LEGAL PRIVILEGED INFORMATION CONFIDENTIAL
Dear Evans,

Further to our telephone conversation and your request for me to provide insight
into the issues surrounding Lilit, I have set out my thoughts below:-

1 Lilit presented her educational credentials on multiple occasions
as having a Degree (MBA) from Harvard University in Boston, USA. She was
constantly introduced to clients and advisors by bank executives as a 'Harvard
Graduate'. For many years she has had the opportunity to correct this error but
never did She knew that she did not have a decree from Harvard and
deliberately allowed this falsehood to continue. This is an act of someone with a
dishonest personality

2 During an investigation carried out by the investigation team at FBME,
(we were under instruction of OE at the time), we had occasion to take a
statement of truth from Lilit.

 

Lilit was always too busy to write the statement, so our team offered to write the
statement for her, based on a verbal conversation. The statement was prepared
with a standard template, but was clear in its meaning i.e.

. . is a criminal offence to make a false statement and all the
above is true to the best of my knowledge and belief, and I would be prepared to
give evidence under oath and that the above is true'

Lilit was then given the opportunity to add, alter or amend anything in the
statement She responded by asking that her qualifications be removed as

I reported our suspicions regarding Lilit's qualifications to Michael Saab, but he
suggested that we were wasting time on non-important issues (During this
period and from the outset, our main point of contact and with whom we
interacted the most was Michael)

3 Sometime later, I again had a conversation with Lilit over a coffee and
diverted the conversation to the years after her separation from her husband in
Armenia Her account of dates and travel to the United States didn't correlate
with doing a Decree at Hult and at Harvard. She also did not like discussing the
issue and was very evasive I felt this was most unusual as all the people I had
met who had qualified from Harvard were very proud of theirtime there and
would always talk about it in great detail. This raised more suspicion and this
time I raised the issue with Michael but again it was not taken as an important
issue. Following my reporting of this issue to Michael, an even stranger
occurrence emerged. Michael approached Alec Leighton suggesting thatl was
pushing Lilit too hard and even sending inappropriate text messages

Having been an investigator at the most senior level for almost 35 years, it was
now clear that we were touching a nerve, it was later the same scenario with
card services. The allegation was quickly dropped when we produced all, each
and every digital communication with Lilit, but this was yet another Red Flag, we
were now certain that Lilit was hiding something significant

4 lwas present in Farid' 5 room when Farid and Lilit were on a conference
call with HL and going through the final wording for the HL public filing of the
311 I know that Lilit had read the draft many many times and I personally read
out to her, the paragraph relating to her qualifications. She became quite
aggressive and said in front of Farid, and what is your point.. I really am too
busy to talk to you and stormed out of the room'. Farid simply said that she was
stressed from all the work, which was possible, but I was certain by this time that
there was a problem with her qualifications.

5 I reported and discussed the issue with OE. It was decided due to the
seriousness of the issue and the most recent filing that QE would email Harvard.
Harvard responded with no trace of her name.

6 requested a copy of the Qualification from Lilit, who was seen
crying in her office. She claimed it was because her Father was ill and
immediately left the bank to fly to Moscow. I personally had doubts about the
story and it is possible that Lilit went to Moscow where she waited to see what
would happen regarding her qualifications or if the 'forgery would be discovered'
before returning

7 A copy of the document was scanned and sent to Harvard, who
immediately confirmed it was a forgery.

8 The shareholders were informed and all were in disbelief. They waived
from anger to compassion not really knowing what to do There was a real
concern that HL having been deliberately mislead by Lilit and already filed a false
and misleading document to FINCEN may even withdraw from the case, which
was deemed to be potentially catastrophic. I am aware that QE strongly advised
that HL be notified immediately. The shareholders wanted an explanation and it
was agreed (I was elected) that I would meet with Lilit upon her return.

I took contemporaneous notes of the meeting--

10 When I presented the allegation to Lilit, she was not surprised and at
first offered no explanation at all, she simply said, 'Ok, I will resign' My notes
record that the meeting lasted more than 2 and half hours of intense
discussions She went from cold totally implausible explanations to hysterical
crying After 2 and half hours, I considered that no further clarity could be
obtained at that point and that she was literally on the verge of collapse and 

really considered that she was a risk to herself She wanted to go home, but the
shareholders, I knew were waiting at Fadi's home.

I, _finally convinced Lilit that Fadi and Michael wanted to see her, she
was at first inconsolable and it took some time for myself and-to
convince her to go to Fadi home. I believed that facing Fadi was her biggest
challenge and this had to be done as soon as possible.

I took her to Fadi house--and first informed Fadi and Michael that
she admitted it was a forgery and she had NEVER been to Harvard. They were in
a state of shock. Both had a different attitude to her future, but I left them alone
for more than an hourtalking amongst themselves.

11 The outcome of the meeting was as follows'-
a Lilit admitted she had not been to Harvard
She accepted the Document was a forgery
She did not admit to constructing the forged

document and gave an explanation that a friend had sent it to her and she
believed that because she attended some lectures on the Harvard campus she
got a degree from Harvard. The friend that she claims to have sent it to her now
resides in India and is an unemployed IT graduate from Hult (on the same Hult
course as Lilit). The explanation is totally unrealistic and not believable

She understood that she had placed the bank and
the shareholders at risk and offered to resign or be dismissed.

12 The following day, HL were inf by Farid by telephone A few
minutes later, I had a follow up call with (HL) and explained in more detail.

13 Subsequently, it seems that the shareholders asked her to resign but
remain in post for 90 days to help with FINCEN. It was always the shareholders
intention to keep her on, but in a way to allow this to 'blow over'.

14 I met with Lilit several times after these events, she was always very
grateful to me for the way in which I had dealt with her issue. On one occasion
(date, time and notes available) I met with her in her office with my colleague
and senior investi ator Alec Lei hton. We wanted to discuss with her an issue in
Card Services.

 

However, having spent many weeks searching through the files in card services
and the Bank, we had not found a single piece of paper anywhere with his name
on it This was in itselfa 'Red Flag'.

Note-We had been

 
 
 
   

 

 

Ultimately, it was accepted that the
ut we still had no evidence of UBO for

  

promo opera Ion was
all these companies and transactions

Lilit responded by saying no problem I have a due diligence file
_and all the details from when Michael went to the US to meet him' We
were pleased by this and then discussed perhaps issuing a massive retrospective

5
SAR report. She thought it was an excellent idea as there had now been a
significant discovery which was not known about previously.

 We immediately went to Farid's office and discussed with him the facts. There
was a Due Diligence file and that we could do retrospective SAR's. I explained
several points:-

i That issuing SAR's retrospectively is exactly what FINCEN
would be expecting following an in-depth review, not doing any
looks suspicious orjust too perfect

ii MOKAS had previously not forwarded SAR's relating to
internet gambling to the US, so doing so now but not before would
be a good mitigation for the Bank

If MOKAS did not forward the SAR's to the US, again it
would be beneficial to the bank. i.e. Beneficial to issue SAR,
beneficial if Mokas forward, beneficial if they don't forward.

Farid was very pleased by this development and wanted to call HL, but decided
to call Lilit to his office first. She came almost immediately and Farid asked Lilit if
she did in fact have a due diligence file on-- She confirmed she did.
He asked "where?" She said "in the file downstairs he said "Go and get it
please" she answered "what now?" he said "yes now'. She left the room and was
gone for more than 35 minutes.

Note: We know now that duriWe went to--

 

 

and asked if he had a copy of passport.

Upon her return she produced a document that consisted ofjust a few papers.
The papers were not in a formal file.

Page one was a poorly written document in bad English which started with the
words I believe, and I can and was signed by Michael Saab and dated,
as I recall 14th November. The document described, in little detail, the visit of
Michael Saab to various addresses in the United States that apparently belonged
t_and was supposed to be a due diligence document.

Page two, was the same document with a little more detail and was unsigned.

Page three was a copy o_passport

Page four was a list of companies apparently owned by-

in the presence and hearing of Farid and Alec Leighton, said "what is this? This
is not written by Michael, who wrote this?" she said "well, its work in progress". I
said Lilit, what is going on here, this document was dated a few days ago, who
wrote this, when Michael went to the US he could not have known the names of
these companies, and there is no name of the company he visited, how can this
be a due diligence document? This is not a document that you would accept as a
due diligence, what is this?

She said Michael wrote it, look I have the email a file, butl can't show you,
because you are not allowed to see Michael's emails, I'll show it to Alec" She
showed an email on her phone to Alec Leighton.

I said "who asked you to write this document "she said 'Michael's lawyer told him
to write this"

     

This was a very bizarre meeting in which Farid was visibly embarrassed. Lilit left
the room refusing to leave the documents. We decided not to push the issue
further. There is no doubt, that the document was highly problematic and was
co--produced between Michael and Lilit something which in itself requires
clarification. The document that was sent to me by Evans Rice that relates to
the same subject, is NOT the same document that was produced to us on request
and must have been produced subsequent to the meeting described above

Even the document that has now been produced and forwarded by Lilit is
flawed. A senior executive of a bank is writing a due diligence document about a
meeting with an individual several years ago. He is claiming that at the time he
appeared to be a man of good character and a 'person the bank hed to do

He does not give the name of the businesses 

or rovide an detail of the com anies.

 

15 The fact that Lilit has or does not have a MBA from Harvard is pretty
irrelevant, but this seems to be, somewhat lost on the shareholders. The issue:
the Head of Compliance of a bank:-

   

Thoughts
16

Please feel free to Contact me with any questions or perhaps a conference call,
once you have had the time to digest the above

Kind Regards

Nigel Brawn

 

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International Investigatmns the pmaze smor