|W kroll. i 2 Ap 2018 Project Tenor — Scoping Phase Final Report Propared for The National Bank of Moldova Neus Place, 25 Faringdon Stet London E64 448 i 4 (0}20 7028-000 beolLcom Pete ond Consents (Copy 39 of 39 rH Cana, the Speaker of he Periament oft Ropu of WoléoveB Kroll. Private & Confidential Restricted Use Warning “Thi rapt was prepared by Kol at ha aque of the int fo wham ie fariahes. The Sant grees th repos and information received fom Kel ining thie reper, sre ealy condentil, may only ledored oregustery Bosas and agen wth pr appioal am Krol an ar tended aay fe the ‘vate and exclave use ofthe cent nl in conection with «busines, invesiment or ther commercial Durpoce. ny ster ure nclung for enloyment purpose, ced evluton of insurance uncerwiing Dpurpoes) i sic probed and cnt has apfead hal sich use wil zzut Any communication, ubtcaon, dacosu, dlsaminatan 2 fapteducton of his tape any gttan fs content oth ‘coreaquatal bly tony ths pate any ota parson wno othe intended saeressae of hs fpr {or te infomation consines nore, i nerpetatin a eplatens, of fr omiasos, oo etane by any such hed party oer prec thareon. To he eaten fmt prouded ots reper is based on@ reviw of publcavaabe records, such infmation, at presente, relss upon the acousey snd ‘complelness of hoe racads, which have ot Been cereboraed by Kol, Satan erin cencring ‘ancl ropatry 0: legal matters should be undertoed to be gneral observations based soley on ‘ros experiance as risk constants ané may not be relied upen as fnanci,ropulatory or logs ace, whlch Kr isnot authorized te prove. A such matrs shouldbe rvawed with apreraalyqualied Jadveor In heee arise. THIS REPORT DOES NOT CONSTITUTE A RECOMMENDATION, ENDORSEMENT, OPINION OR APPROVAL OF ANY KIND WWITH RESPECT TO ANY TRANSACTION, DECISION OR EVALUATION, AND SHOULD NOT BE RELED UPON AS SUCH UNDER ANY ‘RCUMSTANCES, Private ans Canfentia: Copy 33 of 33— Andi Cand, the Speskerof ha Partament of he Repubie ornecons 2BB) Kroll. Contents Irtoduten.nonn ene od fa Sepvatwat 6 2. Bxecute summary : oe 6 22 miantna scaler UB | w TOTAL: oom [oom — Pros 6.41 Sharoholders BS has only dlsclosed to NBM vo groups of related parties amongst its shareholders. The firsts 8 group of shareholders beneicaly owned by VlasimirJardan, as well as Jardan himslf, a Moldovan entepreneut. The olher group includes members of the Cell family. Igor Cael isthe ‘owner of @ Moldovan company named Teluri Mobialre SRL, his father Gheorghe Cale! is eran st any Company Pate and Confident: Copy 39 af 33~ Mr Anan Cand, tho Speeker of he Partaman’ of he Republe of ocove 28BB) Kroll. Project Tenor Phase | Report reported to have previously worked at the Modloven financial markets regulator, CNPF. Both r0ups appear to have held stakes in BS since atleast 2010, when come of them wore fst replstred as shareholders according to deta proved by NBM. Attough Koll has not conducted in depth research Info esch cof the shareholders and beneficiaries, information provided by NBM, supplemented by investigative research, indicates that a number of them were likely to have been acting In concert and holding shares os nominees, to mask sue benefice! Intorost. Certain have links fo lan Shor, whit there 6o not have profes which are not reflective oftheir aquisition of realy significant stakes inthe bank. Examples of information which lead to tis conclusion are highighted below: 4. Maria Gutuleae - Gutuleae acquired a 4.98% stake In BS on 15 May 2013, She has bean reporied In Moldovan media sources 95 the "head of administration’ for tlan ‘Shor. and as « ‘ropresenatve ofthe Miron Shor" foundation. * Miron Shor i¢ in ‘Sho's father. Further information hes been gained from the NBM, showing that Gutuleac is actually lan Shor's cousin, and is marred to Serglu Albet, who was appointed vice-president of UB in December 2012, and subsequently became president (ofS In December 2013, 2. Moldovan Corporate Enles - The five Moldovan companies which obiaind stakes in BS on 30 May 2013 (Olafan SRL, Tonimar SRL, Tivetpro SRL, Rominserv SRL, Veer Plus SRL) were all ncoporated tee weoks before the purchsse on 8 May 2013, Inia research of the beneficial owners of these companies found them to have low public profies. 3. Smit Pls SRL ~ this company oblainad @ stake in BS on 1 November 2019. The discloses beneficial owner, Nalala Gojira, Is Isted in official Moldovan databases 3s being the head of the operational ivsion at Chisinau alot from Novernber 2007 Natala. Gojna's positon at Chisinau airport is notable duo to lan Shor's commercial links to the aiport Chisinau airports curenty managed by Avia Invest SRL folowing the signing of # concessionary agreement with the Moldovan State Asset Agency on 30 ‘August 2013. On 11 September 2014 lan Shor was elected tothe board of Avia Invest 'SRL, at whieh point Durem! reportely aressyrentes 60% ofthe commercial space at the apt." Shor was subsequently elected chairman of Avia Invests board on 1 2 tpsennodaestcangcreunbeez8 5 arsaar/anrenar alone andre adel partcpar¢ conten rernaosla_penranrenat! ‘rive and Contdentat: Copy 3 f 38 = Mr, Arian Candy, the Speaker he Parsment of he Repub oftotiors 2AD) Kroll. Project Tenor Phase | Report November 2014, The current CEO of Ava Invest is Pets Jarcan, tis unclear fam ina researc f this individual ie related to Viadint Jordan ee Voscesay Jada, 4, Uteainian and Russian individuals - A number of Ukrainian and Russian individuals soquied stakes in BS In May 2013 each of which have extremely low puble profes thel espectvejurscetions. According to disclosure documentation provided to NBM, the fe Utcainan indviduals are registered in Nova Kakhovka, Kherson Oblast, Uraine. Nova Kakhovka is @emall ety in couthorn Ukraine with population of loss than 100.000. Two of the sharcholiers, Teena Boke and Sergi Andrictuk, are registered at cferent fats win the same building inthe cy. These profles are not relleetive of a ypea Investor, acqung eelatvely significant stakes ina Moldovan bank, al financed trough loans trom offshore entities and appearing to have opened accounts ‘at Latvjas Pasta Banka atthe sare tne 6.4.2. Funding of share acquisition in BS [As outined above, withthe exception of those shareholders dleclosed by BS as related partes, the melorty appear on ina! examination to be unrelated, However, analysis ofthe source of ‘unding used by the individuals and entiies to acquire the shares in BS provides futher indeation ‘hat a number wore in fact elated and potantally acting In concert. By way of example: ‘+The fve Moldovan companies which acquired stakes in 8S on 30 May 2013 appear to have each financed their share purchase with loans ffom offshore entities between 17 May 2013 and 22 May 2013, Al fe loans carried a 3.5% Interest rate and the fe ‘chore companies each held accounts at ABLY Bank AS in Lab. ‘+ Ancor Lux SRL and Sami Plus SRL, which acquied stakes in BS on 1 November 2018, simlaty financed their share purchases wih leans fram offshore entiosrepstred atthe sama address in Balize, each with Latvian bank accounts. ‘+The Uksainian and Russian individuals, which acquired stakes on 8 Way 2013, were Tkewiae financed by offshore companies, Both he indvduals end the offshore companies held eccounts at Latvjas Pasta Banka, Latvia. Futhermere, the loan agreements disclose to NBM show thatthe iivals have slmoet dentiel account numbers a the Latvian bank, which indcates tat they most probably opened ther accounts st the same tine ‘Pile and Condon Copy 39 58 ltr. aon Can, ho Specter ote Parlement of th Ropubic fate 2