the group of companies "QBF", he did not start to make enquiries about the company, as he knew Igor
Gurevich's financial advisor for more than 20 years, so he did not doubt the honesty of his words about the success
and honesty of the group of companies "QBF". On 30.10.2018 at exactly unspecified time, he, being in the office of LLC
"IK QBF", located at the address: Moscow, Presnenskaya naberezhnaya, 8, pp. 1, under the pretext of investing funds
in securities with high yields, he signed agreements with the company "QCCI LTD" on the provision of services of
direct access to international stock markets No. 4639 - 18/IMR dated 30.10.2018. He also entered into an assignment
agreement No. 4639 dated 30.10.2018 with QCCI ADVISORY LTD. At the same time, he had no relevant knowledge of
the securities market and no experience in investment activities, he believed that he had entered into a securities
trust management agreement with a professional participant of the securities market, QBF Investment Company LLC.
On 30.10.2018, he made a cash transfer of USD 24,000, which at the exchange rate of the Central Bank of the Russian
Federation as of 30.10.2018 was RUB 1,579,440. In February 2020, he had a need to withdraw some of his invested
funds in the "QBF" group of companies, whereupon he wrote an application for withdrawal of funds under the
agreement No. 4639 dated 30.10.2018 on 16.03.2020, for withdrawal of USD 10,000, whereupon the financial advisor
Igor Gurevich accepted the application from him and said that it takes 3 to 6 months to process this procedure. On
26.06.2020, at approximately 15:00, he arrived at the office of QBF Group of Companies at 8 Presnenskaya
Naberezhnaya St., p. 1, Moscow, where his financial advisor was present. 1, where his financial advisor Igor Gurevich
introduced him to Maxim Danilenko (89032897641, 89653915547) and told him that Maxim Danilenko would be his
930
financial advisor, arguing that Igor Gurevich himself was leaving QBF Group. At the same meeting Maksim Danilenko,
in order to accelerate the withdrawal of funds from his account, offered to sign new documents with the company
"White Lake Management Ltd.", afer which he signed a Service Agreement with LLC "VL Consulting" and a "Trust
Management" agreement № D - 000618 - F with the company "White Lake Management Ltd.". He also wrote a
statement on the sale of the securities portfolio and full withdrawal of funds. Afer signing all the documents, the
funds invested by him in the group of companies "QBF", still could not be withdrawn, financial advisor Danilenko
Maxim at several meetings in the office of the Company QBF assured him that the process of selling the portfolio is
very long and complicated. Arguing that the money had lef, but came back, or the account was blocked. He made all
possible excuses to just stall the time and that the money could be returned to me only afer the sale of the securities
portfolio. On 02.10.2020 he received a notification - report on the sale of assets, the free cash balance on the account
was 25 545, 84 USD. From that day he started to actively call Danilenko Maxim on the issue of returning the funds. But
from that moment Danilenko Maxim said that he was on a business trip, then began to say that he was on sick leave,
later he said that he was on holiday. Then at the end of 2020, he stopped contacting us altogether. In January 2021, a
new financial advisor Olga Dataeva (89645303356) got in touch with him and from the very first words she said that
she did not receive any money from him and would just inform him about the state of affairs and that it would take 2
to 3 years to return his money. Seeing the uselessness of these negotiations, he asked to organise a meeting with the
management of "QBF", as he is not satisfied with the position of Dataeva, afer which the excuses that the
management is on a business trip, busy working schedule and others started again. At the beginning of April 2021,
Dataeva called him and said that she had agreed his meeting with the management, which was scheduled for
15.04.2021. In the conversation, he told Dataeva that he was not coming to the meeting to negotiate but to receive his
money and asked her to bring this to the management's attention. On 15.04.2021 a meeting was held with Vladimir
Maslennikov (89645303216), head of the Investment Services Support Department, where he (Maslenikov) returned to
him 5000 USD (385,828.5 rubles at the Central Bank exchange rate as of 15.04.2021, 77.1657 rubles per 1 USD). During
the meeting Vladimir Maslennikov assured him that the rest of the money would be returned to him on 15.06.2021,
asking him not to send the statement he had written to the authorities. At the beginning of June 2021 he heard from
the mass media (official website of the Ministry of Internal Affairs of the Russian Federation) about a criminal case
initiated against the founders of the company QBEF. The meeting on 15.06.2021 appointed by Vladimir Maslennikov,
who promised to return the money invested by him, did not take place due to the events with the company "QBF"
that took place at the beginning of June. Till now the money invested by him in "QBF" group of companies has not
been returned to him in full volume. In total, he transferred 1,579,440 roubles to the "QBF" group of companies. He
believes that an offence has been committed against him, namely thef of his money by deceit and abuse of trust. He
considers the amount of damage caused to him as significant;
(Vol. No. 41, pp. 125 - 129, Vol. No. 42, pp. 5 - 8)
- other documents - documents provided by B.G. Kosovskiy confirming his relationship with QBF Financial Group
(Vol. No. 41, pp. 132 - 229, Vol. No. 42, pp. 9 - 110)
part 4 of article 159 of the Criminal Code of the RF against Semenov I.L.:
- another document - a statement by Semenov I.L., in which he asks to bring to criminal responsibility persons from
(Vol. No. 42, l.d. 122)
- I.L. Semenov's testimony as a witness and victim,

according to which, he, Igor Leonidovich Semenov, at the end of October, but no later than 30.10.2018, at
approximately 13:00 hours, together with his sister Ludmila Leonidovna Semenova in the office of QBF, located at the
931
address: Moscow, Presnenskaya Naberezhnaya 8, p. 1 (Moscow City) met with Andrei Korzh and Elena Iosifova, who
introduced themselves as employees of QBF Investment Company ("QBF") to negotiate his investment. 1 (Moscow
City), met Andrei Korzh and Elena Iosifova, who introduced themselves as employees of QBF Investment Company
("QBF") to negotiate the investment of his funds through trust management under a contract with QBF Investment
Company ("QBF"). According to the information on https://gbfin.ru, QBF had licences from the Central Bank of the
Republic of Belarus for investment activities. Korzh A. convinced them that they should not worry about the safety of
his (Semyonov's) money, because QBF always fulfils its obligations and puts the client's interests first (a literal phrase
he heard many times). Korzh A. and Iosifova E. have the QBF logo on their business cards, the same as on
https://qbfin.ru. Korzh A.'s job title on the business card is Head of Department; Information Services. Iosifova E.'s job
title listed on the business card is Financial Advisor. Korzh A. offered various investment instruments on behalf of QBF
("QBF"), which were printed on the letterheads of QBF IK LLC (INN: 7733673955; OGRN: 5087746335551). Korzh A.
explained to him that all operations would be carried out under the control of QBF ("QBF") and that all their clients'
accounts were insured with Alliance Insurance Group Afer such assurances, he agreed to transfer his funds to them
for management. Thus, on 06.11.2018, at approximately 13:00, he together with his sister Semenova L.L. arrived at the
office of "QBF" at the address: Moscow, Presnenskaya Naberezhnaya 8, p. 1 (Moscow City), where they were given the
opportunity to manage their funds. 1 (Moscow City), where they were met by Korzh A. and Iosifova E., who
subsequently provided him with a set of documents, including the assignment agreement No. 4648 dated 06.11.2018
concluded between him and QBF Advisery represented by attorney Frolov V.G., service agreement No. 4648 - 18/IMR
dated 06.11.2018 between him and "QCCI Ltd" (Cyprus) represented by Gorobets E.V. These agreements and other
accompanying documents were signed by him in the office of QBF Company at 8 Presnenskaya Naberezhnaya
Naberezhnaya, bldg. 1, Moscow (Moscow City International Business Centre) in the presence of Korzh A. and Iosifova
E. and his sister Semenova L. He wants to clarify that the contracts brought to him for signature were already signed
on the part of the above companies. I note that on every page of the assignment agreement No. 4648 dated
06.11.2018 between him and QBF Advisery, the logo of QBF) ("QBF") was present. On the same day 06.11.2018 he
handed over cash (in rubles) in the amount of 2 000 000 (two million) rubles to Korzh A. who gave him a stub of the
cash receipt order from the company "QCCI Ltd", in which there is an imprint of the seal of blue colour "QCCI LTD" and
the signature of the chief accountant Gorobets E.V. Regarding the Cyprus company "QCCI Ltd" (Cyprus), with which he
was actually forced to conclude a contract, he would like to explain the following. QBCI employees assured him that
this company was a subsidiary of QBCI, i.e. it was part of the QBCI group and therefore had the right to engage in
financial activities in Cyprus. As he subsequently found out, the company in question did not have any licences and
permits to engage in financial activities in the Republic of Cyprus. Additionally, he explains that Korzh A.
recommended that he hand over the money in cash to minimise transaction costs. Afer he handed over his money, he
was sent monthly reports by e - mail. The information came from the QBF server (gbcap.ru). From 01.09.2019 he
started receiving reports from another server, namely wl - mnt.com. To my questions about the content of the reports
he did not receive any clear answer, the content of the reports raises suspicions about the reality of investment
transactions. In January 2020, at a meeting with Korzh A. and Iosifova E. at the office of QBF Company, my sister
Semenova L. and I announced that we had decided to return our funds transferred to QBF Company ("QBF"). QBF
("QBF") in trust. Korzh A. informed that in order to return his monetary funds it is necessary to renegotiate the
contracts previously concluded on 06.11.2018. When asked about the reason for renegotiating the contracts, Korj A.
informed him that his funds were transferred to another company, for his own good, as the legislation in Cyprus had
changed. Korzh A. assured him that his funds would be immediately returned to him afer the conclusion of a new
contract with "White Lake Management", the execution of the notice and the withdrawal order. On 05.02.2020, Korzh
A. and Iosifova E. provided a new set of documents, including the "Trust Management" agreement dated 05.02.2020
between him and "White Lake Management Ltd", and the agreement with "VL Consulting" LLC dated 05.02.2020,
which were signed by him at the QBF office in the presence of Korzh A. and Iosifova E., and his sister Semenova L. As
previously, on 06.11.2018, on the part of the above companies, the contracts that were brought to him for signature
were already signed. In March 2020 in a telephone conversation Korzh A. informed that due to the collapse in the
stock markets he was recommended to postpone the withdrawal of his funds for several months. On 11.04.2013 he
submitted an order to sell 100% of his portfolio of shares, which were allegedly on his account. On 10.06.2021 he
received confirmation that the sale had been completed. The deadline for the sale, which is 30 working days, was
932
violated. On 31.07.2021 he submitted an application for withdrawal of funds. On 09.11.2020 he submitted a package
of documents (notarised translation of his Russian passport, certificate from the bank, his questionnaire and
certificate of no criminal record). On his questions about the terms of withdrawal of his funds Korzh A. evaded a
specific answer, his request for a meeting with the management of the company "QBF" Korzh A. ignored. At present,
Korzh A. has stopped responding to his requests and calls and has stopped contacting him. He also wants to
additionally show about the fact that he has not received any notifications, as well as documents for review,
confirming the acquisition of shares within his investment portfolio, and has not seen them. He has only received
reports provided by mail. He believes that QBF is not a financial market participant, but only serves as a cover, a
screen for fraudulent actions aimed at embezzlement of funds of citizens of the Russian Federation and their illegal
withdrawal abroad. These actions, in his opinion, were committed by a group of QBF employees, including but not
limited to Korzh Andrey and Iosifova Elena and other persons. It was these persons who, in his opinion, committed
the unlawful misappropriation (embezzlement) of funds belonging to him in the amount of 2,000,000 (Two million)
roubles;
(Vol. No. 42, pp. 125 - 129, 140 - 143)
- other documents - documents provided by I.L. Semenov confirming his relationship with QBF Financial Group (QBF
(Vol. No. 42, pp. 146 - 193)
part 4 of article 159 of the Criminal Code of the RF against Semenova L.L.:
- another document - a statement by Semenova L.L., in which she asks to bring to criminal responsibility persons
(Vol. No. 43, l.d. 6)
- Testimony of L.L. Semenova, given to her as a witness and victim,

according to which, she, Ludmila Leonidovna Semenova, in October 2018 from her old acquaintance Svetlana
Anokhina (8 - 903 216 - 12 - 08), learnt that "IC QBF" ("QBF") offers to carry out trust management of funds, profitably
investing them in various instruments, including in the stock market. Anokhina S. argued that money should be
entrusted to "professionals" and gave her the contact details of Iosifova E., an employee of this company. At the end
of October, but no later than 30.10.2018, at approximately 13.00 hours, in the office of QBF company, located at the
address: Moscow, Presnenskaya Naberezhnaya 8, pg. 1 (Moscow City), she and her brother Semyonov Igor
Leonidovich met Andrei Korzh and Elena Iosifova, who introduced themselves as employees of QBF. The business
cards of Korzh A. and Iosifova E. bear the logo of QBF, the same logo that appears on the website https://qbfin.ru.
Korzh A.'s job title on the business card is Head of Information Services. The position of Iosifova E. indicated on the
business card is Financial Advisor. - Financial Advisor. Korzh A. and Iosifova E. offered, on behalf of QBF, various
investment instruments, which were printed on the letterheads of QBF LLC (INN 7733673955; OGRN 5087746335551).
Korzh A. and Iosifova E. explained to her that all transactions would be carried out under the control of their company,
which was licensed in the Russian Federation, and that all of their clients' accounts were insured with Alliance
Insurance Group. Afer such assurances, she agreed to hand over her tender funds to them for management. Thus, on
06.11.2018, at about 13:00, in the office of QBF, located at the following address: Moscow, Presnenskaya
naberezhnaya 8, pg. 1 Moscow City) Korzh A. and Iosifova E. provided her with a set of documents, including:
assignment agreement No. 4647 dated 06.11.2018 between her and QBF Advisery, represented by Frolov V.G., service
agreement No. 4647 - 18/IMR dated 06.11.2018 between her and QCCI Ltd (Cyprus), also represented by Frolov V.G..,
933
however, the said document contains an identical signature in the receipts to the arrival orders signed by a certain
Gorobets E.V. This agreement and other accompanying documents were signed by her in the office of QCCI Ltd. at 8
Presnenskaya Naberezhnaya Naberezhnaya, bldg. 1, Moscow. (MIBC "Moscow City") in the presence of Korzh A. and
Iosifova E. and her brother Semyonov I. Wants to clarify that the contracts that were brought to her for signature were
already signed by the above companies. Notes that the logo of QBF ("QBF") is present on each page of the assignment
agreement No. 4647 dated 06.11.2018. Thus, on 06.11.2018 she handed over the cash (in rubles) to Korzh A., who gave
her the stub of the cash receipt slip of the company "QCCI Ltd" (Cyprus). On the following day 07.11.2018, she brought
cash in the amount of 5,000 (five thousand) US dollars to Korzhu A. at the office of "QCCI Ltd", which at the exchange
rate of the Central Bank of the Russian Federation as of 07.11.2018 is equivalent to 329,950 rubles. In total, she
handed over cash in the amount of RUB 2,029,950 to QBeeF employees. Regarding the Cyprus company "QCCI Ltd"
(Cyprus) with which she was actually forced to conclude a contract, she would like to clarify the following. QCCI
employees assured her that this company was a subsidiary of QCCI, i.e. it was part of the QCCI group and therefore
had the right to engage in financial activities in Cyprus. As she subsequently found out, the company in question did
not have any licences or permits to engage in financial activities in the Republic of Cyprus. She further explains that
Korzh A. recommended that she hand over the money in cash to minimise transaction costs. Afer she handed over
her money, she was sent monthly reports by e - mail. The information came from the QBcap server (qbcap.ru). From
01.09.2019 she started receiving reports from another server, namely wl - mnt.com. In January 2020, at a meeting with
Korzh A. and Iosifova E. at the QBF office, she and her brother Semyonov Igor announced that they had decided to
return their money transferred to QBF ("QBF") for trust management. Korzh A. informed that in order to return her
monies it was necessary to renegotiate the contracts previously concluded on 06.11.2018. When asked about the
reason for renegotiating the contracts, Korzh A. advised that her funds had been transferred to another company.
Korzh A. assured that there was no need to worry about the safety of her funds, as the company "QBF" ("QBF") always
fulfils its obligations and puts the interests of the client above all else (a verbatim phrase she had heard many times).
Korzh A. promised her to immediately return the funds afer concluding a new contract with "White Lake Management
Ltd.", executing a notice and withdrawal order. Andrey Korzh claimed that the new contract was a successor to the
previous contract. On 05.02.2020 Korzh A. and Iosifova E. provided a new set of documents, including the trust
management agreement No. D - 168597 - B dated 05.02.2020 between me and "White Lake Management Ltd" and the
agreement with "VL Consulting" Ltd. dated 05.02.2020, which were signed by her at the QBF office in the presence of
Korzh A. and Iosifova E., as well as her brother Semenov I. In March 2020 in a telephone conversation Korzh A.
informed her that due to the collapse of the stock markets she was recommended to postpone the withdrawal of her
funds for several months. On 23.09.2020 she received an order to sell 100% of her portfolio (shares allegedly on her
account). As per the terms of the agreement, the sale of her portfolio was to be completed within 30 working days. To
date, she has not received any response about the sale. On her behalf, her brother has been asking Korj A. on a weekly
basis since 15.11.2010 by phone and via WhatsApp "When can she get the money?". Korzh A. replied that he would
look into it. Since mid - December Korzh A. stopped answering her questions. On 11.12.2020 she sent a letter to
Stanislav Anatolievich Matyukhin, General Director of QBIF LLC (the letter is attached). On 15.01.2021 she received a
reply (the reply is attached), from which it follows that the companies with which she concluded contracts on
06.11.2018 and 05.02.2020 are not related to QBF, and Korzh A. and Iosifova E. do not work for QBF. She also wants to
say additionally about the fact that she has neither received nor seen any notifications or documents confirming the
acquisition of shares within her investment portfolio. She has only received reports provided by mail. She believes
that QBF is not a participant of the financial market, but only serves as a cover, a screen for fraudulent actions aimed
at embezzlement of funds of citizens of the Russian Federation and their illegal withdrawal abroad. These actions, in
her opinion, were committed by a group of QBF employees, including, but not limited to, Andrey Korzh and Elena
Iosifova and other persons. In her opinion, an offence, namely fraud, has been committed against her. She has
suffered material damage totalling 2,029,950 roubles. She assesses the damage to herself as significant;
(Vol. No. 43, pp. 9 - 13, 16 - 20, 31 - 34)
- other documents - documents provided by L.L. Semenova confirming her relationship with QBF Financial Group
934
(Vol. No. 43, pp. 14 - 15, 21 - 22, 40 - 131)
part 4 of article 159 of the Criminal Code of the Russian Federation against Bolshov M.A.:
- another document - a statement by Bolshov M.A., in which he asks to bring to criminal responsibility persons from
(Vol. No. 43, pp. 143 - 145)
- Bolshov M.A.'s testimony as a witness and victim,

according to which, around the end of 2014, he received a call on his mobile phone number from the manager of the
"QBF" group of companies (he found it difficult to give his name). On the phone they discussed investing his personal
funds in the group of companies. Afer some time, they agreed to meet at the main office at the address: 8
Presnenskaya Naberezhnaya Naberezhnaya, bldg. 1, 9th floor, Moscow. On 08.12.2014, it is difficult to give the exact
time due to the age of the events, he arrived at the office of the QBF group of companies located at 8 Presnenskaya
Embankment, page 1, Presnenskaya Embankment, Moscow. There I signed the documents provided to him by QBF
employees, namely: Agreement on provision of services of direct access to international stock markets No. 1931 -
14/IMR dated 08.12.2014 between him and QB Capital CY LTD. currently he does not have this document, he cannot
provide it, agreement on provision of "Trust management" services, in accordance with the agreement on provision
of services of direct access to international stock markets No. 1931 - 14/IMR dated 08.12.2014 between him and the
company "QBF" LLC represented by the Director of Sales Department Munaev Z.V. Within the framework of the
documents concluded with him (Agreement and Contract), he deposited funds to the address of the group of
companies "QBF", part of which, according to the Annex to the above - mentioned agreement signed by him, is
directed to real estate funds. He received reports on the status of his investment portfolio to his e - mail
[email protected]. Several years later and afer his request for withdrawal of funds in full from 08.02.2017, he was
problematically, through a bunch of negotiations, but still withdrew the funds, including earned interest, within a
year. Some part of the funds (he admits) that could have remained in the units of the ZPIF, however, taking into
account the funds withdrawn by him, taking into account the profit, what part of the funds remained not withdrawn
by him, he does not know exactly. Besides, as he realised later, the reports sent to his e - mail contained unreliable
information and did not correspond to reality. He had no claims against the QBF group of companies with regard to
his investment of the above - mentioned funds. He did not retain the documents confirming the deposit and
withdrawal of funds in this part. Afer some time, the manager of the group of companies "QBF" Iosifova Elena called
him on his mobile phone number and offered him to participate in the investment activity again. Iosifova E. insisted
and informed him that at present the group of companies "QBF" has got a reliable investor - partner and withdrawal
of money is guaranteed within a calendar month. He was also provided with this information by Iosifova E.'s manager,
Korzh Andrey. Eventually they agreed that he would come to the company's office, sign documents and immediately
deposit cash. On 13.12.2018, at approximately 14:00, he arrived at the office of the "QBF" group of companies at the
address: Moscow, Presnenskaya Naberezhnaya, 8, p.1, 9th floor. He was met at the entrance by Andrey Korzh. During
the meeting in the office, Korzh A. led him to the meeting room, where he presented the investment products
available in the organisation, the ways of investing, the mechanism of profit formation, the procedure of reporting
and informing the client, as well as the structure of the organisation in general. He was informed that the money will
be invested in investment sites of foreign countries and for this reason the money is required in currency. Everything
was presented in a colourful way, devoid of flaws, and he was promised high returns. And Korzh additionally informed
him that the withdrawal of money is now taking place within one month. As a result of the meeting he finally got the
impression that the group of companies "QBF" could be trusted with his assets, and he gave his consent to invest the
money. Korzh A. had already prepared and signed documents on the part of "QBF" group of companies, namely: an
additional agreement to the agreement on the provision of "Trust Management" services No. 1931 - 147/IMR dated
08.12.2014 between him and "QBF" LLC. During the meeting held on 13.12.2018, he signed the said document. On
13.12.2018 he, being in the office of the "QBF" group of companies at the address: Moscow, Presnenskaya
935
Naberezhnaya, 8, pp. 1, handed over cash in the amount of USD 25,000, which at the exchange rate of the Central
Bank of the Russian Federation as of 13.12.2018 was RUB 1,660,500. He handed the cash to Korzh A., he counted it on
a note counting machine and handed him a receipt to the QCCI ltd cash receipt order for the amount of USD 25,000,
where the signatory of the receipt is Gorobets E.V., and there is also an imprint of the QCCI ltd seal. He has never seen
or communicated with E.V. Gorobets. His email address [email protected] continued to receive reports on the status
of his investment portfolio. In the summer of 2019, for personal reasons, he had a need for a full withdrawal of funds,
in connection with which he contacted his financial advisor Korzh A. and applied for a withdrawal. He notified Korzh
A. that he was going to withdraw the funds, to which Korzh A. informed him that he needed to notify the company in
writing. In connection with the above, he visited the company on 18.06.2020, approximately at 12:00 a.m., in the office
at the address: Moscow, Presnenskaya Naberezhnaya, 8, bldg. 1, 9th floor, where he wrote a notice of withdrawal of
funds. Afer submitting the withdrawal notice, Korzh A. informed him that he needed to collect a large list of
documents to withdraw the funds, which included very strange items, such as an English translation of his passport, a
certificate of no criminal record, etc., including that he was a bona fide client of Sberbank of Russia PJSC. He informed
Korzh A. in a straightforward manner that he would not provide a notarised copy of his passport for reasons of his own
security and that it was nonsense. Afer this conversation Korzh A. stopped contacting him, began to avoid personal
meetings and communication. All communication, or rather delaying the withdrawal of his money from the group of
companies "QBF", was closed on correspondence. Later, at the end of May - beginning of June 2021, he learned from
the media, including the official news of the Ministry of Internal Affairs of Russia, that criminal proceedings had been
initiated and an investigation was underway. Taking into account the above, as well as the impossibility of withdrawal
of the invested funds and delaying this process by QBF employees by all means, he had no doubts that he had
become a victim of fraudsters. In total, he transferred money in the amount of 1,660,500 rubles to the address of
"QBF" group of companies on 13.12.2018. He considers that an offence has been committed against him, namely the
thef of his money by deceit and breach of trust in the amount of 1 660 500. He considers the amount of damage
(Vol. No. 43, pp. 149 - 153, 160 - 164)
- other documents - documents provided by M.A. Bolshov confirming his relationship with QBF Financial Group (QBF
(Vol. No. 43, pp. 167 - 198)
part 4 of article 159 of the Criminal Code of the Russian Federation against Dianov E.G.:
- another document - a statement by E.G. Dianov, in which he asks to bring to criminal responsibility persons from
(Vol. No. 44, l.d. 6)
- Testimony of Dianov E.G., given by him as a witness and victim,

according to which, he, Dianov Evgeny Gennadyevich, approximately in early autumn 2018, from his acquaintance
Kudoyarov Timur (8 - 919 - 998 - 5661), with whom he previously worked in PJSC Gazprom Nef, heard several times
about the possibility of entrusting the management of his money to the company QBF. Timur Kudoyarov repeatedly
told him in telephone conversations and during a personal meeting held in September 2018 in a café near
Paveletskaya metro station how he had profitably invested his family money by entrusting it to QBF for trust
management. Timur Kudoyarov told him at a personal meeting that Grigor Yerzikyan, an employee of QBF, suggested
him to transfer the money to the trust management of QBF. According to Timur Kudoyarov, he knew Grigor Yerzikyan
936
as an employee of VTB Bank. Being a client of VTB Bank, Kudoyarov co - operated with Erzikyan during the period
when Grigor Erzikyan was managing clients' money in VTB Bank on trust. Timur Kudoyarov spoke highly of QBF and
personally of Grigor Yerzikian, who, having become an employee of QBF, was also a personal financial adviser to
Kudoyarov's mother. Afer listening carefully to Timur Kudoyarov, whom he knew well and trusted, he decided to
contact Grigor Yerzikian and discuss with him the possibility of transferring his money to QBF's trust management.
Around the end of November 2018, he called Grigor Yerzikyan, introduced himself to him, and said that he had
received information about him and QBF from their mutual acquaintance Timur Kudoyarov. He would like to explain
that he called Grigor Yerzikyan on one of his two telephone numbers: +7(916)727 - 3909 and +7(903)100 - 4760, which
he had previously received from Timur Kudoyarov. During the telephone conversation with Grigor Yerzikyan, the latter
invited him to a meeting at the QBF office to discuss in detail the conditions of possible management of my funds.
Grigor Yerzikyan invited him to the QBF office located at 8 Presnenskaya Naberezhnaya Embankment, p. 1, 9th floor
(Moscow City). 1, 9th floor (Moscow City). He came to the QBF office at the above address three times during the week
from 3 to 7.12.2018. At the first meeting, which took place on 03.12.2018, he was met only by Grigor Yerzikyan, an
employee of QBF Company, who introduced himself as a financial advisor of QBF. At the second meeting (05.12.2018),
in addition to Grigor Yerzikyan, Nikolay Padalko (8 - 954 - 530 - 3376), who introduced himself as the Director of Sales
and Customer Service of QBF, was also present. At the third meeting (07.12.2018), in addition to Grigor Yerzikyan,
Alexey Golubev (8 - 921 - 858 - 1624), who introduced himself as Regional Director, was also present. During all three
meetings, he was offered different options for trust management, and the terms of such trust management were
described in general terms. Also at these three meetings, Messrs G. Erzikyan, N. Padalko and A. Golubev convinced
him of the absolute reliability and safety of working with QBF, as well as of the high returns he could expect from the
management. According to G. Yerzikyan, N. Padalko and A. Golubev, the high returns were expected because QBF
employees intended to invest his money in securities on the U.S. market, which, they said, would guarantee the high
returns from managing his money. Afer the first three meetings held in the week between 03 and 07 December 2018
at QBF's office, he began to be contacted by telephone and email several times a week (sometimes several times in
one day) by G. G. Yerzikyan and N. Padalko, who always appeared to be employees of QBF. These persons began to
offer him for signing various variants of contracts for the management of his money and to voice various strategies of
trust management of his funds. They also discussed the terms of the contracts with him. As a result of such powerful
psychological processing G. Yerzikyan and N. Padalko persuaded him to transfer the money belonging to him in the
amount of 68,000,000 rubles to QBF Company for trust management. At the same time, it was Grigor Yerzikyan, who
represented himself as his financial advisor and adviser to QBF, who sent letters with evidence of historically high
financial returns on QBF's trust management. Grigor Yerzikian also sent him the text of the contract and convinced
him of the favourable offshore jurisdiction of the Cayman Islands. It was Grigor Yerzikyan who persuaded him to
conclude a contract for the management of his money with a certain company "White Lake Management Ltd",
assuring him that this company was a subdivision of QBF and his money would be in safe hands. According to Grigor
Yerzikyan, the necessity to conclude a contract with this company from the Cayman Islands was caused by the fact
that out of all the companies of QBF group, only this company can work on the American stock market, as only this
company has all the necessary permits and licences of the American regulators. He would like to clarify that at that
moment he was under dense psychological pressure from G. Yerzikyan and N. Padalko, who were "processing" him
almost on a daily basis and inducing him to transfer money to the company controlled by QBF as soon as possible. It
is these circumstances that he explains that he agreed to sign an agreement with some company that supposedly had
permits to work on the American stock market and at the same time he did not receive any reliable and legally
obtained documents from the persons who "processed" him, which really testify that the company White Lake
Management Ltd. that G. Yerzikyan and N. Padalko persistently offered him really works on the American financial
market, is known on this market, really has all the necessary licences and permits, etc. In order to demonstrate loyalty
and put his vigilance to sleep, QBF sent him by email (and through G. Yerzikyan) an invitation to a festive dinner with
Zelimkhan Munayev, Managing Partner of QBF Financial Company, in honor of his (Dianov's) birthday (26.12.2018),
which he (Yerzikyan) cancelled immediately afer he transferred funds. As he understands now, continuing to
psychologically process him, for the purpose of further illegal seizure of my money, G. Yerzikyan and N. Padalko
offered him, in addition to concluding a money management agreement with an unknown Cayman Islands one - day
firm, to transfer money not directly to this firm, but to its payment agent - a certain company "Simtelligence Company
937
Limited". This company, according to Grigor Yerzikyan, is the payment agent not only of "White Lake Management
Ltd", but also of the whole group of companies "QBF". Since it is Simtelligence Company Limited that has a ruble
account and can accept money from QBF clients in rubles. As a result, as a result of powerful psychological treatment
by Grigor Yerzikyan and Nikolay Padalko, these persons persuaded him to give (transfer) his funds in the amount of
RUB 68,000,000 to an unknown company White Lake Management Ltd (Cayman Islands), which has the signs of a one
- day company, and not directly, but to the account of Simtelligence Company Limited No. 1570033649480158 opened
with Ameriabank CJSC (Yerevan, Armenia). This transaction was made on 28.12.2018 (payment order attached).
Having succumbed to such psychological treatment and pressure, believing Grigor Yerzikyan and Nikolay Padalko,
who constantly assured him of the reliability and legality of the trust management of his money, at the same time
constantly slipping him some documents, which according to them were supposed to testify that it was impossible to
formalise the trust management of his money in any other way, given the fact that according to these persons, his
money would be invested by them in the purchase of securities on the American fund. He 25.12.2018 in the office of
QBF company, located at the address: Moscow, Presnenskaya Naberezhnaya 8, str. 1, 9th floor (Moscow City), signed a
trust management agreement for his money with White Lake Management Ltd and transferred USD 1 (one) million in
rubles at the exchange rate of the Central Bank of the Russian Federation to Simtelligence Company Limited account
No. 1570033649480158 opened with Ameriabank CJSC Yerevan Armenia, as instructed by Grigor Yerzikyan. At the
same time, the agreement itself was dated retroactively (10.12.2018) and contained not original but facsimile
signatures. He also explains that he made the transfer from Sberbank branch No. 9038/01833, located at the address:
5, Soymonovsky proezd, Moscow. The following employees of PJSC Sberbank worked with him at this branch: Maria
Serebryakova (Deputy Head of the additional office, tel. +7 - 916 - 683 - 9962) and Eldar Balkarov (Client Manager, tel.
+7 - 929 - 509 - 9323). Grigor Yerzikyan insisted on performing all transfer operations from this particular Sberbank
branch, saying that he always works with this branch and has acquaintances there. He explains that Grigor Yerzikyan
brought him the agreement on trust management of his money with the company "White Lake Management Ltd" (No.
4696 - 18IMR dated 10.12.2018), ready and signed by this company. In the same agreement, "Simtelligence Company
Limited" is also indicated as a paying agent. The invoice issued to "Simtelligence Company Limited" for the interbank
transfer and the agency agreement between "Simtelligence Company Limited" and "White Lake Management Ltd" on
24.12.2018 was also sent to him by Grigor Yerzikyan. In response to his question who exactly signed these documents,
Grigor Yerzikyan told him that he should not worry, everything was done legally and signed by authorised persons, in
confirmation of which Grigor Yerzikyan showed me some powers of attorney for the right to sign the contracts. In
addition, on 27.12.2018 Grigor Yerzikyan sent him an official letter to his email for the bank confirming that "White
Lake Management Ltd" and "Simtelligence Company Limited" are duly established and registered companies, as well
as the fact that "these companies are under common control of the same individual (shareholder and director)".
Having trusted Grigor Yerzikyan, he, obeying his instructions, transferred money to the account indicated by him and
signed, practically without reading, the contract offered to him and signed in advance by someone else. Afer that, for
a year and a half Grigor Yerzikyan, presenting himself as his financial advisor and a full - time employee of QBF,
regularly assured him that his money was competently invested and in safe hands. In January 2020, having previously
seen a lot of feedback from QBF clients on the Internet about difficulties with withdrawal of funds and possible
fraudulent actions on the part of the company, he asked his financial advisor Grigor Yerzikyan at a personal meeting at
the QBF office to conclude a contract with him in the Russian jurisdiction as soon as possible. Having promised to
conclude such an agreement with him within a month, such an agreement was never concluded by Grigor Yerzikyan
under various pretexts. During this period, from January to May 2020, numerous correspondence and telephone
conversations took place with the employees of QBF: Ruslan Spinka, Director of Sales and Customer Service (8 - 967 -
186 - 6039) and Evgenia Rossieva, Legal Consultant (8 - 985 - 173 - 4321). On 22.07.2020 at a personal meeting with
Grigor Yerzikyan and Ruslan Spinka in the office of QBF company, he, having failed to receive the promised income
from money management, having started to realise that it was urgent to take money from possible fraudsters, gave an
order to sell the portfolio of shares, in which Grigor Yerzikyan assured that his money was invested. In September
2020 Grigor Yerzikyan showed him financial (payment) documents allegedly confirming the sale of the share portfolio
and the availability of money from this sale. Afer that he demanded from Grigor Yerzikyan to immediately return his
money, previously transferred to QBF, to his account indicated by him to Grigor Yerzikyan. For three months, from the
end of September 2020 to the end of December 2020, Grigor Yerzikyan delayed the return of his money under various
938
pretexts. Each time we talked to him, he told him another apparently false story explaining and justifying that once
again the money could not be returned to him. Afer he started to insistently demand the return of the entire amount
of money previously transferred to QBF, Grigor Yerzikyan in telephone conversations began to constantly say that the
money is not returned to him because the head and actual beneficiary of QBF Roman Valerievich Shpakov (tel. +7 -
905 - 735 - 55 - 88) believes that he does not need to return the money, and no one will return the money to him
without his decision. Also Grigor Yerzikyan told him that he should communicate with Vladimir Alexandrovich
Maslennikov - Vice President of QBF (8 - 991 - 709 - 0687 and 8 - 964 - 530 - 3216) on the issue of returning the money.
In the period from November to December 2020, he repeatedly asked and demanded in telephone conversations and
by correspondence from Maslennikov V.A. and Shpakov R.V. to return the money previously transferred to him. In
response, he first heard promises to return the money by the end of 2020 (from Shpakov R.V. at a personal meeting on
04.12.2020), and during the last communication with Maslennikov V.A. he was offered to take 100 000 (one hundred
thousand) US dollars and to sign documents waiving the requirements to return the rest of the amount, i.e. to
voluntarily, in writing, give up his own money. Maslennikov V.A. responded to such an offer with a categorical refusal
and demanded that he immediately give him all his money. Maslennikov told him that he would not receive his
money, in any case, in the near future. And R.V. Shpakov wrote to him in correspondence that he was misbehaving,
and at a personal chance meeting on 28.12.2020 in the building of the QBF office he informed him that he did not
want to meet and communicate with him anymore. During the face - to - face meeting held on 28.12.2020 between
him (Dianov), Grigor Yerzikyan and V.A. Maslennikov, which took place in the office of the company "QBF", located on
the 9th floor of the office building at the address: Moscow, Presnenskaya Naberezhnaya, 8, p.1, (MIBC "Moscow City"),
Grigor Yerzikyan and V.A. Maslennikov once again offered him to take from them 100,000 (one hundred thousand) US
dollars instead of the 68,000,000 roubles he had previously received from him, which is about 1 (one) million US
dollars. He once again categorically refused such fraudulent offer and demanded to immediately return to him the
entire amount of money he had previously received from him. Grigor Yerzikyan and V.A. Maslennikov responded by
saying that they would not return the money they had previously received from him. He would like to clarify that on
30.12.2020 and 14.01.2021 he sent official demands to the QBF company and directly to the above - mentioned
persons to return the money. In these letters, he had mentioned the specific bank account to which the refund should
be made. He did not receive any response to his letters, except for the receipt of two transfers, namely USD 6,150 on
06.05.2019, which at the exchange rate of the Central Bank is RUB 397,290, and USD 3,045 on 18.09.2020, which at the
exchange rate of the Central Bank is RUB 228,679. At the same time, he continued to receive calls from Maslennikov
V.A., who, as he is sure, realising his earlier criminal intent, in order to divert his attention and prevent him from
contacting law enforcement agencies, continued to deceive him and offered to wait a little longer for the return of the
money. As he has already indicated above, the illegally received from him and embezzled funds, according to the pre -
existing intention of the group of persons indicated by him, were immediately, that is, in December 2018, transferred
abroad, to the accounts of the company controlled by them, which has the signs of a one - day firm. Moreover, they
were withdrawn under fictitious documents, as there was no real trust management of his money and initially was
not supposed, but it was supposed to steal his money by deception and withdraw it abroad under fictitious
documents. He would like to clarify that a group of persons consisting of the above - mentioned G.R. Erzikyan, V.A.
Maslennikov, R.V. Spink, Z. Munayev, N. Padalko, A. Golubev, E. Rossieva, as well as Andrei Korzh and Elena Iosifova
unlawfully misappropriated the money of dozens of citizens of the Russian Federation through deceit. Some of the
defrauded citizens were interviewed by his lawyer during the preparation of the present application. Minutes of their
interviews are attached to the present application. Thus, he believes that a group of persons consisting of G. R.
Erzikyan, V. A. Maslennikov, R. V. Spink, Z. Munayev, N. Padalko, A. Golubev, E. Rossieva and other unidentified co -
conspirators, led by R. V. Shpakov, by means of deceit, stole money belonging to him in the amount of 67,374,031
roubles, and subsequently, using fictitious documents not reflecting the facts of real economic activity, illegally
transferred them outside the Russian Federation, i.e. committed offences under part 4 of article 159 and part 3 of
article 193.1 of the Criminal Code of the Russian Federation;
(Vol. No. 44, pp. 9 - 15, 26 - 32, 41 - 43)
- other documents - documents provided by Dianov E.G. confirming his relationships with QBF Financial Group (QBF
939
(Vol. No. 43, pp. 16, 33, 44 - 45, 47 - 82)
part 4 of article 159 of the Criminal Code of the Russian Federation against Gubanov A.V.:
- another document - a statement by Gubanov A.V., in which he asks to bring to criminal responsibility persons from
(Vol. No. 44, pp. 89, 93)
- A.V. Gubanov's testimony as a witness and victim,

according to which, he learned about the company "QBF" from his brother Dmitry Gubanov and further met the
company for the first time at a joint meeting, which they came to together with his brother Dmitry in late September
2018. At the meeting on the QBF side were Zarina Salimova (hereinafer my financial advisor) and the senior
management of the company (Gevorg Gevorgyan and Alexey Golubev). At this meeting they were told in detail about
the company, its capabilities, asked about our goals, investment wishes and the amounts to be invested. We were
promised a high yield and he was offered to invest the available funds in roubles in the company "QBF" to carry out
financial operations on the international market. He was immediately warned that the roubles would be converted
into currency as the company operates on foreign markets. He was interested in the offer. Having studied information
about QBF in open sources, he found it attractive enough to try to work with it. The presence of 4 licences of the
Central Bank of the Russian Federation was one of the most important moments that determined the reliability of the
company. 09.10.2018 - under the pretext of investing his funds in high yield securities on behalf of a non - resident,
"QCCI LTD" ("QCCI LTD") on 09.10.2018 concluded by "QBF" the Agreement on provision of services of direct access to
international stock markets No. 4590 - 18/ISR dated 08.10.2018, as well as on behalf of "QBF Advisor" LLC the
Assignment Agreement No. 4590 dated 08.10.2018. 09.10.2018 - The first payment was made to QBF in the amount of
R5,000,000 (five million). The funds were brought in cash and transferred to the company "QBF" at the company's
cash desk located at the address: Degtyarny per. 11B in the Nevskaya Ratusha business centre. As stated by the
financial advisor and in accordance with the terms described in the agreement, these funds were to be converted into
dollars at the current exchange rate and sent to the foreign company "QCCI LTD", which is a part of QBF, within the
framework of which investments are made on the international market. In this company "QCCI LTD" was to open his
trading account (attached to the master account of the company) into which these funds were to be credited. Judging
from the investment reports which he further started receiving from "QBF", the said amount appeared in his trading
account. On 22.11.2018 - a second payment was made to "QBF" in the amount of 5,000,000 (five million) roubles. The
funds were brought in cash and transferred to the company "QBF" at the cash desk of the company at the above
address. These funds afer conversion into dollars at the current exchange rate for that day were to be credited to his
previously opened trading account in the company "QCCI LTD" and used for investment (expansion of the investment
portfolio). Judging by the investment reports provided further, this amount appeared on his trading account. On
22.11.2018 an additional agreement No. 3 to the Assignment Agreement No. 4590 dated 08.10.2018 (investment
declaration) was also signed. On 30.01.2019, the Direct Access to International Stock Markets Service Agreement No.
4757 - 19/ISR dated 30.01.2019 was signed with the company "QCCI LTD". On 31.01.2019 a service agreement No. 4590
dated 31.01.2019 was signed with VLM Limited Liability Company registered in the Cayman Islands, as well as a
determination on termination of the agreement on provision of services of direct access to international stock
markets No. 4590 - 18/ISR dated 08.10.2018, as well as a determination on termination of the Assignment Agreement
dated 08.10.2018 between QBF Advisery LLC and Alexey Vyacheslavovich Gubanov. Copies of these documents are
attached. On 05.02.2019 the third payment was made to "QBF" company in the amount of 5 000 000 (five million)
rubles. The money was brought in cash and handed over to QBF Company at the company's cash desk at the above
address. On 28.08.2019, he signed Trust Deed No. D 605269 - N with White Lake Management Ltd. as well as Service
Agreement with VL Consulting Ltd. as well as Additional Agreement No. 1, 2, 3 to Service Agreement No. 605269 - 09
dated 28.08.2019. Copies of the said documents are attached. The total amount of money transferred to the company
"QBF" (in three payments in cash in the office of the company) was 15 000 000 (fifeen million) rubles. During all this
940
time "QBF" company regularly (once a month) sent investment reports to the mail, in which it was visible, in which
assets the funds were invested, what profit (or loss) on these or those positions and in general what indicators on my
investment portfolio per month. Also during the whole time about 10 meetings were held in the office of the company
"QBF" at the address: Degtyarny per. 11B in the Business Centre "Nevskaya Ratusha" with his financial advisor (Zarina
Salimova) and the top management of the company (Gevorg Shakespevich Gevorgyan and Alexey Golubev). At these
meetings, sometimes they reviewed his investment reports, sometimes they proposed various investment ideas,
explained the structure and principles of the company's work, and offered to contribute additional funds to increase
the size of the investment portfolio and the profits from it. For a long time he did not make any attempt to withdraw
funds from the company, but gradually he started to see losses in the investment reports sent to him and that the
total amount he had contributed was already starting to decrease a lot, not making a profit for many months in a row.
Therefore, by May 2021, he decided to withdraw all the funds he had previously contributed from QBF. In May 2021, he
scheduled a meeting with his financial advisor (Zarina Salimova) to announce his decision to withdraw the funds and
to learn about the sequence of actions required to do so. He was given a list of documents that needed to be collected
in order to be able to make the withdrawal of funds from White Lake and return them to the Russian Federation. He
began to collect these documents. Then, in June 2021, he learnt from the media about the searches conducted at QBF
in Moscow and St. Petersburg. He tried to find out the details of the situation from his financial advisor, to which he
received information that indeed the servers of the company "QBF" were seized and therefore there are difficulties
with the work of the company, but that it is temporary and most likely everything will soon get better. And that the
procedure of withdrawal of funds from White Lake can be continued, as it is another jurisdiction (Cayman Islands) and
everything works there. Further, on 16.06.2021 he signed the Notice of Asset Disposal, from the moment of signing of
which the sale of his investment portfolio was to start, in order to get out of the assets again into cash (dollars) on his
trading account, which can be further received back. The sale of the portfolio from the moment of signing the
application should have taken 30 - 40 days according to the assurances of the company "QBF", afer which he would
have to sign the final application with the balance on the account and from this moment in 1 - 3 months he could
already receive funds in the territory of the Russian Federation. The company "QBF" initially assured him that the
withdrawn funds could be received back in cash in the office of their company at the address: Degtyarny per. 11B in
the Nevskaya Ratusha Business Centre. Further it became clear that they no longer issue cash refunds, and they
began to say that the refunds could only be transferred to a personal current account in a Russian bank. Further
"QBF" informed that the transfer to the bank account is also impossible, and it is possible to return the money only
through the redemption of some shares in warehouse real estate (REF), about which a detailed commercial offer was
sent to the mail. QBF further informed him that the purchase of units and return of capital in this way was also not
possible due to some internal reasons. As a result, 30 - 40 days afer signing the Notice of Disposal of Assets (dated
16.06.2021), he still has not received any document for the sale of these assets and the document for reconciliation of
the final balance before withdrawal of funds. He is still receiving investment reports from White Lake in the mail, as if
he still has all the assets in his account in the form of previously purchased securities. He has also not received his
funds, the return of which was requested from QBF, by any of the methods offered by them, although the deadlines
for the return procedure have already passed, as stated and described in the contract with QBF. He has tried writing
directly to White Lake's email to get information on when the assets will be realised in accordance with the signed
notice, and to inquire about withdrawals from them directly. I have not received any answer from them till now.
Gevorg Gevorgyan and Alexey Golubev, whose contact details he had, have also stopped contacting him to comment
on the situation. His financial advisor - Zarina Salimova was in touch with him and tried to help him as much as
possible in the situation, but as he understood, the top management also stopped informing her and she had no
answers to many questions. She advised him to address to the investigator in Moscow on this case and gave him his
phone number, as she also felt deceived by the "QBF" company, which apparently misled her as an employee all this
time. Taking into account the fact that the terms of returning the money to him expired, there was no doubt that he
became a victim of swindlers. Up to the present time he has not been returned his money deposited to the "QBF"
group of companies in the amount of 15 000 000 (fifeen million) roubles. He believes that the persons acting on
behalf of the group of companies "QBF" initially did not intend to fulfil their obligations to him and acted solely for the
purpose of stealing his money by deceiving him. In the period from 09.10.2018 to 05.02.2019 the persons acting on
behalf of the "QBF" group of companies stole money belonging to him in the total amount of 15 000 000 rubles. He
941
estimates the amount of damage caused to him as significant. He has been explained the right to file a civil suit in the
criminal case. He wishes to exercise this right and file a suit. He has been given the right to familiarise himself with the
composition of the investigation teams, the decisions to order forensic examinations, the expert reports, the records
of expert interrogations, and the materials of the criminal case in full or in part. He does not wish to exercise this right.
He did not apply to the court with applications for recovery of money from the "QBF" group of companies;
(Vol. No. 44, pp. 94 - 98, Vol. No. 45, pp. 5 - 10,)
- other documents - documents provided by A.V. Gubanov confirming his relationship with QBF Financial Group (QBF
(Vol. No. 44, pp. 113 - 245)
part 4 of article 159 of the Criminal Code of the Russian Federation against Vorobyeva - Desyatovskaya N.V.:
- another document - a statement by Vorobyeva - Desyatovskaya N.V., in which she asks to bring to criminal
responsibility persons from among the employees, managers of the financial group "QBF" (LLC "Investment Company
QBF"), who stole her money under the guise of carrying out brokerage activities;
(Vol. No. 45, pp. 22, 26)
- Testimony of Vorobyeva - Desyatovskaya N.N., given to her as a witness and victim,

according to which, in February 2019, her father Vorobyeva - Desyatovsky Nikolay Vladimirovich Vorobyeva -
Desyatovsky, born 29.03.1954, was contacted by the employee of "QBF" Moroz Alexander (tel. 8 903 095 24 26) with a
proposal to invest money in the products of the company "QBF". My father was promised a high rate of return by
investing his available funds, both in roubles and in foreign currency, in QBF to carry out financial transactions on the
international market. He was warned that roubles would be converted into currency as the company operated on
foreign markets. The father was interested in the proposal. Having studied information about QBF in open sources, he
found it attractive enough to try to work with it. The presence of 4 licences of the Central Bank of the Russian
Federation was one of the most important moments that determined the reliability of the company. She would like to
note that at that time her father was practically incapacitated due to brain oncology, moreover, afer a week he
underwent surgery. At that time, namely on 19.02.2019 employees of the company "QBF" specially came to his work
in the company "Polymetal International", from where they took him away, took him to the office of PJSC "Sberbank",
located at the address: St. Petersburg, Krasny Tekstilshchik St., 2, where her father withdrew funds in the amount of 4
500 000 (four million five hundred thousand) rubles. Afer that he was taken to the office of the company "QBF",
located at the address: Degtyarny per. 11 lit. B, pom.1 - H, BC "Nevskaya Ratusha", where the father under the pretext
of investing funds in securities with high yield on behalf of non - resident "QCCI LTD" ("QCCI LTD") concluded the
Agreement on rendering services of direct access to international stock markets No. 4779 - 19/ISR dated 19.02.2019, as
well as on behalf of "QBF Advisor" LLC the Assignment Agreement No. 4779 dated 19.02.2019. At the same time, the
father handed over cash amounting to 4,500,000 (four million five hundred thousand) roubles at the office of QBF. On
14.03.2019, she and her father went to the office of the "QBF" company to sign a power of attorney to manage all of
her father's assets in her name (Direct Access to International Stock Markets Service Agreement No. 4779 - 19/ISR
dated 19.02.2019). As Moroz A. explained to her at the time, this agreement authorised her to fully manage all of her
father's assets even without inheriting them in the event of his death. Starting from March 2019, her personal email
([email protected]) began to receive reports on transactions on the purchase of securities in her account. The
credibility of these reports she cannot confirm or deny. From 17.04.2019 Moroz A. began to schedule periodic
meetings in the office of the company to discuss strategies and possible additional investment of funds. He came to
the office on 10.10.2019, 29.03.2020, 09.12.2020. Since March 2021, Dmitry Vladimirovich Moskalyuk, Client
942
Relationship Director (tel. 8 921 858 16 13, 8 965 028 88 88), started communicating with her and started offering to
invest in ZPIFs. On 30.01.2021 her notary Goltsov I.M. sent a request for information to LLC "Investment Company
QBF" for registration of a certificate of inheritance. She would like to note that Moroz A. himself gave her the details for
sending the request. On 18.02.2021 she received a reply from the General Director S.A. Matyukhin that no contracts or
agreements had been concluded between QBIF and her father. No money or other property had been transferred to
QBF by her father. When she asked Moroz A. Moroz himself for an explanation of this answer, she was contacted by
Moskaluk D.V. and explained that the contract had been signed with the now defunct company QBF Advisery.
According to him, the company has ceased to exist since 2019. D.V. Moskalyuk could not give any answer as to why this
happened and why no one had informed her. Also Moskalyuk D.V. said that the company's assets were transferred
from Cyprus offshore to offshore in the Cayman Islands. On 17.05.2021 she issued a certificate of inheritance of
property located outside the Russian Federation (78AV0303774), of which she notified QBF. In June 2021, she was
contacted by D.V. Moskalyuk and asked to send colour scans of the entire package of documents confirming her
relationship with the company and a colour scan of her birth certificate. On 17.06.2021 she sent the above documents
to D.V. Moskaluk by post. Since that moment the communication with him has been interrupted. Taking into account
the fact that the deadline for refunding her money has expired, there is no doubt that she became a victim of
fraudsters. Up to the present time her money deposited to the address of the group of companies "QBF" in the
amount of 4 500 000 roubles has not been returned to her. She believes that the persons acting on behalf of the group
of companies "QBF" initially did not intend to fulfil their obligations to her and acted solely for the purpose of stealing
her money by deceiving her. On 19.02.2019, the persons acting on behalf of the "QBF" group of companies stole the
money belonging to her father at that time, and currently to her, in the total amount of 4 500 000 rubles. She
considers the amount of damage caused to her as significant. The right to file a civil action in the criminal case has
been explained to her. She wishes to exercise that right and file a lawsuit. She has been explained the right to
familiarise herself with the composition of the investigative teams, with the decisions on the appointment of forensic
examinations, with the conclusions of experts, with the records of expert interrogations, and also to familiarise herself
with the materials of the criminal case in full or in part. She does not wish to exercise this right. She has not applied to
the court with applications for the recovery of funds from the "QBF" group of companies;
(Vol. No. 45, pp. 27 - 30, 89 - 92,)
- other documents - documents provided by Vorobyeva - Desyatovskaya N.V. confirming her relationship with QBF
Financial Group (QBF Investment Company LLC) and testifying to the embezzlement of funds;
(Vol. No. 45, pp. 34 - 84)
part 4 of article 159 of the Criminal Code of the Russian Federation against Galachyan K.G.:
- another document - a statement by Galachyan K.G., in which he asks to bring to criminal responsibility persons from
among the employees, managers of the financial group "QBF" (QBF Investment Company LLC), who stole his money
under the guise of carrying out brokerage activities;
(Vol. No. 45, l.d. 104)
- K.G. Galachyan’s testimony as a witness and victim,

according to which, in autumn 2018, he received an advertising call on his mobile phone number from the
representative of the group of companies "QBF" Tallerov Artem (8 - 967 - 047 - 32 - 81) with an offer of cooperation. In
particular, he offered investments in securities of stock markets of foreign countries. At first he did not give an
unambiguous answer, but started to make enquiries in the Internet about the group of companies "QBF". Having
studied information from various Internet resources, he decided to go to a meeting to confirm his interests. He
contacted the manager Tallerov Artem and they agreed on a meeting. He met with Tallerov Artem several times in a
943
restaurant located at the address: 6 Bolshaya Sadovaya Street, page 2, Moscow. Tallerov very colourfully and
convincingly told him about the investment products available in the organisation "QBF", the ways of investing, the
mechanisms of profit formation, the order of reporting and informing the client, as well as in general about the
structure of the organisation. He was informed that the funds would be invested in investment platforms of foreign
countries. He was promised high profitability. As a result of the mentioned meetings, relying on persuasions and
stories of Artem Tallerov, as well as on the information received in the Internet, he informed that he was ready to
invest in the group of companies "QBF". They agreed to meet at the main office of the company "QBF". On 28.12.2018
he arrived at the office of the company "QBF", located at the address: Moscow, Presnenskaya Naberezhnaya, 8, page 1,
9th floor, where he was met by Tallerov Artem and escorted to the meeting room. He (Tallerov) had documents
already signed by the representatives of the relevant companies. On 28.12.2018 he, being in the office of LLC "IC QBF",
located at the address: Moscow, Presnenskaya naberezhnaya, 8, pg. 1, in order to invest cash in securities with high
yield, he signed a trust management agreement No. 4734 - 18/IMR dated 28.12.2018 with White Lake Management Ltd
("White Lake Management Ltd") and also signed an assignment agreement No. 4734 dated 28.12.2018 with QBIF
Advisery LLC. Within the framework of the concluded agreements, on 25.02.2019, he transferred funds from his
settlement account No. 40817840833004011279 opened in the Nikitsky additional office of PJSC VTB Bank located at
33 Bolshaya Nikitskaya St., p. 33, str. 1, to the "White Lake Management Ltd" settlement account No. 100 - 298633 - 1
opened with "Global Fidelity Bank" ("Global Fidelity Bank", Cayman Islands) in the amount of USD 20,000, which at
the exchange rate of the Central Bank of Russia as of 25.02.2019 amounts to RUB 1,310,200. Afer he invested funds in
the "QBF" group of companies, he started receiving reports to his e - mail address [email protected]. The
said reports reflected the state of his investment portfolio. Periodically he received calls from Tallerov Artem, who
offered him to invest additional funds, as well as to think about purchasing additional financial products of the group
of companies "QBF". In February 2021, he changed his financial advisor to Vyacheslav Morozov (8 - 964 - 530 - 31 - 00).
In February 2021, for personal reasons, he needed to make a full withdrawal of his funds and therefore contacted his
financial advisor, Vyacheslav Morozov, and notified him that he was going to make a withdrawal. Morozov V. replied
that he needed to notify the company in writing and also needed to collect a large list of documents for withdrawal of
funds, which included very strange items, such as translation of passport into English, certificate of no criminal
record, etc. In connection with the above, on 08.02.2021 he sent a notice of withdrawal, afer which Morozov
Vyacheslav informed him that the withdrawal would take several weeks. On 10.03.2021 he received a report on the
trading account operation, afer which he was contacted by Morozov Vyacheslav and informed that in order to
withdraw the funds he had to fill in a questionnaire ("KYC"). Afer he filled in the said questionnaire, he was again
contacted by Morozov Vyacheslav and informed him that the withdrawal mechanism had been agreed with the
management of the company, and also explained to him that in order to carry out the withdrawal operation it was
necessary to sign an assignment agreement. To this end, on 25.05.2021, Morozov Vyacheslav came to his office
located at 2 Letnikovskaya St., page 4, Moscow and provided him with the above - mentioned assignment agreement
dated 25.05.2021 between him and KG LLC, which was signed by him. In early June 2021, he learned from the media,
including official news of the Russian Ministry of Internal Affairs, that criminal proceedings had been initiated and an
investigation was underway. Later, he contacted Vyacheslav Morozov on this fact, to which the latter explained to him
that he would be paid the money within the framework of the assignment agreement signed by him on 25.05.2021,
afer which Vyacheslav Morozov stopped contacting him. To date, his funds have not been returned to him, including
under the withdrawal order sent by him. Proceeding from this, as well as from the delaying by managers and other
representatives of the company "QBF" of the terms of withdrawal of funds under various pretexts, he believes that
fraud has been committed against him, his money has been stolen fraudulently. In total, he transferred 20,000 US
dollars to the address of the group of companies "QBF", which at the exchange rate of the Central Bank of Russia as of
25.02.2019 is 1,310,200 rubles. There were no refunds to his address. Adds that initially, when writing the statement,
he mistakenly indicated the amount of material damage caused to me, as he incorrectly made the calculation at that
time. The claim will be filed for the amount of the damage caused to him. The amount of damage caused is 1,310,200
roubles. I assess the material damage caused to him as significant;
(Vol. No. 45, pp. 107 - 110, 118 - 121)
944
- other documents - documents provided by Galachyan K.G. confirming her relationship with QBF Financial Group
(Vol. No. 45, pp. 122 - 190)
part 4 of article 159 of the Criminal Code of the Russian Federation against Chekmareva E.F.:
- another document - a statement by Chekmareva E.F., in which she asks to bring to criminal responsibility persons
(vol. No. 46, l.d. 6)
- E.F. Chekmareva's testimony as a witness and victim,

according to which, at the end of February 2019, on the recommendation of an acquaintance, she went to the office of
QBF Group of Companies at 8 Presnenskaya Naberezhnaya St., p. 1, Moscow, where she met her financial advisor
Nikita Novazhilov (tel. 8 - 911 - 727 - 37 - 84 and Ruslan Spinka (tel. 8 - 967 - 186 - 60 - 39). 1, where she met her
financial advisor Nikita Novazhilov (tel. 8 - 911 - 727 - 37 - 84) and Ruslan Spinka (tel. 8 - 967 - 186 - 60 - 39), who
offered to invest in various stock exchange products, they were very persuasive and persistent, they offered her to
deposit funds as investments, they guaranteed income from these investments. 28.02.2019, being in the office of LLC
"IC QBF", located at the address: Moscow, Presnenskaya naberezhnaya, 8, pg. 1, in order to invest funds in securities
with high yield, she signed trust management agreements No. 4796 - 19/ISR dated 28.02.2019 with White Lake
Management Ltd ("White Lake Management Ltd"), and also concluded a service agreement (standard form of
adhesion agreement) dated 28.02.2019 with VL Consulting LLC. On 15.03.2019, she transferred funds in the amount of
USD 57,207.68, which at the exchange rate of the Central Bank of Russia as of 15.03.2019 amounts to 3,741,382.27
rubles, from her current account No. 40817840706600001246, opened in the office of JSC "Credit Europe Bank",
located at the address: 2 Kievsky Vokzal Square, Moscow, to account No. 30114840600010008156, opened in
"CITIBANK N.A.". (CITIBANK N.A. (USA) for further crediting to an account in the name of White Lake Management Ltd.)
At the conclusion of the contract, the representatives of the group of the company "QBF" were the employees of
"QBF", namely Ruslan Spinka, Korshunov D.A., Korshunov D.A., WL. - a signatory from the side of WL Managment, who
was not present at the meeting. Afer signing the documents to her, the manager Ruslan Spinka took them
somewhere and then brought them back, already signed by Korshunov D.A. She never saw Korshunov D.A.. In the
future the funds were in her investment account, she had no need to withdraw or withdraw the funds. On 19.08.2019
her financial advisor Nikita Novozhilov informed her that he was leaving the company "QBF", and also recommended
her to start withdrawing the invested funds from this company, due to the existing concerns that the group of
companies "QBF" may not behave correctly towards the investors. In this connection, she sent an order to withdraw
funds from her account in the group of companies "QBF", to which the representatives of the company "QBF"
demanded a list of documents, which she collected and submitted to the company "QBF", afer which she was
informed that the accompanying manager was Artem Efremtsov (tel. 8 - 921 - 858 - 16 - 23), however, when it came to
withdrawal of funds, he resigned. She was told by the QBF group of companies that they would assign her a new
manager. Thus, in her attempts to withdraw funds from her account, she constantly changed managers, namely:
Evgeniya Frolova, Ruslan Sokolov, Maxim Danelenko, who also could not help with the withdrawal of funds, and on
the contrary, there was a feeling that the representatives of the group of companies "QBF" deliberately delay the
withdrawal of funds by all means. So far she has not been able to withdraw the funds invested in the group of
companies "QBF", even partially. In May 2021 she heard from the mass media (official website of the Ministry of
Internal Affairs of the Russian Federation) about a criminal case initiated against the founders of the company "QBF".
To date, no funds have been returned to her. In total, 57,207.68 US dollars were transferred to her to the address of the
"QBF" group of companies, which at the exchange rate of the Central Bank of Russia as of 15.03.2019 amounts to
3,741,382.27 rubles. She estimates the amount of damage caused as significant, namely 3,741,502.41 rubles;
945
(Vol. No. 46, pp. 9 - 13, 81 - 84)
- other documents - documents provided by E.F. Chekmareva confirming her relationship with QBF Financial Group
(Vol. No. 46, pp. 16 - 72)
part 4 of article 159 of the Criminal Code of the Russian Federation against Birnov M.A.:
- another document - a statement by Birnov M.A. in which he asks to bring to criminal responsibility persons from
(Vol. No. 46, l.d. 97)
- Testimony of M.A. Birnov, given by him as a witness and victim,

according to which, in February 2018, he received a recommendation from his former personal manager of Sberbank
PJSC Loginova Maria (8 - 968 - 639 - 33 - 57), who transferred to work in QBF Advisor LLC (INN 7703426941) to apply to
the office of this organisation located at: Moscow, Presnenskaya Naberezhnaya St., 8, p. 1. 1. Maria explained
that QBF is an investment company which has a long and successful experience of work in Russia and abroad, all
necessary licences are available, she also informed him that the reliability of work with QBF group of companies is
guaranteed by the legislation of the Russian Federation, due to the fact that he will cooperate directly with the
Russian organisation, namely: "IC QBF" LLC. Moreover, in open sources of the Internet he saw information that LLC "IK
"QBF" has 4 licences of the Central Bank of Russia, namely: licence for brokerage activities №045 - 12805 - 100000
from 24.12.2009, licence for dealer activity #045 - 12816010000 dated 24.12.2009, licence for securities management
#045 - 12828 - 001000 dated 24.12.2009 and licence for depository activity #045 - 14078 - 000100 dated 08.08.2019.
During the conversation Loginova Maria offered to invest in various exchange products, was very convincing and
persistent. Taking into account these arguments, he decided to invest the money belonging to him in the group of
companies "QBF". On 29.03.2018, he came to the office of LLC IC QBF, located at the address: Moscow, Presnenskaya
Naberezhnaya, 8, p. 1, with the purpose of investing his funds in QBF Group of Companies. 1, with the purpose of
investing funds in international stock markets, he concluded an agreement on provision of direct access services to
international stock markets No. 4317 - 18/IMR dated 29.03.2018 with QCCI LTD and an assignment agreement No. 4317
dated 29.03.2018 with QBCI Advisery LLC. Within the framework of the said agreements, he, being in the office of LLC
QB&E EQE, located at the address: Moscow, Presnenskaya Naberezhnaya, 8, pp. 1, handed over cash to the
representatives of QBF Group, namely: 29.03.2018 in the amount of RUB 1,500,000; 09.04.2018 in the amount of RUB
1,000,000; 11.12.2018 in the amount of RUB 1,500,000; 17.12.2018 in the amount of RUB 500,000; 05.06.2019 in the
amount of RUB 1,000,000 and USD 5,000, which at the exchange rate of the Central Bank of the Russian Federation is
RUB 325,800. On 02.03.2020 at about 19:00, he arrived at the office of QBF Group, located at the following address:
Moscow, 8 Presnenskaya Naberezhnaya St., p. 1, where he met Rusla Rusla. 1, where he met Ruslan Spinka and Egor
Laipanov. During the meeting, they explained to him that he needed to sign two new agreements (a service
agreement with VL Consulting and a trust management agreement with White Lake Management Ltd.) due to the fact
that the agent with whom QBF Group was co - operating had changed. He agreed and signed a service agreement
with "VL Consulting" represented by N.S. Padalko dated 02.03.2020, a notice of authorisation, consent to the
processing of personal data, an application for joining the service agreement No. 211058 - 01 dated 02.03.2020, as well
as a "Trust Management" agreement No. D - 211058 - C dated 02.03.2020 with "White Lake Management Ltd."
represented by D.A. Korshunov and five annexes thereto. Around June 2020, someone from the QBF Group of
Companies (who exactly, he cannot explain at the moment) invited him to the office of the QBF Group of Companies
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located at 8 Presnenskaya Naberezhnaya St., p. 1, Moscow. 1. Once there, he was introduced to my new financial
advisor, Meshkova Daria (8 - 903 - 100 - 53 - 17). Throughout his interactions with the financial advisors, they explained
to him that the money he had invested was in safe hands, and repeatedly offered him various products for
investment. Reports were sent to him on a monthly basis to his email address: [email protected]. On
31.03.2021, in order to withdraw his invested money, he sent a notice for realisation of assets. However, there was no
result, no receipt of funds to him. Daria herself also stopped contacting him. Around May - June 2021, he was
contacted by Abdukadyrov Abbas (8 - 903 - 100 - 64 - 11), who explained that at the moment no funds were
temporarily allocated for withdrawal. A little later, he learnt from the mass media, as well as official publications of
the Ministry of Internal Affairs of Russia, that criminal proceedings had been initiated and key employees of the "QBF"
group of companies had been arrested for fraud. At present, his demand for the return of his money has not been
fulfilled. In total, he transferred to the address of the group of companies "QBF" money in the amount of 5,825,800
rubles. To date, the money has not been returned to him either in full or in part. He considers the amount of damage
caused in the amount of 5,825,800 roubles to be significant;
(Vol. No. 46, pp. 100 - 105, 114 - 117)
- other documents - documents provided by M.A. Birnov confirming his relationship with QBF Financial Group ( QBF
(Vol. No. 46, pp. 118 - 229)
part 4 of article 159 of the Criminal Code of the Russian Federation against Potapov A.V.:
- another document - a statement by Potapov A.V., in which he asks to bring to criminal responsibility persons from
(Vol. No. 47, pp. 6, 10)
- The testimony of Potapov A.V., given by him as a witness and victim,

according to which, approximately in the middle of 2019, he received a call from his long - time acquaintance Vadim
Sergeyevich Romanovich, who previously worked in PJSC "Alfa - Bank", and told him about the possibility of earning
money by depositing funds in the company LLC IK QBF, which is part of the group of companies "QBF". During the
conversation Romanovich V.S. convinced him of the reliability of the QBF group of companies, motivating him, among
other things, by the fact that QBF had a licence from the Central Bank of the Russian Federation, so depositors' funds
were reliably protected. He had known Romanovich V.S. for a long time, he was a service manager in the credit
institution where he kept his savings - PJSC "Alfa - Bank", so he trusted him. Afer working at Alfa - Bank PJSC, V.S.
Romanovich got a job at QBF and was a manager there. He trusted Romanovich V.S. and decided to deposit his money
in "QBF", for which purpose on 25.07.2019 he visited the office of LLC IC "QBF" at the address: 11 Degtyarny per. 11, lit.
B (BC "Nevskaya Ratusha"), St. Petersburg. In the office he was met by Romanovich V.S., under whose guidance on the
same day he concluded Trust Management Agreement No. D - 442209 - G dated 25.07.2019 with White Lake
Management Ltd and Service Agreement No. 442209 dated 25.07.2019 with VL Consulting LLC. Aferwards, being in
the same office (address: St. Petersburg, Degtyarny per., 11 lit. B) he deposited cash belonging to her in the amount of
USD 15,700, which at the exchange rate of the Central Bank of Russia as of 26.07.2019 is 991,568.04 rubles, and EUR
12,900, which at the exchange rate of the Central Bank of Russia as of 26.07.2019 is 906,792.6 rubles, in the cash desk
of the "QBF" group of companies, and she was given a receipt to the cash receipt order. The funds were accepted by
the cashier, whose details he does not know. All the documents and receipts for accepting the money had been
provided to him earlier, no other documents had been saved. Afer he invested in the QBF Group of Companies, he
received reports to his e - mail address [email protected], which were received until June - July 2021. Said
947
reports reflected the status of its investment portfolio with continued investment results. Around December 2019, he
tried to call Romanovich V.S., however, he did not answer him, his phone was switched off. Subsequently, a girl called
Baghdasaryan Mari called him back, introduced herself as the manager of QBF Group of Companies and told him that
V.S. Romanovich was no longer working. In June 2021, he learned from a former employee of the "QBF" group of
companies, Sergey Kuznetsov, that the organisation would most likely no longer work and advised him to contact
lawyers in order to get his money back. He wrote down the contact phone number of Sergey Kuznetsov at the first
interview with V.S. Romanovich, S. Kuznetsov was the deputy head of the branch, as I understood from Romanovich's
words. Due to the fact that the deadline for returning the money has expired, he has no opinion that he was a victim of
fraud. He believes that the above - mentioned reports that came to my e - mail from the "QBF" group of companies
are naive, nobody managed my money and it was stolen. The reports were made to mislead me. He believes that the
persons acting on behalf of the group of companies "QBF" initially did not intend to fulfil their obligations to him and
acted solely for the purpose of stealing his money by deceiving him. Thus, on 26.07.2019 the persons acting on behalf
of the "QBF" group of companies stole his money in the total amount of 1,898,360.64 rubles. He assesses the damage
caused to him as significant. He has been explained the right to file a civil action in the criminal case. He wishes to
exercise this right and file a lawsuit. He has been explained the right to familiarise himself with the composition of the
investigative teams, with the decisions on the appointment of forensic examinations, with the conclusions of experts,
with the records of expert interrogations, and also to familiarise himself with the materials of the criminal case in full
or in part. He does not wish to exercise this right. He did not apply to the court with applications for recovery of
money from the "QBF" companies;
(Vol. No. 47, pp. 11 - 14, 50 - 53,)
- other documents - documents provided by A.V. Potapov confirming his relationship with QBF Financial Group (QBF
(Vol. No. 47, pp. 15 - 42)
part 4 of article 159 of the Criminal Code of the Russian Federation against Bosak L.V.:
- another document - a statement by Bosak L.V., in which she asks to bring to criminal responsibility persons from
(Vol. No. 47, pp. 65, 69)
- Testimony of Bosak L.V., given to her as a witness and victim,

according to which, she first learnt about QBF company from Fedotova Lidia, (+79118326826, +79215639353), former
manager of "City Bank", where she was previously served. This is how they met around 2015 - 2016. In mid - 2018, they
met Fedotova L by chance, as they lived in the same neighbourhood. The conversation gradually turned to discussing
finances and Lydia informed her that she worked for a company called "QBF". She offered her to place funds with
them in the company. During the time she had been working at City Bank, she had grown accustomed to trusting
Lydia and agreed to her proposal, which did not look fraudulent as it did not offer fabulous profits, but offered a
return of 5 - 10% per annum in currency, which was just right. On 28 June 2018, she came to the office of the company
"QBF", located at the address: St. Petersburg, Maloohtinsky pr., 64, lit. B (BC "Plaza SPb"), as agreed with Fedotova
Lidia, where she introduced him to a man and introduced him as the head of the subdivision of the company "QBF"
(whose data she cannot remember), who explained to her the terms of investing money. She had a question why the
investment agreement should be signed with a company registered in Cyprus, to which the head of the company
"QBF" explained to her that it was a normal practice and everything was absolutely legal. He convinced her that the
948
company has a long and successful experience of work in Russia and abroad, and also has all the necessary licences.
Fedotova Lydia and Pakhomov Grigory Gennadyevich, convinced her that the reliability of work with the company is
guaranteed by the legislation of the Russian Federation, due to the fact that she will cooperate directly with the
Russian organisation LLC QBF. Immediately afer the conversation with the head of the office of "QBF" Pakhomov G.G.
and the consent given to her, so on behalf of non - resident "QCCI LTD" ("QCCI LTD") with her was concluded the
Agreement on rendering services of direct access to international stock markets No. 4431 - 18/ISR dated 28.06.2018, as
well as on behalf of "QBF Advisery" LLC the Order Agreement No. 4431 dated 28.06.2018. On the same day -
28.06.2018 in the above - mentioned office of "QBF" company, she handed over the sum (in cash) in the amount of
USD 30,000 (thirty thousand), which at the exchange rate of the Central Bank of Russia as of 28.06.2018 amounted to
RUB 1,894,077 and received a cash receipt order b/n dated 28.06.2018. Lidia Fedotova was appointed as her financial
advisor. On a monthly basis, she started receiving reports containing information about the shares allegedly
purchased with her money. She later realised that no shares had actually been acquired and the reports were
produced to give the appearance of some kind of activity. From time to time they met with Lidia at the company's
office to discuss further strategy. Afer about a year, Lydia referred her as a client to another financial advisor - Mary
Bagdasarian (+79215709698, +79816995578) and the work continued in the same vein - reports, discussions, meetings
in the office once a quarter. 29.07.2019Mary Baghdasarian invited her to the office to re - sign the contract, due to the
change of offshore from Cyprus to Cayman Islands. They explained it as purely technical problems and Cyprus
imposing some restrictions. At the same time, she did not explain to her that she was signing the contract with
another company LLC "VL "Consulting" TIN 7706463476. On 29.07.2019 in the office of the company "QBF", located
already at the new address: St. Petersburg, Degtyarny pereulok, d. 11, lit. B (BC "Nevskaya Ratusha") she signed a new
contract with LLC "VL "Consulting" INN 7706463476, as well as the following annexes to the contract and documents:
Regulations on rendering services of LLC "VL "Consulting" TIN 7706463476 (Annex 1); general terms and conditions of
investment declarations (Annex 2); notification on authorisation (Annex 3); notification on withdrawal of funds (Annex
4); notification on risks (Annex 5); consent to processing of personal data (Annex 6); application on joining (Annex 7),
and she also signed: trust management agreement No. D - 995387 - G with "White Lake Management Ltd" dated
29.07.2019 with annexes: investment objectives (annex 1); investment objectives (annex 2); cash payments (annex 3);
investment objectives (annex 4); similar agreement with annexes in English; investment declaration (additional
agreement No. 1) to the service agreement No. 995387 - 09 dated 29.07.07.2019; investment declaration (additional
agreement no. 2) to service agreement no. 995387 - 09 dated 29.07.2019 investment declaration (additional
agreement no. 3) to service agreement no. 995387 - 09 dated 29.07.2019. Afer signing the above documents, on 31
July 2019, she additionally deposited another USD 10,000 (ten thousand) (in cash), which at the exchange rate of the
Central Bank of the Russian Federation as of 31.07.2019 was RUB 633,791. The funds were intended for the purchase
of shares in SpaceX. She was issued a cash receipt order b/n dated 31.07.2019 for the said cash deposit. In March 2020,
she wrote an application for withdrawal of funds, as she saw a fall in the exchange rate according to the report and
decided to receive the balance. However, they sent her a letter in response to the application saying that the market is
unstable at the moment and they advise her to wait until things calm down. Mary Bagdasarian's manager told her the
same thing and she put the application on hold. About a couple of months later she accidentally read on the Internet
that "QBF" is an unscrupulous company, like a pyramid scheme, then, in the same chat room they refuted it, because
they returned the money, i.e. there was no clear information on this issue. She called Lydia and met with her to ask
her directly. Lydia dissuaded her by telling her that QBF had been in the market for 14 years and there were no
problems with withdrawals or anything else. Mary, a little later, also told her that she was just doing a withdrawal for a
client and everything was fine. This reassured her because she trusted these managers, but in the summer of 2021
Mary invited her to her office and told her that the company was under criminal investigation and the money was lost.
Earlier, when discussing the international market strategy, it always sounded as if my FS was in charge of capital
flows, Mary said let's sell some shares, let's buy some shares, she also said that she was in charge of withdrawals, but
later she changed her position and started saying that she had nothing to do with withdrawals and all questions
should be addressed to VL Consulting Ltd. On 22 October 2021, she sent an application for withdrawal of funds to the
e - mail address regionsupport@wl - innt.com (WL Consulting contact e - mail), but there was no response. Further,
she wrote repeated applications to this address and to the address of this company listed on the foreign website (25
October and 09 November 2021), also without response. From this she can conclude that the company is hiding from
949
its customers and is not going to fulfil its obligations under the contract. Considering all the above, she is lef with no
doubt that she has been a victim of fraudsters. To date, she has not been returned her money deposited to the "QBF"
group of companies in the amount of 2,527,868 roubles. She believes that the persons acting on behalf of the group of
companies "QBF" initially did not intend to fulfil their obligations to her and acted solely for the purpose of stealing
her money by deceiving her. In the period from 28.06.2018 to 31.07.2019, the persons acting on behalf of the "QBF"
group of companies stole money belonging to her in the total amount of 2,527,868 rubles. She considers the amount
of damage caused to her as significant. She has been explained the right to file a civil action in the criminal case. She
wishes to exercise this right and file a lawsuit. She has been explained the right to familiarise herself with the
applications for the recovery of funds from the "QBF" group of companies;
(Vol. No. 47, pp. 70 - 75, 160 - 164,)
- other documents - documents provided by Bosak L.V. confirming her relationship with QBF Financial Group (QBF
(Vol. No. 47, pp. 76 - 150)
part 4 of article 159 of the Criminal Code of the Russian Federation against Paramonov S.V.:
- another document - a statement by Paramonov S.V., in which he asks to bring to criminal responsibility persons
(Vol. No. 48, l.d. 8)
- Testimony of Paramonov S.V., given by him as a witness and victim,

according to which, approximately in 2015 - 2016, being a client of Raiffeisen Bank, he got acquainted with a manager
named Meshkova Daria. She counselled him on the bank's investment products. Some time later, Meshkova D.
resigned from Raiffeisen Bank and was employed by QBF Group. Afer these events, Meshkova D. contacted him and
suggested that he transfer his assets to QBF Group. He did not agree immediately, they met several times in early
2017, in particular in January at his work office at 9 Zemlyanoy Val Street, Moscow. Together with Meshkova D., her
supervisor Spinka Ruslan came to visit. During meetings with him Spinka R. mainly communicated with him, he very
colourfully and convincingly told him about investment products available in the organisation "QBF", ways of
investment, mechanisms of profit formation, the order of reporting and informing the client, as well as in general
about the structure of the organisation. He was informed that the funds will be invested in investment platforms of
foreign countries. Everything was presented in a colourful way, devoid of flaws. Spinka promised him high returns. As
a result of the above meeting, and relying on Spinka's entreaties and stories, R. told Meshkova D. in a telephone
conversation that he was ready to invest in the QBF group of companies. They agreed to meet at the head office of
"QBF". 02.03.2017 he, being in the office of LLC "IK "QBF", located at the address: Moscow, Presnenskaya
naberezhnaya, 8, pg. 1, for the purpose of investing cash in securities with high yield, he signed an agreement with QB
Capital CY LTD ("QB Capital CY LTD") for the provision of services of direct access to international stock markets No.
3065 - 17/IMR dated 02.03.2017. He also signed an agreement for the provision of "Trustee" services under the Direct
Access to International Stock Markets Services Agreement No. 3065 - 17/IMR dated 02.03.2017 with QBF IC Ltd. At the
same time, he had no relevant knowledge of the securities market and no experience in investment activities. He
believed that he had concluded a securities trust management agreement with a professional participant of the
950
securities market with IC QBF LLC. Further, in the office of QBIF, located at the following address: 8 Presnenskaya
Naberezhnaya Embankment, bld. 1, Moscow, he made a transfer of cash to QBIF. 1, made cash transfers as follows:
02.03.2017 in the amount of RUB 1,000,000; 22.06.2017 in the amount of RUB 300,000; 19.12.2017 in the amount of
RUB 500,000; 31.01.2018 in the amount of 3,900 Euros, which at the exchange rate of the Central Bank of the Russian
Federation as of 31.01.2018 was RUB 271,206; 28.06.2018 in the amount of RUB 650,000. Some time later, on
01.08.2019, he, being in the office of IK QBF LLC, located at the address: Moscow, Presnenskaya Naberezhnaya, 8, pp.
1, signed the documents offered to him by the employees: service agreement No. D - 055920 - H dated 01.08.2019 with
WLM Ltd ("WLM LTD") and service agreement (standard form of accession agreement) dated 01.08.2019 with WL
Consulting LLC. Further, he, being in the office of LLC IC QBF, located at the address: Moscow, Presnenskaya
Naberezhnaya, 8, pp. 1, on 01.08.2019, within the framework of the concluded agreement, he made a transfer of cash,
in the amount of 650,000 rubles. At the beginning of September 2019, he had a need to withdraw the cash in full, of
which he notified his financial advisor, at that time Laipanov E., of the need. Afer that, he wrote an official letter and
collected all the requested package of documents for the withdrawal of funds previously provided to him by Laipanov
E. Slowly, through protracted negotiations, he was withdrawn in 7 instalments of RUB 1,521,100 a year later, namely:
25.09.2020 - 385 500 rubles, 10.11.2020 - 384 500 rubles, 23.12.2020 - 225 900 rubles, 02.03.2021 - 148 000 rubles,
30.03.2021 - 151 600 rubles, 22.04.2021 - 115 200 rubles, 21.05.2021 - 110 400 rubles. He did not receive any more
money. Later, at the end of May - beginning of June 2021, he learned from the media, including official news of the
Ministry of Internal Affairs of Russia, that criminal cases had been opened and an investigation was underway. In
addition, he contacted Meshkova D. and she confirmed the above information to him. Taking into account the
specifics of communication with managers, problems in withdrawing money, and the fact that the money was not
returned to him in full, he had no doubts that he had become a victim of fraudsters. Thus, in the period from
02.03.2017 to 01.08.2019, he transferred funds in the amount of 3,371,206 rubles to QBF Group for investment. QBF
employees returned to him the funds in the amount of RUB 1,521,100. The rest of the money has not been returned to
him. I believe that an offence has been committed against him, namely the thef of his money by deceit and breach of
trust in the amount of RUB 3,371,206. I consider the amount of damage caused to him as significant;
(Vol. No. 48, pp. 11 - 16, 25 - 28)
- other documents - documents provided by Paramonov S.V. confirming his relationship with QBF Financial Group
(Vol. No. 48, pp. 29 - 152)
part 4 of article 159 of the Criminal Code of the Russian Federation against Grif S.F.:
- another document - a statement by Grif S.V., in which she asks to bring to criminal responsibility persons from
(Vol. No. 48, pp. 164, 168)
- Testimony of Grif S.V., given to her as a witness and victim,

according to which, she first learnt about the company "QBF" from a man named "Vadim Romanovich",
(+79218581604, +79215593966), a former manager of PJSC "Alfa - Bank", where they met in early 2019. In early August
2019, "Vadim Romanovich" called her on her mobile phone and informed her that he had resigned from the bank and
was currently working in the company "QBF", which is engaged in investment activities, offered her to place funds
with them in the company. During the time she had been working with Alfa - Bank PJSC, she got used to trusting
"Vadim Romanovich" and agreed to his proposal, which did not look fraudulent as it did not offer fabulous profits, but
951
offered an income of 5 - 13% per annum in rubles, which was more than in the bank. On 20 August 2019, she came to
the office of "QBF" company located at 11 Degtyarny per., lit. "B", St. Petersburg, as agreed with "Vadim Romanovich",
where he introduced her to a man and introduced him as Anton Porfiriev (tel. +79214282351), deputy head of the
investment services department of "QBF" company's division, who explained to her the terms and conditions of
investing money. She had a question why it was necessary to sign the investment agreement with a company
registered in Cyprus, to which A. Porfiriev explained to her that it was a normal practice and everything was absolutely
legal. He convinced her that the company had a long and successful experience in Russia and abroad and had all the
necessary licences. Immediately afer that a service contract No. 169322 - 09 dated 20.08.2019 between her and "VL
Consulting" LLC INN 7706463476, for the purchase of securities on the international market, as well as signed the
following annexes to the agreement: regulations on the provision of services by "VL Consulting" LLC INN 7706463476
(Annex 1); general terms and conditions of investment declarations (Annex 2); notification of authorisation (Annex 3);
notification of withdrawal of funds (Annex 4); notification of risks (Annex 5); consent to the processing of personal
data (Annex 6); application for accession (Annex 7). On the same day on 20.08.2019 at the above office, she handed
over the amount (in cash) of 2,000,000 (two million) rubles and by verbal agreement the funds were converted into US
dollars, which amounted to 30,097 (thirty thousand ninety - seven) US dollars, received a cash receipt order dated
20.08.2019. On 27.08.2019 in the same office she deposited another 1,000,000 roubles in cash, received a cash receipt
order the funds were also converted into US dollars amounting to 1,5024 (fifeen thousand twenty - four) US dollars.
Her financial adviser was identified as "Vadim Romanovich". She received monthly reports on the progress of the
securities transactions and met with him periodically at QBF's office to discuss further strategy. Around spring 2020,
"Vadim Romanovich" referred her as a client to another financial advisor, Mary Bagdasarian (+79816995578) and the
work continued in the same vein - reports, discussions, and quarterly meetings in the office. In the spring of 2020 she
tried to withdraw funds, but she was dissuaded by Mary Baghdasaryan. On 22.07.2021 she received a message from
Mary Baghdasaryan in messenger "WhatsApp", which informed her that she was ending her working activity in the
company "QBF" on 30.07.2021, on questions related to the company, she should call 8 - 916 - 783 - 22 - 06. But the said
telephone was not active. From this she can conclude that the company is hiding from its customers and is not going
to fulfil its obligations under the contract. To date, she has not been returned her money deposited to the group of
companies "QBF" (VL Consulting) in the amount of 3 000 000 (three million) rubles. She believes that the persons
acting on behalf of the "QBF" group of companies did not intend to fulfil their obligations to her from the outset and
acted with the sole purpose of stealing her money by deceiving her. The persons acting on behalf of the "QBF" group
of companies stole money belonging to her in the total amount of 3,000,000 roubles. She considers the amount of
damage caused to her as significant. She has been explained the right to file a civil suit in the criminal case, and
wishes to exercise this right and file a suit. She has been given the right to familiarise herself with the composition of
the investigation teams, the decisions to order forensic examinations, the expert reports and the transcripts of expert
interrogations, as well as the materials of the criminal case in full or in part. She does not wish to exercise this right;
(Vol. No. 48, pp. 169 - 172, 239 - 242)
- other documents - documents provided by Grif S.V. confirming her relationship with QBF Financial Group (QBF
(Vol. No. 48, pp. 173 - 232)
part 4 of article 159 of the Criminal Code of the Russian Federation against Andreev R.V.:
- another document - a statement by R.V. Andreev, in which he asks to bring to criminal responsibility persons from
(Vol. No. 49, l.d. 8)
952
- R.V. Andreev's testimony as a witness and victim,
according to which, in 2012, Irshat Izmailov (8 - 903 - 100 - 58 - 95), an employee of QBF Finance LLC, called him on his
mobile phone and offered to come to the office of QBF Group of Companies at 8 Presnenskaya Naberezhnaya St.,
bldg. 1, Moscow, where he met his financial advisor Irshat Izmailov, who offered to invest in various exchange
products. 1, where he met his financial advisor, Irshat Izmaylov, who suggested investing in various exchange -
traded products. Izmailov was very persuasive and persistent. What attracted him at that moment was, as it seemed
to him, the transparent mechanism of earning money by the company "QBF Finance" Ltd. and high (30%) percentage
of the client's profit. On 03.08.2012 he arrived at about 18:00 at the office of the group of companies "QBF" at the
address: Moscow, Presnenskaya Naberezhnaya St., 8, p. 1, where Irshat Izmay arrived at the office of the group of
companies "QBF". 1, where Irshat Izmailov voiced a number of proposals to invest money by investing in securities. At
this meeting Irshat was persuasive and persistent, so he agreed to participate in investing in securities on
international financial markets. Later on, Irshat Izmaylov conducted all consultations on financial products with him.
On 03.08.2012 he signed an agreement on direct access to the US securities market with the company "QB Capital CY
LTD" № 648 - 12/VR dated 03.08.2012, and also on this day he signed an agreement with the company "QBF Finance"
LLC on the provision of "Trust Management" services № 648 - 12/VR dated 03.08.2012. The signing of the agreement
and the contract took place at approximately 18:30 on the territory of the office of the "QBF" group of companies at 8
Presnenskaya Naberezhnaya St., p. 1, Moscow. 1. At the conclusion of the agreement the representatives of the group
of companies "QB Capital CY LTD" were the employees of "QBF", namely Irshat Izmailov - personal manager. He
brought him the agreement on direct access to the US securities market with the company "QB Capital CY LTD" № 648
- 12/VR dated 03.08.2012, as well as the agreement with the company "QBF Finance" Ltd. on the provision of "Trust
Management" services № 648 - 12/VR dated 03.08.2012, already signed by the representative of the company "QBF"
and imprinted with a blue seal. On 03.09.2012 at approximately 18:00 he replenished his investment account in the
company "QBF" by bank transfer through the personal cabinet of OJSC "JSCB "Avangard" from his bank account No.
40817840000000022944 to the account of the bank "Piraeus Bank" "Piraeus Bank", Republic of Cyprus
CY1700800170000000000000000000688040) in the amount of USD 10,000, i.e. 324,171 rubles at the exchange rate of
the Central Bank of the Russian Federation as of 03.09.2012 at the price of 32.4171 rubles per 1 USD. These funds were
transferred under the agreement on direct access to the US securities market No. 648 - 12/VR dated 03.08.2012. Afer
making the bank transfer, he sent Irshat Izmailov a transfer order No. 2 dated 03.09.2012 from OJSC AKB Avangard
Bank to confirm the transfer. The specified bank account in JSCB Avangard OJSC was previously opened by him in the
bank branch at the following address: 24 Sadovnicheskaya St., page 6, Moscow. 6. Afer replenishing the investment
account of the company "QBF", in a month he started to receive monthly electronic reports, which showed positive
dynamics. It should be noted that the reports showed the real value of real companies, so they did not arouse any
suspicions. On 14.12.2012, approximately at 18:00, he again replenished his investment account in the company
"QBF", by bank transfer through the personal cabinet of JSC "AKB".Avangard" from his bank account number
40817840000000022944 to the account of the bank "Piraeus Bank" ("Piraeus Bank", Republic of Cyprus CY
17008001700000000000688040) in the amount of 7 000 USD, that is 215 254 rubles at the exchange rate of the Central
Bank of the Russian Federation as of 12.12.2012 at the price of 30.7506 rubles per 1 USD. The funds were also
transferred under the agreement on direct access to the US securities market No. 648 - 12/BP dated 3.08.2012. Afer
making the bank transfer, he sent Irshat Izmailov a transfer order No. 4 dated 14.12.2012 from JSCB Avangard to
confirm the transfer. Approximately in February 2013, he received a call from a QBF employee, Maxim Yudin,
informing him that Irshat Izmailov had lef for another company and now he, Maxim Yudin, had been appointed as his
financial advisor. On 14.08.2013 at approximately 18:00, at the office of the "QBF" group of companies, at the address:
8 Presnenskaya Naberezhnaya St., page 1, Moscow, he deposited 170,000 in cash. 1, he made a cash deposit of RUB
170,000, which was accepted by Maksim Yudin under the Direct Access to the US Securities Market Agreement No. 648
- 12/VR dated 03.08.2012. Maxim Yudin did not give him any supporting documents for the cash deposit afer the
transfer of the funds. Earlier, when questioned as a witness, he stated that on 14.08.2013 he had deposited 300,000
roubles in cash, and he was unknowingly mistaken about the amount of the deposited sum. Later, when reviewing the
reports from QBF in his possession, he found out that he had deposited cash in the amount of RUB 170,000. On
26.02.2016, at approximately 18:00, he arrived at the office of the "QBF" group of companies at 8 Presnenskaya
953
Naberezhnaya St., page 1, Moscow, where he made a cash deposit of RUB 8,000. 1, where he made a cash deposit of
USD 8,000, i.e. RUB 611,143 at the exchange rate of the Central Bank of the Russian Federation as of 26.02.2016 at the
price of RUB 76.3929 per USD 1, which was accepted by Yulia Zaitseva in the presence of Yudin Maxim. The deposit
was made by him under the agreement on direct access to the US securities market No. 648 - 12/VR dated 03.08.2012.
He was given a receipt to the cash receipt order by Zaitseva Yu. In September 2019, Yulia Zaitseva, who was his
financial advisor at the time, informed him about the need to change the Management Company, assuring him that it
was nothing more than a formality caused by better tax preferences in the Cayman Islands than in Cyprus, and also
assured him that major Russian companies also had representatives in the Caymans. He was unaware of the possible
consequences, so he agreed, afer which Yulia Zaitseva sent a package of documents for review, and on 24.09.2019 he
arrived at the office of the "QBF" group of companies, at the address: Moscow, Presnenskaya Naberezhnaya St., 8, p.
1, where he signed the following documents. 1, where he signed the following documents: service agreement No. 648
dated 04.06.2018 with the company "Simtelligence company Limited", i.e. the date specified "retroactively",
cancellation of the agreement on provision of services of direct access to international stock markets No. 648 - 12/BP
dated 03.08.2012 with the company "QB Capital CY LTD", concluded on 29.09.2017, cancellation of the trust
management agreement No. 648 - 12/BP dated 24.09.09.2019, service agreement No. 334275 - 01 dated 24.09.2019
with VL Consulting Ltd, trust management agreement No. D - 334275 - I dated 24.09.2019 with White Lake
Management ltd and English, order dated 25.09.09.2019 for transfer between trading accounts by agreement No. 648 -
12/VR dated 03.08.2012 with QBF Ltd and agreement No. D - 334275 - I dated 24.09.2019 with VL Consulting Ltd
(change of Management Company). In addition, on 02.10.2019 in the office of QBF Group, at the address: Moscow,
Presnenskaya Naberezhnaya St., 8, pg. 1, Yulia Zaitseva persuaded him to sign another contract D - 067774 - J dated
01.10.2019 with White Lake Management Ltd for the Golden Express strategy and a service agreement with WLM Ltd.
Under this agreement, he deposited R650,000 in cash at the office of "QBF" located at the above address. At the same
time, as he later noticed, the cheque issued to him showed a different amount - 500,000 rubles, and the data of the
person who paid - Kolesnikov Nikolay, the contract - "D - 067774 - J dated 01.10.2019", which he signed. In February
2021, he sent a withdrawal notice to QBF IC and contacted Daria Meshkova, his regular financial advisor, to arrange an
office visit. In March 2021 he visited the office of IC "RWR", signed the withdrawal order (in one copy, which remained
with the financial advisor), and Daria afer some time sent a list of additional documents required for the withdrawal.
Afer that, he tried unsuccessfully to contact Daria for almost 2 months, but she did not answer, and the office assured
him that she would call him back soon. In December 2015, the exact date he cannot remember, he managed to
withdraw only part of the funds in the amount of USD 20,000, which at the maximum exchange rate for December
2015 (USD 1 = 72, 8827 rubles) corresponds to 1,457,654 rubles. The rest of the funds invested in the QBF group of
companies have not been returned to him to date. Approximately in July 2021, he heard from the media (official
website of the Ministry of Internal Affairs of the Russian Federation) about a criminal case initiated against the
founders of the company "QBF". He believes that an offence has been committed against him, namely embezzlement
of funds through deceit and abuse of trust. All payments made by him were made at the insistence of the employees
of the company "QBF" and their words in order to increase the volume of investments and, accordingly, to get more
profit. At the same time, the withdrawal of funds was always accompanied by, as he now realises, far - fetched and
unjustified administrative barriers. And partial return of the invested funds, in his opinion, was only creating a
semblance of the company's work and inducing clients to make additional payments. Thus, the employees of "QBF"
group of companies stole his money in the amount of 1,970,568 rubles, and the amount of damage caused to him is
512,914 rubles, which is significant for him;
(Vol. No. 49, pp. 11 - 18, 130 - 135)
- other documents - documents provided by R.V. Andreev confirming his relationship with QBF Financial Group (QBF
(Vol. No. 49, pp. 23 - 117, 136 - 177)
part 4 of article 159 of the Criminal Code of the Russian Federation against Ivanov K.A.:
954
- another document - a statement by K.A. Ivanov, in which he asks to bring to criminal responsibility persons from
(Vol. No. 50, pp. 9, 11)
- Testimony of Ivanov K.A., given by him as a witness and victim,

according to which, approximately in 2016 he had a salary account in the bank "VTB", the manager of this bank
Salimova Zarina worked with him on the salary project, her tel.: 8 - 921 - 570 - 99 - 08, 8 - 953 - 148 - 18 - 59. During the
time he worked with Salimova Zarina, he developed a trusting relationship with her. Around November 2017,
Salimova 3arina called him and informed him that she had resigned from the bank and was now working in the QBF
group of companies. Salimova 3arina told him about the possibility of earning additional income by depositing
money into the trust management of the "QBF" group of companies, namely "QCCI LTD". During the conversation
Salimova 3arina convinced him in the reliability of the group of companies "QBF", motivated, among other things, by
the fact that "QBF" has a licence of the Central Bank of the Russian Federation, so the depositors' funds are reliably
protected. He met with Salimova 3arina several times, during the meetings she told him about investment products of
"QBF" group of companies and persuaded him to conclude a contract. He believed Salimova 3arina and decided to
deposit his money in "QBF", for which purpose he visited the office of the group of companies "QBF" at the following
address: St. Petersburg, Maloohtinsky Ave, 64, Lit. B. In the office he was met by Salimova 3arina under the direction
of whom on behalf of non - resident "QCCI LTD" ("QCCI LTD") concluded with him the Agreement on rendering
services of direct access to international stock markets No. 4199 - 17/ISR dated 13.11.11.2017 and also on behalf of
QCBF Ltd. entered into a Trust Deed in accordance with the Direct Access to International Stock Markets Services
Agreement No. 4199 - 17/ISR dated 13.11.2017. On 23.01.2018 in the office of the company located at the above
address, under the direction of Salimova 3arina, he handed over his funds in the amount of 2,500,000 rubles to the
cash desk, at the same time he was given a receipt for acceptance of funds with the seal of "QCCI LTD". The money was
accepted by the cashier, whose details he does not know. 29.01.2019 in the office of the company located at the new
address: St. Petersburg, Degtyarny pereulok, v. 11, lit. 11, lit. B (BC "Nevskaya Ratusha"), under the direction of
Salimova 3arina, he also transferred his funds in the amount of 2 050 000 rubles to the cash desk, and he was given a
receipt for the receipt of funds with the seal "QCCI LTD". The money was accepted by the cashier, whose details he
does not know. 29.08.2019Salimova 3arina invited him to the office of the company in order to renegotiate the
agreements on the money he had previously deposited to the company "QBF". From the words of Salimova 3arina to
continue co - operation with the group of companies "QBF" it was necessary to renegotiate the agreements. Thus,
under the direction of Salimova 3arina with him on behalf of non - resident "White Lake Management Ltd" ("White
Lake Management Ltd") was concluded Trust Management Agreement No. D - 417040 - H dated 29.08.2019, as well as
on behalf of LLC "VL Consulting" Service Agreement (standard form of accession agreement) dated 29.08.2019. On
29.08.2019 in the office of the company "QBF", also under the direction of Salimova 3arina, he transferred to the cash
desk of the company his funds in the amount of 25 000 Euros, which at the exchange rate of the Central Bank of the
Russian Federation on 28.10.2019, was 1 777 985 rubles, and he was given a receipt for the receipt of funds with the
stamp "WLM". The funds were accepted by the cashier, whose data he does not know. Throughout the whole period
he received monthly reports from "QBF" from the e - mail box: [email protected] to his e - mail box
[email protected]. The reports contained information about the status of investment products of "QBF" group of
companies, in which he invested his money. On 03.06.2021 he wrote an application to withdraw all his funds from
"White Lake Management Ltd." and sent it to Salimova 3arina by email. Salimova 3arina told him that in order to
withdraw his money he had to provide her with a large number of documents. On 14.07.2021, Salimova 3arina called
him and arranged a meeting. He met with Salimova 3arina on Maly Prospect of Vasilievsky Island, he does not
remember the exact address, the meeting took place in the street. During the meeting, Salimova 3arina told him that
the QBF group of companies had started having problems, their licence had been revoked, their accounts had been
955
frozen, etc. Salimova 3arina offered him to withdraw the money through a scheme he did not understand, with the
crediting of "ZPIV" units. This scheme he refused on the grounds of distrust. At the end of June 2021, he learned from
the media, including official news from the Russian Ministry of Internal Affairs, that criminal cases had been opened
and investigations were underway against employees and managers of the QBF group of companies. Given the fact
that the deadlines for repayment of his money had expired, there was no doubt that he was a victim of fraudsters. He
believes that the above - mentioned reports sent to his e - mail from "QBF" group of companies are fictitious, his
money was not managed by anyone, and it was stolen. The reports were made to mislead him. He believes that the
acted solely for the purpose of stealing his money by deceiving him. In the period from 23.01.2018 to 28.10.2019, the
persons acting on behalf of the "QBF" group of companies stole money belonging to him in the total amount of RUB
6,327,985. He considers the amount of damage caused to him as significant. He has been explained the right to file a
civil action in the criminal case. He wishes to exercise this right and file a lawsuit. He has been explained the right to
familiarise himself with the composition of the investigative teams, with the decisions on the appointment of forensic
(Vol. No. 50, pp. 12 - 15, 143 - 146,)
- other documents - documents provided by K.A. Ivanov confirming his relationship with QBF Financial Group (QBF
(Vol. No. 50, pp. 17 - 136)
part 4 of article 159 of the Criminal Code of the Russian Federation against Petrov P.E.:
- another document - a statement by Petrov P.E., in which he asks to bring to criminal responsibility persons from
(Vol. No. 50, pp. 158, 162)
- Testimony of Petrov P.E., given by him as a witness and victim,

according to which, in the middle of November 2018, an employee of the company "QBF" Lidia Fedotova (tel. 8 - 911 -
832 - 68 - 26) called his personal phone number with offers to invest available funds, both in foreign currency and in
rubles, in their company LLC "IC QBF", a member of the group of companies "QBF", to make financial investments in
the international market. He was interested in the proposal and they agreed to meet at the company's office, which
was located at 11 Lit. B Degtyarny per. in St. Petersburg, BC Nevskaya Ratusha. There he met Anton Porfiriev (tel. 8 -
921 - 428 - 23 - 51), Deputy Head of the Investment Services Department of QBIF LLC. He was informed that the money
will be invested in investment sites of both Russian and foreign countries. Everything was presented in a colourful
way, devoid of flaws, and he was promised high returns (from 8% to 10% per annum). As a result of this meeting, as
well as relying on Porfiriev A.'s entreaties and stories, he said that he was ready to invest in the group of companies
"QBF". They agreed to meet at the head office of the company in a few weeks. He trusted the mentioned employees
and decided to deposit his money in "QBF", for which purpose on 23.01.2019 he visited the office of LLC "IC "QBF" at
the address: St. Petersburg, Degtyarny per. 11, lit. B (BC "Nevskaya Ratusha"). In the office he was met by A. Porfiriev,
under whose guidance on the same day he entered into Trust Management Agreement No. 4747 - 19/ISR dated
23.01.2019 with White Lake Management Ltd and Assignment Agreement No. 4747 dated 23.01.2019 with QBef
Advisery LLC. Then, approximately one week later on 30.01.2019, he transferred funds in the amount of USD 45,000
956
from his current account No. 40817840508060000842 opened by ALFA - BANK JSC, located at the address: Saint
Petersburg, Polikarpova Alley, to Simtelligence Company Limited current account No. 1570033649480101 opened
with AMERIABANK, which amounted to RUB 2,985,354 at the exchange rate of the Central Bank of Russia on
30.01.2019. Afer he invested funds in "QBF" group of companies, he started receiving reports to the e - mail
address [email protected], which were received until the beginning of 2020. The said reports reflected the
status of his investment portfolio with positive results from the investment. Also about once a month they met with
Porfiriev A., who told him about the growth of my investment portfolio. Afer some time he had an opportunity to
additionally invest the available funds, for which purpose on 15.11.2019 from his current account №
40817840508060000842, opened by JSC "ALFA - BANK", located at the address: St. Petersburg, Polikarpova Alley, 2, he
transferred to the current account "Simtelligence Company Limited" №1570033649480101, opened in "AMERIABANK"
funds in the amount of USD 15 000, which at the exchange rate of the Central Bank of Russia on 15.11.2019 amounted
to 938 316 rubles. On 03.02.2020im was submitted an order to withdraw funds in the amount of 10 000 (ten thousand)
USD from his investment account. In response, he was asked for a large package of documents, which he provided to
the company's employees in full. On 19.03.2020 he registered a withdrawal order No. SPB2003017. The transaction
was supposed to take place within 90 days from the moment the number was assigned. However, the funds were not
received on his account. A. Porfiriev stopped answering his calls. He could not get through to the company's office
either. In May 2021, he read in the media about a criminal case brought against the managers of the company "QBF".
All the documents and receipts for the transfer of funds had been provided to him earlier, and no other documents
had been retained. Due to the fact that the deadline for refunding the money has expired, I have no doubt that he was
a victim of fraudsters. He believes that the above - mentioned reports sent to his e - mail from the "QBF" group of
companies are fictitious, his money was not managed by anyone, and it was stolen. The reports were made to mislead
him. He considers that the persons acting on behalf of the group of companies "QBF" initially did not intend to fulfil
their obligations to him and acted solely with the purpose to steal his money, having deceived him. Thus, in the
period from 30.01.2019 to 15.11.2019 the persons acting on behalf of the "QBF" group of companies stole his money
in the total amount of 3 923 670 rubles. He assesses the damage caused to him as significant. He has been explained
the right to file a civil action in the criminal case. He wishes to exercise this right and file a lawsuit. He has been
explained the right to familiarise himself with the composition of the investigative teams, with the decisions on the
appointment of forensic examinations, with the conclusions of experts, with the records of expert interrogations, and
also to familiarise himself with the materials of the criminal case in full or in part. He does not wish to exercise this
right. He did not apply to the court with applications for recovery of money from the "QBF" group of companies;
(Vol. No. 50, pp. 163 - 165, Vol. No. 51, pp. 26 - 29)
- other documents - documents provided by Petrov P.E. confirming his relationship with QBF Financial Group (QBF
(vol. No. 50, pp. 181 - 240, vol. No. 51, pp. 1 - 16, 18 )
part 4 of article 159 of the Criminal Code of the Russian Federation against Baskova T.V.:
- another document - a statement by T.V. Baskova, in which she asks to bring to criminal responsibility persons from
among the employees and managers of the financial group "QBF" (LLC "Investment Company QBF"), who stole her
(Vol. No. 51, l.d. 43)
957
- Testimony of T.V. Baskova, given to her as a witness and victim,
according to which, 27.07.2017 she was sold a flat belonging to her by right of ownership at the address: Moscow
region, Reutov, Novosovikhinskoye shosse, 27, sq. 756, in connection with which she had free cash in a large amount.
Just at that time she started receiving calls to her mobile phone number from representatives of the group of
companies "QBF", in particular a manager named Sukharev Leonid with a proposal for cooperation, in particular
investments in securities of stock markets of foreign countries. At first she did not give an unambiguous answer, but
began to make enquiries on the Internet about the group of companies "QBF". Having studied information from
various Internet resources, she called Leonid Sukharev back and made an appointment at the main office of the
company. On 01.08.2017 at approximately 19:00 she arrived at the office of the "QBF" group of companies located at
the address: Moscow, Presnenskaya Naberezhnaya, 8, p.1, 9th floor. During the meeting in the office she was
contacted by the manager Sukharev Leonid together with his manager named Padalko Nikolay. During the meeting,
the latter presented to her the investment products available in the organisation, the ways of investment, the
mechanism of profit formation, the procedure of reporting and informing the client, as well as the structure of the
organisation in general. She was informed that the funds will be invested in investment sites of foreign countries.
Everything was presented in a colourful way, devoid of flaws, she was promised a return of 15 to 20% per annum. She
was also provided with original licences from the Central Bank of the Russian Federation. At the end of the meeting,
she finally got the impression that these people could be trusted with her assets. I decided to sign the necessary
contracts and put my available funds into investments. Padalko and Sukharev already had the contracts with my data
and signed by the representatives of the organisations: Agreement on provision of services of direct access to
international stock markets No. 3332 - 17/IMR dated 01.08.2017 with QB Capital Cy LTD represented by Yudin Maxim
Stanislavovich (already signed by Yudin M.S.), as well as Agreement on provision of "Trust Management" services with
QBIF LLC (INN 7733673955) represented by Yudin M.S., Director of Sales and Customer Service Department (signed by
Yudin M.S.). On 01.08.2017 she signed the said documents and they agreed that on 14.08.2017 she would come with
cash for deposit. So, on 14.08.2017 at about 19:00 she arrived at the same office at the address: Moscow,
Presnenskaya Naberezhnaya, 8, p.1, 9th floor, she was met by Sukharev Leonid and escorted to the meeting room,
where Padalko Nikolay was waiting for them. She handed them cash in the amount of 4,220,000 roubles, in return
they gave me three receipts for a cash receipt for the sums of: RUB 2,400,000, RUB 1,800,000 and RUB 20,000.
Everywhere in the receipts was the signature of the chief accountant Gorobets E.V. and the stamp of QB Capital CY
LTD, these receipts were dated 14.08.2017, under the contract No. 3332 - 17/ IMR dated 01.08.2017. Why money was
accepted from her with such split amounts, she does not know. Afer she invested money in "QBF" group of
companies, she started receiving reports to her e - mail address: [email protected], which were received by her till
30.04.2021. These reports reflect the state of her investment portfolio. Periodically she received calls from the
manager Sukharev Leonid, who offered her to invest additional funds, and also to think over acquisition of additional
financial products of group of companies "QBF". However, Sukharev Leonid soon resigned and moved to work
elsewhere, Padalko Nikolay began to contact her directly, but afer some time Meshkova Daria became her financial
advisor. On 20.01.2018, she applied for the first time for a withdrawal of USD 3,000. The withdrawal process turned
out to be very difficult and rather long, nevertheless, on 04.06.2018 she was invited to the office to withdraw the
funds. At the meeting in the office on 04.06.2018 at the address: Moscow, Presnenskaya Naberezhnaya, 8, bldg. 1, 9th
floor, she was met by Padalko Nikolay and handed over to her USD 3,000, which at the Central Bank (CB) exchange
rate as of 04.06.2018 amounts to RUB 189,407.7. At the same time, she was urged to sign new documents allegedly on
the transfer of her invested funds to another company "Simtelligence company LTD". She was told that the signing of
the said document was conditioned by the new investment strategy of "QBF" group of companies. On 04.06.2018, she
signed Service Agreement No. 3332 dated 04.06.2018 with "Simtelligence company LTD". On 15.01.2019, she
submitted a new application for withdrawal of already USD 6,000. It also took several months to withdraw the funds,
and on 29.05.2019 she was invited by Padalko Nikolay also to the office of the company at the address: Moscow,
Presnenskaya Naberezhnaya, 8, p.1, 9th floor. During the meeting on 29.05.2019, Padalko Nikolay gave her USD 6,000,
which at the Central Bank exchange rate as of 29.05.2019 is 387,236.4 rubles. At the same time, she was also obliged to
sign new documents, this time the "Trust Management" agreement No. D - 939415 - E dated 29.05.2019 between me
and the company White Lake Management ltd represented by Korshunov D.A. (already signed by Korshunov D.A.) and
958
the Service Agreement (standard form of adhesion agreement) dated 29.05.2019, between me and the company VL
Consulting LLC (INN 7706463476). The explanations were still of the same nature. A couple of months later, in August
2019 she again decided to withdraw the funds, but this time in full. Padalko Nikolay talked her out of it. This was the
case several times. Moreover, Padalko Nikolai persuaded her to invest more in "QBF" and she signed on 28.11.2019
Service Agreement No. 682385 - K between me and WLM ltd, under this agreement she deposited USD 5,400, in cash,
which at the Central Bank exchange rate as of 28.11.2019 is 345,438 rubles. However, on 23.03.2021, she filed a notice
with QBF Group of Companies to withdraw the entire amount. Her current financial advisor Meshkova D. informed her
with a list of documents for withdrawal of funds. She collected all the documents and handed them over to Meshkova
D., the latter in turn notified her on 21.04.2021 that the documents had been submitted for processing. At the end of
May 2021, Meshkova Daria called her on her mobile phone and informed her that a criminal case had been opened,
investigative actions had been carried out, and that the group of companies "QBF" was a pyramid scheme. She made
enquiries on the Internet and the above information was confirmed, as well as her inner fears. On 10.06.2021 she
applied to the Department of Internal Affairs of the Department of Internal Affairs for ZAO of the Main Department of
the Ministry of Internal Affairs of Russia for Moscow with a statement about fraudulent actions on the part of
unidentified persons from among the employees and managers of the group of companies "QBF". Later in June 2021,
her financial advisor Padalko Nikolay contacted her with a proposal to close the existing debts of QBF to her. She was
interested in this proposal and they agreed to meet. On 06.07.2021 at 14.00 she arrived at the address: Moscow,
Presnenskaya naberezhnaya 8, st. 1, 9th floor, she was met by Padalko Nikolay and escorted to the meeting room.
Padalko Nikolai suggested that she transfer the debt she owed to him to a unit investment fund. Afer giving her
consent, Padalko Nikolay provided her with the following documents for her signature: Netting agreement with
Lamera Holdings Limited dated 06.11.2021, investment units purchase and sale agreement dated 06.07.2021,
between her and Lamera Holdings Limited, assignment agreement No. 3332 dated 29.10.2020, between her and
Lamera Holdings Limited. Afer signing the above agreements to her, Padalko Nikolay also persistently persuaded her
to sign confirmations of absence of claims against "VL Consulting" LLC dated 06.07.2021, IK QBF LLC dated
06.07.2021, QCCI LTD (formerly QB Capital CY Ltd) dated 06.07.2021. She has signed the above documents. On
29.07.2021 she was again contacted by Padalko Nikolay and informed her that to date the units have not been
transferred. To date, she is not the owner of these shares. I believe that she was induced to sign the documents on the
transfer of the shares in order to prevent her from filing a criminal complaint with law enforcement authorities. In
total, she transferred 4,565,438 roubles to the "QBF" group of companies between 14.08.2017 and 28.11.2019. Until
now, the full amount of the money invested by her in the group of companies "QBF" has not been returned to her.
Claims will be brought for the amount of damage caused to her. Believes that a crime has been committed against
her, namely thef of her money by deceit and abuse of trust. The amount of damage caused to her assesses it as
significant for herself;
(Vol. No. 51, pp. 46 - 49, 50 - 53, 81 - 86)
- other documents - documents provided by T.V. Baskova confirming her relationship with QBF Financial Group (QBF
(Vol. No. 51, pp. 54 - 71, 90 - 226)
part 4 of article 159 of the Criminal Code of the Russian Federation against Mishin I.Y.:
- another document - a statement by Mishin I.Y., in which he asks to bring to criminal responsibility persons from
(Vol. No. 52, pp. 6, 10)
959
- Testimony of Mishin I.Y., given by him as a witness and victim,
according to which, he first learnt about the company "QBF" from his father Mishin Yuri Alekseevich (+79112268209),
who in July 2018 introduced him to the representative of the company "QBF", Porfiriev Anton Olegovich
(+79112262120), the meeting was held in the office of the company at the address: Degtyarny pereulok, v. 11, lit. B (BC
"Nevskaya Ratusha"). 11, lit. B (BC "Nevskaya Ratusha"), Porfiriev A.O. immediately introduced himself as his
future personal financial advisor and colourfully told about financial strategies in investment activities, as well as
about the prospects of cooperation with the company. He told about the company itself and the options of investing
money in order to receive income. He showed beautiful presentations, told that the company has been on the market
for many years, that during this time it has shown itself well in the investment market, that with the help of the
company "QBF" you can officially invest money in securities (shares) traded on the New York Stock Exchange. He was
shown the licences issued by the Federal Service for Financial Markets. A.O. Porfiriev showed different strategies. As
he remembers now, there were aggressive, moderate and conservative strategies to choose from. Everything sounded
very convincing, so he was very interested in the proposal at that time. Having analysed the proposed strategies on
the spot, he chose the "moderate" strategy with an income of 10% to 15% per annum. On the same day, on behalf of
non - resident "QCCI LTD" ("QCCI LTD") concluded with him the Agreement on rendering services of direct access to
international stock markets No. 4496 - 18/ISR dated 14.08.2018, as well as on behalf of "QBF Advisor" LLC the Order
Agreement No. 4496 dated 14.08.2018. Thus, during the period from 16.11.2018 to 31.11.2019, he transferred cash
through his father A.O. Porfiriev, viz: 16.11.2018 in the amount of USD 10,000, which at the exchange rate of the
Central Bank of the Russian Federation as of 16.11.2018 was RUB 666,159; in January 2019 in the amount of USD
5,474, which at the maximum exchange rate of the Central Bank of the Russian Federation as of January 2019 was
RUB 367,809.01; in November 2019 in the amount of USD 8,500, which at the maximum exchange rate of the Central
Bank of the Russian Federation as of November 2019 was RUB 545,785.85. The father transferred all the funds to A.O.
Porfiriev while in the office of the company "QBF", located at the address: St. Petersburg, Degtyarny per. 11, lit. B (BC
"Nevskaya Ratusha"), in cash. He would like to note that no receipts for the second and third refill were given to his
father, as well as to him. According to the words of A.O. Porfiriev, these cash deposits will be reflected in the reports
provided by the company on a monthly basis, which came to his e - mail and that in this regard there is no need for a
physical receipt. Wants to note that from the beginning of 2019, he started receiving electronic reports on alleged
securities transactions to his email address. Around the end of 2019, the reports began to arrive less and less
frequently. At some point Porfiriev A.O. started sending them personally from his corporate email
([email protected]). In the spring of 2020 he received a call from A.O. Porfiriev informing him that it was
necessary to re - sign the assignment agreement due to a change in the company's policy, but the re - signing never
took place, meetings were constantly postponed. Therefore, at the beginning of 2021 he came to the office of "QBF"
and wrote an application for the complete withdrawal of his funds, as well as all accumulated interest, this
application was made by A.O. Porfiriev on his work computer and did not give him any confirmation on paper.
According to the contract, the withdrawal procedure could take about 3 months. In spring 2021, A.O. Porfiriev stopped
answering phone calls, and from the Internet he learnt about the problems in the company "QBF", the investors were
advised to apply to the police. As early as June 2021, he learnt from the media, as well as official publications of the
Russian Ministry of Internal Affairs that criminal proceedings had been initiated and key employees of the QBF group
of companies had been arrested for fraud. Given the fact that the deadline for returning his money had expired, there
was no doubt that he had become a victim of fraud. Up to the present time his money deposited to the address of the
group of companies "QBF" in the amount of 1 575 753,86 roubles has not been returned to him. He believes that the
acted solely for the purpose of stealing his money by deceiving him. In the period from 16.11.2018 to 31.11.2019, the
persons acting on behalf of the "QBF" group of companies stole money belonging to him in the total amount of
1,575,753.86 rubles. He considers the amount of damage caused to him as significant. He has been explained the right
to file a civil suit in the criminal case. He wishes to exercise this right and file a lawsuit. He has been explained the
right to familiarise himself with the composition of the investigative teams, with the decisions on the appointment of
forensic examinations, with the conclusions of experts, with the protocols of interrogations of experts, as well as to
960
familiarise himself with the materials of the criminal case in full or in part. He does not wish to exercise this right. He
has not applied to the court with applications for the recovery of money from the QBF Group;
- (Vol. No. 52, pp. 11 - 14, 79 - 82,)

- other documents - documents provided by Mishin I.Y. confirming his relationships with QBF Financial Group
- (Vol. No. 52, pp. 15 - 66)
part 4 of article 159 of the Criminal Code of the Russian Federation against Nazarenkov A.V.:
- another document - a statement by A.V. Nazarenkov, in which he asks to bring to criminal responsibility
"QBF"), who stole his money under the guise of carrying out brokerage activities;
- (Vol. No. 52, pp. 95, 96, 97)
- Testimony of A.V. Nazarenkov, given by him as a witness and victim,

according to which, in October 2019, his acquaintance Aminov Rafail Ravilyevich introduced him to the manager of
the group of companies "QBF" Gulyaeva Xenia. The meeting took place in the office of the said company at the
address: Degtyarny pereulok, d. 11, lit. B (BC "Nevskaya Ratusha"), Gulyaeva Ksenia immediately introduced herself
as his future personal financial advisor and colourfully told him about financial strategies in investment activities, as
well as the prospects of cooperation with the company. She told him about the company itself and the options for
investing money in order to receive income. She showed beautiful presentations, told him that the company has been
on the market for many years, that during this time it has shown itself well in the investment market, that with the
help of the company "QBF" you can officially invest money in securities traded on the international stock exchange.
He was shown the licences issued by the Federal Financial Markets Service and told about different strategies. As he
remembers now, there were aggressive, moderate and conservative strategies to choose from. For the sake of
persuasiveness Gulyaeva Ksenia also introduced him to her colleague - Deputy Head of Investment Services
Department of "QBF" Group of Companies Anton Porfiriev. The two of them (Gulyaeva K. and Porfiriev A.) persuaded
him to invest in the products of the group of companies "QBF". On 19.12.2019, being in the office of the company
"QBF" at the above address, under the direction of Gulyaeva K. and Porfiriev A. with him on behalf of LLC "VL
Consulting" on 19.12.2019 concluded the Service Agreement standard form of accession agreement dated 17.12.2019,
as well as trust management agreement № D - 779786 - L with a non - resident "White Lake Management Ltd" ("
White Lake Management Ltd") dated 17.12.2019. Further, on the same day, he deposited his cash in the
amount of USD 2,600, which at the exchange rate of the Central Bank of Russia as of 19.12.2019 amounted to RUB
162,716.06 and EUR 47,000, which at the exchange rate of the Central Bank of Russia as of 19.12.2019 amounted to
RUB 3,275,547.50. He does not remember the details of the cashier who accepted the above amount from him. Afer
that, he received periodic calls from Gulyaeva Ksenia and offered to deposit additional funds to the address of the
group of companies "QBF" for additional investment. He refused her offers. He wants to note that from that time on
his e - mail: [email protected] every month began to receive electronic reports containing information about
the shares allegedly purchased with his money. Later he realised that no shares were actually purchased, and the
reports were made to give the appearance of some activity. In May 2021, he learnt from his acquaintances that QBF
Group was under investigation. He called Xenia Gulyaeva, who confirmed the information about the existence of a
criminal case and recommended to contact the investigator. Afer that, in May 2021, he applied to withdraw his funds.
He never received a reply to the application. Afer calling Guliaeva K., he was asked to fill in a new application form for
withdrawal of funds. He did so, having filled in this form and sent it to the e - mail of the group of companies "QBF"
regionsupport@wl - consulting.m. In response, aferwards, he only received a letter that he had USD 48,201.53 on his
balance. Where this money is, what account it is in, and whether it even exists, he does not know. To date, the funds
have not been returned to him. Guliaeva K. is dragging out the time in every possible way and evades answering the
961
question about the return of his money. Taking into account all of the above, he has no doubt that he has become a
victim of fraudsters. To date, he has not been returned his money deposited to the "QBF" group of companies in the
amount of 3,438,263.56 roubles. He believes that the persons acting on behalf of the group of companies "QBF"
initially did not intend to fulfil their obligations to him and acted solely for the purpose of stealing his money by
deceiving him. On 19.12.2019, the persons acting on behalf of the "QBF" group of companies stole money belonging
to him in the total amount of RUB 3,438,263.56. I estimate the amount of damage caused to him as significant. He has
been explained the right to file a civil suit in the criminal case. He wishes to exercise this right and file a lawsuit. He
has been explained the right to familiarise himself with the composition of the investigative teams, with the decisions
on the appointment of forensic examinations, with the conclusions of experts, with the records of interrogations of
experts, and also to familiarise himself with the materials of the criminal case in full or in part. He does not wish to
companies;
(Vol. No. 52, pp. 100 - 103, 163 - 165, 223 - 226)
- other documents - documents provided by A.V. Nazarenkov confirming his relationship with QBF Financial Group
(Vol. No. 52, pp. 106 - 162, 166 - 216)
part 4 of article 159 of the Criminal Code of the Russian Federation against Burmistrov V.N.:
- another document - a statement by V.N. Burmistrov, in which he asks to bring to criminal responsibility persons
(Vol. No. 53, l.d. 9)
- The testimony of Burmistrov V.N., given by him as a witness and victim,

according to which, in 2019, his acquaintance Belsky Evgeny introduced him to the manager of the group of
companies "QBF" Vasilieva Nadezhda Anatolievna, informing him that Vasilieva N.A. previously worked in a bank, and
at that time (his acquaintance) was engaged in investments in the group of companies "QBF". N.A. Vasilieva presented
him with the financial products of the QBF group of companies and assured him that the company had a long and
successful experience in Russia and abroad, with all the necessary licences in place. N.A. Vasilieva informed him that
reliability of work with them is guaranteed by the legislation of the Russian Federation, due to the fact that he will
cooperate directly with a Russian organisation, namely: LLC IC "QBF" INN 7733673955. At the same time, as a method
of investment he was offered to conclude an asset management agreement within a foreign jurisdiction with the
company "White Lake Management Ltd." and operating in the Russian Federation through LLC "VL Consulting". On
23.12.2019 he arrived at the office of QBF Group of Companies at 11 Degtyarny per. 11, Lit. B, 6th floor, St. Petersburg
to sign the agreement. Under the guidance and persuasion of N.A. Vasilieva, he signed a trust management
agreement No. D - 899182 - L with White Lake Management Ltd. Also while in the office, he signed a service agreement
with VL Consulting Ltd. and a service agreement No. 899182 - L with VLM Limited Liability Company. Under the
direction of N.A. Vasilieva, he signed an application for accession to the agreement on trust management of securities
and means of investment in securities No. DU - F - 1713/IIIS with IK QBF LLC and an application for accession to the
agreement on trust management of securities and means of investment in securities No. DU - F - 1714 with IK QBF
LLC. Under the agreement No. DU - F - 1713/IIS, he deposited RUB 300,000 on 24.12.2019 with IK QBF LLC and another
RUB 100,000 on 25.12.2019, and under the agreement No. DU - F - 1714, he deposited RUB 600,000 in March 2020 with
IK QBF LLC. He transferred the funds from his account opened with PJSC "RGS Bank". A couple of days later, on
25.12.2019, he, being in the above - mentioned office, at the address: St. Petersburg, Degtyarny per. 11, lit. B, under
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the contract № D - 899182 - L with "White Lake Management Ltd." transferred funds in the amount of 2 550 000 rubles
to the group of companies "QBF", the funds he handed over personally to Vasilieva N.A., and the manager of the group
of companies "QBF" Porfiriev Anton was also present. Afer signing the above documents, his email address received
regular reports from reports@wl - mnt.com informing him of alleged changes in the value of the securities in his
investment portfolio. Around December 2020, he wanted to withdraw his money from the QBF Group of Companies
and informed N.A. Vasilieva about it, to which the latter started to persuade him not to withdraw his money. In March
2021, he actively insisted on withdrawing his money from the QBF Group of Companies, but N.A. Vasilieva kept
coming up with various reasons not to return his money. In April 2021, he wrote an application to the QBF Group of
Companies for the return of his money, but received no response. In May 2021, he learned from the media, as well as
official publications of the Ministry of Internal Affairs of Russia, that QBF Group had had its licences revoked. He called
N.A. Vasilieva, who confirmed the difficult situation of the QBF group of companies and recommended that he
withdraw his money. To date, he has not been returned his money deposited with the "QBF" group of companies in
the amount of RUB 3,550,000, RUB 2,550,000 under contract No. D - 899182 - L with "White Lake Management Ltd",
RUB 400,000 under contract No. DU - F - 1713/IIS, RUB 600,000 under contract No. DU - F - 1714. He believes that an
offence has been committed against him, namely the thef of his money by deceit and abuse of trust. He estimates the
amount of damage caused to him as significant, namely 3,550,000 (three million five hundred and fify thousand)
roubles. Also considers that the persons acting on behalf of the group of companies "QBF" initially did not intend to
fulfil their obligations to him and acted solely for the purpose of stealing his money by deceiving him. The persons
acting on behalf of the "QBF" group of companies stole money belonging to him in the total amount of 3,550,000
roubles. I consider the amount of the damage caused to him to be significant. He has been explained the right to file a
civil action in the criminal case. He wishes to exercise this right and file a lawsuit. He has been given the right to
familiarise himself with the composition of the investigative teams, the decisions on the appointment of expert
reports, the records of expert interrogations, and the materials of the criminal case in full or in part. He does not wish
to exercise this right. He has not applied to the court with applications for recovery of money from the "QBF" group of
companies;
- (Vol. No. 53, pp. 10 - 13, 136 - 139)

- other documents - documents provided by V.N. Burmistrov confirming his relationship with QBF Financial
- (Vol. No. 53, pp. 15 - 131)
part 4 of article 159 of the Criminal Code of the Russian Federation against Mishin Y.A.:
- another document - a statement by Mishin Y.A., in which he asks to bring to criminal responsibility persons
- (Vol. No. 53, pp. 155, 156)
- The testimony of Mishin Y.A., given by him as a witness and victim,

according to which, in about 2010, he met Porfiriev A.O. Then, buying a car brand Hundai Santa Fe, he applied for a
loan to VTB Bank. The bank manager proved to be a competent and qualified consultant. He quickly helped him to
apply for a car loan. This is how he got acquainted with A.O. Porfiriev. Subsequently he also repeatedly turned to him
for consultations on deposits and other products of VTB Bank. These were always professional financial advisory
services. Not being an expert in financial matters, for several years, he turned for help exclusively to A.O. Porfiriev.
Having become a VIP - client of VTB Bank, he fully trusted him with the management of his funds. At some point, Mr
Porfiriev transferred from VTB Bank to QBF. Having resigned from VTB Bank, A.O. Porfiriev, while maintaining good
relations, repeatedly invited him to meet at the company's office and offered him various opportunities to withdraw
all assets from VTB Bank and invest them in "QBF" securities. In the spring of 2017, afer another call from A.O.
Porfiriev, he agreed to come for an introductory meeting at the office of QBF, located at 64, Lit. B, Maloohtinsky Ave,
963
St. Petersburg, where he was shown the successful activities of the company. During the meeting the atmosphere in
the office, as it seemed to him at the time, really confirmed the success of the work. Everything was supported by
colourful presentations, various video clips. There were talks about the planned increase of the scope of activity and
expansion of the volume, and special attention was paid to the absolute transparency and hundred per cent
guarantees of all transactions concluded in "QBF". To confirm the success and reliability of the company "QBF",
Porfiriev A.O. presented the licences issued by the Federal Service for Financial Markets and the Central Bank of the
Russian Federation, and also announced the company's plans for expansion and moving to an office with more
opportunities for meetings with a large number of clients at the address: St. Petersburg, Degtyarny pereulok, ul. 11,
Lit. B (BC "Nevskaya Ratusha"). So on 31.10.2017, being in the office of the company "QBF", located at the above
address, under the direction of Porfiriev A.O. on behalf of non - resident "QCCI LTD" ("QCCI LTD") with him was
concluded Agreement on provision of services of direct access to international stock markets No. 4108 - 17/ISR dated
31.10.10.2017, and on behalf of QBIF Ltd. the Trustee Services Agreement pursuant to the Direct Access to
International Stock Markets Services Agreement No. 4108 - 17/ISR dated 31.10.2017. On the same day, he handed over
to A.O. Porfiriev cash in the amount of RUB 590,000. In return, a receipt order b/n was received. Starting from the next
month, he started receiving reports on allegedly made transactions with securities to his email. Planning to form a
potential income for retirement, he began to deposit free money to the company "QBF" with a certain periodicity.
During this period he made additional deposits: 12.02.2018 in the amount of RUB 540,000; in January 2019 in the
amount of USD 9,900, which at the maximum exchange rate of the Central Bank of Russia for January 2019 was RUB
665,200.80; in February 2019 in the amount of USD 11,500, which at the maximum exchange rate of the Central Bank
of Russia for February 2019 was RUB 767,100.60; in March 2019 in the amount of USD 3,000, which at the maximum
exchange rate of the Central Bank of Russia for March 2019 was RUB 198,228.90; in April 2019 in the amount of USD
14,000, which at the maximum exchange rate of the Central Bank of Russia for April 2019 was RUB 916,616.40; in July
2019 in the amount of USD 9,900, which at the maximum exchange rate of the Central Bank of Russia for July 2019
was RUB 632,312.01. They met regularly with A.O. Porfiriev at the office of QBF. The occasions for the meetings were
various: signing, re - signing of various documents, additional agreements and so on. The wording each time was: "for
reliability" and "greater assurance" of financial operations. And, since the degree of trust in this person was high, the
documents were signed by him automatically and unconditionally. This was accompanied by A.O. Porfiriev's words:
"Yuri Alekseevich, all this is a pure formality, don't pay attention, everything is reliable!". Afer Porfiriev A.O. rechecked
everything independently. Thus 03.10.2019, being in the office of LLC "IC "QBF", located at the address: St. Petersburg,
Degtyarny per., 11, lit.B (BC "Nevskaya Ratusha"), with him on behalf of non - resident "White Lake Management Ltd"
("White Lake Management Ltd") concluded a trust management agreement No. D - 048711 - J dated 03.10.2019, as
well as on behalf of LLC "VL Consulting" a Service Agreement (standard form of accession agreement) dated
03.10.2019. In December 2019, while in the office at the above address, he additionally handed over to the employees
of the company cash in the amount of USD 10,145 and USD 9,000, which at the maximum exchange rate of the Central
Bank of the Russian Federation as at December 2019 amounted to RUB 1,233,123.71. He would like to note that under
the guise of paying interest from investment activities, the stolen funds were partially returned to him, namely: in
June 2018 in the amount of USD 700, which at the maximum exchange rate of the Central Bank of the Russian
Federation as at June 2018 was 44,847.81 rubles; in November 2019 in the amount of USD 4,400, which at the
maximum exchange rate of the Central Bank of the Russian Federation as at November 2019 was 282,524.44 rubles; in
November 2020 in the amount of USD 14,000, which at the maximum exchange rate of the Central Bank of the Russian
Federation as at November 2020 was 1,128,048.60 rubles. However, in 2020 and especially in 2021, delays in the
submission of reports began, and for some months they were not submitted at all. A.O. Porfiriev commented on this
by failures in the general electronic information system, accompanying these delays or lack of reports by the fact that
in the electronic form, accessible only to him, the reports are visible and everything is in order there. And he sent
several reports personally from his email account. In March 2020, a letter from A.O. Porfiriev was sent to his e - mail
address, where he once again reassured him about the reliability of the company "QBF", and in confirmation referred
to a large number of "fake" articles, which were commissioned by competitors. Such conversations took place
constantly during his statements about his desire to withdraw funds from the company. When he retired in September
2020, he decided to withdraw the deposited funds from QBF. Alas, nothing has come of this to date. All notices were
sent by mail to A.O. Porfiriev or delivered by him personally to the company office, and since May 2021 A.O. Porfiriev
964
ofen did not respond to his phone calls and messages, and if he did respond, he refused to communicate and meet in
person, citing his excessive workload. On 27 November 2021, afer another unsuccessful attempt to call A.O. Porfiriev,
he wrote in a text message to him: "See you in court". A.O. Porfiriev called him back in half an hour, explaining that
everything happening with "QBF" was due to temporary difficulties and advised him to prepare another notification
on the realisation of assets and send it to the e - mail address where the reports come from. Considering the fact that
the deadline for the return of his money had expired, there was no doubt that he had fallen victim to fraudsters. To
date, his money deposited to the "QBF" group of companies in the amount of 4,087,161.57 roubles has not been
returned to him. He believes that the persons acting on behalf of the group of companies "QBF" initially did not
intend to fulfil their obligations to him and acted solely for the purpose of stealing his money by deceiving him. In the
period from 31.10.2017 to 31.12.2019, the persons acting on behalf of the "QBF" group of companies stole money
belonging to him in the total amount of 4,087,161.57 rubles. He considers the amount of damage caused to him as
significant. He has been explained the right to file a civil action in the criminal case. He wishes to exercise that right
protocols of interrogations of experts, as well as to familiarise himself with the materials of the criminal case in full or
in part. He does not wish to exercise this right. He did not apply to the court with applications for recovery of money
from the "QBF" group of companies;
- (vol. No. 53, pp. 159 - 162, vol. No. 54, pp. 75 - 79 )
- other documents - documents provided by Mishin Y.A. confirming his relationship with QBF Financial Group
- (Vol. No. 53, pp. 169 - 228, Vol. No. 54, pp. 1 - 56)
part 4 of article 159 of the Criminal Code of the Russian Federation against Mazitov V.G.:
- another document - a statement of V.G. Mazitov, in which he asks to bring to criminal responsibility persons
- (Vol. No. 54, pp. 92, 96)
- The testimony of V.G. Mazitov, given by him as a witness and victim

, according to which, previously he was a client of the bank "Vostochny", where he kept his savings. At the beginning
of 2020 he received a phone call from Kuznetsov Sergey (tel. 8 - 921 - 564 - 87 - 86), who introduced himself as the
head of one of the departments of the company "QBF", according to him, previously he (Kuznetsov S.) was an
employee of the bank "Vostochny", where he (Mazitov V.G.) was served. During the telephone conversation Kuznetsov
S. told about the possibility of additional earnings by investing available funds, both in foreign currency and in rubles,
in the company "QBF" for further financial operations on domestic and international markets. Then he was interested
in the proposal and they agreed on a personal meeting. The meeting took place in the company's office located at 11B
Degtyarny per. in St. Petersburg (BC Nevskaya Ratusha). Some time later (he does not remember the exact date) he
came there with his wife, where they met Kuznetsov S. At the meeting he told about the prospects of co - operation,
told about the company itself and the options for investing money to generate income. He showed colourful
presentations, told them that the company has existed since 2008, that during this time it has shown itself well on the
investment market, that with the help of the company "QBF" it is possible to officially invest money in securities
(shares) traded on the New York Stock Exchange. They were shown licences issued by the Federal Service for Financial
Markets (FSFM of Russia). They were promised a high yield and profit of at least 20% per annum in dollars, with the
commission of "QBF" on Trust Management Agreements of 30% of the profit. Different strategies were shown. On a
choice were offered: aggressive, average weighted and conservative. Everything sounded very convincing, so the
proposal then they were very interested, they took a pause to study everything carefully, think about it and make an
informed decision. At home they found and carefully checked the reviews about the company on the Internet, as well
965
as data on the website of the Central Bank of Russia, where the information was confirmed - the licence is valid, the
reviews about the company were exclusively positive. All this was a decisive factor in terms of choosing the company
and confirming its reliability. On 03.02.2020 in the office of the company on behalf of non - resident "White Lake
Management Ltd" ("White Lake Management Ltd") the Trust Management Agreement No. D - 830245 - B dated
03.02.2020 was concluded with him, on behalf of non - resident "WLM" ("WLM") the Service Agreement No. 830245 - B
dated 03.02.2020 was concluded, and also on behalf of LLC "VL Consulting" the Service Agreement (standard form of
accession agreement) dated 03.02.2020 was concluded. The documents were signed by D.A. Korshunov. This person is
not known to him. At the same time, in a separate cash room, they were handed over cash in the amount of 65,000
USD, which at the exchange rate of the Central Bank of Russia as of 03.02.2020 was 4,104,002.50 rubles. The money
was accepted by an employee, Ekaterina Martsenyuk, who in return handed him a receipt order b/n. Starting from
February 2020, he started to receive reports on transactions on the purchase of securities on his account. He cannot
confirm or deny the reliability of these reports. In February 2021, he decided to withdraw the funds in full, then he
called Kuznetsov S. and told about his intention. Kuznetsov S. tried for a long time to persuade him not to withdraw
the money and even to deposit more, because, as he said, "now is the best period for depositing money, not for
withdrawal". However, his arguments seemed unconvincing. In the end, he insisted on signing an order to withdraw
the money. Kuznetsov S. warned that it would take about two or even three months to withdraw the money. In order
to speed up the process, he offered to transfer the invested funds, or rather to purchase the assets of the RIF
Skladskoy Federal 1 real estate ZPIF. He trusted and came to the office of the company, where he concluded a new
contract (unit sale and purchase agreement dated 26.04.2021). In the spring of 2021 he learnt from the media that the
company "White Lake Management Ltd.", aka "QBF", became bankrupt and its founder went on the run. S. Kuznetsov
answered his calls, but to all his questions he just shrugged his shoulders and said that, unfortunately, he did not
know anything about the prospects of the company. That he himself was in the same deplorable situation as he was.
Considering the fact that the deadline for refunding his money had expired, there was no doubt that he was a victim
of fraud. To date, he has not been returned his money deposited to the "QBF" group of companies in the amount of
4,104,002.50 roubles. He considers that the persons acting on behalf of the group of companies "QBF" initially did not
intend to fulfil their obligations to him and acted solely for the purpose of stealing his money by deceiving him. On
03.02.2020, the persons acting on behalf of the "QBF " group of companies stole the money belonging to her
in the total amount of 4,104,002.50 rubles. He assesses the amount of damage caused to him as significant. He has
been explained the right to file a civil action in the criminal case. He wishes to exercise this right and file a lawsuit. He
has been explained the right to familiarise himself with the composition of the investigation teams, with the decisions
on the appointment of forensic examinations, with the conclusions of experts, with the protocols of interrogations of
companies;
- (Vol. No. 54, pp. 97 - 99, 194 - 197)

- other documents - documents provided by V.G. Mazitov confirming his relationship with QBF Financial Group
- (Vol. No. 54, pp. 102 - 187)
part 4 of article 159 of the Criminal Code of the Russian Federation against Toloknov D.Y.:
- another document - a statement by Toloknov D.Y., in which he asks to bring to criminal responsibility persons
- (Vol. No. 55, l.d. 6)
- D.Y. Toloknov's testimony as a witness and victim

, according to which, in the period 2017 - 2018, he was a client of JSC "Alfa Bank". He was accompanied by the
personal manager of the bank Budarin Nikita. At the end of 2018, Budarin Nikita resigned from the bank and was
employed by QBF Group. He then got in touch with him and suggested that he transfer his assets to the QBF Group of
966
Companies. He independently studied the information available on the Internet regarding the investment activities of
the "QBF" group of companies and became interested in them. He repeatedly came to the office of the company
"QBF" located at the address: Moscow, Presnenskaya Naberezhnaya, 8, st.1, 9th floor. In the course of the interaction,
he purchased investment products, invested his personal funds and subsequently withdrew them without
experiencing any particular problems. In the first half of 2019, Nikita Budarin resigned from QBF Group for reasons
unknown to him, afer which his manager, Andrey Korzh, became his financial advisor. In the autumn of 2019, he was
approached by Korzh Andrey with an offer to invest in the QBF Group of Companies on promising investment
strategies. It was communicated to him that the funds would be invested in investment platforms of foreign countries.
Everything was presented in a colourful way, devoid of flaws. Korzh Andrey promised him stable profitability. Taking
into account the existing positive experience of interaction with Budarin Nikita, he agreed to the proposal of Korzh
Andrei and arranged a meeting with him in the office of the company "QBF", at the same time saying in advance that
he would come with cash. On 28.11.2019, at approximately 12:00, he arrived at the office of the "QBF" group of
companies, located at the address: Moscow, Presnenskaya Naberezhnaya 8, page 1, 9th floor. Upon arrival, he was
met by Korzh Andrey and escorted to a meeting room. Korzh Andrey had already signed copies of the documents with
VL Consulting LLC represented by Maricheva O.V., namely the service agreement dated 27.11.2019, the trust
management agreement No. D - 284592 - K dated 27.11.2019 with White Lake Manadement Ltd represented by
Korshunov D.A., service agreement No. 284592 - K with "WLM Ltd" represented by Korshunov D.A., as well as service
agreement No. 284592 - K with "WLM Ltd" represented by Korshunov D.A. He would like to inform that he has never
seen Korshunov D.A. and Maricheva O.V. and has never communicated with them. Having signed the above
documents, he gave Korzh Andrey 15,000 US dollars, which at the exchange rate of the Central Bank of Russia as of
28.11.2019 was 959,550 rubles. Korzh Andrey took the money, counted it on a counting machine, went to a
neighbouring room and later returned with a receipt with a facsimile of Korshunov D.A.'s signature (the same in the
contract) and a stamp "WLM CR - 347210", which he gave to him. Afer he had invested money in the group of
companies "QBF", he started to receive monthly reports on the state of his investment portfolio to his e - mail address
[email protected]. Afer a couple of months Korzh Andrey got in touch with him again and offered to invest an
additional amount of money under another conservative investment strategy. Taking into account the positive
dynamics of the state of affairs, based on the reports received to his e - mail, he agreed and arranged a meeting with
Korzh Andrey at the head office. So on 06.02.2020, at about 12:30 he arrived at the office of the "QBF" group of
companies at the address: Moscow, Presnenskaya Naberezhnaya, 8, bldg. 1, 9th floor. On arrival he was met by Andrey
Korzh and escorted to a meeting room. In the meeting room, he gave Korzh Andrey 30,000 US dollars, which at the
exchange rate of the Central Bank of the Russian Federation as of 06.02.2020 was 1,895,100 rubles. Korzh Andrei took
the money, counted it on a counting machine, went to a neighbouring room and later returned with a receipt with a
facsimile signature of Korshunov D.A. (the same in the contract) and a stamp "WLM CR - 347210", which he gave to
him. In late May - early June 2021, he learned from the media, including official news from the Russian Ministry of
Internal Affairs, that criminal proceedings had been initiated and an investigation was underway. In connection with
the above events, he became concerned about the safety of his funds and on 03.06.2021 submitted an application for
withdrawal of funds. At the same time, he repeatedly communicated and met with Korzh Andrey in order to
communicate with him about the difficulties he had encountered. Korzh Andrey told him the most incredible reasons
for the lack of possibility to withdraw funds from the group of companies "QBF". He had a clear impression that there
was no intention to return his money. In total, he transferred 2,854,650 roubles to the "QBF" group of companies in
the period from 28.11.2019 to 06.02.2020. Till date, the funds have not been returned to him. Claims will be brought
for the amount of damage caused to him. Believes that an offence has been committed against him, namely thef of
his money by deceit and breach of trust. He considers the amount of damage caused to him as significant;
- (Vol. No. 55, pp. 9 - 12, 20 - 23)

- other documents - documents provided by Toloknov D.Y. confirming his relationship with QBF Financial
- (Vol. No. 55, pp. 24 - 92)
967
part 4 of article 159 of the Criminal Code of the Russian Federation against Kim A.L.:
- another document - a statement by Kim A.L., in which he asks to bring to criminal responsibility persons from
among the employees, managers of the financial group "QBF" (LLC "Investment Company QBF"), who stole
his money under the guise of carrying out brokerage activities;
- (Vol. No. 55, pp. 104,108)
- A.L. Kim's testimony as a witness and victim

, according to which, in the spring of 2019, the former manager of JSC "Alfa - Bank", where he was previously serviced,
Anastasia (tel. 89117694950) told him about the investment company "QBF". She also introduced him to QBF manager
Daniil Vetrov (tel. 89218891089). In order to obtain high returns, he offered to invest his available cash in roubles in
QBF to carry out financial transactions on the international market. He was immediately warned that roubles would
be converted into currency as they were operating on foreign markets. He was interested in the offer. Having studied
information about "QBF" company in open sources, he found it attractive enough to try to work with it. The presence
of 4 licences of the Central Bank of the Russian Federation was one of the most important moments that determined
the reliability of the company. In the future, all interactions with QBF took place through the financial advisor Daniil
Vetrov, who at that time got the position of a senior manager for St. Petersburg. According to Vetrov D., Anastasia also
started working for QBF. It should be noted that Vetrov D. himself is ready to co - operate with the investigative
authorities. According to him, he agrees to confirm the facts stated below and to be confronted. Afer initial
consultations and assurances in words that the company is reliable and there are no problems with the withdrawal of
funds, he decided to try to withdraw the first amount. So on 31.05.2019 under the pretext of investing funds in
securities with high yield on behalf of a non - resident "White Lake Management Ltd" ("White Lake Management Ltd")
concluded with him Trust Management Agreement No. D - 416912 - E dated 31.05.2019, as well as on behalf of LLC "VL
Consulting" Service Agreement (standard form of adhesion agreement) dated 31.05.2019. Thereafer, he was asked to
sign additional adhesion agreements with Lamera Holding and WhiteLake Management. Funds to the company's
accounts were delivered to them in the form of cash, in the company's office (BC Nevskaya Ratusha, Degtyarny per.
11B). The money was accepted by the cashier, and in exchange he was given receipts with the White Lake stamp. The
explanation of the difference was as follows: White Lake is an affiliated company and a direct participant of
investments in the Cayman Islands. Thus in the period of time from 31.05.2019 to 10.02.2020, being in the office of the
company QBF, located at the address: St. Petersburg, Degtyarny per. 11, lit.B (BC "Nevskaya Ratusha"), he handed
over to the employees monetary funds, namely: 31.05.2019 in the amount of RUB 1,700,000; 13.06.2019 in the amount
of RUB 1,600,000; 04.07.2019 in the amount of RUB 4,500,000; 01.08.2019 in the amount of RUB 6,000,000; 31.10.2019
in the amount of RUB 600,000; 10.02.2020 in the amount of RUB 13,000,000. The total amount of funds transferred
to them for investment is 27,400,000 roubles (twenty seven million four hundred thousand roubles). In January 2021,
when attempting to withdraw funds from the account, he was informed that QBF had frozen accounts in the Cayman
Islands and that it was impossible to withdraw funds directly. He was offered the following scheme of withdrawal of
funds from abroad: a certain company Aurum in Luxembourg provides a promissory note for the amount of debt of
"QBF", and this promissory note is exchanged under an assignment agreement for units of ZPIF QBF Reef Warehouse
Federal. Thus, the money "arrives" to the foreign accounts of "QBF" (and in fact is already there), and it has units in
the Russian Federation. The price of a unit was determined at 600,000 roubles. Later, the price in open sources was
determined at 325,000 rubles per unit. In order for this scheme to work, he was asked to have his passport translated
into English by a translation agency and provide this data to QBF, which he did. In order to accrue units, he opened an
account with a depository (certificate attached). In addition, he was actually forced to sign documents stating that he
had no claims against "VL Consulting" under the threat of non - return of funds. Given that he had been consistently
denied withdrawals for several months at that point, he was forced to agree. In June 2021, he learnt from the media
and official publications of the Russian Ministry of Internal Affairs that criminal proceedings had been initiated and
key employees of QBF Group had been arrested for fraud. According to the information known to him, criminal cases
have already been opened against some representatives of the QBF group of companies (QBF) on episodes of Trust
Management (TM) and money diversion to offshore: case No. 12101007754000065, case No. 12001450007000902.
968
Despite the scheme and amount of withdrawal agreed with QBF, the funds were not received. There were different
explanations, starting from seizure of servers by investigative bodies, ending with frozen accounts of "QBF" and
impossibility to accrue shares. All official representatives of "QBF" group of companies took a formal position and did
not answer questions on the merits, thus covering the recently working scheme and connections between affiliated
groups of "QBF" companies. There is every reason to believe that instead of investing the funds received from clients
to participate in investment products, these funds were withdrawn to various surrogate products abroad, as well as
invested in development projects of the beneficiaries, which knowingly could not generate returns comparable to
participation in investments in securities. And in order not to pay this yield to the client, the client's portfolio was
artificially driven into negative yield. This scheme could have been a real financial fraud, which ended in the complete
misappropriation of the transferred funds. Taking into account the fact that the deadline for returning the money to
him had expired, there was no doubt that he had become a victim of fraud. Up to now he has not been returned his
money deposited to the address of the group of companies "QBF" in the amount of 27 400 000 (twenty seven million
four hundred thousand) roubles. He believes that the persons acting on behalf of the group of companies "QBF"
initially did not intend to fulfil their obligations to him and acted solely for the purpose of stealing his money by
deceiving him. In the period from 31.05.2019 to 10.02.2020, the persons acting on behalf of the "QBF" group of
companies stole his money in the total amount of 27,400,000 rubles. He estimates the amount of damage caused to
him as significant. He has been explained the right to file a civil action in the criminal case. He wishes to exercise that
right and file a lawsuit. He has been given the right to familiarise himself with the composition of the investigative
teams, with the decisions to order forensic examinations, with the conclusions of experts, with the transcripts of
expert interrogations and with the materials of the criminal case in full or in part. He does not wish to exercise this
right. He did not apply to the court with applications for recovery of money from the "QBF" group of companies;
- (Vol. No. 55, pp. 109 - 113, Vol. No. 56, pp. 33 - 37)
- other documents - documents provided by A.L. Kim confirming his relationship with QBF Financial Group
- (Vol. No. 55, pp. 120 - 224, Vol. No. 56, pp. 1 - 28)
part 4 of article 159 of the Criminal Code of the Russian Federation against Troshkova M.S.:
- another document - a statement by Troshkova M.S., in which she asks to bring to criminal responsibility
- (Vol. No. 56, pp. 49, 52)
- Testimony of Troshkova M.S., given to her as a witness and victim,

according to which, in the period from 30 January to 5 February 2019, her mobile phone number received a call from
an employee of the group of companies "QBF" Salimova Zarina with an offer of additional income by allegedly
investing in financial products of the group of companies "QBF". Salimova Zarina persuaded her to meet with her to
get additional information. On 18.02.2019 the meeting with Salimova 3arina took place in her car in the immediate
vicinity of the metro station "Grazhdansky Prospekt", which is located at the address: St. Petersburg, Kalininsky
district, Grazhdansky Ave. 116, к. 1, where Salimova 3arina told her about all investment products of the group of
companies "QBF", assured her of its financial stability and integrity, and also described all financial benefits that she
would receive by investing money in the group of companies "QBF". She believed the words of Salimova Zarina and
concluded with the company "White Lake Management Ltd", which is a part of the group of companies "QBF", the
contract of trust management № D - 617579 - B from 18.02.2020, by means of electronic document management. She
deposited funds on 18, 19, 20 and 21 February 2019 (4 payments of RUB 250,000 each) by non - cash transfers from her
current account No. 40817810615064000405 opened with PJSC VTB Bank, branch No. 7806 in St. Petersburg. The total
amount of the transferred funds totalled RUB 1,000,000. Having trusted the employee of the group of companies
969
"QBF" Salimova 3arina and being in a state of delusion on 18.02.2020 in the office of the group of companies "QBF" at
the address: St. Petersburg, Degtyarny pereulok, d. 11, Lit. B, under the direction of the manager of the group of
companies "QBF" Salimova 3arina, she deposited the money belonging to her in the amount of 10 000 Euro, which at
the exchange rate of the Central Bank of Russia as of 18.02.2020 was 686 201 rubles, she was given 1 receipt to the
cash register of the group of companies b/n. The cash was accepted by a cashier, who was not presented to her. From
the moment of depositing money into the group of companies "QBF", the company "White Lake Management" sent
her monthly reports on alleged investment activities. She received the last report on 4 February 2022. During the time
her money was held in "trust" at QBF Group, she did not withdraw or receive any funds. In November 2021, she
learned from the media that QBF Group had some difficulties and their licence was being withdrawn. At the end of
December 2021, she was contacted by Salimova 3arina with a proposal to transfer ruble - denominated securities held
by QBF Group to the investment programme of PJSC FC Otkritie in the city of St. Petersburg. She responded to the
proposal by agreeing to it. In the first half of January 2022, the securities in the amount of RUB 1,000,000 were
transferred to the investment programme of PJSC FC Otkritie, thus she believes that the funds in the amount of RUB
1,000,000 have been returned to her (attached to the interrogation: the order on the return of property on 1 sheet). To
date, she has not been returned her funds deposited to the "QBF" group of companies in the amount of 10,000 Euros,
at the exchange rate of the Central Bank of Russia as of 18.02.2020 was 686,201 rubles. She believes that an offence
has been committed against her, namely the thef of her money by deceit and breach of trust. She estimates the
amount of damage caused to her as significant, namely 10 000 Euro, at the rate of the Central Bank of Russia as of
18.02.2020 was 686 201 rubles. The right to file a civil action in the criminal case has been explained to her. She wishes
to exercise this right and file a lawsuit. She has been explained the right to familiarise herself with the composition of
the investigation teams, with the decisions on the appointment of forensic examinations, with the conclusions of
experts, with the protocols of interrogation of experts, as well as to familiarise herself with the materials of the
criminal case in full or in part. She does not wish to exercise this right. She has not applied to the court with
applications to recover money from the "QBF" group of companies;
- (Vol. No. 56, pp. 53 - 55, Vol. No. 56, pp. 139 - 141)
- - other documents - documents provided by Troshkova M.S. confirming her relationship with QBF Financial
Group (Q BF Investment Company LLC) and testifying to the embezzlement of funds;
- (Vol. No. 56, pp. 56 - 131, 142)
part 4 of article 159 of the Criminal Code of the Russian Federation against Ganeva E.P.:
- another document - a statement by Ganeva E.P., in which she asks to bring to criminal responsibility persons
- (Vol. No. 56, pp. 161, 162, 173 - 174)
- Testimony of Ganeva E.P., given to her as a witness and victim,

according to which, in 2014 from her friend Kvitko Elizaveta Petrovna, born on 22.10.1994 (or 1993), who previously
worked as a manager in the group of companies "QBF", she learnt about the activities of the group of companies
"QBF". E.P. Kvitko told her about the possibility of earning money by investing in the "QBF" group of companies. She
trusted E.P. Kvitko because she was her friend. E.P. Kvitko worked in "QBF" group of companies for about 2 months. In
July 2014, she went to the office of the "QBF" group of companies at the address: 68, Maloohtinsky Ave., St.
Petersburg, Business Centre "Plaza", the manager of the "QBF" group of companies, Dmitry Moskalyuk, worked with
her and prepared all the documents necessary for signing the contract. She concluded a contract with some
organisation from the group of companies "QBF", which one she does not remember. As part of the contract, while in
the office of the QBF group of companies at 68 Maloohtinsky Prospekt, 68, Plaza Business Centre, St. Petersburg, she
deposited her cash in the amount of approximately 800,000 roubles in the cash desk. In October 2014, she filed an
970
application to withdraw her funds from the QBF Group. At the end of December 2014, she received her cash in full. At
the beginning of 2019, she entered into an agreement with the "QBF" group of companies, under which she deposited
her cash in the amount of 350,000 roubles in the cash desk of this group of companies. On 28.02.2020, being in the
office of "QBF" at 11 Degtyarny Lane, Lit. B, 6th floor, office 601, St. Petersburg, under the supervision of Efremtsev A.,
she signed the following documents: trust management agreement No. D738025 - B with "White Lake Management
Ltd", service agreement No. 738025 - B with limited liability company "VLM", service agreement with LLC "VL
Consulting". She did not read these documents because she did not assume that she could be deceived. A. Efremtsev
explained to her that there were certain risks of losing the invested money, which could be up to 30% of the invested
amount. She trusted A. Efremtsev and deposited her money in the group of companies "QBF". On 28.02.2020, she
went to the office of "QBF" at the address: St. Petersburg, 11, Degtyarny per. Degtyarny, 11, lit. B, 6th floor, office 601,
under the escort of the manager of the group of companies "QBF" Efremtsev Artyom, she carried to the cash desk of
the group of companies "QBF" her money in the amount of 13 700 Euros, which at the rate of the Central Bank of
Russia as of 28.02.2020 was 981 547,46 rubles and 14 300 US dollars, which at the rate of the Central Bank of Russia as
of 28.02.2020 was 938 218,71 rubles. Who was the cashier, she does not remember. In March 2021, she applied to the
"QBF" group of companies with an application for the return of her money. She applied to Efremtsev A., but he told
her that he had resigned from the group of companies "QBF", but at the same time he said that he would deal with the
issue of returning her money, as she was his client. Efremtsev A. told her that it would take up to 3 months to return
the money and gave her a list of documents to be submitted to the "QBF" group of companies to return the money.
She submitted all the necessary documents to Efremtsev A., but the money was not returned to her. In May 2021,
Efremtsev A. told her that a criminal case had been opened against the QBF Group of Companies. Efremtsev A. told
her to contact Moskaluk D., who in turn told her that by the end of September 2021 there would be some kind of
restructuring and she would receive the money afer selling the portfolio of shares allegedly bought with her money.
At the end of September 2021 the money was not returned to her, Moskalyuk D. constantly drags out the time, does
not say anything concrete about the return of funds. Afer that, she realised that she had been misled and deceived,
and the money she had paid into the cash desk of the QBF group of companies had been stolen. Till now her money
deposited to the address of the group of companies "QBF" in the amount of 13 700 Euro and 14 300 US dollars, i.e. 1
919 766,17 roubles has not been returned to her. She believes that an offence has been committed against her,
namely the thef of her money by deceit and abuse of trust. She estimates the amount of damage caused to her as
significant, namely 13,700 Euros and 14,300 US dollars, which at the exchange rate of the Central Bank of the Russian
Federation at the time of depositing the money amounted to 1,919,766.17 roubles. To date, she has not been returned
her money deposited in the address of the group of companies "QBF" in the amount of 13 700 Euros and 14 300 US
dollars, which at the exchange rate of the Central Bank of Russia at the time of deposit of funds amounted to 1 919
766,17 rubles. Believes that the persons acting on behalf of the "QBF" group of companies initially did not intend to
fulfil their obligations to her and acted solely for the purpose of stealing her money by deceiving her. The persons
acting on behalf of the "QBF" group of companies stole her money in the total amount of 1,919,766.17 roubles. She
estimates the amount of damage caused to her as significant. She has been explained the right to file a civil action in
the criminal case. She wishes to exercise this right and file a lawsuit. She has been explained the right to familiarise
examinations, with the conclusions of experts, with the protocols of interrogations of experts, and also to familiarise
herself with the materials of the criminal case in full or in part. She does not wish to exercise this right. She has not
applied to the court with applications for the recovery of funds from the "QBF" group of companies;
- (Vol. No. 56, pp. 191 - 194, Vol. No. 57, pp. 18 - 21)
- other documents - documents provided by E.P. Ganeva confirming her relationship with QBF Financial Group
- (Vol. No. 56, pp. 175 - 183, 197 - 245 Vol. No. 57, pp. 1 - 10)
part 4 of article 159 of the Criminal Code of the Russian Federation against Podgornaya I.A.:
971
- another document - a statement by I.A. Podgornaya, in which she asks to bring to criminal responsibility
- (Vol. No. 57, pp. 34, 35, 36 - 37)
- Testimony of I.A. Podgornaya, given to her as a witness and victim

, according to which, in March 2020 in the Internet she found an announcement about the group of companies "QBF",
which spoke about the possibility of additional income by investing money in IPO - initial public offering of securities
on the stock exchange. Afer making enquiries on the Internet, namely on the website of the QBF group of companies,
as well as in other sources, she decided to contact the head office for counselling. She called the general phone
number of the group of companies "QBF", she was answered by a secretary, whose data she does not remember. She
lef her contacts with the secretary. Afer that she was contacted by the manager of the group of companies "QBF"
Artyom Efremtsov (tel.: 8 - 921 - 858 - 16 - 23), who immediately began to mislead her about the alleged financial
products of the group of companies "QBF", about the system of participation in the IPO allegedly increased allocation.
By his stories Efremtsov A. convinced her that the group of companies "QBF" has a long and successful experience of
work in Russia and abroad, has direct access to IPO, all necessary licences are available. A. Efremtsov convinced her
that the reliability of working with QBF Group was guaranteed by the legislation of the Russian Federation. Efremtsov
A. told her that his manager was Dmitry Vladimirovich Moskalyuka, who is the vice - president of "QBF" companies.
Trusting Efremtsov A. she agreed to contribute her money to the group of companies "QBF". She provided Efremtsov
A. with her e - mail address: [email protected], to which she received documents for signing the agreement and
participation in investment projects. On 21 April 2020, being in the office of the "QBF" group of companies at the
address: St. Petersburg, Degtyarny pereulok, ul. 11, lit. B, she signed a contract with the above legal entity. She cannot
give the number of the contract, because this contract was taken away from her by Efremtsov A., when she
renegotiated the contract with another legal entity, according to Efremtsov A., a subsidiary of QBF LLC. On 21 April
2020, being in the office of LLC IC QBF at the address: St. Petersburg, Degtyarny pereulok, d. 11, Lit. B she handed over
to Efremtsov A. her cash in the amount of 3,900,000 roubles and 38,500 Euros, which at the exchange rate of the
Central Bank of Russia as of 21.04.2020 amounted to 3,122,423.15 roubles. In order to give the appearance of real
investment of funds, A. Efremtsov gave her two so - called "documents" with the title "CONFIRMATION RECEIPT",
which indicated the amount of the deposited funds. Thereafer, monthly reports from the e - mail address reports@wl
- mnt.com. were sent to her aforementioned e - mail account, containing information about the alleged presence of
her funds in the QBF account. She believed that her funds were invested. In June 2020, Efremtsov A. told her that she
needed to renegotiate the contract with QBF IK LLC for other QBF subsidiaries. She travelled to the aforementioned
office of QBF IK LLC, where she signed agreements with the affiliated companies, namely: Trust Management
Agreement No. D - 110500 - D dated 21.04.2020; on behalf of non - resident "WLM" ("WLM") Service Agreement No. D -
110500 - D dated 21.04.2020; on behalf of WL Consulting LLC entered into a Service Agreement (standard form of
affiliation agreement) with her dated 21.04.2020. In August 2020 she decided to terminate all contracts with the group
of companies "QBF" and take her money, for which purpose she came to the above mentioned office of LLC IC "QBF".
There she was met by Efremtsov A., who persuaded her in every possible way not to terminate the contracts,
motivated by the fact that the value of her investment portfolio at that time was lower than the purchase price, and
when selling it she would partially lose her money. Despite his persuasions, she wrote an application for cancellation
of the contracts. According to the terms of the contracts, her money was to be returned to her within 3 months from
the date of the application. Afer 3 months the money was not returned to her, so she called "QBF", she was answered
by Moskalyuk D.V. who said that Efremtsov A. was fired from their company and he (Moskalyuk D.V.) would work with
her. D.V. Moskalyuk, as well as A. Efremtsev, began to deceive and mislead her in every possible way regarding the
return of her money. D.V. Moskalyuk said that his application for cancellation of contracts and withdrawal from
participation in the activities of "QBF" was allegedly lost and she had to write this application again. She once again
972
wrote an application for cancellation of contracts with "QBF" companies. Afer another 3 months the money was not
returned to her. At that moment she realised that she had become a victim of fraudsters. Throughout the whole time
Moskalyuk D.V. was inventing various reasons not to return her money, constantly stalling time, misleading her. During
that period of time, she saw information in the media that criminal cases had been opened and investigations were
being conducted against employees and managers of the QBF group of companies. This confirmed his thoughts that
she was a victim of fraud. To date, her money deposited to the "QBF" group of companies in the amount of 43,000 US
dollars, which at the exchange rate of the Central Bank of Russia on the dates of depositing the money on 20.03.2018
and 24.03.2018 amounted to 2,464,507.60 rubles, has not been returned to her. She believes that the persons acting
on behalf of the "QBF" group of companies initially did not intend to fulfil their obligations to her and acted solely for
the purpose of stealing her money by deceiving her. On 21.04.2020 the persons acting on behalf of "QBF" group of
companies stole her money in the total amount of 7 022 423,15 rubles. She considers the amount of damage caused
to her as significant. She has been explained the right to file a civil action in the criminal case. She wishes to exercise
this right and file a lawsuit. She has been explained the right to familiarise herself with the composition of the
investigative teams, with the decisions on the appointment of forensic examinations, with the conclusions of experts,
with the records of interrogations of experts, and also to familiarise herself with the materials of the criminal case in
full or in part. She does not wish to exercise this right. He did not apply to the court with applications for the recovery
of funds from the "QBF;
- (Vol. No. 57, pp. 106 - 109, 196 - 199)

- other documents - documents provided by I.A. Podgornaya confirming her relationship with QBF Financial
- (Vol. No. 57, pp. 41 - 99, 111 - 189)
part 4 of article 159 of the Criminal Code of the Russian Federation against Kovin A.P.:
- another document - a statement by Kovin A.P., in which he asks to bring to criminal responsibility persons
- (Vol. No. 58, pp. 7, 11)
- The testimony of Kovin A.P., given by him as a witness and victim,

according to which, in April 2019, he found information about the group of companies "QBF" in the Internet. He was
interested in the published materials in the part concerning participation in IPO. IPO is a primary market with
subsequent circulation of securities on the stock exchange. Having made enquiries in the network - Internet, namely
on a site of group of companies "QBF", and also in other sources he has decided to call to the main office for
consultation. He called the general telephone number and lef his contacts there. Later he was contacted by a
manager of the QBF Group of Companies named Zarina Salimova (tel. 8 - 953 - 148 - 18 - 59), who presented him the
financial products of the QBF Group of Companies and the system of participation in the IPO. Earlier Salimova Zarina
was familiar to him from her work in the bank PJSC "VTB Bank", where she was his manager and with her he had good
trusting relations. In the course of telephone conversations Salimova Zarina very colourfully and convincingly told
him about investment products available in the organisation "QBF", ways of investment, mechanisms of profit
formation, the order of reporting and informing the client, as well as in general about the structure of the
organisation. He was informed that the funds would be invested in investment platforms of foreign countries.
Everything was presented in a colourful way, devoid of flaws, and he was promised a high yield (not less than 10% per
annum). As a result of the above meeting, as well as relying on the entreaties and stories of Salimova Zarina during a
telephone conversation, he informed her that he was ready to invest in the group of companies "QBF". They agreed to
meet at the main office of the company. On 28 May 2019 at about 14:00 he arrived at the office of the company "QBF"
at the address: St. Petersburg, Degtyarny per. 11 (BC "Nevskaya Ratusha"). Upon arrival he was met by Salimova
Zarina and escorted to the meeting room, she already had signed copies of documents with LLC "VL Consulting"
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represented by Maricheva O.V. Service agreement (standard form of accession agreement) dated 28.05.2019, "White
Lake Management Ltd." represented by Korshunov D.A. service agreement № 192630 - E dated 28.05.2019 and trust
management agreement № D - 192630 - E dated 28.05.2019. Also, Salimova Zarina provided him with the following
documents for signature: authorisation notice dated 28.05.2019 (Annex No. 3 to Service Agreement No. 192630 -
09 dated 28.05.2019), risk notice (Annex No. 5 to Service Agreement No. 192630 - 09 dated 28.05. 2019),
consent to the processing, use and dissemination of personal data (Annex No. 6 to the service contract No. 192630 - 09
dated 28.05.2019), statement of adherence to the service contract (Annex No. 7 to the service contract No. 192630 - 09
dated 28.05.2019). Neither Maricheva O.V. nor Korshunov D.A. are personally known to him, he has never
communicated with them, he has never seen them. Having signed the above documents, Salimova Zarina led him to
the neighbouring cashier's office, where he handed over cash to the cashier (no name) in the amount of 300,000
Euros. Having counted the amount of money he had given her, the cashier gave him a "confirmation receipt" for the
said amount, which bore the signature of a person unknown to him and the imprint of the "WLM" stamp. Afer he had
invested in the QBF Group, he received reports to his e - mail address [email protected], which were sent until the end of
2021. These reports reflected the status of his investment portfolio. Periodically, he received calls from Salimova
Zarina, who offered him to invest additional funds, as well as to think about purchasing additional financial products
of the group of companies "QBF". So, on 30 August 2019 at about 14:00 he again arrived at the office of the company,
at the address: St. Petersburg, Degtyarny per., 11 (BC "Nevskaya Ratusha"), where he was also met by Salimova
Zarina, took him to the meeting room and began to tell him about the need to invest more money in the group of
companies "QBF". He again trusted Salimova Zarina and gave the cashier another USD 130,000 and EUR 250,000 in
cash as part of the previously concluded agreements. The cashier gave him two "confirmation receipts" for these
amounts, bearing the signature of a person unknown to him and the stamp of "WLM". Afer depositing the funds,
Salimova Zarina provided him with an investment declaration (additional agreement to the service agreement No.
192630 - 09 dated 28.05.2019). Afer some time, he had an opportunity to further invest the available funds. Then he
contacted Salimova Zarina to schedule a meeting at the company's office. So, on 06 November 2019 at about 14:00 he
again arrived at the office of the company, at the address: St. Petersburg, Degtyarny per., 11 (BC "Nevskaya Ratusha"),
where he was also met by Salimova Zarina, took him to the meeting room and began to tell him about the need to
invest additional funds in the group of companies "QBF". He again trusted Salimova Zarina and gave the cashier
another 50,000 Euros in cash within the framework of the previously concluded agreements. The cashier gave him a
"confirmation receipt" for this amount, which bore the signature of a person unknown to him and the stamp of WLM.
Afer depositing the funds, Salimova Zarina provided him with the declaration (additional agreement to the service
agreement No. 192630 - 09 dated 28.05.2019). Afer some time, he again had an opportunity for additional investment
and contacted Salimova Zarina to schedule a meeting at the company's office. So, on 29 November 2019 at about
14:00 he again arrived at the office of the company, at the address: St. Petersburg, Degtyarny per., 11 (BC "Nevskaya
Ratusha"), where he was also met by Salimova Zarina, took him to the meeting room and began to tell him about the
need to invest more money in the group of companies "QBF". He again trusted Salimova Zarina and gave the cashier
another 50,000 Euros and 170,000 USD in cash under the previously concluded agreements. The cashier gave him two
"confirmation receipts" for these amounts, bearing the signature of a person unknown to him and the stamp of
"WLM". Afer depositing the funds, Salimova Zarina provided him with an investment declaration (additional
agreement to the service agreement No. 192630 - 09 dated 28.05.2019). Afer some time, he again had an opportunity
for additional investment and contacted Salimova Zarina to schedule an appointment at the company's office. So, on
23 April 2020 at about 14:00 he again arrived at the office of the company, at the address: St. Petersburg, Degtyarny
per., 11 (BC "Nevskaya Ratusha"), where he was also met by Salimova Zarina, took him to the meeting room and
began to tell him about the need to invest more money in the group of companies "QBF". He again trusted Salimova
Zarina and handed over to the cashier another 6,000,000 roubles in cash under the previously concluded agreements.
The cashier gave him a "confirmation receipt" for this amount, which bore the signature of a person unknown to him
and the stamp of "WLM". Afer depositing the funds, Salimova Zarina provided him with an investment declaration
(additional agreement to the service agreement No. 192630 - 09 dated 28.05.2019). In total, during the period from
28.05.2019 to 23.04.2020, being in the office of the company "QBF", located at the address: St. Petersburg, Degtyarny
per., 11, lit. B (BC "Nevskaya Ratusha"), he transferred to the employees of the company "QBF" monetary funds,
namely: 28.05.2019 in the amount of 300,000 Euros, which at the exchange rate of the Central Bank of Russia as of
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28.05.2019 was 21,655,890 roubles; 30.08.2019 in the amount of 250,000 Euros, which at the exchange rate of the
Central Bank of Russia as of 30.08. 2019 was 18,48898950 roubles and 130,000 US dollars, which at the exchange rate
of the Central Bank of Russia as of 30.08.2019 was 8,677,123 roubles; 06.11.2019 in the amount of 50,000 Euros, which
at the exchange rate of the Central Bank of Russia as of 06.11.2019 was 3,521,015 RUB; 29.11.2019 in the amount of
50,000 Euros, which at the exchange rate of the Central Bank of Russia as of 29.11.2019 was 3,528,735 RUB and 170,
000 USD, which at the exchange rate of the Central Bank of Russia as of 29.11.2019 was 10,897,085 RUB;
23.04.2020 in the amount of 6,000,000 RUB. In the process of co - operation with the group of companies
"QBF", he periodically withdrew funds from investment accounts. According to the representatives of the company, he
withdrew only the interest accrued on the amounts he had deposited. He made withdrawals on a quarterly basis. In
the period from 01.09.2019 to 31.06.2020 he received: in September 2019 in the amount of 2,250,000 rubles; in
January 2020 in the amount of 2,250,000 rubles; in April 2020 in the amount of 2,250,000 rubles; in June 2020 in the
amount of 2,250,000 rubles. He received all the funds at the cash desk of the QBF Group of Companies at 11 Degtyarny
per. in St. Petersburg (Nevskaya Ratusha BC). In June 2021 he received a call from Salimova Zarina and appointed a
meeting. During this period he should make another withdrawal of profit in the form of interest. In June 2021, he met
with Salimova Zarina in a cafe at the address: St. Petersburg, 6th line V.O. (he does not remember the house), at the
meeting she informed him that criminal proceedings had been initiated against the management of the "QBF" group
of companies, that all company accounts had been blocked and he would not be able to receive the funds belonging
to him. Taking into account the fact that the terms for returning his money had expired, there was no doubt that he
had become a victim of swindlers. To date, he has not been returned his money deposited to the "QBF" group of
companies in the amount of 63,768,798 roubles. He considers that the persons acting on behalf of the group of
companies "QBF" initially did not intend to fulfil their obligations to him and acted solely with the purpose to steal his
money by deceiving him. During the period of time from 28.05.2019 to 23.04.2020, the persons acting on behalf of the
"QBF" group of companies stole his money in the total amount of 63,768,798 rubles. He considers the amount of
damage caused to him as significant. He has been explained the right to file a civil action in the criminal case. He
wishes to exercise that right and file a lawsuit. He has been explained the right to familiarise himself with the
conclusions of experts, with the records of interrogations of experts, and also to familiarise himself with the materials
of the criminal case in full or in part. He does not wish to exercise this right. He did not apply to the court with
applications for recovery of funds from the group of companies "QBF;
- (Vol. No. 58, pp. 12 - 17, 106 - 110)

- other documents - documents provided by A.P. Kovin confirming his relationship with QBF Financial Group
- (Vol. No. 58, pp. 20 - 97)
part 4 of article 159 of the Criminal Code of the Russian Federation against Zatsarinsky D.E.:
- another document - a statement by Zatsarinsky D.E., in which he asks to bring to criminal responsibility
persons from among the employees, managers of the financial group "QBF" (Investment Company "QBF"
LLC), who stole his money under the guise of carrying out brokerage activities;
- (Vol. No. 58, l.d. 124)
- Testimony of Zatsarinsky D.E., given by him as a witness and victim,

according to which, approximately in May 2020, he found in the network - Internet information containing information
about the group of companies "QBF". He was interested in the published materials in the part concerning
participation in IPO. IPO is a primary market with subsequent circulation of securities on the stock exchange. Having
made enquiries on the Internet, namely on the website of the group of companies "QBF", as well as in other sources,
he decided to call the head office to consult with a specialist on this issue. He called QBF's general telephone number
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and lef his contacts there. Later, around the end of May 2020, he was contacted by a representative of the QBF group
of companies named Alexey Murashov (he does not remember his mobile phone number), who presented him with
the financial products of the QBF group of companies, the IPO participation system with increased allocation. Alexey
was very convincing and persistent. Allocation is the percentage of securities from the bid that the client can count on
on the day of the IPO sale. Alexey assured him that the company has a long and successful experience of work in
Russia and abroad, has direct access to IPOs, all necessary licences are available, financial advisor Alexey Murashov,
informed him that the reliability of work with the group of companies "QBF" is guaranteed by the legislation of the
Russian Federation, due to the fact that he will cooperate directly with Russian organisations, namely: LLC IC "QBF"
(INN 7733673955) and LLC "Q.broker" (INN 9703003668). Moreover, in open sources of the Internet he has seen
information that LLC IC QBF (INN 7733673955) has 4 licences of the Central Bank of Russia, namely: licence for
brokerage activities No. 045 - 12805 - 100000 dated 24.12.2009,licence for dealer activity No. 045 - 12816010000 dated
24.12.2009, licence for securities management No. 045 - 12828 - 001000 dated 24.12.2009 and licence for depository
activity No. 045 - 14078 - 000100 dated 08.08.2019. On 29.05.2020 he decided to accept the offer of cooperation from
Alexey Murashov, in connection with which he registered his account on the website qbfm.ru, and provided Alexey
with his email address: [email protected], to which a package of documents for him to sign and participate in the IPO
was sent. He remotely signed the documents sent to him by Alexei Murashov by email. In the process of signing the
documents, he was at the address: Moscow, Presnenskaya Naberezhnaya, 8, page 1, tentatively signed the documents
at 15:00 hours, the package of documents sent to his e - mail by Alexei Murashov was formed by: Agreement on
electronic document flow, questionnaire of a registered individual, application for individuals to join the Brokerage
Services Agreement No. FB - 528 of 29.05.2020. He sent the signed documents by e - mail to the address: qbfin.ru.
01.06.2020 at 19:31 hours from his bank account No. 40817810300020006687 opened in the Bank "FFIN BANK", which
is located at: Moscow, Koretny Ryad str. 5/10, bldg. 2, he transferred to the address of LLC IC QBF (INN 7733673955) to
the settlement account No. 40701810700003010998 the funds belonging to him in the amount of 900,000 roubles. The
details for the transfer to QBF LLC were provided to him by Alexei Murashov to the e - mail address [email protected].
Afer he transferred the funds, he informed Alexei Murashov via messenger "WhatsApp" that he had made the transfer,
so that he could confirm the receipt of funds. 01.06.2020 at 19:31 hours from his bank account No.
40817810300020006687 opened in the Bank "FFIN BANK", which is located at: Moscow, Koretny Ryad str. 5/10, bldg. 2,
he transferred funds belonging to him in the amount of 500,000 roubles to the address of QBIF LLC (INN 7733673955)
to settlement account No. 40701810700003010998. The details for the transfer to QBF LLC were provided to him by
Alexei Murashov to the e - mail address [email protected]. Afer he had transferred the funds, he informed Alexei
Murashov via WhatsApp messenger that he had made the transfer, so that he could confirm the receipt of the funds.
Afer depositing the funds into the account of QBF LLC, he began to receive offers from Alexei Murashov's financial
advisor to participate in specific IPOs. In case he agreed to participate in the IPO, Alexey Murashov sent him client
orders prepared for his application to purchase/change/cancel the structured product purchase agreement. He
signed and sent them to the company's e - mail [email protected]. In total, during the whole period of co - operation
with QBIF LLC he signed 3 agreements for the purchase of structured products (participation in IPOs). Afer he
invested in the group of companies of IC QBF LLC, he started receiving reports to his e - mail address in the format of
an "Excel - table", which reflected the list of transactions he had made, the state of his investment portfolio and the
balance of funds. He also checked the values in the reports against the quotes on the stock exchange, so he had no
doubts about the safety of his funds. At the end of May 2021, he learnt from the mass media and official publications
of the Ministry of Internal Affairs of Russia that criminal proceedings had been initiated and key employees of QBF
Group had been arrested for fraud. In this connection, on 20.05.2020, in order to preserve the funds belonging to him
1 400 000 (one million four hundred thousand) rubles, through official communication channels (e - mail
[email protected]), he sent to LLC "IK QBF" a client's order for withdrawal (recall) of funds in the amount of free
balance. The requested funds were received on his brokerage account on 09.02.2021 in the amount of RUB 399,826
and on 02.03.2021 in the amount of RUB 387,722.27, totalling RUB 787,548.27. In order to preserve the funds
belonging to him, around May 2021, he applied for withdrawal of funds for all structural products available to him and
also sent an order to withdraw the free balance from the Master Agreement. Afer submitting the withdrawal request,
a deadline of one month was given for the execution of all orders. To date, RUB 787,548.27 has been returned to him,
the remaining funds have not been returned to him. At present, his demand to return the funds belonging to him has
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not been fulfilled. According to the reports submitted to him, the funds in the amount of 1,400,000 roubles were spent
on the purchase of IPOs. No securities in his name were registered in depositaries, no documents confirming the
purchase of securities were issued. In total, he deposited funds in the amount of 1,400,000 roubles with the company
QBF LLC, which were subsequently stolen from him. He believes that he has suffered material damage in the amount
of 1,400,000 roubles, the amount of the damage caused I assess as significant;
- (Vol. No. 58, pp. 127 - 131, 141 - 144)

- other documents - documents provided by Zatsarinsky D.E. confirming his relationship with QBF Financial
- (Vol. No. 58, pp. 145 - 164)
part 4 of article 159 of the Criminal Code of the Russian Federation against Mudrogin A.V.:
- another document - a statement by A.V. Mudrogin, in which he asks to bring to criminal responsibility persons
- (Vol. No. 59, pp. 7, 11, 115 - 117, 118 - 119)
- Testimony of A.V. Mudrogin, given by him as a witness and victim,

according to which, in 2017, he learnt from the Internet about the possibility of earning money by investing in
financial products of the group of companies "QBF". He was interested in this information, so he called the phone
number indicated on the Internet site of the group of companies "QBF". During the conversation, the manager of the
group of companies "QBF", whose data he does not remember at present, misled him about allegedly high earnings
from investments in the group of companies "QBF", and for obtaining additional information invited him to come to
the office of the group of companies "QBF", 64B, where he was met by the above - mentioned manager of the group of
companies "QBF", who continued to persuade and persuade him in every possible way to deposit money, to mislead
him about the legality of their activities, about the possibility of high earnings from investments and so on. He
believed the words of this manager of "QBF" group of companies and trusted him. 11.11.2017 being in the office of the
group of companies "QBF" at the address: St. Petersburg, Maloohtinsky Ave, 64B with the purpose, as he believed at
that time, of investing money in securities, he concluded the Agreement on rendering services of direct access to
international stock markets No. 4170 - 17/ISR dated 11.11.2017 with "QCCI LTD" ("QCCI LTD"), and also entered into a
"Trustee Services Agreement" with "QBIF" LLC pursuant to the Direct Access to International Stock Markets Services
Agreement No. 4170 - 17/ISR dated 11.11.2017. Having trusted the manager of the group of companies "QBF" and
being in a state of delusion on 11.11.2017 being in the office of the group of companies "QBF" at the address: St.
Petersburg, Maloohtinsky prospect, 64B, in the presence of the manager of the group of companies "QBF", he
deposited his own funds in the amount of 593 000 rubles in the cash desk of the group of companies "QBF". The
cashier of the group of companies "QBF" whose data he does not know took the money from him. In order to mislead
him and give the appearance of legitimate activity, the cashier of the group of companies "QBF" gave him a receipt to
the receipt order No. b/n dated 11.11.2017 in the amount of 593,000 rubles. About one month afer that he received a
call from the manager of the group of companies "QBF" Efremtsev Artem, who informed him that he was assigned to
him (Mudrogin A.V.) and was his personal financial adviser from the group of companies "QBF". Around February 2020,
he wanted to check the mechanism of withdrawal of funds from the group of companies "QBF", for which he applied
for withdrawal of 40,000 rubles. Approximately one month later, in March 2020, Efremtsev A. invited him to his office
to give him the funds. In March 2020, the exact date he does not remember, in the office of the "QBF" group of
companies at the address: St. Petersburg, Degtyarny per. 11 lit. B, room 1 - H, Efremtsev A. gave him 40,000 rubles in
hand to convince him of the legality and profitability of investing, thereby further misleading him. On 25.06.2020,
being in a state of delusion, in the office of the group of companies "QBF" at the address: St. Petersburg, Degtyarny
per. 11 lit. B, room 1 - N, in the presence of Efremtsev A., he deposited his own money in the amount of 350 000 rubles
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in the cash desk of the group of companies "QBF". The cashier of the "QBF" group of companies whose data he does
not know took the money from him. In order to mislead him and to make what was happening look like a legal
activity, the cashier of the group of companies "QBF" gave him a receipt to the receipt order No. b/n dated 25.06.2020
in the amount of 350 000 rubles. In January 2021, he received a call from the manager of the group of companies
"QBF" Tetyuev Sergey, who informed him that he was his new financial advisor from the group of companies "QBF".
Tetyuev S. also misled him about the activities of the group of companies "QBF", about his investments, that
everything was in order with his money and that his invested money was yielding a return. In May 2021, he saw
information in the media that criminal cases had been opened and investigations were underway against employees
and managers of the QBF Group of Companies. He immediately contacted Tetyuev S. about what was going on, to
which Tetyuev S. began to deceive him that the criminal case was initiated against some other company "QBF". At the
end of May 2021, he approached Tetyuev S. about a full refund of his money, to which Tetyuev S. demanded that he
provide a large number of documents allegedly necessary for the refund. He collected these documents for about one
month, afer which he provided them to Tetyuev S., but the money was not returned to him. At that moment he
realised that he had become a victim of fraudsters and had simply been deceived in order to steal his money. To date,
he has not been returned his money deposited in the cash desk of the QBF group of companies, as he naively believed
at the time for investment, in the amount of 903,000 roubles. He believes that the persons acting on behalf of the
group of companies "QBF" initially did not intend to fulfil their obligations to him and acted solely for the purpose of
stealing his money by deceiving him. In the period from 11.11.2017 to 25.06.2020, the persons acting on behalf of the
"QBF" group of companies stole money belonging to him in the total amount of 903,000 rubles. He considers the
amount of damage caused to him as significant. He has been explained the right to file a civil action in the criminal
case. He wishes to exercise that right and file a lawsuit. He has been given the right to familiarise himself with the
composition of the investigative teams, with the decisions to order forensic examinations, with the conclusions of
experts, with the transcripts of expert interrogations and with the materials of the criminal case in full or in part. He
does not wish to exercise this right. He did not apply to the court with applications for recovery of money from the
"QBF" group of companies;
- (Vol. No. 59, pp. 12 - 14, 140 - 143)

- other documents - documents provided by A.V. Mudrogin confirming his relationship with QBF Financial
- (Vol. No. 59, pp. 16 - 114, 120 - 135),
part 4 of article 159 of the Criminal Code of the Russian Federation against Ruchiev A.V.:
- another document - a statement by A.V. Ruchiev, in which he asks to bring to criminal responsibility persons
- (Vol. No. 59, l.d. 158)
- A.V. Rucheev's testimony as a witness and victim,

according to which, since 2019 he has contractual relations with Freedom Finance. He has a brokerage services
agreement with this company, according to which "Freedom Finance" carries out operations with securities within
the framework of existing contractual relations. In 2020, the employees of the organisation where he worked received
a call from a representative of the investment company "QBF" (QBF Investment Company LLC) and offered similar
services from their organisation, but on more favourable terms. He explains that this company is widely known
among persons engaged in investment activities, everyone calls this company "QBF" both among themselves and in
various chat rooms. He considered this option, but in order to decide whether to start a relationship with this
company, his condition was to meet with its direct manager. In May 2020, in agreement with the company's
employees, he came to the office of QQO Investment Company QBF, located at the address: Moscow, Presnenskaya
Naberezhnaya, 9th floor, Moscow City complex. An employee of QQB Investment Company LLC named Stella
(Ermolenko Stella Rochelevna, phone number 8 - 987 - 835 - 44 - 44) organised his entry to the company's office. Stella
escorted him to the office to the head of the organisation, who turned out to be Roman Valeryevich Shpakov (the
978
phone number he used to communicate with him was 8 - 905 - 735 - 55 - 88). Shpakov introduced himself as the head
and principal owner of QBF. During the conversation, Shpakov explained that QBF IK LLC was engaged in absolutely
legal "white" activities. Shpakov presented him the company's financial products and explained that QBIF LLC
provides, among other things, brokerage services. The company has two main options for working with securities on
the stock markets, namely: one option - conclusion of trust management agreements, and the second option -
concerning participation in IPO, signing an accession agreement, according to which the client himself can choose
which agreements to conclude and which securities to purchase. He had a large amount of money that he wanted to
invest in securities. The first option with signing a trust management agreement was not suitable for him, as in this
option the broker decides which securities to purchase, and they are not placed at the client's disposal, but are
included in the general pool on the brokerage account of the company. Under the second option, the purchase of
securities is controlled by the client, at the client's request, and the purchased securities are credited to a
personalised account in a depository, and they must be registered in the client's name, according to the law. Explains
more: IPO (Initial Public Offering) or Initial Public Offering is the first public sale of shares of a company (joint stock
company) to an unlimited number of persons through the stock exchange. There is a public calendar of these
offerings, approximately one year in advance, and, according to this calendar, it is possible to choose securities of
interest. Within the framework of the agreement concluded between the Client and the Broker, the Client can send a
request to buy shares of a certain company. The Broker, in its turn, sends the order to the underwriter, who conducts
the placement of this company, and on the day of trading the Client is notified by what percentage the order is
executed, i.e. the Client becomes the owner of the shares a few hours before the public offering. Further, the Broker's
duty is to transfer these purchased securities to the Client's brokerage account, whereby the securities are transferred
from the Broker's own brokerage account held with the Depository to the Client's personalised account opened with
the same Depository on the basis of internal payment documents drawn up by the Broker. Upon transfer, the
Depository shall register the securities in the Client's name. R.V. Shpakov assured him that the activities of the
company LLC IC QBF are legal, the company has the necessary licences of the Central Bank of the Russian Federation,
namely, the licence of a professional participant of the securities market for securities management activities No. 045
- 12828 - 001000 dated 24.12.2009 and brokerage services activities on the basis of the licence of a professional
participant of the securities market for brokerage activities No. 045 - 12805 - 100000 dated 24.12.2009. During their
(A.V. Rucheev and R.V. Shpakov) communication, he (R.V. Shpakov) emphasised that the company's work in
accordance with Russian law and the existence of licences from the Central Bank of the Russian Federation
guaranteed absolute reliability. Shpakov also explained to him that the company has a direct access to IPO, has been
working on the Russian and foreign market for a long time, and the conditions of work with LLC "IC QBF" for clients
are more favourable than with "Freedom Finance", namely less commission for the client, as well as increased
allocation, compared to "Freedom Finance" at that time. Allocation is, simply put, the percentage of fulfilment of a
bid to purchase securities at their initial offering. Demand in such cases always exceeds supply, so the bids to
purchase securities at their initial offering are not fully satisfied. While talking to Shpakov, he asked him a number of
questions concerning the company's work: he was interested in the number of clients, which directly indicates the
company's reliability and credibility, as well as other aspects of the company's business. Shpakov and QBF staff
showed him their information base on the computer, according to which the number of clients exceeded 1,000; he
was introduced to the company's financial analysts. In general, afer talking to Shlakov and visiting the office of QBIF
LLC, he got the impression that QBIF LLC was a truly legitimate and reliable company. Afer visiting the company's
office, he checked the information provided by Shpakov, namely the existence of licences of QBIF LLC issued by the
Central Bank of Russia: it turned out that the information was true and the company actually had the above licences.
In addition, Shpakov explained during the interview that QBIF LLC was working with the National Settlement
Depository. He checked this information as well, and it also turned out to be true. The said depository confirmed the
existence of contractual relations with the company. Besides, he studied all the news background about the company
QBIF LLC in the public sources of information available to him, and it seemed very favourable: favourable conditions
for clients, large number of clients, impressive office, absence of negative feedback from clients. Taking into account
all of the above, he decided to conclude an agreement with QBIF LLC. About a week and a half afer he met Shpakov
and visited the office of QBIF LLC, he decided to sign an agreement with QBIF LLC to carry out brokerage activities. He
called Roman Shpakov and informed him of his intention to start co - operation. An employee of his organisation
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contacted Stella Ermolenko, a representative of QBIF LLC, regarding technical issues of concluding contracts; she was
appointed as his personal financial consultant. The employees of IC QBIF LLC sent to the specially created e - mail
[email protected] the contract - Agreement on rendering brokerage services (contract of adhesion) of Limited
Liability Company Investment Company QBIF LLC dated 15.05.2020, Regulations on rendering brokerage services of IC
QBIF LLC (general, similar to the one posted on the website of the organisation), as well as other documents. On
20.05.2020 he, being in the office of JSC GC Osnova at the address: Moscow, 132 Bolshaya Semyonovskaya str. 7,
signed the following documents: - Application on joining for individuals dated 20.05.2020 (accession to the Agreement
on rendering brokerage services of IC QBF LLC with all Appendices thereto); - An application form of a registered
individual; - Application for complex service. On the same day, 20.05.2020, an employee of JSC GC Osnova took the
above documents signed by him to the office of IC QB&EF LLC, afer which he returned with one copy of the
Application for Adhesion with an official mark of the employee of IC QB&EF LLC Koloskov A.S. on acceptance of the
Application, which indicated the number FB - 502 of 20.05.2020 assigned to the Agreement. As part of the execution of
the said Agreement, he made 4 transfers of funds from account No. 40818810538048350189, opened in his name in
the branch of PJSC "Sberbank" at the address: Moscow, Romanov pereulok, d. 4 (branch No. 9038/01872), to the
account No. 40701810700003010998 of LLC IC QBF (INN 7733673955), beneficiary bank: NSD, Moscow: 1) on
02.06.2020 in the amount of 100,000,000 (one hundred million) roubles; 2) on 08.06.2020 in the amount of 50,000,000
(fify million) roubles; 3) on 16.06.2020 in the amount of 25,000,000 (twenty - five million) roubles; 4) on 29.06.2020 in
the amount of 20,000,000 (twenty million) roubles. In total, he transferred 195,000,000 (one hundred and ninety - five
million) roubles to the account of IK QBF LLC under the concluded agreement on provision of brokerage services. This
amount includes the Security Payment. Thereafer, within the framework of the instructions given by him, LLC IC QBF
carried out the purchase of securities (ostensibly carried out; as he later learnt, no securities were registered in his
name and therefore not purchased). The e - mail [email protected] received monthly reports from QBIF Ltd. on
transactions and account status (Report on the status of the client's accounts for securities transactions and
transactions related to them, as well as for futures transactions and operations). Approximately once a quarter, he
would call Shlakov and drive to the office of QBIF LLC to make sure that the company was stable. Shpakov assured
him that there was nothing to worry about, everything in the company was going well according to plan. He trusted
his words, as well as the reports sent to him. However, then came the information that everything was not going
smoothly in QBIF Ltd. He called Roman Shpakov and asked him questions about the company's activities, to which
Shpakov assured him that everything was fine and that the rumours about problems at QBIF LLC and possible
revocation of the licence were only rumours. Despite Shpakov's assurances, he prepared and sent two applications for
withdrawal of funds, namely: 06.06.2021 - client's order for withdrawal of 55,000,000 rubles, and 02 .07. 2021
- client's order for withdrawal of 50,000,000 rubles. According to the reports of IC QBF LLC, the total amount of RUB
105,000,000 was in the form of free cash; the rest of the invested money was placed in securities, the procedure for
receiving cash from these securities provides for their sale, which was not planned by the client at that time.
According to the law, the application should be executed by the Broker within two weeks, but the applications were
not executed, no money was transferred to him for withdrawal according to these applications. Then he called
Shpakov and during the telephone conversation asked him to transfer his securities from his brokerage account in the
National Settlement Depository to his brokerage account in Sberbank PJSC. Shpakov replied that there were no
securities on his brokerage account in the depository, as the scheme of activity of LLC IC QBF was such that the
company itself did not purchase securities and did not place them on clients' brokerage accounts, but transferred the
funds sent by the client to LLC IC QBF within the framework of concluded contracts to the account of a non - resident
of the Russian Federation. Shpakov did not explain to him the name of the company or its location. He (Shpakov)
assured him (Rucheev) that he would return all the money to him and he could not worry about anything. This
"scheme of activity" voiced by Shpakov does not comply with Russian law and is therefore criminal. If he had known
earlier about this "scheme of operation" of QBIF LLC, he would never have placed his funds through this company.
Afer talking to Shpakov, he checked his words: indeed, there were no securities on his account at the National
Settlement Depository, nor on the account of QBIF LLC. On the basis of this information it turns out that the reports
sent to him by IC QBF LLC about the state of his account and information about the placement of securities were
falsified, and the money that he sent to IC QBF LLC to carry out brokerage activities under the concluded agreement
was stolen by Roman Valeryevich Shpakov and employees of IC QBF LLC, i.e. fraudulent actions were committed
980
against him. Afer that he repeatedly called Shpakov R.V. about the return of the money belonging to him. Roman
explained to him that he had no assets lef on the territory of the Russian Federation, but that he had assets abroad
and that he would find an opportunity to settle accounts with him at the expense of the funds abroad. Thus, he
transferred funds totalling RUB 195,000,000 to LLC IK QBF. On 19.03.2021 he submitted an order to withdraw
(withdraw) funds in the amount of 25,000,000 (twenty - five million) roubles. In pursuance of this order, on 23.03.2021,
LLC IK QBF transferred funds in the amount of 25,000,000 (twenty - five million) rubles to his account No.
40818810538048350189 opened with PJSC Sberbank. According to the latest official report on the status of its
accounts provided by IC QBF LLC, as of 12.07.2021, the market value of its portfolio (includes unallocated cash as well
as purchased securities) is 268,546,723.67 rubles;
- (Vol. No. 59, pp. 159 - 166, Vol. No. 61, pp. 43 - 49)
- other documents - documents provided by A.V. Ruchiev confirming his relationship with QBF Financial Group
- (vol. No. 59, pp. 168 - 246, vol. No. 60, pp. 1 - 16, 19 - 240, vol. No. 61, pp. 1 - 37)
part 4 of article 159 of the Criminal Code of the Russian Federation against Donskoy I.V.:
- another document - a statement by Donskoy I.V., in which he asks to bring to criminal responsibility persons
- (Vol. No. 61, pp. 74, 75)
- Testimony of I.V. Donskoy, given by him as a witness and victim,

according to which, in early 2020, he learnt about the company "QBF" from his acquaintance Boris Anatolievich
Egudkin. He (B.A. Yegudkin) told about his personal positive experience of investing available funds in the company to
carry out financial transactions on the international market. He (I.V. Donskoy) was interested in this information and
afer some time, on the recommendation of B.A. Yegudkin, he was contacted by the representative of the company
Alexander Moroz. He invited him to the office of the company "QBF", located at the address: Degtyarny per. 11 lit. B,
pom.1 - H, BC "Nevskaya Ratusha". On 08.07.2020 their (Moroz and Donskoy I.V.) first meeting took place. In the office
of the company he was shown colourful presentations and was promised to receive high returns by investing available
funds, both in rubles and in currency in the company "QBF" for financial operations on the international market. He
was immediately warned that rubles would be converted into currency, as the company operates on foreign markets.
He was interested in the offer. Having previously studied information about QBF in open sources of the Internet, he
found many positive reviews and found the company attractive enough to try to work with it. Availability of licences of
the Central Bank of the Russian Federation was one of the most important moments that determined the reliability of
the company. On 08.07.2020, under the pretext of investing his funds in securities with high yield on behalf of a non -
resident "White Lake Management Ltd" ("White Lake Management Ltd"), he entered into Trust Management
Agreement No. D - 101936 - G dated 08.07.2020, as well as Service Agreement 101936 - 09 dated 08.07.2020 on behalf
of LLC "VL Consulting". Afer the conclusion of the contract, Alexander Moroz became his financial advisor. At the same
time, he handed over funds in the amount of USD 20,000, which at the exchange rate of the Central Bank of Russia as
of 08.07.2020 amounted to RUB 1,443,438 at the QBF office. The funds were handed over in cash in the presence of
Moroz A. to the cashier of the group of companies, about which a receipt order was received. On 09.07.2021 he
(Donskoy I.V.) notified Alexander Moroz of his desire to terminate the contract and take back the funds he had
invested. Alexander replied that at that time withdrawal of funds was a very bad decision due to the decline in the
market value of shares, that at that time, he would lose a lot of money when selling off his portfolio of assets. He
(Moroz A.) suggested to wait two months until more favourable conditions. His speech sounded convincing and he
agreed to the proposal. Afer some time, the unexpected happened, Moroz A. blocked his phone number for unknown
reasons and stopped answering his calls. He would like to note that starting from July 2020, his personal email started
981
to receive reports on transactions on the purchase of securities on his account. He cannot confirm or deny the
accuracy of these reports. In August 2021, he contacted Dmitry Vladimirovich Moskaluk, who had previously been
Oleksandr Moroz's superior. He explained to him the current situation and expressed his dissatisfaction regarding his
(Donskoy I.V.) strange communication with Moroz A. Then Moskalyuk D. explained that there were problems with the
withdrawal of funds and the return would be made by purchasing bonds with promissory notes. He promised to give
him more detailed information later, approximately by the end of September 2021. Afer this conversation Moskalyuk
D. as well as Moroz A. stopped answering his calls. Later, he learnt from the media that the management of the
company "QBF" was accused of major fraud and creating a pyramid scheme. Taking into account the fact that the
deadline for returning his money expired, there was no doubt that he had become a victim of fraudsters. To date, his
money deposited with the QBF group of companies in the amount of 1,443,438 roubles has not been returned to him.
He considers that the persons acting on behalf of the group of companies "QBF" initially did not intend to fulfil their
obligations to him and acted solely for the purpose of stealing his money by deceiving him. On 08.07.2020 the persons
acting on behalf of the "QBF" group of companies stole the money belonging to him in the total amount of 1 443 438
rubles. He considers the amount of damage caused to him as significant. He has been explained the right to file a civil
action in the criminal case. He wishes to exercise this right and file a lawsuit. He has been explained the right to
familiarise himself with the composition of the investigative teams, with the decisions on the appointment of forensic
- (Vol. No. 61, pp. 78 - 80, 122 - 125)

- other documents - documents provided by Donskiy I.V. confirming his relationship with QBF Financial Group
- (Vol. No. 61, pp. 83 - 115)
part 4 of article 159 of the Criminal Code of the Russian Federation against Nosenko M.N.:
- another document - a statement by Nosenko M.N., in which he asks to bring to criminal responsibility
- (Vol. No. 61, l.d. 138)
- Testimony of Nosenko M.N., given by him as a witness and victim,

according to which, in April 2020, he found in the Internet information about the group of companies "QBF". The new
and attractive product offered by the representatives of the group of companies QBF was "Participation in IRO". He
was interested in the published materials, as far as participation in IPO was concerned. IPO is the entry of private
companies to the stock exchange by initial public offering (sale) of their securities. Having made enquiries on the
Internet, namely through a telegram channel, he received the contact details of the financial adviser Alexey Murashev
(tel. 8 - 903 - 100 - 36 - 31). Afer some time, approximately in May 2020, he called the financial advisor of QBF group of
companies Alexey Murashev, with whom he had a conversation of introductory advertising character, during which
Alexey Murashev assured him that the company "QBF" has a long and successful experience of work in Russia and
abroad, has a direct access to IPO, all necessary licences are available, the financial advisor Alexey Murashev informed
him that the reliability of work with the group of companies "QBF" is guaranteed by the legislation of the Russian
Federation, in view of the fact that he will cooperate directly with the Russian Federation. Moreover, in open sources
of the Internet he saw information that LLC "IK QBF" has 4 licences of the Central Bank of Russia, namely: the licence
for brokerage activities № 045 - 12805 - 100000 dated 24.12.12.2009, licence for dealer activity No. 045 - 12816010000
dated 24.12.2009, licence for securities management No. 045 - 12828 - 001000 dated 24.12.2009 and licence for
depository activity No. 045 - 14078 - 000100 dated 08.08.2019. On 08.06.2020 he decided to agree to Alexey's proposal
982
and sent him his e - mail address: ln20mn - @mail.ru, as well as copies of his documents. Afer he agreed to
participate in the cooperation, on 08.06.2020, being in contact with the financial advisor, he signed a brokerage
services agreement (accession agreement) with IK QBEEF LLC, an application for individuals to the Brokerage Services
Agreement No. FB - 547 dated 08.06.2020 and to the Depository Agreement b/n, a notice of opening a client account
and other documents. On the same day, he sent the documents via courier delivery service to the address of the office
of QBF Group of Companies located at: Moscow, Presnenskaya Naberezhnaya, 8, p. 1, for the purpose of entering into
futures transactions. 1, for the purpose of entering into fixed - term transactions for the purchase of financial products
(option contracts). Afer that, between 17.06.2020 and 08.07.2020, he transferred funds from his current account No.
40817810306180024189 opened with JSC Alfa - Bank, located at the address: Moscow, Bagrationovsky proezd, ul. 3, to
IC QBF LLC's settlement account No. 40701810700003010998 opened with NSD, located at 12 Spartakovskaya Street,
Moscow, under Brokerage Services Agreement No. FB - 547 dated 08.06.2020, namely: 17.06.2020 in the amount of
RUB 2,800,000; 08.07.2020 in the amount of RUB 3,400,000, totalling RUB 6,200,000. Afer he (Nosenko M.N.)
transferred the funds, he sent the payment order to Alexei on "WhatsApp", about two days later, he (Alexei) confirmed
that the funds had been received. Later, afer the funds were deposited to the account of IK QBF LLC, he (Nosenko
M.N.) started receiving offers from Alexey Murashev's financial advisor to participate in specific IPOs. In case he agreed
to participate in the IPO, Alexey Murashev sent him the client's orders prepared for his request to
purchase/change/cancel the structured product purchase agreement. During the entire period of co - operation with
IK QBF LLC, he signed a total of 52 agreements for the purchase of structured products (participation in IPOs). Afer he
invested in the group of companies of IK QBF LLC, he started to receive reports to his e - mail address, which reflected
the list of his transactions, the state of his investment portfolio and cash balance. He also checked the values in the
reports against the quotations on the stock exchange, so he had no doubts about the safety of his funds. Around May
2021, he learnt from the mass media and official publications of the Ministry of Internal Affairs of Russia that criminal
proceedings had been initiated and key employees of QBF Group had been arrested for fraud. In order to save the
money belonging to him, on 06.06.2021 he sent an order for withdrawal of funds on the free balance on the brokerage
account in the amount of 2 900 000 rubles and part of closing of options, also on 15.06.2021 he sent orders for closing
of all available options, however, no proceeds were made to his current account, afer that, on 09.07.2021 he again
submitted an order for closing of all available options, however, no proceeds were made to his current account until
now. The representatives of QBF Group are unable to explain the situation in substance. At present, his demand for
the return of the money belonging to him has not been fulfilled. In total, he transferred to the "QBF" group of
companies money in the amount of 6,200,000 roubles, which has not been returned to him in full or in part. He
believes that an offence has been committed against him, namely the thef of his money by deception and breach of
trust in the amount of 6,200,000 roubles. He considers the amount of damage caused to him to be significant;
- (Vol. No. 61, pp. 141 - 145, 155 - 158)

- other documents - documents provided by Nosenko M.N. confirming his relationship with QBF Financial
- (Vol. No. 61, pp. 159 - 236)
part 4 of article 159 of the Criminal Code of the Russian Federation against Mitroshin N.G.:
- - another document - a statement by N.G. Mitroshin, in which he asks to bring to criminal responsibility
persons from among the employees, managers of the financial group "QBF" (LLC "Investment Company "
- (Vol. No. 62, l.d. 8)
- Testimony of N.G. Mitroshin, given by him as a witness and victim

, according to which, from his acquaintances he learnt about the company "QBF" (LLC "IC QBF") and attended in May
2020 the presentation of this company at the address: Moscow Presnenskaya naberezhnaya, 8, p.1, which was held by
983
Javad Isaev and Murashov Alexey. Afer the presentation, in May 2020, he researched information on the Internet
regarding the group of companies of QBIF LLC. He was interested in the published materials regarding participation in
the IPO. He found out that IPO is a primary market with subsequent circulation of securities on the stock exchange.
Having made enquiries on the Internet, namely on the website of the group of companies LLC "IC QBF", as well as in
other sources, he decided to call the head office and consult. He called the general telephone number of the company
IK QBF Ltd. and lef his contacts there. Later, around 09.07.2020, he was contacted by a manager of the group of
companies LLC "IC QBF" named Murashov Alexey (tel. 8 - 903 - 100 - 36 - 31), who presented him the financial products
of the group of companies LLC "IC QBF", the system of participation in an IPO with increased allocation, Murashov
Alexey was very persuasive and persistent. Allocation is the percentage of securities from the bid that the client can
count on on the day of the IPO sale. Murashov Aleksey assured him that the company has a long and successful
experience of work in Russia and abroad, has direct access to IPO, all necessary licences are available, financial
advisor Murashev Aleksey, informed him that the reliability of work with the group of company LLC "IC QBF" is
guaranteed by the legislation of the Russian Federation, due to the fact that he will cooperate directly with Russian
organisations, namely: LLC "IC "QBF" (INN 7733673955) and LLC "Q.broker" (INN 9703003668). Moreover, in open
sources of the Internet he saw information that LLC "IC QBF" (INN 7733673955) has 4 licences of the Central Bank of
Russia, namely: licence for brokerage activities No. 045 - 12805 - 100000 dated 24.12.12.2009, licence for dealer
activity No. 045 - 12816010000 dated 24.12.2009, licence for securities management No. 045 - 12828 - 001000 dated
24.12.2009 and licence for depository activity No. 045 - 14078 - 000100 dated 08.08.2019. On 10.07.2020 he decided to
agree to Murashev Alexey's proposal, in connection with which he registered an account on the website qbfln.ru, and
also provided Alexey with his email address: [email protected], to which a package of documents was sent for him to
study and sign, ensuring his participation in the IPO. Having studied the documents provided to him, he signed them
remotely, having previously agreed to the electronic document flow. At the time of signing the documents, he was at
the address: Moscow, 3 Paveletsky Proezd 3, 3, sq. 43, tentatively signed the documents at 12:00. The list of
documents sent to him by Murashov Alexey to his e - mail is: Agreement on electronic document flow, questionnaire
of a registered individual, application for individuals to join the Brokerage Services Agreement No. FB - 728 of
10.07.2020. He sent the signed documents by e - mail to the address: qbfln.ru. On 06.08.2020 at 15:03, he transferred
from his bank account No. 40817810716254002101 opened with Branch No. 7701 of PJSC VTB Bank, located at 5
Marxistskaya Street, page 1, Moscow, to the address of LLC IK QBF (INN 7733673955) to the settlement account No.
40701810201400000052 in the amount of RUB 4,000,000. The details for the transfer to QBF IK LLC were provided to
him by Murashov Alexei to the e - mail address: [email protected]. Afer he had transferred the funds, he informed
Alexei Murashov via WhatsApp messenger that he had made the transfer in order to confirm it. Later, he began to
receive offers from Alexey Murashev's financial advisor to participate in specific IROs. If he agreed to participate in an
IPO, Alexey Murashev would send him client orders for the purchase/amendment/cancellation of the structured
product purchase agreement executed in accordance with his application. He signed and sent them to the company's
e - mail [email protected]. In total, during the whole period of cooperation with QBIF LLC he signed 50 agreements for
the purchase of structured products (participation in IPOs).Afer he invested in the group of companies of QBIF LLC, he
began to receive reports to his e - mail address in the format of an Excel - table, which reflected the list of transactions
made by me, the state of the investment portfolio and the balance of funds. He also checked the values in the reports
with the quotes on the stock exchange, so he had no doubts about the safety of his funds. At the end of May 2021, he
learned from the mass media and official publications of the Russian Ministry of Internal Affairs that criminal
proceedings had been initiated and key employees of the group of companies of QBIF LLC had been arrested for
fraud. In order to preserve the funds belonging to him, on or about 21 June 2021, he submitted withdrawal requests
for all of his structured products and also sent an order to withdraw the free balance from the Master Agreement. Afer
submitting the withdrawal request, he was given a deadline of one month to execute all the orders, however, to date
he has not been able to withdraw the funds invested in the group of companies of QBIF LLC, even partially. Till now
the orders have not been executed, the funds have not been returned. At present, his demand to return the funds
belonging to him has not been fulfilled. According to the reports submitted to him, the funds in the amount of
4,000,000 roubles were spent on the purchase of IPOs. However, these funds have not been returned to him. No
securities in his name have been registered in depositaries, and no documents confirming the purchase of securities
have been issued;
984
- (Vol. No. 62, pp. 9 - 13, 23 - 26)
- other documents - documents provided by Mitroshin N.G. confirming his relationship with QBF Financial
- (Vol. No. 62, pp. 27 - 173)
part 4 of article 159 of the Criminal Code of the Russian Federation against Batuev A.A.:
- another document - a statement by A.A. Batuev, in which he asks to bring to criminal responsibility persons
- (Vol. No. 62, l.d. 189)
- A. A. Batuev's Testimony as a witness and victim,

according to which, approximately at the end of July 2020, he found information about the group of companies
"QBF" in the Internet. He was interested in the published materials in the part concerning participation in IPO. He
knows that IPO is a primary market with subsequent circulation of securities on the stock exchange. Having studied
all the available information concerning the activity of the group of companies "QBF" in the network - Internet,
namely on the site of the group of companies "QBF", and also in other sources, afer that he lef his contact
information on the site of "QBF". Some time later he received a call from Natalia Chernysheva (8 - 921 - 858 - 16 - 58, 8 -
921 - 873 - 50 - 24), who introduced herself as the manager of the group of companies "QBF" and presented him the
financial products of the group of companies "QBF", the system of participation in IPO with increased allocation, and
Natalia Chernysheva was very persuasive and persistent. He learnt that allocation is the percentage of securities from
the bid that a client can expect to receive on the day of the IPO sale. Natalia Chernysheva assured him that the
company has a long and successful experience in Russia and abroad, has direct access to IPOs, all necessary licences
are available, the financial advisor Natalia Chernysheva, informed him that the reliability of work with the group of
companies "QBF" is guaranteed by the legislation of the Russian Federation, due to the fact that he will cooperate
directly with Russian organisations, namely: LLC IC "QBF" (INN 7733673955) and LLC "Q.Broker" (INN 9703003668).
Moreover, in open sources of the Internet he saw information that LLC IC QBF (INN 7733673955) has 4 licences of the
Central Bank of Russia, namely: licence for brokerage activities No. 045 - 12805 - 100000 dated 24.12.12.2009, licence
for dealer activity No. 045 - 12816010000 dated 24.12.2009, licence for securities management No. 045 - 12828 -
001000 dated 24.12.2009 and licence for depository activity No. 045 - 14078 - 000100 dated 08.08.2019. On 03.08.2020
he decided to agree to Natalia Chernysheva's proposal, in this regard, he registered an account on the website:
qbfm.ru, and also provided Natalia Chernysheva with his e - mail address: [email protected]. to which documents
for signing and participation in the IPO were sent. Afer that, he remotely signed the documents sent to his e - mail by
Natalia Chernysheva using an electronic signature. When signing the documents, he was at the address: Moscow,
Energeticheskaya Street, 16, bldg. 1, sq. 13, tentatively signed the documents at 12 o'clock 00 minutes, namely:
application for brokerage services, agreement on electronic document flow, questionnaire of a registered individual,
application on joining for individuals to the Brokerage Services Agreement No. BO - F - N - 0 - 00102 dated 03.08.2020.
He also wants to clarify that the details for the transfer of funds to the account of the company LLC IC QBF were
provided to him by Natalia Chernysheva. Later, in the period from 04.08.2020 to 21.10.2020, he made transfers of
funds from his current account No. 40817810200000367214, opened in JSC "Tinkoff Bank", located at the following
address: Moscow, 2nd Khutorskaya St., 38 "A", building 26, to QBF LLC's settlement account No.
40701810700003010998 opened with NSD, located at 12 Spartakovskaya Street, Moscow, under Brokerage Services
Agreement No. BO - F - N - 0 - 00102 dated 03.08.2020, namely: RUB 100,000 on 04.08.2020; RUB 500,000 on
04.08.2020; RUB 300,000 on 12.08.2020; RUB 400,000 on 12.08.2020 in the amount of RUB 400,000; 17.08.2020 in the
08.09.2020 in the amount of RUB 600,000; 10.09.2020 in the amount of RUB 500,000; 10.09.2020 in the amount of RUB
520,000; 11.09.2020 in the amount of RUB 400,000; 21.09.2020 in the amount of RUB 400,000; 29.09.2020 in the
amount of RUB 150,000; 21.10.2020 in the amount of RUB 500,000, totalling RUB 5,250,000. Afer the first deposit
of funds to the account of QBIF LLC, he began to receive offers from Natalia Chernysheva to participate in specific
985
IPOs. In case he agreed to participate in the IPO, Natalia Chernysheva sent him client orders prepared for his
application to purchase/change/cancel the structured product purchase agreement. He signed and sent them to the
company's e - mail [email protected]. In total, during the whole period of co - operation with QBIF LLC, he signed 50
agreements for the purchase of structured products (participation in IPOs). Afer he invested in the group of
companies of IK QBF LLC, he started receiving reports to his e - mail address, which reflected the list of transactions he
had made, the state of his investment portfolio and the balance of funds. He also checked the values in the reports
with the quotations on the stock exchange, so he had no doubts about the safety of his funds. At the end of April 2021,
he submitted withdrawal requests for all of his structured products and also sent an order to withdraw the free
balance from the master agreement. The deadline for execution of all the orders was 08.07.2021. Till date he has not
been able to withdraw the funds invested in QBF Group in full. On 09.06.2022 he was returned the funds in the
amount of 121,863.10 rubles under the Brokerage Services Agreement No. BO - F - N - 0 - 00102 dated 03.08.2020. At
present, his demand to return the funds belonging to him in full has not been fulfilled. The employees of QBF Group of
Companies cannot explain the current situation in essence. At the end of May 2021 he learnt from mass media and
official publications of the Ministry of Internal Affairs of Russia that criminal proceedings have been initiated and key
employees of the "QBF" group of companies have been arrested on the fact of fraud. No securities in his name have
been registered in depositaries, no documents confirming the purchase of securities have been issued to him. Thus,
he believes that an offence, namely fraud, has been committed against him. In addition, the company cannot provide
evidence of real participation in the IPO. In total, he made a cash deposit of 5,250,000 roubles to the company QBF
LLC, which was subsequently stolen from him. He believes that he has suffered material damage in the amount of
5,250,000 roubles, the amount of damage caused to him I estimate as significant;
- (Vol. No. 62, pp. 192 - 198, 208 - 211)

- other documents - documents provided by A.A. Batuev confirming his relationship with QBF Financial Group
- (Vol. No. 63, pp. 1 - 45)
part 4 of article 159 of the Criminal Code of the Russian Federation against Drapeza N.V.:
- another document - a statement by N.V. Drapesa, in which he asks to bring to criminal responsibility persons
- (Vol. No. 63, pp. 60 - 61, 168)
- The testimony of N.V. Drapesa, given by him as a witness and victim,

according to which, approximately in September 2020, on his phone number 8 - 914 - 706 - 20 - 49, which is registered
in his name, called Builov Nikita Olegovich, from the number 89099356990, 89639900700, who introduced himself as a
senior financial advisor of LLC IC QBF. He was not previously acquainted with this citizen, during the conversation he
introduced himself as a former employee of IK Friedem Finens LLC, where he had a brokerage portfolio. Builov N.O.
offered him participation in initial public offerings on the American stock market. The initial payment was about
4,000,000 roubles. During the conversation he (N.O. Builov) demonstrated high competence in the matter, in order to
demonstrate the success of the work of IK QBF LLC, he (N.O. Builov) sent a summary table with the results of the
proposed product to his (N.V. Drapesa) e - mail [email protected] from the e - mail address:
[email protected]. He was interested in the proposed results and therefore decided to conclude a contract for
brokerage services in the amount of 4,000,000 roubles. The contract was signed and sent by e - mail. He did not see
Builov N.O. personally. He (N.O. Builov) offered to meet him in Moscow, but he had no opportunity to meet him. The
funds were to be transferred not directly to IK QBF LLC, but to the account of NSD, the national settlement depository,
which has the status of a neutral depository of the Russian Federation. This added confidence in the stability of the
company. On 09.10.2020, he (N.V. Drapesa) and IK QBF LLC entered into brokerage services agreement No. BO - F - 11 -
0 - 00565. He transferred funds from the settlement account No. 40817810204080000716 opened in the branch of JSC
986
"Alfa - Bank" at the address: 19, Admiral Fokin St., Vladivostok. Thus, on 22.10.2022 he, being most likely at the
address: Vladivostok, Admiral Kuznetsova St., Vladivostok. Admiral Kuznetsova 78, sq. 132, Vladivostok, more
precisely he cannot say more precisely, as a long time has passed, he transferred funds in the amount of RUB 300,000
from the above mentioned settlement account to the settlement account of NSD. Also on 23.10.2020 he, being most
likely located at the address: 78, Admiral Kuznetsov Street, Vladivostok, sq. 132, he cannot say more precisely, as a
long time has passed, transferred funds in the amount of RUB 300,000 from the above - mentioned current account to
NSD's current account. Given that it was not possible to transfer an amount exceeding RUB 300,000 via mobile
banking, he went to an Alfa Bank branch and transferred RUB 3,400,000 to NSD's account. Afer that, he was sent a
package of documents required to participate in the product, and daily reports were sent to his e - mail, with positive
dynamics. For about 6 months, at the time of crediting the funds, there were no problems with IK QBF LLC. Afer
about 6 months, Builov N.O. started to contact rarely, moreover, the figures in the daily report stopped changing.
Within two weeks N.O. Builov commented on the constancy of the figures with failures in computers and technical
problems. Afer two weeks of communication with Builov N.O. he decided to withdraw part of the portfolio, which was
available for withdrawal, he asked Builov N.O. to prepare an application for withdrawal, but during the conversation
he delayed it in every possible way, motivated by technical failure, his illness and the workload of the central office,
the documents were not sent to him. Afer that, he was offered to fill in the documents himself. The form of
documents was sent to his e - mail box, he prepared it and sent it, but afer a week the money in the amount of about
600,000 roubles had not been received. Builov N.O. delayed the withdrawal of funds, each time giving different
reasons. Around May 2021, he saw an article published on the Forbs website, in which it was stated that searches were
being conducted at IK QBF LLC in connection with the failure to return the funds. He tried to contact Builov N.O., who
said that everything was fine in the company. Builov N.O. informed him that he was leaving IK QBF LLC, he was not
provided with a new agent. He called the phone number listed on the website (he does not remember the phone
number), where the office manager told him that he would be contacted. However, no one contacted him for about
two weeks, in connection with which he wrote letters to the General Director of LLC "IC QBF" and to the e - mail of LLC
"IC QBF". Also at that time he applied to the Central Bank, with a request to influence "IC QBF" LLC and return the
funds, to which he was told that they had revoked the licence of "IC QBF" LLC, and also recommended to apply to the
court, as they are not a party to the dispute. In June 2021, he was approached by Alexey Chentsov, who introduced
himself as the head of the client department of IK QBF LLC, and offered to settle the matter by waiving his claims
against IK QBF LLC and handing over the funds in the amount of RUB 5,800,000 in their accounts. He refused to do so.
Knowing that OOO "IK QBF" owned real estate, he offered to return the funds to him in the form of real estate. OOO IK
QBF offered to pay him 50% of the 5,800,000 roubles, and the other 50% was to be repaid with real estate. He did not
agree to participate in this scheme, as he was convinced of the fraudulent actions of the management of this
company. Afer that, he said that he would turn to law enforcement authorities, Alexey began to say that his money
was frozen on the accounts of IK QBF LLC, said that he was going to resign, and then stopped contacting him. In
August 2021, knowing that a criminal case was being investigated by the Investigation Department, he filed a criminal
complaint, to which he enclosed copies of documents, including a copy of the brokerage services agreement No. BO -
F - N - 0 - 00565. Also, his wife Drapeza Maria Igorevna, 12.08.1984, invested in LLC "IC QBF" in the amount of 4,000,000
rubles, who has now lef for permanent residence in Kaliningrad, where she lives at the address: 168 Gorky St., sq.
105. In the near future, he is also going to leave for permanent residence in Kaliningrad, where he will live at the same
address. He explains that he personally supervised the fulfilment of obligations under the contract, his wife learnt
about all the problems from his words. The situation with the money she deposited was the same as with his. All
documents confirming the transfer of funds, correspondence with the Central Bank, IK QBF LLC, and the agreement
were submitted with his criminal complaint. The reports were sent from the e - mail address [email protected].
Applications for withdrawal of funds and participation in products were sent to the e - mail address [email protected].
Alexey Chentsov's email address is [email protected]. Thus, the actions of the employees of IK QBF LLC
caused him material damage in the amount of 4,000,000 roubles;
- (Vol. No. 63, pp. 170 - 173)

- other documents - documents provided by N.V. Drapeza confirming his relationship with QBF Financial Group
987
- (vol. No. 63, pp. 62 - 154, vol. No. 64, pp. 2 - 239),
part 4 of article 159 of the Criminal Code of the Russian Federation against Kormilitsyn S.V.:
- another document - a statement by S.V. Kormilitsyn, in which he asks to bring to criminal responsibility
- (Vol. No. 65, pp. 9, 107 - 110)
- Kormilitsyn S.V.'s testimony, given by him as a witness and victim,

according to which, since June 2014, he was engaged in investing activities. As he had free cash, and he was
searching for additional income by investing his money. In August 2020, his friend Batoyev Anton offered to invest his
funds in QBIF LLC (INN7733673955). Since he had previous experience of investing in IPOs, he had an understanding
of this product. In addition, he was interested in the published materials regarding participation in IPO. IPO (Initial
Public Offering) is an initial public offering of companies on the stock market with subsequent circulation of securities
(shares) on the stock exchange. Having looked for information in the Internet, he found information that LLC IC "QBF"
(INN 7733673955) has 4 licences of the Central Bank of Russia, namely: licence for brokerage activities № 045 - 12805 -
100000 from 24.12.2009, licence for dealer activity No. 045 - 12816010000 dated 24.12.2009, licence for securities
management No. 045 - 12828 - 001000 dated 24.12.2009 and licence for depository activity No. 045 - 14078 - 000100
dated 08.08.2019. At the beginning of August 2020, his acquaintance Batoyev Anton provided him with contacts of a
girl, who from his words was a financial advisor of the group of companies "QBF". He wrote to the girl via messenger
"WatsApp". Afer some time, he received a call on his mobile phone 8 - 964 - 589 - 58 - 07 from a girl who introduced
herself as Natalia Chernysheva, who explained that she was a financial advisor of the group of companies "QBF".
During the telephone conversation, the financial advisor Natalia Chernysheva presented him the financial products of
the group of companies "QBF", the system of participation in IPO with increased allocation. Allocation is the
percentage of securities from the bid that an investor can count on on the day of the IPO. Financial Advisor Natalia
Chernysheva assured him that the company has a long and successful track record and has a direct access to the IPO.
Also, Natalia Chernysheva explained that investing through them will be safe, as the company has all the necessary
licences from the Central Bank of the Russian Federation to conduct such activities, also Natalia Chernysheva
informed him that the reliability of work with the company "QBF" is guaranteed by the legislation of the Russian
Federation, due to the fact that he will cooperate directly with Russian organisations, namely: with LLC IC "QBF" (INN
7733673955). Afer listening to all the arguments of the financial advisor Natalia Chernysheva, he decided to agree to
participate in the IPO through the broker "QBF". In addition, she explained that he had to sign the following
documents: application for joining, questionnaire of a registered individual, application for comprehensive service,
notification of opening an account and other documents. Afer that, he provided his personal data to the financial
advisor Natalia Chernysheva, namely: Full name, contact phone number, passport details, bank details, email address
[email protected]. On 02.09.202 at 10:09 a.m. Moscow time, Natalia Chernysheva, Financial Advisor, sent him a
package of documents to the following e - mail address: [email protected], namely: client questionnaire,
individual's questionnaire, self - certification form, individual's questionnaire No. 2, agreement on electronic
document flow, application on joining for individuals to the Brokerage Services Agreement No. BO - F - N - O - O - OO -
253 dated 02.09.2020, application on granting the status of qualified Investor for signing and for further participation
in the IPO. In the period from 10.09.2020 to 19.11.2020 he made transfers of funds from his settlement account No.
40817810900000359975 opened with JSC "Tinkoff Bank", located at: Moscow, 2nd Khutorskaya St., 38 "A", building 26,
to QBF LLC's settlement account No. 40701810700003010998 opened with NSD, located at 12 Spartakovskaya Street,
Moscow, under Brokerage Services Agreement No. BO - F - N - 0 - 00253 dated 02.09.2020, namely: 10.09.2020 in the
18.09.2020 in the amount of RUB 350,000; 30.09.2020 in the amount of RUB 200,000; 19.11.2020 in the amount of RUB
350,000, totalling RUB 2,250,000. The requisites for the transfer of funds to the company IK QBF LLC were taken by him
from the agreement signed by him. Afer depositing the funds belonging to him into the settlement account of the
company LLC IK QBF, he began to receive offers from his financial advisor, Natalia Chernysheva, to participate in
988
specific IROs. In case he agreed to participate in the IPO, the financial advisor Natalia Chernysheva sent him client
orders for the purchase of a structured product prepared for his application. These orders were signed by him and
sent to QBFin LLC's e - mail address: orders@qbfin. In total, he signed 35 orders for the purchase of structured
products (participation in the IPO) during the entire period of co - operation with QBfin LLC. Afer his investment in the
group of companies of QBF LLC, he received reports to his e - mail address in the format of an Excel - table, which
reflected the list of his transactions, the state of his investment portfolio and the balance of funds. He repeatedly
checked the values in the reports against the quotations on the stock exchange, so he had no doubts about the safety
of his funds. In May 2021, he learnt from the mass media and official publications of the Russian Ministry of Internal
Affairs that key employees of QBF Group had been detained for alleged fraud and that the Central Bank of the Russian
Federation had ordered an audit of QBF LLC. In order to preserve the funds belonging to him, in March 2021, as well as
in May 2021, he sent an order to withdraw funds in the amount of 1,067,958 roubles 68 kopecks. Thus, the amount of
RUB 150,000 was returned to his settlement account No. 40817810900000359975 opened with Tinkoff Bank JSC from
the settlement account of QBIF LLC 40701810700003010988 opened with NSD JSC on 07.12.2020; the amount of RUB
571,962.87 kopecks was returned on 19.03.2021; and the amount of RUB 353,365.04 kopecks was returned on
07.04.2021. A total of RUB 1,075,327.91 kopeck was returned to him. The instructions were not fulfilled in full, the
money invested in the company LLC IC QBF was not returned to him. According to the reports provided to him, the
money belonging to him was spent on the acquisition of IPO. However, the company cannot provide evidence of
actual participation in the IPO. No securities in his name have been registered in depositories, no documents
confirming the purchase of securities have been issued. His demand to return the money belonging to him has not
been fulfilled. In total, he deposited funds in the amount of 2,250,000 roubles with the company QBIF LLC, which were
subsequently stolen from him. He believes that he has suffered material damage in the amount of 2,250,000 roubles
and considers the amount of damage caused to be significant;
- (Vol. No. 65, pp. 12 - 16, 25 - 28)

- other documents - documents provided by S.V. Kormilitsyn confirming his relationship with QBF Financial
- (Vol. No. 65, pp. 29 - 106)
part 4 of article 159 of the Criminal Code of the Russian Federation against Podolna A.V.:
- another document - a statement by Podolna A.V., in which she asks to bring to criminal responsibility persons
- (Vol. No. 65, l.d. 125)
- The testimony of Podolna A.V., given to her as a witness and victim,

according to which, approximately in May 2020 (she cannot specify the exact date and time), she learnt from
acquaintances information about the group of companies "QBF". She was interested in the published materials
regarding participation in the IPO. Having familiarised herself with the information published in the Internet, namely
on the website of the group of companies "QBF", as well as in other sources, she found out that IPO is a primary
market with subsequent circulation of securities on the stock exchange. Before she started investing in the "QBF"
group of companies, she talked to acquaintances who had participated in IPOs through the "QBF" group of
companies, her acquaintances had financial advisors: Denis Kotelevets and Nikolay Padalko, the acquaintances had
invested through the group of companies "QBF" for a long period of time, they had a high return on invested assets,
as well as problems with withdrawal of invested funds they had no problems, in this connection, she decided to start
investing in IPO through the group of companies "QBF", and turned to the financial advisor, Denis Kotelevets (8 - 967 -
294 - 37 - 26), afer which Denis Kotelevets presented her financial products of the group of companies "QBF", the
system of participation in IPO with increased allocation. Allocation is the percentage of securities from the bid that
the client can count on on the day of the IPO sale. Denis Kotelevets, was very persuasive and persistent, inspiring her
989
confidence. On 18.11.2020 at approximately 10:00, Denis Kotelevets sent the documents for opening a brokerage
account with QBF to her email: [email protected]. Afer that she signed the received documents and sent them to
her financial advisor [email protected]. at [email protected]. In the process of signing the documents, she was in
Moscow, 13, 8th Parkovaya Street, sq. 30, and signed the documents at 16:16 hours, namely: Agreement on electronic
document flow, questionnaire of a registered individual, application on joining for individuals to the Brokerage
Services Agreement No. BO - F - N - 0 - 00830 dated 18.11.2020. Denis Kotelevets assured her that the company has a
long and successful experience of work in Russia and abroad, has direct access to IROs, all necessary licences are
available, the financial advisor Denis Kotelevets, informed her that the reliability of work with the group of companies
"QBF" is guaranteed by the legislation of the Russian Federation, due to the fact that it will cooperate directly with
Russian organisations, namely: LLC "IK "QBF" (INN 7733673955) and LLC "QBF Broker" (INN 9703003668). Moreover, in
open sources of the Internet she saw information that LLC "IC "QBF" (INN 7733673955) has 4 licences of the Central
Bank of Russia, namely: licence for brokerage activities No. 045 - 12805 - 100000 dated 24.12.12.2009, licence for
dealer activity No. 045 - 12816010000 dated 24.12.2009, licence for securities management No. 045 - 12828 - 001000
dated 24.12.2009 and licence for depository activity No. 045 - 14078 - 000100 dated 08.08.2019. 22.11.2020 from its
settlement account No. 40817810340017621257 opened in the office of PJSC Sberbank, located at: Moscow, 53,
Shcherbakovskaya str. 1, tentatively at 12:00 hours, she made a transfer of funds belonging to her to LLC IC QBF (INN
7733673955) to settlement account No. 40701810700003010998 in the amount of RUB 6,000,000. The details for the
transfer to LLC IK QBF were provided to her by Denis Kotelevets to the e - mail address: [email protected]. Afer
she made the transfer, she sent Denis Kotelevets a payment order via WhatsApp to confirm the payment, afer which
Denis Kotelevets confirmed receipt of the payment. Later, afer depositing the funds to the account of QBIF LLC, she
began to receive offers from Denis Kotelevets to participate in specific IPOs. If she agreed to participate in the IPO,
Denis Kotelevets would send her client orders for the purchase/change/cancellation of the structured product
purchase agreement in accordance with her application. She signed and sent them to the company's mail:
[email protected]. and to Denis Kotelevets' mail: [email protected]. In total, during the whole period of co -
operation with QBIF LLC, she signed 13 agreements for the purchase of structured products (participation in IPOs).
Afer she invested her funds in the group of companies of LLC "IC QBF", she started to receive reports to her e - mail
address, reports in the format of "Excel - tables", which reflected the list of her transactions, the state of the
investment portfolio and the balance of funds. She also checked the values in the reports against the quotes on the
stock exchange, so she had no doubts about the safety of her funds. Initially, the funds she transferred to the account
of the companies of IC QBF LLC were at NSD, however, throughout the entire communication Denis Kotelevets
persistently offered her to transfer the funds from NSD to the "General Agreement", as Denis Kotelevets said, to a
special account through which to participate in the IPO, so that the funds raised for the purchase of options would be
realised faster. On 14.12.2020, she signed a general agreement under brokerage services agreement No. BO - F - N - 0 -
00830 dated 18.11.2020, and transferred part of the funds in the amount of RUB 2,520,000 to the general agreement to
participate in the IPO as a security payment. There were 3,480,000 roubles lef in the account. In order to keep the
funds belonging to her, on 04.06.2021, she submitted requests for withdrawal (return) of the funds invested in the
"QBF" group of companies. The term of execution of all orders was specified till 12.07.2021. The term expired on
12.07.2021, but the funds she requested were not received on her account. So far, she has been able to withdraw the
funds in the amount of RUB 784,000 invested in the "QBF" group of companies. To date, the orders to withdraw the
remaining funds have not been executed and the funds have not been returned. At present, her demand to return the
funds belonging to her has not been fulfilled. The employees of the group of companies "QBF" cannot explain the
situation in essence. No securities in her name have been registered in the depositaries, no documents confirming the
purchase of securities have been issued. Thus, she believes that an offence, namely fraud, has been committed
against her. In addition, the company cannot provide evidence of real participation in the IRO. Her demand to return
the funds belonging to her has not been fulfilled. She deposited funds in the amount of 6,000,000 roubles with QBIF
LLC, which were subsequently stolen from her. She believes that she has suffered material damage in the amount of
6,000,000 roubles and considers the amount of damage caused to her to be significant;
- (Vol. No. 65, pp. 128 - 132, 143 - 146)
990
- other documents - documents provided by A.V. Podolna confirming her relationship with QBF Financial
- (Vol. No. 65, pp. 147 - 172)
part 4 of article 159 of the Criminal Code of the Russian Federation against Koncherova V.S.:
- another document - a statement by V.S. Koncherova, in which she asks to bring to criminal responsibility
- (Vol. No. 66, l.d. 9)
- The testimony of V.S. Koncherova, given to her as a witness and victim,

according to which, in April 2020, she found information on the Internet regarding the group of companies "QBF". She
was interested in the published materials distributed by the lawyer Zatsarinsky Dmitry in the social network
"Instagram" in the part concerning participation in the IPO. She found out that IPO is a primary market with
subsequent circulation of securities on the stock exchange. IPO (Initial Public Offering) is an initial public offering of
companies on the stock market with subsequent circulation of securities (shares) on the stock exchange. In the
network - Internet, she saw information that LLC "IC "QBF" (INN 7733673955) has 4 licences of the Central Bank of
Russia, namely: licence for brokerage activities № 045 - 12805 - 100000 from 24.12.2009, licence for dealer activity No.
045 - 12816010000 dated 24.12.2009, licence for securities management No. 045 - 12828 - 001000 dated 24.12.2009
and licence for depository activity No. 045 - 14078 - 000100 dated 08.08.2019. Having studied all the information
available on the Internet, also on the website of the group of companies "QBF", as well as in other sources, she
decided to call Zatsarinsky Dmitry on the mobile phone +7903 - 100 - 36 - 31, which belonged to the chief manager for
work with IPOs, Murashev Alexei, for advice. Her phone call was answered by a man who introduced himself as
Murashev Alexei, who explained that he was a financial advisor (hereinafer referred to as FS) of QBF Group. In the
course of the telephone conversation, Murashev Alexey presented to her the financial products of the group of
companies "QBF", the system of participation in IPO with increased allocation. Allocation - the percentage of
securities from the bid, which can count on the investor on the day of the IPO. Murashov Alexey assured her that the
company has a long and successful experience, has a direct access to IPO. Also Murashov Alexey explained that
investing through this group of companies will be safe, as the company has all necessary licences of the Central Bank
of the Russian Federation for conducting such activity, also Murashov Alexey informed her that reliability of work with
the company "QBF" is guaranteed by the legislation of the Russian Federation, in view of the fact that it will cooperate
directly with Russian organisations, namely: with LLC "IC "QBF" (INN 7733673955) and LLC "Q.Broker" (INN
9703003668). Having listened to all of Murashev Alexey's arguments, she gave her consent to participate in the IPO
through the broker "QBF". Afer giving her consent to participate in the cooperation, on 27.07.2020 at about 15 o'clock
she registered an account on the website qbfin.ru. When registering the account, she filled in the form indicated on
the website, providing her personal data: Full name, phone number, passport, SNILS, bank details, email address:
[email protected], to which the documents for signing and for participation in the IRO came. On 27.07.2020,
with the help of Murashev Alexey, she remotely signed the documents, namely: Agreement on electronic document
flow, questionnaire of a registered individual, application on joining for individuals to the Brokerage Services
Agreement No. BO - F - N - 0 - 00059 dated 27.07.2020, application on granting the status of Qualified Investor. Later,
from her settlement account No. 40817810700020375867 opened with JSC "Tinkoff Bank", located at the address:
Moscow, 2nd Khutorskaya St., 38A, page 26, she made transfers of funds belonging to her to LLC "IC QBF" (INN
7733673955) to settlement account No. 40701810201400000052 opened with JSC "Alfa - Bank", located at the address:
Moscow, Kalanchevskaya St., 27, namely: 30.07.2020 in the amount of RUB 1,190,000, 31.07.2020 in the amount of
RUB 980,000, 03.12.2020 in the amount of RUB 100,000, 03.12.2020 in the amount of RUB 50,000. In total, she
transferred 2,320,000 roubles 00 kopecks to LLC "IC QBF" (INN 7733673955). The details for the transfer were provided
to her by Murashev Aleksey, via messenger "WhatsApp". Afer depositing the funds into the account of QBIF LLC, she
began to receive offers from Murashev Alexey to participate in specific IPOs. If she agreed to participate in the IPO, the
991
financial adviser sent her client orders for the purchase of a structured product prepared for her application. She
signed them and sent them to the company's e - mail [email protected]. In total, during the entire period of co -
operation with QBF LLC, she signed 48 orders for the purchase of structured products (participation in IPOs). The
employees of QBF Group provided her with reports in Excel - table format, which reflected the list of transactions she
had made, the state of her investment portfolio and her cash balance. At the end of May 2021, she learned from the
mass media and official publications of the Ministry of Internal Affairs of Russia that criminal proceedings had been
initiated and key employees of QBF Group had been arrested for fraud. In order to preserve the funds belonging to
her, she submitted withdrawal requests for all structural products available to her and also sent an order to withdraw
funds in the amount of the free balance from the Master Agreement. The deadline for execution of all orders was
31.07.2021. Since then until now the orders have not been executed and the funds remaining on her investment
account have not been returned to her. In the period from 08.10.2020 to 25.05.2021 she managed to withdraw part of
the stolen funds in the amount of 1,284,765.62 rubles. No securities in her name were registered in depositaries, no
documents confirming the purchase of securities were issued. Thus, she believes that an offence, namely fraud, has
been committed against her. In addition, the company could not provide evidence of real participation in the IPO. Her
demand to return the money belonging to her has not been fulfilled. In total, she made a cash deposit of 2,320,000
roubles to the company QBIF LLC, which was subsequently stolen from her. She considers that she has suffered
material damage in the amount of 2,320,000 roubles, the amount of the damage caused being significant;
- (Vol. No. 66, pp. 12 - 16, 25 - 28)

- other documents - documents provided by V.S. Koncherova confirming her relationship with QBF Financial
- (Vol. No. 66, pp. 29 - 100)
part 4 of article 159 of the Criminal Code of the Russian Federation against Koreshkov V.S.:
- another document - a statement by Koreshkov V.S., in which he asks to bring to criminal responsibility
- (Vol. No. 66, l.d. 117)
- The testimony of V.S. Koreshkov, given by him as a witness and victim,

according to which, since September 2020, he has been engaged in investing activities. He had free cash, and he was
searching for additional income by investing his money. Thus, in September 2020, he found information on the
Internet regarding the QBF group of companies. As he had previously invested in IPOs, he had an understanding of the
product and was interested in the published material as it related to participating in IPOs. IPO (Initial Public Offering)
is an initial public offering of companies on the stock market with subsequent circulation of securities (shares) on the
stock exchange. Making enquiries in the Internet, he saw information that LLC IC "QBF" (INN 7733673955) has 4
licences of the Central Bank of Russia, namely: the licence for brokerage activities № 045 - 12805 - 100000 from
24.12.2009, licence for dealer activity |№ 045 - 12816010000 dated 24.12.2009, licence for securities management №
045 - 12828 - 1001000 dated 24.12.2009 and licence for depository activity № 045 - 14078 - 1000100 dated 08.08.2019.
Having studied, all available information in the network - Internet, approximately at the beginning of September 2020,
he called the phone number (8 - 495 - 988 - 98 - 21) indicated on the website of the group of companies "QBF"
https://www.qbfin.ru, and he lef a request for consultation, by registering his contacts. Afer some time, he received a
call on his mobile phone 8 - 916 - 344 - 29 - 43 from a man who introduced himself as Anton Lazarev, who explained
that he was a financial advisor of the "QBF" group of companies. During the telephone conversation, Anton Lazarev
presented him financial products of the group of companies "QBF", the system of participation in IRO with increased
allocation. Allocation - the percentage of securities from the bid, which can count on the investor on the day of the
IPO. Anton Lazarev assured him that the company has a long and successful track record and has a direct IPO. Also
Anton Lazarev explained that investing through them will be safe, as the company has all necessary licences of the
992
Central Bank of the Russian Federation for conducting such kind of activity, also Anton Lazarev informed him that
reliability of work with the company "QBF" is guaranteed by the legislation of the Russian Federation, in view of the
fact that he will cooperate directly with Russian organisations, namely: with LLC IC "QBF" (INN 7733673955). Having
listened to all the arguments of Anton Lazarev, he gave his consent to participate in the IPO through the broker "QBF".
Afer giving his consent Anton Lazarev informed that currently the online signing system is not working and that an
employee of this organisation will come to him on 9 September 2020 to fill in all the documents. On 09.09.2020 at
11:10 a.m. a representative of the company IKK LLC came to his house at the address: Moscow, 7, Fourth Lesniye
Polyany str. 1, a representative of the company LLC IC QBF arrived at his home at 11:10 a.m. on 09.09.2020, with the
help of which he signed the documents, namely: Agreement on electronic document flow, questionnaire of a
registered individual, application on joining for individuals to the Brokerage Services Agreement No. FB - 784 of
09.09.2020, application on assignment of the status of Qualified Investor. He also provided his personal data: Full
name, telephone number, passport, bank details, e - mail address: [email protected], to which documents
for signing and for participation in the IPO were sent. All correspondence took place in the messenger "WhatsApp". He
further communicated with his financial advisor from his mobile phone. Later, in the period from 11.09.2020 to
03.12.2020, he made transfers of funds from his current account No. 42301810900002639990, opened in JSC "Tinkoff
Bank", located at: Moscow, 2nd Khutorskaya St., 38 "A", page 26, to the settlement account No.
40701810700003010998 opened with NSD JSC, located at 12 Spartakovskaya Street, Moscow, under Brokerage
Services Agreement No. FB - 784 dated 109.09.2020, namely: 11.09.2020 in the amount of RUB 750,000; 25.09.2020 in
the amount of RUB 500,000; 19.10.2020 in the amount of RUB 200,000; 03.12.2020 in the amount of RUB 600,000,
totalling RUB 2,050,000. The requisites for the transfer were taken from the agreement signed by him. Afer depositing
the funds into the account of QBIF LLC, he began to receive offers from Anton Lazarev to participate in specific IPOs. If
he agreed to participate in the IPO, the financial advisor sent him client orders for the purchase of a structured
product prepared for his application. He signed them and sent them to the company's e - mail [email protected].
During the entire period of co - operation with QBIF LLC, he signed 22 orders for the purchase of structured products
(participation in IPOs). He received reports in the format of "Excel - tables", which reflected the list of transactions he
had made, the state of his investment portfolio and cash balance. In May 2021, he learnt from the media and official
publications of the Russian Ministry of Internal Affairs that key employees of QBF Group had been detained for alleged
fraud, and that the Central Bank of the Russian Federation had initiated an audit of QBF LLC. In order to retain the
funds belonging to him, he applied to sell the options held by him and to withdraw the funds in all the structured
products held by him, and on 08.06.2021, he sent a withdrawal order of RUB 148,400 and on 08.07.2021, he applied to
withdraw RUB 1,344,033. The funds in the amount of RUB 148,400 were returned to him on 09.06.2021 to his current
account opened with Tinkoff Bank JSC from the current account of QBIF LLC opened with NSD with the payment
purpose "Withdrawal under the Brokerage Services Agreement FB - 784 - 09.09.2020 Koreshkov Vasily Sergeyevich.
Also, the funds in the amount of RUB 8.70 were returned to him on 12.07.202I to his current account opened with
Tinkoff Bank JSC from the current account of QBIF LLC opened with NSD with the payment purpose "Withdrawal
under Brokerage Services Agreement No. FB - 784 - 09.09.2020 Koreshkov Vasily Sergeevich. To date, the funds
belonging to him have not been returned in full. No securities in his name have been registered in depositories, no
documents confirming the purchase of securities have been issued. In addition, the company can not provide
evidence of real participation in the IPO. His demand for the return of the funds belonging to him has not been
fulfilled. Thus, he believes that an offence, namely fraud, has been committed against him. In total, he deposited
funds in the amount of 2,050,000 roubles with the company QBIF LLC, which were subsequently stolen from him. He
believes that he has suffered material damage in the amount of 2,050,000 roubles and considers the amount of
damage caused to be significant;
- (Vol. No. 66, pp. 118 - 122, 132 - 135)

- - other documents - documents provided by V.S. Koreshkov confirming his relationship with QBF Financial
Group (Q BF Investment Company LLC) and testifying to the embezzlement of funds;
- (Vol. No. 66, pp. 136 - 178)
part 4 of article 159 of the Criminal Code of the Russian Federation against Borisov M.A.:
993
- another document - a statement by Borisov M.A., in which he asks to bring to criminal responsibility persons
- (Vol. No. 67, l.d. 8)
- The testimony of Borisov M.A., given by him as a witness and victim,

according to which, he has been engaged in investment activities for a long time, with the purpose of extracting
additional income, as he had free money. Also, he was constantly studying information related to the said activity. In
the summer of 2020 he found information about QBF group on the Internet. He was interested in the published
materials regarding participation in the IPO. He knew that IPO (Initial Public Offering) is an initial public offering of
companies on the stock market with subsequent circulation of securities (shares) on the stock exchange. Having
studied the information placed in the Internet, on the website of the group of companies "QBF", as well as in other
sources, he decided to invest his money in order to receive additional income in the group of companies LLC "IK
"QBF". Having made enquiries in the Internet, he saw the information that LLC "IC "QBF" (INN 7733673955) has 4
licences of the Central Bank of Russia, namely: the licence for brokerage activities № 045 - 12805 - 100000 from
24.12.12.2009, licence for dealer activity No. 045 - 12816010000 dated 24.12.2009, licence for securities management
No. 045 - 12828 - 001000 dated 24.12.2009 and licence for depository activity No. 045 - 14078 - 000100 dated
08.08.2019. Afer a short time (he cannot specify the exact date and time, as he does not remember), he contacted the
representatives of the company QBIF LLC by the phone number indicated on the website and lef his contacts. Later,
he was contacted by Trutnev Alexander, a representative of the group of companies of QBIF LLC, who told him in
detail about the scheme of participation in the IPO and the absence of any risks, as all the clients' money is in Russia
on Russian accounts and is not transferred to any offshore companies. Afer he agreed to participate in the co -
operation, he provided his email address: [email protected], to which the documents for signing, for participation in
the IPO, were sent. On 03.09.2021, keeping in touch with the representatives of IC "QBF", he remotely signed the
documents, namely: the general agreement on general terms and conditions of granting options to conclude
contracts, the agreement on electronic document flow, the questionnaire of the registered individual, the application
on joining for individuals to the Brokerage Services Agreement No. BO - F - N - 0 - 00263 dated 03.09.2020, the notice
on opening of the client's account and others. He would like to explain that the details for the transfer of funds to the
account of "IC QBF" LLC were provided to him by Trutnev Alexander, in the messenger "WhatsApp". Later, in the
period from 24.09.2020 to 08.12.2020 he made transfers of funds from his current account No.
40817810637004017483, opened in PJSC "VTB Bank", located at the address: Moscow, 5, Marxistskaya str, to QBIF IK's
settlement account No. 40701810700003010998 opened with NSD, located at 12 Spartakovskaya Street, Moscow,
under Brokerage Services Agreement No. BO - F - N - 0 - 00263 dated 03.09.2020, namely: 24.09.2020 in the amount of
RUB 800,000; 27.09.2020 in the amount of RUB 800,000; 28.09.2020 in the amount of RUB 900,000; 08.12.2020 in the
amount of RUB 5,000, totalling RUB 2,505,000. Afer depositing funds to the account of LLC IK QBF, he began to receive
offers to participate in specific IROs. If he agreed to participate in an IPO, his financial advisor, Trutnev Alexander, sent
him client orders for the purchase of the IPO's structured products, executed in accordance with his application. He
signed and sent them to QBIF LLC. In total, he signed 43 IPO contracts during the entire period of co - operation with
QBIF Ltd. He would like to clarify that he received Excel spreadsheet reports showing lists of his transactions, the
status of his investment portfolio and his cash balance. Between January 2021 and early April 2021, he submitted 18
orders to close transactions and withdraw funds to his current account, totalling RUB 956,974.57. The IRO positions
were closed according to the regulations, on the next business day, which was reflected in the company's reports. The
said funds were transferred to its settlement account No. 40817810637004017483 opened with PJSC "VTB Bank"
located at 5, Marxistskaya Street, Moscow. From 23.04.2021 to 08.06.2021 he submitted 25 orders to close transactions
and withdraw funds to his current account. IPO positions were closed according to the regulation on the next working
day, which was reflected in the company's reports. The funds in the amount of 1,548,025 roubles 43 kopecks were not
transferred to his current account within the time period specified by the regulations in the contract (20 working
days). At the beginning of June 2021, he learned from the mass media and official publications of the Ministry of
Internal Affairs of Russia that key employees of the QBF group of companies had been detained for fraud. No
994
securities in his name were registered in the depositories, no documents confirming the purchase of securities were
issued. His demand to return the money belonging to him was not fulfilled. In total, he deposited funds in the amount
of 2,505,0000 roubles with the company QBIF LLC, which were subsequently stolen from him. He believes that he has
suffered material damage in the amount of 2,505,000 roubles, the amount of the damage caused I assess as
significant;
- (Vol. No. 67, pp. 11 - 15, 82 - 85)

- other documents - documents provided by Borisov M.A. confirming his relationship with QBF Financial Group
- (Vol. No. 67, pp. 16 - 74, 86 - 105)
part 4 of article 159 of the Criminal Code of the Russian Federation against Tokareva A.A.:
- another document - a statement by Tokareva A.A., in which she asks to bring to criminal responsibility
- (Vol. No. 67, l.d. 119)
995

The QBF NOA Circle Scam: Eventually everything comes to light: how justice finally caught up with the masterminds behind the QBF financial scandal. Linda Athanasiadou, among others, tried to manipulate the system and evade justice, but their fraud couldn't remain hidden.

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INDICTMENT..................................................................................................................................

IN CRIMINAL CASE NO. 12001450007000902 .............................................................................22

CONVICTED IN ABSENTIA AND ON THE RUN: R.V. SHPAKOV......................................................22

CONVICTED IN ABSENTIA AND ON THE RUN: ATHANASIADOU LINDA (KOVALENKO, TORRES,

CONVICTED AND JAILED: .............................................................................................................22

IN THAT HE VLADIMIR SERGEEVICH PAKHOMOV COMMITTED THE MANAGEMENT OF A

ACCORDING TO THE CRIMINAL PLAN OF R.V. SHPAKOV, THE CRIMINAL ASSOCIATION

PAKHOMOV V.S. WAS ASSIGNED THE FOLLOWING DUTIES: ......................................................29

THE MEMBERS OF THE SEPARATE STRUCTURAL SUBDIVISION OF THE CRIMINAL

- MATYUKHIN S.A., ........................................................................................................................31

- MUNAEV Z.V. ...............................................................................................................................31

A.S. GOLUBEV ...............................................................................................................................31

ATHANASIADOU LINDA VOLUNTARILY JOINING THE CRIMINAL ASSOCIATION IN THE ROLE OF

THE MEMBERS OF THE SEPARATE STRUCTURAL SUBDIVISION OF THE CRIMINAL

THE MEMBERS OF THE SEPARATE STRUCTURAL SUBDIVISION OF THE CRIMINAL

THE CONSCIOUSNESS AND WILL OF ALL ACCOMPLICES IN THE OFFENCES ENCOMPASSED

IN ADDITION, THE PARTICIPANTS OF THE CRIMINAL ASSOCIATION DETERMINED IN ADVANCE

THUS, PAKHOMOV V.S. COMMITTED THE LEADERSHIP OF A STRUCTURAL SUBDIVISION

THE SPECIFIC CRIMINAL ACTIVITY OF THE PARTICIPANTS IN THE CRIMINAL ASSOCIATION

THUS, PAKHOMOV VLADIMIR SERGEEVICH COMMITTED FRAUD, I.E. THEFT OF OTHER

- TESTIMONY OF Z.V. MUNAYEV..................................................................................................360

- PROTOCOL OF CONFRONTATION BETWEEN THE ACCUSED MUNAYEV Z.V. AND THE

- PROTOCOL OF CONFRONTATION BETWEEN THE ACCUSED MUNAYEV Z.V. AND THE

- TESTIMONY OF E.A. ROSSIEVA, GIVEN TO HER AS A WITNESS, AS A SUSPECT, AS WELL AS IN

- THE TESTIMONY OF PAKHOMOV V.S., GIVEN BY HIM AS A WITNESS, SUSPECT, AS WELL AS

- PROTOCOL OF CONFRONTATION BETWEEN THE WITNESS PAKHOMOV V.S. AND THE

- PROTOCOL OF CONFRONTATION BETWEEN THE ACCUSED PAKHOMOV V.S. AND THE

- PROTOCOL OF CONFRONTATION BETWEEN THE ACCUSED PAKHOMOV V.S. AND THE

- TESTIMONY OF A.S. GOLUBEV, GIVEN BY HIM AS A WITNESS, SUSPECT, AS WELL AS THE

- THE TESTIMONY OF S.A. MATYUKHIN, GIVEN BY HIM AS A WITNESS, SUSPECT, AS WELL AS

- A. ABDUKADYROV'S TESTIMONY, GIVEN BY HIM AS A WITNESS,...........................................411

- R.F. AMEROV'S TESTIMONY AS A WITNESS .............................................................................413

- THE TESTIMONY OF AFANASYEVA Y.S......................................................................................417

- TESTIMONY OF BALAYAN A.S ...................................................................................................418

- THE TESTIMONY OF BASHKIROV D.A .......................................................................................418

- BELYAKOV B. E.'S TESTIMONY...................................................................................................419

- D. V. BERKUTOVA'S TESTIMONY ...............................................................................................420

- THE TESTIMONY OF BLIK S.N.,..................................................................................................421

- THE TESTIMONY OF BOLTOVA L.N.,..........................................................................................422

- TESTIMONY OF V.G. BUTKOVSKAYA .........................................................................................423

- A.F. VOZHZHOV'S TESTIMONY,.................................................................................................426

- I. A. GAVRILOVA'S TESTIMON- I. A. GAVRILOVA'S TESTIMONY ...........................................427

- THE TESTIMONY OF GADIRLI T.R.O.,.........................................................................................428

- K.V. HERTSIK'S TESTIMON K.V. HERTSIK'S TESTIMONY ...........................................................428

A.S. GOLUBEVA'S TESTIMONY....................................................................................................429

I.S. GORSHENEVA'S TESTIMONY GIVEN TO HER AS A WITNESS,..............................................430

E.A. GRABAREVA'S TESTIMONY..................................................................................................430

- M.V. DANILENKO'S TESTIMONY, ...............................................................................................431

- E.Y. DOROKHINA'S TESTIMONY ................................................................................................434

- A.V. DRACHEVA'S TESTIMONY..................................................................................................435

- TESTIMONY OF G.R. ERZIKYAN, ...............................................................................................437

- TESTIMONY OF S.R. ERMOLENKO, ...........................................................................................438

- ZAVYALOVA T.G.'S TESTIMONY .................................................................................................439

- E.G. ZOLOTOVA'S TESTIMONY ..................................................................................................440

A.V. ZYKOV'S TESTIMONY ...........................................................................................................440

IBRAHIMOV E.E.'S TESTIMONY ...................................................................................................441

- I. N. IVANOVA'S TESTIMONY ................................................................................................443

A.K. IGNATOV'S TESTIMONY GIVEN AS A WITNESS,..................................................................443

- A.V. ILYIN'S TESTIMONY GIVEN BY HIM AS A WITNESS, ..........................................................445

IOSIFOVA E.O.'S TESTIMONY AS A WITNESS, .............................................................................446