How we identified a sanctioned individual

Client

Investment Fund

Country

Moldova

In the intricate world of corporate investments, understanding the ownership structure of a potential investment target is paramount. Our client, eyeing a prospective investment in a Moldovan agricultural company, sought our expertise to unravel the ownership structure of the entity. The task involved tracing the immediate shareholders of the company and conducting a deep dive into their backgrounds to identify any potential red flags that could pose a risk to the investment.

Challenge

The challenge was to meticulously trace and analyze the ownership structure of the Moldovan company, a task that spanned multiple jurisdictions and involved a complex web of individuals and entities. The initial screening required identifying the immediate shareholders and assessing any potential risks associated with them, including screening against sanctions lists. The investigation extended to scrutinizing a Spanish private limited company linked to the Moldovan company, a process that involved delving into corporate information and identifying connections to other individuals and entities, including a British national associated with the company.

Solution

Our solution involved a multi-faceted approach that leveraged both desk research and field investigations to unravel the complex ownership structure. The methodology encompassed:

  1. Mapping Immediate Shareholders: We initiated the process by mapping the immediate shareholders of the Moldovan company, identifying two Moldovan individuals and one Spanish private limited company.
  2. Sanctions List Screening: A crucial step in our investigation was screening the identified entities and individuals against sanctions lists to identify any initial red flags.
  3. Corporate Information Assessment: We delved into the corporate information of the Spanish company, identifying a British national as the sole director and tracing the corporate address to an apartment building in the Balearic Islands.
  4. Field Investigation: Conducting a parallel field investigation, we explored the business ties of the British national, uncovering supposed connections to a wealthy Russian family rumored to be the ultimate beneficial owners of the Spanish company.
  5. Land Registry Searches: To further substantiate our findings, we conducted searches of the Spanish land registry, eventually linking the British national to a sanctioned Russian individual through marriage, thereby identifying a significant risk factor for our client.

Through our detailed investigation, we were able to paint a comprehensive picture of the Moldovan company’s ownership structure, unveiling connections that posed a substantial risk to our client’s potential investment. Our findings, grounded in meticulous research and investigative rigor, empowered our client to approach their investment decision with a full understanding of the associated risks, ensuring an informed and cautious approach to their investment strategy.

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