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MT 25 March 2018

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News 3 31 August 2004 Venezuela and Iran sign a cooperation framework agreement. 2 December 2005 Venezuela and Iran sign a Memorandum of Understanding on an infrastructure project in Venezuela. The project involves the construction of houses and will be led by Stratus Group, an Iranian conglomer- ate with operations in the construction, banking and oil industries. December 2006 Stratus Group sets up a company in Iran by the name Iranian International Hous- ing Corporation (IIHC), responsible for the Venezuela project. 2 July 2007 IIHC enters into a contract with a subsidi- ary of a Venezuelan state-owned energy company (VE). The project includes the building of 7,000 housing units in ex- change for approximately $475,734,000 (€386,367,254). 2009 Stratus Group sets up the Venezuela Pro- ject Executive Committee with Ali Sadr Hasheminejad among its members. Sadr is also responsible for project finances. 2 February 2009 Sadr's father sets up Stratus Global Invest- ments, which is incorporated in St Kitts and Nevis. 8 December 2009 Sadr's father incorporates Cirrus General Trading in Dubai, the United Arab Emir- ates. 10 February 2010 IIHC nominates Cirrus to receive pro- ceeds of the Venezuela project on its be- half. 22 February 2010 Sadr's father registers Clarity Trade & Fi- nance in Switzerland and opens a tempo- rary bank account in Clarity's name at a Swiss bank (the bank is not identified in the indictment). 12 May 2010 Cirrus receives approximately €11,388,566 at its bank account in Dubai as payment for first invoice linked to the Venezuela project. 31 May 2010 Sadr opens bank accounts in the name of Clarity at another Swiss bank (this second bank is also not identified in the indict- ment). 30 July 2010 Sadr sends an email to his father inform- ing him of Clarity's US dollar and Euro accounts. The email contains documents indicating the USD account with the first Swiss bank and a US-based bank in New York (this bank is also not mentioned in the indictment) that would act as interme- diary for USD transfers. 20 October 2010 Sadr and his father set up Stratus Interna- tional Contracting, also known as Stratus Turkey or Straturk, in Istanbul Turkey, listing St Kitts and Nevis as their indi- vidual nationality and providing Dubai as a personal address. Sadr, his father and his sister owned 90% of the shares and anoth- er person owned 4%. 28 October 2010 Sadr opens a bank account in the name of Stratus Turkey at the first Swiss bank. He starts off as sole signatory on the account and will later add his father and sister. 30 December 2010 Sadr sends an email to a third co-conspir- ator (unnamed) with USD account in- formation for Stratus, including the New York-based intermediary bank. 2 February 2011 Sadr sends email to Swiss bank 1 inform- ing them he expected a money transfer of $29 million from Venezuela. 7 March 2011 Sadr sends an email to a business associ- ate informing him that "an abbreviated version" of IIHC's full name will be used in Venezuela "so that we can make our transactions a bit easier", more so that the payments will be made in USD. 9 May 2011 Business associate emails Sadr on the restructuring of Stratus International Turkey, informing him that at least five persons or legal entities are required to appear for the company so that none of the original shareholders are shown in the structure. The associate says, having one Austrian company is not sufficient and four other entities or people have to be found. The reason behind the re- structuring is to remove Iran from the equation. 6 July 2011 Sadr sends an email to a business associate informing him of a $20,692,579 transfer of funds from Venezuela with the omi- nous words "It seems like our strategy has worked so far." 17 October 2011 An email between business associates notes that IIHC will change its name to 'International Housing Company' "due to developing circumstances". The move is intended to remove reference to Iran. 24 October 2011 Another email exchange suggests the name be changed to 'International Indus- trial Housing Company', with Sadr sug- gesting the wording should be re-ordered to 'Industrial International Housing Com- pany'. 1 February 2012 Clarity wires more than $2 million of pro- ceeds from the Venezuela project directly to the US. The money is used to purchase property in California. 2 March 2014 Project committee meeting discusses how the Venezuelan subsidiary should receive "accumulated monies" for completed ac- tivities, amounting to approximately $10 million. A timeline of events Houses in Venezuela, a company in Iran and money transfers via Switzerland and Turkey THE only connection so far is the fact that the man being charged by the US authorities, Ali Sadr Hasheminejad, also owns Pilatus Bank in Malta. However, nowhere in the 34-page indictment filed by US in- vestigators is there a reference to Malta, or Malta-based companies. It has to be noted that most of the transactions probed by the Americans pre-date the existence of Pilatus Bank. But there is an overlap between the period covered by the investi- gation (2006 to May 2014) and the birth of Pilatus Bank in Malta. The Malta Financial Services Authority awarded Pilatus Bank a banking licence in January 2014. Pilatus Bank plc was registered as a company in December 2013 with an issued share capital of €10 million and Pilatus Holding Ltd as its shareholder. The holding company was regis- tered in Malta on 7 August 2013 with its shareholder being the Hong Kong-based Alpene Ltd. The Hong Kong company reg- istry does not show sharehold- ers but Hasheminejad is listed as a director, holding a St Kitts and Nevis passport. Alpene Ltd was set up on 31 August 2012. Alpene also appears as a share- holder in the Malta-based Pilatus Capital, which was registered on 22 May 2015. In all of the Malta-based Pilatus companies, Hasheminejad is list- ed as a director along with others and his place of residence is given as Washington DC, the US capi- tal. Is there a Malta connection? St Kitts and Nevis: scion of one of Iran's richest families, Hasheminejad acquired his working passport from the small Caribbean island in order to enable him to avoid unnecessary scurinty due to the US sanctions against Iran Venezuela, where Hasheminejad's family company Stratus was constructing some 7,000 housing units as part of a bilateral deal between the two countries' governments Hasheminejad set up Clarity in Zurich, and Stratus Turkey in Istanbul as subsidiaries of the family company to receive payments via a Swiss financial institution. He provided Dubai as his address Washington DC Caracas Zurich Istanbul Dubai Tehran maltatoday SUNDAY 25 MARCH 2018 'Banknotes' bearing Hasheminejad's likeness were hung outside Pilatus Bank by demonstrators on Friday night

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