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Felix Sater's New Cross Complaint - Part Three



As 2018 had come to a close, Sater's company LitCo had started arbitration because of the terminated agreement and lack of payment. Based on court records, the convoluted understanding of events leading up to the March lawsuit are as follows, in summary:

  • 2008 - Bayrock Group LLC announced partnership with Swiss Development Group (SDG), "owned and controlled by Ilyas and allegedly funded by Ablyazov and the Khrapunovs" and "through this relationship, Sater became much more involved with Ablyazov and the Khrapunovs"

  • Late 2009 - Felix Sater was finally sentenced for his role in the stock fraud scam mid-90s and it was assumed any cooperation he might have been providing the U.S. government was over (his cooperation files had been stolen from him at Bayrock and his cooperation had been alleged in a 2007 news article)

  • Late 2009 - UK issued worldwide freezing order on Ablyazov assets

  • Acting in a consultant role to Swiss Promotion Group, SPG, "Sater allegedly assisted Ablyazov and the Khrapunovs in funneling stolen funds into various U.S. investments"

  • 2013 - Sater had a falling out with the Khrapunovs in or about 2013 in connection with an investment referred to as the Tri-County Mall investment, "resulting in a lawsuit in which Sater was accused of improperly retaining funds. That suit was quickly settled, and Sater wound up with approximately $20 million in the settlement. Plaintiffs contend that the settlement money is also derived from their stolen funds."

  • Spring 2015 - Another dispute on which Sater had advised led to the filing of the Ablyazov Action. "According to the allegations in the Ablyazov Action, Triadou was seeking to recover an investment in the Flatotel (located in New York City), but when Plaintiffs learned of Triadou's attempts to recover its investment, they asserted rights over the money on the grounds that the investment money was derived from their stolen funds. By early July 2015, an interpleader action was filed in New York State Supreme Court to determine whether $21 million from the Flathotel investment should be discharged to Triadou or, alternatively, to Almaty. That action was removed to this Court in the form of the Ablyazov Action."

  • Spring 2015 - Shortly before the Ablyazov Action commenced, Sater formed Litco in order to consult with the parties in litigation and Sater's lawyer, Robert Wolf, contacted Plaintiffs to offer assistance by Litco in recovering their stolen assets. Wolf indicated Litco could provide useful information

  • June 2015 - Litco entered into Confidential Assistance Agreement (CAA) with "Kazakhstan, Almaty, BTA Bank, and Arcanum, a private investigative firm hired by plaintiffs. The CAA provided that Litco would provide information, assistance, and cooperation to Arcanum, including by identifying witnesses and locating Plaintiffs' stolen assets. In exchange, Kazakhstan, Arcanum, Almaty, and BTA Bank agreed to pay Litco a $100,000 monthly fee and give Litco 16% of the stolen assets recovered with Litco's assistance."

  • Arcanum negotiated the CAA which started June 2015 "on behalf of Kazakhstan, Almaty, and BTA Bank. Sater did not directly negotiate on Litco's behalf. Rather, Wolf negotiated the terms of the CAA with Arcanum, keeping Sater's name and connection to Litco secret. Sater testified that he wanted to hide his affiliation with Litco because, among other things, he feared that Ablyazov and the Khrapunovs had spies and would learn that he was assisting Plaintiffs. Further, 'in light of the well-known and wide spread corruption and violence in Kazakhstan, including the alleged murder of the former head of BTA [Bank] at the alleged direction of Ablyazov,' he was concerned about harm that might befall him or his family. Accordingly, Sater's name is not mentioned anywhere in the CAA, and Sater did not sign the CAA on behalf of Litco. A different individual named Kalsom Kam signed the CAA as a Director of Litco. The CAA expressly provides that Litco would not identify or produce to Arcanum any potential witness who has an ownership interest in Litco, a provision which Sater apparently believed would prevent him from becoming a witness in the Ablyazov Action."

  • Between mid-2015 and 2018, "Litco identified various witnesses with knowledge about Plaintiffs' stolen assets to assist Plaintiffs in the Ablyazov Action. Litco received approximately $2.7 million under the CAA during this period."

  • Sept 2018 thru Oct 2018 - "Sater met personally with Plaintiffs' counsel in the Ablyazov Action to provide information about which he had personal knowledge to assist them in their prosecution of that action. This led Plaintiffs to name Sater as a witness in the Ablyazov Action. At his deposition, Sater revealed that he was the owner of Litco and had received substantial sums from Plaintiffs under the CAA. Plaintiffs, claiming to have just learned that Sater owned Litco, then terminated their agreement with Litco.”) Though the Plaintiffs Kazakhs were linked to the Kazakh KGB and had been utilizing a private investigative firm, Arcanum Global, for years, the narrative was they had no idea whom they were paying all of this time

  • Litco started arbitration in accordance to the arbitration clause less than a month following the termination of the CAA

  • March 2019 - Lawsuit filed against Felix Sater alleging his involvement in laundering money for Ablyazov, stolen monies purchasing condos at Trump SoHo, as well as plans to launder Ablyazov money into Trump Tower Moscow


Between the time period of this March 2019 filing by BTA versus Felix Sater and other parties and August of 2019, there was negative media attention focusing on this lawsuit which was countering any positive media attention President Trump was receiving from the Mueller investigation finally being over. When this original lawsuit by BTA Bank against Sater was filed, there was an almost what-appeared-to-be- coordinated timing of interrelated news delivered around the same time. This new cross complaint addressed this timing stating:

"Boies Schiller’s political motives are further illustrated by the timing of their lawsuit against Sater filed in this Court, which they filed on the eve of Sater’s Congressional testimony in March 2019 to inflict maximum political damage against Sater and Trump."

One of the biggest reasons this lawsuit coming out of a bank in Kazakhstan was a serious distraction from the initial findings of the Mueller investigation was their allegation Sater was planning to launder a large portion of the Ablyazov money through Trump Tower Moscow. Within their March 2019 filing they claimed, "Among other proposed investments, Sater conspired with Ilyas to invest the Stolen Funds to develop a Trump Tower project in Russia, which Sater has claimed would have been a 'high-rise, high-end development that could make a significant amount of money.' On information and belief, this project in Russia was the proposed Trump Tower Moscow. As Sater recently stated to BuzzFeed News, '[m]y idea was to give a $50 million penthouse to Putin and charge $250 million more for the rest of the units. All the oligarchs would line up to live in the same building as Putin.'

Also noted by OptimisticCon was the timing of the Ukraine election as well as Nazarbayev resigning from power in Kazakhstan. In their recent reporting, "That suit was filed on 25 March 2019, which as noted in the January article was shortly before the first round of the Ukrainian presidential election that year. Given the strong showing of outsider candidate Volodymyr Zelensky in the pre-election polls, and the ethics woes of the Bidens and their connections in both Ukraine and Kazakhstan, the prospect of a Ukraine freed from the rule of the Biden-friendly Petro Poroshenko, who had earlier quashed the chief prosecutor’s inquiry into Burisma and its Biden ties, had to be alarming. It would have been especially so in light of Nursultan Nazarbayev’s resignation from the presidency of Kazakhstan on 20 March 2019, after nearly 20 years of oligarchic rule. It was under Nazarbayev’s tenure that so many Americans had been involved in questionable activities in Kazakhstan, including the Bidens as well as the Clintons. Changing the guard there could well result in exposure through follow-on probes. And Felix Sater was likely to have information very relevant to such a vulnerability."


However, when August 23, 2019 rolled around, Felix Sater's files were finally unsealed by the judge. The legal battle to have a public view of his pre-sentencing (PSR) letter from late 2009 had been ongoing since 2010. The unsealed PSR noted he had fully cooperated with providing information on Russian organized crime and been "crucial" to the infiltration and investigation of two international money laundering networks originating from Russia and involving Cyprus and Turkey. When Felix went on a podcast interview to answer questions when these files were finally made public, he sat down with David Corn and Michael Isikoff. They asked him if then-President Trump had been aware of Felix's work with the United States government and Felix disclosed for the first time he had sent a letter sometime in 2015 to Donald Trump disclosing details through his lawyer, Robert Wolf, of this cooperation with them over the years. Buzzfeed News also reported on these newly unsealed files and sources describing Sater's cooperation as continuing after his 2009 sentencing and going "until at least late 2017."

The fact Felix still had still been a cooperator according to FBI sources in the years well past his sentencing in 2009 was not an established public possibility when BTA Bank filed their lawsuit. It was still somewhat plausible Felix Sater could have been idiotic enough to help an oligarch and his associates being targeted by multiple governments to violate worldwide freezing orders and launder money directly into the United States not long after his 2009 sentencing, only hoping he would not be caught and finally serve the prison time he had previously avoided.

However, what BTA Bank were alleging in their earlier claims compared to this new public evidence was an actual argument Sater apparently continued to assist the US government after his sentencing and was also helping an oligarch dissident from Kazakhstan and his family whom were accused of stealing billions and were attempting to be extradited by multiple countries and being pursued by multiple private intelligence firms and investigators. And that even after all of Mueller's team's inquiry and Felix Sater being an actual confirmed long-term asset for the U.S. government, he would be openly committing money laundering crimes during a tumultuous election. This seems far, far less plausible so one would think our legacy mainstream media should have started questioning the source and potential agenda behind these allegations. However, this never happened.


Prior to the Mueller Report summaries being released by Bill Barr, Felix Sater was expected to testify publicly to the House Intelligence Committee as Michael Cohen did, per Adam Schiff's remarks to the media. His testimony was reported as delayed when the "no collusion" found came out. Afterward, it was no longer set for public testimony. Media reporting indicated a transition from public to private testimony due to his work with the DIA on "Russian matters."

"Sater was initially scheduled to testify in March, but the imminent release of special counsel Robert Mueller’s report on Russian interference in the 2016 election prompted the panel to postpone the interview.

Lawmakers had initially said the interview — which is expected to focus on the negotiations surrounding the failed Moscow real estate project — would be public. But the panel decided to make it private because the subjects are extremely sensitive and concern national security issues, including Sater’s previous work as an undercover asset for the Defense Intelligence Agency on Russia issues, said a person familiar with the matter.

A spokesman for Intelligence Committee Chairman Adam Schiff (D-Calif.) declined to comment. The Washington Post first reported Sater’s scheduled appearance." (Politico)

So again, their lawsuit was filed in March of 2019. At this point, nothing had been made public. Not Felix's 5k letter, or pre-sentencing letter which came out August 2019. Not the full Mueller Report which came out April 2019. Not the final Volume 5 of the Senate Report or any of the 53 transcripts which were finally released in 2020.

Unless there was insider information or a leak of some kind through employees of Arcanum's whom still held top security clearances, it should not have been possible for Arcanum Global, Massimov or Rakishev, to have known Felix was still cooperating for many years following his 2009 sentencing. This may have been a closely-held secret when Felix had decided to continue to assist them even without having any legal requirement to further do so. We just don't know.


Interestingly, two other things took place between BTA Bank filing their lawsuit and the public expecting a public Felix Sater testimony spectacle similar to the one unfolding in the media with Michael Cohen. Michael Cohen was asked about and testified he had also briefly been paid by BTA Bank to search for Ablyazov monies. Matthew Schwartz was quoted in February of 2019 by Forbes as confirming the payments after Cohen had admitted as much to the House Oversight Committee. It was reportedly a "social acquaintance" whom in mid-to-late 2017 had been referred to as a consultant because he "was rumored to have 'the best legal sources' and could 'assemble a winning team.'" Schwartz was also quoted as saying Cohen "did nothing of absolute value" and "BTA quickly tore up its agreement." Cohen reportedly received $300,000 over a period of two months and even "continued to demand payment after the contract was cancelled." The original contract, however, was reportedly for 12-month term and worth $1.8 million. Less than a month later, their lawsuit had been filed against Felix Sater and Sater's scheduled public testimony was delayed.


Notably, the March 2019 lawsuit filed by BTA Bank alleged Ablyazov monies being wired into a bank named FBME, Federal Bank of Middle East, a bank doing a lot of their business in Cyprus. There were no news reports found in a date search with both FBME and BTA until 2017. In an article in November of 2017, it was reported "Some of the illicit funds were wired with the alleged assistance of lawyers through accounts held at FBME. The following year OCCRP was reporting:

"Documents presented in court show that much of the money for the U.S. investments came from offshore, largely from accounts at FBME Bank, a now-defunct Tanzania-based financial institution with offices in Russia and Cyprus. The bank was sanctioned by the U.S. government in early 2016 after it was found to be involved in money laundering, terrorism financing, and arms proliferation. But the exact money trail, and how it connects with Ablyazov’s world, has so far been hidden from public view. The investigation by OCCRP and partners, however, shows for the first time that the money can be traced back to hundreds of millions connected to Ablyazov’s fraud case.

The revelations come from a set of documents first unearthed in the United Kingdom, which has been the center of the protracted global wrangle over the Kazakhstani mogul’s assets.

In 2016, a lawyer for BTA Bank — the Kazakhstani bank defrauded by Ablyazov — disclosed to a U.K. court that a private investigator had approached the bank with what he said was evidence that a Dubai-based offshore financial planner named Eesh Aggarwal had been building and running a network of offshore companies that were laundering the stolen money.

According to the lawyer, the private investigator presented documents taken by what he claimed were 'Israeli computer hackers' from Aggarwal’s computer. They revealed, he said, that Aggarwal had worked for Ablyazov’s son-in-law, Ilyas, in building and running a network of offshore companies that funneled hundreds of millions of dollars between FBME accounts."

In September 2019, the Court summarized Triadou as investing funds "embezzled from the Kazakh Entities into New York City real estate projects, including the Flatotel and the Cabrini Medical Center, with New York City real estate developer Joseph Chetrit and several of his corporate affiliates (the "Chetrit Entities") "and the money to fund these investments was "allegedly wired to escrow accounts maintained by counsel for the Chetrit Entities in the United States from accounts held by a Dubai-based private contracting entity called Telford International Limited ("Telford"), which the Individual Defendants allegedly controlled, and FBME, a Tanzanian-headquartered financial institution with operations primarily in Cyprus."

In 2014, allegedly at the direction of the Individual Defendants, Triadou allegedly sought to liquidate those assets at below-market value to attempt to prevent the Kazakh Entities from accessing the funds. Accordingly, Triadou engaged in a sham transaction with the Chetrit Entities whereby Triadou assigned its interest in the Flatotel to the Chetrit Entities in exchange for $21 million to be paid in four installments, a "fraction of the fair market value of the properties." Interestingly, this seems close to the amount Sater is reported to have kept as part of the late 2013 settlement.


From 2009 up until 2019, there were no Arcanum Global-linked companies which had registered in FARA for Kazakhstan. This changed the last month of 2019. Arcanum Global also is part of RJI Capital as well as Magellan Holdings in the UK. Here is the link to 2019 FARA filing for RJI Capital for Kazakhstan. It was filed around the same time this Intelligence Online news report in November 2019 reported RJI Capital coming to DC on Kazakhstan's behalf. (There do not appear to be any FARA filings filed by RJI prior to 2019. There are no FARA filings for Arcanum.)




When the Soviet Union fell in 1991, the country of Kazakhstan formed the KNB with ex-KGB guys. The KNB is otherwise known as the National Security Committee, or NSC. Interestingly, due to unsealed files by the Department of Justice since late 2019, we now have confirmation Felix Sater was forming a network of contacts at least by 1997 and assisting the Defense Intelligence Agency. As the Senate Report Volume 5 report published in summer of 2020 indicated, "Sater's accesses came from his continued connections to Russian individuals and criminal groups. Sater 'used his connections with several high-ranking Russian military or former military and KGB officers' as the source for the information he provided to the US government...." (p.412-13) Sater's cooperation was described in the Report as revealing "a number of connections and accesses related to high level national security information."

Related footnote referred to Loretta Lynch being questioned about Felix Sater during her nomination hearing. In early 2015, she had described Sater's assistance as "valuable and sensitive" and reminder of the fact the court had twice upheld its order to keep much of his record sealed as two lawyers in particular fought to have them unsealed.

Lynch's nomination hearings took place only a couple of months prior to Arcanum and LitcCo (Sater) signing their agreement in June of 2015 to start working together to assist BTA Bank (which was effectually Karim Massimov and Kenes Rakishev).



Felix Sater's under-oath transcript of his testimony was also released in 2020 related to the Mueller investigation and confirmed he did not stop cooperating with the U.S. government when he faced sentencing in late 2009 for his role in the 90s stock scam but instead cooperated with them "almost two decades." This falls in line with what Buzzfeed News has reported in late 2019, writing per their anonymous sources, Felix had continued to cooperate "until at least late 2017."

Part of his statement in his transcript reads as follows: "Understanding the gravity of my actions, for the better part of the next 20 years, I provided extraordinary assistance to our government involving serious matters of national security posing tremendous risk to my life and the safety of my family. My cooperation extended to the highest levels of government and implicated some of our Nation's greatest enemies whose terrorism threatened our way of life."



Ramzan Kadyrov was also linked by OCCRP reporting to Adam Delimkhanov again, whom the media in Russia has linked to several killings of Kadyrov’s enemies. The U.S. government sanctioned Delimkhanov in 2014 due to his association with Brother's Circle. They linked Rakishev and BTA Bank to Pavel Krotov's involvement with Rakishev obtaining the port asset in the White Sea. "The Russian company register shows that at least one major BTA asset — Vitino, an oil port on the White Sea in Russia’s north — was indeed returned to Rakishev’s bank with Krotov’s involvement. In 2015, the port was acquired by Vitino Management Company, which is now partially owned by BTA." They reported Rakishev turning BTA Bank into "an investment company whose main assets were its claims against Ablyazov, estimated at $6 billion" and of him "shedding its banking business." Krotov was also linked to Delimkhanov.

Notably, Robert Mueller, while still in his role as FBI Director, addressed Brother's Circle along with the Mogilevich network in a speech in 2011:

"In the past nine years, we in the FBI have shifted from a law enforcement agency to a national security service that is threat-driven and intelligence-led.

With organized crime, we are using intelligence to expand upon what we already know, from phone, travel, and financial records to extensive biographies of key players. And we are sharing this information with our partners around the world.

But we are also building a long-term strategy for dismantling these enterprises. Last year, we set up two units, called Threat Focus Cells, to target Eurasian organized crime. The first focuses on the Semion Mogilevich Organization; the second on the Brother’s Circle enterprise.

For those of you not familiar with either group, their memberships are large, their reach is global, and their scope of operations is broad, from weapons and drug trafficking to high-stakes fraud and global prostitution. If left unchecked, the resulting impact to our economy and our security will be significant. Indeed, Semion Mogilevich is on the FBI Top Ten Most Wanted List, and he will remain so until he is captured.

These Threat Focus Cells include FBI personnel from the Criminal, Cyber, Counterintelligence, and International Operations divisions. They also include our partners in the law enforcement and intelligence communities, both at home and abroad."

(In 2013, the U.S. Treasury sanctioned some gangsters and noted Brothers Circle in this way: "The Brothers’ Circle is a multi-ethnic criminal group composed of leaders and senior members of several Eurasian criminal groups largely based in countries of the former Soviet Union but extending to Europe, the Middle East, Africa, and Latin America. To date, Treasury has identified 15 individuals affiliated with the Brothers’ Circle and their associates under E.O. 13581, including their most prominent members Gafur Rakhimov and Zakhariy Kalashov. The Brothers’ Circle serves as a coordinating body for several national level criminal networks, mediating disputes between the individual criminal networks and directing global criminal activity." Obama's executive order noted "the activities of significant transnational criminal organizations ... have reached such scope and gravity that they threaten the stability of international political and economic systems. Such organizations are becoming increasingly sophisticated and dangerous to the United States; they are increasingly entrenched in the operations of foreign governments and the international financial system, thereby weakening democratic institutions, degrading the rule of law, and undermining economic markets. These organizations facilitate and aggravate violent civil conflicts and increasingly facilitate the activities of other dangerous persons.")

To make it more clear how close Rakishev is to Kadyrov, and Kadyrov is to Putin, here is additional reporting and a couple pictures. In July of 2015, Kadyrov posted on Instagram wishing Kenes a Happy Birthday, writing "We have been true friends and brothers for many years. And our friendship has nothing to do with positions and financial situation. I worked as first deputy prime minister when we first met. I made sure that Kenes Khamitovich he is a decent, deeply faithful man. He helps our people a lot, often visits me, always shares any joys and hardships with me. He is well known and respected in Chechnya. My people are called PRINCE. For charity work Kenes Rakishev was awarded the Order of Kadyrov. He is a real son of his people, a patriot of Kazakhstan. He is pleased that he supports the President of Kazakhstan, a friend of the Chechen people, Nursultan Nazarbayev. Kenes Khamitovich has close ties of friendship with prominent politicians of the world. This contributes to the successful solution of international tasks. Dear brother, I wish you eternal youth, health, prosperity. I wish prosperity to fraternal Kazakhstan!"

In 2020 there was reporting of an increasingly nervous Rakishev wanting any public reference of his ties to Kadyrov scrubbed as the State Department was moving to sanction Kadyrov using the Magnitsky Act. "According to sources at, the State Department’s statement about the collection of data on persons having relationships, including financial, with Kadyrov caused a panic in Kenesav Rakshev. He is the first to fall under the control of the State Department and also fall under sanctions. The source is called precisely Rakishev, a man promoting the interests of a friend of Kadyrov in England. Previously, he promoted Kadyrov's interests in Kazakhstan. In these photos Kadyrov and Nursultan Nazarbayev; Rakishev, Kadyrov and former director of the FSB of the Russian Federation, head of the Security Council Nikolai Patrushev." Kadyrov was on a sanctions list in December of 2017 and remained sanctioned as recently as late 2020.

All of the following was established using open source information by 2020 yet none of it was being questioned by any of the same media whom had parroted BTA Bank's claims against Felix Sater and Donald Trump without doing much digging themselves:

  • Emails and text messages confirm communications and a pipeline deal between Ukraine and Kazakhstan

  • This pipeline deal was completed at a time when Hunter Biden was on the Ukraine gas company Burisma's board and receiving a monthly payment

  • Timing of Kenes Rakishev's promotion to Chairman of BTA Bank coincided with Hunter Biden and Devon Archer's company receiving $3.5 million for a consultancy agreement and both of them joining the Burisma board

  • Rakishev is closely linked to Chechen Head Ramzan Kadyrov to the extent Kadyrov was giving Rakishev shoutouts on his birthday in 2015, only months following Massimov, Rakishev, Joe and Hunter Biden posing for a photo together

  • Rakishev of BTA Bank not only was tied to this lawsuit against Felix Sater as well as Hunter Biden, but Felix had now been confirmed as spying on Russian KGB with established links from Rakishev to Kadyrov to Delimkhanov to Putin

In early 2020, Buzzfeed News was reporting it was odd Stephan Roh, Joseph Mifsud's lawyer, "controlled dozens of offshore companies that are alleged to have ultimately belonged to Mukhtar Ablyazov." They also stated "material seen by BuzzFeed News shows that over several years, Roh and his legal and business partners were used to move assets and funds that, according to BTA Bank, ultimately belonged to Ablyazov and his close associates. During that same time, legal proceedings against Ablyazov were ongoing in the US and UK. He was also under multiple freezing orders and had been found guilty of contempt for concealing the scale of his assets." Interestingly, they also noted in 2005 Roh had purchased a "small British nuclear firm called Severnvale Nuclear Services Ltd." Somehow over a three-year period, "Severnvale Nuclear was turning over more than £24 million a year, despite having only two employees," despite the company only earning a modest "£42,000 a year" before Roh had bought it. OptimisticCon again linked this same thread through Ablyazov and Roh to Ablyazov and Arcanum's involvement in Kazakhstan with the Uranium One scandal here and here.


Records obtained by the FBI show that Rosemont Seneca Bohai — a U.S. firm tied to Hunter Biden and his longtime business partner and fellow Burisma board member Devon Archer — received regular monthly payments totaling $166,666 from Burisma starting in 2014 and continuing into 2016. A Senate report last month concluded Hunter Biden and his partner received at least $4 million in payments from the Ukraine gas company.

According to reporting by John Solomon in October of 2020, "The newly released Bobulinski text messages, along with documents obtained by Just the News under the Freedom of Information Act, add a new twist to the long-running saga. They indicate Hunter Biden's work with Burisma — and possibly part of his compensation — may have been tied to a gas deal in neighboring Kazakhstan that was struck in 2014 shortly after the vice president's son was added to Burisma's board. " (Alleged Hunter Biden text message replies to Tony Bobulinski mentioning Kazakh deal and income from Burisma)


Did BTA Bank lie in an affidavit during 2020? According to the earlier referenced New York Times reporting, "If some of London’s law firms have reaped rich rewards by defending oligarchs and former Soviet countries, they have sometimes been less successful at recovering funds for those clients. As of November 2020, BTA Bank had recovered just $45 million of the more than $6 billion it claims Mr. Ablyazov stole, its chairman said in a recent affidavit." This directly contradicts what is being claimed in this new cross-complaint:

Sater is claiming by the fall of 2018 that side-by-side work with Boies, Arcanum, and the Kazakhs resulted in their identification, freezing, and/or recovery of billions of dollars. What happened to all of the recovered money? Assuming a fee of approximately 16 percent, the lowest estimate of $50 million means an estimated identification and/or recovery of at least $312,500,000. The highest estimate of $800 million would mean identification and/or recovery of up to $5 billion dollars.

Even the aforementioned OCCRP-reported White Sea port asset Rakishev reportedly obtained was worth more than what they had stated in this affidavit as amount of monies recovered.



When Felix Sater learned Christopher's Steele 302 mentioned himself, Ablyazov, Kazakhstan, Cyprus, and a presentation which had been created by Arcanum, within around four months he had changed legal counsel to New York lawyers who had represented cases involving the Kazakhstan elite in the past. John Snyder first shows up in court to represent Felix Sater in late May 2021.

Steele 302 excerpt:

Sater's reply to a thread regarding the BTA Bank case on July 6, 2021 referred to it as hiding "the biggest crimes and intel operations against our country in a decade."

Per his new complaint, its contents had already been drafted by July and through former high-level Obama officials, shown to the Kazakhstan parties and their Boies Schiller lawyer, Matthew Schwartz. So in less than six months, Felix Sater had investigated, changed legal counsel to those with background and expertise in cases involving Kazakhstan by May, and had this complaint drafted by July.


Less than six months following the release of the Steele 302, The Bureau of Investigative Journalism published 'The Power of Money: How Autocrats Use London To Strike Foes Worldwide." Their reporting regarding Olena Tyshchenko, remember her?, stated in order to be a freed from a Moscow prison, her agreeing to turn on her client Ablyazov which prompted BTA Bank to drop charges against her was described as "a vivid illustration of how the brutal politics of authoritarian countries like Russia and Kazakhstan have spilled into England’s legal system, with lawyers and private investigators in London raking in huge fees and engaging in questionable tactics in the service of autocratic foreign governments." Below is another excerpt from the results of their investigation:

"Four out of the past six years, litigants from Russia and Kazakhstan have been involved in more civil cases in England than have any other foreigners. Authoritarian governments, or related state entities, are often pitted against wealthy tycoons who have fallen from favour and fled. Neither side elicits much pity — but both pay generous legal fees.

Filing litigation in London can bring legitimacy for claims by autocratic governments, whose own legal systems are so tainted that their decisions carry little weight outside their borders. England also offers advantages: Judges have broad latitude to accept evidence, even if it is produced by corrupt security services or compromised foreign legal systems. London’s own private intelligence firms are unregulated, largely unrestrained and sometimes willing to use borderline methods for deep-pocketed clients."

Further down they detailed, "Lawmakers in Britain are increasingly expressing alarm over Russian influence, warning in a parliamentary report last year that a growing industry of London professionals, including lawyers and private investigators, has emerged 'to service the needs” of the Russian elite.'" The lawyer, Tyshchenko, was involved in the BTA Bank case on behalf of Ablyazov. As their investigative reporting made clear, "Tyshchenko was a lawyer for a company related to Ablyazov. She had gone to Moscow in August 2013 but was grabbed from her luxury hotel near the Kremlin, tossed in prison and accused of helping Ablyazov hide assets. Russian authorities blessed the deal with Hardman’s client that set her free. She denied any wrongdoing, but the affidavit that she later provided to Hardman became evidence in a case that saw an English judge issue a freezing order against Ablyazov’s son-in-law."



FT reporting in April of 2021 highlighted how bad the Wirecard scandal was appearing in Germany, detailing how Ralf Bose, the head of Germany’s auditor watchdog, had admitted to both buying and selling Wirecard stock "while Apas was investigating Wirecard’s auditor EY." Bose was described as having run "a government agency that is normally protected from public scrutiny by stringent secrecy laws. But those laws do not apply to the Bundestag’s inquiry into Wirecard." He was fired within weeks of making this declaration during a late-night hearing. The inquiry looking into how German auditors could have not known what was going on has "expressed amazement at the scale of the Wirecard lobbying operation, with its network of former police chiefs, ministers and spymasters, and at revelations that BaFin employees traded Wirecard shares while the company was under investigation. They also expressed shock at the fanciful stories cooked up by Wirecard lawyers alleging journalists’ attempts to blackmail the company." Further down FT had noted another two special investigators being mandated, "one to probe Wirecard’s connections to the law enforcement agencies and secret services, and another to evaluate the work of its auditor, EY, which resulted in a damning report."

The fact the Wirecard scandal had -- in the previous month -- been linked to a Russian intelligence operation which was described as "carefully orchestrated" is more concerning when additional reporting by FT stated Arcanum Global was working for Wirecard to the tune of a $3.2 million dollar contract. Arcanum may have likely played a role in the efforts against FT journalists as they pursued the Wirecard story as well as having them accused of committing crimes themselves, but they may have also played a role in doing what was possible to prevent the probe into the company. Reporting months later by Intelligence Online linked BellTroX, the security company in India, Arcanum, to the Wirecard scandal also, noting "Arcanum and Belltrox have already worked on the same cases. Arcanum has long worked for Kazakhstan to track down the fallen oligarch Mukhtar Ablyazov, a case that Indian businessman Appin Security, the hacking firm founded by Rajat Khare, has also been involved in. The ties between Belltrox and Appin are numerous, with Belltrox taking over contracts targeting Ablyazov and his clan. Meanwhile, Arcanum continues to work on the case for Kazakhstan." Additional reporting of theirs detailed "Most of the contracts were overseen by Wirecard's director of operations, Jan Marsalek, who subsequently fled to the former USSR, where he has a substantial network of Russian intelligence contacts, and is now wanted by Interpol. Many of Marsalek's intelligence and PR suppliers remain unknown, since he communicated with them via Telegram messages that were subsequently erased."

Remember FBME from the earlier BTA Bank lawsuit claims against Ablyazov and then Sater for their alleged involvement in moving Ablyazov funds? Oddly, they are also linked to the Wirecard scandal involving Arcanum Global. In 2020, it was reported FBME and Wirecard had ties "via an unnamed key client." Another massive hack-for-hire operation was apparently using employees from Belltrox, according to a Citizen Lab report in 2020.

This series continues in Part 4.

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